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7. Small Businesses and Minor Area Air Pollution Sources

CONTRIBUTION OF SMALL VS. LARGE INDUSTRY TO VOC EMISSIONS IN OZONE NON-ATTAINMENT AREAS (%)

Source: Texas Natural Resource Conservation Commission ,Revisions to State Implementation Plans for Ozone (1996).

"Area sources" are small, stationary sources that usually do not emit large amounts of criteria pollutants or toxics, but area sources are very numerous. Some of the important area sources that have been impacted by the federal Clean Air Act include dry cleaners, printers, machine shops, service stations, wastewater-treatment plants, and automobile painting and repair shops. Consumers who use household items are another area source. Even small scale agricultural activities in rural areas contribute to air pollution.

While these "small" businesses and consumer activities individually do not contribute large amounts of pollution to the atmosphere, taken collectively they emit more of some types of pollutants than do some individual large industries. For example, in many cities in Texas, area sources -- such as dry cleaners, paint and auto body shops --contribute more VOCs to smog formation than do major stationary sources.

The federal Clean Air Act is impacting an estimated  55,000 Texas businesses with fewer than 100 employees. The EPA has been developing specific rules for small businesses to reduce their generation of toxic wastes, their use of ozone-depleting chemicals, and, in nonattainment areas, their emissions of VOCs and nitrogen oxides. While some of these regulations are still being formulated, the EPA has pinpointed 23 types of industries it would most likely regulate first.* The state estimated costs for the approximately 20,573 small businesses most likely to be affected by the federal Clean Air Act -- and for which reliable cost data were available -- at over $1 billion, most of it for capital equipment, to comply with the act's regulations over the next five years.*

Air Pollution Control Costs by Industry in Texas

Industry

Estimated Number in Texas

Cost per Facility

Total Industry Cost

Asphalt Manufacturers

67

350,000

23,450,000

Auto Body Painting

1,760

120,000

211,200,000

Auto Repairs

4,634

7,000

131,438,000

Bakeries

138

114,000

15,732,000

Dry Cleaners

3,314

28,000

92,792,000

Furniture Manufacturers

447

500,000

223,500,000

Gasoline Filling Stations

3,710

40,000

148,400,000

Hospitals

139

100,000

13,900,000

Metal Finishers

305

40,000

12,200,000

Newspapers

567

40,000

22,680,000

Printing Shops

3,247

40,000

129,880,000

Refrigeration/AC Repair

2,244

7,000

15,708,000

Wood Finishers

21

40,000

840,000

Total

20,593

51,000

$1,041,720,000

Source: State Small Business Ombudsman, Texas Air Control Board, The Price of Clean Air (April 1993), 20.

In the four nonattainment areas alone, the cost to businesses for obtaining a federal operating permit and installing pollution control equipment is expected to total $505 million. In addition, in 2004, the EPA will announce which areas will be considered nonattainment for the 1997 standards for the eight-hour ozone standard and fine particles  (PM 2.5). It is likely to  bring new areas in Texas -- like Austin, Tyler-Longview, and San Antonio -- into nonattainment for ozone, while Houston, El Paso and Corpus Christi could be declared non-attainment for PM 2.5 resulting in further controls on small businesses.*

All sources, regardless of location, that emit more than 10 tons per year of any of the 189 toxic pollutants, or 25 tons per year of any combination of these 189 chemicals for which the EPA has or is devloping rules under the Hazardous Air Pollutant program, must install control technology that is at least equivalent to the average of the top 12 percent for that industry if the source is existing at the time those rules are developed. New sources must install the best proven technology for that industry.

Certain categories of small businesses will face other costs under the federal Clean Air Act. In nonattainment areas, for example, service stations must recover gasoline vapors that are released during the transfer of gas from the pump to a vehicle and from a tanker to the underground storage tank. In Texas, gas stations in Brazoria, Chambers, Fort Bend, Galveston, Liberty, Montgomery, Waller,  Hardin, Jefferson, Orange, Collin, Dallas, Denton, Tarrant and El Paso have had to install Stage I and Stage II vapor recovery systems, which under new rules, must be checked each year to measure their effectiveness. Some older and smaller stations are exempt from some parts of the regulations*. As other metropolitan areas begin to institute ozone control strategies in San Antonio, Austin, and Longview-Tyler, it is likely that stations will be forced to institute these controls as well. In fact, some stations in these areas have already begun installing the systems in anticipation of new regulations.

STAGE I AND STAGE II VAPOR RECOVERY SYSTEM

Source: Texas Air Control Board, Texas Air Control Board Fact Sheets: Stage II Vapor Recovery Systems (1993).

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