UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: July 23, 2014

SUBJECT: Technical Support Document for Allegheny County’s Adoption of Control

Techniques Guidelines for Miscellaneous Metal and/or Plasti c Parts Surface Coating Processes; Automobile and Light

- Duty Truck Assembly Coatings; Miscellaneous Industrial Adhesives, and Fiberglass Boat Manufacturing Materials

for Control of Volatile Organic Compound Emissions

/s/

FROM: Irene Shandruk, Physical Scie ntist

Office of Air Program Planning

TO: File

/s/

THRU: Marilyn Powers

, Acting Associate Director

Office of Air Program Planning

A. BACKGROUND

S ection 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (SIPs)

for nonatta inment areas must include reasonably available control measures (RACM), including reasonably available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States must revise their SIPs t o include RACT for

sources of volatile organic compound ( VOC ) emissions covered by 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 by the application of control technology that is reasonably available considering technological and economic feas i bility.” (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 VO Cs from various sources, including miscellaneous metal and plastic parts surface coatings; automobile and light

- duty truck assembly coatings; miscellaneous industrial adhesives; and fiberglass boat manufacturing materials

. In developing these CTGs, EPA, a mong 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 provides2

recommendations for RACT for VOCs from miscellaneous metal and plastic parts surface coatings; automobile and light

- duty truck assembly coatings; miscellaneous industrial adhesives; and fiberglass boat manufacturing materials

.

In 197 7 and 197 8 , EPA published CTGs for mi scellaneous metal and plastic parts surface coatings

, automobile and light

- duty truck assembly coatings , miscellaneous industrial adhesives, and fiberglass boat manufacturing materials. A fter reviewing the 1977 /1978 CTGs for these

industries

, conducting a review of currently existing state and local VOC emission reduction approaches for these industries, and taking into account any information that has become available since then, EPA deve loped new CTGs entitled Control Techniques Guidelines for

Miscellane ous Metal and Plastic Parts Coatings (Publication No. EPA 453/R

- 0 8

- 003 ; September 200 8 ); Control Techniques Guidelines for Automobile and Light

- duty Assembly Coatings (Publication No. EPA 453/R

- 0 8

- 00 6 ; September 200 8 ); Control Techniques Guidelines for Mis cellaneous Industrial Adhesives (Publication No. EPA 453/R

- 0 8

- 005; Sep tember 2008 ); Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (Publication No.

EPA 453/R

- 0 8

- 004 ; September 2008 ).

Description of M iscellaneous Metal and Plasti c Parts Surface Coatings

The miscellaneous metal product and plastic parts surface coatings categories under section 183(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 entirely or partially from metal or plastic. These miscellaneous metal products and plastic parts include, but are not limited to, metal and plastic components of the following types of products as well as the produ cts themselves: fabricated metal products, molded plastic parts, small and large farm machinery, commercial and industrial machinery and equipment, automotive or transportation equipment, interior or exterior automotive parts, construction equipment, moto r vehicle accessories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational boats), extruded aluminum structural components, railroad cars, heavier vehicles, lawn and garden equipment, business machines, laboratory and med ical equipment, electronic equipment, steel drums, metal pipes, and numerous other industrial and household products. VOC emissions

from miscellaneous metal product and plastic parts surface coating processes result from the evaporation of the components o f the coatings and cleaning materials.

EPA’s Recommended Control Options for M iscellaneous Metal and Plastic Parts Surface Coatings

Recommendations for controlling VOC emissions from miscellaneous metal product and plastic parts surface coatings are ou tlined in the CTG , which was issued in 2008

. Three alternatives are recommended: (1) emission limits that can be achieved through the use of low

- VOC coatings ; (2) equivalent emission limits that can be achieved through the use of low

- VOC coatings or a

co mbination of coatings and add

- on controls; and (3) an overall control efficiency of 90 percent

for add

- on controls.

A. Recommended Option 1 for Reducing Coating Emissions: VOC Content Limits Based on

Low

- VOC Coatings3

EPA recommended separate sets of emiss ion limits for metal parts coatings, plastic parts

c oatings, automotive/transportation and business machine plastic parts, and pleasure craft coatings. For the metal parts coatings, EPA recommended separate emission limits for baked

and air

- dried coatings

. Provided in the following five tables are the recommended emission limits expressed in terms of mass of VOC per volume of coating (excluding water and exempt compounds, as applied).

