EPA Industrial Surface Coating MACT Residual Risk and Technology Review Underway

The U.S. Environmental Protection Agency (EPA) developed numerous Maximum Achievable Control Technology (MACT) standards for Surface Coating between 1995 and 2004. These rules set standards for Hazard Air Pollutant (HAP) at major source coating application facilities. EPA is required to conduct a Residual Risk and Technology Review for each MACT standard eight years after promulgation. EPA is currently in the RTR process for several MACT standards.

The RTR requires EPA to review the MACT standard to determine if additional tightening is necessary to eliminate any significant “residual risks” to public health that might remain despite the application of the MACT Standard. Under the residual risk review, EPA must evaluate the risk to public health remaining after application of the technology-based standards and revise the standards, if necessary. Revisions to a MACT standard must provide an ample margin of safety to protect public health or to prevent an adverse environmental effect. During the decision-making process EPA t considers cost, energy, safety, and other relevant factors. Under the technology review, EPA must review the technology-based standards and revise them ‘‘as necessary.”  EPA has determined that revisions would be considered necessary if there were technological developments in practices, processes, and control technologies. Finally, EPA can also set new MACT standards as part of the RTR process.

To date, EPA has completed RTRs for three MACT standards:

  1.  Wood Furniture Manufacturing operations (limited usage of formaldehyde in coatings and contact adhesives to 1% by weight);
  2.  Shipbuilding and Repair (no changes were necessary); and
  3.  Aerospace Coatings Operations (adopted specialty aerospace coating VOC limits).

EPA is under court-ordered deadline to complete the review of the remaining surface coating MACT rules. At a Feb. 22, 2018 meeting with EPA, the agency noted its tentative schedule for completing the RTR reviews:

  • Fabric, Printing and Dyeing; Large Appliance; Metal Furniture — publish proposed rule in May 2018; final rule December 2018
  • Metal Can and Metal Coil — publish proposed rule in Summer 2018; final rule Summer 2019.
  • Auto and Light Duty Truck; Miscellaneous Metal Parts; Plastic Parts — publish proposed rule in late Summer 2018; final rule late Summer 2019
  • Boat Manufacturing — publish Fall 2018; final rule Fall 2019
  • Paper and other Web — publish proposed rule in Spring 2019; final rule March 13, 2020

For many of these MACT categories, while EPA may propose lower HAP limits and more stringent add-on controls, it is more likely that the agency 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.

ACA and its Industrial Coating Air Regulatory Committee will review and submit comments any proposed changes to MACT standards. ACA will also coordinate comments with downstream coating application associations.

Contact ACA’s David Darling for more information.

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