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MAPP Plastics Discussion Forum

The MAPP Plastic Industry Discussion Forum allows members to rapidly communicate with each other. Post both questions and answers to questions that other MAPP members have about any industry topic from material and process issues to R&E Tax Credits and other business issues.

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Plastic Industry Forum - Converse with Plastics Processing Leaders / Business / Letter of Exemption from the EPA” for air emissions"
Posted:  18 Aug 2017 20:39
Has anyone ever been asked about a "Letter of Exemption from the EPA  for air emissions?"
We are an injection molder and we mainly process ABS, Acrylic and Polypropylene.
Does anyone have any information on this?

Peter Blaas
Posted:  28 Aug 2017 00:50
Hello Peter:  Many industrial activities are exempt from air permitting requirements.  For instance in Ohio, resin injection molding equipment using less than one million pounds of resin annually are exempt and no notification to Ohio EPA is required.  This is one of 60 types of equipment and activities that are exempt in Ohio.  As an another example, in Pennsylvania plastic bead or pellet milling, screening, and storage operations (does not include handling and storage of resin powders) are exempt from air permitting requirements.  This is one of 44 listed exempt activities in Pennsylvania.  In general, activities exempt from air permitting requirements do not result in a confirming letter from the state permitting agency, however you may be able to achieve the same result by having your operations analyzed by a qualified air permitting expert or consultant and getting a written determination from them.  In addition to listed exemptions, there is also the possibility of not needing a site specific permit but being eligible for a “permit by rule” (PBR) where you are exempted from general air permitting requirements  but then have to make short (one-page) notification to your state permitting authority (as is required in Ohio). Each state is different and the specific application of state or federal air permitting law to your business operations should be conducted with the assistance of an environmental attorney.  As a member of MAPP, you get two free hours of legal advice, renewable to three free hours per year if certain thresholds are met.

Alan Rothenbuecher
Posted:  13 Sep 2017 21:25
We recently filed our RCRA form with the EPA, but we went through a third party service.  They completed everything and we just had to sign it.  They also take care of disposing of materials for us properly when needed.  It was form OBM# 2050-0024

Donna Rorrer
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