# RTR NESHAP for Shipbuilding and 

# Ship Repair & Wood Furniture Manufacturing Operations

OMB Briefing 

## October 5, 2011

## Overview

• Wood Furniture Manufacturing Operations

– Background

– Proposed rule

– Risk review

– Final rule



### • Shipbuilding and Ship Repair (Surface Coating)

– Background

– Proposed rule

– Risk review

– Final rule



### • Schedule

2Wood Furniture Manufacturing Operations



## Background
- 1995 MACT

• 406 facilities

• Restrictions for HAPs achieved through coating formulation

– Consistent with other coating regulations

• 1995 MACT requires compliant coatings for finishing, cleaning, gluing and thinning

– Does not apply to aerosol adhesives & gluing to nonporous substrates (e.g. plastics and metals)

• Conventional spray gun use limited to emissions routed to control device

• Formaldehyde: Rule requires sources to establish a baseline of emissions and, if it is exceeded, a response to the permitting authority is required

– If exceeded, one of several explanations to maintain compliance is that formaldehyde emissions are less than 400 lbs/12 months

3Wood Furniture Manufacturing Operations



## What Was Proposed?

• Elimination of all conventional spray guns under section 112(d)(6)

• Implementation of use limit of 400 pounds (0.2 tons) per rolling 12
- month period on formaldehyde use facility
- wide

– 400 lb/year is the negotiated de minimis value established with industry in the 1995 Wood Furniture NESHAP

– Proposed under section 112(f)(2); solicited comment on section 112(d)(6)

• Startup, Shutdown and Malfunction (SSM) revisions

– Elimination of SSM exemption

– Incorporation of affirmative defense language

• Risks estimates were determined to be acceptable

- Potential acute risk to the general public is not ruled out with estimated max 1
- hr exposures exceeding short
- term occupational and WHO reference values

4Wood Furniture Manufacturing Operations 

## What Has Transpired Since Proposal?

• The facility with the highest chronic cancer risk was 

### determined not to be a wood furniture facility

- The Maximum Individual Lifetime cancer risk (MIR) based on actual emissions change from 20 to 10 in 1 million

- MIR based on allowable emissions changes from 40 to 20 in 1 million



### • A limit of 400 lb/yr of formaldehyde will restrict production 

### at large volume facilities

– Based on comment from Kitchen Kompact



### • Many of the larger formaldehyde
- emitting facilities have significantly reduced emissions from 2005 NEI data

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### • Formaldehyde limit compliance alternatives

- Low formaldehyde (≤ 1%) formulations for all wood furniture coatings

- 400 lb/12 month period emission limit of formaldehyde



### • Conventional spray gun restriction

- Restrict conventional spray gun use to instances when overspray is routed to an add
- on control device



### • SSM

- Incorporation of affirmative defense language

6 Wood Furniture Manufacturing Operations



## Final RuleShipbuilding and Ship Repair (Surface Coating)



## Background

• 90 facilities: Build, paint, repaint and repair ships

• MACT applies to marine and freshwater vessels used for military or commercial operations

• Primary HAPs include: Xylenes , Ethyl benzene, Toluene and Glycol ethers

• Existing MACT requirements:

- Compliant coatings o Volatile organic hazardous air pollutant (VOHAP) limits based on coating category either general use or specialty use such as military exterior and undersea weapons equipment

- Work practice standards o Coatings should be covered when not in use and stored and transported in a manner that minimizes spills

• Since 1995 MACT, HAP reduced by 27% 7Shipbuilding and Ship Repair (Surface Coating)



## What Was Proposed?

• SSM revisions

– Elimination of SSM exemption

– Incorporation of affirmative defense language



### • No revisions to the current numerical coating limit 

### standard

– Requested comment on availability and performance of coating with lower overall VOHAP content or lower toxicity VOHAP content



### • Preamble states EPA’s intent to list welding and 

### abrasive blasting operations occurring at shipbuilding and ship repair facilities as a major source category under section 112(c)(5) in a separate action

– Hexavalent chromium from welding and abrasive blasting is the driver for facility
- wide risk
8Shipbuilding and Ship Repair (Surface Coating)



## Final Rule

• Finalize rule as proposed with updated SSM language



### • Retain current language expressing the EPA’s intent to list welding and abrasive blasting operations occurring at 

### shipbuilding and ship repair facilities as a separate major source category under section 112(c)(5)

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## OMB Review Schedule

• OMB review began October 3, 2011



### • Final Signature (court
- ordered) October 31, 2011

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