Comment submitted by Division of Air Pollution Control, Ohio Environmental Protection Agency (OhioEPA)

Docket No. EPA-HQ-OAR-2007-0329 Comments on DRAFT Control Techniques Guidelines for Large Appliance Coatings: The section on "Powder Coatings" (page 6) provides general information applicable to the large appliance industry. This section should indicate that a low solids adhesion enhancer may be needed as the initial step in a two-step powder coating process. Table 1 and the sections on "The CTG" and the "The NSPS" could be clarified to indicate that the CTG limit is a daily volume-weighted average limit and the NSPS limit is a monthly volume-weighted average limit. Presumably the recommended limit under this draft CTG is a daily volume-weighted average limit. It is suggested that USEPA exclude from the definition of coating any material that does not form a solid film, similar to the exclusion of a "protective oil" under the 2002 NESHAP. "'Protective oil' means an organic material that is applied to a substrate for the purpose of providing lubrication or protection from corrosion without forming a solid film. This definition of protective oils includes, but is not limited to, lubricating oils, evaporative oils (including those that evaporate completely), and extrusion oils." It is suggested that a two-step powder coating process be regulated by combining the usage of adhesion enhancer coating and powder coating to determine the amount of VOC per gallon of coating, excluding water and exempt solvents and the amount of VOC per gallon of coating solids. This would be similar to the combining of coatings for the production of pressure sensitive tapes and labels in which a low-solids precoat and adhesive coating are both applied. In Appendix B, the summary of the large appliance coating regulation for Ohio should be revised to state that it applies to a prime coat, single coat, or topcoat coating line as follows: (a) in 24 counties [listed in OAC rule 3745-21-09(A)(1)], to existing and new coating lines; (b) in the other 64 counties, to any new coating line and to existing and new coating lines at a facility with potential to emit equal to or greater than 100 tons VOC per year. A new coating line is a coating line for which construction or modification commenced on or after October 19, 1979. The emission limitation does not apply to the use of quick drying lacquers for repair of scratches and nicks that occur during assembly, provided that the maximum usage of such lacquers does not exceed one quart in any eight hour period. The emission limitation is achieved by: (a) complying coatings; or (b) control system that meets either 4.5 lbs VOC/gal solids or an overall 81% reduction with a control device efficiency of at least 90%; or (c) an alternative emissions limitation based upon a "tested" transfer efficiency greater than 60%.