EPA Industrial Surface Coating MACT Residual Risk and Technology Review (RTR) Update  

On May 17, the U.S. Environmental Protection Agency (EPA) published its proposed residual risk and technology review (RTR) for Boat Manufacturing and Reinforced Plastic maximum achievable control technology (MACT). For both rules, EPA found the residual risk acceptable and did not propose any changes based on technology review. However, EPA did suggest that some facilities train their spray gun operators to deliver a controlled spray. EPA estimated that the training resulted in as much as 40–50% reduction in overspray. In the reinforced plastic industry some spray operators weigh the overspray to gauge application efficiency. EPA is asking if this training is widely used and could be applied across both industries. EPA also asks if significant hazardous air pollutant (HAP) reductions would be possible; and if HAP reductions can be achieved for both large and small operations.

EPA is also removing the startup, shutdown, and malfunction (SSM) provisions and is adding an electronic reporting requirement. The agency included a 180-day compliance period in the rules. Comments on the proposed rules are due July 1, 2019.

EPA developed numerous MACT standards for Surface Coating between 1995 and 2004. These rules set standards for HAP at major source coating application facilities. EPA is required to conduct an RTR for each MACT standard eight years after promulgation. EPA is concluding 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 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.

On May 6, EPA released a prepublication version of its proposed Metal Can and Metal Coil RTR. EPA is proposing no revisions to HAP limits, but is proposing amending provisions addressing emissions during periods of SSM.

The agency is also proposing to amend provisions regarding electronic reporting of performance test results, as well as monitoring requirements; and to make miscellaneous clarifying and technical corrections. EPA is also proposing that for metal can and coil facilities that utilize add-on control devices, that the performance of these devices be retested every five years (performance testing via state or Title V permits are accepted). As an alternative, EPA has said that the facility could install a continuous emissions monitoring system (CEMS). In addition, EPA has replaced the Occupational Safety and Health Administration (OSHA) 0.1 percent / 1.0 percent HAP thresholds with a new table of organic HAP that must be included in calculating total organic HAP content of a coating material if they are present at 0.1 percent or greater by mass.

EPA has completed four other reviews:

  • Wood Furniture Manufacturing Operations. EPA limited usage of formaldehyde in coatings and contact adhesives to 1 percent by weight.
  • Shipbuilding and Repair. EPA deemed no changes were necessary.
  • Aerospace Coatings Operations. EPA adopted specialty aerospace coating VOC limits.
  • Large Appliances and Metal Furniture. On Dec. 20, 2018, EPA finalized this RTR. Consistent with ACA comments, EPA did not increase the stringency of the standards (e.g., EPA did not impose more stringent spray gun requirements). EPA replaced the OSHA 0.1 percent / 1.0 percent HAP thresholds with a new table of organic HAP that must be included in calculating total organic HAP content of a coating material if they are present at 0.1 percent or greater by mass.

EPA is under court ordered deadlines to complete the review of the remaining surface coating MACT rules. This summer the agency will likely propose amendments to the Auto & Light Duty Truck; Miscellaneous Metal and Plastic Parts; and Paper and Other Web MACT Surface Coating Rules; and finalize them by March 13, 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; require performance testing of control devices, and require that the application facility comply with the standards at all times, including periods of SSM.

Via the Industrial Coatings Council, ACA will review and submit comments the proposed rules. ACA will also coordinate comments with downstream coating application associations (e.g., auto manufacturers, can manufacturers, and coil manufacturers).

The EPA Residual Risk and Technology Review (RTR) website is https://www3.epa.gov/ttn/atw/rrisk/rtrpg.html.

Contact ACA’s David Darling for more information.

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