UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: April 15, 2013

SUBJECT: T echnical Support Document for Maryland’s Adoption of Control Techniques

Guidelines (CTG) for Miscellaneous Metal and Plastic P arts which I ncludes Pleasure Craft Coating Operations

FROM: Gregory Becoat , Environmental Scientist /s/

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez

, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND:

On Janua ry 10, 2013

, the Maryland Department of the Environment ( MDE ) submitted a revision

to the State of Maryland State Implementation Plan (SIP )

. The SIP revision includes a new Regulation .27

- 1 under the Code of Maryland Regulations (COMAR) 26.11.19

– Volatil e Organic Compounds from Specific Processes in order to adopt the recommended level of control requirements of EPA’s Control Technique Guideline (CTG) for miscellaneous metal and plastic parts which include controls for pleasure craft coating operations

.

Section 172(c)(1) of the Clean Air Act (CAA) provides that SIP s for nonattainment areas must include reasonably available control measures (RACM), including RACT , for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainmen t areas , S tates must revise

their SIP to include RACT for sources of volatile organic compound ( VOC ) emissions covered by a CTG document issued after November 15, 1990 and prior to the Area’s date of attainment.

EPA defines RACT as “the lowest emission limitatio n that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility” (44 FR 53761, September 17, 1979).

CTGs are documents issued by EPA intended to pr ovide state and local air pollution control authorities information that should assist them in determining RACT for VOC from various

sources. Section 183(e)(3)(c) provides that EPA may issue a CTG in lieu of a national regulation as RACT for a product cat egory where EPA determines that the CTG will be substantially as effective as regulations 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 partic ular situation based upon the circumstances. States can follow the CTG and adopt state2

regulations to implement the recommendations contained therein, or they can adopt alternative approaches. In either case, states must submit their RACT rules to EPA fo r review and approv al as part of the SIP process.

EPA’s Miscellaneous Metal and Plastic Parts Coatings CTG

EPA developed the CTG for Miscellaneous Metal and Plastic Parts Coatings (MMPPC) after reviewing the 1978 CTG, the 1988 new source performance s tandards (NSPS) for Surface Coating of Plastic Parts for Business machines, the 1994 Alternative Control Techniques (ACT) document (1994 ACT) for controlling VOC emissions from surface coating of automotive/transportation and business machine plastic parts , the National Emission Standards for Hazardous Air Pollutants for Miscellaneous Metal Parts and Products Surface Coating, and existing State and local VOC emission reduction approaches.

The miscellaneous metal product and plastic parts su rface coatings c ategories under se ction 183(e) of the CAA include the coatings that are applied to the surfaces of a varied range of metal and plastic parts and products. Such parts or products are constructed either entirely or p artially from metal or plastic. These mi scellaneous metal products and plastic parts include, but are not limited to, metal and plastic components of the following t ypes of products as well as the products themselves: fabricated metal products, molded plas tic parts, small and large farm

machiner y, commercial and industrial machinery and equipment, automotive or transportation equipment, interior or exterior automotive parts, constr uction equipment, motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicle s, pleasure craft (recreational boats), extruded aluminum structural components, railroad cars, heavier vehicles, lawn and garden equipment, business machines, laboratory and medical e quipment, electronic equipment, steel drums, metal pipes, and numerous other industrial a nd household products

.

The pleasure craft coating category does not include coatings that are a part of other product categories listed under Section 183(e) of the CAA for which CTGs have been published or included in other CTGs. As a result, members o f the pleasure craft coatings industry contacted

EPA requesting reconsideration of the pleasure craft VOC limits contained in EPA's 2008

MMPPC CTG. In response, EPA issued a memorandum on June 1, 2010, titled “ Control Technique Guidelines for Miscellaneou s Metal and Plastic Part Coatings

- Industry Request for Reconsideration,” recommending that the pleasure craft industry work with s tate agencies during their RACT rule development process to assess what is reasonable for the specific sources regulated. EPA stated that s tates can use the recommendations from the MMPPC CTG to form their own determinations as to what constitutes RACT for pleasure craft coating operations in their particular ozone nonattainment area. CTG impose s no legally binding requireme nts on any entity, including pleasure craft coating facilities. As stated in the memorandum, EPA will

evaluate s tate

- developed RACT rules and determine whether the submitted rules meet the RACT requirements of the CAA.3

B . STATE SUBMITTAL:

MDE’s SIP re vision for the control of VOCs from pleasure craft coating operations adopts some of the recommended requirements of EPA’s MMPPC CTG , as well as alternative standards

based on the recommendation s of the pleasure craft industry for the following coatings: Finish Primer/Surfacer; Anti fouling Sealer/Tiecoat; Other Substrate Antifoulant; and Extreme High

Gloss.