Table 1

. Metal Parts and Products VOC Content Limits (kilogram s per l iter or kg/l and pounds per gallon or lb/gal) Coating Category Air Dried Baked kg VOC/l Coating lb VOC/ gal

Coating kg VOC/l

Coating lb VOC/ gal

Coating General One Component 0.34 2.8 0.28 2.3

General Multi

- Component 0.34 2.8 0.28 2.3 Camouflage 0.42 3.5 0.42 3.5

Electric

- Insulating Varnish 0.42 3.5 0.42 3.5 Etching Filler 0.42 3.5 0.42 3.5 Extreme High

- Gloss 0.42 3.5 0.36 3.0

Extreme Performance 0.42 3.5 0.36 3.0

Heat

- Resistant 0.42 3.5 0.36 3.0 High Performance Architectural 0.74 6.2 0.74 6.2 High Temperature 0.42 3.5 0.42 3.5

Metallic 0.42 3.5 0.42 3.5 Military Specification 0.34 2.8 0.28 2.3

Mold

- Seal 0.42 3.5 0.42 3.5 Pan Backing 0.42 3.5 0.42 3.5

Prefabricated Architectural

Multi

- Component 0.42 3.5 0.28 2.3

Prefabricated Architectural One Component 0.42 3.5 0.28 2.3

Pretreatment 0.42 3.5 0.42 3.5 Repair and Touch

- Up 0.42 3.5 0.36 3.0

Silicone Release 0.42 3.5 0.42 3.5

Solar

- Absorbent 0.42 3.5 0.36 3.0

Vacuum

- Metalizing 0.42 3.5 0.42 3.5 Drum Coating, New, Exterior 0.34 2.8 0.34 2 .8 Drum Coating, New, Interior 0.42 3.5 0.42 3.5 Drum Coating, Reconditioned,

Exterior 0.42 3.5 0.42 3.5

Drum Coating, Reconditioned,

Interior 0.50 4.2 0.50 4.24

Table 2. Plastic Parts and Products VOC Content Limits

Coating Category kg VOC/l Coat ing lb VOC/ gal Coating General One Component 0.28 2.3

General Multi

- Component 0.42 3.5 Electric Dissipating and Shock

- Free 0.80 6.7 Extreme Performance (2

- pack coatings) 0.42 3.5

Metallic 0.42 3.5 Military Specification (1

- pack coatings) 0.34 2.8

M ilitary Specification (2

- pack coatings) 0.42 3.5

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

Table 3. Automotive / Transportation and Business Machine Plastic Parts VOC Content Limits

Coatin g Category kg VOC/l Coating lb VOC/ gal Coating

Automotive/Transportation Coatings* I. High Bake

– Interior and Exterior Parts

Flexible Primer 0.54 4.5

Non

- Flexible Primer 0.42 3.5

Basecoat 0.52 4.3

Clearcoat 0.48 4.0

Non

- Basecoat/Clearcoat 0.52 4. 3

II. Low Bake/Air Dried

– Exterior Parts

Primer 0.58 4.8

Basecoat 0.60 5.0

Clearcoat 0.54 4.5

Non

- Basecoat/Clearcoat 0.60 5.0

III. Low Bake/Air Dried

– Interior Parts 0.60 5.0

IV. Touch

- Up and Repair 0.62 5.2 Business Machine Coating

I. Prime rs 0.35 2.9 II. Topcoat 0.35 2.9

III. Texture Coat 0.35 2.9 IV. Fog Coat 0.26 2.2

V. Touch

- Up and Repair 0.35 2.9 *For red, yellow, and black automotive coatings, except touch

- up and repair coatings, the limit is determined by multiplying the appro priate limit in this section of the table by 1.15.5

Table 4. Pleasure Craft Surface Coating VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating 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 0.56 4.7

Other Substrate Antifoulant 0.33 2.8 All Other Pleasure Craft Surface Coatings

for Metal or Plastic 0.42 3.5

Table 5. Motor Vehicle Materials VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating Motor Vehicle Cavity Wax 0.65 5.4

Motor Vehicle Sealer 0.65 5.4

Motor Vehicle Deadener 0.65 5.4 Motor Vehicle Gasket/Gasket Sealing

Materials 0.20 1.7

Motor Ve hicle Underbody 0.65 5.4

Motor Vehicle Truck Interior 0.65 5.4

Motor Vehicle Bedliner 0.20 1.7 Motor Vehicle Lubricating Wax/Compound 0.70 5.8

B. Recommended Option 2 for Reducing Coating VOC Emissions: Emission Rate Limits

Based on Low

- VOC Coatings and Add

- on Controls

- VOC per Volume Solids

Option 2 is intended for facilities that use a combination of low

- VOC coatings and add

- on control equipment on a coating unit. Using an assumed VOC density of 7.36 pounds per gallon, the equivalent limits in terms of mass of VOC per volume of solids, as applied, are provided in the following three tables.

