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Monitoring by Control Technique - Compliant (Low/No VOC/HAP) Inks and Coatings

Description

Many industry sectors involving surface coating operations are currently using coatings and (printing) inks containing low or no Volatile Organic compounds (VOCs) or Hazardous Air Pollutants (HAPs) in the formulation. These materials are often referred to as low- or no- VOC/HAP coatings. Although the term low- or no-VOC/HAP is not definitive in terms of the actual levels of VOC or HAP in a particular coating, most EPA and industry representatives use the term to mean "compliant coatings" or those materials having VOC/HAP contents equal to or less than any applicable limits. Examples of low- and no-VOC/HAP coatings include waterborne, UV-cured, high-solids, and powder coatings.

Replacing higher emitting (noncompliant) coatings with lower emitting (compliant) coatings is a good example of how coating manufacturers and end-users are promoting EPA Pollution Prevention (P2) strategy (in accordance with the national policy expressed in the Pollution Prevention Act of 1990). Pollution prevention is EPA first priority within an environmental management hierarchy that includes: 1) prevention; 2) recycling; 3) treatment; and 4) disposal or release.

Some examples of studies to evaluate the use of lower emitting coatings or solvents are listed below.

Monitoring Information

Monitoring low- and no-VOC/HAP coatings used in a coating operation is basically a two-step process. First, the owner or operator of the source using such materials demonstrates (and documents) the VOC/HAP content of each low- or no-VOC/HAP coating meets the applicable requirement(s). This can be done by product testing or using product data sheets, material safety data sheets, or other documentation from the coating manufacturer. Secondly, usage of each low- or no-VOC/HAP coating, along with product recovery records, can be monitored using purchase and shipping records or daily/weekly/monthly/yearly usage logs. Monitoring approaches range from maintaining written logs to the use of sophisticated computerized systems for tracking content and usage.

EPA continues to strive for streamlined monitoring requirements for those facilities whose compliance strategies are based on use of compliant materials, including low- and no- VOC/HAP coatings. Streamlining difficulties can result when requirements apply to different pollutants (VOC vs. HAP), use different units of applicability in compliance terms (volume of coating vs. volume of coating solids), and averaging times (daily vs. rolling 12-month averages).

Example Permits

If you elect to monitor compliance by measuring the VOC/HAP content of coatings, the permit application should include the following information:

  • the numerical compliance limit;
  • the sampling/measurement method to be used;
  • the frequency of sampling;
  • emissions calculation procedures;
  • the averaging period;
  • QA/QC procedures; and
  • recordkeeping procedures.

For most of the recently promulgated surface coating MACT rules, the compliance demonstration must include the calculations and supporting documentation showing that, during the compliance period, the owner or operator of the affected source used no coating with a VOC/HAP content that exceeded any applicable emissions limit. As part of the calculations and supporting documentation, the permittee may be asked to:

  1. determine the mass fraction of VOC/HAP for each material used;
  2. determine the volume fraction of coating solids for each coating;
  3. determine the density of each coating; and
  4. calculate the VOC/HAP content of each coating.

Links to some examples of monitoring requirements when using compliant coatings are presented below.

Example: Surface Coating of Metal Parts and Products

Example: Surface Coating of Metal Cans

Example: Wood Furniture Manufacturing Operation