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NY Bows Changes to Coating Rules

Tuesday, November 20, 2012

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Coating makers are taking a close look at newly proposed rules that would affect coating processes, paint and coating products, and facility permits in New York. 

Architect of the Capitol

The proposed changes include clarifying adjustments to a section dealing with commercial adhesives, sealants and primers. New sealants have been applied to the joints and cast iron connection points of the U.S. Capitol skirt.

The American Coatings Association says it's reviewing the New York State Department of Environmental Conservation's (NYSDEC) proposed amendments and plans to submit comments by NYSDEC’s deadline—Dec. 28.

The proposed changes to Subpart 228-1, and attendant revisions to Parts 200 and 201, incorporate several federal Control Techniques Guidelines (CTGs), including establishing Reasonably Available Control Technology (RACT) for VOCs emitted by surface coating processes.

ACA says the CTGs changes will affect processes relating to metal furniture; large appliances; flat wood; miscellaneous metal and plastic parts; automotive and light duty trucks; paper, film and foil; and wood coatings.

The Rules fall under NYSDEC’s Regulations, Chapter III–Air Resources and Title 6 of the Official Compilation of Codes, Rules, and Regulations of the State of New York (6 NYCRR).

Proposed Revisions to Part 228

Within Part 228, there are proposed revisions to Subpart 228-1, Surface Coating Processes, and "clarifying and non-substantive changes" to Subpart 228-2, Commercial and Industrial Adhesives, Sealants and Primers.

The proposed changes to 228-1 include:

• Applicability criteria for various coating processes;
• New definitions, including several added coating types used in updated coating processes;
• A new section that describes the minimum requirements of surface coating facilities and acceptable application techniques common to surface coating processes;
• The maximum VOC content allowed for coatings used in surface coating processes, including additional requirements and exceptions specific to a coating process, coating type, or application requirements;
• Alternative means of complying with VOC content limits; and
• The requirements necessary to determine and maintain compliance with the regulation.

Proposed Revisions to Parts 200 and 201

Part 200, General Provisions, has proposed revisions that will add three references in Table 1 of Section 200.9. This table correlates specific referenced material with specific regulations. The publication date and page numbers of existing referenced documents to the 2006 Code of Federal Regulations will also be updated.

Proposed updates to Part 201, Permits and Registrations, revises the criteria for a facility performing coating processes to qualify as an exempt activity. The existing provisions exempt facilities using less than 25 gallons per month of coating materials and cleaning solvents, combined. The revision provides an optional exemption criterion for facilities with 1,000 pounds or less of actual facility-wide VOC usage on a 12-month rolling basis.

Submitting Comments

The agency is accepting written comments through 5 p.m. ET Dec. 28, 2012.

Comments should be directed to John Henkes, New York State Department of Environmental Conservation, Division of Air Resources, 625 Broadway, Albany, NY 12233-3254; phone: 518-402-8403; email 228scp@gw.dec.state.ny.us.