`The Advantages & Drawbacks of the EPA`s Coating & Composites Coordinated Rule Development,` presented at the 2000 SUR

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Courtesy of Trinity Consultants

Introduction

Under the 1990 Clean Air Act Amendments (CAAA), the U.S. EPA is required to regulate sources of hazardous air pollutants (HAPs). Primarily, HAP emissions are regulated through National Emission Standards for Hazardous Air Pollutants (NESHAPs), which are codified under Title 40 Code of Federal Regulations (CFR)Part63. NESHAPs address HAP emissions from a particular process or industry such as metal can coating operations. Each NESHAP establishes the maximum available control technology (MACT) for that particular process based on the best performing twelve percent of existing sources.1 Reductions are achieved through various means, such as product substitution, operating method changes, and pollution control equipment. As anyone who works at a facility that has recently had to comply with a NESHAP can attest, satisfying these requirements can be a major undertaking.

The CAAA also require the U.S. EPA to regulate the emissions of volatile organic compounds (VOC) from sources located in ozone nonattainment areas. In many cases, facilities that are or will be subject to a NESHAP are also significant sources of VOC emissions. As a result, the EPA will often establish controls of VOC emissions for the same industry type that has been identified for NESHAP applicability through the development of a Control Technique Guideline (CTG). A CTG is not a direct requirement for industry, but instead serves to establish minimum guidelines for state agencies for the development of Reasonably Available Control Technology (RACT) rules. These RACT rules then set the standards that must be met by industry.

The EPA is continuing to develop, with few exceptions, both NESHAPs and CTGs according to the source categories that were originally established in 1992. The EPA is required to issue the final 'bin' of NESHAPs by November of 2000. Most if not all of the regulated source

categories will then have three years before the onset of the compliance deadline for existing sources. Any new sources that are constructed after the new NESHAP is proposed, however, will have to comply upon startup.

Among the November 2000 bin of NESHAP source categories are a number of surface coating industries and operations. The U.S. EPA is undertaking a coordinated effort for the development of the NESHAPs and CTGs for the coatings and composites sources in this bin in an effort to ensure consistency in the industry.2 The following sections discuss the rule development process, the advantages the coordinated approach brings for industry, the drawbacks of the approach, and how companies can get involved to get their concerns heard

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