Table 6

. Metal Parts and Products VOC Content Limits Coating Category Air Dried Baked kg VOC/l Coating lb VOC/ gal

Coating kg VOC/l

Coating lb VOC/ gal

Coati ng General One Component 0.54 4.52 0.40 3.35

General Multi

- Component 0.54 4.52 0.40 3.35 Camouflage 0.80 6.67 0.80 6.67

Electric

- Insulating Varnish 0.80 6.67 0.80 6.67 Etching Filler 0.80 6.67 0.80 6.67 Extreme High

- Gloss 0.80 6.67 0.61 5.066

Extreme Performance 0.80 6.67 0.61 5.06

Heat

- Resistant 0.80 6.67 0.61 5.06 High Performance Architectural 4.56 38.0 4.56 38.0 High Temperature 0.80 6.67 0.80 6.67

Metallic 0.80 6.67 0.80 6.67 Military Specification 0.54 4.52 0.70 3.35

Mold

- Seal 0.80 6.67 0. 80 6.67 Pan Backing 0.80 6.67 0.80 6.67

Prefabricated Architectural

Multi

- Component 0.80 6.67 0.40 3.35

Prefabricated Architectural One Component 0.80 6.67 0.40 3.35

Pretreatment 0.80 6.67 0.80 6.67

Silicone Release 0.80 6.67 0.80 6.67

Solar

- Absorben t 0.80 6.67 0.61 5.06

Vacuum

- Metalizing 0.80 6.67 0.80 6.67 Drum Coating, New, Exterior 0.54 4.52 0.54 4.52 Drum Coating, New, Interior 0.80 6.67 0.80 6.67 Drum Coating, Reconditioned,

Exterior 0.80 6.67 0.80 6.67

Drum Coating, Reconditioned,

Interior 1.17 9.78 1.17 9.78

Table 7. Plastic Parts and Products VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating General One Component 0.40 3.35

General Multi

- Component 0.80 6.67 Electric Dissipating and Shock

- Free 8.96 74.7

Extreme Performance (2

- pack coatings) 0.80 6.67

Metallic 0.80 6.67 Military Specification (1

- pack coatings) 0.54 4.52 Military Specification (2

- pack coatings) 0.80 6.67

Mold

- Seal 5.24 43.7

Multi

- colored Coatings 3.04 25.3 Optical Coatings 8.96 74.7

Vacuum

- Metalizing 8.96 74.7

Table 8. Automotive/Transportation and Business Machine Plastic Parts VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

Automotive/Transportation Coatings* I. High Bake

– Interior and Exterior Parts

Flexib le Primer 1.39 11.58

Non

- Flexible Primer 0.80 6.67

Basecoat 1.24 10.34

Clearcoat 1.05 8.767

Non

- Basecoat/Clearcoat 1.24 10.34 II. Low Bake/Air Dried Coatings

– Exterior Parts

Primer 1.66 13.80

Basecoat 1.87 15.59

Clearcoat 1.39 11.58

Non

- Basecoat/C learcoat 1.87 15.59

III. Low Bake/Air Dried

– Interior Parts 1.87 15.59

IV. Touch

- Up and Repair 2.13 17.72 Business Machine Coating

I. Primers 0.57 4.80 II. Topcoat 0.57 4.80

III. Texture Coat 0.57 4.80 IV. Fog Coat 0.38 3.14

V. Touch

- Up and Repair 0.57 4.80 *For red, yellow, and black automotive coatings, except touch

- up and repair coatings, the limit is determined by multiplying the appropriate limit in this section of the table by 1.15.

