1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: June 4, 2012

SUBJECT: Technical Support Document for Delaware’s Adoption of Control Technique

Guidelines (CTG) for Plastic Parts, Metal Furniture, La rge Appliances, and

Miscellaneous Metal Parts.

FROM: Gregory Becoat /s/

Office of Air Program Planning

TO: File

THRU: Donna Mastro

, Acting Associate Director /s/

Office of Air Program Planning

A. BACKGROUND

S ection 172(c)(1) of the Clean Air Act (C AA) provides that S tate I mplementation P lans (SIP) for

nonattainment 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 f

o r certain nonattainment areas, s tates must revise their SIP to include RACT for

sources of volatile organic compound ( VOC ) emissions covered by a control technique guideline (CTG) document issued after November 15, 1990 and prior to the A rea’s date of atta inment. The 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 f easibility ” (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 documents issued by EPA intended to provide state and local air pollution control

authori ties information that should assist t hem in determining RACT for VOC from various

sources . EPA may issue a CTG in lieu of a national regulation as RACT for a product category where EPA determines that the CTG will be substantially as effective as regulati ons in reducing

emissions of VOC in ozone nonattainment areas. The recommendations in the CTG are based

upon available data and information and may not apply to a particular situation based upon the circumstances. States can follow the CTG and adopt s tat e regulations to implement the

recommendations contained therein

, or they can adopt alternative approaches

. In either case,

s tates must submit their RACT rules to EPA for review and approval as part of the SIP process.

EPA will evaluate the rules and d etermine, through notice and comment rulemaking in the SIP approval process, whether the submitted rules meet the RACT requirements of the CAA and2

EPA’s regulations.

Surface Coating of Miscellaneous Metal and Plastic Parts CTG ( EPA 453/R

- 08

- 003, Septembe r 2008 )

In June 1978, EPA issued a CTG document for controlling VOC emissions from the surface coating of miscellaneous metal parts and products. In January 1988, EPA promulgated the new source performance standards ( NSPS) for the Surface Coating of Plas tic Parts for Business Machines. In February 1994, EPA issued an Alternative Control Techniques (ACT) document for controlling VOC emissions from the surface coating of automotive/transportation and business machine plastic parts. In January 2004, EPA pr omulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Metal Parts and Products Surface Coating. In April 2004, EPA promulgated the NESHAP for Plastic Parts and Products Surface Coating. After reviewing the 1978 CTG, the 1988 NSPS, the 1994 ACT, and existing state and local VOC emission reduction approaches, EPA developed a new CTG combining the requirements for miscellaneous metal and plastic parts coatings into a single CTG, entitled “Control Technique Guideli nes for Miscellaneous Metal and Plastic Parts Coatings” (EPA

453/R

- 08

- 003, September 2008).

Miscellaneous metal product s and plastic part s surface coatings include, but are not limited to, the coatings that are applied to the surfaces of a varied range of metal and plastic parts and products. These parts or products are constructed either entirely or partially from metal or plastic. They include, but are not limited to, metal and plastic components of the following types of products as well as the produc ts 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, motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational boats), extruded aluminum structural components, railroad cars,

heavier vehicles 1 , lawn and garden equipment, business machines, laboratory and med ical equipment, electronic equipment, steel drums, metal pipes, and numerous other industrial and household products (hereinafter collectively referred to as “miscellaneous metal and plastic parts”)

. The CTG applies to manufacturers of miscellaneous metal and plastic parts that surface

coat the parts they produce. Miscellaneous metal products and plastic parts coatings do not include coatings that are a part of other product categories listed under s ection 183(e) of the CAA for which CTGs have been publis hed and/or coatings addressed by other CTGs. These other categories that are not part of the miscellaneous metal product s and plastic parts coatings categories include shipbuilding and repair coatings; aerospace coatings; wood furniture coatings;

metal fu rniture coatings; large appliance coatings; automobile and light

- duty truck assembly coatings; flatwood paneling coatings; miscellaneous industrial adhesives; fiberglass boat manufacturing materials; and paper, film, and foil coatings. Can coatings, coil coatings, and magnet wire coatings were not listed under section 183(e) of the Act, but were addressed by earlier CTGs, and are also not included in the miscellaneous metal product s and plastic parts

1 Heavier vehicles includes all vehicles that meet the definition of the term “other motor vehicles,” as defined in the National Emission Standards for Surface Coating of Automobile and Ligh t

- Duty Trucks at 40 CFR 63.3176.3

coatings categories addressed by this CTG.

Applicabilit y

The September 2008 CTG for Miscellaneous Metal and Plastic Parts Coating s provides recommendations for reducing VOC emissions from the use of coatings in a miscellaneous metal products and miscellaneous plast ic parts surface coating unit at a facility w here the total actual VOC emissions from all miscellaneous metal product and plastic parts surface coating operations, including related cleaning activities

, at that facility

, are equal to or exceed 6.8 kilograms a day (kg/day)

, 15 pounds a day (lb/day), o r an equivalent level of 2.7 t ons per 12

- month rolling period

, before con sideration of controls. A coating unit consists of a series of one or more coating applicators and any associated drying area and/or oven where a coating is applied, dried, and/or cu red. A coating unit ends at the point where the coating is dried or cured, or prior to any subsequent application of a different coating. As mentioned previously, states can adopt the above recommended 6.8 kg/day (15 lb/day) actual VOC emissions

, or an e quivalent applicability threshold, or they can develop other applicability criteria that they determine are appropriate considering the facts and circumstances of the sources in their particular

nonattainment areas. EPA will review the state RACT rules in the context of the SIP revision

process. For facilities that coat bodies and/or body parts for new heavier vehicles, EPA recommends that these facilities have the option of meeting either the state RACT requirements for miscellaneous metals and plastic p arts coatings or the state RACT requirements for auto and light

- duty truck coatings.

Sources of VOC Emissions

Primarily, VOC emissions from miscellaneous metal product s and plastic parts surface coating operations result from the evaporation of volatile components from the coatings and cleaning materials. The majority of VOC emiss ions from these materials occur during coating application/flash

- off and drying/curing of the coatings. The remaining emissions are primarily from mixing and/or thinning. In mo st cases, VOC emissions from surface preparation, storage, handling, and waste/wastewater operations are relatively small.

Coating Application

Surface coating of miscellaneous metal product s and plastic parts surfaces is applied by applying a coating to the metal or plastic part followed by curing or drying the coating. The coating itself may be in the form of a liquid or powder. Several different types of application technologies are used to apply liquid coatings, and the selection of the applicati on technology can have a significant effect on the amount of coating used and the resulting VOC emissions from the operation. The most common types of liquid coating applicators include: air atomized spray coating, electrostatic spray coating, high volum e/low pressure (HVLP) spray coating, dip coating, flow coating, roll coating, electrocoating, and autophoretic coating. Powder coatings can be applied through electrostatic spraying or dipping. An alternative to the coating techniques

outlined in EPA’s C TG for this source category would need to be approved by the State and

EPA.4

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from miscellaneous metal and plastic parts coating operations: (1) evaporation of the VOC components of the coatings; and (2) evaporation of VOC from the cleaning materials. To control VOC emissions from miscellaneous metal and plastic part s surface coatings, the CTG recommends these three options: (1) VOC content limits for each c oating category based on the use of low

- VOC content coatings and specified application methods to achieve good transfer efficiency; (2) equivalent VOC

emission rate limits based on the use of a combination of low

- VOC coatings, specified application methods , and add

- on controls; or (3) an overall V OC control efficiency of 90 percent

for facilities that choose to add

- on controls instead of low

- VOC content coatings and specified application methods. The low

- VOC coatings recomm e ndation (Option 1) consists of V OC content limits in terms of mass of VOC per volume of coating, as applied, excluding water and exempt compounds, and the use of specified application methods. The equivalent emission rate

limit recommendation (Option 2) consists of emission rate limits in terms of mass of VOC emitted per volume of coating solids, as applied, and the use of specific application methods. This option is intended only for facilities using a combination of low

- VOC coatings, specific application methods, and add

- on control eq uipment on a coating unit to meet the recommended limits for mass of VOC emitted per volume of coating solids.

In addition, it is recommended that one or more of the following coating application methods be used in conjunction with the use of low

- VOC co ntent coatings in Options 1 and 2: electrostatic application, HVLP spray, flow coat, roller coat, dip coat (including electrodeposition), airless spray, air

- assisted airless spray, or other coating application methods capable of achieving a

transfer effic iency equivalent to or better than that achieved by HVLP spraying. Under an add

on control option, (Option 3), a facility would use an emissio n c apture system and add

- on control

device to achieve an overall emission capture and control ef ficiency of at le ast 90 percent. The facility would not have to limit the VOC c ontent of the coating materials and would not need to use any partic ular coating application method.

