Coating Applications Research Laboratory (CARL)

 

The New Clean Air Act Amendments and How CARL Can Help Indiana Counties

The 1990 Clean Air Act Amendments (CAAA) went into effect in Indiana on December 14, 1996.  The CAAA changes the previous state-controlled air pollution permit programs to federal air pollution programs operated by the states. Two of the CAAA's most important sections are Title III--regulation of Hazardous Air Pollutants (HAPs), and Title V--the air pollution permit and reporting process.  The new air regulations substantially reduce the pollution emission thresholds which define a polluting source (plant or factory) as a major source and/or an area source. A major source in an attainment area is one which emits, or has the potential-to-emit (PTE), 100 tons or more per year of any one criteria pollutant (CO, SOx, NOx, particulate, Pb and/or VOC) or the PTE 10 tons per year of any one Hazardous Air Pollutant (HAP) and/or 25 tons per year of two or more HAPs.  Area sources are generally classified as sources which have the PTE less than the aforementioned thresholds.

The Title V section for criteria pollutants is similar to the thresholds of the previous State Operating Permits (SOPs), which Indiana companies have been subject to for many years. Previously, a major source had to have the PTE 100 tons of criteria pollutants in order to be fully subject to the state's air pollution regulations.  The PTE 100 or more tons of criteria pollutants required substantial material usage and, thus, most small companies were not affected by the air pollution regulations. According to the Title III section (which includes the most restrictive portion of the CAAA), a source can now be classified as a major source if it has the PTE 10 tons or more of any HAP and/or 25 tons or more of two, or more, HAPs.  Many of the Hazardous Air Pollutant chemicals are common solvents used in most thinner and paint formulations.  Under the new CAAA only 10 tons PTE (for a HAP) is required to be categorized as a major source of air pollution.  This amount is 90% lower than the previous 100 ton threshold which a company had to exceed to be designated a major source. Therefore, the number of companies affected by the new CAAA has dramatically increased and now includes many small companies because their potential-to-emit is often in excess of the new, lower thresholds of 10 tons of any one HAP and/or 25 tons of two, or more, HAPs.

The affected companies will have to use reduced VOC-and/or reduced HAP-containing products.  These products may require changes in the companies' production systems. Purdue's Coating Applications Research Laboratory (CARL) can provide invaluable assistance in this endeavor.  The laboratory can test new compliant coatings with respect to dry-time,sheen/gloss, durability and adhesion.  CARL (using the lab's equipment) can also assist companies in the selection of the correct drying technology so that dry-time, equipment cost, production requirements and product quality can be optimized.

In some cases, CARL may be used to investigate and prove new coating technologies, which if employed by client companies, may allow the company to reduce VOC and HAP emissions to levels which exclude them from the major source CAAA regulations.

The New Clean Air Act Amendments for NonAttainment Counties in Indiana and How CARL Can Help

The 1990 Clean Air Act Amendments (CAAA) went into effect in Indiana on December 14, 1996.  The CAAA changes the previous state-controlled air pollution permit programs to federal air pollution programs operated by the states. Two of the CAAA's most important sections are Title III--regulation of Hazardous Air Pollutants (HAPs) and Title V--the air pollution permit and reporting process.  The new air regulations substantially reduce the pollution emission thresholds, which define a polluting source (plant or factory) as a major source and/or an area source. A major source in a nonattainment area is one which emits, or has the potential-to-emit (PTE), 25 tons per year (or less, depending on the severity of nonattainment) of any one criteria pollutant (CO, SOx, NOx, particulate, Pb and/or VOC for which the nonattainment status relates) or the PTE 10 tons per year of any one Hazardous Air Pollutant (HAP) and/or 25 tons per year of two or more HAPs.  Area sources are generally classified as sources which have the PTE less than the aforementioned thresholds.

The Title V section for criteria pollutants is similar to the thresholds of the previous State Operating Permits (SOPs), which Indiana companies have been subject to for many years. Previously, a major source in a nonattainment county had to have the PTE 25 tons of criteria pollutants in order to be fully subject to the state's air pollution regulations.  Sources in attainment counties may emit (or have the PTE) 100 tons or more of the criteria pollutants before being categorized as major sources. Now, depending on the severity of the county's nonattainment status, a major source status may be tripped at PTE of less than 25 tons per year. According to the Title III section (which includes the most restrictive portion of the CAAA), a source can now be classified as a major source if it has the PTE 10 tons of any HAP and/or 25 tons of two, or more, HAPs. Many of the Hazardous Air Pollutant chemicals are common solvents used in most thinner and paint formulations.  Under the new CAAA, only 10 tons PTE (for a single HAP) are required to be categorizedas a major source of air pollution.  This amount is 60% lower than the previous 25-ton threshold which a company had to exceed to be designated a major source.  Therefore, the number of companies affected by the new CAAA in nonattainment counties has dramatically increased and now includes many small companies because their potential-to-emit is often in excess of the new, lower thresholds of 10 tons of any one HAP and/or 25 tons of two, or more, HAPs.

The affected companies will have to use reduced VOC-and/or reduced HAP-containing products.  These products may require changes in the companies' production systems. Purdue's CARL  (Coating Applications Research Laboratory) can provide invaluable assistance in this endeavor.  The laboratory can test new compliant coatings with respect to dry-time, sheen/gloss, durability and adhesion.  CARL(using the lab's equipment) can also assist companies in the selection of the correct drying technology so that dry-time, equipment cost, production requirements and product quality can be optimized.

In some cases, CARL may be used to investigate and prove new coating technologies, which if employed by client companies, may allow the company to reduce VOC and HAP emissions to levels, which exclude them from the major source CAAA regulations.

For more information contact:
Jean Hall
Clean Manuacturing Technology Institute
Phone: 765/463-4749
Fax: 765/463-3795
E-mail: hall@ecn.purdue.edu
CMTI Home Page: http://www.ecn.purdue.edu/CMTI/