Monday, August 22, 2022

ACA Submits Comments to EPA Proposed Amendments to NESHAP for MCM

On Aug. 8, ACA submitted comments to the U.S. Environmental Protection Agency (EPA) on the proposed amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coating Manufacturing (MCM) facilities. EPA’s proposed amendments would establish inorganic HAP standards for process vessels, following the mandated technology review conducted under the Clean Air Act (CAA), originally promulgated in August 2020. The current MCM NESHAP does not regulate metal HAP from process vessels.

Specifically, EPA is proposing to revise Table 1 of 40 CFR part 63 subpart HHHHH to include the emission limits that apply to process vessels based on the following findings by EPA:

  • Existing sources demonstrate initial compliance with the particulate matter (PM) emissions limit of 0.014 gr/dscf (grains per dry standard cubic foot); and
  • New sources demonstrate initial compliance with the PM emissions limit of 0.0079 gr/dscf.

Background

During the manufacturing process, with the addition of raw materials in powder form to paint mixing vessels, emissions of metal HAP in the form of PM emissions may occur and are typically collected and routed to a PM control device (i.e., baghouse, fabric filters, cartridge filters, or scrubbers). EPA’s proposal addresses the currently unregulated metal HAP emissions from this category and proposes Maximum Achievable Control Technology (MACT) for emission sources of metal HAP.

As proposed, facilities will be required to comply continuously with the standards during all operations that emit metal HAP; but it does not apply to pigments and other solids that are in paste, slurry, or liquid form. The agency also provided a mechanism for owners and operators to demonstrate that materials containing inorganic HAP metals below certain levels are not subject to the standards, as well as a definition for “material containing metal HAP.” Finally, the agency proposed monitoring, recordkeeping, and reporting requirements that apply specifically to these facilities.

EPA has proposed a compliance date of one year from the date of a final rule for existing sources.

ACA Comments

Compliance Dates

In its comments, ACA urged EPA to provide three years to comply with the revised rule for existing facilities that need to install a PM control device or modify or replace an existing control device, since many facilities will need to do so to meet the metal HAP emission limits specified in Table 1. ACA expressed support for the one-year compliance timeline for all other existing sources.

ACA noted that the EPA proposal erroneously states that “all facilities in the source category currently have PM controls in place using existing baghouses, fabric filters, or cartridge filters.” The proposal also does not account for facilities that may need to install new controls. It is unclear whether EPA’s statement is intended to mean that each existing MCM-subject process vessel that will become subject to the metal HAP requirements is already controlled by a PM control device, or instead that each MCM-subject facility has at least one PM control device that it uses to control PM emissions from at least one of its process vessels. Because the rule applies to vessels, one or more facilities that have multiple vessels will likely need additional control devices, not all of which are necessarily in place.

Alternatives to Method 5 Compliance Testing 

When coatings are made, the addition of dry solids to MCM-subject process vessels tends to be short in

duration and often occurs infrequently, representing only a fraction of the time required to conduct Method 5 test runs. The proposed rule correctly specifies that the metal HAP emission limits apply to MCM-subject process vessels only “during the addition of dry pigments and solids that contain material containing metal HAP” (see proposal at 40 C.F.R. §§ 63.8005(a)(1)(iii) and Table 1, Item 2.c.). Moreover, facilities are required to conduct a compliance demonstration under “normal operation,” consisting of at least three Method 5 test runs of the corresponding PM control device (see proposal at 40 C.F.R. § 63.8005(i)(1)).

In practice, Method 5 test runs usually require an hour or more, whereas the addition of dry solids to an MCM-subject vessel typically occurs over a much shorter duration period. For example, under normal operation, the addition of solids from bags or sacks into some vessels occurs in no more than 10 or 15 minutes for each batch. It also might be a matter of days, or even months, before another batch is made involving the addition of dry solid metal HAP. For such vessels, only one of the three Method 5 test runs might reasonably occur while dry solids are being added to the vessel, and with that solids addition possibly spanning only part of the duration of the single-test run.

In its comments, ACA underscored that Method 5 testing is not feasible for vessels that are infrequently or rarely subject to MCM. The MCM rule applies to vessels ≥ 250 gallons only during uses of the vessel that meet the rule’s applicability criteria at 40 C.F.R. § 63.7985(a). At some facilities, only a small number of batches (in some cases, no more than one or two batches in a year) are subject to MCM, and even fewer of these might involve the addition of metal HAP in dry solids. Notably, some facilities manufacture many different types of materials in the same vessel. Some of the manufactured materials might not be coatings, and/or some materials are coatings made without “processing, using, or producing a HAP.” Neither of those uses of a vessel are subject to MCM (see 40 C.F.R. §§ 63.7985(a)(2)–(3)). Overall, Method 5 testing is not feasible for PM control devices that service one or more vessels that are subject to the MCM rule and in dry metal HAP service for a small number of instances each year.

