UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: December 20, 2011

SUBJECT: T echnical Support Document for Delaware ’s Handling, Storage, and Disposal of

V olatile Organic Compounds Emissions; Automobile a nd Light

- Duty Truck Coating Operations; Paper Coating; Coating of Flat Wood Paneling; Graphic Art Systems; and Industrial Cleaning Solvents

FROM: Gregory Becoat , Environmental Scientist /s/

Office of Air Program Planning

TO: File

THRU: Cristina Ferna ndez

, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND:

On June 20, 2011

, U.S. Environmental Protection Agency (EPA) received a revision to the Delaware State Implementation Plan (SIP) submitted by the Delaware Department of Natural

R esources and Environmental Control (DNREC) . The SIP revision updates regulations in 7 DE

Admin. Code 1124

– Control of Volatile Organic Compound (VOC) Emissions in order to implement reasonably available control technology (RACT) controls on emission sour ces covered by EPA’s control techniques guidelines (CTG). The SIP revision amends section 8.0, “Handling, Storage, and Disposal of Volatile Organic Compounds,” section 13.0, “Automobile and Light

- Duty Truck Coating Operations,” section 16.0, “Paper Coatin g,” section 23.0, “coating of flat Wood Paneling,” section 37.0, “Graphic Art Systems,” and section 45.0, “Industrial Cleaning Solvents.” The amendments are part of Delaware ’s strategy to achieve and maintain

the 8

- hour ozone national ambient air quality standard (NAAQS) throughout the S tate

. The

effective date of these revised regulations is March 11, 2011.

Section 182(b)(2) of the Clean Air Act (CAA) requires all ozone nonattainment areas, including Delaware, to update relevant regulations for RACT c ontrols and submit the regulations to EPA as SIP revisions for emission sources covered by EPA’s CTG documents issued after November 15, 1990 and prior to the area’s date of attainment. CTGs are intended to provide state and local air pollution control au thorities information that should assist them in determining RACT for

VOCs from a specific type of product or source category . In developing these CTGs, EPA, among other things, evaluated the sources of VOC emissions and the available control approaches f

or addressing these emissions, including the costs of such approaches. Based on2

available inf

ormation and data, EPA provides recommendations for RACT for VOCs

.

Section 8.0, “Handling, Storage, and Disposal of Volatile Organic Compounds,” section 13.0, “Automobile and Light

- Duty Truck Coating Operations,” section 16.0, “Paper Coating,” section 23.0, “coating of flat Wood Paneling,” section 37.0, “Graphic Art Systems,” and section 45.0, “Industrial Cleaning Solvents,” of 7 DE Admin. Code 1124

- Control of Volatile Organic Compound Emissions was originally developed in t he 1990’s based on EPA’s CTGs. From September 2006 to September 2008, EPA updated relevant CTGs affecting sections 8.0, 13.0, 16.0, 23.0, 37.0, and 45.0 in order to reflect technology devel opments and expand VOC emission

controls. As a result, DNREC revised sections 8.0, 13.0, 16.0, 23.0, 37.0, and 45.0 to reflect the new requirements in EPA’s CTGs into existing Delaware Regulation 1124.

B. STATE SUBMITTAL

Summary of the SIP Revision

Se ction 8.0

– Handling, Storage, and Disposal of Volatile Organic Compounds

Delaware’s amendments to section 8.0 add provisions to conform to the Industrial Cleaning Solvents CTG issued by EPA in September 2006 (EPA 453/R

- 06

- 001). This CTG is intended to provide Delaware with information that should assist in determining RACT for industrial cleaning solvents.

Section 8.0 was amended to add a new VOC content limit for any facility regulated under Regulation 1124 and any facility that emits at least 6.8 kil ograms/day (15 pounds/day) of VOC

before consideration of controls.

Section 8.0 also adds the foll owing definitions and terms: “Cleanup solvent,” “Electrical and electronic components,” “Flushing,” “Hand

- wiping,” “Medical device,” “Non

- manufacturing

area cleaning,” “Medical Device and Pharmaceutical Manufacturing,” “Pharmaceutical product,” “Precision optics,” “Solvent cleaning operation,” “Stripping,” “Surface preparation,” and “Surface preparation solvent.”

The SIP revision amends section 8.0 in order to: (1) establish exemptions, (2) update existing work practice standards, (3) establish control requirements, and (4) establish test methods, procedures and recordkeeping requirements based on EPA CTGs.

