PROPOSED ACTION ON REGULATIONS
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MARYLAND REGISTER, VOLUME 38, ISSUE 2, FRIDAY, JANUARY 14, 2011 (20) “Vacuum-metalizing c oatings” means topcoats and
basecoats that are used in th e vacuum-metalizing process. (21) “Vacuum metalizing process” means a process of evaporating metals inside a vacuum chamber which then bonds to the desired substrate to achieve a uniform metalized layer. B. Standards for Coating Installations. (1) A person may not cause or permit the discharge into the atmosphere of any VOC from any in stallation listed in §B(2), (3), and (4) of this regulation in excess of the standards in §B(2), (3), and (4) of this regulation. (2) Plastic Parts Coating Standards.

Coating
Installation Applicability (Pounds of VOC per day) Pounds of VOC Per Gallon of Coating (As applied minus water) Kilograms of
VOC Per Liter

of Coating (As applied minus water)

Decorative coating of other

p lastic parts 20 5.9 0.70

General, onecomponent 15 2.3 0.28

General, multicomponent 15 3.5 0.42

Electric dissipating coatings and shock-free coatings 15 6.7 0.80

Extreme

p erformance 15 3.5 0.42

Metallic 15 3.5 0.42 Military specification,
one-component 15 2.8 0.34

Military specification, multi-component 15 3.5 0.42

Mold seal 15 6.3 0.76

Multi-colored coatings 15 5.7 0.68

Optical coatings 15 6.7 0.80

Plastic vehicle

p arts 20 3.0 0.36

Vacuummetalizing 15 6.7 0.80

Vinyl 20 3.8 0.45

(3) Business Machines Coating Standards.

Coating
Installation Applicability (Pounds of VOC per day) Pounds of VOC Per Gallon of Coating (As applied minus water) Kilograms of
VOC Per Liter

of Coating (As applied minus water)

Prime Coat 15 2.9 0.35
Topcoat 15 2.9 0.35

Texture coat 15 2.9 0.35
Fog coat 15 2.2 0.26 Touchup and repair 15 2.9 0.35 (4) Printing Standards.

Printing Installation Applicability (Pounds of VOC per day) Pounds of VOC Per Gallon of Coating (As applied minus water) Kilograms of
VOC Per Liter

of Coating (As applied minus water)

Plastic other than vinyl Non-major

source 5.8 0.69

Plastic other than vinyl Major source as defined in
COMAR 26.11.19.01B(4) 3.8 0.45

Vinyl 20 3.8 0.45

C. Application Methods. A person subject to the requirements of §B of this regulation shall us e the following application methods: (1) Electrostatic application; (2) HVLP spray; (3) Flow coat; (4) Roller coat; (5) Dip coat including electrodeposition; (6) Brush coat; or (7) A coating application me thod capable of achieving a transfer efficiency equivalent to or better than the efficiency achieved by HVLP spraying.

ROBERT M. SUMMERS, Ph.D. Acting Secretary of the Environment



# Subtitle 11 AIR QUALITY
26.11.19 Volatile Organic Compounds from

Specific Processes

Authority: Environment Article, §§1-101, 1-404, 2-101—2-103, 2-301—2- 303, 10-102, and 10-103, Annotated Code of Maryland

Notice of Proposed Action
[11-026-P] The Secretary of the Environmen t proposes to amend Regulation
.13 under COMAR 26.11.19 Volatile Organic Compounds from Specific Processes

. Statement of Purpose The purpose of this action is to adopt the requirements of the EPA’s Control Techniques Guidelines (CTG) for metal parts and products. EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. MDE proposes to adopt new standards that will be set for drum and pail coati ng. Application method and work practice requirements will also be adopted. These amendments affect coaters of drums and pails.
This action will be submitted to the U.S. Environmental Protection Agency (EPA) for approval as part of Maryland’s State Implementation Plan.

