No. 41822 (Change in Proposed Rule): Rule R307-352. Metal Container, Closure, and Coil Coatings

DAR File No.: 41822
Filed: 10/05/2017 12:38:25 PM

RULE ANALYSIS

Purpose of the rule or reason for the change:

The rule changes are being proposed in response to comments received during the public comment period. The amendments to this rule strengthen the area source coating rules. These amendments will help further reduce Volatile Organic Compound (VOC) emissions and will be part of the upcoming Serious PM2.5 State Implementation Plan (SIP).

Summary of the rule or change:

Several changes were made throughout Rule R307-352 as a result of public comments. These changes include adding a compliance schedule for affected sources, adding a definition for Aerosol coating product, and adding an exemption for operations that use aerosol coating products. (EDITOR'S NOTE: The original proposed amendment upon which this change in proposed rule (CPR) was based was published in the July 1, 2017, issue of the Utah State Bulletin, on page 138. 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.)

Statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

There is no cost or savings to the state budget as a result of these changes because the changes do not change the way the rule impacts the state.

local governments:

There is no cost or savings to local governments as a result of these changes because the changes do not affect the way the rule impacts local governments.

small businesses:

The extension of the exemption for aerosol coating product may lead to savings to small businesses; however, it is difficult to determine the amount of the savings to be realized. The other changes would not result in additional costs or savings because the changes simply clarify the purpose of the rule.

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

Persons other than small businesses, businesses, or local government entities will not be impacted by these changes because the rule does not apply to them.

Compliance costs for affected persons:

There will be no added compliance costs because of these changes. The changes (the added compliance schedule for affected sources, added a definition for Aerosol coating product, and added exemption for operations that use aerosol coating products) do not result in additional compliance costs because the requirements of the rule otherwise remain unchanged.

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

The new exemption for aerosol coating product may lead to a savings to businesses; however, it is difficult to determine the amount of the savings to be realized. The other changes would not result in additional costs because the changes simply clarify the purpose of the rule.

Alan Matheson, Executive Director

The full text of this rule may be inspected, during regular business hours, at the Office 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:

• Mat Carlile at the above address, by phone at 801-536-4116, by FAX at 801-536-4136, or by Internet E-mail at [e-mail]

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:

12/01/2017

Authorized by:

Bryce Bird, Director

RULE TEXT

R307. Environmental Quality, Air Quality.

R307-352. Metal Container, Closure, and Coil Coatings.

R307-352-1. Purpose.

The purpose of this rule is to reduce volatile organic compound (VOC) emissions from the coating of metal containers, closures and coils in the manufacturing or reconditioning process.

 

R307-352-2. Applicability.

[R307-352 applies to metal container, closure and coil coating operations and related cleaning activities that use a combined 20 gallons or more of coating products and associated solvents per year and are located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties.](1) R307-352 applies to metal containers, closure and coil coating operations located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties.

(2) Before September 1, 2018, R307-352 applies to metal containers, closure and coil coating operations that have the potential to emit 2.7 tons per year or more of VOC, including related cleaning activities.

(3) Effective September 1, 2018, R307-352 shall apply to metal containers, closure and coil coating operations that use a combined 20 gallons or more of coating products and associated solvents per year.

 

R307-352-3. Definitions.

The following additional definitions apply to R307-352:

"Aerosol coating product" means a pressurized spray system that dispenses product ingredients by means of a propellant or mechanically induced force but does not include pump sprays.

"As applied" means the volatile organic compound and solids content of the finishing material that is actually used for coating the substrate. It includes the contribution of materials used for in-house dilution of the finishing material.

"End sealing compound" means a compound which is coated onto can ends and which functions as a gasket when the end is assembled onto the can.

"Exterior body spray" means a coating sprayed on the exterior of the container body to provide a decorative or protective finish.

"Interior body spray" means a coating sprayed on the interior of the container body to provide a protective film between the product and the can.

"Metal container or closure coating" means any coating applied to either the interior or exterior of formed metal cans, pails, lids or crowns or flat metal sheets which are intended to be formed into cans, pails, lids or crowns.

"Overvarnish" means a coating applied directly over a design coating to reduce the coefficient of friction, to provide gloss, and to protect the finish against abrasion and corrosion.

"Reconditioned" means any metal container which is reused, recycled or remanufactured.

"Three-piece can coating" means a coating sprayed on the exterior and/or interior of a welded, cemented or soldered seam to protect the exposed metal.

"Two-piece can exterior coating" means a coating applied to the exterior bottom end of a can to reduce the coefficient of friction and to provide protection to the metal.

 

 

R307-352-4. VOC Content Limits.

(1) Operations that use aerosol coating products are exempt.

(2) No owner or operator shall apply coatings with a VOC content greater than the amounts specified in Table 1, unless the owner or operator uses an add-on control device as specified in R307-352-6.

 

TABLE 1

METAL CONTAINER AND CLOSURE COIL COATING LIMITATIONS
(values in pounds 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 Limits (lb/gal) 
 
CANS 
 
Sheet basecoat (interior and exterior) 
and overvarnish                                    1.9 
 
Two-piece can exterior basecoat, 
overvarnish, and end coating                       2.1 
 
Interior body spray 
 
     Two-piece cans                                3.5 
 
     Three-piece cans                              3.0 
 
Three-piece can side seam spray                    5.5 
End sealing compound:  Food cans, non-food 
cans, and beverage cans                            0.1 
Exterior body spray                                3.5 
 
PAILS AND LIDS 
 
Body spray 
 
     Reconditioned interior                       4.2 
 
     Reconditioned exterior                       3.5 
 
     New interior                                 3.5 
 
     New exterior                                 2.8 
 
End sealing compound                              0.5 
 
Inks, all applications                            2.5 
 
Coil 
Coil coating                                      1.7

 

R307-352-5. Work Practices.

(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) No person shall apply any coating unless the coating application method has a transfer efficiency of at least 65%.

The following applications achieve a minimum of 65% transfer efficiency and shall be operated in accordance with the manufacturers specifications:

(a) Electrostatic application;

(b) Flow coat;

(c) Roll coat;

(d) Dip coat;

(e) High-volume, low-pressure (HVLP) spray;

(f) Hand application methods;

(g) Printing techniques; or

(h) Other application method capable of achieving at least 65% transfer efficiency, as certified by the manufacturer.

(3) Solvent cleaning operations shall be performed using cleaning materials having a VOC composite vapor pressure no greater than 1 mm Hg at 20 degrees Celsius, unless an add-on control device is used as specified in R307-352-6.

 

R307-352-6. Add-On Controls Systems Operations.

(1) If an add-on control system is used, the owner or operator shall install and maintain the add-on emission control system in accordance with the manufacturer recommendations and maintain 90% or greater capture and control efficiency. The 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.

 

R307-352-7. Recordkeeping.

(1) The owner or operator shall maintain records of the following:

(a) Records that demonstrate compliance with R307-352. Records shall include, but are not limited to, inventory and product data sheets of all coatings and solvents subject to R307-352.

(b) If an add-on control device is used, records of key system parameters necessary to ensure compliance with R307-352-6.

(i) Key system parameters shall include, but are not limited to, temperature, pressure, flow rates, and an inspection schedule.

(ii) Key inspection 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.

(2) All records shall be maintained for a minimum of 2 years.

(3) Records shall be made available to the director upon request.

 

KEY: air pollution, emission controls, metal containers, coil coatings

Date of Enactment or Last Substantive Amendment: 2017

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