plastic parts and products surface coating mact summary

2. What source categories and subcategories are affected by this rule and what are the primary emission sources?

The final rule applies those who own or operate a plastic parts and products surface coating facility that is a major source, or is located at a major source, or is part of a major source of HAP emissions. A plastic parts and products surface coating facility is defined as any facility engaged in the surface coating of any plastic part or product. If application of coating to a substrate occurs, then surface coating also includes associated activities, such as surface preparation, cleaning, mixing, and storage. However, these associated activities do not comprise surface coating if the application of coating does not occur. Coating application with handheld, non-refillable aerosol containers, touch-up markers, marking pens, or the application of paper film or plastic film which may be pre-coated with an adhesive by the manufacturer is not a coating operation for the purposes of this rule.

A facility will not be subject to the final rule if the plastic parts and products surface coating facility is located at an area source. An area source of HAP is any facility that has the potential to emit HAP but is not a major source. A facility may become an area source by limiting the source’s potential to emit HAP enforceable requirements through their permitting authority. This rule does not apply to surface coating or a coating operation that meets any of the following criteria:

• Coating operations conducted at a source that uses only coatings, thinners and/or other additives, and cleaning materials that contain no organic HAP.

• Surface coating that occurs at research or laboratory facilities, or is part of janitorial, building, and facility maintenance operations, or that occurs at hobby shops operated for noncommercial purposes.

• Surface coating of plastic on-site at installations owned or operated by the Armed Forces of the United States (including the Coast Guard and the National Guard of any such State) or the National Aeronautics and Space Administration (NASA), or the surface coating of military munitions manufactured by or for the Armed Forces of the United States (including the Coast Guard and the National Guard of any such State).

• Surface coating where plastic is extruded onto plastic parts or products to form a coating.

• Surface coating of magnet wire.

• In-mold coating or gel coating operations in manufacturing of reinforced plastic composites that meet the applicability criteria of the Reinforced Plastic Composites Production NESHAP.

• Surface coating of plastic components of wood furniture that meet the applicability criteria for Wood Furniture Manufacturing NESHAP.

• Surface coating of plastic components of large appliances that meet the applicability criteria for large appliance surface coating.

• Surface coating of plastic components of metal furniture that meet the applicability criteria for Metal Furniture Surface Coating NESHAP.

• Surface coating of plastic components of wood building products that meet the applicability criteria for Wood Building Products Surface.

• Surface coating of plastic components of aerospace vehicles that meet the applicability criteria for Aerospace Manufacturing and Rework NESHAP.

• The application of specialty coatings defined in Appendix A to 40 CFR Part 63, Subpart GG to a plastic aerospace vehicle or component.

• Surface coating of plastic components of ships that meet the applicability criteria for Shipbuilding and Ship Repair NESHAP.

• Surface coating of plastic using a web coating process that meets the applicability criteria for Paper and Other Web Coating NESHAP.

• Surface coating of fiberglass boats or parts of fiberglass boats where the facility meets the applicability criteria for Boat Manufacturing NESHAP, except where the surface coating of the boat is a post mold coating operation performed on personal watercraft or parts of personal watercraft.

• Surface coating of plastic components of automobiles and light duty trucks that meet the applicability criteria for Automobiles and Light-Duty Trucks Surface Coating NESHAP. If a facility performs surface coating of plastic parts or products that meet the applicability criteria for both the Automobiles and Light-Duty Trucks NESHAP and these NESHAP rules, then the facility may comply with the requirements of the Automobiles and Light-Duty Trucks NESHAP for the surface coating of all their plastic parts used in automobile or light-duty truck manufacturing in lieu of complying with each subpart separately.

This rule contains four subcategories: general use coating, thermoplastic olefin (TPO) coating, automotive lamp coating, and assembled on-road vehicle coating. Each subcategory consists of all coating operations, including associated surface preparation, equipment cleaning, mixing, storage, and waste handling of organic HAP.

The general use subcategory includes all surface coating operations in the plastic parts and products source category that are not included in the other four subcategories. This includes operations that coat a wide variety of substrates, surfaces, and types of plastic parts, as well as more specialized coating scenarios.

The TPO subcategory includes all materials used in the surface coating of TPO substrates for automotive applications. The TPO subcategory requires the use of solvents to facilitate proper adhesion of coatings.

The automotive lamp subcategory addresses the unique requirements for surface coating of exterior automotive lamps (e.g., headlamps, tail lamps, etc.). Automotive lamps are subject to regulatory requirements established by the National Highway Traffic Safety Administration resulting in the use of specific coatings to achieve required performance specifications.

The assembled on-road vehicle subcategory addresses surface coating of fully assembled vehicles that are physically larger than the other plastic parts and products coated in this source category and that may contain heat-sensitive parts. The large size and presence of heat-sensitive parts make certain lower-HAP technologies, such as heat-cured waterborne coatings, infeasible for assembled on-road vehicles. The assembled on-road vehicle subcategory will affect primarily recreational vehicle manufacture and automobile body refinishing.

The majority of organic HAP emissions from facilities engaged in plastic parts and products surface coating operations can be attributed to the application, drying, and curing of coatings. The remaining emissions are primarily from cleaning operations. In most cases, organic HAP emissions from mixing, storage, and waste handling are relatively small.