The first two options are expected to achieve equivalent VOC emission reductions. The t hird option provides facilities the flexibility to use a high efficiency add

- on control in lieu of low

VOC coatings and specified application methods, especially when the use of high VOC coatings is necessary or desirable. The third option is expected to achieve an emission reduction at least as great as the first two options.

Additionally, work practices to further reduce VOC emissions from coatings as well as to minimize emissions from cleaning materials used in the surface coating process are

recommend ed.

Consistent with the State rules which are the basis for the recommended VOC limits, the CTG

recommends VOC limits and application methods not apply to certain types of coatings and coating operations. For all coating operations, it is recommende d tha t the VOC limits and application methods not apply to aerosol coatings products or powder coatings. Aerosol coatings are a separate category under Section 183(e) of the CAA, and powder coatings are an inherently

low

- VOC alternative to many liquid coatings

.5

The CTG recommend s that for all metal parts coatings, only the recommended work practices, but not the recommended VOC limits and application methods, apply to the following types of coatings and coating operations: stencil coatings, safety indicating c oatings, solid

- film lubricants, electric

- insulating and thermal

- conducting coatings, magnetic data storage disk coatings, and plastic extruded onto metal parts to form a coating. In addition, for all metal parts coatings, it is recommended that the recomm ended application methods not apply to touch

- up coatings, repair coatings, and textured finishes, but that the recommended VOC limits and work practices apply

.

For plastic parts coatings, the CTG recommend s the application methods and work practices, but

not the recommended VOC limits

, apply to the following types of coatings and coating operations: touch

- up and repair coatings, stencil coatings applied on clear or transparent substrates, clear or translucent coatings, coatings applied at a paint manufact uring facility while conducting performance tests on the coatings, any individual coating category used in volumes

of less than 50 gallons in any one year, if substitute compliant coatings are not available, provided that the total usage of all such coatin gs does not exceed 200 gallons per year, per facility, reflective coating s applied to highway cones, mask coatings that are less than 0.5 millimeter thick (dried) and the area coated is less than 25 square inches, EMI /RFI shielding coatings, and hepa rin

- be nzalkonium chloride (HBAC)

- containing coatings applied to medical devices, provided that the total usage of all such coatings does not exceed 100 gallons per year, per facility.

Additionally, for plastic parts coatings, the CTG recommend s that the appli cation methods not apply to airbrush operations using 5 gall ons or less per year of coating. However, the recommended VOC limits and work practices apply to these operations.

For automotive/transportation and business machine plastic part s coatings, the CTG recommend s that the application methods and work practices, but not the VOC limits, apply to the following types of coatings and operations: texture coatings, vacuum metalizing coatings, gloss reducers, texture topcoats, adhesion primers, electrostati c preparation coatings, resist coatings, and stencil coatings.

For pleasure craft surface coating operations, the CTG recommend s that the application methods not apply to extreme high gloss coatings, but that the recommended VOC limits and work practices apply.

F or cleaning materials, the CTG recommends that work practices be used with all three of the control options to reduce VOC emissions. The application of add

- on controls in conjunction with these work practices is not recommended. In addition, the use of a VOC content or VOC composite vapor pressure limit for cleaning materials is not recommended.

Under Option 1 described above, s eparate sets of emission limits for metal parts coatings, plastic parts coatings, automotive/transportation and busines s machine plastic parts, and pleasure craft coatings are recommended. Separate emission limits for baked and air

- dried coatings is recommended. Provided in the following five tables are the recommended emission limits expressed in terms of mass of VOC pe r volume of coating (excluding water and exempt6

compounds, as applied).

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

Low

- VOC Coatings

Table 1. Metal Parts and Products VOC Content Limits

Air Dried Baked Coating Cat egory kg/VOC/l coating lb VOC/gal

coating kg VOC/l

c oating 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 Fill er 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 Coatings 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

, 0.42 3.5 0.42 3.57

Reconditioned,

Exterior Drum Coating, Reconditioned,

Interior 0.50 4.2 0.50 4.2

Table 2

. Plastic Parts and Products VOC Content Limits Coating Category kg/VOC/l coating lb VOC/gal coating General One Component 0.28 2.3

General Mul ti

- Component 042 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

Table 3

. Automotive/Transportation and Business Machine Plastic Parts VOC Content

Limits Coating Category kg/VOC/l coating l b VOC/gal coating

Automoti ve Transportation Coatings 2

I. High Bake Coatings

– Interior and Exterior Parts

Flexible Primer 0.54 4.5

Non

- flexible Primer 0.42 3.5

Base Coats 0.52 4.3

Clear Coat 0.48 4.0

Non

- basecoat/clear coat 0.52 4.3 II. Low Bake/Air Dried Coatings

– Exteri or Parts

Primers 0.58 4.8

Basecoat 0.60 5.0

Clearcoats 0.54 4.5

Non

- basecoat/clearcoat 0.60 5.0

III. Low Bake/AirDried Coatings

– Interior Parts 0.60 5.0 IV. Touchup and Repair Coatings 0.62 5.2

2 For red, yellow and black automotive coatings, except touch up and repair coatings, the recommended limit is determined by multiplying the appropriate limit in this table by 1.15

.8 Business Machine Coatings

I. Primers 0.35 2. 9 II. Topcoats 0.35 2.9

III. Texture Coat 0.35 2.9 IV. Fog Coat 0.26 2.2 V. Touchup and repair 0.35 2.9

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 Coating 0.56 4.7

Other Substrate Antifoulant Coating 0.33 2.8 All other ple asure 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 deaden er 0.65 5.4 Motor vehicle gasket/gasket sealing

material

0.20 1.7 Motor vehicle underbody coating 0.65 5.4 Motor vehicle trunk interior coating 0.65 5.4

Motor vehicle bedliner 0.20 1.7 Motor vehicle lubricating wax/compound 0.70 5.8

Recommend Option 2 for Reducing Coating VOC Emissions: Emission Rate Limits Based

on Low

- VOC Coatings and Add

- on Controls

— VOC per Volume Solids

The recommended emission limits can also be expressed in terms of mass of VOC per volume of coating solids, as applied. This recommendation 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 VOC per volume of

sol ids, as applied, are provided in the following three ta bl es. As noted earlier, for the motor vehicle materials listed in Table 5 under Option 1 above, alternative emission rate limits (VOC per volume solids) is not recommended.9

Table 6 . Metal Parts and P roducts VOC Emission Rate Limits (VOC per Volume Solids)

Air Dried Baked

Coating Category kg VOC/l

solids lb VOC/gal

solids kg VOC/l

solids lb VOC/gal

solids

General One Component 0.54 4.52 0,40 3.35

General Multi Component 0.54 4.52 0.40 3.35

Camouf lage 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 5.06

Extreme Performance 0.80 6.67 0.61 5.06

Heat

- Resistant 0.80 6.67 0.61 5.06 High Performance

Archite ctural 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 0.40 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 6.6 7 0.40 3.35

Prefabricated

Architectural One

Component 0.80 6.67 0.40 3.35

Pretreatment Coatings 0.80 6.67 0.80 6.67

Silicone Release 0.80 6.67 0.80 6.67

Solar

- Absorbent 0.80 6.67 0.61 5.06

Vacuum

- Metalizing 0.80 6.67 0.80 6.67 Drum Coating, New,

E xte rior 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 9.7810

T able 7. Plastic Parts and Products VOC Emission Rate Limits (VOC per Volume Solids) Coating Category k g VOC/l solids lb VOC/gal solids General One Component 0.40 3.35

General Multi

- Component 0.80 6.67 Electric Dissipating Coatings and Shock

- Free Coatings 8.96 74.7

Extreme Performance 0.80 (2

- pack coatings) 6.67 (2

- pack coatings)

Metallic 0.80 6.67 Military Specification 0.54 (1 pack) 0.80 (2 pack) 4.52 (1 pack) 6.67 (2 pack)

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/T ransportation and Business Machine Plastic Parts VOC Emission Rate Limits (VOC per Volume Solids) Coating Category k g VOC/l solids lb VOC/gal solids

Automotive/Transportation Coatings 3

I. High Bake Coatings

– Interior and Exteri or Parts

Flexible Primer 1.39 11.58

Non

- flexible Primer 0.80 6.67

Base Coats 1.24 10.34

Clear Coat 1.05 8.76

Non

- basecoat/clear coat 1.24 10.34 II. Low Bake/Air Dried Coatings

– Exterior Parts

Primers 1.66 13.80

Basecoat 1.87 15.59

Clearcoats 1.3 9 11.58

Non

- basecoat/clearcoat 1.87 15.59 III. Low Bake/Air Dried Coatings

– Interior Parts 1.87 15.59

IV. Touchup and Repair Coatings 2.13 17.72 Business Machine Coatings

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. T ouchup and repair 0.57 4.80

3 For red, yellow, and black automotive c oatings, except touch up and repair coatings, the recommended limit is determined by multiplying the appropriate limit in this table by 1.15.11

Table 9. Pleasure Craft Surface Coating VOC Emission Rate Limits (VOC per Volume Solids) Coating Category kg VOC/l solids lb VOC/gal 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 m etal or plastic 0.80 6.7

Recommend Option 3 for Reducing Coating VOC Emissions: Add

- on Controls in Lieu of

Low

- VOC Coatings and Specified Application Methods

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

- V OC

materials than those that would meet the recommended emission limits

, a facility could choose to

use add

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

low

- VOC coatings and specified application methods. This option, like th e two options summarized above, applies to all coatings and thinners applied to miscellaneous metal and plastic part components or products, except as des cribed above for motor vehicles

.

