Coating Manufacturing Emissions Rule Published

FRIDAY, MARCH 17, 2023

The U.S. Environmental Protection Agency recently published the final rule amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for coating manufacturing facilities. The updated amendments include provisions for inorganic hazardous air pollutant standards for process vessels.

Rule Summary

The Miscellaneous Coating Manufacturing (MCM) category reportedly covers the manufacturing of paints, inks and adhesives that are intended to be applied to a substrate and consist of a mixture of resins, pigments, solvents and/or other additives, where the material is produced by a manufacturing operation where materials are blended, mixed, diluted or otherwise formulated.

The EPA reports that this category includes 42 source facilities.

The NESHAP regulation establishes emission limits and work practice requirements for new and existing miscellaneous coating manufacturing operations. This includes process vessels, storage tanks, wastewater, transfer operations, equipment leaks and heat exchange systems.

Implementing sections of the Clean Air Act, MCMs are required to have all major sources to meet hazardous air pollutant (HAP) emission standards reflecting application of the maximum achievable control technology.

According to the EPA, HAP emitted from miscellaneous coating manufacturing facilities include toluene, xylene, glycol ethers, and methyl isobutyl ketone. Exposure to these substances has been demonstrated to cause adverse health effects such as irritation of the lung, eye and mucous membranes, effects on the central nervous system and cancer.

The final rule is anticipated to reduce HAP emissions by 4,900 tons per year for existing facilities that manufacture miscellaneous coatings.

Latest Amendments

According to the American Coatings Association, the HAP standards for process vessels amendments follow the mandated technology review conducted under the Clean Air Act, dating back to August 2020. Prior to this, there were not regulations for metal HAP from process vessels.

Following the review, the EPA announced it was finalizing the amendments to address unregulated emissions from the MCM source category, by setting maximum achievable control technology standards for inorganic HAP.

The latest rule:

  • Requires facilities with process vessels emitting inorganic HAP emissions, which consist of particulate matter (PM) emissions from addition of raw materials in powder form to paint mixing vessels, to demonstrate initial compliance with PM emissions of 0.014 grains per dry standard cubic foot (gr/dscf) for existing sources and 0.0079 gr/dscf for new sources; and
  • Requires facilities to demonstrate ongoing compliance through monitoring of control devices such as baghouses and fabric filters.

The ACA reports that facilities will be required to comply continuously with the standards during all operations that emit metal HAP, but this does not apply to pigments and other solids that are in paste, slurry or liquid form.

The final rule was published in The Federal Register and went into effect on Feb. 22.

However, the EPA is allowing one year to with the final rule amendments, with an effective compliance date of Feb. 22, 2024. The agency reportedly maintains that one year is an adequate amount of time for facilities to conduct performance tests on existing inorganic HAP control devices.

During a workgroup in August, the ACA adds that it submitted comments to the EPA, including suggesting a three-year compliance date. 

“While the agency’s final rule did not add design evaluations of PM control devices as an alternative to Method 5 performance testing, EPA recognizes that there may be instances where inorganic HAP materials are processed for very limited periods of time,” wrote the Association.

“As such, EPA’s final rule clarifies that the performance test may be conducted during any solids addition or processing steps, and not just during the addition of inorganic HAP-containing materials.”


Tagged categories: Coating Materials; Coatings; Coatings manufacturers; Coatings raw materials manufacturers; Emissions; Environmental Control; Environmental Controls; Environmental Protection; Environmental Protection Agency (EPA); EPA; Government; hazardous materials; Health & Safety; Health and safety; NA; North America; Program/Project Management; Raw materials; Regulations

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