SEFA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 2771 f
EPA-450/3-85-019b
December 1986
Air
Surface Coating Final
Of Plastic Parts EIS
For Business
Machines—
Background
Information for
Promulgated Standards
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NOTICE
This document has not been formally released by EPA and should not now be
construed to represent Agency policy. It is being circulated for comment
on its technical accuracy and policy implications.
SURFACE COATING OF PLASTIC PARTS FOR BUSINESS MACHINES-
BACKGROUND INFORMATION FOR PROMULGATED STANDARDS
Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1986
U S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12tn Moor
Chicago, IL 60604-3590
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Final
Environmental Impact Statement
for the Surface Coating of Plastic Parts for Business Machines
Prepared by:
Jack R. Farmer (Date)
Director, Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
1. The promulgated standards of performance would limit emissions of
volatile organic compounds (VOC's) from new, modified, and
reconstructed facilities that surface coat plastic parts for business
machines. Section 111 of the Clean Air Act (42 U.S.C. 7411), as
amended, directs the Administrator to establish standards of
performance for any category of new stationary source of air pollution
that ". . . causes or contributes significantly to air pollution which
may reasonably be anticipated to endanger public health or welfare."
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense,
Transportation, Agriculture, Commerce, Interior, and Energy; the
National Science Foundation; the Council on Environmental Quality;
State and Territorial Air Pollution Program Administrators; EPA
Regional Administrators; Local Air Pollution Control Officials; Office
of Management and Budget; and other interested parties.
3. The comment period for review of this document is 75 days from the
date of publication of the proposed standard in the Federal Register.
Mr. C. Douglas Bell may be contacted at (919) 541-55/8 regarding the
date of the comment period.
4. For additional information contact:
Ms. Laura Butler or Mr. Doug Bell
Standards Development Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27/11
Telephone: (919) 541-5578
5. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, N.C. 27711
Telephone: (919) 541-2777
National Technical Information Service
5285 Port Royal Road
Springfield, Va. 22161
11
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TABLE OF CONTENTS
Section Page
1 SUMMARY 1-1
1.1 Summary of Changes Since Proposal 1-1
1.2 Summary of Impacts of Promulgated Action 1-2
1.2.1 Alternatives to Promulgated Action 1-2
1.2.2 Environmental Impacts of Promulgated Action 1-2
1.2.3 Energy and Economic Impacts of the
Promulgated Action 1-3
1.2.4 Other Considerations 1-3
1.2.4.1 Irreversible and Irretrievable
Commitment of Resources 1-3
1.2.4.2 Environmental and Energy Impacts
of Delayed Standards 1-3
2 SUMMARY OF PUBLIC COMMENTS 2-1
2.1 Standards and Affected Facility 2-1
2.2 Achievability of the Standard 2-3
2.2.1 Availability of Compliance Coatings 2-3
2.2.2 Availability of Primers for Waterborne Coatings 2-4
2.3 Recordkeeping and Reporting Requirements 2-4
2.3.1 Recordkeeping and Reporting Requirements 2-4
2.3.2 Sample Size for Method 24 2-6
2.4 Emission Control Technology 2-7
2.5 Economic Impact 2-8
2.6 EMI/RFI Shielding 2-8
2.7 References for Chapter 2 2-9
LIST OF TABLES
Table Page
2-1 List of Commenters on Proposed Standards of Performance
for Surface Coating of Plastic Parts for Business
Mach i nes 2-2
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1. SUMMARY
On January 8, 1986, the Environmental Protection Agency (EPA)
proposed new source performance standards (NSPS) for surface coating of
plastic parts for business machines (51 FR 866) under authority of
Section 111 of the Clean Air Act. Public comments were requested in the
proposal in the Federal Register. A total of three comments from
industry, one from a trade association, and one from a State agency were
submitted during the comment period. The comments that were submitted,
along with responses to these comments, are summarized in this document.
The summary of comments and responses serves as the basis for the
revisions made to the standards between proposal and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
In response to the public comments and as a result of EPA
reevaluation, certain changes have been made in the proposed standards.
The more significant changes are summarized below.
Section 60.721, Definitions, has been amended by the addition of a
definition for the term "coating operation." The addition of this
definition will clarify the compliance provisions of the regulation for
situations where two or more types of coatings are applied at different
times at the same spray booth.