Table 9. Pleasure Craft Surface Coating VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating 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 A ntifoulant 1.53 12.8

Other Substrate Antifoulant 0.53 4.4 All Other Pleasure Craft Surface Coatings

for Metal or Plastic 0.80 6.7

C. Recommended Option 3 for Reducing Coating VOC Emissions: Add

- on Controls In Lieu

of Low

- VOC Coatings and Specified Applic ation Methods

Should product performance requirements or other needs dictate the use of higher

- VOC materials than those that would meet the recommended emission limits, a facility could choose to
use add

- on control equipment with an overall control effici ency of 90 percent in lieu of using

low

- VOC coatings and specified application methods. This control option, like the two options described above, applies to all coatings and thinners applied to miscellaneous metal and plastic part components or products, except as described above for motor vehicle materials. For both recommended options 2 and 3, available add

- on devices include, for example, oxidizers, adsorbers, absorbers, and concentrators. Add

- on devices coupled with capture systems to collect

the VO C being released at the affected facilities can achieve an overall control efficiency of 90

percent.

Work Practice Recommendations8

EPA recommended the following work practices for coating

- related activities : (1) store all

VOC

- containing coatings, thinne rs, and coating

- related waste materials in closed containers; (2)

ensure that mixing and storage containers used for VOC

- containing coatings, thinners, and coating

- related waste materials are kept closed at all times except when depositing or removing

thes e materials; (3) minimize spills of VOC

- containing coatings, thinners, and coating

- related waste materials; and (4) convey VOC

- containing coatings, thinners, and coating

- related waste

materials from one location to another in closed containers or pipes.

A dditionally, EPA recommend ed that, at a minimum, the work practices for cleaning materials

include the following: (1) store all VOC

- containing cleaning materials and used shop towels in

closed containers; (2) ensure that storage containers used for VOC

- con taining cleaning materials

are kept closed at all times except when depositing or removing these materials; (3) minimize spills of VOC

- containing cleaning materials; (4) convey VOC

- containing cleaning materials

from one location to another in closed contai ners or pipes; and (5) minimize VOC emission from cleaning of application, storage, mixing, and conveying equipment by ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent solvent is captured in

closed containe rs.

Description of Automobile and Light

- Duty Truck Assembly Coatings

The automobile and light

- duty truck assembly coatings product category under section 183(e) of the CAA includes the primary coatings that are applied to (1) new automobile or new light

- duty truck bodies, or body parts for new automobiles or new light

- duty trucks, and (2) other parts that are coated along with these bodies or body parts. The category also includes additional coatings applied during the vehicle assembly process. A utomobi le and light

- duty truck assembly coatings most commonly are applied at automobile or light

- duty truck assembly plants.

H owever, this 183(e) category also includes coatings used in facilities that perform these coating operations on a contractual basis. I n addition to the coating applications described above, automobile and light

- duty truck assembly coating facilities may have separate coating lines on which coatings are applied to other parts intended for use in new automobiles or new light

- duty trucks (e .g., application of spray primer, color and clear coat to fascia or bumpers) or to aftermarket repair or replacement parts for automobiles or light

- duty trucks. The separate coating of these other parts and aftermarket or replacement parts is included in the Miscellaneous

Metal Products and Plastic Parts Coatings categories under section 183(e) and covered in the CTG for those categories.

The VOC emissions from automobile and light

- duty truck assembly coating operations are primarily a result of evaporati on of the VOC contained in the coatings and cleaning materials

used in these operations. The primary VOC emissions from automobile .and light

- duty truck assembly coatings occur during coating application/flash

- off and drying/curing of the coatings.

The rem aining emissions occur mainly from mixing and/or thinning.

EPA’s Recommended Control Options for Automobile and Light

- Duty Truck Assembly Coatings

EPA’s 2008 CTG recommends the following VOC reduction measures: VOC emission limits for9

coating operations; work practices for storage and handling of coatings, thinners, and coating waste materials; and work practices for the handling and use of cleaning materials. Recommended VOC emission limits are the same as those adopted by Allegheny County and are

shown in Tables 10

- 11.

Description of Miscellaneous Industrial Adhesives

The miscellaneous industrial adhesives product category includes adhesives (including adhesive primers used in conjunction with certain types of adhesives) used at industrial manufacturi ng and repair facilities for a wide variety of products and equipment that operate adhesives application

processes. The miscellaneous industrial adhesives product category does not include adhesives

that are addressed by CTGs already issued for categories listed under CAA s ection 183(e) or by

earlier CTGs. T hese include the CTGs issued under s ection 183(e) for aerospace coatings; metal furniture coatings; large appliance coatings; flat wood paneling coatings; paper, film, and foil coatings; offset lithogr aphic printing and letterpress printing; and flexible package printing. Coil coating, fabric coating, and rubber tire manufactu ring were not listed under CAA s ection 183(e), however, they were the subject of earlier CTGs which address adhesives used in tho se processes. Motor vehicle adhesives, glass bonding primers, and weatherstrip adhesives that are used at a facility that is not an automobile or light

- duty truck assembly coatings facility, are addressed in

the 2008 CTG for miscellaneous industrial adhes ives.

