EPA Progresses Industrial Surface Coating MACT Residual Risk and Technology Review

On Dec. 20, the U.S. Environmental Protection Agency (EPA) finalized minor amendments to the 2002 and 2003 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface Coating of Large Appliances; Printing, Coating, and Dyeing of Fabrics and Other Textiles; and Surface Coating of Metal Furniture. In its final amendments, EPA heeded many of ACA’s comments — including excluding requirements for high-efficiency spray guns and certain compliance demonstrations after operational changes — and determined that risks from these source categories are acceptable; and that the agency has identified no developments in practices, processes or control technologies that would further reduce emissions of hazardous air pollutants. As such, EPA is finalizing no significant changes to the original NESHAP for these source categories and has determined the standards continue to provide an ample margin of safety to public health and the environment.

According to EPA, the agency is finalizing minor amendments to the existing regulations to enhance the effectiveness of the rules by improving compliance with the existing requirements, to increase efficiency of data submissions and to standardize the frequency of performance testing. This action clarifies that the standards are applicable during periods of startup, shutdown and malfunction. In addition, EPA is requiring that affected facilities submit compliance reports and test results electronically and is requiring that performance tests be conducted every five (5) years.

EPA developed numerous Surface Coating Maximum Achievable Control Technology (MACT) standards between 1995 and 2004. These rules set Hazard Air Pollutant (HAP) standards for major source coating application facilities. EPA is required under the Clean Air Act evaluate the risk to public health remaining after application of the technology-based standards and revise the standards, if necessary.

Throughout this process, ACA is coordinating advocacy efforts with applicator associations, auto manufacturers, can manufacturers and coil manufacturers.

To date, EPA has completed the following Residual Risk and Technology Reviews:

• Wood Furniture Manufacturing operations (limited usage of formaldehyde in coatings and contact adhesives to 1% by weight);

• Shipbuilding and Repair (no changes were necessary);

• Aerospace Coatings Operations (adopted specialty aerospace coating volatile organic compound limits); and

• Large Appliances and Metal Furniture (consistent with ACA comments, EPA did not increase the stringency of the standards).

EPA is under court-ordered deadlines to complete the review of the remaining surface coating MACT rules.

• Metal Can and Metal Coil – EPA published proposed rule in October 2018, final rule May 2019;

• Boat Manufacturing – EPA to propose in February 2019, final rule November 2019; and

• Auto and Light Duty Truck; Miscellaneous Metal Parts; Plastic Parts – EPA to publish proposed rule March 2019, final rule February 2020.

While EPA may propose lower HAP limits and more stringent add-on controls, it is more likely that EPA will propose to prohibit the use of conventional spray guns; increase add-on control monitoring; and require that the application facility comply with the standards at all times, including periods of start-up, shut-down and malfunction.

Via the Industrial Coatings Council, ACA will review and submit comments on the proposed rules. ACA will also coordinate comments with downstream coating application associations.

Contact ACA’s David Darling for more information.

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from American Coatings Association https://www.paint.org/mact-deadline/
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