DAR File No. 38685

Environmental Quality, Air Quality

Rule R307-353

Plastic Parts Coatings

Change in Proposed Rule

DAR File No.: 38685
Filed: 10/07/2014 10:04:04 AM

RULE ANALYSIS

Purpose of the rule or reason for the change:

The EPA has indicated its intention to approve the area source coatings rules for the PM2.5 State Implementation Plan as reasonable available control technology (RACT), but not until: 1) they are amended to clarify that the amount of control removal specified in each rule is based on the entire system, and 2) the inspection and recordkeeping requirements for these systems are expanded. These changes were proposed to this and 13 other air quality area source rules, and a 30-day public comment period was held. During the public comment period, several inquiries were made regarding why the rules do not permit the use of exempt solvents for cleaning. The definition of "volatile organic compound (VOC)" found in Section R307-101-2 incorporates the definition of VOC found in 40 CFR 51.100(s)(1). This definition does permit the use of exempt compounds for cleaning; however, this allowance is not explicitly stated in this or the other proposed area source rules. The change to the proposed rule is to specify that exempt compounds are not VOC by definition.

Summary of the rule or change:

The change clarifies that exempt compounds are not VOC by definition. (DAR NOTE: The original proposed amendment upon which this change in proposed rule (CPR) was based was published in the August 1, 2014, issue of the Utah State Bulletin, on page 39. Underlining in the rule below indicates text that has been added since the publication of the proposed rule mentioned above; strike-out indicates text that has been deleted. You must view the CPR and the proposed amendment together to understand all of the changes that will be enforceable should the agency make this rule effective.)

State statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

This change is to add clarifying language and does not change any of the rule requirements; therefore, there are no anticipated costs or savings to the state budget.

local governments:

This change is to add clarifying language and does not change any of the rule requirements; therefore, there are no anticipated costs or savings to local government.

small businesses:

This change is to add clarifying language and does not change any of the rule requirements; therefore, there are no anticipated costs or savings to small businesses.

persons other than small businesses, businesses, or local governmental entities:

This change is to add clarifying language and does not change any of the rule requirements; therefore, there are no anticipated costs or savings to persons other than small businesses, businesses, or local government entities.

Compliance costs for affected persons:

This change is to add language to clarify that exempt compounds are not VOC by definition. This change does not result in any additional compliance costs.

Comments by the department head on the fiscal impact the rule may have on businesses:

This change is to add language to clarify that exempt compounds are not VOC by definition. This change will not have a fiscal impact on businesses.

Amanda Smith, Executive Director

The full text of this rule may be inspected, during regular business hours, at the Division of Administrative Rules, or at:

Environmental Quality
Air QualityRoom Fourth Floor
195 N 1950 W
SALT LAKE CITY, UT 84116-3085

Direct questions regarding this rule to:

• Mark Berger at the above address, by phone at 801-536-4000, by FAX at 801-536-0085, or by Internet E-mail at mberger@utah.gov

Interested persons may present their views on this rule by submitting written comments to the address above no later than 5:00 p.m. on:

This rule may become effective on:

12/01/2014

Authorized by:

Bryce Bird, Director

R307. Environmental Quality, Air Quality.

R307-353. Plastic Parts Coatings.

R307-353-1. Purpose.

The purpose of this rule is to limit volatile organic compound (VOC) emissions from the application of coatings to any plastic product.

 

R307-353-2. Applicability.

R307-353 applies to plastic parts coating operations located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 2.7 tons per year or more of VOC, including related cleaning activities.

 

R307-353-3. Exemptions.

(1) The provisions of this rule shall not apply to any of the following:

(a) Stencil coatings;

(b) Safety-indicating coatings;

(c) Electric-insulating and thermal-conducting coatings;

(d) Magnetic data storage disk coatings;

(e) Plastic extruded onto metal parts to form a coating; and

(f) Textured finishes.

(2) If a coating line is subject to the requirements for existing automobile, light-duty truck, and other product and material coatings or for existing metallic surface coating lines, the coating line shall be exempt from this rule.

 

R307-353-4. Definitions.

The following additional definitions apply to R307-353:

"Air dried coating" means coatings that are dried by the use of air or a forced warm air at temperatures up to 194 degrees Fahrenheit.

"Baked coating" means coatings that are cured at a temperature at or above 194 degrees Fahrenheit.

"Coating" means a protective, functional, or decorative film applied in a thin layer to a surface. This term often applies to paints such as lacquers or enamels. It is also used to refer to films applied to paper, plastics, or foil.