Also in Section 60.721, the meaning of the symbol "T" used in the
equations to determine compliance was revised to be the transfer
efficiency for each type of coating application equipment used at a
coating operation. A symbol "Tavq" was added to represent the volume-
weighted average transfer efficiency for a coating operation to ensure
that the distinction is clear between transfer efficiency and average
transfer efficiency in equations presented later in the regulation.
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Section 60.722, Standards for volatile organic compounds (VOC's), has
been clarified to state specifically that all VOC emissions that are
caused by coatings applied in each affected facility, regardless of the
actual point of discharge of those emissions into the atmosphere, are
covered by the standard and must be included when compliance with the
numerical emission limits is determined. Refer to Chapter 2, Section 2.1,
Standards and affected facility, for further explanation of the change.
In Section 60.723, Performance tests and compliance provisions,
Table 1 has been revised to clarify the applicability of the transfer
efficiency (TE) values. Table 1 now specifies the TE's for each type of
application equipment for specific types of coatings (i.e., prime, color,
texture, fog, and touch-up). This change was made because air-assisted
airless and electrostatic spray guns have not been used to apply texture,
touch-up, or fog coats. Therefore, the TE's presented in Table 1 at
proposal were not applicable to these types of operations. However, if an
owner or operator can demonstrate to the satisfaction of the Administrator
that TE's other than those presented in Table 1 are appropriate, the
Administrator will approve their use on a case-by-case basis. The TE
values for application methods not listed in Table 1 shall also be
approved by the Administrator on a case-by-case basis.
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of Volume I of
the background information document (BID) for the proposed standards
(EPA-450/3-85-019a). These regulatory alternatives reflect the different
levels of emission control, one of which is selected that represents best
demonstrated technology (BDT), considering costs, nonair quality health,
and environmental and economic impacts for facilities that surface coat
plastic parts used in business machines.
1.2.2 Environmental Impacts of Promulgated Action
The environmental impacts are discussed in Chapter 7 and Appendix D
of the Volume I BID. These impacts have remained unchanged since
proposal. The changes that have been made to the regulation are not of
sufficient magnitude to affect the environmental impact analysis.
Therefore, the Volume I BID now becomes the final Environmental Impact
Statement for the promulgated standards.
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1.2.3 Energy and Economic Impacts of the Promulgated Action
The energy impacts of the proposed standards were evaluated in
Chapter 7 of the Volume I BID. It was determined that the control
technologies that are the basis for the regulatory alternatives have a
negligible effect on the energy requirements for facilities that surface
coat plastic parts for business machines. Therefore, a negligible energy
impact is attributed to the proposed or final standards.
The economic impacts of the proposed standards were evaluated in
Chapter 9 of the Volume I BID. Since proposal, no changes have been made
to the economic analysis. The nationwide cost in the fifth year of
implementation is projected to be a net credit.
1.2.4 Other Considerations
1.2.4.1 Irreversible and Irretrievable Commitment of Resources. The
Volume I BID concluded in Chapter 7 that for many of the regulatory
alternatives, additional equipment will be required. However, consumption
of steel and other raw materials for this purpose will be small compared
to the national usage of each material.
1.2.4.2 Environmental and Energy Impacts of Delayed Standards.
Delay in the standards would cause a similar delay in realizing the
beneficial impacts associated with the standards. No changes in the
potential effects of delaying the standards have occurred since proposal
of the standards.
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2. SUMMARY OF PUBLIC COMMENTS
A list of commenters, their affiliations, and the EPA docket entry
number assigned to each comment is shown in Table 2-1. Five letters
containing comments on the proposed standards for the surface coating of
plastic parts for business machines industry were received. Significant
comments have been organized into the following six categories:
1. Standards and Affected Facility;
2. Achievability of the Standards;
3. Recordkeeping and Reporting Requirements;
4. Emission Control Technology;
5. Economic Impact; and
6. Electromagnetic Interference/Radio Frequency Interference
(EMI/RFI) Shielding.
The comments and the issues they address are discussed in the following
sections of this chapter.
