ST. LOUIS – The EPA, in the first of several actions designed to reduce emissions of hazardous air pollutants (HAPs) from a variety of industrial coating processes, has issued proposed emission standards for the first three of 11 industrial-manufacturing categories involving coating application. Proposed standards for the eight other categories are scheduled to be issued over the next several months.
The EPA in July issued a proposed National Emission Standard for Hazardous Air Pollutants, called a NESHAP, for metal coil coating, with a public-comment period on the proposal concluding on Sept. 18. Also in July, the agency issued a proposed NESHAP for boat manufacturing, including coating and adhesive-application processes, with the comment period closing on Sept. 14. But development of the boat-manufacturing regulation has been moved to an EPA group that is focusing on chemicals, not coatings. The standards are scheduled to be finalized within one year after the proposed rules are issued.
Then, in September, the EPA issued a proposed air-toxics rule for paper-coating and other web-coating processes, which affects the process of applying a coating to one or both sides of a continuous web substrate, such as a roll of paper, plastic, film, or foil. The public-comment period on that proposed NESHAP was scheduled to close on Nov. 13.
Hard on the heels of those proposed rules, the agency was expected to issue draft regulations for coating processes in the metal-furniture and large-appliance industries by late September, an agency official said. Those will be followed by proposed NESHAPs for coating processes in several other industrial categories — auto and light-duty truck; fabric printing; coating and dyeing; metal can; metal furniture; miscellaneous metal parts; plastic parts and products; and wood building products. The regulations, which were mandated by the Clean Air Act Amendments of 1990, are scheduled to become effective three years after being finalized and published in the Federal Register.
The EPA in recent years has enacted air toxics standards for several other industries where coatings are applied. Those standards cover aerospace manufacturing, wood-furniture manufacturing, and shipbuilding. The NESHAPs, while not directly regulating toxics content in coatings, can significantly affect coatings manufacturers indirectly through demands for coating reformulation from coatings users.
Details on the proposed NESHAPs affecting coating processes can be obtained from the EPA website www.epa.gov/ttn/uatw/coat/coat.html.
Proposals Affect Major Emission SourcesThe proposed NESHAP on coil coating calls for a limit on HAP emissions of 0.24 pounds of air toxics per gallon of coatings solids applied, based on a monthly average, at major emission sources. Facilities affected by the standard also would have the option of reducing emissions of the HAP by 98%. A major source is defined as a facility that emits more than 10 tons per year of a single hazardous pollutant or more than 25 tons per year of a combination of pollutants. Substances covered by the NESHAPs are any materials included on the Clean Air Act list of 186 hazardous air pollutants. The list includes coil-coating raw materials such as methyl ethyl ketone, glycol ethers, xylenes, toluene and isophorone.
Under the proposed standard, the coatings user can employ formulations with reduced HAP content, or add-on capture and control devices, or both, to meet the specified emissions limits.
The proposed NESHAP on boat manufacturing includes a variety of highly complex guidelines for the different operations that will be regulated. For example, the manufacturer employing open-molding resin and gelcoat operations will be required to comply with a HAP emission limit calculated for that specific facility, with the limit generally based on levels occurring at operations reporting the lowest levels of HAP emissions. The proposed standards also would require that carpet and fabric adhesive operations must use zero-HAP materials, while aluminum-boat wipedown solvents and surface coatings would be subject to HAP content limits.
Under the proposed regulation covering paper-coating and other web-coating processes, operators of application systems can choose among the following three emissions-limit guidelines.
- No more than 5% of the organic HAP applied at existing sources and no more than 2% at new sources, or
- No more than 4% of the mass of coating materials applied at existing sources and no more than 1.6% at new sources, or
- No more than 20% of the mass of solids applied at existing sources and no more than 8% of the solids applied at new sources.
Coil-Coating Industry Sees Flaws in Proposed RuleBased on a preliminary coil-coating industry assessment of the proposed standard affecting coil-coating processes, the EPA is seeking major reductions in HAP emissions from an industry that is already considered to be highly efficient in controlling such emissions.
Kelly Garbin, executive director of the National Coil Coaters Assocation (NCCA), said the proposed rule on coil-coating processes seeks a nationwide reduction in HAP emissions of approximately 77%, based on an industry estimate. Garbin said that exceeds the reductions imposed by earlier standards regulating the wood-furniture, aerospace and printing and publishing industries. Even if the EPA modifies the proposed standard in response to industry complaints, the coil-coatings user will be looking for help from coatings suppliers, in the form of reduced HAP content, Garbin predicted.
“They’re going to ask for assistance to help meet these numbers,” Garbin said. “There’s no question this is going to impact the paint companies.”
In preliminary comments on the proposed coil-coating standard, the NCCA is calling for a number of changes in the final rule. In those comments, the organization says the EPA’s proposed overall control efficiency standard of 98% is too stringent for existing emissions sources, and a 95% standard is suggested instead.
The NCCA also says the EPA should provide more compliance flexibility rather than impose a single set of emission standards. The EPA’s approach “fails to account for the significant diversity in various segments of our industry, in terms of coating use (waterborne versus solventborne),” and other factors, the organization says. The NCCA recommends separate emission standards for waterborne and solventborne coating operations, which would offer a “feasible compliance option for the waterborne lines that currently comply with VOC regulations without employing add-on controls.” The regulation, as currently proposed, could actually discourage greater use of waterbornes and even drive some existing waterborne lines back to solventborne coatings, the association says.
The NCCA’s comments also state that the proposed rule includes overly burdensome testing, monitoring and reporting requirements, and that the EPA is underestimating the economic impact of the proposed standard. The association also points out that its processes are already “environmentally far superior” to post-fabrication coating processes such as spray painting, boasting 100% transfer efficiency and widespread employment of emission-control technologies.
The association said it is “deeply concerned that a rule that significantly disadvantages the coil-coating industry could cause a trend back to more post-fabrication surface coating. This is clearly bad for the environment and should be avoided.”