Air pollution control regulations currently affect many organic coatings operations and new regulations are being developed that will increase the number of facilities affected. Facilities covered by existing and/or new regulations may need to obtain permits, control and monitor air emissions, and submit reports.
Most Federal regulations are implemented through state programs. Check with your state air agency to determine the specific requirements for your facility.
The pollutants of concern from coating operations are volatile organic compound (VOC) emissions and hazardous air pollutants (HAPs). VOCs are present in most paints, but are found in much higher amounts in solvent-based paints than in waterborne formulations. HAPs are specific chemicals and include many of the common paint solvents (e.g., xylene, toluene, methyl ethyl ketone or MEK). In many cases, chemical substances regulated as VOCs are also listed as HAPs. VOC limitations have been in effect since the 1970s for some coating operations, while Federal rules limiting HAPs are relatively new.
There are six elements of the Federal regulations that coaters should be aware of:
Industrial Surface Coatings Rule Development
EPA is currently developing regulations for a number of industrial surface coating operations categories. The regulations under development are national emission standards for hazardous air pollutants (NESHAPs) under Section 112 of the Clean Air Act (commonly called MACT rules) and for some of the categories, national volatile organic compound (VOC) rules or control technique guidelines (CTG) under Section 183(e) of the Act. EPA h as emphasized involvement of a wide variety of stakeholders interested in these rule makings. Information such as announcements of meetings, agendas, meeting minutes, and papers for review and comment can be accessed below for each active project. In addition, general information common to the source categories is available under the coordination section such as maps to meetings, local hotel information, lists of active participants, and cross-cutting issue papers.
Current and Future Regulations
Use this locator to determine which current and future federal regulations pertain to your coating operation.
Risk Management Programs under Clean Air Act Section 112(r)
Under CAA section 112(r), EPA must adopt regulations for the prevention and detection of accidental releases of chemicals and response to releases that occur. On June 20, 1996, EPA published its final rule on accidental release prevention. The regulations (40 CFR part 68) require covered facilities to develop and implement a risk management program that includes analyses of offsite consequences of accidental chemical releases to the air, a five-year accident history, a prevention program, and an emergency response program. In addition, the facility must submit a risk management plan (RMP) that describes its hazards and prevention activities and indicates its compliance with the regulations.
Any source with more than a threshold quantity (maximum amount of a substance in a process, not the maximum quantity on site) of listed "regulated substance" must comply with this regulation. The threshold quantities are relatively high and most manufacturers will not regulated under Section 112(r). Examples of "regulated substances" and thresholds that may pertain to manufacturers include:
- Ammonia (10,000 lbs.)
- Chlorine (2,500 lbs.)
- Hydrochloric acid (conc. 30% or greater) (15,000 lbs.)
- Nitric Acid (15,000 lbs.)
- Formaldehyde (15,000 lbs.)
- Methyl chloride (10,000 lbs.)
- Propane (10,000 lbs.)