[EHCWM] FINAL AIR TOXICS REGULATION FOR PLYWOOD AND COMPOSITE WOOD PRODUCTS (fwd)

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Subject: [EHCWM] FINAL AIR TOXICS REGULATION FOR PLYWOOD AND COMPOSITE WOOD

PRODUCTS

FINAL AIR TOXICS REGULATION FOR PLYWOOD AND COMPOSITE WOOD PRODUCTS

FACT SHEET http://www.epa.gov/ttn/oarpg/t3/fact_sheets/pcwp_fs2.pdf

ACTION

On February 26, 2004, the Environmental Protection Agency (EPA)

finalized a rule to reduce emissions of toxic air pollutants from

facilities that manufacture plywood and veneer; particleboard;

medium density fiberboard; hardboard; fiberboard; oriented

strandboard; and engineered wood products. The rule will reduce air

toxics from the manufacturing of Plywood and Composite Wood Products

(PCWP) by 11,000 tons per year, a 58 percent decrease from 1997

levels. The final rule will also reduce volatile organic compound

emissions by 27,000 tons per year, a 52 percent decrease

from 1997 levels.

Toxic air pollutants, also known as air toxics, are those pollutants

known or suspected to cause cancer and other serious health or

developmental problems. Air toxics emitted during the manufacture of

plywood and composite wood products include methanol, formaldehyde,

acrolein, acetaldehyde, phenol and propionaldehyde. These toxic

pollutants are associated with a variety of adverse health effects,

including damage to nasal membranes, reproductive disorders,

irritation of eyes and throat, dizziness, headache, and nausea. Some

(formaldehyde, acetaldehyde) have been classified as probable or

possible human carcinogens.

EPA estimates that about 220 plywood and composite wood products

facilities are major sources of air toxics.

The final rule also creates and removes from the list for air toxic

control a subcategory of low-risk facilities. The final rule puts

eight specific facilities into the low-risk subcategory. However,

the final rule sets forth provisions for additional facilities to

opt into this subcategory. This action also finalizes amendments to

the effluent limitations guidelines for four subcategories of the

timber industry (40 CFR Part 429, Subparts B, C, D, and M). These

amendments will exclude from the existing regulations wastewaters

generated by specific air pollution control devices installed by

facilities to comply with the final PCWP rule. Effluent limitations

for process wastewaters generated by

air pollution control devices discharged from these facilities will

be developed on a case-by-case basis.

COMPLYING WITH THE RULE REQUIREMENTS

The final rule provides three options for PCWP manufacturers to meet

emissions requirements. These options provide facilities flexibility

in meeting the rule requirements while ensuring environmental

protection:

1. Install and use emissions control systems with an efficiency of

at least 90 percent on specific emissions points at the facility;

2. Meet an emissions limit by using pollution prevention techniques

such as reformulating raw materials or modifying manufacturing

processes; and

3. Average emissions from several emissions points at a facility.

Most facilities will comply with this rule using three types of

equipment: regenerative thermal oxidizers; catalytic thermal

oxidizers; or biofilters when complying with option number one or

three.

Each facility that opts into the low-risk subcategory must

demonstrate that its air toxic emissions pose risks below certain

health effects thresholds. The facility has two options to qualify

for the low-risk subcategory. Both options ensure that facilities in

the low-risk subcategory meet the low-risk criteria of one in one

million cancer risk and less than or equal to a hazard index of 1.0.

Low-risk demonstrations must be submitted to EPA for approval.

A The first approach allows facility owners or operators to use a

limited number of site-specific input parameters to demonstrate to

EPA that their facility is low-risk.

A The second approach allows facility owners or operators to use a

site-specific risk assessment

to demonstrate to EPA that their facility is low risk. The site-

specific risk assessment requires more

effort, but produces results that are less likely to overstate risk.

Facilities that qualify for the low-risk subcategory established in

this final rule must assume federally

enforceable emissions limitations. These limits ensure that their

air toxics emissions do not exceed levels

used to qualify for the compliance alternative.

EPA estimates that potentially 147 plywood manufacturing facilities

may qualify for the low-risk

subcategory. Additional facilities may take action to control their

air toxics emissions in order to qualify

as low-risk, thus increasing the number of eligible facilities to

more than 147.

As part of this rule, EPA is identifying eight plywood manufacturers

that already qualify as low-risk.