The VOC emissions from miscellaneous industrial adhesives result from evaporation of the solvents contained in many of the primers, adhesives and cleaning materials during adhesive application and drying processes, as well as during surface preparat ion and cleaning processes

associa ted with adhesives application. The primary VOC emissions from miscellaneous industrial adhesives occur during application and flash

- off.

EPA’s Recommended Control Options for Industrial Adhesives

EPA’s 2008 CTG recomme nds the following VOC reduction measures: VOC emission limits for

i ndustrial adhesives ; work practices for storage and handling of industrial adhesives ; and work practices for the handling and use of cleaning materials. Recommended VOC emission limits

are the same as those adopted by Allegheny County and are shown in Table 12.

Description of Fiberglass Boat Manufacturing Materials

Th e CTG for fiberglass boat manufacturing materials provides control recommendations for reducing VOC emissions from the use of gel coats, resins, and materials used to clean application equipment in fiberglass boat manufacturing operations. This CTG applies to

facilities that manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or d ecks (hereinafter referred to as “fiberglass boat manufacturing

facilities” ). R ecommendations in this CTG do not extend t o facilities that manufacture solely parts of boats (such as hatches, seats, or lockers), or boat trailers, but do not manufacture hul ls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks. If a facility

manufactures hulls or decks, or molds for hulls or decks, then the manufacture of all other fiberglass boat parts, including small parts such as hat ches, sea ts, and lockers is also covered.10

EPA recommend s that the c ontrol approaches discussed in s ection VI of this CTG apply to each fiberglass boat manufacturing facility where the total actual VOC emissions from all fiberglass boat manufacturing opera tions covered by the recommendations in s ection VI of this CTG are equal to or exceed 6.8 kg/day (15 lb/day). An alternative equivalent threshold would be 2.7 tons per 12

- month rolling period. Cleaning materials should be included in determining whether to tal

actual VOC emissions exceed this level. If a facility has add

- on controls, then emissions before

the add

- on controls should be used in determining if a facility meets this threshold.

EPA’s Recommended Control Options for Fiberglass Boat Manufacturing Materials

EPA’s 2008 CTG recommends that the following operations are covered: • Open molding resin and gel coat operations (these include pigmented gel coat, clear gel coat, production resin, tooling gel coat, and tooling resin); • Resin and gel coat mi xing operations; and • Resin and gel coat application equipment cleaning operations.

EPA’s 2008 CTG recommends the following VOC reduction measures: VOC emission limits for

industrial adhesives ; work practices for storage and handling of industrial adhesi ves ; and work practices for the handling and use of cleaning materials. Recommended VOC emission limits

are the same as those shown in Table 2105.86

.

B. STATE SUBMITTAL

On November 15, 2013 , Pennsylvania Department of Environmental Protection (PADEP)

submitted to EPA on behalf of the Allegheny County Health Department (ACHD) a SIP revision concerning the adoption of the EPA CTGs for miscellaneous metal and/or plastic parts surface coating processes, automobile and light

- duty truck assembly coatings, mi scellaneous industrial adhesives, and fiberglass boat manufacturing materials in Allegheny County. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. Allegheny Cou nty is adopting EPA’s CTG standards for miscellaneous metal and/or plastic parts surface coating processes, automobile and light

- duty truck assembly coatings, miscellaneous industrial adhesives, and fiberglass boat manufacturing

materials

. These regulatio ns are contained in the ACHD Rules and Regulations, Arti cle XXI,

Air Pollution Control s ections 2105. 83, 2105.84

, 2105.85, and 2105. 86 . This SIP revision also includes revisions to existing regulations fo r surface coating processes in s ection 2105 .10 and

related definitions in s ection 2101.20. The revisions are summarized below.

