No. 38685 (Amendment): Rule R307-353. Plastic Parts Coatings

(Amendment)

DAR File No.: 38685
Filed: 07/07/2014 10:40:30 AM

RULE ANALYSIS

Purpose of the rule or reason for the change:

The EPA has indicated that it cannot approve Rule R307-353 as a Reasonable Available Control Technology (RACT) rule as part of Utah's PM2.5 State Implementation Plan (SIP) until it is amended to clarify that the amount of control removal specified in each rule is based on the entire system and the inspection and recordkeeping requirements of the rule are expanded.

Summary of the rule or change:

The rule is amended to require an overall control efficiency of the add-on emission control system of 90%, clarify methodology for determining capture efficiency, and to include additional recordkeeping requirements for the add-on emission control system.

State statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

There are no new requirements in this proposed rule for the State of Utah; therefore, there are no anticipated costs or savings.

local governments:

There are no new requirements for local government; therefore, there are no anticipated costs or savings.

small businesses:

There are two options to reduce the emissions of VOCs. The first, and more cost-effective, option for small businesses is to use products that meet the VOC limits as specified in Table 1. The other option, which likely only very few larger sources would do, is to use an add-on emission control system that meets the 90% efficiency threshold.

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

There are no new requirements for persons other than small businesses, or local government entities; therefore, there are no anticipated costs or savings.

Compliance costs for affected persons:

There are two options to reduce the emissions of VOCs. The first, and more cost-effective option for small businesses, is to use products that meet the VOC limits as specified in Table 1. The other option, which likely only very few larger sources would do, is to use an add-on emission control system that meets the 90% efficiency threshold. It is difficult to determine the cost of installing and operating an add-on emission control system that meets the 90% requirements, as appropriate emission control systems for each source are extremely variable.

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

In most cases businesses will choose to use products that meet the VOC limits in Table 1 of the rule, as that option is usually the most cost-effective. Should a business choose to install and operate an add-on emission control system that meets the 90% overall capture and control efficiency, there would be additional costs to that business. However because appropriate emission control systems for each source are extremely variable, those costs are difficult to predict.

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 [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:

09/02/2014

This rule may become effective on:

10/02/2014

Authorized by:

Bryce Bird, Director

RULE TEXT

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.

[(1) ]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.

[(2) In Box Elder and Tooele counties, R307-353 applies to the following sources:

(a) Existing sources as of May 1, 2013 with the potential to emit 5 tons per year or more of VOC, including related cleaning activities; and

(b) New sources as of May 1, 2013 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. [Emission Standards]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.

 

. . . . . . .

 

(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.

 

. . . . . . .

 

(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.

 

. . . . . . .

 

(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 of 0.21 pounds per gallon or less.

(3) All sources subject to R307-353 shall maintain records demonstrating compliance with[ all provisions of] R307-353-5, R307-353-6 and R307-353-7(2)[ on an annual basis].

(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. [Optional ]Add-On Control[s] Systems Operations.

[(1) The owner or operator may install and maintain an incinerator, carbon adsorption, or any other add-on emission control device, provided that the emission control device will achieve at least a 90% or greater emission reduction.

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

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

](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.

 

[R307-353-9. Compliance Schedule.

All sources within Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties shall be in compliance with this rule by January 1, 2014.

 

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

Date of Enactment or Last Substantive Amendment: [May 1, 2013]2014

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

 

---