### PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT



# STAFF REPORT

PROPOSED NEW RULE 249
, SURFACE COATING OF PLASTIC PARTS AND PRODUCTS

August 8 , 201 31

SUMMARY

The District is required to adopt volatile organic compounds (VOCs) standards at leas t as stringent as contained in the U.S. EPA “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (CTG), September 2008. Rule 245, Surface Coating of Metal Parts and Products

, was amended August 20, 2009 to meet the requiremen ts for metal parts. Adoption of this proposed new Rule 249, Surface Coating of Plastic Parts and Products

, would meet the requirements for plastic parts.

A draft version of Rule 249 was forwarded to the U.S. EPA on May 29, 2013

, for review and

comment. Comments were received on June 26, 2013. The District revised Rule 249 and re

- sent
the Rule to EPA for final comments. EPA indicated that the changes to the Rule were fine and

there were no further comments.

BACKGROUND

Clean Air Act (CAA) section 172(c )(1) provides that state implementation plans (SIPs) 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 th at for certain nonattainment areas, s tates must revise their SIPs to include RACT for each category of volatile organic compound (VOC) sources covered by a control techniques guidelines (CTG) document issued between November 15, 1990

, and the date of attai nment.

The United States 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 a nd economic feasibility

.

DISCUSSION OF THE PROPOSED RULE

Placer County currently has only one minor source, Freedom Refinishing, under permit which would be required to meet the requirements of this rule. The owner indicates that he occasionally

coats plastic parts and the total plastic parts coated amounts to approximately 2% of his business. He uses the same paint to coat plastic as he uses for metal parts. The company is currently in compliance with the proposed rule.

The following is a summary of the rule sections.

Applicability:

The rule applies throughout all of Placer County

.

Exemptions:

Section 104 contains a low usage exemption for non

- compliant coatings used in quantities of less than 55 gallons , if substitute compliant coatings are not available, and (2) the requirements of

Sections 401 and 501 are met.2

Section 105 contains the exemptions for operations and coating which are covered by other specific rules.

Section 106 contains partial ex emptions for coating operations used for repair and touchup. Coating operations used for repair and touchup are exempt from all sections of the rule except the application method requirements of Section 302, surface preparation and cleanup of Section 303, the work practices requirements of Section 304 , and the recordkeeping requirements of Section 501 shall apply.

Coating operations used for stencil, safety indicating, solid film lubricating, electric insulating, thermal conduction, and magnetic data storage, are exempt from all sections of the rule e xcept the application method requirements of Section 302, surface preparation and cleanup of Section 303, the work practices requirements of Section 304, and the recordkeeping requirements of Section 501 shall apply.

Definitions:

The definitions were bas ed on definitions used in other District Rules or in EPA’s CTG

.

Standards:

The VOC limits are listed in Table 1 of Section 301. The limits are expressed in both grams per liter and pounds per gallon (lb/gal).

The coating categories covered are ; gener al one component, general multi

- component, and specialty coating categories of: electric dissipating and shockfree coating, extreme performance (2 pack), metallic, military specification (1 pack), military specification (2 pack), mold seal, multi

colored, optical and vacuum metalizing.

Administrative:

The administrative requirements contain prohibition of specification, product information requirements for sellers, formula for determining the VOC Content of the coatings, formula for determining the VOC Co ntent per Liter of Coating Removers (Strippers), surface preparation materials, and cleanup materials.

Monitoring and Records:

Standard recordkeeping is required, including a monthly record of the volume of each product

used.

Records must be retained fo r at least 3 years, unless the source is a Title V source subject to Rule 507, Federal Operatin g Permit Program

.3

FINDINGS

FINDING DEFINITION REFERENCE Authority The District is permitted or required to adopt, amend, or repeal the rule by a provision of law or a state or federal regulation. California Health and Safety Code, Section 40702 and Section 41010; 1990 Federal Clean Air Act, Section 110(a ) ( 2 ) ( H) and Section 182(d). Necessity The District has demonstrated that a need exists for the rule, or for its amendment or repeal. The adoption of proposed new Rule

24 9 is necessary to satisfy the requirement that U.S. Environmental Protection Agency “Control Techniques Guidelines for

Miscellaneous Metal and Plastic Parts Coatings” (CTG) be implemented

. Clarity The rule is written or displayed so that its meaning can be easily understood by the persons directly affected by it. There is no indication at this time

that the rule is not written in such a manner that the person affected by the rule can easily understand it. Consistency The rule is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, or state or federal regulations. The District has found that the rule is consistent with existing state and federal g uidelines.

Non

- duplication The rule does not impose the same requirements as an existing state or federal regulation, unless the District finds that the requirements are necessary or proper to execute the powers and duties granted to, and imposed upon the District. There are no other duplicate requirements in federal law. The limits came from the CTG, which is a guideline to agencies.

Reference Any statute, court decision, or other provision of law that the District implements, interprets, or makes speci fic by adopting, amending, or repealing the rule. An example

of this would be the 1988 EPA State Implementation Plan call to revise District

rules. This rule is being proposed because of the requirements of the Federal

Clean Air Act Amendments of 1990.

SUMMARY

District staff recommends the District Board approve the Findings in this document and adopt the proposed new Rule 249, Surface Coating of Plastic Parts and Products , with standards for plastic parts and products as contained in the U.S. EPA “Con trol Techniques Guidelines for

Miscellaneous Metal and Plastic P arts Coatings” (CTG), September, 2008.