Upon review of the November 15, 2013 submittal, EPA found that in section 2105.86

– Control of VOC Emissions from Fiberglass Boat Manufacturing Materials

– under “Limitations”, T able 2105.86 (average monomer VOC content limit) was referenced, however, the table was not

included in the submittal. ACHD indicated that the table had not been included as part of the regulation that went out to public hearing. Given that the table of VOC emission limits is a significant part of the regulation, and that this omission is inconsistent with EPA’s procedures for SIP revisions set forth at 40 CFR section 51.102(d)(2), which requires the availability of the entire plan for public inspection, ACHD was notified that they would need to amend their11

regulation , following all appropriate state and Federal notice and comment procedures, and

s ubmit to EPA the missing table. While ACHD works to amend the regulation, EPA offered to

take action on the N ovember 15, 2013 SIP submittal by conditionally approving the SIP submittal under CAA section 110(k)(4).

On July 17, 2014, EPA received a letter dated July 16, 2014 from PADEP committing to revising Article XXI, Section 2105.86, which is before EPA for action , by amending the regulation and submitting the missing content (i.e. Table 2105.86, which is shown below) within one year from

the Federal Register publication of final n otice of conditional approval of ACHD’s November 15, 2013 CTG SIP submittal (A CHD SIP number 74 )

. In the letter, ACHD indicated that it is confident that this commitment can be met for the following reasons.

(1) The amount of technical work necessary for the measures to be adopted is minimal. The content of the table already exists in the CTG and must merely be placed into Article XXI, Section 2105.86. (2) Adoption of the measure is not expected to be controversial because there are no related regulated sources in Allegheny County. (3) The regulation revision can be adopted in at the County le vel, and reviewed by PADEP and forwarded to EPA in less than one year.

Table 2105.86: Monomer VOC Content Limitations for Open Molding Resin and Gel Coat Operations

Materials Application Method Weight Average Monomer VOC Content Limit (weight percent)

P roduction Resin Atomized (spray) 28

Production Resin Nonatomized 35 Pigmented Gel Coat Any Method 33

Clear Gel Coat Any Method 48 Tooling Resin Atomized 30 Tooling Resin Nonatomized 39 Tooling Gel Coat Any Method 40

ACHD understands that this commi tment will result in a conditional approval by EPA of the previous ly submitted CTG SIP revision number 74 for Allegheny County. Upon EPA’s approval of the SIP revision satisfying the rulemaking commitments, EPA’s conditional approval to the Allegheny port ion of the Pennsylvania SIP will become a full approval.

I. Miscellaneous Metal and/or Plastic Parts Surface Coating Processes

Beginning January 1, 201 4 , this section applies to the owner or operator of a miscellaneous metal parts and/or plastic parts surface coating process, where the total actual VOC emissions from all miscellaneous metal parts and/or plastic parts surface coating processes , including related cleaning activities, at that facility are equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 (2,455 kilograms) per twelve month rolling period , before controls

.12

The provisions of this rule do not apply to (1) shipbuilding and repair coatings; (2) Aerospace coatings; (3) wood furniture coatings; (4) metal furniture coatings; (5) la rge appliance coatings; (6) auto and light

- duty truck assembly coatings; (7) flat wood paneling coatings; (8) miscellaneous industrial adhesives; (9) fiberglass boat manufacturing materials; (10) paper, film, and foil coatings; or (11) can, coil, or magnet wire coatings which are not listed under section 183(e) of the Clean Air Act, but were addressed by regulation section 2105.10.

This section establishes emission limits, recordkeeping and housekeeping requirements, as well as exemptions. Emission limit s of VOCs from miscellaneous metal and/or plastic surface coating processes are as follows:

1. The VOC content of each applied coating is equal to or less than the standard specified in Tab l e s 1

- 5

.

2. The VOC content limitations based on low

- VOC coatings as sp ecified in Tables 6

- 9

, the use of add

- on pollution control equipment to meet the VOC content limitations, and the use of an application method specified in subsection e of this rule.

3 . The overall weight of VOCs emitted to the atmosphere is reduced thro ugh the use of an oxidizer, adsorber, absorber, concentrator, or another add

- on control which is acceptable under section 2105.01 . The overall control system, as determined by the test methods and procedures specified in Part G , shall be no less than 90%

.

II. Automobile and Light

- Duty Truck Assembly Coating s

Beginning January 1, 201 4 , this section applies to the owner or operator of a n automobile and/or light

- duty truck assembly coating operation , where the total actual VOC emissions from all

automobi le and/or light

- duty truck assembly coating operations, including related cleaning activities, at the facility are equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month rolling period , before controls

.

T his section establishes emission limits, recordkeeping and housekeeping requirements, as well as exemptions. Emission limits of VOCs from automobile and light

- duty truck assembly coatings are as follows:

1. The VOC content of each assembly coating proce ss and applied material coating is equal to or less than the standard specified in Table s 10

- 11

.

