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EPA Paint and Allied Products Area Source Rulemaking: Interpretation for Powder Coating Manufacturing Operations

Contact: David Darling Tuesday, July 09, 2013

Recently, ACA was able to secure an interpretation from the U.S. Environmental Protection Agency (EPA) regarding powder coating operations under the agency’s finalized Paint and Allied Products Area Source Rulemaking. While certain powder coating manufacturing operations are subject to the rule (i.e., if they use the hazardous air pollutants (HAPs) of concern), EPA recently clarified that the rule does not cover secondary processes that occur after powder coating extrusion, since HAPs would be bound in the coating matrix after this point.

On Dec. 3, 2009, EPA promulgated the Paint and Allied Products Area Source Rulemaking, which may impact coatings (including powder coatings), ink, and adhesive manufacturing operations by requiring add-on pollution controls and work-practice standards to reduce 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. This rule would apply to facilities that use raw materials containing, generating, or producing benzene, methylene chloride, compounds of cadmium, chromium, lead, or nickel above the U.S. Occupational Health and Safety Administration (OSHA) thresholds of 0.1% for carcinogens or 1.0 % for noncarcinogens. The compliance date for this rule was December 3, 2012.

The rule includes separate requirements for the metal HAPs (cadmium, chromium, lead, and nickel compounds) versus organic HAPs (benzene, methylene chloride). Affected facilities that use, generate, or produce the metal HAPs of concern must:

  • Capture and control particulate emissions from addition of dry pigments to a process vessel or grinding/milling process via control; or
  • Fully enclose the grinding and milling processes; or
  • Utilize HAP containing pigments and other solids that are in paste, slurry, solution, or liquids form.
  • Facilities need to complete initial and quarterly visual determination tests to confirm particulate control device is working and conduct weekly inspections of flexible ductwork and initial and annual inspections of rigid duct work and control devices.

Facilities using the organic HAPs of concern need to cover process vessels containing the HAPs of concern. 

While the requirements are burdensome, ACA’s Environmental Management Committee was able to mitigate the extent of the obligations on the coatings industry, convincing EPA to make several significant changes to the rulemaking. At ACA’s behest, EPA published an amendment to the Paint and Allied Products Area Source Rule that will significantly reduce the burden on the paint and coatings industry by allowing companies that use certain chromium compounds to opt out of this rulemaking. As a result, fewer manufacturing facilities will be impacted by its provisions.

ACA has provided a number of compliance webinars for its membership on the Paint and Allied Products Area Source regulation for hazardous air pollutants and worked with EPA on additional guidance regarding compliance with the regulations prior to the initial compliance date.

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