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

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Wood 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

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Wood 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

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Wood 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

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Wood Furniture Manufacturing Operations 

Final Rule
Shipbuilding 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%

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Shipbuilding 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

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Shipbuilding 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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