Case study: development of national emissions standards for hazardous air pollutants for magnet wire manufacturing

Many industries in the United States are facing new Federal air emissions regulations, known as NESHAP or MACT, intended to reduce emissions of hazardous air pollutants (HAPs). US-EPA\´s regulatory philosophy when writing a MACT is to demand that all members of a given industry raise their air pollution control hardware and practices to match the better performers within that industry, while maintaining extensive records to prove compliance. Any facility subject to a MACT would thus find itself challenged, and the challenge for the magnet wire industry was made even more profound by being a mature, specialized industry included in an enormous MACT subcategory ("miscellaneous metal parts and products surface coating"). This paper discusses the efforts of the magnet wire industry to work cooperatively to meet the underlying purpose of the MACT air standard, thus achieving meaningful reduction in HAP emissions, while minimizing useless expense and effort as much as possible.