June 20, 2023

New and Revised Business Machine Surface Coating NSPS

EPA’s new and revised rules for the surface coating of plastic parts for business machines are effective March 27, 2023. [88 FR 18056] These new source performance standards in Part 60, Subparts TTT and TTTa regulate VOC emissions that occur primarily in spray booths but are also present in flash-off areas and curing ovens. The regulations have been finalized as proposed, with the subparts being nearly identical except for applicability, emission standards, and presence of the startup, shutdown, and malfunction (SSM) exemption.

The affected facility for both standards is “each spray booth.” [§§60.720(a) and 60.720a(a)] However, due to §§60.722(b) and 60.722a(b), all VOC emissions caused by coatings applied in the spray booths, regardless of the actual point of discharge into the atmosphere, must be included when determining compliance. Thus, VOC emissions outside of spray booths, such as flash-off areas and curing ovens, must also be factored in, even though those areas are not part of the affected facility. EPA estimates approximately 80% of emissions occur in spray booths, 10% in flash-off areas, and 10% in curing ovens. [88 FR 18059]

Differences

Part 60, Subpart TTT now applies to any affected facility for which construction, modification, or reconstruction began after January 8, 1986 but [on or] before June 21, 2022. Subpart TTTa applies to any affected facility for which construction, modification, or reconstruction began after June 21, 2022.
The emission standards for both subparts are measured in kg of VOCs per liter of coating solids applied to the plastic parts for business machines. The Subpart TTT emission rate limits are:

1.5 kg/l from prime coating,
1.5 kg/l from color coating,
2.3 kg/l from texture coating, and
2.3 kg/l from touch-up coating. [§60.722(a)]

The Subpart TTTa emission rate limits are all 1.4 kg of VOCs per liter of coating solids applied regardless of coating operation. [§60.722a(a)]

The SSM exemption is still allowed in Subpart TTT per §60.8(c). The exemption is not included in Subpart TTTa, to be consistent with Sierra Club vs. EPA (U.S. Court of Appeals, D.C. Circuit; Docket No. 02-1135; December 19, 2008). [§60.723a(a); 88 FR 18060]

Similarities

All other aspects of the two standards, including the affected facilities, definitions, performance testing/compliance demonstrations, approved test methods, and reporting/recordkeeping, are the same. The final rule simplifies the definition of “business machine” to eliminate obsolete SIC codes while keeping examples of what those machines are (i.e., computers, telephones, photocopiers). The rule allows use of not only Method 24 or an EPA-approved alternative for determining the VOC content of each coating, but also ASTM D2369-20, ASTM D2697-22, and ASTM D6093-97 as acceptable alternatives. Finally, electronic reporting of performance test reports, quarterly reports of noncompliance, and semiannual statements of compliance are required via the Compliance and Emissions Data Reporting Interface accessible via EPA’s Central Data Exchange.

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This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.