EPA proposed amendments to three National Emission Standards for Hazardous Air Pollutants (NESHAP): 1) Surface Coating of Large Appliances, 2) Printing, Coating, and Dyeing of Fabric and Other Textiles, and 3) Surface Coating of Metal Furniture.
The proposed amendments are Risk and Technology Review (RTR) standards, which are designed to address the risk that remains eight years after the implementation of Maximum Achievable Control Technology (MACT) standards and improvements in controls since MACT was established. The proposal applies to emission units covered under the three NESHAPs including all coating operations; coatings, conveyors and transfer equipment; and storage, mixing and waste containers.
According to EPA's analysis, the risks remaining after MACT implementation are acceptable and provide an ample margin of safety. However, the agency is proposing several changes, including eliminating startup, shutdown and malfunction exemptions; requiring high-efficiency spray application equipment for units that spray coatings without using permanent total enclosures and control devices; and calling for facilities to submit electronic compliance reports and performance tests.
The proposals were published in the Federal Register (83 Fed. Reg. 46,262) with a comment deadline of October 29, 2018.