Section 13 .0

– Automobile and Light

- Duty Truck Coa ting Operations

Delaware’s amendments to section 13.0 add and update regulations to reflect EPA’s CTG recommendations for Automobile and Light

- Duty Truck Assembly Coatings issued in September 2008 (EPA

- 453/R

- 08

- 006). This CTG is intended to provide Dela ware with information that should assist in determining RACT for VOCs from automobile and light

- duty truck assembly3

coatings. In developing this CTG, EPA evaluated the sources of VOC emissions from the automobile and light

- duty truck assembly coating indu stry and the available control approaches for addressing these emissions. Section 13.0 was revised in order to set more stringent VOC emission limits for coating operations used in new automobile and light

- duty truck coating operations to reflect the CTG recommendation.

Section 13.0 was amended to establish applicability for each prime coat operation, each electro

deposition prime coat operation, each primer

- surfacer operation, each topcoat operation, each combined primer

- surfacer and topcoat operation, e ach final repair operation, and each miscellaneous motor vehicle materials operation. Section 13.0 also adds a transition period for existing permitted sources for every owner or operator of any automobile or light

- duty truck assembly plant. Owners or op erators must comply with all new provisions of section 13.0 on and after January 1, 2011.

Section 13.0 adds the foll owing definitions and terms: “Adhesive,” “Automobile and light

- duty truck adhesive,” “Automobile and light

- duty truck bedliner,” “Automobi le and light

- duty truck cavity wax,” “Automobile and light

- duty truck deadener,” “Automobile and light

- duty truck gasket/gasket sealing material,” “Automobile and light

- duty truck glass bonding primer,” “Automobile and light

- duty truck lubricating wax/comp ound,” “Automobile and light

- duty truck sealer,” “Automobile and light

- duty truck interior coating,” “Automobile and light

- duty truck underbody coating,” “Automobile and light

- duty truck weatherstrip adhesive,” “In

- line Repair,”
“Primer

- surfacer,” and “Pri mer

- surfacer and topcoat protocol.” The following definitions were

amended to reflect the CTG: (1) Electro

- deposition (EDP), (2) Final repair operation, (3)

Primer

- surfacer operation, (4) Solids turnover ratio (R T ), (5) Topcoat, and (6) Volume design

cap acity. The definition of “Topcoat protocol” was deleted.

The SIP revision amends section 13.0 in order to: (1) update daily

- weighted average limitation and control devices, (2) update compliance procedures for EDP prime coat operations, (3) and update t est methods, procedures and recordkeeping requirements.

Section 16 .0

– Paper Coating

Del aware’s amendments to section 16 .0 add “film and foil coating” to the regulated category in

order to reflect EPA’s CTG recommendations for Paper, Film, and Foil Coati ngs issued in September 2007 ( EPA 453/R

- 07

- 003 ). The SIP revision expands the regulated capacity from only paper coating to “paper, film, and coating.” This CTG is intended to provide Delaware with information that should assist them in determining RACT for VOCs from paper, film, and foil coatings.

The title of s ection 16 .0 was amended to add “ Film, and Foil, ” now entitled “Paper, Film, and Foil Coating.” This SIP revision applies to any paper, film, or foil coating unit. Section 16.0

was amended to a dd exemptions for any coating unit in

- line with any offset lithographic, screen, letterpress, flexographic, rotogravure, or digital printing operations. Section 16.0 also adds a4

transition period for existing permitted sources for every owner or operator of any paper coating unit. Owners or operators must comply with all new provisions of section 16.0 on and after January 1, 2011.

Section 16.0 adds the definition of “ Coating,” and updates the following definitions: (1) Paper, film, or foil coating line and (2) Paper, film, or foil coating unit.

Section 16.0 was amended to set standards by which no application of any coating on that unit with VOC content in excess of 0.40 kilogram VOC/kilogram of solid applied. In addition, for pressure sensitive tape a nd label surface coating, no application of any coating on that unit with VOC content in excess of 0.40 kilogram VOC/kilogram of solid applied.

The SIP revision amends section 16.0 in order to: (1) update daily

- weighted average limitation

and control dev ices, (2) and update recordkeeping and reporting requirements.

Section 23 .0

– Coating of Flat Wood Paneling

Del aware’s amendments to section 23 .0 add and update regulations in order to establish more stringent emission limits. EPA’s CTG for flat wood pa neling coatings was issued in September 2006 (EPA 453/R

- 06

- 004) and intended to provide Delaware with recommendations for RACT for flat wood paneling coating.

