Countdown continues for wood finishing compliance deadline.
In 1990, Clean Air Act Amendments were passed by the U.S. Congress. Now, after nearly six years of waiting and debating, of committee meetings and conference calls, of rhetoric and rigamarole, a national and uniform emission standard for wood finishers is official. That ticking you hear is the clock winding down toward compliance; for some the alarm is set to go off as early as November 1997.
On Dec. 7, 1995, the National Emission Standards for Hazardous Air Pollutants (NESHAP), were published in the Federal Register. This standard was developed, along with guidelines for communities with poor air quality (see related story page 87), during a Regulatory/Negotiations process. The process, thoroughly chronicled by Wood & Wood Products in December 1994, brought together representatives from the woodworking industry, coating suppliers, environmental groups and state and federal environmental agencies. For nearly two years, from 1992 to 1994, the group worked on developing the two regulatory projects. A product of their work, the NESHAP was signed by EPA administrator Carol Browner in November 1994. It then was subject to a three-month public comment period and a year-long revision period.
These comments led to only minor changes to the rule, said Reg/Neg committee member Paul Eisele, who serves as director of Health, Safety and Environmental Affairs for MASCO Corp. (Eisele authored an editorial on the NESHAP and the Reg/Neg process in Wood & Wood Products' December 1994 EnviroBeat section entitled, What Woodworkers Need to Know About the New Clean Air Act Amendments.) Fellow Reg/Neg member Brian Morton, an economist with the North Carolina Environmental Defense Fund, (who wrote an opposing editorial to Eisele in the same edition) said he was not aware of any changes and that he "trusted the EPA when it said it wouldn't do anything nefarious."
Paul Almodovar of the EPA Office of Air Quality Planning and Standards, said the changes did not alter the "basic structure" of the rule as proposed by the EPA. The changes included adding a category for non-wood product companies that may make furniture for in-house use, added language to the standard to include custom cabinet manufacturers among those who would need to abide by NESHAP, and extended the deadline for an initial notification report to 270 days from the Dec. 7 publishing date. The initial report would need to include basic information such as where the facilities are located and the estimated amount of emissions that a company has the potential to release annually.
The EPA says that its goal is to prevent pollution before it starts rather than having to clean the air later. In that vein, NESHAP aims to reduce air pollutant emissions of these smog-producing, ozone-depleting, and possibly harmful-to-your-health chemicals. The EPA says exposure to these "toxic" chemicals can cause eye, nose, throat and skin irritation; damage to the heart, liver and kidneys; and reproductive effects.
The NESHAP targets facilities that are major sources of emissions of HAPs. HAPs are any of 189 chemicals such as toluene, xylene and methanol that were identified by the EPA as particularly harmful to the environment. A "major source" is defined as a facility that has the potential to emit 10 tons of any one HAP or 25 tons of a combination of HAPs annually. The EPA said the rule could effect about 750 wood furniture manufacturing facilities nationwide.
The EPA estimates that the NESHAP will help reduce wood furniture emission of HAPs by 33,000 tons annually, representing a 60 percent reduction from current levels. The EPA estimates the standard will cost the industry $7 million initially, and annual compliance costs to top off at approximately $15 million.
Companies using finishing or adhesive materials that contain any of the 189 HAPs and are above the 10/25 ton threshold must track usage carefully. Once over the 10/25 HAP threshold, a company must meet an emission level that is stated in terms of pounds of HAPs per pounds of solids used (lbs HAPs/lb of solids). The overall emission standard under NESHAP is 1.0 pounds of HAPs per pound of solids used for an existing facility or finishing line, and 0.8 per pound of solid for a new source. (See chart page 86.)
Companies that emit less than 50 tons of HAPs in 1996 will need to come into compliance by December of 1998. Those that emit 50 tons or more of HAPs in 1996 will need to comply by November 1997.
The final rule outlines the monitoring, recordkeeping and reporting requirements for wood finishers emitting hazardous air pollutants during finishing, gluing and cleanup operations. About 80 percent of hazardous air pollutants come from finishing lines, 10 percent from gluing operations and 10 percent from cleanup operations. Because HAP [TABULAR DATA OMITTED] emissions come from these three areas, the NESHAP addresses all three.
