FPA Urgent Request for Input for Proposed EPA Revision

LINTHICUM, MD, USA—The Flexible Packaging Assn. (FPA) is requesting information from its members regarding the Environmental Protection Agency's proposed revision "to 'cover' mixing operations in the web coating MACT." According to FPA's release:

  • EPA is scrambling to put together an amendment or rule change to exclude these operations from Miscellaneous Organic Chemical Manufacturing (MOCM) and Miscellaneous Coating Manufacturing (MCM) NESHAPs. FPA is requesting your review and feedback of the following items via email or fax by no later than Monday, June 3, 2002. Please note EPA needs to make the required changes in the rule immediately because the POWC MACT Rule is ready for OMB review. Sorry for a short notice, but the schedule is EPA driven.

    Item #1: Please review the [information below] for definition of "ancillary" operations. Let me know if it meets your requirements. If not, please provide amendment to the language.

  • Draft Surface Coating Ancillary Operations Definition
    Any activity associated with the preparation of coatings and coating-line equipment prior to application of a coating. Including the following:
    Coating Mixing
    viscosity adjustment
    color tints/additive blending
    stirring
    two-component coating systems

    Coating-Line and Coating-Line Parts Cleaning
    Solvent and Coating Storage
    Wastewater

  • Draft Rule Language for the MON/MCN

    The applicability section of these rules would state that:
    Surface coating ancillary operations at facilities subject to Subpart JJJJ of part 63, Paper and Other Web Surface Coating, are not subject to the requirements of the rule.

  • Draft Language for the POWC Preamble

    Would describe what surface-coating ancillary operations at POWC facilities are;
    Would clarify that surface-coating ancillary operations are part of the POWC source category;
    Would clarify that available data was inadequte to determine a MACT floor for ancillary operations, therefore, emission limitations were not set for them, and they are not included in the affected source in the final rule.

  • Item #2: Review your current emissions data for operations listed in Item #1, and let me know:
    (a) The type of organic HAPS from mixing inks and/or coatings
    (b) Quantity of emissions from above operations
    (c) Basis/technique used for estimating emissions in (b) above
    (d) Type of controls used including work practices.

    Our plan is to get our "comments" back to EPA by Wednesday, June 12, 2002. Please call me if you have any questions or need additional information.
    Ram Singhal
    410/694-0823 (ph)
    410/694-0900 (fax)
    rsinghal@flexpack.org



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