2.1 STANDARDS AND AFFECTED FACILITY
Comment; One commenter (IV-D-4) stated that because the affected
facility is the spray booth, the standards for VOC emissions set forth in
Section 60.722 could be interpreted as applying only to those VOC's
emitted from the spray booth. The effect of this interpretation would be
to exclude VOC's that are emitted from outside the spray booth (i.e.,
flash-off area and oven) from the coverage of the standards. To rectify
this problem, the commenter suggested that VOC emission limits be
established for the entire line (i.e., spray booth, flash-off area, and
oven) but that the reconstruction provisions still apply only to the spray
booth.
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TABLE 2-1. LIST OF COMMENTERS ON PROPOSED STANDARDS OF
PERFORMANCE FOR PLASTIC PARTS FOR BUSINESS MACHINES INDUSTRY3
Docket item No. Commenter/affiliation
IV-D-1 Mr. Robert K. Brothers
Director, Regulatory Affairs
Eastman Kodak Company
343 State Street
Rochester, New York 14650
IV-D-2 Mr. Ryan Sullivan
Research and Development Associate
The B. F. Goodrich Company
Electronic Chemicals Department
9221 Brecksville Road
Brecksville, Ohio 44141
IV-D-3 Ms. Ellen Robinson
Staff Director
The Society of the Plastics Industry, Inc.
Structural Foam Division
355 Lexington Avenue
New York, New York 10017
IV-D-4 Mr. Charles M. Taylor
Chief, Division of Air Pollution Control
State of Ohio Environmental Protection Agency
361 East Broad Street
Columbus, Ohio 43266-0149
IV-D-5 Mr. Ryan Sullivan
Research and Development Associate
The B. F. Goodrich Company
Electronic Chemicals Department
9921 Brecksville Road
Brecksville, Ohio 44141
aThe docket No. for this project is A-83-50. Dockets are on file at EPA
Central Docket Section in Washington, D.C. and at the Office of Air
Quality Planning and Standards in Durham, N.C.
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Response: The EPA believes that the wording of the proposed
standards precludes the interpretation suggested by the commenter and,
therefore, believes it to be unnecessary to implement the commenter's
solution. Section 60.722 uses the language "no affected facility shall
cause the discharge into the atmosphere" (emphasis added). The coatings
application which takes place in the spray booth is clearly the cause of
VOC emissions from the flash-off area and oven. Therefore, VOC emissions
from these areas are covered by the standards.
To protect against possible misinterpretation, Section 60.722 has
been revised by the addition of the following:
(b) All VOC emissions that are caused by coatings applied in each
affected facility, regardless of the actual point of discharge of
emissions Into the atmosphere, shall be included in determining
compliance with the emission limits in (a) above.
The language of Section 60.723 also precludes the commenter's
interpretation. The calculations by which performance is determined
include all VOC's resulting from coatings applied in the spray booth and
do not allow for the exclusion of VOC's that may be emitted from the
flash-off area and oven. It should be noted that because the affected
facility remains unchanged, the reconstruction provisions still apply only
to the spray booth.
2.2 ACHIEVABILITY OF THE STANDARDS
2.2.1 Availability of Compliance Coatings
Comment: One commenter (IV-D-3) stated that "conformance coatings"
(i.e., coatings that comply with the standards) cannot achieve performance
levels for abrasion, adhesion, and chemical resistance. Another commenter
(IV-D-1) stated that "compliance coatings" (high-solids, solvent-based and
waterborne coatings) could not meet performance specifications (i.e.,
chemical and stain resistance) for certain business machine uses. The
commenter suggested that the regulation allow variances on a case-by-case
basis if the coater can demonstrate to the satisfaction of the
Administrator that no coating exists that meets both the emission limits
and necessary performance specifications.
Response: The commenters were contacted for information on the
specific cases for which they stated that compliance coatings could not
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1 -1*
meet certain performance specifications. However, no information was
provided that would clarify the specific situations mentioned by the
commenters.
The EPA has determined that high-solids, solvent-based and waterborne
coatings that comply with the emission limits when used with appropriate
coating application technologies are being used for prime, color, texture,
and touch-up coats by coaters in at least two States.5'6 These coatings
have been approved by some original equipment manufacturers (OEM's) for
performance specifications including abrasion, adhesion, and chemical and
physical stain resistance. ' The EPA expects coaters to use high-solids,
solvent-based coatings to achieve compliance and has determined that these
coatings are available for use. ' Waterborne coatings also can be used
to meet the standards and are available for use.5'6 For the reasons
presented above, EPA has determined that the standards are achievable and
has not revised the proposed standards.