For both recommended options 2 and 3, available add

- on devices inclu de, for example, oxidizers, adsorbers, absorbers, and concentrators

. Add

- on devices coupled with capture systems to collect the VOC being released at the affected facilities can achieve an overall control efficiency of 90 percent.

Work Practices for Coat ing Operations and Cleaning Materials

In addition to the control options mentioned above, this CTG recommends work practices to further reduce VOC emissions from miscellaneous metal and plastic part s surface coating

- related activities. Specifically, at a minimum, the following work practices are recommended: (1) store

all VOC

- containing coatings, thinners, and coating

- related waste materials in closed containers; (2) ensure that storage containers used for VOC

- co ntaining cleaning materials are kept close d 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 containers or pipes; and (5) minimize VOC emiss ions 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

containers.12

Surface Coating of Metal Furnit ure CTG (EPA 453/R

- 07

- 005, September 2007)

In December 1977, EPA issued a CTG document for controlling VOC emissions from the surface coating of metal furniture. In October 1982, EPA promulgated the NSPS for the S urface

C oating of M etal F urniture, and in May 2003, EPA promulgated the NESH AP for the Surface

C oating of Metal Furniture. After reviewing the 1977 CTG, the 1982 NSPS, and the 2003 NESHAP, and existing state and local VOC emission reduction approaches, EPA developed a CTG entitled, “Control Tech nique Guidelines for Metal Furniture Coatings” (EPA 453/R

- 07

- 005).

Coatings used in metal furniture surface coating operations include paints, sealants, caulks, ink, adhesives, and maskants

. 4 It is recommended that the control approaches discussed herein apply to each metal furniture surface coating unit 5 at a facility where the total actual VOC emissions from all metal furniture coating operations, including related cleaning activities, at that facility, are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per 12

- month rolling period, before consideration of controls. These control approaches are not recommended

for facilities that emit below this level.

The metal furniture coatings product category under section 183(e) of the CAA includes the coatings that are applied to the surfaces of metal furniture

. A metal furniture substrate is the furniture or components of furniture constructed either entirely or partially from metal. Metal furniture includes, but is not limit ed to, the following types of products: household, office, institutional, laboratory, hospital, public building, restaurant, barber and beauty shop, and dental furniture, as well as components of these products. Metal furniture also includes office and s tore fixtures, partitions, shelving, lockers, lamps and lighting fixtures, and wastebaskets. Metal furniture coatings include paints and adhesives and are typically applied without a primer. Higher solids and powder coatings are used extensively in the m etal furniture surface coating industry. Metal furniture coatings provide a covering, finish, or functional or protective layer, and can also provide a decorative finish to metal furniture.

Applicability

The September 2007 CTG for Metal Furniture coat ings provides recommendations for reducing VOC emissions from the use of coatings applied to each metal furniture surface coating unit at a facility where the total actual VOC emissions from all metal furniture coating operations, including related cleanin g activities, at that facility

, are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per 12

- month rolling period, before consideration of controls. As mentioned previously, states can adopt the above recommended 6.8 kg/day (15 lb/day) actual VOC emissions or an equivalent applicability threshold, or they can develop other

4 Decorative, protective, or functional materials that consist only of protective oils for metal, acids, b a ses, or any combination of these substances are not considered metal furniture coatings.

5 A coating unit consists of a series of one or more coating applicators and any associated drying area and/or oven wherein a coating is applied, dried, and/or cured. A coat ing unit ends at the point where the coating is dried or cured, or prior to any subsequent application of a different coating. It is not necessary for a coating unit to have an oven or flash

- off area

.13

applicability criteria that they determine are appropriate considering the facts and circumstances of the sources in their particular nonattainment areas.

Sources of VOC Emissions

Primarily, emissions from metal furniture coating operations result from the evaporation of the VOC components of the coatings and cleaning materials. In most cases, VOC emissions from the surface preparation, storage, handlin g, and waste/wastewater operations are relatively small. The primary VOC emissions from metal furniture coatings occur during coating application/flash

- off and drying/curing of the coatings. The remaining emissions are primarily from mixing and/or thinni ng. The VOC emissions from mixing and thinning of coatings occur from the displacement of VOC

- laden air in containers used to mix coatings containing solvents (thinners) prior to coating application. The displacement of VOC

- laden air can also occur durin g fi l ling of containers and can be caused by changes in temperature, changes in barometric pressure, or agitation during mixing.

Coating Application

Surface coating of metal furniture is applied by applying a coating to the metal furniture

component or p roduct. After being coated by any of the typical coating methods (e.g., spray coating or dip coating), the metal furniture components or products are dried/cured. Prior to entering the ovens, solvents in the coatings evaporate slowly in the flash

- off are a to prevent bubble formation during curing. The coating itself may be in the form of a liquid or powder, and may be applied by spraying or dipping. T he amount of VOC emissions from the flash

- off area depends on the type of coating used, how quickly the component or product moves through the

flash

- off area, and the distance between the application area and the bake oven. For liquid spray applications, it is estimated that 65

- 80 percent of the volatiles are emitted during the application

and flash

- off ope rations, and the remaining 20

- 35 percent from the drying/curing operation.

For powder coatings, the curing/drying step melts the powder and forms a continuous coating on the metal furniture component or product. For liquid coatings, this step removes any remaining volatiles from the coating. The cured coatings provide the desired decorative and/or protective characteristics. The VOC emissions during the curing/drying process result from the evaporation of the remaining solvents in the dryer.

There are several different types of applicators that may be used to apply coatings. The most common types of coating applicators include: air atomized spray coating, electrostatic spray coating, high volume/low pressure (HVLP) spray coating, dip coating, flow coa ting, roll coating, electrocoating, and autophoretic coating.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from metal furniture surface coating operations: (1) evaporation of VOC from the coatings; an d (2) evaporation of VOC from the cleaning materials. To control VOC emissions from metal furniture coatings, the CTG

recommends three options: (1) emission limits that can be achieved through the use of low

- VOC14

coatings; (2) equivalent emission limits t hat can be achieved through the use of low

- VOC coatings or a combination of coatings and add

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

- on controls. The low

- V OC coatings recommendation (Option 1) consists

of emission limits i n terms of mass of VOC per volume of coating, excluding water and exempt compounds, as applied

, and the use of specified application methods. The equivalent emission

limit recommendation (Option 2) consists of emission limits in terms of mass of VOC per

v olume of coating solids, as applied, and the use of specific application methods. Additionally, for cleaning materials, work practices are recommended to reduce VOC emissions.

Specific recommendations for coating operations and cleaning materials used in metal furniture surface coating operations are summarized below:

Emissions Limits Base d on Low

- VOC C oatings

- Option 1

The CTG recommends e mission limits for one

- component and multi

- component general purpose coatings

. In addition, specific emission lim its for certain specialty coatings are recommended. For each of these coating types, separate emission limits are recommended for baked and air

dried coatings. Provided below are the recommended emission limits expressed in terms of mass of VOC per volum e of coating (excluding water and exempt compounds, as applied).

