The 1996 amendments to SCAQMD’s
Rule 1136 (Wood Products Coatings) included a staff commitment to
complete a technology assessment, evaluating the viability of compliant
coating technologies, by July 2003. Industry was required to submit
progress reports to the District by January 2003.
The following are examples of operations subject to Rule 1136:
- Household furniture
- Office and contract furniture
- Kitchen and bathroom cabinets
- Architectural millwork and store fixtures
- Shutters, blinds, doors, windows and moldings
- Specialty products (musical instruments, toys, speaker cabinets,
picture frames, skateboards)
- Repair and finishing operations
- Job shop (a combination of above operations)
SCAQMD staff identified various compliant technologies (waterborne
systems, light curable processes, acetone formulations, high solids,
thermally cured) as part of their findings. Out of 780 facilities
subject to the rule, 366 responded to an SCAQMD survey. According
to the survey, 16% of respondents are in full compliance with the
2005 VOC limits. The rest are either in partial compliance (32%
of respondents) or not yet meeting the 2005 limits (52% of respondents).
One percent of respondents comply with the limits via the use of
add-on control equipment.
The Technology Assessment concluded that “Technology exists
and is in use today in the form of many resin and solvent systems
to meet the July 1, 2005 future VOC limits that are primarily 275
grams VOC per liter, less water and less exempt solvents.”
The EPA promulgates Maximum Achievable
Control Technology (MACT) Standards to regulate emissions of 188
listed toxic air pollutants from major sources nationwide. A “major
source” emits 10 tons per year or more of a single toxic air
pollutant or 25 tons per year or more of a combination of these
pollutants. “By the end of August, EPA will have issued 92
MACT standards. When fully implemented, these rules will keep nearly
two million tons of toxic compounds out of our nation’s air
each year,” said Acting EPA Administrator Marianne Lamont
Horinko. A summary of some of the new MACTs follows:
Surface Coating of Miscellaneous Metal Parts and Products
The surface coating of miscellaneous parts and products is a process
of applying a protective, decorative, or functional coating to metal
parts of items such as railcars, steel drums, construction equipment,
iron and steel pipe, structural steel, extruded aluminum products,
motorcycles and musical instruments. Paints, stains, sealers, topcoats,
basecoats, primers, inks and adhesives are some of the coatings
subject to the regulation.
The rule mandates a 48-percent (approximately 26,000 tons per year)
reduction of total air toxics emissions from the 1997 baseline.
Many of the air toxics are also Volatile Organic Compounds (VOCs).
EPA estimates that 1,500 existing facilities nationwide and 225
newly constructed ones in the next five years will be impacted by
the changes. The total annualized cost will be approximately $57.3
million per year.
Surface Coating of Metal Cans
The can manufacturing process involves the coating of metal cans
or ends. Various coating operations (basecoating, decorative inks,
end seal or end lining compounds, side seam stripes, inside sprays,
interior lacquers, overvarnishes, repair spray coatings) associated
with can manufacturing can result in emissions of air toxics. The
processes regulated by MACT are:
- One and two-piece draw iron can body coating;
- Three-piece can assembly;
- End coating.
The projected toxics reductions of 6,800 tons per year will come
from 142 existing facilities and represent a 70 percent reduction
from the 1997 baseline year. A total annualized cost of $58.7 million
Surface Coating of Metal Furniture
Metal furniture operations include the production of office furniture,
hospital furniture, shelving and lockers. Approximately 3,000 facilities
nationwide produce metal furniture but only 655 are major sources
subject to the requirements. The new MACT standard is 0.10 kilogram
toxic compound per liter of coating solids used (0.83 pound/gallon)
for existing facilities. Affected facilities are given 3 years to
New facilities will be required to use coatings with no air toxics.
Upon demonstration that toxics-free coatings are not available for
specific operations, an emissions limit of 0.094 kilograms toxics
per liter (0.78 pound/gallon) will be allowed. The estimated annualized
cost (over a 5-year period) is $14.8 million.
Miscellaneous Organic Chemical Manufacturing Facilities
This MACT rule will require control for process vents, storage tanks,
equipment tanks, equipment leaks, wastewater systems, and transfer
operations from organic chemical manufacturing facilities. Chlorinated
paraffin production, rubber chemical production, polyester resin
production and alkyd resin production are examples of processes
covered by this rule. The primary air toxics associated with these
operations are methanol, vinyl acetate, hexane, methylene chloride,
hydrogen chloride and toluene.
An estimated air toxics reduction of 16,800 tons per year is expected.
The annualized cost for industry to implement changes, such as solvent
use reduction, will be roughly $75 million.
Printing, Coating, and Dyeing of Fabric and other Textiles
Facilities subject to this rule include those involved in the process
of applying a coating or printing material to one or both sides
of a continuous web substrate, such as a roll of fabric. Dyeing
and finishing of a textile (yarn, thread, cord, fiber, fabric) are
also subject to the requirements. The agency projects emission reductions
of 4,100 tons per year and an annualized cost of $14.5 million from
this particular measure.
Reinforced Plastic Composites Production
Facilities manufacturing fiberglass bath tubs and showers, automobile
and recreational vehicle parts, storage tanks, and engine and tool
covers fall under the EPA’s regulation. This rule will affect
435 existing facilities and requires incorporating pollution prevention
techniques (use of non-toxic raw materials, non-atomized resin applications
and covering of open resin baths and tanks) in the manufacturing
process. New large (emitting 100 tons per year or more of air toxics)
facilities that perform processes such as open molding, pultrusion,
centrifugal casting and continuous lamination/casting, will have
to install air pollution control equipment. Large new manufacturers
of sheet molding compound and bulk molding compound must also install
controls. A projected 7,680 tons per year toxics reduction is projected
for the reinforced plastic composites industry. The EPA estimates
that the total annualized cost of said reductions will be $21.5
Semiconductor manufacturing operations emit various air toxics,
which will be regulated by the MACT rule. Hydrochloric acid, hydrofluoric
acid, glycol ethers, methanol and xylene comprise over 90 percent
of all emissions, according to EPA staff. The product of semiconductor
operations is the integrated circuit used in electronics (computers,
appliances, radios, CD players) manufacturing. Although 170 semiconductor
facilities have been identified by EPA, only one will be subject
to the rule. The rest are not considered major sources.
Surface Coating of Wood Building Products
The rule will impact major sources using more than 1,100 gallons
of coatings per year. Exterior siding and primed door skins, flooring,
interior wall paneling, tileboard, windows fall under the EPA’s
definition of wood building products. 215 facilities performing
coating operations associated with wood building products will be
subject to the MACT. An estimated 4,900 tons per year of air toxics
will be reduced by implementing the more stringent emission standards.
The annualized cost to industry will be approximately $22.5 million.