I. What does the rule do?

The plastic parts surface coating rule, __ Fed. Reg. ___, available at
http://www.epa.gov/ttn/atw/plastic/pppfnlpkg22aug03.pdf, is mandated by the Clean Air Act. It requires manufacturing facilities coating plastic parts, for example for the automobile industry, to reduce emissions of toxic air contaminants. These organic hazardous air pollutants include methyl ethyl ketone, methyl isobutyl ketone, toluene ethylene glycol monobutyl ether and other glycol ethers, and xylenes, which are commonly used in the automotive industry.

II. Who could be affected by this rule?

Your facility is affected if you are engaged in surface coating operations including:

Preparation of coating for application (e.g., mixing with thinners and/or other additives);
Surface preparation of plastic parts and products (including the use of a cleaning material to remove dried coating);
Coating application and flash-off;
Drying and/or curing of applied coatings;
Cleaning of equipment used in surface coating;
Storage of coatings, thinners, and/or other additives and cleaning materials; or
Handing and conveyance of waste materials from the surface coating operations.

III. How could my operations be impacted?

If your facility is an existing affected source, your operations will have to decrease emission of toxic air contaminants as follows:

EXISTING SOURCE

For an affected source applying coating to… The organic HAP emission limit you must meet, in kilograms organic HAP emitted/kg coating solids used.
(Same number applies to lb organic HAP emitted/lb coating solids used.)
Thermoplastic olefin substrates 0.26
Automotive lamps 0.45
Assembled on-road vehicles 1.34
Other (general use) plastic parts and products 0.16

If your facility is a new or reconstructed affected source, your operations must meet the following limits:

NEW OR RECOSTRUCTED SOURCE

For an affected source applying coating to… The organic HAP emission limit you must meet, in kilograms organic HAP emitted/kg coating solids used.
(Same number applies to lb organic HAP emitted/lb coating solids used.)
Thermoplastic olefin substrates 0.22
Automotive lamps 0.26
Assembled on-road vehicles 1.34
Other (general use) plastic parts and products 0.16

If you need to reduce your facility’s emissions, you may do so by:

Use of low-hazardous air pollutant or non-hazardous air pollutant coatings and other materials;
Use of coatings and materials that comply with the emissions limits;
Use of capture system and add-on control devices. If this option is used, then you must develop and implement a work practice plan to minimize organic HAP emissions from mixing operations, storage tanks and other containers, and handling operations for coatings, thinners, and/or other additives, cleaning materials, and waste materials.
VI. When do I need to act?

You have until April 19, 2007 to make facility changes, obtain permits, etc. However, compliance need not be demonstrated until the end of the initial compliance period, an approximately twelve-month period beginning on the compliance date, which is April 19, 2007, and ending on May 1, 2008.

V. What else should I keep in mind?

The rule also requires you to provide the following information to the EPA:

Initial notification requirements;
Notification of performance test if using a capture system and control device;
Notification of compliance status;
Recordkeeping requirements, including periodic reports and other reports regarding startups, shutdowns, or malfunctions.
Importantly, the rule provides for a “predominant activity alternative” to facilitate compliance with multiple coating NESHAP and multiple emission limits. In other words, if your manufacturing activities fall into several different regulated categories of coating activities, the rule provides a method by which you may qualify to comply with only one set of regulations.

Also keep in mind that the emission limitations established by this rule are in addition to any possible additional requirements you might face in the future due to plant expansions, new ozone standards, etc.