1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103
DATE: July

19, 2011 SUBJECT: Technical Support Document for Maryland ’s Adoption of Plastic Parts and

Business Machines Coating Standards /s/ FROM: Irene Shandruk, Phy sical Scientist

Office of Air Program Planning TO: File /s/ THRU: Cristina Fernandez, Associate Director

Office of Air Program Planning
A. BACKGROUND S ection 172(c)(1) of the Clean Air Act (CAA) provides that state i mplementation plans (SIPs) for nonattainment areas must include reasonabl y available control measures (RACM), including reasonabl y available control technology (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 sources of volatile organic compound (VOC ) emissions covered b y a control techniques guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of attainment. The United States Environmental Protection Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting b y the application of control technology

that is reasonably

available considering technological and economic feasibi lity .” (44 FR 53761, Sept. 17, 1979 )

. In subsequent Federal Register notices, EPA has addressed how states can mee t the RACT requirements of the CAA

. CTG s are intended to provide state and local air pollution control authorities information that should assist them in determining RACT for VOCs from various sources , including miscellaneous metal product and plastic parts surface coating operations . In developing these CTGs, EPA, among other things, evaluated the sources of VOC emissions from this industry and the available control approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recommendations for RACT for VOCs from miscellaneous metal product and plastic parts surfac e coating

. In June 1978, EPA published a CTG for controlling VOC emissions from surface coating of miscellaneous metal and plastic products (EPA

- 450/2

- 78
- 0 15 ). Th is CTG discuss es the nature2

of VOC emissions from th is industry , available control technolog ies for addressing such emissions, the costs of available co ntrol options, and other items. EPA also publi shed a national emission standard for hazardous air pollutants (NESHAP) for surface coating of miscellaneous metal parts and products surface coating (40 CFR part 63, subpart MMMM ) and a NESHAP for plastic parts and products surface coating in 2004 (40 CFR 63, subpart PPPP)

. In 2008 , after conducting a review of currentl y existing state and local VOC emiss ion reduction approaches for this industry , reviewing the 1 978 CTG and the NESHAP for th is industry , and taking into account the information that has become available since then, EPA developed a new CTG for surface coating of miscellaneous metal and plastic parts products , entitled Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (Publication No. EPA 453/R

- 0 8
- 00 3 ). Description of Miscellaneous Metal and Plastic Parts Coatings The miscellaneous metal product and plastic parts surface coatings categories under section 1 83(e) of the CAA includes the coatings that are applied to the surfaces of a varied range of metal and plastic parts and products. Such parts or products are constructed either entirel y or partially from metal or plastic. The CTG applied to manufacturers of miscellaneous metal and plastic parts that surface

- coat the parts they produce. The CTG also applies to facilities that perform surface coating of miscellaneous metal and plastic parts on a contract basis. Miscellaneous metal product and plastic par ts surface coatings serve decorative, protective, and functional purposes. Coatings protect metal parts from corrosion b y providing resistance to moisture, heat, and sometimes the outdoor elements. Plastic parts may be coated to provide color, texture, o r protection, thus improving appearance and durability , and can also function to attenuate electromagnetic interference/radio frequency interference signals, and to conceal mold lines and flaws in substrate surface. The miscellaneous metal product and pla stic parts surface coating process may be divided into three main unit operations: (1) surface preparation, (2) coating application operations, and (3) cleaning activities. These three types of activities utilize VOC

- containing compounds (i.e., coatings, thinners, and/or cleaning materials). The CTG provides control recommendations for reducing VOC emissions from the use of these activities. The VOC emissions from miscellaneous metal product and plastic parts surface coating processes result from the evaporation of the volatile components of the coatings and cleaning materials used in these operations. In most cases, VOC emissions from surface preparation, storage, handling, and waste/wastewater operations are relativel y small. EPA’s Recommended Co ntrol Options for Miscellaneous Metal and Plastic Parts Coatings EPA issued a CTG for miscellaneous metal and plastic parts c oatings in September 2008 (Publication No. EPA 453/R

- 0 8
- 00 3 ). EPA recommends that the control approaches outlined below appl y to each miscellaneous metal product and plastic parts surface coating unit at a3

facility where the total actual VOC emissions from all miscellaneous metal product and plastic parts surface coating operations, including related cleaning activities, at that fac ility are equal to or exceed 6.8 kilograms (kg) /day (15 pounds (lbs) /day), or an equivalent level of 2.7 tons per 12

- month rolling period, before consideration of controls. The Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings document recommends emission limits for various metal and plastic coatings and those emission limits that apply

to this particular State Implementation Plan (SIP) revision are as follow: Table 1. VOC Content Limits Plastic Parts Coatings Coating Ca tegory k g VOC/liter coating l bs VOC/gallon coating General One Component 0.28 2.3 General Multi Component 0.42 3.5 Electric Dissipating Coatings and Shock

- Free Coatings 0.80 6.7 Extreme Performance 0.42 (2

- pack coatings) 3.5 (2

- pack coatings) Metallic 0.42 3.5 Military Specification 0.34 (1 pack) 0.42 (2 pack) 2.8 (1 pack) 3.5 (2 pack) Mold