2. The overall weight of VOCs emitted to the atmosphere is reduced through the use of an oxidizer, adsorber, or another add

- on control which is acceptable un der section 2105.01 (Equivalent Compliance Techniques). The overall control system, as determined by the test methods and procedures shall be no less than 85%.13

Table 10. VOC Emission Limits for Automobile and/or Light

- duty Truck Assembly Coatings

Asse mbly Coating Process VOC Emission Limit lb/gal g/l Electrodeposition primer operation when solids turnover ratio (R T ) ≥ 0.16 (including application area, spray/rinse stations, and curing oven) 0.7 84

Electrodeposition primer operation when 0.040 ≤ (R T ) <
0.16 (including application area, spray/rinse stations, and curing oven) 0.7*350 0.160

- R T 84*350 0.160

- R T

Electrodeposition primer operation when (RT) < 0.040 (including application area, spray/rinse stations, and curing oven) No VOC emission limit

Prim er

- surfacer operations (including application area,

flash

- off area, and oven) 12.0 1,440

Topcoat operation (including application area, flash

- off area, and oven) 12.0 1,440

Final repair operation 4.8 580 Combined primer

- surfacer and topcoat operations 1 2.0 1,440

Table 11. VOC Emission Limits for Miscellaneous Materials Used at Automobile and/or Light

duty Truck Assembly Coating Facilities

Material VOC Emission Limits lb/gal g/l Automobile and light

- duty truck glass bonding primer 7.5 900

Automobil e and light

- duty truck adhesive 2.1 250 Automobile and light

- duty truck cavity wax 5.4 650 Automobile and light

- duty truck sealer 5.4 650 Automobile and light

- duty truck deadener 5.4 650 Automobile and light

- duty truck gasket/gasket sealing material 1 .7 200 Automobile and light

- duty truck underbody coating 5.4 650 Automobile and light

- duty truck trunk interior coating 5.4 650 Automobile and light

- duty truck bedliner 1.7 200 Automobile and light

- duty truck weatherstrip adhesive 6.3 750

Automobile a nd light

- duty truck lubricating wax/compound 5.8 700

III. Miscellaneous Industrial Adhesives

Beginning January 1, 201 4 , this section applies to the owner or operator of a miscellaneous industrial adhesive application process, where the total actual V OC emissions from all

miscellaneous industrial adhesive s , including related cleaning activities, at that facility are equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month rolling period , before controls

.

This section establishes emission limits, recordkeeping and housekeeping requirements, as well as exemptions. Emission limits of VOCs from miscellaneous industrial adhesives are as follows:14

1. The VOC content of each as applied ahesive is equal to o r less than the standard specified in Table 12

.

2. The overall weight of VOCs emitted to the atmosphere is reduced through the use of an oxidizer, adsorber, absorber, or another add

- on control which is acceptable under section 2105. 01 (Equivalent Compl iance Techniques). The overall control system, as determined by the test methods and procedures specified in Pa rt G, shall be no less than

85 %.

3. A combination of the methods listed in paragraphs 1 and 2.

Table 12

. Emission Limits of VOCs for Miscel laneous Industrial Adhesives

Limits as Applied VOC Content Minus Exempt Compounds General Adhesive Application Process lb/gal g/l Reinforced Plastic Composite 1.7 200 Flexible Vinyl 2.1 250

Metal 0.3 30 Porous Material (Except Wood) 1.0 120

Rubber 2. 1 250

Wood 0.3 30

Other Substrates 2.1 250

Specialty Adhesive Application Processes

Ceramic Tile Installation 1.1 130

Contact Adhesive 2.1 250

Cove Base Installation 1.3 150 Floor Covering Installation (Indoor) 1.3 150 Floor Covering Installation (Outdoor) 2.1 250 Floor Covering Installation (Perimeter Bonded Sheet Vinyl) 5.5 660 Metal to Urethan/Rubber Molding or Casting 7.1 850

Motor Vehicle Adhesive 2.1 250

Motor Vehicle Weather

- strip Adhesive 6.3 750 Multipurpose Construction 1.7 200

Pla stic Solvent Welding (ABS) 3.3 400 Plastic Solvent Welding (Except ABS) 4.2 500 Sheet Rubber Lining Installation 7.1 850 Single

- Ply Roof Membrane Installation/Repair (Except EPDM) 2.1 250 Structural Glazing 0.8 100 Thin Metal Laminating 6.5 780