Background EPA developed the CTG after reviewing the 1978 CTG, the 1988 NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR 60 Subpart TTT), the 1994 ACT for Surface Coating of Automotive/Transportation and Business Machine Plastic Parts,
National Emission Standards for Hazardous Air Pollutants for Miscellaneous Metal Parts and Products 40 CFR 63 Subpart MMMM, and existing State and local VOC emission reduction approaches. The metal parts and products category includesPROPOSED ACTION ON REGULATIONS
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MARYLAND REGISTER, VOLUME 38, ISSUE 2, FRIDAY, JANUARY 14, 2011 fabricated metal products, sma ll and large farm machinery, commercial and industrial machinery and equipment, automotive or transportation equipment, interior or exterior automotive parts, construction equipment, motor ve hicle accessories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational boats), extruded al uminum structural components, railroad cars, heavier vehicles, lawn and garden equipment, business machines, laboratory and medical equipment, electronic equipment, metal pipes, and other industria l and household products. Drums and pails are included in this category. The metal parts and products co ating category does not include coatings that are a part of ot her product categories listed under Section 183(e) of the Act for which CTGs have been published or included in other CTGs. Several different types of application technolog y are used to apply liquid coatings, and the selection of the application technology can have a significant effect on the amount of coating used and the resulting VOC emissions from the operation. The CTG requires that coatings can only be applied by coating applicators such as air atomized spray coating, electrosta tic spray coating, high volume/low pressure (HVLP) spray coating, dip coating, flow coating, roll coating, electrocoating, and autophor etic coating. Powder coatings can be applied through electro static spraying or dipping. Cleaning activities other than surface preparation also occur at miscellaneous metal product surface coating facilities. Additional requirements for cleaning materials and activities are covered under COMAR 26.11.19.02I. Cleaning materials are used during these activities to remove coating residue or other unwanted materials from equipment related to coating operati ons, as well as the cleaning of spray guns, transfer lines (e.g., tubing or piping), tanks, and the interior of spray booths. These cleaning material s are typically mixtures of VOC containing solv ents. Emission control requirements for cleaning materials are in the CTG.

Affected Sources These proposed amendmen ts affect coaters of drums and pails.

Regulation Amendment COMAR 26.11.19.13 is amended to set VOC coating standards for exterior and interior coatings for new and reconditioned drums and pails in the range of 2.8 to 4.2 lbs/gal. Application methods for coatings are limited to: 1. Electrostatic application; 2. HVLP sp ray; 3. Flow coat; 4. Roller coat; 5. Dip coat including electrodeposition; 6. Brus h coat; or 7. Other coating application method capable of ach ieving a transfer efficiency equivalent or better than th at achieved by HVLP spraying.

Impact on Ambient Air Quality The proposed amendments set sta ndards for coatings, application methods, and work practices. Emi ssions of VOCs from metal parts and products are expected to be re duced by 35 percent nationally. Drum and pail coatings are a part of this category. The maximum benefit will be provided during the ozone season when VOCs readily
combine with NO

x to from the pollutant ground level ozone.

Comparison to Federal Standards There is a corresponding federal standard to this proposed action, but the proposed action is not mo re restrictive or stringent.

Estimate of Economic Impact I. Summary of Economic Impact. The economic impact of implementing CTG requirements ha s been estimated by EPA on a national level. Cost effectivene ss is approximately $1,800/ton of
VOC controlled. This action will have minimal to no economic impact on affected Maryland sources. The impact on the Department is going to be minimal as affected sources are already regulated. The Department will need to review additional records and ensure new standards are being met.

Revenue (R+/R-)
II. Types of Economic Impact. Expenditure (E+/E-) Magnitude

A. On issuing agency: (E+) Minimal

B. On other State agencies: (E+) Minimal

C. On local governments: (E+) Minimal

Benefit (+) Cost (-) Magnitude

D. On regulated industries or trade groups: (-) $1,800/ton of VOC
controlled

E. On other industries or trade groups: (+) Unable to Estimate

F. Direct and indirect effects on public: (+) Indeterminable
III. Assumptions. (Identified by Impact Letter and Number from Section II.)
A. Inspections and reporting will be required if new coatings and
materials are used.
B. Compliance with the new standards and change in composition and cost of coatings and materials.
C. Local governments will be required to comply with the new standards and change the compositi on of coatings and materials.
D. The impact on the regulated industry has been estimated by EPA to be in the range of $1,800/ton VOC for compliance with the requirements of the CTG.
E. There will be a positive impact on companies that manufacture or sell the compliant coatings and materials.
F. This action will help improve Maryland’s air quality and will result in fewer negative health ef fects on the general public from air pollution.

Economic Impact on Small Businesses The proposed action has minimal or no economic impact on small businesses.

Impact on Individuals with Disabilities The proposed action has an impact on individuals with disabilities
as follows: This action will have a positive impact on individuals with disabilities involving respiratory problems by reducing air pollutants that contribute to disease.

Opportunity for Public Comment The Department of the Environmen t will hold a public hearing on the proposed action on February 15, 2011, at 10 a.m. at the Department of the Environment, 1800 Washington Boulevard, 1st Floor Conference Rooms, Baltimore, Maryland 21230-1720. Interested persons are invited to attend and express their views. Comments may be sent to Deborah Rabin, Regulations Coordinator,PROPOSED ACTION ON REGULATIONS
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MARYLAND REGISTER, VOLUME 38, ISSUE 2, FRIDAY, JANUARY 14, 2011 Air and Radiation Management Administration, Department of the Environment, 1800 Washington B oulevard, Suite 730, Baltimore, Maryland 21230-1720, or emailed to drabin@mde.state.md.us. Comments must be received not late r than February 16, 2011, or be submitted at the hearing. For more information, call Deborah Rabin at (410) 537-3240. Copies of the proposed action and supporting documents are available for review at the following locations: The Air and Radiation Management Administrati on; regional offices of the Department in Cumberland and Salisbury; all local air quality control offices; and local health departments in thos e counties not having separate air quality control offices. Anyone needing special accomm odations at the public hearing should contact the Department’s Fa ir Practices Office at (410) 537- 3964. TTY users may contact the Department through the Maryland Relay Service at 1-800-735-2258.

