| Résumé : |
Before opening the floor for general discussion on the Clean Air Act Amendments of 1990 (CAAA), the Symposium Chairman has asked me to provide a brief overview of the impact thses regulations will have on leather tanning and finishing facilities. Some of this may be covered by the following speakers, but I want to try and sharpen the focus a bit on specific air pollutants, relevant regulatory requirements and areas of tannery operations potentially affected. If this discussion does nothing more than get your attention and perhaps disabuse some earlier misconceptions, then it will have been successful. Some of you, for example, may have been lulled into a sense of complacency, believing these regulations are applicable only to very large facilities, or, perhaps, only to tannery finishing operations. Clearly that is not the case. Because of the far reaching nature of these regulations coupled with a number of very worrisome ambiguities for which EPA has yet to provide satisfactory guidance, there appear to be few if any industry facilities that will not be impacted to some degree either now or in the future. To begin with, the universe of regulated air pollutants is extremely broad - including, among other things, volatile organic compounds (VOCs), PM-10 particulates, hazardous air pollutants (HAPs), ozone depleting chemicals, sulfur dioxide and nitrogen oxides and, finally, pollutants subject to accidental release reporting (e.g. hydrogen sulfide). Generation, usage and/or release of pollutants in any one or more of these categories is very likely to trigger compliance requirements under the CAAA. In addition to this broad coverage of air pollutants, the regulations clearly target facilities of all sizes, both large and small. Initially, EPA has provided an exemption for most so-called "non-major" sources. However, this exemption will only last for approximatively five years, at which time CAA permitting requirements may be extended to include non-major sources as well. Of often greater significance, the major source determination is based on a plant's potential to emit rather than its actual emissions, which by itself brings many relatively small facilities into the system. So the light you see in the Clean Air tunnel is indeed a train, bearing down at remarkable speed and before much of the track has even been completed ! |
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Impact of the new air regulations on leather tanning and finishing operations in JOURNAL OF THE AMERICAN LEATHER CHEMISTS ASSOCIATION (JALCA), Vol. LXXXX, N° 2 (02/1995)
