UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Placer County Air Pollution Control District Rule 249 Surface Coating of Plastic Parts and Products

Prepared by: Arnold Lazarus Reviewed by: Andrew Steckel

December

, 2014 2



RULE IDENTIFICATION

-

Agency: Placer County Air Pollution Control District ( P CA PC D)

SIP Approved Rule: There have been no versions of PCAPCD Rule 249 which have been SIP approved.

Subject of this TSD: Rule 249

- Surface Coating of Plastic Parts and

Products Adopted

– August 8, 2013

Submitted

– May 13, 2014

BACKGROUND

- PCAPCD Rule 249 is a new rule that was adopted by PCAPCD

to establish requirements concerning the surface coating of plastic parts and products (SCPPAP) . According to PCAPCD’s Staff Report associated with rule adoption

, “ The District is required to adopt volatile organic compounds (VOCs) standards at least as stringent as contained in the U.S. EPA “Control Techniques

Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (CTG), (EPA 453

- R

- 08

- 03), September 2008. Rule 245, Surface Coati ng of Metal Parts and

Product s, was amended August 20, 2009 to meet the (CTG) requirements for metal p arts. Adoption of this proposed new Rule 249, Surface Coating of Plastic
Parts and Products, would meet the (CTG) requirements for plastic parts. ” 1 The PCAPCD is required to adopt th is rule because the PCAPCD is classified as

Severe Nonattainment for the 8

- hour Ozone National Ambient Air Quality Standard (NAAQS). Such nonattainment areas are generally required to adopt local rules, like PCAPCD 249, consistent with relevant CTGs.

RULE SUMMARY

- Rule 249 establishes VOC content limits and workplace

standards for S CPPAP . It also describes related recordkeeping, reporting, and monitoring requirements.

EVALUATION CRITERIA

-

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule
Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

- EPA ’ s “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (CTG), September 2008 , and other state and local rules for this category were used to help evaluate the RACT requirements of CAA § 182(b)(2) and § 182(f).

1 PCAPCD Staff Report, “Surface Coating of Plastic Parts and Products, August 8, 2013

. 3

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3. SIP Relaxation

- CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990,

in a nonattainment area.

EPA EVALUATION

-

1. The rule requirements and applicability are cl ear, and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can evaluate and determine compliance

with Rule 249 consistently.

2. The relevant VOC c ontent l imits in PCAPCD Rule 249

, the 2008 CTG

, South Coast Air Quality Management District ’s (SCAQMD) Rule 1145, San Joaquin Valley Unified Air Control District’s (SJVUACD) Rule 4603 and Antelope Valley Air Quality Management District’s (AVAQMD) Rule 1145 are compared in Table 1 below

.

Table 1

Surface Coating of

Plastic Parts and

Products VOC As Applied Limit, grams/liter (lb/gal) Less water and exempt compounds

Category PCAPCD

Rule 249 CTG SCAQMD

Rule 1145 SJVUAPCD

Rule 4603 AVAQMD

Rule1145

General

- One

- Component 275 (2.3) 280 (2.3) 120 (1.0) 280 (2.3) 275 (2.3)

General

- Multi

- Components 420 (3.5) 420 (3.5) N/A 420 (3.5) 420 (3.5)

Electric Dissipating and Shock

free 800 (6.7) 800 (6.7) 360 (3.0) 800 ( 6.7) 360 (3.0 )

Extreme Performance (2 pack) 420 (3.5) 800 (6.7) 420 (3.5) 420 (3.5) N/A

Metallic 420 (3.5) 800 (6.7) 420 (3.5) 420 (3.5) 420 (3.5)

Military Specification (1 pack) 335 (2.8) 340 (2.8) 340 (2.8) 340 (2.8) 340 (2.8)

Military Specification (2 pack) 420 (3.5) 420 (3.5) 420 (3.5) 420 (3.5) 420 (3.5)

Mold Seal 755 (6.3) 760 (6.3) 750 (6.3) 760 (6.3) 750 (6.3) 4

 Multi

- colored 680 (5.7) 680 (5.7 ) 680 (5.7) 680 (5.7) 685 (5.7)

Optical 800 (6.7) 800 (6.7) 50 (0.4) 800 (6.7) 800 (6.7)

Vacuum Metalizing 800 (6.7) 800 (6.7) 800(6.7) 800 (6.7) 800 (6.7)

As shown in the table, all VOC limits in PCAPCD Rule 249 are e quivalent or more stringent to the relevant CTG and the analogous rules in

SJVUAPCD and

, with exception of electric dissipating and s hock

- free coatings which are l ikely to be of limited use, AVAQM D . With exception o f this category, general one

- component and optical coatings, PCAPCD Rule

249 ’s VOC limits are also equivalent to the analogous limits in SCAQMD, which generally has the most stringent requirements in the country. As a result, we conclude that PCAQM D Rule 249 adequately fulfils the RACT requirements of CAA § 182(b)(2) and § 182(f).

3. W e propose to determine that our approval of the submittal would comply

with CAA §§ 110(l) and 193 because (1) the proposed SIP revision would

not interfere with the on

- goin g process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the emission limits in the submitted rule are more stringent than the existing SIP

- approved control requirements that they would replace

DEFICIENCIES

– We have identified no deficiencies with Rule 249 sufficient for EPA to propose less than full approval.

EPA ACTION

– The submitted Rule 249 strengthens the SIP and meets the CTG requirements. The rule fulfils the relevant CAA §110 and part D requireme nts. EPA recommends a full approval of Rule 249 pursuant to CAA §110(k)(3) and CAA §301(a).

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The following revisions are not currently the basis for rule disapproval, but are

recommended for the next time the rule is amended.

1. The 55 gallon/year exemption of non

- compliant coating in paragraph 104.1 “Low Usage of Non

- Compliant Coating Materials” should be reduced to 50 gallons/year as per the 2008 CTG.

2. We recommend reducing the VOC limits for electric dissipating and s hock

free , general one

- component and optical coatings consistent with the more stringent analogous limits in SCAQMD Rule 1145. 5



REFERENCES

1. PCAPCD Staff Report, “Surface Coating of Plastic Parts and Products, August 8, 2013.

2. PC APCD Rule 249, “Surface Coating of Plastic Parts and Products.”

3. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (CTG), September 2008. ( EPA 453

- R

- 008

- 003). http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf

5

. SC AQMD Rule 1145 , “Plasti c, Rubber, Leather and Glass Coatings

, ” July
14, 2010

.

6. AV AQMD Rule 1145, “Plastic, Rubber and Glass Coatings,” December 20,

1993.

7. SJUACD Rule 4603, “ Surface Coating of Metal Parts and Products, Plastic

Parts and Products and Pleasure Crafts ,” November 1, 2011

.