These facilities include:

A Georgia-Pacific Plywood Plant, Monroeville, AL

A Georgia-Pacific - Hawthorne Plywood Mill, Hawthorne, FL

A Oregon Panel Products, Lebanon, OR

A Hardel Mutual Plywood Corporation, Chehalis, WA

A Hood Industries, Incorporated, Wiggins, MS

A Plum Creek Manufacturing, LP, Kalispell, MT

A Potlatch Corporation - St. Maries Plywood, St. Maries, ID

A SierraPine Limited, Rocklin MDF, Rocklin, CA

HEALTH AND ENVIRONMENTAL BENEFITS

The final rule will reduce emissions of acetaldehyde, acrolein,

formaldehyde, methanol, phenol,

propionaldehyde and other toxic air pollutants by 11,000 tons per

year, or a 58% percent reduction

from 1997 levels. Depending on the number of facilities eligible for

the low-risk subcategory, these

emission reductions could change to 6,600 tons per year.

The final rule also will reduce the emissions of volatile organic

compounds by 27,000 tons per year, a

52 percent reduction from 1997 levels. Volatile organic compounds

contribute to the formation of

ground-level ozone, or smog. Depending on the number of facilities

eligible for the low-risk

subcategory, these emission reductions could change to 14,000 tons

per year.

EPA estimates the total annualized cost to comply with the final

rule will be about $140 million. These

costs could drop to $74 million depending on the number of

facilities eligible for the low-risk

subcategory.

BACKGROUND

The Clean Air Act requires EPA to identify categories of industrial

facilities, or source categories, that

emit one or more listed 188 toxic air pollutants.

For major sources within each source category, the Clean Air Act

requires EPA to develop standards

that restrict emissions to levels consistent with the lowest-

emitting (also called best-performing) plants.

Major sources are those that emit 10 tons per year or more of a

single air toxic or 25 tons per year or

more of a combination of air toxics.

FOR MORE INFORMATION

To download the final rule from EPA's page on the Worldwide Web, go

to

http://www.epa.gov/ttn/oarpg . For additional information, contact

Tom Kissell of the EPAs

Office of Air Quality Planning and Standards at (919) 541-4516 or by

e-mail at

kissell.mary@....

EPA's Office of Air and Radiation home page on the Internet contains

a wide range of information on

the air toxics program, as well as many other air pollution programs

and issues. The address is:

http://www.epa.gov/oar/.

FINAL RULE TO REDUCE TOXIC AIR POLLUTANTS FROM SURFACE COATING OF

PLASTIC PARTS AND PRODUCTS

FACT SHEET http://www.epa.gov/ttn/oarpg/t3/fact_sheets/pppsc_fs.pdf

ACTION

! On August 29, 2003, the Environmental Protection Agency (EPA)

issued a final rule to reduce

toxic air pollutant emissions from plastic parts and products

surface coating operations. Toxic

air pollutants, also called air toxics, are those pollutants known

or suspected to cause cancer or

other serious health and environmental effects.

! The final rule applies to new and existing facilities 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.

! The surface coating of plastic parts and products is a process of

applying a protective,

decorative, or functional coating to a plastic substrate. Coating

materials include, but are not

limited to, paints, stains, sealers, topcoats, basecoats, primers,

inks, and adhesives.

! EPA estimates that there are approximately 202 existing major

sources nationwide that will be

affected by this rule. Another six new major sources are expected to

be constructed within the

5-year period following publication of the final rule, and they will

also be affected by the rule.

! The final rule will require existing facilities that are subject

to the rule to limit air toxic emissions.

These facilities will have up to 3 years from the date of

publication of the final rule to comply

with its requirements.

! For both new and existing sources, the emission limits can be met

by pollution prevention

techniques.

BENEFITS AND COST

! The final rule will reduce total emissions of air toxics by

approximately 7,560 tons per year.

This represents an 80 percent reduction from the estimated 1997

baseline.

! Many of these air toxics are also volatile organic compounds.

These compounds contribute

significantly to the formation of ground-level ozone, or smog, which

has been shown to cause

adverse effects on human health and can damage forests and crops.

! EPA estimates that the total nationwide annualized cost would be

about $10.9 million per year.

2

! After assessing the impact of the final rule on small businesses,

EPA determined that it will not

significantly impact a substantial number of small businesses.

BACKGROUND

! Under the Clean Air Act, EPA is required to regulate emissions of

188 listed toxic air

pollutants. The Act also requires EPA to identify industrial or

source categories that emit one

or more of these pollutants. The Act further requires EPA to develop

emissions standards

requiring stringent air pollution reduction measures for each of the

identified source categories.

! EPA's published list of industry groups to be regulated includes

surface coating of plastic parts

and products.

