The Illinois EPA has proposed new regulations that will impact facilities that:

• coat miscellaneous metal and plastic parts
• apply industrial adhesives

The proposed rules include new control techniques and new work standards associated with the use of coatings and industrial adhesives containing Volatile Organic Materials (VOM).

Although the rules are only in the proposal stage, the review and adoption is on a fast track and there will not be much time for affected facilities to come into compliance. The expected compliance date is May 1, 2011.

The details of all the changes are too many to list here, but a few of the major changes are as follows:

• Number of coating subcategories will increase significantly, especially for plastic parts coatings
• More stringent limits for VOM content in each coating category
• If pollution controls are needed, the overall minimum control rate that pollution control devices must achieve will increase from 81% to 90%
• The method to calculate the 15 lb/day VOM emission exemption will change, resulting in some facilities that were previously exempt from the coating rules becoming subject to the new rules
• New work standards to minimize VOM emissions

Regulated facilities must submit a certification of procedures used to achieve compliance, by May 1, 2011.

Because the proposed rules include potentially sweeping changes, we recommend that an evaluation of your operation be conducted soon. Admiral can assist in reviewing the operations and materials used to determine if your facility is subject to the proposed rule. Please give us a call or contact me at Steve@Admiralenv.com.

Stephen B. Anderson, P.E., CHMM
Environmental Engineer
March 29, 2010

847-228-5355