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 Plastic
Parts and Business Machines Coating Standards 

			/s/

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:	File

			/s/	

THRU: 	Cristina Fernandez, Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

Section 172(c)(1) of the Clean Air Act (CAA) 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 that for certain nonattainment areas, States must
revise their SIPs to include RACT for sources of volatile organic
compound (VOC) emissions covered by a control techniques guidelines
(CTG) document issued after November 15, 1990 and prior to the area’s
date of attainment. 

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 and economic feasibility.” (44 FR
53761, Sept. 17, 1979).  In subsequent Federal Register notices, EPA has
addressed how states can meet the RACT requirements of the CAA. 

CTGs are intended to provide state and local air pollution control
authorities information that should assist them in determining RACT for
VOCs from various sources, including miscellaneous metal product and
plastic parts 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-450/2-78-015).  This CTG discusses the nature of VOC emissions from
this industry, available control technologies for addressing such
emissions, the costs of available control options, and other items.  EPA
also published 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) and a NESHAP for plastic
parts and products surface coating in 2004 (40 CFR 63, subpart PPPP).

In 2008, after conducting a review of currently existing state and local
VOC emission reduction approaches for this industry, reviewing the 1978
CTG and the NESHAP for this 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-08-003).

Description of Miscellaneous Metal and Plastic Parts 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 products are constructed either entirely 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 by providing resistance to moisture, 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 types 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 relatively small.
 

EPA’s Recommended Control Options for Miscellaneous Metal and Plastic
Parts Coatings

EPA issued a CTG for miscellaneous metal and plastic parts coatings in
September 2008 (Publication No. EPA 453/R-08-003).  EPA recommends that
the control approaches outlined below apply to each miscellaneous metal
product and plastic parts surface coating unit at a facility where 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
(kg)/day (15 pounds (lbs)/day), or an equivalent level of 2.7 tons per
12-month rolling period, before consideration 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
State Implementation Plan (SIP) revision are as follow:

Table 1.  VOC Content Limits

Plastic Parts Coatings

Coating Category	kg VOC/liter coating	lbs VOC/gallon coating

General One Component	0.28	2.3

General Multi Component	0.42	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

Business Machine Coatings

Primers	0.35	2.9

Topcoat	0.35	2.9

Texture Coat	0.35	2.9

Fog Coat	0.26	2.9

Touchup and repair	0.35	2.9



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
plastic parts and business machines 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 adopted EPA’s CTG standards for plastic parts and
business machine coating processes.  These regulations are in COMAR
26.11.19, Volatile Organic Compounds from Specific Processes. 
Specifically, this revision amends the existing regulation at Section
26.11.19.07 by moving existing VOC coating standards for plastic parts
and vinyl from Section 26.11.19.07 to new Section 26.11.19.07-2, Plastic
Parts and Business Machines Coating.  Additionally, coating standards
for plastic parts and business machines from EPA’s CTG are being
adopted into COMAR 26.11.19.07-2.  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
previously been approved into Maryland’s SIP.

The following changes are being made to COMAR 26.11.19:

The title of Section 26.11.19.07 is being changed from “Paper, Fabric,
Vinyl, and Other Plastic Parts” to “Paper, Fabric, Film, and Foil
Coating.”

Existing definitions in section 26.11.19.07(A) and standards in Section
26.11.19.07(C)(3) pertaining to plastic parts and vinyl are being moved
to new Section 26.11.19.07-2.

Section 26.11.19.07-2, entitled Plastic Parts and Business Machines
Coatings, is added.  The following definitions are included in Section
26.11.19.07-2(A), Definitions: business machine, business machine
coating, electric dissipating coating, extreme performance coating, fog
coating, metallic coating, military specification coating, mold seal
coating, multi-colored coating, multi-component coating, one-component
coating, optical coating, plastic part, plastic part coating, prime
coat, shock-free coating, standard industrial classification code (SIC
code), texture coat, touch-up and repair coat, vacuum-metalizing
coatings, and vacuum metalizing process.

Section 26.11.19.07-2(B), Standards for Coating Installations, includes
VOC emission limits for plastic parts coating standards, business
machines coating standards, and printing standards (see Tables 2-4).

Section 26.11.19.07-2(C), Application Methods, 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 by HVLP spraying.

Table 2.  Plastic Parts Coating Standards

Coating Installation	Applicability (lbs 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 plastic parts	20	5.9	0.70

General, one-component	15	2.3	0.28

General, multi-component	15	3.5	0.42

Electric dissipating coatings and shock-free coatings	15	6.7	0.80

Extreme performance	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 parts	20	3.0	0.36

Vacuum-metalizing	15	6.7	0.80

Vinyl	20	3.8	0.45



Table 3.  Business Machines Coating Standards

Coating Installation	Applicability (lbs 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	2.9	0.26

Touchup and repair	15	2.9	0.35



Table 4.  Printing Standards

Printing  Installation	Applicability (lbs 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.  EPA EVALUATION

MDE has adopted the standards and requirements of the CTG for a variety
of plastic parts coatings and business machine 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 (NOx) to form
ground-level ozone.  Specifically, emissions of VOCs from plastic parts
and products and business machines coating are expected to be reduced by
35 percent nationally from facilities above the recommended 6.8 kg/day
threshold as a result of this rulemaking, but because Maryland already
has regulations in place which have reduced VOC emissions from plastic
parts coating, the reduction is expected to be less than that on a
national level.  Nonetheless, 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 plastic parts coatings and
business machines coating standards by the State of Maryland will result
in the reduction of VOC emissions from plastic parts and business
machines coatings.  EPA’s approval of the SIP revision is recommended.

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