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.