In addition, Method 5 testing is not feasible for vessels for which PM emissions are routed to a control device that operates only while the dry materials are being added to the vessel. As such, ACA encouraged U.S. EPA to modify the proposed rule by adding design evaluations as an option in lieu of Method 5 testing with specific suggestions outlined in its comments. ACA also stressed that the agency already authorizes design evaluations under some circumstances for the MCM rule’s organic HAP emission limits and authorizes design evaluations for particulate HAP in several related NESHAP rules.

Clarification for Inapplicability of Subpart SS

Finally, ACA sought official clarification from EPA that Subpart SS, which is referenced by the existing MCM rule, does not apply to PM control devices. To avoid any potential confusion, ACA asked EPA to specify in the rule’s subsection language that Subpart SS does not apply to the proposed requirements for metal HAP by adding qualifiers and proposed explicit clarifying verbiage.

ACA will continue to engage with EPA as it progresses through its amendment rulemaking process. 

Contact ACA’s Rhett Cash for more information.

The post ACA Submits Comments to EPA Proposed Amendments to NESHAP for MCM appeared first on American Coatings Association.



from American Coatings Association https://www.paint.org/neshap-mcm-comments/
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SCAQMD to Hold Public Workshop for Rule 1168 on September 1

The South Coast Air Quality Management District (SCAQMD) will host a public workshop to present and solicit information on and comments for Proposed Amended Rule 1168 – Adhesive and Sealant Applications  – on Sept. 1 at 1:00 pm EDT (10:00 am Pacific). The meeting will be held virtually, with an agenda and Zoom meeting link available here.

SCAQMD will be accepting comments on its proposed amendments through Sept. 15. The proposed amendments are tentatively scheduled for a public hearing before SCAQMD’s Governing Board on Nov. 4, 2022.

In preparation for the public workshop, SCAQMD provided a Preliminary Draft Proposed Amended Rule 1168 and Preliminary Draft Staff Report. Notably, the proposal includes the following:

  • Delays to the effective date for certain categories where the technology assessment has demonstrated more time would be needed;
  • Created further subcategories to better characterize and refine VOC limits;
  • Prohibited the use of Para-Chlorobenzotrifluoride (pCBtF) and Tertiary-Butyl Acetate (t-BAc); and
  • Allowed certain categories to maintain higher VOC limits due to the prohibition on pCBtF and t-BAc or because a newly created subcategory of adhesive or sealant requires a higher VOC limit.

The workshop is the fifth in a series kicked off  in February 2022 whereby stakeholders were invited work with SCAQMD staff and provide input on the technology assessments – and the status of exempt solvents (e.g., PCBTF) – for the following categories:

  • Single Ply Roof Membrane Sealant
  • All Other Roof Sealants
  • Top and Trim Adhesive
  • PVC Welding Cement
  • CPVC Welding Cement
  • ABS to PVC Transition Cement

Rule 1168 was adopted in April 1989 to reduce VOC emissions from adhesive and sealant applications. The rule has been amended 14 times. The last amendment was in October 2017 and included VOC limit reductions for 18 categories and new Quantity and Emissions Reporting (QER) requirements.

In compliance with the regulation, SCAQMD will report on the results of the technology assessments to the Stationary Source Committee prior to the implementation date for these categories.

More information on Rule 1168 may be found at https://www.aqmd.gov/home/rules-compliance/compliance/vocs/adhesive-and-sealants.

ACA monitors and engages in regulatory activity, including Rule 1168, through its Consumer Products Committee.

Contact ACA’s Rhett Cash for more information.

The post SCAQMD to Hold Public Workshop for Rule 1168 on September 1 appeared first on American Coatings Association.



from American Coatings Association https://www.paint.org/scaqmd-sept-22/
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Evonik Increases Production Capacities for Matting Agents

Evonik’s Coating Additives business line is expanding the production capacity of its ACEMATT® precipitated matting agents at its manufacturing facility in Taiwan.

According to the company, the capacity increase will help meet the rising demand for matting agents in Asia, with the capacity expansion scheduled for completion by the second half of 2023.