Table 10. Emission Limits (ma ss of VOC per volume of coating excluding water and exempt compounds, as applied) for Metal Furniture Coatings Coatings Type Baked Air Dried kg/l lb/gal kg/l lb/gal General, One Component 0.275 2.3 0.275 2.3
General, Multi

- Component 0.275 2.3 0.340 2.8 Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Performance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatmen t Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

Equivalent Emission Limits Achieved Through the Use of Low

- VOC Coatings or a Combination of Coatings and Add

- on Controls

- Option 2

The recommended emission limits can also be expressed in terms of mass of VOC per volume of coating solids, as applied. A facility could use low

- VOC coatings or a combination of coatings

and add

- on control equipment on a coating unit to meet the recommended mass of VOC per volume of coating solids limits. U sing 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 as follows:15

Table 11. Emission Limits (mass of VOC per volum e of coating solids as applied) for Metal

Furniture Coatings Coating Type Baked Air Dried kg/l lb/gal kg/l lb/gal General, One Component 0.40 3.3 0.40 3.3
General, Multi

- Component 0.40 3.3 0.55 4.5 Extreme High Gloss 0.61 5.1 0.55 4.5

Extreme Performance 0.61 5.1 0.80 6.7

Heat Resistant 0.61 5.1 0.8 0 6.7

Metallic 0.80 6.7 0.80 6.7 Pretreatment Coatings 0.80 6.7 0.80 6.7

Solar Absorbent 0.61 5.1 0.80 6.7

The following types of coatings and coating operations are exempt from the recommended VOC content limits: stencil coatings, safety

- indicating coatings, solid

- film lubricants, electric

insulating and thermal conducting coatings, touch

- up and repair coatings, and coating applications utilizing hand

- held aerosol cans.

The CTG recommend s that all VOC

- containing materials used by each metal furnitur e surface coating unit be included when determining the coating unit’s emission rate. Additionally, the following application methods are recommended: electrostatic application, HVLP spray, flow coat, roller coat, dip coat including electrodeposition, or brush coat.

Optional Add

- On Controls

- Option 3

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 equi pment to meet an overall efficiency of 90 percent. Alternatively, a facility could use a combination of coatings and add

- on control equipment on a coating unit to meet the recommended mass of VOC per volume of coating solid limits.

Work Practices for Coa ting Operations and Cleaning Materials

Work practices to further reduce emissions from the coatings as well as minimize emissions from cleaning materials used for large appliance coating operations are recommended, and they are:

store all VOC

- containing coatings, thinners, and cleaning materials in closed containers; minimize spills of VOC

- containing coatings, thinners, and cleaning materials; clean up spills immediately; convey any coatings, thinners, and cleaning materials in closed containers or pipes; close mixing vessels that contain VOC coatings and other materials

, except when in use; and minimize usage of solvents during cleaning of storage, mixing, and conveying of equipment.

Surface Coating of Large Appliances CTG (EPA 453/R

- 07

- 004, September 20 07)

In December 1977, EPA published CTGs for large appliance coatings (EPA

- 450/2

- 77

- 034), and surface coating s of metal furniture (EPA

- 450/2

- 77

- 032)

. In October 1982, EPA promulgated the NSPS for industrial surface coating of large appliances, and in 200 2, EPA promulgated the16

NESHAP for large appliances

. After reviewing the 1977 CTG, the 1982 NSPS, the 2002 NESHAP, and existing s tate and local VOC emission reduction approaches

, and considering information obtained since issuance of the 2002 NESHAP, EPA d eveloped a new CTG for the surface coating of large appliances, entitled, “Control Technique Guidelines for Large Appliance Coatings” (EPA 453/R

- 07

- 004, September 2007).

Large appliance coatings include, but are not limited to , materials referred to as pa int, topcoats, basecoats, primers, enamels, and adhesives used in the manufacture of large appliance parts or products. A large appliance part is defined as any organic surface

- coated metal lid, door, casing, panel, or other interior or exterior part or a ccessory that is assembled to form a large appliance product. A large appliance product is also defined as any organic surface

- coated metal range, oven, microwave, refrigerator, freezer, washer, dryer, dishwasher, water heater, or trash compactor manufact ured for household, commercial, or recreational use.

The coating application methods used are typical of surface coating operations in many industries, and include air atomized spraying, dip coating, electrodeposition, and flow coating.

VOC emissions fro m large appliance coating processes result from the evaporation of the components of the coatings and cleaning materials.

Applicability

The September 2007 CTG provides control recommendations for reducing VOC emissions stemming from the use of coatings i n large appliance coating operations. Coatings include paints, sealants, caulks, inks, adhesives, and maskants. The CTG provides recommendations for reducing VOC emissions from the use of coatings applied to each large appliance coating unit at

a facilit y where the total actual VOC emissions from all large appliance coating operations, including related cleaning activities, at that facility are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as three (3) tons per 12

- month rolling pe riod, before consideration of

controls. States can adopt the above recommended 15 lb/day actual VOC emissions or an equivalent applicability threshold, or they can develop other applicability criteria that they determine are appropriate considering the fa cts and circumstances of the sources in their particular nonattainment areas.

Sources of VOC Emissions

Primarily, VOC emissions from large appliance coating operations result from the evaporation of the components of the coatings and cleaning materials. The primary VOC emissions from large appliance coatings occur during coating application (prime, single or topcoat application), flash

off and drying/curing of the coatings. The remaining emissions are primarily from mixing

a nd/or thinning. In most case s, VOC emissions from storage, handling, and waste/wastewater operations related to coating operations are relatively small.

Coating Application

Surface coating of large appliances is applied by applying a coating to the large appliance. After being coa ted by any of the typical coating methods (spray coating or dip coating), the large17

appliance products are cured using heated dryers or allowed to air dry. This step removes any remaining volatiles from the coating so that the surfaces of the large applia nce product meet the hardness, durability, and appearance requirements of the customers. Coating mixing may be performed in an agitated drum or it may be performed by merging two different coating supply lines into one. Coating mixing is typically perfor med by the coating manufacturer prior to shipment to a large appliance manufacturer’s facility. Some facilities add water or solvent to the coating (thinning), which may be performed in a small mixing booth or it may be automated.

Some facilities combine reclaimed coating from various coating operations and mix the different coatings together in a drum. Mixing also varies depending upon the type of coating and usage requirements.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from large furniture surface coating operations: (1) evaporation of VOC from the coatings; and (2) evaporation of VOC from the cleaning materials. To control VOC emissions from large appliance coatings, the CTG

recommends three o ptions: (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 combination of coatings and add

- on controls; and (3) an overall control effi ciency of 90 percent for add

- on controls. The low VOC coatings recommendation consists of emission

limits in terms of mass of V OC per volume of coating, excluding water and exempt compounds,

as app l ied

, and the use of specified application methods. The e quivalent emission limit recommendation consists of emission limits in terms of mass of VOC per volume of coating solids, as applied, and the use of specific application methods. Additionally, for cleaning materials, work practices are recommended to redu ce VOC emissions.

Specific recommendations for coating operations and cleaning materials used in large furniture surface coating operations are summarized below:

Emission Limits Based on Low

- VOC Coatings

- Option 1

Emission limits for one

- component and multi

- component g eneral p u rpose coatings are

recommended. In addition, specific emission limits for certain specialty coatings are recommended. For each of these coating types, separate emission limits are recommended for

baked and air

- dried coatings. P rovided below are the CTG

- recommended emission limits expressed in terms of mass of VOC per volume of coating, excluding water a nd exempt compounds, as applied.

Table 12: Recommended Emission Limits (mass of VOC per volume of coating) Excluding

Water and Exempt Compounds, as Applied Coating Type Baked Air Dried kg/l lb/gal kg/l lb/gal General, One Component 0.275 2.3 0.275 2.3
General, Multi

- Component 0.275 2.3 0.340 2.8 Extreme High Gloss 0.360 3.0 0.340 2.8

Heat Resistant 0.360 3.0 0.420 3.518

Meta llic 0.420 3.5 0.420 3.5 Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

Emission Limits in Mass of VOC Per Volume of Coatings Solids, as Applied

- Option 2

The recommended emission limits can also be expressed in terms o f mass of VOC per volume of coating solids, as applied. A facility could use low

- VOC coatings or a combination of coatings

and add

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

follows:

Table 1 3 : Recommended Emission Limits (mass of VOC per volume of coating solids) for Large Appliance Coa tings Coating Type Baked Air Dried kg/l lb/gal kg/l lb/gal General, One Component 0.40 3.3 0.40 3.3
General, Multi

- Component 0.40 3.3 0.55 4.5 Extreme High Gloss 0.61 5.1 0.55 4.5

Extreme Performance 0.61 5.1 0.80 6.7

Heat Resistant 0.61 5.1 0.80 6. 7

Metallic 0.80 6.7 0.80 6.7 Pretreatment Coatings 0.80 6.7 0.80 6.7

Solar Absorbent 0.61 5.1 0.80 6.7

The CTG recommends that the following types of coatings be exempt from the recommended VOC content limits: stencil coatings, safety

- indicating coat ings, solid

- film lubricants, electric

insulating and thermal

- conducting coatings, touch

- up and repair coatings, and coating application utilizing hand

- held aerosol cans.

