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Compliance deadlines are nearing for two new federal emissions rules that will affect the coatings industry, and the American Coatings Association is trying to help its members get ready.
Facilities have until Dec. 3 to comply with the U.S. Environmental Protection Agency’s new Paint and Allied Products Area Source Rule. To that end, ACA has published a compliance guide for members on its website.
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EPA |
| The Clean Air Act identifies 188 chemicals or chemical classes as hazardous air pollutants, or air toxics. |
Meanwhile, the association is working to push back the implementation date of EPA’s Chemical Manufacturing Area Source Rule, now set to kick in Oct. 29.
Both rules, finalized in 2009, may impact coatings, ink, adhesive, and resin manufacturing operations by requiring add-on pollution controls and work-practice standards to reduce hazardous air pollutants (HAPs).
“Area Sources” (also known as "minor sources") are facilities with the potential to emit less than 10 tons per year of any HAP or less than 25 tons per year of aggregate HAPs, notes ACA, which represents coating manufacturers.
Paint & Allied Products
The Paint and Allied Products area source rule applies to coating, adhesive and ink area source manufacturing operations with North American Industry Classification System (NAICS) codes 325510, 325520 and 325910/325998.
The rule affects facilities that use, generate or produce the following so-called “HAPs of concern” above the Occupational Safety and Health Administration thresholds of 0.1 percent for carcinogens and 1.0 percent for non-carcinogens such as trivalent chromium: benzene, methylene chloride, compounds of cadmium, chromium, lead or nickel.
ACA says EPA will revise the rulemaking this spring to increase the threshold for trivalent chromium.
Affected facilities would need to install baghouses (or use pigments in paste form) for the metal HAPs and install covers for the organic HAPs. Additional work practices, recordkeeping, and reporting requirements would also apply.
Chemical Manufacturing
The Chemical Manufacturing area source rule applies to operations under NAICS code 325, including resin manufacturing.
The rule affects facilities that generate or produce the following HAPs of concern above the OSHA thresholds: 1,3-butadiene, 1,3-dichloropropene, acetaldehyde, chloroform, ethylene dichloride, hexachlorobenzene, methylene chloride, quinoline, hydrazine and compounds of arsenic, cadmium, chromium, lead, manganese and nickel.
ACA says it is requesting an extension to the compliance date on the chemical manufacturing rule.
Members may contact ACA’s David Darling or Tim Serie for more information on these rules.
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