I

. New Regulation COMAR 26.11.19.27

- 1

– Control of Volatile Organic Compounds from Pleasure Craft Coating Operations

The SIP revision added Regula tion .27

- 1 in order to establish applicability for pleasure craft and fiberglass boat coating operations at facilities with actual VOC emissions of 15 pounds or more per day (15 lb/day) from coating operations as determined on a monthly average on or after January 1, 2013

. The SIP revision also establishes exemptions for the following: (1) coatings applied using a hand

- held , pressurized, nonrefillable container which expels coatings from the container in finely divided spray when a valve on the container is depressed; (2) coatings applied to recoat portions of a product which as sustained mechanical damage to the coating following normal painting operations; (3) coatings applied to cover minor coating imperfections appearing after the main coating operatio n; and (4) coatings or resins applied during the manufacturing

process.

The SIP revision adds the following definitions to Regulation .27

- 1: “ Antifouling sealer/tiecoat,” “Extreme high gloss coating,” “Fiberglass boat,” “Finish primer/surface,” “High bui ld primer/surface,” “Pleasure craft,” “Pleasure craft coating,” and “Pretreatment wash primer.” The SIP revision also incorporates by reference testing methods and specifies VOC limit requirements for pleasure craft coating operations in Table 1 below

. M DE added an additional specialty category of “Anitfouling Sealer/Tie Coat” with a VOC limit of 420 grams/liter (g/L); amended the VOC emission limits in the category, “Other Substrate Anitfoulant Coating” from 330 g/L to 400 g/L; amended the CTG “Finish Pr imer/Surfacer” VOC limit from 420 g/L to 600 g/L; and amended the “Extreme High Gloss” VOC limit form 420 g/L to 600 g/L. For these four categories, Maryland reviewed industry data and determined that for the purpose of functionality, cost, and VOC emissi ons, the alternative limits adopted for these four coating categories

constitute RACT.

Table 1. Pleasure Craft Coating Standards (Expressed in Terms of Mass of VOC per Volume of Coating Excluding Water and Exempt Compounds, as Applied)

Coating Types lbs VOC/gallon kg VOC/liter Extreme high gloss topcoat 5.0 0.60 High gloss topcoat 3.5 0.42 Pretreatment wash primers 6.5 0.78 Finish primer/surface Applicable through March 31, 2014 5.0 0.604 Coating Types lbs VOC/gallon kg VOC/liter Applicable through March 31, 2014 3.5 0.42 High build primer/surface 2.8 0.34 Aluminum substrate antifoulant coating 4.7 0.56 Antifouling sealer/tiecoat 3.5 0.42 Other substrate antifoulant coating 3.3 0.40 All other pleasure craft surface coatings 3.5 0.42

The SIP revision establishes that the le ast stringent emission limitation is applicable if more than one emission limitation in Table 1 applies to a specific coating. The SIP revision also establishes the following application methods, except for the application of Extreme high gloss coating: (1) Electrostatic application, (2) High Volume Low Pressure (HVLP) spray, (3) Flow coat, (4) Roller coat, (5) Dip coat including electrodeposition, (6) Brush coat, (7) Airless spray, and (8) Other coating application method that has a transfer efficiency e quivalent to or better than that achieved by HVLP spraying.

C . CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requ irements for an acceptable SIP. The addition of new Regulation .27

- 1 under COMAR 26.11.19 Volatile Organic Com pounds from Specific Processes

meet the applicable requirements of the CAA, and the applicable EPA regulations, guidance

, and policy and strengthen the SIP . The State of Maryland generally implemented the requirements as

r ecommended by the MMPPC CTG by in cluding applicability, standards, exemptions, definitions, requirements for testing, and application methods for pleasure craft coatings with the exception of adopting the pleasure craft industry recommendations for the following four coating categories: Finish Primer/Surfacer; Antifouling Sealer/Tiecoat; Other Substrate Antifoulant; and Extreme High Gloss. EPA believes that Maryland’s approach is consistent with the guidance memorandum entitled, “Control Technique Guidelines for Miscellaneous Metal and P lastic Part Coatings

- Industry Request for Reconsideration,” and therefore, believes that these regulations

reflect RACT . This SIP revision satisfies all requirements for an acceptable SIP and for

RACM/RACT . EPA is proposing approval of the S IP revision

.