The CTG also recommend s that all VOC

- containing materials used by each large applianc e surface coating unit be included when determining the coating unit’s emission rate. Additionally, the following application methods are recommended: electrostatic application, high volume/low pressure (HVLP) spray, flow coat, roller coat, dip coat incl uding electrodeposition, or brush coat.

O ptional Add

- On Controls for Coating Operations

- Option 3

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 to meet an o verall efficiency of 90 percent. Alternatively, a facility could use a combination of coatings and add

- on control equipment on a coating unit to meet the recommended mass of VOC per volum e of coating solids on a coating unit to meet the recommended mass of VOC per volume of coating solids limits. Add

- on devices include oxidizers and solvent recovery systems that, coupled with their attendant systems to capture the19

VOC being released at th e affected facilities, can achieve an overall control efficiency of 90 percent. This control option, like the options noted above, applies to all coatings and thinners applied to large appliances.

Work Practices for Coating Operations and Cleaning Materi als

Work practices to further reduce emissions from the coatings as well as minimize emissions from cleaning materials used for large appliance coating operations are recommended, and they are:

store all VOC

- containing coatings, thinners, and cleaning ma terials in closed containers; minimize spills of VOC

- containing coatings, thinners, and cleaning materials; clean up spills immediately; convey any coatings, thinners, and cleaning materials in closed containers or pipes; close mixing vessels that contain VOC coatings and other materials except when in use; and minimize use of solvents during cleaning of storage, mixing, and conveying of equipment.

B. STATE SUBMITTAL

On April 1, 2010, Delaware Department of Natural Resources and Environmental Control ( D NREC ) submitted SIP revision s to EPA adoptin g the requirements of EPA ’s CTGs for plastic parts, metal furniture, larg e appliances, and miscellaneous metal parts. On March 9, 2012

, Delaware submitted a revision to its April 1, 2010 submittal to correct non

- substantive

administrative er rors , and to include EPA approval

, as well as the Department’s for any alternative coating application method that is not one of the of the application methods explicitly specified in the regulations

. EPA develops CTGs as gu idance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. DNREC is adopting EPA’s CTG standards for the coating of miscellaneous metal and plastic parts, metal furniture,

and lar ge appliances, a nd incorporating them into their Regulation 1124, Control of Volatile Organic Compounds

- s ection s 12.0, 19.0, 20.0, and 22.0. Listed below is a summary of

Delaware’s SIP revision s to Regulation 1124.

I. Revisions to s ection 2.0

, Definitions

The revisions to s ection 2.0, “Definitions,” add the following definitions used in the substantive provisions of this regulation and in multiple sections of other Delaware air quality regulations.

Adhesion primer

- means a coating that is applied to thermoplastic olef in (TPO) parts to promote adhesion of subsequent coatings. An adhesion primer is clearly identified as an adhesion primer or adhesion promoter on its accompanying material safety data sheet.

Aerosol coating product

- means a pressurized coating product co ntaining pigments of resins that dispense product ingredients by means of a propellant and is packaged in a disposable can for

hand

- held application, or for use in speciali zed equipment for ground traffic marking applications.

Air

- dried coating

- means a c oating that is cured at a temperature below 90 o C (194o F).

Baked coating

- means a coating that is cured at a temperature at or above 90o C (194o F).20

Dip coating

- means the application method of a coating material to a substrate by dipping the part int o a tank of coating material.

Electric

- insulating and thermal

- conducting coating

- means a coating that displays an electrical insulation of at least 1000 volts DC per mil on a flat test plate and an average thermal conductivity of at least 0.27 BTU per ho ur

- foot

- degree Fahrenheit.

Electrostatic spray

- means a method of applying a spray coating in which opposite electric charges are applied to the substrate and the coating. The coating is attracted to the substrate by the electrostatic potential between th em.

Extreme high

- gloss coating

- means a coating which, when tested by ASTM International Method

D

- 523, adopted in 1980, shows a reflectance of 75 or more on a 60o meter.

Extreme performance coating

- means a coating used on a metal surface where the coate d surface is, in its intended use, subject to the following: (a) chronic exposure to corrosive, caustic or acidic agents, chemicals, chemical fumes, chemical mixtures or solutions; or (b) repeated exposure to temperatures in excess of 250oF or (c) repeate d heavy abrasion, including

mechanical wear

, and repeated scrubbing with industrial grade solvents, cleansers o r scouring

agents.

Flow coating

- means the application of a coating material to a substrate by pouring the coating over the suspended part.

Han d application

- means a method of applying coatings by non

- mechanical hand

- held equipment including, but not limited to, paint brushes, hand rollers, caulking guns, trowels, spatulas, syringe daubers, rags and sponges.

Heat resistant coating

- means a coati ng that must withstand a temperature of at least 400oF during normal use.

High

- volume, low

- pressure (HVLP) spray equipment

- means spray equipment that is used to apply coatings using a spray gun that operates less than or equal to 10 psig of atomized air pressure at the air cap.

Metallic coating

- means a coating which contains more than 5 grams of metal particles per liter of coating, as applied. Metal particles are pieces of a pure elemental metal or a combination of

elemental metals.

Mold

- seal coating

- means the initial coating applied to a new mold or a repaired mold to provide a smooth surface which, when coated with a mold release coating

, prevents products from sticking to the mold.

O ne

- component coating

- means a coating that is ready for applicat ion as it comes out of its container to form an acceptable dry film. A thinner, necessary to reduce the viscosity, is not considered a component.21

Pretreatment coating

- means a coating which contains no more than 12 % solids by weight, and at

least 0.5% ac id by weight, is used to provide surface etching, and is applied directly to metal surfaces to provide corrosion resistance, adhesion, and ease of stripping.

Repair coating

- means a coating used to re

- coat portions of a previously coated product which

has sustained mechanical damage to the coating foll owing normal coating operations.

Safety

- indicating coatings

- means a coating which changes physical characteristics, such as color, to indicate unsafe conditions.

Solar

- absorbent coating

- means a coating whi ch has as its prime purpose the absorption of solar

radiation.

Solid

- film lubricant

- means a very thin coating consisting of a binder system containing as its chief pigment material one or more of molybdenum disulfide, graphite, polytetraflouroethylene (P TFE) or other solids that act as a dry lubricant between faying surfaces.

Stencil coating

- means a coating which is rolled or brushed onto a template or stamp in order to add identifying letters, symbols or numbers.

Touch

- up coating

- means a coating used to cover minor coating imperfections appearing after the main coating operation.

Two

- component paint

- means a coating that is manufactured in two components that are mixed shortly before use. When mixed, the two liquids rapidly crosslink to form a solid composition.

Vacuum

- metalizing coating

- means the undercoat applied to the substrate on which the metal is deposited or the overcoat applied directly to the metal film. Vacuum metalizing/physical/physical vapor deposition (PVD) is the process whereby met al is vaporized and deposited on a substrate in a vacuum chamber.

II. Revisions to Section 12.0, Surface C oating of Plastic Parts

D NREC has individual regulations for the CTG recommendations contained in the EPA combined CTG entitled, “Control Technique Guid elines for Miscellaneous Metal and Plastic Parts Coatings,” dated September 2008. Section 12.0 of Delaware’s Regulation 1124 pertains to the control of VOC from the surface coating of plastic parts, and s ection 22.0 pertains to the

control of VOC from the surface coatings of miscellaneous metal parts. A summary of Delaware’s revised regulations can be found below.

A pplicability

T he provisions of this section apply to any plastic parts or products coating unit

. Every owner or operator of any plastic par ts or products coating unit shall comply with this section on and after April 11, 2010. A transition period exists for sources that h ave been previously permitted.

E very owner or operator of any plastic parts or products coating unit that has a permit is sued22

pursuant to 7 DE Admin Code 1102 or 1130 containing all applicable conditions of section 12.0 of this regulation as that regulation existed on November 29, 1994, needs to comply with those permit condi tions until December 31, 2010. On and after Janua ry 1, 2011, every such owner or operator of any plastic parts or products coating unit shall comply with the provisions of 12.0 of this regulation. The provisions of this section do not apply to plastic parts or products coating

facilities whose actual em issions, without control devices, from all plastic parts or products coating units, including emissions from related cleaning activities, are less than 6.8 k g, 15 lb s of VOC per day. An owner or operator of a facility whose emissions are below th is applic ability threshold shall comply with the certification, recordkeeping and reporting requirements of this

section. The provisions of s ection 12.0 do not apply to parts covered by other sections of this regulation, exterior parts of completely assembled mari ne vessels, and internal electrical parts of business and commercial machines, including, but not limited to, medical and entertainment equipment. If a metal component that is permanently attached to a plastic part is coated in a spray booth or on a proce ss line where plastic parts or products are being coated, the requirements of this section apply to the coating of both the plastic part and the attached metal

component.