- Seal 0.76 6.3 Multi

- Colored Coatings 0.68 5.7 Optical Coatings 0.80 6.7 Vacuum
- Metalizing 0.80 6.7 Business Machine Coatings Primers 0.35 2.9 Topcoat 0.35 2 .9 Texture Coat 0.35 2.9 Fog Coat 0.26 2.9 Touchup and repair 0.35 2.9
B. STATE SUBMITTAL On June 22 , 2011 , Maryland Department of the Environment (MDE) submitted to EPA a SIP revision concerning the adoption of the emission limits for plastic part s and business machines coatings, part of the EPA miscellaneous metal and plastic parts coatings CTG
. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. The State of Maryland has adopt ed EPA’s CTG standards for plastic parts and business machine coating processes. These regulations are in COMAR 26.11.19, Volatile Organic Compounds from Specific Processes

. Specifically , this revision amends the existing regulation at S ection 26.11.19.07 by moving existing VOC coating standards for plastic parts and vinyl from Section 26.11.19.07 to new Section 2 6.11.19.07
- 2 , Plastic Parts and Business Machines Coating . Additionally, coating standards for plastic parts and business machines from EPA’s CTG are being adopted into COMAR 26.11.19.07

- 2. Work practice procedures for coating can be found in COMAR 26.11.19.02. Specificall y,4

requirements for cleaning activities can be found in COMAR 26.11.19.02(I) and these have previously been approved into Maryland’s SIP. The following changes are being made to COMAR 26.11.19: The title of Section 26.11.19.07 is being changed from “Paper, Fabric, Vinyl, and Other Plastic Parts” to “Paper, Fabric, Film, and Foil Coating.” Existing defini tions in section 2 6.11.19.07(A) and standards in S ection 26.11.19.07(C)(3) pertaining to plastic parts an d vinyl are being moved to new S ection 26.11.19.07

- 2. Section 26.11.19.07
- 2, entitled Plastic Parts and Business Machines Coatings, is added. The fol lowing definitions are included in Section 26.11.19.07
- 2(A) , Definitions : business machine, business machine coating, electric dissipating coating, extreme performance coating, fog coating, metallic coating, military specification coating, mold seal coatin g, multi

- colored coating, multi

component coating, one - component coating, optical coating, plastic part, plastic part coating, prime coat, shock

- free coating, standard industrial classification code (SI C code), texture coat, touch

- up and repair coat, vacuum - metalizing coatings, and vacuum metalizing process. Section 26.11.19.07
- 2(B ) , Standards for Coating Installations , includes VOC emission limits for plastic parts coating standards, business machines coating standards, and printing standards (see Tables 2
- 4)

. Section 26.11.19.07
- 2(C) , Application Methods , lists the application methods subject to this regulation. They

are: electrostatic application, high volume low pressure ( HVLP ) spray , flow coat, roller coat, dip coat including electrodeposition, brus h coat, or a coating application method capable of achieving a transfer efficiency equivalent to or better than the efficiency achieved by HVLP spraying.
Table 2. Plastic Parts Coating Standards Coating Installation Applicability (lbs of VOC per day) Po unds of VOC Per

Gallon of Coating (as applied minus water) Kilograms of VOC

Per Liter of Coating (as applied minus water) Decorative coating of other plastic parts 20 5.9 0.70 General, one component 15 2.3 0.28 General, multi component 15 3.5 0.42 Elec tric dissipating coatings and shockfree coatings 15 6.7 0.80
Extreme performance 15 3.5 0.425

Metallic 15 3.5 0.42 Military specification, one component 15 2.8 0.34 Military specification, multi component 15 3.5 0.42
Mold seal 15 6.3 0.76 Multi - color ed coatings 15 5.7 0.68 Optical coatings 15 6.7 0.80 Plastic vehicle parts 20 3.0 0.36 Vacuum - metalizing 15 6.7 0.80 Vinyl 20 3.8 0.45 Table 3. Business Machines Coating Standards Coating Installation Applicability (lbs of VOC per day) Pounds of VOC Per

Gallon of Coating (as applied minus water) Kilograms of VOC

Per Liter of Coating (as applied minus water) Prime coat 15 2.9 0.35 Topcoat 15 2.9 0.35 Texture coat 15 2.9 0.35 Fog coat 15 2.9 0.26 Touchup and repair 15 2.9 0.35 Table 4. Printing Standards Printing Installation Applicability (lbs of

VOC per day) Pounds of VOC Per Gallon of Coating (as applied minus water) Kilograms of VOC

Per Liter of Coating (as applied minus water) Plastic other than vinyl Non
- major source 5.8 0.69 Plastic ot her than vinyl Major source as

defined in COMAR 26.11.19.01B(4) 3.8 0.45 Vinyl 20 3.8 0.45
C. EPA EVALUATION MDE has adopted the standards and requirements of the CTG for a variety of plastic parts coatings and business machine coating applications and is amending the Maryland SIP to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs readil y combine with nitrogen oxides (NO x) to form ground

- level ozone. Specifically , emissions of VO Cs from plastic parts and products and business machines6

coating are expected to be reduced b y 35 percent nationally from facilities above the recommended 6.8 kg/day threshold as a result of this rulemaking , but because Maryland already has regulations in place which have reduced VOC emissions from plastic parts coating, the reduction is expected to be less than that on a national level

. Nonetheless , this revision will help Maryland attain and maintain the National Ambient Air Quality Standards (NAAQS ) for ozone.
D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION The adoption of the EPA CTG requirements for plastic parts coating s and business machines coating standards by

the State of Maryland will result in the reduction of VOC emissions from plastic parts and business machines coating s . EPA ’s approval of the SIP revision is recommended.