Will your facility be subject to stricter volatile organic compound (VOC) emission limits under the eight-hour National Ambient Air Quality Standards (NAAQS) for ozone? During the next four months, the U.S. Environmental Protection Agency (EPA) will publish new regulations implementing the eight-hour standard. VOC emissions are regulated under ozone NAAQS provisions because VOCs react in the atmosphere to create ground-level ozone. Meeting future VOC emission reduction requirements imposed under the ozone NAAQS program may compel use of add-on emission controls. Most at risk are composite parts manufacturers located in newly designated "nonattainment areas" or in areas that are receiving higher nonattainment classification levels that trigger additional VOC emission reduction requirements.

Two rules set the stage for transitioning from the older one-hour 0.12-ppm ozone standard to the eight-hour 0.08-ppm standard. By mid-February 2004, EPA is expected to publish an implementation rule defining the compliance framework for attaining the 0.08-ppm ozone standard. Basically, this rule will tell state air quality agencies how EPA will designate air quality areas as attainment or nonattainment with regard to meeting the 0.08-ppm ozone standard. The rule will also explain the procedure for classifying nonattainment areas based on the severity of ozone exceedances (classifications include marginal, moderate, serious, severe, and extreme). Setting VOC emission reduction mandates and attainment schedules are also important parts of the rule. The next "Composites & Compliance" column will explain this rule.

In the next few months, EPA will designate and classify all nonattainment areas of the United States with respect to the eight-hour ozone standard. The agency has already notified states of its intended ozone designations. Using this information, I've compiled a map showing expected nonattainment areas under the new standard. Expected ozone nonattainment areas are shown in red and blue. Red indicates areas where EPA and the state agree on an eight-hour ozone nonattainment designation. Blue indicates areas where the state advocated an attainment designation, but EPA is poised to label the area nonattainment.

EPA's planned designations expand many state-recommended nonattainment areas by adding more surrounding counties. While EPA prefers to designate entire counties as attainment or nonattainment, large counties containing disparate city/rural areas may have rural portions designated nonattainment and metropolitan portions designated attainment. In cases where air quality designations split counties, the map overstates nonattainment areas because it is drawn using entire counties. California is a prime example. Many of California's counties in the Central Valley and the southern desert area will have split designations. Although more than half of California appears slated for eight-hour ozone nonattainment, less of the state will be designated nonattainment.

While the map data were current as of December 2003, EPA may revise designations based on more recent ambient air quality monitoring data and additional feedback from states. Final air quality designations will be issued by April 15, this year.

Generally, industrial facilities located in areas with the highest ambient ozone concentrations (and highest nonattainment classifications) are subject to the most stringent VOC emission reductions. Based on data released thus far, EPA appears to be leaning toward a relatively lenient classification system. Most one-hour nonattainment areas would receive an eight-hour ozone classification at the same or a lower level. However, a few areas that currently meet the one-hour ozone standard could be designated nonattainment for the eight-hour standard and receive unexpectedly high classification levels. Several of these nonattainment areas could be classified as serious.

State and regional air quality agencies individually determine which types of facilities must cut emissions to improve air quality in areas under their jurisdictions. Therefore, composite parts manufacturers in one nonattainment area may need to cut VOC emissions, while similar facilities in another nonattainment area continue operations unaffected. If VOC emissions from the composites industry are a significant portion of total VOC emissions in an area, composites facilities are more likely to be targeted for emission reductions.

After EPA promulgates official eight-hour ozone nonattainment designations, state and regional agencies will have three years to develop VOC emission reduction plans, known as state implementation plans (SIPs). After states submit SIPs to EPA in 2007 (or before), emission reduction deadlines will be imposed, beginning that same year. Area classifications determine the schedule for VOC emission reductions, although state and local air quality agencies can accelerate deadlines. VOC reduction under the NAAQS program can be a trial-and-error process. If a state's initial SIP does not achieve federal ozone standards, additional reductions must occur in future years. In addition, new or expanding facilities in ozone nonattainment areas are subject to a stringent preconstruction review process during which air quality agencies ensure that expansion will not increase ozone pollution.

Unfortunately, pollution prevention strategies that help facilities meet Maximum Achievable Control Technology (MACT) requirements (e.g., using low-VOC resins and gel coats and non-atomizing application methods) are unlikely to reduce emissions enough to meet NAAQS-driven mandates in areas where composites facilities are targeted for additional VOC reductions. Ideally, composites manufacturers should take into account their area's eight-hour ozone designation and classification when they select emission reduction techniques, as they develop MACT compliance strategies. Timing, however, may create less than ideal conditions: Because April 21, 2006 is the compliance deadline for most facilities subject to the reinforced plastic composites production MACT, composite parts manufacturers must implement compliance strategies before most states will finalize their eight-hour ozone SIPs. Consequently, a composites facility located in an ozone nonattainment area could meet MACT in April 2006 but discover, a year later, that it must reduce VOC emissions to meet state-imposed NAAQS requirements.

For more information about the MACT, order a copy of Emission Control Strategies: A Guide for Composites Manufacturers, Tel.: (303) 467-1776, Fax: (303) 467-1777.