JUN () j- 2010 

MEMORANDUM 

SUBJECT: Control Technique Guidelines for Miscellaneous Metal and Plastic Part Coatings — 

Industry Request for Reconside 

FROM: Stephen D. Page, Directo 

Office of Air Quality Pla , ing and Stanydar rs((C404-04) 

TO: Chief, Air Branch 

Regions I-X 

The purpose of this memorandum is to inform EPA Regional Offices that members of the 

pleasure craft industry have contacted EPA to request changes to the Control Techniques 

Guidelines (CTG) for Miscellaneous Metal and Plastic Part Coatings (MMPPC) (EPA-453/R-08- 

0373). This memorandum serves as a reminder to EPA Regional Offices of the role that CTG 

play in the State Implementation Plans (SIP) process for ozone nonattainment areas. CTG provide 

information and recommendations for state and local air pollution control agencies to consider 

when developing rules to meet the Clean Air Act's (CAA) reasonably available control technology 

(RACT) requirements. Specifically, we reiterate that the information contained in CTG, including 

the MMPPC CTG, is provided only as guidance. The CTG do not impose any legally binding 

requirements on any entity, State and local air pollution control agencies are free to implement 

other technically-sound approaches that are consistent with the CAA and EPA's implementing 

regulations. Therefore, EPA does not intend to revise the MMPPC CTG. Instead, EPA is 

recommending that the pleasure craft industry work together with state agencies in the RACT rule 

development process for MMPPC to assess what is reasonable for the specific sources regulated 

under each state's rules. EPA will evaluate the state-developed RACT rules and determine through 

notice and comment rulemaking in the SIP approval process, whether the submitted rules meet the 

RACT requirements of the CAA and EPA's regulations. 

BACKGROUND 

The MMPPC CTG were published on October 7, 2008 (73 FR 58486). On September 14, 

2009, EPA was contacted by the pleasure craft industry with a request for EPA to reconsider some 

of the emission limits for volatile organic compounds (VOC) recommended in the MMPPC CTG. 

In its letter to EPA, industry asserted that three of the emission limits for VOC, recommended in 

the MMPPC CTG for pleasure craft, were too low considering the performance requirements of 

pleasure craft coatings, and that overall, the VOC emission limits recommended in the MMPPC 
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CTG did not represent RACT for the national pleasure craft coatings industry. To get further 

clarification of the issues, EPA held an industry conference call and spoke with individual industry 

members on several other occasions. The pleasure craft industry presented what they deemed to 

be technological and feasibility challenges to meeting the VOC emission limits recommended in 

the MMPPC CTG. 

Table 2 of the MMPPC CTG recommends the following VOC content limits (expressed in 

terms of mass of VOC per volume of coating, excluding water and exempt compounds, as applied) 

for surface coating of pleasure craft: 

Table 2. Pleasure Craft Surface Coating VOC Content Limits 

Extreme High Gloss Topcoat 0.49 4.1 

High Gloss Topcoat 0.42 3.5 

Pretreatment Wash Primers 0.78 6.5 

Finish Primer/Surfacer 0.42 3.5 

High Build Primer Surfacer 0.34 2.8 

Aluminum Substrate Antifoulant Coating 0.56 4.7 

Other Substrate Antifoulant Coating 0.33 2.8 

All other pleasure craft surface coatings for metal 

or plastic 

0.42 3.5 

Also, the MMPPC CTG provide an option to meet alternate emission rate limits based on lowVOC coatings and add-on controls. Table 10 of the MMPPC CTG recommends the following 

emission rate limits for pleasure craft operations: 

Table 10. Pleasure Craft Surface Coating VOC Emission Rate Limits 

(VOC per Volume Solids) 

Extreme High Gloss Topcoat 1,10 9.2 

High Gloss Topcoat 0.80 6.7 

Pretreatment Wash Primers 6.67 55.6 

Finish Primer/Surfacer 0.80 6.7 

High Build Primer Surfacer 0.55 4.6 

Aluminum Substrate Antifoulant Coating 1.53 12.8 

Other Substrate Antifoulant Coating 0.53 4.4 

All other pleasure craft surface coatings for metal 

or plastic 

0.80 6.7 

The three pleasure craft categories that industry requested EPA to reconsider were extreme gloss, 

high gloss and antifoulant coatings. Industry urged EPA to revise the MMPPC CTG to include an 

averaging approach as a compliance option to allow pleasure craft coating facilities to use a 

combination of high and low VOC-containing products as long as the average value was kept 
3 

below a level specified by EPA. In summary, the pleasure craft industry suggested that the CTG 

be revised to include (one or all of) the following measures: 

