1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: July

19, 2011 SUBJECT: Technical Support Document for Maryland ’s Adoption of D rum and Pail Coating

Standards /s/ FROM: Irene Shandruk, Phy sical Scientist

Office of Air Program Planning TO: File /s/ THRU: Cristina Fernandez, Associate Director

Office of Air Program Planning

A. BACKGROUND S ection 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (S IP s) for nonattainment areas must include reasonabl y available control measures (RACM), including reasonabl y available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States must rev ise their SIPs to include RACT for sources of volatile organic compound ( VOC ) emissions covered b y a control techniques guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of attainment. The United States Environmental P rotection Agency (EPA) defines RACT as “the lowest emission limitation that a particular source is capable of meeting b y the application of control technology

that is reasonably

available considering technological and economic feasibility .” (44 FR 53761, S ept. 17, 1979 )

. In subsequent Federal Register notices, EPA has addressed how states can mee t the RACT requirements of the CAA

. CTG s are intended to provide state and local air pollution control authorities information that should assist them in determi ning RACT for VOCs from various sources , including drum and pail surface coating operations . In developing these CTGs, EPA, among other things, evaluated the sources of VOC emissions from this industry and the available control approaches for addressing these emissions, including the costs of such approaches. Based on available information and data, EPA provides recommendations for RACT for VOCs from miscellaneous metal product and plastic parts surface coating

. In June 1978, EPA published a CTG for controlling VOC emissions from surface coating of miscellaneous metal and plastic products (EPA

- 450/2

- 78

- 0 15 ). Th is CTG discuss es the nature2

of VOC emissions from th is industry , available control technologies for addressing such emissions, the costs of availa ble co ntrol options, and other items. EPA also publi shed a national emission standard for hazardous air pollutants (NESHAP) for surface coating of miscellaneous metal parts and products surface coating (40 CFR part 63, subpart MMMM )

. In 2008 , after condu cting a review of currentl y existing state and local VOC emiss ion reduction approaches for this industry , reviewing the 1 978 CTG and the NESHAP for th is industry , and taking into account the information that has become available since then, EPA developed a new CTG for surface coating of miscellaneous metal and plastic parts products , entitled Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (Publication No. EPA 453/R

- 0 8

- 00 3 ). Description of Miscellaneous Metal and Plastic Pa rts Coatings The miscellaneous metal product and plastic parts surface coatings categories under section 183(e) of the CAA includes the coatings that are applied to the surfaces of a varied range of metal and plastic parts and products. Such parts or pro ducts are constructed either entirel y or partially from metal or plastic. The CTG applied to manufacturers of miscellaneous metal and plastic parts that surface

- coat the parts they produce. The CTG also applies to facilities that perform surface coating of miscellaneous metal and plastic parts on a contract basis. Miscellaneous metal product and plastic parts surface coatings serve decorative, protective, and functional purposes. Coatings protect metal parts from corrosion b y providing resistance to mo isture, heat, and sometimes the outdoor elements. Plastic parts may be coated to provide color, texture, or protection, thus improving appearance and durability , and can also function to attenuate electromagnetic interference/radio frequency interference signals, and to conceal mold lines and flaws in substrate surface. The miscellaneous metal product and plastic parts surface coating process may be divided into three main unit operations: (1) surface preparation, (2) coating application operations, and (3) cleaning activities. These three t ypes of activities utilize VOC

- containing compounds (i.e., coatings, thinners, and/or cleaning materials). The CTG provides control recommendations for reducing VOC emissions from the use of these activities. The VOC emissions from miscellaneous metal product and plastic parts surface coating processes result from the evaporation of the volatile components of the coatings and cleaning materials used in these operations. In most cases, VOC emissions from surface preparation, storage, handling, and waste/wastewater operations are relativel y small. EPA’s Recommended Control Options for Miscellaneous Metal and Plastic Parts Coatings EPA issued a CTG for miscellaneous metal and plastic parts c oatings in September 20 08 (Publication No. EPA 453/R

- 0 8

- 00 3 ). EPA recommends that the control approaches outlined below appl y to each miscellaneous metal product and plastic parts surface coating unit at a facility where the total actual VOC emissions from all miscellaneous met al product and plastic parts surface coating operations, including related cleaning activities, at that facility are equal to3

or exceed 6.8 k ilograms (kg) /day (15 pounds (lbs) /day), or an equivalent level of 2.7 tons per 12