NEWLY ENACTED EMISSION STANDARDS FOR WOOD FINISHING
Existing sources New sources (lbs HAP per lb solids)
AVERAGING APPROACH MONTHLY WEIGHTED AVERAGE OF ALL FINISHING MATERIALS 1.0 0.8
COMPLIANT COATING APPROACH
Stains 1.0, as applied 1.0, as applied Washcoats(*) 1.0, as applied 0.8, as applied Sealers 1.0, as applied 0.8, as applied Topcoats 1.0, as applied 0.8, as applied Basecoats(*) 1.0, as applied 0.8, as applied Enamels(*) 1.0, as applied 0.8, as applied
Thinning solvents 10% by weight HAP
* If they are formulated on-site, they must be formulated with compliant finishing materials and thinners containing no more than 3% HAP by weight. NEWLY ENACTED EMISSION STANDARDS FOR CONTACT ADHESIVES AND FOR SPRAY BOOTH PEEL COATINGS
Existing sources New sources (lbs HAP per lb solids)
USE OF COMPLIANT CONTACT ADHESIVES
All contact adhesives, except for 1.0 0.2 foam adhesives meeting inflammability tests
Foam adhesives meeting inflammability tests 1.8 0.2
Use of Control Device 1.0 0.2
(lbs VOC per lb solids)
Spray Booth peel coatings 0.8 0.8
To meet these limits, many companies may be forced to use to change its workplace practices, the finishing materials it uses (for example, switching to waterborne or high-solid content finishes), and upgrade its finishing equipment. For instance, conventional spray guns have been eliminated except in limited circumstances.
These circumstances when conventional spray guns are allowed include:
* When using a finish with a VOC content no greater than 1 pounds of VOCs per 1 pound of solid;
* Doing touch up and repair;
* Using an automated spray line;
* Using add-on equipment;
* If use is only 5 percent of overall use;
* or, if it is determined to be either not technically or feasibly possible to do so.
Alternative systems include high-volume, low-pressure spray guns, electrostatic, airless, air-assisted airless and roll coat/curtain coat/dip coat finishing systems.
While it may force these changes, the final rule does give wood finishers some leeway as to how to meet the emission limits. "Flexibility was built into the process so that companies can comply with the standards in a variety of ways," said Eisele in a November 1994 interview.
Three ways to comply
The emission limits can be met through a variety of compliance options. The most direct method could be using all compliant coatings, i.e. those that meet the 1 pound of HAP per 1 pound of solids used for existing sources.
A second way is by averaging for compliance. While this method is more difficult than using only compliant coatings, it does offer greater flexibility. If one step in the finishing process, such as the application of sealer, is above the compliance level, the steps that fall below the compliance level can help bring the total average into compliance with the 1.0 pound of HAPS per 1 pound of solid limit for existing sources.
The third way to comply is by using control devices or a combination of devices known as control systems that capture or destroy HAPs before they are released into the atmosphere. These add-on controls include incinerators or adsorbers. While these devices do eliminate a high percentage of emissions, they can also be very expensive pieces of equipment.
Under NESHAP, contact adhesives are also regulated. The emission limits for foam adhesives used in furniture requiring flammability testing are 1.8 pounds of HAPS/per pounds of solids in an existing source and 0.2 in a new source. For all other contract adhesives, the limit is 1.0 for existing sources and 0.2 pounds for new sources.
While the rule is generally considered to be workable, and does not force companies to purchase incinerators for instance, industry analysts warn wood finishers to not be complacent. The wood furniture industry is a part of the EPA's 1992 list of industry group, or "source categories," in which it will be attempting to reduce emissions, and thus will be vigilant in tracking the industry.
Dick Titus, executive vice president of the Kitchen Cabinet Manufacturers Assn., said, "Plants need to be able to demonstrate to the EPA that they are not simply substituting one HAP for another and that an effort is being made to reduce emissions."
RELATED ARTICLE: FOR MORE INFORMATION
Anyone with a computer and a modem can download the rule from the Clean Air Act Amendments bulletin board of the EPA electronic Technology Transfer Network by calling (919) 541-5742 (look under "Recently Signed Rules"). For further information about how to access the board, call (919) 541-5384. For further information about the rule, contact Paul Almodovar of the EPA Office of Air Quality Planning and Standards at (919) 541-0283.
RELATED ARTICLE: NESHAP AT A GLANCE
* NESHAP is an acronym for National Emissions Standards for Hazardous Air Pollutants. The NESHAP establishes a uniform set of minimum guidelines for wood finishing operations through out the nation.
* Initial Notification Report due to U.S. EPA within 270 days from Dec. 7 publishing of the rule in the Federal Register
* New sources must comply immediately
* Companies that emit less than 50 tons of HAPS in 1996: Dec. 1988
* Companies that emit 50 tons of HAPs or more in 1996: Nov. 1997
* Companies must abide by the NESHAP if it has the potential to emit 10 tons or a single HAP or 25 tons of a combination of HAPs
* In an attempt to reduce emissions of potentially ozone-depleting chemicals
Karen Koenig contributed to this report.
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|Title Annotation:||Envirobeat Update: What Wood Finishers Must Know About the New Clean Air Act; includes related article; National Emission Standards for Hazardous Air Pollutants|
|Publication:||Wood & Wood Products|
|Date:||Feb 1, 1996|
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