Definitions

T he revisions to s ection 12. 0 add the following definitions:

Black coa ting

- means a coating which meets a maximum lightness of 23 units, and has a saturation of less than 2.8, where saturation equals the square root of A 2 + B 2 . These criteria are based on Cielab color space, 0/45 geometry. For spherical geometry, specular included, the maximum lightness is 33 units.

Business machine

- means a device that uses electronic or mechanical methods to process

i nformation, perform calculations, print or copy information or convert sound into electrical impulses for transmission, i ncluding devices listed in standard industrial classification numbers 3572, 3573, 3574, 3579, and 3661 and photocopy machines, a subcategory of standard industrial

classification number 3861.

Commercial machine

- means a device that is used in commercial a ctivities, including, but not limited to, medical, laboratory and entertainment equipment.

Electric dissipating coating

- means a coating that rapidly dissipates a high

- volume electric charge.

Electrostatic preparation coating

- means a coating that is app lied to a plastic part solely to provide conductivity for the subsequent application of a prime, a topcoat, or other coating through the use of electrostatic a pplication methods. An electrostatic prep coat is clearly identified as an electrostatic prep co at on its accompanying material safety data sheet.

Fog coat

- means a coating that is applied to a plastic part for the purpose of color matching without masking a molded

- in texture. A fog coat shall not be applied at a thickness of more than

0.5 mils of coating solids.23

Gloss reducer

- means a coating that is applied to a plastic part solely to reduce the shine of the part. A gloss reducer shall not be applied at a thickness of more than 0.5 mils of coating solids. Mask coating

– means a thin film coating a pplied through a template to coat a small portion of a

substrate.

Military specification coating

- means a coating which has a formulation approved by a United States military agency for use on military equipment.

Optical coating

- means a coating applied to an optical lens.

Red coating

- means a coating which meets all of the following criteria: yellow limit, the hue of hostaperm scarlet; blue limit, the hue of monastral red

- violet, lightness limit for metallics; 35%

aluminum flake; lightness limit for so lids, 50% titanium dioxide white; solid reds, hue angle of

- 11 to 38 degrees and maximum lightness of 23 to 45 units; metallic reds, hue angle of

- 16 to 35 degrees and maximum lightness of 28 to 45 units. These criteria are based on Cielab color space, 0/ 45 geometry. For spherical geometry, specula included, the upper limit is 49 units. The maximum lightness varies as the hue moves from violet to orange. This is a natural consequence of the strength of the colorants, and real colors show this effect.

T exture coat

- means a coating that is applied to a plastic part which, in its finished form, consists of discrete raised spots of the coating.

Translucent coating

- means a coating which contains binders and pigment, and is formulated to form a colored, but not opaque, film.

The revisions to section 12.0 revise the following definitions:

Basecoat/clearcoat

– means a two

- step topcoat system in which a highly pigmented, often metallic, basecoat is followed by a clearcoat, resulting in a finish with high

- gloss characteristics.

EMI/RFI (electromagnetic interference/radio frequency interference shielding coating

- means a coating that is used in a plastic business or commercial machine housing to attenuate electromagnetic and radio frequency interference signals t hat would otherwise pass through the plastic housing.

Flexible primer

- means any coating that is required to comply with engineering specifications for impact resistance, mandrel bend, or elongation as defined by the original equipment

manufacturer.

Nonfl exible primer

- means a paint that cannot withstand dimensional changes.

Plastic part or product

- means a piece made from a substance that has been formed from resin through the application of pressure or heat. Plastic parts or products include automotive o r other transportation equipment including, but not limited to, parts or products for automobiles, trucks (light, medium, and heavy

- duty), large and small farm machinery, motorcycles, recreational vehicles, construction equipment, vans, buses, lawnmowers a nd other motorized mobile24

equipment; business and commercial machines, including, but not limited to, computers, copy machines, typewriters, medical equipment, laboratory equipment and entertainment equipment;

and commercial and industrial machinery, sport ing goods, toys, lawn and garden equipment and other industrial and household products.

Specialty coating

- means a coating that is used for unusual job performance requirements, usually in small amounts. These products include but are not limited to adhes ion primers, resist coatings, soft coatings, reflective coatings, electrostatic prep coatings, headlamp lens coatings, ink pad printing coatings, stencil coatings, texture coatings (automotive), vacuum metalizing coatings, and gloss flatteners.

As a resu lt of comments received at a public hearing held on January 5, 2010, a new definition for “specialty coating” was added and the term,”hand

- held aerosol cans” was changed to “aerosol coating product.” A definition for the term “aerosol coating product” ha s been added to section 12.0, “Definitions,” since other Regulation 1124 sections and other existing Delaware regulations also use this term.

The revisions to section 12.0 delete the following definitions: add

- on controls, adhesion promoter (primer), aff

ected facility, aftermarket automobile, overspray, two

- component paint, and waterborne coating.

Standards

Except as noted in the exemptions listed below, n o owner or operator of a plastic parts or products coating unit subject to s ection 12.0 of this reg ulation may cause or allow the application of any coating to plastic parts or products unless:

1. The VC content of the coating is less than or equal to the limits listed in Table 14 below , or

2. For a plastic parts or products coating unit that applies mu ltiple coatings, which are subject to

the same numerical emission limits in Tabl e 14

, the daily

- weighted average VOC content is less than or equal to the limit in Table 1 4 corresponding to the category of coating used, or

3. Control equipment is installed an d operated that achieves an emission reduction efficiency in accordance with this regulation. The application requirements below do not apply to any plastic parts or products coating unit that achieves an emission reduction efficiency of 95% or greater.

4. Except as provided in number 3 above and in the sp ecific exemptions listed below, no owner or operator of a plastic parts or products coating unit subject to section 12.0 of this regulation shall apply a coating to plastic parts or products unless the coat ing is applied with equipment properly operated and maintained according to the manufacturer’s suggested guidelines and using one or more of the following coating application methods. a) Electrostatic spray b) Flow coating c) Dip coating, including electrodepositio n d) Roll coating25

e) High

- volume, low pressure (HVLP) spray f) Hand application g) An alternative method demonstrat ed to be capable of achieving a transfer efficiency equal to or better than HVLP spray and approved by the Department and EPA.

Table 14 : Plastic Parts Coating Voc Content Limits

- VOC content limits are expressed as mass kg or lb per volume l or ga l of coating less water and exempt compounds, as applied. Coating Category kg VOC/l coating l b VOC/gal coating

General* One component coating 0.28 2.3

Multi

- component coating 0.42 3.5 Electric dissipating coatings and

shock

- free coatings 0.36 3.0 Extreme performance 0.42 (2 pack) 3.5 (2 pack)

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 Multicolored coatings 0.68 5.7 Optical coatings 0.80 6.7

Vacuum

- metalizing 0.80 6.7

Business Machine Parts

Primers 0.14 1.2 Topcoat 0.28 2.3

Texture coat 0.28 2.3 Fog coat 0.26 2.2 Touchup and repair 0.28 2.3

Clearcoats 0.28 2.3

EMI/RFI coati ngs 0.48 4.0 Soft coatings 0.52 4.3 Plating resist coatings 0.71 5.9 Plating sensitizer coatings 0.85 7.1 Automotive/Transportation Parts High bake coatings Flexible primer 0.46 3.8

Non

- flexible primer 0.42 3.5

Base coats 0.52 4.3

Clear coat 0.48 4.0

Non

- basecoat/clear coat 0.52 4.3

Interior colorcoat 0.49 4.1

Exterior colorcoat 0.55 4.6 Low bake/air dried coatings

- exterior

Primers 0.58 4.8

Basecoat 0.60 5.0

Clearcoats 0.54 4.526

Non

- basecoat/clearcoat 0.60 5.0

Red and black colorcoats 0.67 5.6

All other colorcoats 0.61 5.1 Low bake/air dried coatings Interior primers 0.42 3.5

Colorcoats 0.38 3.2 Touchup and repair coatings 0.62 5.2 Auto specialty Vacuum metalizing basecoats 0.66 5.5 Texture coatings 0.66 5.5 Reflective argent co atings 0.71 5.9 Soft specialty coatings 0.71 5.9 Air bag cover coatings 0.71 5.9

Gloss flatteners 0.77 6.4 Vacuum metalizing topcoats 0.77 6.4 Texture topcoats 0.77 6.4 Stencil coatings 0.81 6.8 Adhesion primers 0.81 6.8 Ink pad printing coatings 0 .81 6.8 Electrostatic prep coats 0.81 6.8 Resist coatings 0.81 6.8 Headlamp lens coatings 0.89 7.4 *General refers to those parts or products which are not Business Machine Parts or Automotive/Transportation Parts.

