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New EPA Paint, Chemical Rules Loom

Wednesday, September 19, 2012

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Three years after they were issued, new federal environmental rules are set to take effect for certain coating, adhesive, and  chemical manufacturers.

 The rules 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).
The rules 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).

The U.S. Environmental Protection Agency issued the so-called “Area Source” rules in 2009. Now, compliance deadlines are looming.

Facilities subject to the Paint and Allied Products Area Source Rule will need to comply by Dec. 3, 2012. Facilities subject to EPA’s Chemical Manufacturing Area Source Rule will need to comply by Oct. 29, 2012.

Reducing HAPs

The two rules 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 those 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, according to the American Coatings Association, which has been tracking the regulations. This includes facilities permitted as "synthetic minor sources."

Paint and Allied Products

The Paint and Allied Products rule applies to coating, adhesive and ink area source manufacturing operations that have North American Industry Classification System (NAICS) codes 325510 (Paint and Coating Manufacturing), 325520 (Adhesive Manufacturing), and 325910/325998 (Printing Ink and Miscellaneous Chemical Product Manufacturing).

Affected sources are those facilities that use, generate, or produce these "HAPs of concern" above the relevant OSHA thresholds: benzene, methylene chloride, compounds of cadmium, chromium, lead or nickel.

Affected facilities will need to comply with the rule by Dec. 3 and will 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 also apply.

Chemical Manufacturing

The Chemical Manufacturing rule applies to operations under NAICS code 325 (Chemical Manufacturing), including resin manufacturing. Affected are those 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.

Affected facilities will need to comply with the rule by Oct. 29.

There is one wrinkle to the chemical rule rollout, however; On Jan. 20, 2012, EPA published a notice of reconsideration for the rule. The comment period for that reconsideration closed March 30, and EPA has issued no further statements on the measure. So for now, the Oct. 29 deadline holds.

ACA is clearly hoping for firmer guidance from EPA on the rule, however, saying: "It is hoped the issues will be resolved before the Oct. 29, 2012 compliance date.”

   

Tagged categories: Adhesive; Emissions; EPA; Facility Managers; Hazardous air pollutants; Resins; VOC emissions

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