National Emission Standards for Hazardous Air Pollutants for the Boat Manufacturing Industry, Risk and Technology Review

July 1, 2019 Via Electronic Filing U.S. Environmental Protection Agency EPA Docket Center Docket ID No. EPA-HQ-OAR-2016-0447 Mail Code 28221T 1200 Pennsylvania Avenue, NW Washington, DC 20460 RE:National Emission Standards for Hazardous Air Pollutants: Boat Manufacturing Residual Risk and Technology Review; ACA Comments Dear Sir or Madam: The American Coatings Association (ACA) submits the following comments on the National Emission Standards for Hazardous Air Pollutants: Boat Manufacturing Residual Risk and Technology Review Proposal. ACA supports the comments submitted by the National Marine Manufacturers Association (NMMA) and EPAs overall proposed conclusions regarding the residual risk and technology review. However, ACA opposes the inclusion of formal spray gun training requirements because they are unnecessary and would not be cost effective. Spray Gun Operator Training Work Practice Requirements are not Cost Effective The Environmental Protection Agency (EPA) requested comment on the use of training for spray gun operators to ensure delivery of controlled spray when applying resin and/or gel coating during open molding production. Specifically, EPA is seeking comments to determine whether this practice is widely used by industry, whether significant HAP reductions are achieved industry-wide, and whether HAP reductions can be achieved in the manufacturing of large and small boats or large and small boat parts. Boat manufacturers implement a wide array of processes, procedures, and best practices to minimize waste of materials, improve transfer efficiency, and reduce overall emissions. Spray gun operator training is just one such approach to ensure both lower emissions as well as lower material usage in the industry. Given the already widespread use of these practices and the importance of minimizing costs for boat manufacturing businesses, imposing an additional, formal work practice training requirement for spray gun operators will not result in much, if any, environmental benefit. However, imposing formal work practice training programs in addition to the existing training programs will result in greater costs associated with tracking operator training, reporting, and recordkeeping requirements. Therefore, ACA opposes the inclusion of formal spray gun training requirements because they are unnecessary and would not be cost effective. Thank you for your consideration of our concerns. Please do not hesitate to contact us if you have any questions. Sincerely, /s/ David Darling Vice President, Health, Safety and Environmental Affairs