Tuesday, July 3, 2012

EPA Removes Refrigerant From List of Regulated VOC

On June 22, EPA released a final rule to revise the definition of volatile organic compounds (VOCs) under the Clean Air Act (CAA). The revision adds trans-1,3,3,3-tetrafluoropropene (HFO-1234ze) to the list of compounds excluded from the definition of VOC. The final rule is effective on July 23, 2012.

According to the Agency, it is removing the compound from the list because it “makes a negligible contribution to tropospheric ozone formation.” As a result, the Agency says if a facility is subject to certain federal regulations limiting emissions of VOCs, its emissions of HFO-1234ze may not be regulated for some purposes. EPA's action may also affect whether the compound is considered a VOC for state regulatory purposes, depending on whether the state relies on EPA's definition of VOC.

The rule will affect industries that manufacture or use refrigerants, aerosols, propellants, and blowing agents for insulating foams. EPA notes that the use of HFO-1234ze remains subject to other restrictions under the CAA. The use of the compound as an aerosol propellant, blowing agent, refrigerant, or any other use in which it would substitute for chlorofluorocarbons, or their substitutes, is regulated under the Significant New Alternatives Policy (SNAP) program. The SNAP program accepts HFO1234ze as an "acceptable foam and refrigerant substitute and as an aerosol propellant."

EPA policy has been to exclude these slow-forming compounds from the regulatory VOC definition “so as to focus VOC control efforts on compounds that do significantly increase zone concentrations.” EPA also contends that these exemptions create an incentive for industry to use negligibly reactive compounds in place of more highly reactive ones. The Agency lists compounds that it has determined to be negligibly reactive in its regulations at 40 CFR 51.100(s).

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