! Plastic parts and products surface coating operations emit a

number of toxic air pollutants

including toluene, methyl ethyl ketone, glycol ethers including

ethylene glycol monobutyl ether,

xylenes, and methyl isobutyl ketone. Health effects associated with

these pollutants include

irritation of the lung, skin, and mucous membranes; effects on the

central nervous system; and

damage to the liver.

FOR MORE INFORMATION

! To download the standard from EPA's website on the Internet, go

to " Recent Actions " at the

following address: http://www.epa.gov/ttn/oarpg/ramain.html.

! For general information about the standards, contact Ms. Kim Teal

of EPA's Office of Air

Quality Planning and Standards, Emission Standards Division,

Coatings and Consumer

Products Group at (919) 541-5580, or by electronic mail at:

teal.kim@.... Or visit the

plastic parts and products (surface coating) website at:

http://www.epa.gov/ttn/atw/plastic/plasticpg.html.

! The EPA's Office of Air and Radiation (OAR) homepage on the

Internet contains a wide range

of information on the air toxics program and many other air

pollution programs and issues. The

OAR's home page address is: http://www.epa.gov/oar/.

! This source category was assigned electronic docket number OAR-

2002-0074.

FACT SHEET http://www.epa.gov/ttn/oarpg/t3/fact_sheets/mocm_fs.pdf

FINAL RULE TO REDUCE HAZARDOUS AIR EMISSIONS FROM MISCELLANEOUS

ORGANIC CHEMICAL MANUFACTURING FACILITIES

ACTION

! On August 25, 2003, the Environmental Protection Agency (EPA) is

issued a final rule to reduce

hazardous air emissions from, miscellaneous organic chemical

manufacturing facilities .

! Hazardous air pollutants, also known as air toxics, are those

pollutants known, or suspected, to

cause cancer and other serious health problems. The primary air

toxics emitted during the

production of organic chemicals are methanol, vinyl acetate, hexane,

methylene chloride, hydrogen

chloride and toluene.

! Today's final rule requires facilities to install excellent

emissions controls known as " maximum

achievable control technology " or MACT for process vents, storage

tanks, equipment leaks,

wastewater systems, and transfer operations at facilities covered by

this rule.

! Today's rule also includes provisions that allow industry to

comply through an alternative, pollution

prevention-based standard. The alternative standard requires

significant reductions in the amounts

of toxic air pollutants used during the manufacturing process. The

rule would allow facilities to

focus on improving processes by reducing solvent use.

! The final rule will reduce air toxics emissions by 16,800 tons per

year. The rule will also reduce

volatile organic compound emissions, which contribute to the

formation of ground-level ozone (smog).

! The annualized cost of this rule will be approximately $75 million.

BACKGROUND

! The Clean Air Act requires EPA to identify industrial or " source "

categories that emit one or more

of the 188 toxic air pollutants listed in the Act.

! For major sources within each source category, the Act requires

EPA to develop standards that

restrict emissions to levels consistent with the lowest emitting

plants. Major sources are those

sources that emit 10 tons per year or more of a single air toxic or

25 tons per year or more of a

combination of air toxics.

! The " Miscellaneous Organic Chemical Manufacturing " source category

covers 22 categories on

EPA's initial list of source categories. It includes source

categories generally known as

miscellaneous chemical production and polymers and resins.

Chlorinated paraffin production,

rubber chemical production, polyester resin production and alkyd

resin production are examples

of processes covered by this rule.

MORE INFORMATION

! For further information about the proposal, contact Randy Mc

of EPA's Office of Air

Quality Planning and Standards at (919) 541-5402.

! EPA's Office of Air and Radiation's homepage on the internet

contains a wide range of information

on the air toxics program, as well as many other air pollution

programs and issues. The Office of

Air and Radiation's home page address is: http://www.epa.gov/oar.

May 29, 2003

CLARIFICATIONS TO EXISTING REGULATIONS REDUCING EMISSIONS OF TOXIC

AIR POLLUTANTS

FACT SHEET http://www.epa.gov/ttn/oarpg/t3/fact_sheets/cedp_fs.pdf

TODAY'S ACTION

• The Environmental Protection Agency (EPA) is amending a series of

its regulations that control

toxic air emissions. Toxic air pollutants, or air toxics, are known

or suspected of causing cancer

or other serious health effects.

• Today's rulemaking revises EPA's national standards for emissions

of toxic air pollutants from

industrial sources. These amendments clarify which discretionary

authorities contained in each

regulation can be delegated to state, local, and tribal air

pollution control agencies (S/L/Ts).