2.2.2 Availability of Primers for Waterborne Coatings
Comment: One commenter (IV-D-3) stated that none of the primers
available for waterborne coatings will achieve the standards.
Response; Discussions with several coaters, coating manufacturers,
and a regional air quality management district representative affirmed
that primers that will achieve the standards are available for use with
waterborne coatings. Two coaters stated that they are using waterborne
coatings for primers and, in addition, that these waterborne coatings can
be applied as a combination primer/barrier coat for certain types of
plastic that are sensitive to direct application of solvent-based
coatings. ' Two coating manufacturers are producing waterborne primer
coatings.8'9 A regional air quality management district representative
also stated that waterborne primers are available that will achieve the
standards and are being used 1n production. He noted that, in many
cases, waterborne coatings are not used as primers but are applied as a
color coat to the part(s) without the use of a primer coating.
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2.3 RECORDKEEPING AND REPORTING REQUIREMENTS
2.3.1 Recordkeepinq and Reporting Requirements
Comment: One commenter (IV-D-1) stated that recordkeeping
requirements to determine compliance are excessive, particularly for large
surface coating operations that coat both plastic and metal parts with a
variety of coatings. The commenter also stated that the cost of analyzing
coatings using EPA Reference Method 24 could be unreasonable. He
requested that the language of the standards be changed to allow alternate
methods of compliance on a case-by-case basis for facilities that use a
large number of paint formulations. One such method suggested by the
commenter would allow small volume coatings to be grouped with a large
volume coating having similar formulation and application characteristics,
with the large volume coating required to comprise 90 percent of the total
coating volume. The costs of monthly compliance testing would be reduced
because it would be necessary only to test the large volume coating
formulation and to measure the total coatings volume.
Response: The level of effort necessary for recordkeeping is not
considered excessive. Most coaters maintain at least some of the infor-
mation that would be required by these standards, and some coaters are
already maintaining the information needed to perform the calculations to
determine compliance with the standards. This information is available
from the operation and inventory logs kept by the coaters. In addition,
the recordkeeping requirements, as written, are the only feasible way for
a coater to demonstrate continuous monthly compliance with the
standards. The time and costs necessary to determine compliance have
previously been evaluated by EPA and were determined to be reasonable.
In most cases, coating composition data determined by EPA Reference
Method 24 can be obtained from the coating manufacturer. The coater can
use these data and plant records of VOC used for dilution to perform the
calculations necessary to demonstrate monthly performance. The EPA
recognizes that there are rare cases for which the coater cannot obtain
EPA Reference Method 24 data from an outside coating manufacturer.
Examples of such cases occur when coaters manufacture coatings in-house or
modify the formulation (e.g., tinting) of a purchased coating. The
estimated cost to the coater to perform EPA Reference Method 24 is
$200 per coating. The EPA considers this cost to be reasonable.
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Because the time and costs necessary to perform the compliance
calculations were determined to be reasonable and because EPA Reference
Method 24 coating composition data can, in most cases, be obtained from
the coating manufacturer, EPA has determined that the recordkeeping and
reporting requirements of the standards are not excessive. Therefore, it
is unnecessary to implement the commenter's suggested method of compliance
determination.
2.3.2 Sample Size for Method 24
Comment; One commenter (IV-D-1) stated that the 1-liter sample size
requested for the determination of VOC content of each coating using EPA
Reference Method 24 is unreasonable, especially in the case of specialty
coatings. The commenter said that 1 liter may be equivalent to the total
volume of coating manufactured or supplied for a specialty coating,
whereas EPA Reference Method 24 requires only a 10-gram sample size. The
commenter noted that the cost of manufacturing or purchasing additional
paint for sample analysis alone would be unreasonable. The commenter
recommended that the standards be rewritten to specify a sample size of
10 grams.
Response: The sample size was set at 1 liter for several reasons:
(1) losses of the sample could occur during transfer of the sample between
pieces of equipment or sample container and equipment, (2) losses of the
sample could occur during equipment setup, and (3) additional runs of the
EPA Reference Method 24 tests could require additional sample in the event
of problems with the initial runs. Therefore, to account for any sample
losses and for the need for additional test runs, the sample size remains
at 1 liter.
