Plastic Parts and Products (Surface Coating) NESHAP Subpart PPPP Kim Teal Coatings and Consumer Products Group (919)

(919) Plastic Parts and Products Applicability "Major" source of HAP which means that they have the potential to emit 10 tons/year of any one HAP or 25 tons/year of multiple HAP Use at least 100 gallons of material/year for the coating (includes paints, sealants, caulks, inks, adhesives, and maskants) of plastic Coating operation must not be specifically covered by another NESHAP (e.g., in- mold/gel coating are covered under the Reinforced Plastic Composites NESHAP).

(919) Plastic Parts and Products Example of End-Products Transportation Equipment Cars, Heavy Duty Trucks, Personal Watercraft Communications/Electronics Equipment Cell Phones, Television/Computer Housings Toys & Sporting Goods Pool Floats, Train Sets Household and Personal Products Picture Frames, Glasses Military Equipment

(919) Plastic Parts and Products Current MACT Floor Approach 4 Subcategories Assembled On-Road Vehicle General Use Headlamp Thermoplastic Olefin (TPO) Covers only “post-mold” coating operations (i.e., no gel/in-mold coating) Average of all materials used in coating related operations Annual average calculated on a rolling monthly basis Calculated using MSDS information

(919) Plastic Parts and Products Emission Limits DRAFT PRELIMINARY PRE-DECISIONAL All Limits stated in Kg (Lb) Organic HAP emitted/Kg (Lb) Coating Solids Used Assembled On-Road Vehicle Surface Coating --Existing New 1.34 Headlamp Surface Coating --Existing New 0.26 TPO Surface Coating --Existing New 0.17 General Use Surface Coating --Existing New 0.16

(919) Plastic Parts & Products Definitions Assembled On-Road Vehicle--Coating of a fully assembled motor vehicle or trailer intended for on-road use, including, but not limited to, automobiles and light trucks that have been repaired after a collision or otherwise repainted, fleet delivery trucks, motor homes and other recreational vehicles (including camping trailers and fifth wheels). Assembled on-road vehicle coating also does not include the use of adhesives, sealants, and caulks used in assembling on-road vehicles.

(919) Plastic Parts & Products Definitions (continued) Coating— material applied to a substrate for decorative, protective, or functional purposes. Such materials include, but are not limited to, paints, sealants, caulks, inks, adhesives, and maskants. Decorative, protective, or functional materials that consist only of protective oils for metal, acids, bases, or any combination of these substances are not considered coatings for the purposes of Subpart PPPP.

(919) Plastic Parts & Products Definitions (continued) General Use--Coating operations that do not meet the definition of assembled on-road vehicle, headlamp, or TPO coating operation. Headlamp—Coating operations where coatings are applied to the surface of automotive headlamp components, including the application of reflective argent coatings and clear topcoats. Headlamp coating does not include any coating operation performed on an assembled on-road vehicle.

(919) Plastic Parts & Products Definitions (continued) Liquid Plastic Coating—coating made from fine, particle-size polyvinyl chloride (PVC) in solution (also referred to as Plastisol) Plastic Part and Product—any piece or combination of pieces of which at least one has been formed from one or more resins. Such pieces may be solid, porous, flexible, or rigid.

(919) Plastic Parts & Products Definitions (continued) Protective Oil—organic material applied to metal providing lubrication or protection from corrosion without forming a solid film including lubricating, evaporative, and extrusion oils. TPO-- means any coatings applied, singularly or in combination as a system, to a TPO substrate, including adhesion promoters, primers, colorcoats, clearcoats and topcoats. Thermoplastic olefin coating does not include the coating of TPO substrates on assembled on-road vehicles.

(919) Plastic Parts and Products Coming Attractions Proposal Package currently undergoing internal agency review enroute to the Office of Management and Budget (OMB) Early Fall 2002—Administrator Signature and Federal Register publication Fall 2002 public comment period Late Fall 2002 public hearing, if requested. Fall 2003 publication of Final Rule in Federal Register

(919) Plastic Parts and Products Additional Information Status Reports & Notifications with request to be added to Subpart PPPP stakeholder Subpart PPPP webpage Docket Information Air and Radiation Docket and Information Center (6102), Attention Docket Number A-99-12, U.S. EPA, 1200 Pennsylvania Avenue, NW, Washington, DC 20460