Aerosol spray paint VOC standards
EPA published a draft rule proposing amendments to the National Volatile Organic Compound (VOC) Emission Standards for Aerosol Coatings. This part of the Clean Air Act (CAA) establishes reactivity-based emission standards for the aerosol coatings category, commonly known as aerosol spray paints. The current rulemaking comments close this month, on or before November 16, 2021. After that date EPA will review all comments received, make any adjustments necessary to the draft rule, and then publish a final rule.
EPA is proposing to make multiple changes to Tables 1 and 2 in subpart E of part 59. In Table 1 the draft rule combines the ‘‘enamel,’’ ‘‘lacquer,’’ and ‘‘clear or metallic’’ coatings into one category of ‘‘Hobby/Model/Craft Coatings.’’ The Hobby/Model/Craft category limit will be set equal to 1.6 g O3/g VOC. The ‘‘clear’’ and ‘‘pigmented’’ subcategories will be combined under the ‘‘Shellac Sealers’’ category, with a limit set at 1.00 g O3/g VOC. EPA also is proposing to add six new specialty coating categories and corresponding limits for those categories:
- Electrical/Electronic/Conformal Coatings, with a category limit set equal to 2.00 g O3/g VOC;
- Flexible Coatings, with a limit equal to 1.60 g O3/g VOC;
- Mold Release Coatings, with a limit equal to 1.10 g O3/g VOC;
- Rust Converter, with a limit equal to 1.10 g O3/g VOC;
- Two Component Coating, with a limit equal to 1.20 g O3/g VOC; and
- Uniform Finish Coating, with a limit equal to 1.30 g O3/g VOC.
EPA is proposing to amend Tables 2A, 2B, and 2C by adding new compounds and reactivity factors (RFs) and updating existing reactivity values.
In this rulemaking, EPA is proposing to eliminate part of the VOC definition that exempts de minimis contributions to VOC emissions. Specifically, it would retain part (a), where compounds that comprise less than 0.1 percent of the product weight are excluded from the product’s mass-weighted reactivity, and eliminate (b), the exclusion of low reactivity compounds that comprise more than 0.1 percent but less than 7.3 percent of the product weight. These two actions, in combination, would make EPA’s national regulation consistent with the aerosol coatings regulation in California.
Last, continuing with efforts that extend beyond this proposed rule, EPA has included revisions to the existing aerosol coatings rule that would require regulated entities to submit electronic copies of required notifications and reports via EPA’s Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI). This would eliminate the current hard copy submission requirements for Temporary Variances, Initial Notification, Change to Information in Initial Notification, Response to Written Notification, Exemption Claim Initial Notification, Exemption Claim Annual Report, Notice of Certifying Entity to Maintain Records, Notice Rescinding Certification, and Triennial Reports.
Key to remember: EPA draft updates to VOC Emission Standards for Aerosol Coatings propose the combination of coating categories, remove de minimis exemptions, and switch to e-reporting.
