Wisconsin Department of Commerce Newsletter
Rule Changes Affecting Use of T-butyl Acetate
Effective December 29, 2004, the United States Environmental Protection Agency (U.S. EPA) no longer considered t-butyl acetate (TBAC) a Volatile Organic Compound (VOC) for purposes of permit emission limits or for material content requirements. It will, however, continue to require recordkeeping and reporting requirements similar to VOCs. This means that facilities currently tracking their VOC usage will now also be required to track their TBAC emissions as a separate category.
Why did EPA remove TBAC from the category of VOCs?
TBAC is a chemical that is currently used to make pharmaceutical, pesticides and other products. Since it may be a suitable substitute for more reactive and harmful substances like toluene and xylene, it is estimated that TBAC will soon be found in industrial coatings, adhesives, contact cement, and solvent based inks.
How do I know whether I have TBAC?
What does this mean for air pollution requirements in Wisconsin?
When reporting emissions to the CRS, you must include any TBAC emissions together with your total VOCs to determine if you are above the 6,000 pound per year reporting threshold for VOCs. If this total, VOCs plus TBAC, is above 6,000 pounds you must report all of those emissions, but the TBAC emissions should be included separate from VOCs in the report.
For example, if you have 5900 pounds of VOCs and 120 pounds of TBAC, then your total emissions are 6020 pounds. You would then report 5900 pounds VOC and 120 pounds TBAC on the CRS.
If you have any further questions about TBAC emissions, feel free to contact Renee Lesjak Bashel at 608-264-6153.
-- Renee Lesjak Bashel
The newsletter is issued electronically every other month.
Please send comments or questions to Barbro McGinn, editor.