Additionally, the low-volume usage of specialty coatings is expected
to be a rare occurrence. It should be noted that if coaters run the EPA
Reference Method 24 test, they are free to use as small a volume as
necessary to conduct the test. However, the 1-liter sample size require-
ment would apply when a coating sample is requested for analysis by EPA.
2.4 EMISSION CONTROL TECHNOLOGY
Comment: One commenter (IV-D-4) requested additional information on
control techniques and cost effectiveness of add-on controls for the
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oven. In further discussion with the commenter to clarify his submittal,
he stated that in many cases, the State of Ohio requires that emissions
from new ovens be controlled with best available technology (i.e., an
incinerator), yet the standard does not give credit for the emission
reduction achieved through the use of add-on control devices.
The commenter also stated that there was no discussion on techniques
to increase the VOC concentration and to reduce the volumetric flow rate
of the exhaust gases from the spray booth and the oven (e.g., recircu-
Tation systems). He noted that these factors could affect the cost
effectiveness of any vapor control technologies.
Response: The EPA evaluated incineration as a vapor control
technology for the spray booth, flash-off areas, and oven for a medium-
size typical surface coating facility.12*13 Total coating consumption for
this model plant was estimated to be 155,000 liters per year with total
VOC emissions of 85 megagrams (Mg) per year. The cost-effectiveness value
for vapor control of the oven and flash-off areas was estimated to be
$3,380/Mg of VOC controlled.12 The cost-effectiveness values for vapor
control of the spray booth were estimated to range from $10,700/Mg of VOC
controlled to $20,620/Mg of VOC controlled, depending on the spray booth
ventilation rate. Spray booth and oven exhaust air recirculation
systems were not examined in this analysis.
The EPA believes that the costs of add-on control devices will result
in few, if any, coaters selecting such devices to control VOC emissions
from facilities that coat plastic parts for business machines. However,
the compliance provisions in Section 60.723(b)(2)(iv) are written to allow
an owner or operator to use add-on controls in order to reduce VOC
emissions to within the limits of the standard. If add-on controls are
used, the owner or operator must demonstrate that the volume-weighted
average mass of VOC's emitted to the atmosphere during each nominal
1-month period per unit-volume of coating solids applied (N) is within the
limits given in Section 60.722 of the standards because of this equipment
in order to demonstrate compliance. In such cases, compliance would be
determined by the Administrator on a case-by-case basis.
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2.5 ECONOMIC IMPACT
Comment: One commenter (IV-0-3) said that because compliance
coatings that will meet all performance specifications are not available,
the proposed standards would force OEM's to change to solid wall plastics
that can have molded-in color, thereby eliminating structural foam and all
coatings and severely impacting both industries, or to move tooling,
molding, and finishing operations offshore, which would result in
additional loss of jobs in the already depressed business machine
cabinetry market as well as loss of local, State, and Federal tax
revenues.
Response: The commenter was contacted for clarification of areas
where compliance coatings would not meet the performance specifications,
and EPA was referred to an industry contact.1 No specific information to
support the comment was given by the contact or by a suggested third
, 1<* 1 5
contact. *
Several coaters and coating manufacturers have affirmed that both
waterborne and high-solids solvent-based coatings that could meet the
fl Q
standards are available and are being used by industry. * In addition,
EPA has performed an economic market analysis, presented in Chapter 9 of
the Volume I BID for this industry, that indicates that the net effect
from the use of the combination of the BDT coatings and coating
application equipment is a net credit to industry of $30 million/yr.
Therefore, because BOT coatings are available and are being used and,
because there is a net credit from the use of BDT coatings, no adverse
economic impacts are expected.
2.6 EMI/RFI SHIELDING
Comment: One commenter (IV-D-2, IV-D-5) stated that there should be
an EMI/RFI shielding standard and that the basis of this standard should
be a waterborne EMI/RFI shielding coating. The commenter noted that the
proposed exemption of shielding coatings from the regulation provides no
motivation to maintain the momentum toward lower VOC emissions without an
increase in the cost of coating operations. He suggested that the
standard be revised to give credit to coaters using waterborne shielding
coatings instead of solvent-based shielding coatings.
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Response: The waterborne EMI/RFI shielding coating referred to by
the commenter was not available during development of the standards. The
coating is presently undergoing production trials in some areas of the
country but cannot be considered a demonstrated shielding coating at this
time. *16 At the 4-year review of the standard, EPA will reevaluate the
need and technological bases for a standard for VOC emissions from EMI/RFI
shielding.