- month rolling period, before con sideration of controls. The Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings document recommends emission limits for various metal and plastic coatings and those emission limits that apply

to this particular SI P revision are shown in Table 1. Table 1. VOC Content Limits Air Dried Baked Coating Category kg VOC/liter coating lbs VOC/gallon

coating kg VOC/liter

coating lbs VOC/gallon

coating Drum Coating, New, Exterior 0.34 2.8 0.34 2.8 Drum Coating, New, Interior 0.42 3.5 0.42 3.5 Drum Coating, Reconditioned, Exterior 0.42 3.5 0.42 3.5 Drum Coating, Reconditioned, Interior 0.50 4.2 0.50 4.2

B. STATE SUBMITTAL On June 22 , 2011 , Maryland Department of the Environment (MDE) submitted to EPA a SIP revision concerning the adoption of the emission limits for drum and pail coatings, part of the EPA miscellaneous metal and plastic parts coatings CTG . EPA develops CTGs as guidance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. The State of Maryland has adopt ed EPA’s CTG standards for drum and pail coating processes and th is regulation i s found in COMAR 26.11.19, Volatile Organic Compounds from Specific Processes

. This revision amends the existing regulation by making it specific to drum and pail coating processes only

. Specifically , this revision ame nds the existing regulation at section 26.11.19. 13 by

removing several definitions and adding several new definitions, amending the applicability and exemptions, amending the emission standards , and adding application methods. Work practice procedures for coating can be found in COMAR 26.11.19.02. Specifically , requirements for cleaning activities can be found in COMAR 26.11.19.02(I) and these have previousl y be en approved into Maryland’s SIP. The following changes are being made to COMAR 26.11.19 .13 , Volatile Organic Compounds from Specific Processes : The title of Section 26.11.19. 13 is being changed from “Miscellaneous Metal Coating” to “Drum and Pail Coating .” The following terms are being removed from Section 26.11.19. 13 (A) , Definitions : clear coating, high performance coating, and standard coating. Definitions for the following terms are added to Section 26.11.19.13(A) : drum, pail, and reconditioned drums or pails. Section 26.11.19. 13 (B ) , Applicability and Exemptions , is being amended to apply to an y drum or pail coating operations at a premises where the total VOC emissions exceed 15 pounds (6.84

kilograms) per day . It does not apply to coatings appli ed using a hand

- held, pressurized, non

refillable container which expels coatings from the container in a finel y divided spray when a valve on the container is depressed (a) To recoat portions of a previousl y coated product which has sustained mechanical d amage to the coating following normal painting operation, or (b) To cover minor coating imperfections appearing after the main coating operation. Section 26.11.19.13(C) , Emission Standards, is amended to explain that any person subject to Regulation 26.11 .19.13 may not exceed the applicable VOC emission standards in Table 2. Table 2. Drum and Pail Coating Standards Coating Types lbs VOC/gallon coating (minus water) kg VOC/liter coating (minus water) New, Exterior 2.8 0.34 New, Interior 3.5 0.42 Recond itioned, Exterior 3.5 0.42 Reconditioned, Interior 4.2 0.50 Section 26.11.19. 13 ( D ) , Application Methods , is added to the regulation. This section lists the application methods subject to this regulation. They are: electrostatic application, high volume low pressure ( HVLP ) spray , flow coat, roller coat, dip coat including electrodeposition, brush coat, or a coating application method capable of achieving a transfer efficiency equivalent to or better than the efficiency

achieved b y HVLP spraying. The a bove application requirements do not apply to the following drum or pail coating operations: (a) Coating applied in order to recoat portions of a previousl y coated product which has sustained mechanical damage to the coating following normal painting oper ation, or (b) Coatings applied in order to cover minor coating imperfections appearing after the main coating operation. C. EPA EVALUATION
MDE has adopted the standards and requirements of the CTG for drum and pail coating applications and is amending the Maryland SIP to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs readily combine with nitrogen oxides (NO x ) to form ground

- level ozone. Specifically , emissions of VOCs from drum and pail coating s are expected to be reduced by 35 percent nationally from facilities above the recommended 6.8 kg/day threshold , which include those in Maryland, as a result of this rulemaking

. Therefore , this revision will help Maryland attain and maintain the National Ambient Air Quality Standards (NAAQS ) for ozone. D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION The adoption of the EPA CTG requirements for drum and pail coating standards by the State of Maryland will result in the reduction of VOC emissi ons from drum and pail coatings . EPA ’s approval of the SIP revision is recommended.