"Electric-insulating and thermal-conducting" means a coating that displays an electrical insulation of at least 1000 volts DC per mil on a flat test plate and an average thermal conductivity of at least 0.27 BTU per hour-foot-degree-Fahrenheit.

"Magnetic data storage disk coating" means a coating used on a metal disk which stores data magnetically.

"Metallic coating" means a coating which contains more than 5 grams of metal particles per liter of coating as applied.

"Military specification coating" means a coating which has a formulation approved by a United States military agency for use on military equipment.

"Mirror backing" means the coating applied over the silvered surface of a mirror.

"Mold-seal coating" means the initial coating applied to a new mold or a repaired mold to provide a smooth surface which, when coated with a mold release coating, prevents products from sticking to the mold.

"Multi-colored coating" means a coating which exhibits more than one color when applied, and which is packaged in a single container and applied in a single coat.

"Multi-component coating" means a coating requiring the addition of a separate reactive resin, commonly known as a catalyst, before application to form an acceptable dry film.

"One-component coating" means a coating that is ready for application as it comes out of its container to from an acceptable dry film. A thinner necessary to reduce the viscosity is not considered a component.

"Optical coating" means a coating applied to an optical lens.

"Plastic" means a substrate containing one or more resigns that may be solid, porous, flexible, or rigid, and includes fiber reinforced plastic composites.

"Primer" means a coating applied to a surface to provide a firm bond between the substrate and subsequent coats.

"Repair coating" means a coating used to recoat portions of a part or product which has sustained mechanical damage to the coating.

"Roller Coated" means a type of coating application equipment that utilizes a series of mechanical rollers to form a thin coating film on the surface of a roller, which is then applied to a substrate by moving the substrate underneath the roller.

"Safety-indicating coating" means a coating which changes physical characteristics, such as color, to indicate unsafe condition.

"Stencil coating" means an ink or a coating which is rolled or brushed onto a template or stamp in order to add identifying letters or numbers to metal parts and products.

"Textured finish" means a rough surface produced by spraying and splattering large drops of coating onto a previously applied coating. The coatings used to form the appearance of the textured finish are referred to as textured coatings.

"Touch-up coating" means a coating used to cover minor coating imperfections appearing after the main coating operation.

"Topcoat" means the last film-building finishing material applied in a finishing system. Non-permanent final finishes are not topcoats.

 

R307-353-5. VOC Content Limits.

(1) For automobile and truck plastic parts coating lines:

(a) Each owner or operator shall not apply coatings with a VOC content in excess of the amounts specified in Table 1 or shall use an add-on control device as specified in R307-353-8.

(b) For red and black coatings, the emission limitation shall be determined by multiplying the appropriate limit in Table 1 by 1.15.

(c) When EPA Method 24 is used to determine the VOC content of a high bake coating, the applicable emission limitation shall be determined by adding 0.5 to the appropriate limit in Table 1.

(d) When EPA Method 24 is used to determine the VOC content of an air-dried coating, the applicable emission limitation shall be determined by adding 0.1 to the appropriate limit in Table 1.

 

TABLE 1

AUTOMOBILE AND TRUCK PLASTIC PARTS COATING LINES
(values in pounds of VOC per gallon of coating, minus water and
exempt solvents (compounds not classified as VOC as defined in 
R307-101-2), as applied)

COATING CATEGORY                     VOC Content Limitations

High bake coating - exterior and
interior parts

     Prime

          Flexible coating                     4.5

          Nonflexible coating                  3.5

     Topcoat

          Basecoat                             4.3

          Clearcoat                            4.0

          Non-basecoat/clearcoat               4.3

Air-dried coating - exterior parts

     Prime                                     4.8

     Topcoat

          Basecoat                             5.0

          Clearcoat                            4.5

          Non-basecoat/clearcoat               5.0

     Air-dried coating - interior parts        5.0

     Touch-up and repair                       5.2

 

(2) Each owner or operator of a business machine plastic parts coating line shall not apply coatings with a VOC content in excess of the amounts specified in Table 2 or shall use an add-on control device as specified in R307-353-8.

 

TABLE 2

BUSINESS MACHINE PLASTIC PARTS COATING LINES
(values in pounds of VOC per gallon of
coating, minus water and exempt solvents (compounds not
classified as VOC as defined in R307-101-2)[)], as applied)

COATING CATEGORY       VOC Content Limitations

Prime                                          2.9

Topcoat                                        2.9

Texture coat                                   2.9

Fog coat                                       2.2

Touch-up and repair                            2.9

 

(3) Each owner or operator engaged in other plastic product coating operations shall not apply coatings with a VOC content in excess of the amounts specified in Table 3 or shall use an add-on control device as specified in R307-353-8.