Tire Repair 0.8 100 Waterproof Resorcinol Glue 1.4 170

Adhesive Primer Application Processes Motor Vehicle Glass Bonding Primer 7.5 900 Plastic Solvent Welding Adhesive Primer 5.4 65015

Single

- Ply Roof Membrane Adhesive Primer 2.1 250

Other Adhesive Prime r 2.1 250

IV. Fiberglass Boat Manufacturing Materials

Beginning January 1, 2014, this section applies to the owner or operator of a fiberglass boat manufacturing facility , where the total actual VOC emissions from fiberglass boat manufacturing

materi als including related cleaning activities, at that facility are equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month rolling period,

before controls. This regulation applies to facilities that manufactu re hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks. This regulation does not apply to facilities that manufacture solely fiberglass parts of boats such as hatches, seats, lockers,

or boat trailers.

This regu lation does not extend to surface coatings applied to fiberglass boats, and industrials adhesives used in the assembly of fiberglass boats. Surface coating for fiberglass and metal recreational boats, also called pleasure crafts, are addressed in regulati on 2105.83, Control of VOC Emissions from Miscellaneous Metal and/or Plastic Parts Surface Coating Processes. Industrial adhesives used in fiberglass boat assembly are addressed in regulation 2105.85,

Control of VOC Emissions from Miscellaneous Industrial Adhesives.

This section establishes emission limits, recordkeeping and housekeeping requirements, work practice standards, as well as exemptions. Emission limits of VOCs from miscellaneous metal and/or plastic surface coating processes are as follows: Fiberglass boat manufacturing facilities shall use resins and/or gel coats that are equal to or less than the applicable weighted average monomer VOC content limit specified in Table 2105.86 1 and the non

- monomer VOC limit shall not exceed 5 percent, by we ight, of resin and/or gel coat.

V. Additional Revisions

In addition to adopting the CTGs discussed above, definitions arising from these CTG regulations were added to Article XXI (section 2101.20) and are being added to the Allegheny County portion of the Pennsylvania SIP. They are as follows:

Section 2101.20: Definitions :

“General Multi

- Component Coating” means a coating requiring the addition of a separate reactive resin, commonly known as a catalyst or hardener, before application to form an

acce ptable dry film.

“General One Component Coating” means a coating that is ready for application as it comes out

1 This table was erroneously omitted from the regulation, but ACHD has committed to amend Article XXI and submit this missing portion to EPA within 12 months of the Federal Register publication of final notice of conditional approval of ACHD’s November 15, 2013 CTG SIP submittal

.16

of its container to form an acceptable dry film. A thinner, necessary to reduce the viscosity, is not considered a component.

“Solids turnover ratio (RT)” means the ratio of the total volume of coating solids that is added to the electrodeposited primer system in a calendar month divided by the total volume design capacity of the electrodeposited primer system.

Changes were also made to an exis ting regulation, Section 2105 .10, Surface Coating Processes. The specific language added is as follows:

1. The limits from section 2105.10 and Table section 2105.10, number 10 for miscellaneous metal parts and products, no longer apply to miscellaneous meta l and/or plastic parts surface coating processes as of January 1, 2014.

2. The limits from section 2105.10 and Table section 2105.10, number 6 for automobile and light

- duty truck coating, no longer apply to automobile and light

- duty truck assembly coatings of January 1, 2014

.

C. EPA EVALUATION AND RECOMMENDED AGENCY ACTION

Allegheny County has adopted the standards and requirements of the CTG s for miscellaneous metal and/or plastic parts surface coating processes, automobile and light

- duty truck assembl y coatings, miscellaneous industrial adhesives, and fiberglass boat manufacturing materials, and is amending the Pennsylvania SIP to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs rea dily combine with NO
x to form ground

- level ozone. Therefore, this revision will help Pennsylvania attain and maintain the NAAQS for ozone . Given that ACHD has erroneously omitted the table of average monomer VOC content limits (Table 2105.86) from sectio n 2105.86

– Control of VOC Emissions from Fiberglass Boat Manufacturing Materials

– EPA recommends conditional approval of the SIP

revision under CAA section 110(k)(4) until ACHD amends the regulation and submits to EPA the missing content. Upon EPA’s app roval of the SIP revision satisfying the rulemaking commitments, EPA’s conditional approval to the Allegheny portion of the Pennsylvania SIP will become a full approval.