New
Final and Proposed Air Pollution Regulations
Coverage of two final rules and one proposed rule
affecting the surface coating industry
EPA
Administrator Christie Whitman signed 13 final rules to reduce toxic
air emissions from industrial facilities across the United States.
These 13 standards promise to reduce hazardous air pollutants by
more than 37,000 tons per year, and more than 6,000 tons of other
air pollutants, including particulate matter and ozone-forming volatile
organic compounds. One of the 13 industries affected is the surface
coating of metal furniture. EPA estimates there are 3,000 metal
furniture facilities nationwide, and about 655 of these facilities
will be affected by this new rule.
The
final rule to reduce emissions of toxic air pollutants during application
of surface coatings to metal furniture and associated cleaning operations
covers pollutants known or suspected to cause cancer or other serious
health and environmental effects. The final rule applies to all
industrial facilities with metal furniture coating operations that
are a major source of air toxics or are part of a facility
that is a major source of air toxics. (A major
source emits 10 tons per year or more of a single toxic air
pollutant listed in the Clean Air Act or 25 tons per year or more
of a combination of those pollutants.)
Metal
furniture surface coating is the process of applying a coating (usually
protective or decorative) to a piece of metal furniture or a metal
furniture component. Metal furniture includes items such as household
and office furniture; restaurant, beauty and barbershop furniture;
institutional furniture such as for hospitals and public buildings;
office and store fixtures; shelving and lockers and lamps and lighting
fixtures.
The
final rule requires existing metal furniture surface coating facilities
that are subject to the rule to limit toxic emissions to 0.1 kg
toxic compounds per liter of coating solids used (0.83 lb/gal).
These facilities will have up to three years from the date of publication
of the final rule to comply with the requirements.
New
facilities will have to use coating materials that do not contain
air toxics; however, the final rule allows a new affected source
to demonstrate on a case-by-case basis that toxics-free coating
technologies cannot be used for specific applications. Under such
circumstances and upon approval by the EPA Administrator, the facility
would be required to meet an emission limit of 0.094 kg toxics per
liter (0.78 lb/gal).
For
both the new and existing sources, the emission limits represent
levels that can be met by pollution prevention techniques, according
to EPA.
EPA
estimates that the total nationwide annualized cost in the fifth
year after the final rule is promulgated would be approximately
$14.8 million. After assessing the impact of the final rule on small
businesses, EPA determined that it would not significantly impact
a substantial number of small businesses.
Surface
Coating of Wood Building Products
Wood building product surface coating is the process of applying
a protective or decorative coating to products such as doors and
windows, exterior siding, interior wall paneling, flooring and trim.
The
final rule applies to facilities with commercial wood building surface
coating operations using more than 1,100 gal of coatings per year.
In addition, affected facilities must be a major source
of air toxics or are a part of a facility that is a major
source of air toxics. EPA estimates that there are approximately
215 facilities that will be affected by this rule.
The
final rule will require wood building products surface coating facilities
that are subject to the rule to limit air toxic emissions from five
types of coating lines: exterior siding and primed door skins; flooring;
interior wall paneling and tile board; other interior panels; and
doors, window, finished doors skins and miscellaneous.
Existing
facilities will have up to three years from the date of publication
of the final rule to comply with its requirements. EPA does not
expect new sources to be built in the first five years.
This
rule will reduce total emissions of air toxics by 4,900 tons per
year in the fifth year after the rule becomes final. This is a 63%
reduction from the 1997 baseline. EPA estimates that the total nationwide
annualized cost in the fifth year would be approximately $22.5 million.
After assessing the impact of the final rule on small businesses,
EPA determined that it would not significantly impact a substantial
number of small businesses.
Cars
and Light Duty Trucks
EPA has also proposed a rule to reduce toxic air pollutants from
surface coating of automotives and light-duty trucks. EPA is also
proposing an amendment to its hazardous waste regulations to exempt
certain activities covered by this proposed rule.
According
to the EPA documents, the surface coating of automobiles and light-duty
trucks is a process of applying decorative, protective or functional
coatings to new automotive and light-duty truck bodies. Coating
materials include but are not limited to primer, primer-surfacer,
topcoat, sealer, sound deadener and glass bonding primer and adhesive.
The
EPA states that the proposed rule would reduce total emissions of
air toxics by 6,000 tons per year, or about 60% from the 1997 emission
levels. The rule is expected to cost $154 million per year for the
entire industry. This represents less than 1/10 of 1% of baseline
industry pre-tax earnings of $14 billion. These costs take into
account the implementation of pollution prevention activities, such
as reformulation of coatings. They also include monitoring, record
keeping and reporting costs.
The
proposed rule would affect any new, reconstructed or existing automobile
and light-duty truck manufacturing facility that is a major source
of air toxic emissions. The rule would affect about 60 existing
facilities. The emissions limits proposed would give the industry
choices and flexibility in how they reduce organic air toxic emissions.
The compliance options include the following: use coatings that
have been reformulated to reduce the air toxic content; improve
coating application efficiency; upgrade or install new capture-and-control
systems; use any combination of the first three; work practice and
equipment requirements for cleaning. Facilities must also meet certain
record keeping and report requirements, including semi-annual compliance
reports.
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