• Discretionary authorities are certain regulatory requirements,

such as when to submit compliance

reports or approval of minor monitoring changes. Under the Clean Air

Act, the approval of some

of these authorities can be delegated to S/L/Ts. For example, when

an industry seeks to change

their schedule for submitting compliance reports, today's rulemaking

clarifies that the S/L/Ts can

either approve or disapprove their request. However, other

regulatory requirements, such as

approving alternative emission standards, must be retained by EPA

and cannot be delegated.

• EPA is issuing this rule to make the delegation provisions in all

national air toxics regulations

consistent. Delegation provisions are sections of the regulations

spelling out discretionary

authorities that can be delegated. See the Attachment for a list of

the standards being revised in

today's rulemaking. Recently issued standards include corrected

delegation provisions.

• Today's rule will also make the delegation provisions in all

national air toxics rules consistent with

EPA's " General Provisions. " The general provisions (1) are

requirements and authorities that are

common to each air toxics standard and (2) provide regulatory

language for EPA to use, such as

general air pollution monitoring requirements, that are common to a

variety of emission standards.

• EPA developed today's rulemaking in response to S/L/T concerns

regarding the uncertainty of

delegated national emission standard authorities. Specifically, who

has the authority to approve or

disapprove source-specific alternatives to air toxic requirements.

• Today's rulemaking would either add an implementation and

delegation paragraph to or modify

the existing implementation and delegation paragraph contained in

each national air toxics

regulation.

BACKGROUND

• Under the Clean Air Act , EPA is required to regulate emissions of

188 listed toxic air pollutants.

On July 16, 1992, EPA published a list of industrial source

categories that emit one or more of

these air toxics. For listed categories of " major " sources (those

that emit 10 tons annually or more

of a listed pollutant or 25 tons or more of a combination of

pollutants), the Act requires EPA to

develop national emission standards requiring the specified

industrial source category to apply

stringent air pollution reduction measures known as maximum

achievable control technology.

• Since the Clean Air Act Amendments of 1990, EPA has promulgated

most of the air toxics

standards. The Agency expects to have the remaining emission

standards promulgated by 2004.

The newer emission standards will have updated delegation provisions

and will not require the of

revisions included in today's rulemaking.

FINAL RULE REQUIREMENTS

• In some cases, a specific facility would like to use a alternate

approach, to monitor emissions or to

demonstrate compliance (discretionary authorities), than what is

required in the applicable air toxic

regulation. The source would need to contact either the EPA or the

S/L/T to determine whether

their alternative approach is acceptable. Currently, it is not clear

in each existing air toxic rule who

has the authority to approve or disapprove these kind of

alternatives.

• A specific example of a discretionary authority that can be

delegated is " notification of initial

compliance status " which requires a source to submit a report

discussing whether it is complying

with all the requirements of the national emission standard for

Primary Aluminum Reduction Plants.

A source may request to submit this information in their operating

permit application rather than a

separate report known as an initial compliance status notification.

Today's rulemaking clarifies that

the appropriate S/L/T would have the authority to either approve or

disapprove this request.

• In order to receive EPA approval to exercise these discretionary

authorities, the S/L/Ts would have

to seek delegation of each national emission standard through the

delegation process defined by the

Clean Air Act.

BENEFITS AND COST

• Today's rulemaking contains amendments to each national emission

standard ensuring that required

air toxic emission reductions will occur, while providing state,

local, and tribal air pollution control

agencies greater flexibility; without additional cost or process.

• Today's rulemaking would also benefit industry in several ways.

For example, this rulemaking will

clarify which agency (S/L/Ts or federal) they need to contact when

seeking approval of alternative

requirements. In many cases, industry will be dealing with state,

local, and tribal air pollution

control agencies with whom they have more contact and routine

interaction than with the federal

government.

FOR FURTHER INFORMATION

• Interested parties can download today's rulemaking from EPA's web

site on the Internet under

" recent actions " at the following address:

http://www.epa.gov/ttn/oarpg. For further information

about today's rulemaking, contact Tom Driscoll of EPA's Office of

Air Quality Planning and

Standards at (919) 541-5135.

• EPA's Office of Air and Radiation's home page on the Internet

contains a wide range of

information on the air pollution programs including air toxics

issues. The Office of Air and

Radiation's home page address is: http://www.epa.gov/oar/.