1, Regulate VOC emissions from facilities using pleasure craft coatings by including an 

averaging approach as a compliance option. If this is not deemed possible, then points 2 and 3 

should apply. 

2. Amend the MMPPC CTG "Finish Primer/Surfacer" VOC limit from 420g/L to 600g/L for 

a four-year interim period to allow coating manufacturers and users sufficient time to develop and 

implement compliant coatings. 

3. Make permanent changes to the MMPPC CTG with immediate and permanent effects, as 

follows: 

• Add an additional specialty category of "Antifouling Sealer/Tie Coat" with VOC 

limit of 420g/L to align the MMPPC CTG with the International Maritime Organization's 

International Convention on the Control of Harmful Antifouling Systems on Ships; 

%ating" 

Change the VOC emission limits in the category, "Other Substrate Antifoulant 

 from 330g/L to 400g/L; 

• Change the VOC emission limits in the category, "Extreme High Gloss" from 420 

g/L to 600 g/L, reflecting the very specialized nature of the coatings in this category; and 

• Revise the coating category definition of "Extreme High Gloss Topcoat" to read: 

"Extrenze high gloss coating fneans any coating which achieves greater than 90 peNcent 

reflectance on a 60° fneter when tested by ASTMMethod D 523-89. " 

4. Make the provisions and VOC limits in the pleasure craft categories of the MMPPC CTG 

consistent with the requirements of the planned revision to the Shipbuilding MACT Standard. 

OAQPS RECOMMENDATION 

After careful evaluation of the issues raised by the pleasure craft industry, OAQPS is 

recommending that the pleasure craft industry work with state agencies during their RACT rule 

development process to assess what is reasonable for the specific sources regulated because the 

CTG impose no legally binding requirements on any entity, including pleasure craft coating 

facilities. CAA Section 172(c)(1) provides that SIPs for nonattainment areas must include 

"reasonably available control measures" (RACM), including RACT, for sources of emissions. 

Section 182(b)(2)(A) provides that for certain nonattainment areas, states must revise their SIPs to 

include RACT for each category of VOC sources covered by a CTG document issued between 

November 15, 1990, and the date of attainment. The CTG are intended to provide state and local 

air pollution control authorities with information to assist them in determining RACT for VOC. 

Based on available information and data, EPA has provided recommendations for RACT 

for MMPPC operations, including pleasure craft coating operations, in the MMPPC CTG. States 

can use the recommendations from the MMPPC CTG to inform their own determination as to 

what constitutes RACT for VOC for pleasure craft coating operations in their particular ozone 

nonattainment areas. 
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Regardless of whether a state chooses to implement the recommendations contained in the 

MMPPC CTG through state rules, or to issue state rules that adopt different approaches, states 

must submit their R.ACT rules to EPA for review and approval as part of the SIP process. EPA 

will evaluate the state's RACT rules and determine, through notice and comment rulemaking in 

the SIP approval process, whether the submitted rules meet the RACT requirements of the CAA 

and EPA's regulations. If a state proposes to adopt any of the recommendations in the MMPPC 

CTG into its state RACT rules, interested parties can comment on and raise objections about the 

application of any specific RACT recommendation in the MMPPC CTG to a particular situation 

during the development of the state rules and EPA's SIP approval process. 

Should you have further questions, please contact Kaye Whitfield of my staff at 919-541- 

2509 or whitfield.kaye@epa.gov , 
OAR-10-000-7927 

OAQPS/SPPD/NRCG:KWhitfield/jrogers(x 14487):RTP/E 143- 

03/042310/F:JRoger08/KWhitfield/ OAR100007927MMPPC Response Steve Page — Kaye 

20Mayl0.doc 

Coordinated with AQPD.