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The Wisconsin Department of Natural Resources (DNR) released new rules that focus on volatile organic compound (VOC) emission regulations for use of adhesives, and miscellaneous metal parts coating and plastic parts coating operations. All rules are effective June 1, 2022.
The DNR’s existing VOC rules for these types of operations (“Part 1” rules) will remain in effect, however the new VOC rules (“Part 2” rules) contain more stringent VOC limits for coatings and ensures Wisconsin’s Administrative Code meets federal Clean Air Act requirements. The new Part 2 rules are found in:
- NR 422.084 (Plastic parts coating – part 2)
- NR 422.128 (Use of adhesives – part 2)
- NR 422.151 (Miscellaneous metal parts and products – part 2)
Some sources that were previously subject to the Part 1 rules for these operations may now be subject to the more stringent Part 2 rules if they meet the applicability criteria. Affected sources will either be subject to the Part 1 rule or the Part 2 rule, but not both.
VOCs are regulated under the Clean Air Act because they react in the atmosphere to form ground-level ozone, a pollutant known to adversely impact human health and the environment. The Clean Air Act requires that additional VOC emission limits be implemented in areas that are not attaining the national ozone standards. Specifically, the Part 2 rules are required for affected sources located in areas that the U.S. Environmental Protection Agency (EPA) has classified as “Moderate” (or higher) ozone nonattainment. The DNR’s online map identifies areas of the state that meet these criteria.
Areas impacted by Part 2 rules
The Part 2 rules apply to sources located in Sheboygan County and the area of Kenosha County east of I-94 if the source’s VOC emissions from adhesive use, metal part and plastic part coating operations meet or exceed the rule’s 2.7 ton per year threshold. In the past, Sheboygan County and eastern Kenosha County have both been classified as Moderate, or higher, for the 2008 national ozone standard. Affected sources have 180 days from the effective date of this rule to comply with the new requirements.
Anticipated future impacts
The EPA is considering reclassification of certain Wisconsin nonattainment areas from Marginal to Moderate. The DNR anticipates these reclassifications will be effective in late Summer 2022. Upon the effective date of EPA’s reclassifications, sources within the Milwaukee 2015 ozone standard nonattainment area will become subject to the Part 2 rules if their VOC emissions from adhesive use, metal part and plastic part coating operations meet or exceed the 2.7 TPY threshold.
The DNR’s online map shows the Milwaukee 2015 ozone standard nonattainment area, which includes Milwaukee County, Ozaukee County and portions of Washington, Waukesha and Racine counties. Affected sources have 180 days from the effective date of the reclassification to comply with the new requirements.
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