 

TABLE 3

OTHER PLASTIC PRODUCT COATING CATEGORIES

(values in pounds of VOC per gallon of
coating, minus water and exempt solvents (compounds not
classified as VOC as defined in R307-101-2), as applied)

COATING CATEGORY       VOC Content Limitations

General One-Component                          2.3

General Multi-Component                        3.5

Electric Dissipating Coatings
And Shock-Free Coatings                        3.0

Extreme Performance                            3.5
                                        (2-pack coatings)

Metallic                                       3.5

Military Specification                         2.8 (1 pack)
                                               3.5 (2 pack)

Mold-Seal                                      6.3

Multi-colored Coatings                         5.7

Optical Coatings                               6.7

Vacuum-Metalizing                              6.7

Mirror Backing
     Curtain Coated                            4.2
     Roll Coated                               3.6

 

(4) If a part consists of both plastic and metal surfaces and is exempted from the requirements for existing metallic surface coating lines, the part shall be subject to this rule.

 

R307-353-6. Application Methods.

No person shall apply VOC containing coatings unless the coating is applied with equipment operated according to the manufacturer specifications, and by use of one of the following methods:

(1) Electrostatic application;

(2) Flow coat;

(3) Roller coat;

(4) Dip/electrodeposition coat;

(5) Airless Spray;

(6) High-volume, low-pressure (HVLP) spray; or

(7) Other application method equal to or better than HVLP, as certified by the manufacturer.

 

R307-353-7. Work Practices and Recordkeeping.

(1) The owner or operator shall:

(a) Store all VOC-containing coatings, thinners, and cleaning materials in closed containers;

(b) Minimize spills of VOC-containing coatings, thinners, and cleaning materials;

(c) Clean up spills immediately;

(d) Convey any coatings, thinners, and cleaning materials in closed containers or pipes;

(e) Close mixing vessels that contain VOC coatings and other materials except when specifically in use; and

(f) Minimize usage of solvents during cleaning of storage, mixing, and conveying equipment.

(2) All persons shall perform solvent cleaning operations with cleaning material having VOC content (excluding water and solvents exempt from the definition of volatile organic compounds found in R307-101-2) of 0.21 pounds per gallon or less.

(3) All sources subject to R307-353 shall maintain records demonstrating compliance with R307-353-5, R307-353-6 and R307-353-7(2).

(a) Records shall include, but not be limited to, inventory and product data sheets of all coatings and solvents subject to R307-350.

(b) These records shall be made available to the director upon request.

 

R307-353-8. Add-On Controls Systems Operations.

(1) The owner or operator shall install and maintain an incinerator, carbon adsorption, or any other add-on emission control system, provided that the emission control system is operated and maintained in accordance with the manufacturer recommendations in order to maintain at least 90% capture and control efficiency. Determination of overall capture and control efficiency shall be determined using EPA approved methods, as follows.

(a) The capture efficiency of a VOC emission control system's VOC collection device shall be determined according to EPA's "Guidelines for Determining Capture Efficiency," January 9, 1995 and 40 CFR Part 51, Appendix M, Methods 204-204F, as applicable.

(b) The control efficiency of a VOC emission control system's VOC control device shall be determined using test methods in Appendices A-1, A-6, and A-7 to 40 CFR Part 60, for measuring flow rates, total gaseous organic concentrations, or emissions of exempt compounds, as applicable.

(c) An alternative test method may be substituted for the preceding test methods after review and approval by the EPA Administrator.

(2) The owner or operator of a control system shall provide documentation that the emission control system will attain the requirements of R307-353-8(1).

(3) The owner or operator shall maintain records of key system parameters necessary to ensure compliance with R307-353-8. Key system parameters may include, but are not limited to, temperature, pressure and flow rates. Operator inspection schedule, monitoring, recordkeeping, and key parameters shall be in accordance with the manufacturer's recommendations, and as required to demonstrate operations are providing continuous emission reduction from the source during all periods that the operations cause emissions from the source.

(4) The owner or operator shall maintain for a minimum of two years records of operating and maintenance sufficient to demonstrate that the equipment is being operated and maintained in accordance with the manufacturer recommendations.

 

KEY: air pollution, emission controls, coatings, plastic parts

Date of Enactment or Last Substantive Amendment: 2014

Authorizing, and Implemented or Interpreted Law: 19-2-104(1)(a)