Based on comments received on its pr oposed regulation, DNREC made the following changes

from its proposed regulation to its final r egulation.

1. Ch anged Table 14 in its final submittal from its proposed regulation by delet ing the following note applicable to “Automotive/Transportation Parts:” (Note: for red, yellow, and black automotive coatings, except touch up and repair coatings, the allowable limit is determined by multiplying the appropriate limit in this table by 1.15). Although this language is contained in EPA’s CTG for Plastic Parts, including i t in Delaware’s VOC limits would make the proposed limits less stringent than the current limits for colo r coats. As a result, in its final regulation,

Delaware has reverted the language back to its existing regulatory language

.

The SIP revis ion also amends section 12.0 in order to: (1) establish exemptions, (2) establish control devices, and (3) establish test methods, compliance certification, recordkeeping, and reporting requirements based on EPA CTGs.

III. Revisions to Section 19.0, Coating o f Metal Furniture

Applicability

The provisions of this section apply to any metal furniture coating unit

. Every owner or operator of any metal furniture coating unit shall comply with this section on and after April 11, 2010. A27

transition period exist s for sources that have been previously permitted. Every owner or operator of any plastic parts or products coating unit that has a permit issued pursuant to 7 DE Admin Code 1102 or 1130 containing all applicable conditions of section 19.0 of this regulat ion as that regulation existed on January 11, 1993, needs to comply with those permit conditions until December 31, 2010. On and after January 1, 2011, every such owner or operator of any metal furniture coating unit shall comply with the provisions of 19 .0 of this regulation. The provisions of this section do not apply to any metal furniture coating unit within a facility whose actual emissions without control devices from all metal furniture coatings units within the facility, including emissions from r elated cleaning activities, are less than 6.8 kg 15 lb of VOC per day. An owner or operator of a facility whose emissions are below the applicability threshold described above shall comply with the certification, recordkeeping and reporting requirements o f

this section.

Definitions

The revisions to s ection 19 revise the definition of Metal furniture to include “fixtures, lamps, and

l ighting units

.

As a result of comments received at its public hearing, Delaware revised the term “hand

- held

aerosol cans ” to “Aerosol coating product.” A definition for the term “Aerosol coating product” has been added to Section 2.0, Definitions, since other Regulation 1124 sections and other existing Delaware air regulations also use this term.

Standards

No owner or op erator of a metal furniture coating unit subject to this section shall allow the application of any coating to metal furniture unless:

1. The VOC content of the coating is less than or equal t o the limits listed in Table 15 below , or

2. For a metal furniture c oating unit that applies multiple coatings, which are subject to the same

emission limit in Table 15 , the daily

- weighted average VOC content, is less than or equal to the

limit in Table 15 corresponding to the category of coating used, or

3. Control equipmen t is installed and operated that achieves an emission reduction efficiency in accordance with the provisions for control devices as specified below. The application requirements described below shall not apply to any metal furniture coating unit that achi eves an emission reduction efficiency of 95 percent or greater.

Table 15: Metal Furniture Coating VOC Content Limits

- (VOC content limits are expressed as mass (either kg or lb) per volume (either l or gal) of coating less water and exempt compounds, as applied

Coating Category Baked Air Dried

k g VOC/l coating lb VOC/gal

coating k g/VOC/l

coating lb/VOC/gal

coating
General, one

- component 0.275 2.3 0.275 2.328

General, multi

- component 0.275 2.3 0.340 2.8 Extreme, high

- gloss 0.360 3.0 0.340 2.8

Extreme performance 0.360 3.0 0.420 3.5

Heat

- resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment 0.420 3.5 0.420 3.5

Solar

- absorbent 0.360 3.0 0.420 3.5

No owner or operator of a metal furniture coating unit subject to this section shoul d apply a coating to metal furniture unless the coating is applied with equipment properly operating and maintained according to the manufacturer’s suggested guidelines and using one or more of the following coating application methods:

1. Electrostatic spra y 2. Flow coating.

3. Dip coating, including elec t rodeposition.

4. Roll coating.

5. High

- volume, low

- pressure (HVLP) spray.

6. Hand application.

7. A n alternative method that is demonstrated to be capable of achieving a transfer efficiency equal to or better than HVLP spray and approved by the Department and EPA.

Note: Touch

- up and Repair coatings are exempt from the application methods of this section.

The SIP revision also amends section 19.0 in order to: (1) establish exemptions, (2) establish control devices, and (3) establish test metho ds, compliance certification, recordkeeping, and reporting requirements based on EPA CTGs.

IV. Revisions to Section 20.0 Coating of Large Appliances

Applicability

The provisions of this section apply to any large appliance coating unit. Every owner or operator of any metal furniture coating unit shall comply with this section on and after April 11, 2010. A transition period exists for sources that have been previously permitted. Every owner or operator of any plastic parts or pr oducts coating unit that has a permit issued pursuant to 7 DE Admin Code 1102 or 1130 containing all applicable conditions of this section of this regulation as that regulation existed on January 11, 1993, needs to comply with those permit conditions until December 31, 2010. On and after January 1, 2011, every such owner or operator of any metal furniture coating unit shall comply with the provisions of 19.0 of this regulation. The provisions of this section do not apply to any large appliance coating uni t within a facility whose actual emissions without control devices from all large appliance coating units within the facility, including related cleaning activities, are less than 6.8 kg, 15 lb of VOC per day. An owner or operator of a facility whose emis sions are below th is applicability threshold described above shall comply with the certification, recordkeeping and reporting requirements of this section.29

D efinitions

The definition for “Large appliance” has been revised to read as follows:

Large app liance

- means any residential or commercial washer, dryer, range, oven, microwave oven, refrigerator, freezer, water heater, dishwasher, trash compactor, air conditioner, or other similar products under North American Industry Classification System Code 33 522.

As a result of comments received at its public hearing, Delaware revised the term, “hand

- held aerosol cans” to “Aerosol coating product.” A definition for the term “aerosol coating product” has been added to Section 2.0, Definitions, since other Reg ulation 1124 sections and other existing Delaware air regulations also use this term.

Standards

No owner or operator of a large appliance coating unit subject to this section shall allow the application of any coating to large appliances unless:

1. The VOC content of the coating is less than or equal to the limits in Table 16 below or

2. For a large appliance coating unit that applies multiple coatings, which are subject to the

same numerical emission limitation in Table 16 , the daily

- weighted average VOC con tent, is less than or equal to the limit in Table 16 of this section corresponding to the category of coating used, or

3. C ontrol equipment is installed and operated that achieves an emission reduction efficiency in accordance with the control devices provis ion of this regulation as specified below. The application requirements described below do not apply to any metal furniture coating unit that achieves an emission reduction efficiency of 95 percent or greater.

Table 16: Large Appliance Coating VOC Conte nt Limits

- VOC Content Limits are expressed as mass (either kg or lb) per volume (either l or gal) of coating less water and exempt compounds, as applied

Coating Category Baked Air Dried Kg VOC/l coating lb VOC/gal

coating kg VOC/l

coating lb VOC/gal

coating
General, one

- component 0.275 2.3 0.275 2.3
General, multi

- component 0.275 2.3 0.340 2.8 Extreme high

- gloss 0.360 3.0 0.340 2.8 Extreme performance 0.360 3.0 0.420 3.5

Heat

- resistance 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatm ent 0.420 3.5 0.420 3.5

Solar

- absorbent 0.360 3.0 0.420 3.530

No owner or operator of a metal furniture coating unit subject to this section should apply a coating to metal furniture unless the coating is applied with equipment properly operated and

main tained according to the manufacturer’s suggested guidelines and using one or more of the following coating application methods:

1. Electrostatic spray

. 2. Flow coating.

3. Dip coating, including electrodeposition.

4. Roll coating.

5. High

- volume, low

- pressure (HVLP) spr ay.
6. Hand application.

7. A n alternative method that is demonstrated to be capable of achieving a transfer efficiency equal to or better than HVLP spray and approved by the Department and EPA.