“The capacity expansion of our leading matting agents in Taiwan further emphasizes our commitment to the growing markets in Asia and to all our regional and multinational customers,” says Maximilian Morin, head of Industrial & Transportation Coatings at Evonik Coating Additives. “We are continuously expanding our position as a truly global partner for our coatings customers.”

The company says the ACEMATT® matting agents manufactured in Taiwan exhibit the same properties as the products that are currently manufactured at Evonik’s production site in Bonn, Germany.

The post Evonik Increases Production Capacities for Matting Agents appeared first on American Coatings Association.



from American Coatings Association https://www.paint.org/evonik-increases-production-capacities-for-matting-agents/
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Chemours Begins Commissioning at Sand Mine in Florida

The Chemours Company recently announced it has begun commissioning its newest mineral sand mine, Trail Ridge South in Florida. According to the company, the new mining operation represents a $93 million investment that will create approximately 50 new jobs in the three-county area.

Commissioning work to test operational aspects of the new mine has begun, and startup is anticipated later this year. Expansion of its mining operations will allow Chemours—the only domestic producer of titanium and zirconium minerals and one of only two domestic producers of rare earth minerals—to have additional access to these high-quality concentrated deposits used to produce Chemours’ Ti-Pure™ brand of titanium dioxide (TiO₂).

“The commissioning of our new Trail Ridge South mine is much more than an operational milestone—it represents a huge win for our customers, community, and our country,” said Jody Sciance, co-director of Minerals Operations for Chemours. “This secure, domestic mineral supply means more tons of TiO₂ for our pigment customers, more jobs for Clay County residents, and access to critical materials identified by the U.S. Department of the Interior as vital to our nation’s security and economic prosperity—all with minimal impact on our local environment.”

The post Chemours Begins Commissioning at Sand Mine in Florida appeared first on American Coatings Association.



from American Coatings Association https://www.paint.org/chemours-begins-commissioning-at-sand-mine-in-florida/
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Ashland Completes Sale of Land in Ajax, Canada

Ashland, Inc. recently announced it has completed the sale of approximately six acres of land in Ajax, Canada, to Sunray Group of Hotels Inc., a Canadian real estate developer, for (CAD) $12.25 million, with net proceeds of (CAD) $9.2 million.

Ashland is selling its unused land to fund the newly established environmental trust.

“We are continuing to execute our plan to sell valuable land that is not being utilized by the company, and we will place the proceeds in an environmental trust,” said Guillermo Novo, Ashland chair and CEO. “Our environmental trust is an integral part of our core values and strategy and a clear example of our environment, social and governance commitment.”

The post Ashland Completes Sale of Land in Ajax, Canada appeared first on American Coatings Association.



from American Coatings Association https://www.paint.org/ashland-completes-sale-of-land-in-ajax-canada/
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Norwegian Producer Jotun Exits Russia

Jotun is exiting Russia after selling its assets in the country to the industrial group Atomstroykomplex. Terms of the deal were not disclosed.

The Norwegian producer of paints and coatings shut down its Russian plant on March 3 after Moscow’s invasion of Ukraine.

“It has become more and more difficult to operate in the country under the ongoing sanctions, and we realize the situation won’t change in the near future,” said President and CEO Morten Fon. “Our employees have been our main priority, and several options have been evaluated over the last few months. We regret that the conclusion was to sell the company. We believe we have found a good solution for our employees under the ownership of Atomstroykomplex.”

Jotun has operated in Russia since 1989 and has had its own production facilities since 2017. At end of 2021, the company had activities throughout the country with a staff of more than 300 people. Current employees will keep their positions with the new owner. Brands, intellectual property and technology are not part of the transaction.

The post Norwegian Producer Jotun Exits Russia appeared first on American Coatings Association.



from American Coatings Association https://www.paint.org/norwegian-producer-jotun-exits-russia/
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IGM Resins Opens New Laboratory in Brazil

IGM Resins recently announced opening of a new application laboratory at IGM Resins do Brasil. According to the company, the new laboratory will test the efficiency and performance of radiation-curing products for various segments.

“This new laboratory will allow us to get even closer to the customer to understand their real expectations and keeping the focus and centricity on our customers according to our ‘Go, Grow, Green’ strategy,” the company said.

The company says the aim of the new laboratory is to improve performance and/or remove technical barriers to potential new applications as well as optimize processes.

The post IGM Resins Opens New Laboratory in Brazil appeared first on American Coatings Association.



from American Coatings Association https://www.paint.org/igm-resins-opens-new-laboratory-in-brazil/
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