1. INFORMATIONAL MEETING – Surface coating operations

2. EPA-defined PM2.5 Nonattainment Area Boundaries Cache Box Elder Tooele Weber Davis Salt Lake Utah

3. Why Revising Coating Rule Volatile organic compounds (VOCs) when released into the atmosphere, react to form PM2.5. Surface coating operations used in a wide variety of industries release VOCs.

4. Regulatory History Early 1980’s – surface coating rule R307-340 part of ozone SIP: Paper coatings Fabric and vinyl coatings Large appliance coating Magnet wire coating Flat wood coating Misc. metal parts coating Graphic arts

5. Revising Coating Rule R307-340 repealed, existing sections made into new rules. Newly regulated coating sectors: Film and foil Plastic parts Sheet, strip and coil Autobody refinishing

6. Coating Rule Structure Three choices: 1.Use coatings with limited VOC content. Each rule specifies VOC limits. For example: wood manufacturing topcoat – 0.8 VOC lb/solid lb 2.Use add-on controls to capture/destroy VOC’s with 80-90% control efficiency: incineration, carbon absorption etc. 3.Combination of option 1 and 2.

7. Where Did VOC Limits Come From? EPA has developed control measure guidance documents called, control techniques guidelines (CTGs) for VOCs. These CTGs are Reasonable Available Control Technology guidance used by states in SIP rulemaking. A list of CTGs can be found on the EPA webpage, http://www.epa.gov/ttn/naaqs/ozone/ctg_act/index.htm. Where a CTG is not available for a specific industrial sector, DAQ has conducted research into other state rulemaking and utilized EPA research databases.

8. ESTIMATED COST StrategyCost in 2011 dollar Surface Coating a.Appliance b.Paper, film and foil c.Metal furniture d.Magnet wire e.Flat wood f.Machinery g.High performance h.Special coatings i.Graphic arts j.Transportation k.Fabric and vinyl l.Sheet, strip & coil m.Plastic parts n.Wood furniture manufacturing o.Autobody refinishing $2,020/ton VOC $1,440/ton VOC $2,020/ton VOC $6,560/ton VOC $2,110/ton VOC $2,020/ton VOC $351/ton VOC $2,020/ton VOC $5,890/ton VOC $238/ton VOC $3,500/ton VOC $3,221/ton VOC $2,020/ton VOC $2,260/ton VOC $2,740/ton VOC Sources: CTG’s and EPA database AirControlNet v4.1 Present Worth Estimate Present worth of U.S. dollar- Samuel H. Williamson, Seven Ways to Compute the Relative Value of a U.S. Dollar Amount, 1774 to present, MeasuringWorth, 2011. Apply GDP deflator, an index number that represents the "average price" of all the goods and services produced in the economy. URL: www.measuringworth.com/uscompare/.

9. Your Role TECHNICAL COMMENTS: DAQ seeks technical comments on the proposed rules; implementation feasibility and associated costs. WHEN: August 6, 2012 HOW: e-mail – jkarmazyn@utah.gov

10. What’s Next DAQ will use information as we proceed with drafting rules that can then be proposed to the Air Quality Board for inclusion into the SIP.