The SIP revision al so amends section 20 .0 in order to: (1) establ ish exemptions, (2) establish control devices, and (3) establish test methods, compliance certification, recordkeeping, and reporting requirements based on EPA CTGs.

IV. Revisions to Section 22.0 Coating of Miscellaneous Metal Parts

Applicability

The provi sions of this section apply to any miscellaneous metal parts and products coating unit. Every owner or operator of any miscellaneous metal parts and products coating unit shall comply with this section on and after April 11, 2010. A transition period exi sts for sources that have been previously permitted. Every owner or operator of any miscellaneous metal parts and products coating unit that has a permit issued pursuant to 7 DE Admin Code 1102 or 1130 containing all applicable conditions of this section of this regulation as that regulation existed on January 11, 1993, needs to comply with those permit conditions until December 31, 2010. On and after January 1, 2011, every such owner or operator of any miscellaneous metal parts and products coating unit, shall comply with the provisions of 22.0 of this regulation. The provisions of this section do not apply to any miscellaneous metal parts and products coating unit within a facility whose actual emissions without control devices from all large appliance coating units within the facility, including related cleaning activities, are less than 6.8 kg, 15 lb of VOC per day. An owner or operator of a facility whose emissions are below this applicability threshold described above shall comply with the certifica tion, recordkeeping and reporting requirements of this

section

.

Definitions

The revisions to section 22.0 delete the following definitions: Air dried coating, b aked coating

, clear coating, extreme environmental conditions, extreme performance coatings, and refinishing.

The revisions add the following definitions:

Camouflage coating

- means a coating used principally by the military to conceal equipment from31

detection.

Electric

- insulating varnish

- means a non

- convertible

- type coating applied to electric motors, components of electric motors or power transformers, to provide electrical, mechanical and environmental protection or resistance.

Etching filler

- means a coating that contains less than 23 % solids by weight and at least 0.5 percent acid by weigh t and is used instead of applying a pretreatment coating followed by a primer.

High

- performance architectural coating

- means a coating used to protect architectural subsections and which meets the requirements of the Architectural Aluminum Manufacturer As sociations publication number AAMA 2604

- 05a (Voluntary Specification, Performance Requirements and Test Procedures for High Performance Organic Coatings on Aluminum Extrusions and Panels) or

2605

- 05 (Voluntary Specification Performance Requirements and Tes t Procedures for Superior Performing Organic Coatings on aluminum Extrusions and Panels).

High

- temperature coating

- means a coating that is certified to withstand a temperature of 1000°F

for 24 hours.

Military specification coating

- means a coating which has a formulation approved by a United States military agency for use on military equipment.

Pail

- means any cylindrical metal shipping container of 1 to 12

- gallon capacity and constructed of

29

- gauge and heavier material.

Pan

- backing coating

- means a c oating applied to the surface of pots, pan s , or other cooking implements that are exposed directly to a flame or other heating elements.

Prefabricated architectural component coating

- means a coating applied to a metal part and product which is to be used as an architectural structure.

Silicone

- releasing coating

- means a coating which contains silicone resin and is intended to prevent food from sticking to metal surfaces such as baking pans.

The revisions revise the following definitions:

Drum

- means any cylindrical metal shipping container larger than 12 gallons capacity, but no larger than 110 gallons capacity.

Miscellaneous metal parts and products coating unit

- (deleted provision #8 from the definition).

Due to public comments received at its public h earing, Delaware revised the term, “hand

- held

aerosol cans” to “ Aerosol coating product.” A definition for the term “aerosol coating product” has been added to Section 2.0, Definitions, since other Regulation 1124 sections and other existing Delaware air regulations also use this term.32

Standards

No owner or operator of a miscellaneous metal parts and products coating unit subject to this section shall cause or allow the application of any coating to miscellaneous metal parts and products unless:

1. The VOC content of the coating is less than or equal to the limits in Table 17 below, or

2. For a miscellaneous metal parts and products coating unit that applies multiple coatings, which are subject to the same numerical emission limitation in Table 17 below, the daily

weighted average VOC content, is less than or equal to the limit in Table 17 corresponding to the category of coating used, or

3. Control equipment is installed and operated that achieves an emission reduction efficiency in accordance with the stipul ations in this section. The application requirements described below shall not apply to any metal parts and products coating unit that achieves an emission reduction efficiency of 95 percent or greater.

No owner or operator of a miscellaneous metal parts and products coating unit subject to this section shall apply a coating to miscellaneous metal parts and products unless the coating is applied with equipment properly operated and maintained according to the manufacturer’s suggested guidelines and using one or more of the following coating application methods:

1. Electrostatic spray.

2. Flow coating.

3. Dip coating, including electrodeposition.

4. Roll coating.

5. High

- volume, low

- pressure (HVLP) spray.

6. Hand application.

7. An alternative method that is demonstrated to be capable of achieving a transfer efficiency equal to or better than HVLP spray and approved by the Department and

EPA.

The following types of coatings are exempt from the application methods of this section:

1. Texture coatings

2. Repair and Touch

- up coatin gs.

Table 17: Metal Parts and Products Coating VOC Content Limits

- VOC con t ent limits are expressed as mass (either kg or lb) per volume (either l or gal) of coating less water and exempt compounds, as applied

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 2.333

Camouflage 0.42 3.5 0.36 3.0 Electric Insulating Varnish 0.42 3.5 0.36 3.0 Electric Insulating and

Ther mal Conducting Coatings 0.42 3.5 0.36 3.0

Etching Filler 0.42 3.5 0.36 3.0 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 0.42 3.5 0.36 3.0

High Temperature 0 .42 3.5 0.36 3.0 Magnetic Data Storage Disc Coatings 0.42 3.5 0.36 3.0

Metallic 0.42 3.5 0.36 3.0 Military Specification 0.34 2.8 0.28 2.3

Mold Seal 0.42 3.5 0.36 3.0 Pan Backing 0.42 3.5 0.36 3.0

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 Coatings 0.42 3.5 0.36 3.0 Repair and Touch Up 0.42 3.5 0.36 3.0 Safety Indicating Coatings 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

Solid

- Film Lubricant 0.42 3.5 0.36 3.0 Stencil Coatings 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 0.36 3.0

Drum Coating, reconditioned, Interior 0.50 4.2 0.50 4.2

Based on comments received on its proposed regulation, DNREC made the following changes

from its proposed rule to their final rules that are reflected in its final regulation.

1. De leted the following exemptions from the VOC content and application method requirements: Stencil Coatings, Safety Indicating Coatings, Solid

- Film Lubricant, Electric Insulating and Thermal Conducting Coatings, and Magnetic Data Storage Disc Coatings. The se coating category exemptions, which are listed in the CTG, were inadvertently added to the34

proposed regulation, despite the fact that the current section 22.0 subjected these coatings to a VOC limit of 3.0 lb/gal (i.e., the limit applicable to “All other coatings”). This proposed change makes the proposed regulation less stringent than the current version

— a condition called “backsliding.” The Department proposes to correct this by withdrawing these proposed new exemptions, and maintaining the existing a llowable VOC content limits ( see #2 below).

2. Changed Table 17 to maintain the VOC content limits that currently exist for the following coating categories: Stencil Coatings, Safety Indicating Coatings, Solid

- Film Lubricant, Electric Insulating and Thermal Conducting Coatings, Magnetic Data Storage Disc Coatings.

The SIP revision also amends section 2 2 .0 in order to: (1) establish exemptions, (2) establish control devices, and (3) establish test methods, compliance certification, recordkeeping, and

report ing requirements based on EPA CTGs.

C . CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. EPA evaluates that Regulation 1124, Control of Volatile Organic Compounds

- sections 12.0, 19.0, 20.0, and 22.0 contains the required elements for a federally enforceable rule: emission limitations, compliance procedures and test methods, compliance dates and record keeping provisions . Delaware’s SIP revision contains special provisions that establishes d efinitions, specifies applicability, establishes standards, specifies exemptions, specifies control devices, and specifies general testing, compliance, recordkeeping, and reporting require ments

. The amendments to sections 12.0, 19.0, 20.0, and 22.0 meet t he applicable requirements of the CAA, and the applic able EPA regulations and policy and can be approved.

EPA approval of the SIP revision is recommended. The regulations reduce the VOC contents of currently regulated coatings, regulate additional coatin g categories, require the use of coating application equipment that provides for high transfer efficiency, and require that clean

- up solvent emissions be included in regulatory applicability determinations. The reduction of VOC

emissions will reduce the f ormation of ozone, and thereby protect public health and welfare.