Attachment

Standards Affected by this Rulemaking

Subpart F National Emission Standards for Organic Hazardous Air

Pollutants for the Synthetic

Organic Chemical Manufacturing Industry

Subpart G National Emission Standards for Organic Hazardous Air

Pollutants from the Synthetic

Organic chemical Manufacturing Industry for Process Vents, Storage

Vessels, Transfer

Operations, and Wastewater

Subpart H National Emission Standards for Organic Hazardous Air

Pollutants for Equipment

Leaks

Subpart I National Emission Standards for Organic Hazardous Air

Pollutants for Certain

Processes Subject to the Negotiated Regulation for Equipment Leaks

Subpart L National Emission Standards for Coke Oven Batteries

Subpart M National Perchloroethylene Air Emission Standards for Dry

Cleaning Facilities

Subpart N National Emission Standards for Chromium Emissions from

Hard and Decorative

Chromium Electroplating and Chromium Anodizing Tanks

Subpart O Ethylene Oxide Emissions Standards for Sterilization

Facilities

Subpart Q National Emission Standards for Hazardous Air Pollutants

for Industrial Cooling

Towers

Subpart R National Emission Standards for Gasoline Distribution

Facilities (Bulk Gasoline

Terminals and Pipeline Breakout Stations)

Subpart S National Emission Standards for Hazardous Air Pollutants

from the Pulp and Paper

Industry

Subpart T National Emission Standards for Halogenated Solvent

Cleaning

Subpart U National Emission Standards for Hazardous Air Pollutant

Emissions: Group I Polymers

and Resins

Subpart W National Emission Standards for Hazardous Air Pollutants

for Epoxy Resins Production

and Non-Nylon Polyamides Production

Subpart X National Emission Standards for Hazardous Air Pollutants

from Secondary Lead

Smelting

Subpart Y National Emission Standards for Marine Tank Vessel Loading

Operations

Subpart AA National Emission Standards for Hazardous Air Pollutants

from Phosphoric Acid

Manufacturing Plants

Subpart BB National Emission Standards for Hazardous Air Pollutants

from Phosphate Fertilizers

Production Plants

Subpart CC National Emission Standards for Hazardous Air Pollutants

From Petroleum Refineries

Subpart DD National Emission Standards for Hazardous Air Pollutants

from Off-Site Waste and

Recovery Operations

Subpart EE National Emission Standards for Magnetic Tape

Manufacturing Operations

Subpart GG National Emission Standards for Aerospace Manufacturing

and Rework Facilities

Subpart HH National Emission Standards for Hazardous Air Pollutants

from Oil and Natural Gas

Production Facilities

Subpart II National Emission Standards for Shipbuilding and Ship

Repair (Surface Coating)

Subpart JJ National Emission Standards for Wood Furniture

Manufacturing Operations

Subpart KK National Emission Standards for the Printing and

Publishing Industry

Subpart LL National Emission Standards for Hazardous Air Pollutants

from Primary Aluminum

Reduction Plants

Subpart OO National Emission Standards for Tanks- Level 1

Subpart PP National Emission Standards for Containers

Subpart QQ National Emission Standards for Surface Impoundments

Subpart RR National Emission Standards for Individual Drain Systems

Subpart VV National Emission Standards for Oil-Water Separators and

Organic-Water Separators

Subpart CCC National Emission Standards for Hazardous Air Pollutants

from Steel Pickling-HCl

Process Facilities and Hydrochloric Acid Regeneration Plants

Subpart DDD National Emission Standards for Hazardous Air Pollutants

from Mineral Wool

Production

Subpart EEE National Emission Standards for Hazardous Air Pollutants

from Hazardous Waste

Combustors

Subpart GGG National Emission Standards for Pharmaceuticals

Production

Subpart HHH National Emission Standards for Hazardous Air Pollutants

from Natural Gas

Transmission and Storage Facilities

Subpart III National Emission Standards for Hazardous Air Pollutants

from Flexible Polyurethane

Foam Production

Subpart JJJ National Emission Standards for Hazardous Air Pollutant

Emissions: Group IV

Polymers and Resins

Subpart LLL National Emission Standards for Hazardous Air Pollutants

from the Portland Cement

Manufacturing Industry

Subpart MMM National Emission Standards for Hazardous Air Pollutants

from Pesticide Active

Ingredient Production

Subpart NNN National Emission Standards for Hazardous Air Pollutants

from Wool Fiberglass

Manufacturing

Subpart OOO National Emission Standards for Hazardous Air Pollutant

Emissions: Manufacture of

Amino/Phenolic Resins

Subpart PPP National Emission Standards for Hazardous Air Pollutants

for Polyether Polyols

Production

Subpart RRR National Emission Standards for Hazardous Air Pollutants

for Secondary Aluminum

Production

Subpart TTT National Emission Standards for Hazardous Air Pollutants

for Primary Lead Smelting

Subpart VVV National Emission Standards for Hazardous Air

Pollutants: Publicly Owned Treatment

Works (POTW)

Subpart XXX National Emission Standards for Hazardous Air Pollutants

for Ferroalloys Production:

Ferromanganese and Silicomanganese