.13 [Miscellaneous Metal] Drum and Pail Coating. A. Definitions. In this regulation, the following terms have the meanings indicated: [ (1) “Clear coating” means a coating that, when applied not less than 0.001 inch thick on a glass microscope slide having an opacity less than 15 percent, causes the opacity to increase less than 5 percent opacity. ] [ (2) ] (1) “Drum” means any cylindrical metal [shipping] container with a capacity of greate r than 12 gallons and up to 110 gallons (45 to 416 liters). [ (3) “High performance coating” means a coating designed for continuous exposure to weather; s ubject to zero thickness (16 gauge or greater) post-coating flexure; s ubject to temperatures consistently
above 201 ° F (95 ° C); subject to immersion in detergents, VOC, or other corrosive extremes; subject to impact loadings above 5 footpounds/square inch; or air dried at temperatures less than 180 ° F. ] [ (4) ] (2) “Pail” means any cyli ndrical metal [shipping]
container of 5 to 12 [ gallon ] gallons (19 to 45 [ liter ] liters ) capacity and constructed of 29 gaug e or heavier material. (3) “Reconditioned Drums or Pails” means any metal drum or pail which is reused, recycled or remanufactured. [ (5) “Standard coating” means all coatings other than those in §A(1) and (3) of this regulation. ] B. Applicability and Exemptions. (1) This regulation applies to any drum or pail [ m e tal surface ] coating operations at a premises where the total VOC emissions [ from all metal surface coating operations not specifically covered by Regulations .03—.10 of this chapter ] exceed [ 20 ] 15 pounds (6.8 kilograms) per day. [ (2) The provisions of §C(2) of this regulation apply to the interior and exterior coating of metal drums and pails. (3) The provisions of §C of this regulation do not apply to: (a) Refinishing motor vehicles; (b) Customizing less than 20 motor vehicles per day; (c) Marine vessel coating oper ations subject to Regulation .27 of this chapter; (d) Aerospace coating operations subject to Regulation .13-1 of this chapter; (e) Brake shoe coating operatio ns subject to Regulation .13- 2 of this chapter; and (f) Structural steel coating oper ations subject to Regulation .13-3 of this chapter. (4) If a coating is both a clear coating and a high-performance coating, the clear coating standard applies. ] (2) This regulation does not apply to coatings applied using a hand-held, pressurized, non-refillable container which expels coatings from the container in a fin ely divided spray when a valve on the container is depressed: (a) To recoat portions of a pr eviously coated product which has sustained mechanical damage to the coating following normal painting operation; or (b) To cover minor coating imperfections appearing after the main coating operation. C. Emission Standards. [ (1) A person may not cause or permit the discharge of VOC into the atmosphere from a miscellaneous metal coating operation unless the following emission standards are achieved:

Coating Types Pounds Per Gallon of Coating Applied

(Minus Water) Kilograms Per Liter of Coating Applied

(Minus Water) High Performance 3.5 0.42 Clear Coating 4.3 .51
Standard 3.0 .36

(2) A person may not use any coat ing to line the interior of a metal drum or pail unless the VOC content the coating is 4.3 pounds per gallon (0.51 kilogram per liter) of coating minus water, or less. ] A person subject to this regulation may not exceed the applicable VOC emission standards of the following table:

Coating Types Pounds Per Gallon of Coating Applied

(Minus Water) Kilograms Per Liter of Coating Applied

(Minus Water) Drum or Pail Coating, New, Exterior 2.8 0.34

Drum or Pail Coating, New, Interior 3.5 0.42

Drum or Pail Coating, Reconditioned, Exterior 3.5 0.42

Drum or Pail Coating, Reconditioned, Interior 4.2 0.50

D. Application Methods. (1) Except as provided in §D(2), a person subject to the requirements of this regulation shall use the following application
methods: (a) Electrostatic application; (b) HVLP spray; (c) Flow coat; (d) Roller coat; (e) Dip coat including electrodeposition; (f) Brush coat; or (g) A coating application me thod capable of achieving a transfer efficiency equivalent or be tter than that achieved by HVLP spraying. (2) The application requirements of §D(1) do not apply to the following drum or pail coating operations: (a) Coatings applied in order to recoat portions of a previously coated product which has sustained mechanical damage to the coating following normal painting operation; or (b) Coatings applied in order to cover minor coating imperfections appearing after the main coating operation.

ROBERT M. SUMMERS, Ph.D. Acting Secretary of the Environment