American Coatings Association
EPARulemakingEPA-HQ-OAR-2018-0747

Review of National Emission Standards for Hazardous Air Pollutants: Miscellaneous Coating Manufacturing

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Last modified
Jun 12, 2024
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closed 1450d ago
American Coatings Association filings
2

Activity

American Coatings Association filed 2 comments on this docket between Oct 25, 2019 and Aug 9, 2022. 1 other organizations filed here. The comment window closed 1450d ago.

What American Coatings Association filed (2)

Aug 9, 2022· Comment submitted by American Coatings Association (ACA)· EPA-HQ-OAR-2018-0747-0077

Please see attached for the American Coatings Association's (ACA) comments to the U.S. Environmental Protection Agency (EPA) regarding its proposed amendments to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coatings Manufacturing (MCM) facilities. ACA appreciates the opportunity to comment on the proposal and looks forward to working with U.S. EPA throughout the rulemaking process.

Oct 25, 2019· Comment submitted by David Darling, Vice President, Health, Safety and Environmental Affairs, American Coatings Association (ACA)· EPA-HQ-OAR-2018-0747-0036

Please find attached comments from the American Coatings Association Best regards, David Darling, P.E. VP, Health, Safety and Environmental Affairs American Coatings Association 901 New York Ave., NW Suite 300 West Washington, DC 20001 202-719-3689

Abstract

This docket contains information to address the Agency's residual risk and technology reviews (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coating Manufacturing. This NESHAP was promulgated pursuant to section 112(d) of the Clean Air Act (CAA) and established emission limitations and work practice requirements based on maximum achievable control technology (MACT) for controlling emissions of hazardous air pollutants. Miscellaneous Coating Manufacturing NESHAP, subpart HHHHH, was promulgated pursuant to section 112(d) of the Clean Air Act (CAA) on December 11, 2003 and covers facilities that manufacture paints, inks, and adhesives. The NESHAP controls emissions of HAP from process vessels, storage tanks, equipment leaks, wastewater streams, transfer operations and heat exchange systems. This review implements the residual risk review requirements of CAA section 112(f)(2) and the technology review requirements of CAA section 112(d)(6). The statute directs the EPA to promulgate emission standards under CAA 112(f)(2) if such standards are required to provide an ample margin of safety to protect public health or to prevent, taking relevant factors into account, an adverse environmental effect. Any such standards are to be promulgated within 8 years after promulgation of MACT standards under CAA section 112(d). CAA section 112(d)(6) requires the EPA to review and revise the MACT standards as necessary, taking into account developments in practices, processes and control technologies, no less often than every 8 years.

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