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P2 for Area Source Categories: P2 Opportunities
Table of Contents
Background and Overview
Affected Industries
Reasons to Change
P2 Opportunities
Where to Go for P2 Help
Complete List of Links

Essential Links:

Auto Refinish Project Best Practices Kit
Checklists and fact sheets on painting topics including: sanding, solvent wipe down, paint mixing, s...

Automotive Refinishing Pollution Prevention Outreach Program - Results
This case study presents the results of two P2 measures; the STAR training and the use of LaserPaint...

Clean Air Rules: Will They Affect You?
Automotive refinish coatings future may hold additional regulatory requirements. Describes rulemakin...

Ethylene Oxide (EtO) Sterilizers
Fact Sheet: Background of regulations concerning EtO. Presents alternatives that can be used. *Note ...

Ethylene Oxide Fact Sheet
Fact sheet written to give employers the information they need in order to manage staff exposure to ...

Fact Sheet: Industrial Boilers
This fact sheet describes the process of establishing NESHAP regulation of major industrial boiler s...

Frequently Asked Questions for Auto Body Refinishing Area Source Rule
Explains why this rule is being proposed, who will be affected, what toxics the rule is targeting, i...

P2RX Hospital Sterilizer Topic Hub
This website gives extensive pollution prevention information and resources for the hospital sterili...

P2RX Auto Body Topic Hub
This website gives extensive information about pollution prevention for the Auto Body sector, includ...

In anticipation of the new rules to be promulgated by the EPA for 70 area source categories, P2RX is committed to providing information for proactive businesses, agencies and non-profits that are interested in adopting practices and technologies that will reduce air emissions.

The first three area source categories that P2RX is providing P2 information for are:

  • Auto Body Refinishing
  • Hospital Sterilizers
  • Industrial Boilers

These were selected as the first sectors to focus on because they are prevalent in all regions of the U.S. and are good candidates to achieve compliance with the expected regulation through P2 enhancements. P2 information for additional area source categories will be added as it becomes available.

Auto Body Refinishing

Under the new air rule, auto body refinishing shops will be subject to standards that control pollution from the refinishing of motor vehicles such as automobiles, trucks and commercial vehicles. The new rule will apply to "area" sources; those sources that emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons or more annually of a combination of hazardous air pollutants. Major sources; sources that emit more than 10 tons annually of a single hazardous air pollutant or more than 25 tons or more annually of a combination of hazardous air pollutants, were regulated by a national emission standard for hazardous air pollutants (NESHAP) in 2004.

The primary SIC for this source category is 7532. Auto body and mobile equipment refinishing operations are known to emit hazardous air pollutants (HAPs) such as cadmium, chromium, isocyanates, lead, manganese, and nickel compounds.

Although the rule has not been finalized, some of the proposed requirements of the new rule include:

  • All shop (not office) personnel would need to complete training in the proper use of refinish materials and to be certified by a national certification body, such as I-CAR and ASE, in order to buy and use auto refinish materials.
  • All shops would need to have a filtered spray booth and all spraying of coatings, would need to be done in the spray booth, or in a similar filtered enclosure, such as a prep station.
  • All spraying of coatings would need to be done with an HVLP spray gun, or one with equivalent transfer efficiency.
  • All shops would need to have an enclosed spray gun cleaner.

Each of these measures will not only reduce emissions, but also may help bring a shop into compliance with the new regulations. In addition, these measures have other benefits ranging from reducing material costs, insurance costs, risk of health related injuries and/or illnesses, to giving your shop a competitive edge, based on technological improvements. Case studies relating to these measures are available by following the links listed in the sidebar.

Hospital Sterilizers

The use of the hospital sterlizer ethylene oxide (EtO) is one of the area sources that may be regulated by December 2007. It is estimated that approximately half of all hospitals are still using EtO and so will be subject to the new area source rule. Since many states have already regulated hospital emissions of EtO, many hospitals may have already been regulated, however others will be regulated for the first time. The EPA's proposed rule requires all hospitals which do not control their emissions of ethylene oxide to reduce emissions by sterilizing full loads to the extent practical. Hospitals which route ethylene oxide to a control device are exempt from the management practice. EPA estimates that the propose rule would prevent 5 tons per year of ethylene oxide emissions at a cost of less than $2 million per year.

EtO has been regulated for large air pollution emitters by a National Emission Standard for Hazardous Air Pollutant (NESHAP) rule for commercial sterilizers since 1994. The NESHAP regulation also applies to many smaller "area sources", however historically there has been an exemption for hospital use. "Area sources" are those that emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons annually of a combination of hazardous air pollutants, with major sources emitting greater than those quantities. Previously area sources were not regulated since individually they are small emitters, however together they represent a significant contribution to the emission of many hazardous air pollutants. Almost 100% of all hospitals fall into the area source category rather than being major sources of air pollution individually. Currently however, the EPA is drafting an area source rule that will specifically regulate hospital EtO emissions.

Since 1999 many hospitals have reduced their use of EtO voluntarily or to comply with their state regulations. This reduction was likely a result of the designation of EtO as be a probable human carcinogen, teratogen and neurotoxin in the late 1990s. In 1990, the estimated total EtO emitted by hospitals in the U.S. was about 1000 tons/year. At that time, almost all of this use was uncontrolled, with emissions released into sewers or into the air. By 2005, use has dropped to about 135 tons/year with an estimated 50% of the use being controlled.

Industrial Boilers

Boilers burn coal and wood as well as using other types of fuel to produce steam. The steam is used to produce electricity or provide heat. Process heaters heat raw or intermediate materials during an industrial process. Boilers and process heaters are used at facilities such as refineries, chemical and manufacturing plants, and paper mills. In addition, these boilers may stand alone to provide heat for shopping malls and university heating systems.

Emissions from boilers include mercury, lead and CO2. Exposure to emissions of air toxics from boilers may produce a wide variety of human health effects including irritation of the lungs, skin and mucous membranes, problems with the central nervous system, kidney damage, and cancer. The final area source rule will protect human health and the environment by reducing emissions from boilers.

Although the rule has not been finalized, some of the proposed requirements of the new rule include:

  • Emissions reduction limit of 10-20% of metals
  • Emission reduction limit of 30-40% of particulate matter
  • Annual energy audit
  • Annual tune-up
  • Work practice standards requirements
  • Incentives to use cleaner fuel
  • Operator training


The Topic Hub™ is a product of the Pollution Prevention Resource Exchange (P2Rx)

The P2 for Area Source Categories Topic Hub™ was developed by:

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Hub Last Updated: 9/24/2012