Delaware amended section 23.0 by deleting a regulation that did not require Class I hardboard

p aneling finishes, particle board used in furniture, insulation board, exterior siding, tileboard, and softwood plywood coating lines to apply to flat wood paneling coating standards.

The standards of section 23.0 were amended to add tileboard panels and e xterior sidings to the flat wood paneling product category and establish VOC emission limits. The SIP revision also establishes more stringent emission limits to previously existing flat wood paneling products: printed interior panels, natural finish pan els, and Class II finish panels. The standards require that no owner or operator of a flat wood paneling coating line subject to the regulation for flat wood paneling coating

shall allow VOC emissions in excess of the emission limits in Table 1.

Table 1. VOC Emission Limits from Flat Wood Paneling Coatings

Flat Wood Paneling Product Category VOC Content Limits in Coatings, Inks, or Adhesives Being Applied pounds/gallon (lb/g) grams/liter

( g/L ) Printed interior panels made of hardwood, plywood, or th in particleboard 2.1* 250

Natural finish hardwood plywood panels 2.1 250 Class II finishes on hardboard panels 2.1 250

Tileboard 2.1 250 Exterior siding 2.1 2505

*This limit of 2.1 lb/gal is equivalent to 5.0 lb VOC per 1,000 square feet coating area.

The SIP revision amends section 23.0 in order to: (1) add work practice standards, (2) update control devices, and (3 ) update test methods and efficiency of control systems , and recordkeeping and reporting requirements.

Section 37 .0

– Graphic Arts Syste ms

Delaware ’s amendments to section 37.0 add provisions to conform to the Flexible Package Printing CTG issued by EPA in September 2006 ( EPA 453/R

- 06

- 003 ). This CTG is intended to provide Delaware with guidance and recommendations in determining RACT for VOCs from flexible package printing facilities

.

This SIP revision applies to any packaging rotogravure, publication rotogravure, or flexographic printing press at any facility whose maximum theoretical emissions of VOCs without control devices from all p rinting presses is greater than or equal to 7.7 tons per year on and after March 11, 2011 (effective date of this SIP revision). Section 37 .0 also adds a transition period for existing permitted sources for every owner or operator of any flexible package printing facility

. Owners or operators must comply with all new provisions of section 37 .0 on and after January 1,

2011.

Section 37.0 adds the foll owing definitions and terms: “Add

- on air pollution control device (APCD),” “Flexible packaging,” and “Fl exible packaging printing.”

Section 37.0 establishes efficiency requirements for control systems to be installed on the flexible packaging printing presses. The revision requires any individual flexible packing printing press with the potential

- to

- emit b efore controls greater than 25 tons of VOC per year an overall emission reduction efficiency specified in regulations.

The SIP revision amends section 37.0 in order to update recordkeeping and reporting requirements.

Section 45 .0

– Industrial Cleaning So lvents

Delaware’s amendments to section 45.0 update the applicability for the industrial use of organic cleaning solvents based on the Industrial Cleaning Solvents CTG issued by EPA in September 2006 (EPA 453/R

- 06

- 001). This SIP revision amends the regul ation to clarify that the requirements of section 45.0 are triggered based on a limit of VOC emissions rather than cleaning solvent used.

C. EPA EVALUATION

These regulations conform to the updated CTGs issued by EPA in order to reflect technology6

devel opments and expand VOC emission controls. The revisions to the SIP will reduce VOC

emissions from industrial cleaning solvents facilities , automobile and light

- duty truck coating operations, paper, film and foil coating units, flat wood paneling products, and flexible packaging printing presses. 7 DE Admin Code 1124, s ection s 8.0, 13.0, 16.0, 23.0, 37.0, and 45.0 meet and

reflect the RACT requirements in EPA’s CTGs

.

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

Amendments to the control of VOC emissions ( 7 DE Admin. Code 1124 ) in section 8.0, “Handling, Storage, and Disposal of Volatile Organic Compounds,” section 13.0, “Automobile and Light

- Duty Truck Coating Operations,” section 16.0, “Paper Coating,” section 23.0, “coating of flat Wood Paneling,” sect ion 37.0, “Graphic Art Systems,” and section 45.0 , “Industrial Cleaning Solvents, ” adopted by the State of Delaware will result in the reduction of VOC emissions from the affected sources. The SIP revisions meet the applicable requirements of the

CAA and the applicable EPA regulations, guidance and policy and can be approved. The SIP revisions will help Delaware in attaining compliance with the 8

- hour ozone NAAQS.

EPA’s approval of the SIP revisions is recommended.