2.7 REFERENCES FOR CHAPTER 2
1. Telecon. Larson, J., MRI, with Robinson, E., The Society of the
Plastics Industry, Inc. April 10, 1986. Discussion about comments
submitted by Ms. Robinson.
2. Telecon. Larson, J., MRI, with Simmons, I., Eastman Kodak Company.
April 8, 1986. Discussion about comments submitted by Mr. Brothers.
3. Telecon. Larson, J., MRI, with Simmons, I., Eastman Kodak Company.
June 5 and 17, 1986. Discussion about coatings usage, coating test
results, and plant operations.
4. Telecon. Larson, J., MRI, with Simmons, I., Eastman Kodak Company.
August 5, 19, and 22, 1986. Discussion about coatings usage.
5. Telecon. Larson, J., MRI, with Kyle, H., Hewlett-Packard. April 15,
1986. Discussion about coatings usage and application techniques.
6. Telecon. Larson, J., MRI, with Guthrie, J., Bay Area Air Quality
Management District. April 11, 1986. Discussion about coatings
usage in the district.
7. Telecon. Larson, J., MRI, with McDonald, C., Foam Molding Company.
April 15, 1986. Discussion about coatings usage and application
techniques.
8. Telecon. Larson, J., MRI, with Edwards, F., Breakthrough Coatings
Company. April 15, 1986. Discussion about coatings manufactured by
the company.
9. Telecon. Larson, J., MRI, with Adams, G., Cardinal Industrial
Finishes. April 9, 1986. Discussion about coatings manufactured by
the company.
10. Docket Item No.
(Supporting Statement for Standard Form 83.).
11. Telecon. Larson, J., MRI, Butler, L., EPA:SDB, and Salman, D.,
EPA:CPB, with Juris, W., State of Ohio Environmental Protection
Agency. April 16, 1986. Clarification of comments on proposed NSPS.
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12. Memorandum from Larson, J., MRI, to Plastic Parts project file.
November 15, 1985. Cost-effectiveness calculations for the control
of VOC emissions from flash-off areas and ovens used in the surface
coating of plastic parts used in business machines.
13. Memorandum from Newton, D., MRI, to Plastic Parts project file.
February 17, 1984. Cost effectiveness calculated for the control of
VOC emissions from the surface coating of plastic parts used in
business machines by thermal incineration.
14. Telecon. Larson, J., MRI, with Reilly, J., Electro Kinetic Systems,
Inc. April 25, 1986. Discussion about coatings usage.
15. Telecon. Larson, J., MRI, with Keough, G., CTI/EM Lubricants, Inc.
May 19, 1986. Discussion about coatings usage.
16. Telecon. Larson, J., MRI, with Sullivan, R., B. F. Goodrich.
April 22, 1986. Discussion about new waterborne EMI/RFI shielding
coating.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing!
1. REPORT NO. 2
EPA-450/3-85-0195
4. TITLE AND SUBTITLE
Surface Coating of Plastic Parts for Business
Machines-- Background Information for Promulgated
Standards
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U. S. Environmental I Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director for Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3 RECIPIENT'S ACCESSION NO.
S REPORT DATE
December 1986
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3817
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
IS. SUPPLEMENTARY NOTES
of
I
Standards of Performance for the control of VOC emissions from affected facilities
that perform exterior surface coating of plastic parts for business machines are
being promulgated under authority of Section 111 of the Clean Air Act. These
standards apply to each new, modified, and reconstructed spray booth in which
plastic parts for business machines are surface coated and for which construction
commences on or after the data of proposal of the regulation. This document
contains a detailed summary of the public comments on the proposed standards
(51 FR 854), responses to these comments, and a summary of the changes to the
proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS
c. COSATI Meld/Croup
Air Pollution
Pollution Control
Standard of Performance
Exterior Surface Coating
Business Machine
Volatile Organic Compounds
Plastic Part
Air Pollution Control
13B
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS I Tins Report/
Unclassified
21. NO. OF PAGES
20 SECURITY CLASS /This page/
\ Unclassified
Jfi.
22. PRICE
EPA Form 2220-1 (Re». 4-77)
PR£VIOUS EDITION 'S OBSOLETE
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