Bruce Carter Associates - Surface Coating , MACT

United States Environmental Protection Agency (USEPA) was mandated under the 1990 Clean Air Act to develop MACT (Maximum Achievable Control Technology) standards for specific industry categories that emit HAPS (Hazardous Air Pollutants). EPA is to develop technology based standards that would apply to major sources of HAPS. A major source is defined as one with the potential to emit 10 TPY (Tons Per Year) of any individual HAP or 25 TPY of any combination of HAPS.

General information about Surface Coating MACT standards can be obtained at the following website:

http://www.epa.gov/ttn/uatw/coat/coat.html

Two industry source categories subject to MACT standards that are important to the Indiana manufacturing community are:

< Plastic Parts and Products

< Miscellaneous Metal Coating

The MACT standards for these two industry categories are being developed independently by two separate stakeholder groups and two project officers. I will address the status each of these below.

Plastic Parts and Products MACT

USEPA has been developing a MACT standard for Plastic Parts and Products based upon surveys conducted of representative industries. The database consists of approximately 600 facilities. Of these, 200 surface coating facilities were included in the MACT floor database. (A MACT A Floor@ is the minimum performance standards that must be met by industry to comply with MACT). After compiling the results of the survey; USEPA determined that the MACT floor for existing sources should be proposed at 0.06 pounds of HAP per pound of coating solids. By comparison, the Wood Furniture Manufacturing Surface Coating standard was set at 1.0 pounds of HAP per pound of surface coating solids for existing sources. Based on our experience, this standard will be very difficult to achieve. Other relevant points in the survey are:

< The floor was calculated on a facility wide basis, including emissions from coating, thinning, surface preparation, cleaning, adhesives, caulks, sealers, and cure HAP.

< There was no technical justification for establishing any subcategories.

This standard is currently in development and a proposed rule should be published in November 2000. Stakeholders are currently meeting to work on this MACT standard. Kim Teal is the USEPA project officer in charge of this standard and can be reached at the following e-mail address:

The development of the Miscellaneous Metal Coating MACT standard is about six months behind the Plastic Parts and Products MACT. The stakeholders are currently meeting and reviewing the database to establish the floor. USEPA is planning to issue a proposed floor to the stakeholders in November, 1999. The target date for publication of the proposed rule is 1^st quarter of 2001. According to USEPA, there is justification to establish a number of subcategories under the Miscellaneous Metal Coating MACT standard. Information can be obtained by contacting Bruce Moore at USEPA at the following e-mail address:

In addition, you may also wish to be placed on the stakeholders list to receive additional information as it is being published. The contact for placing your name on the stakeholders list:

I will continue to monitor activities on these MACT standards and will compile information as it becomes available. Contact me at the following e-mail address if you would like me to forward relevant information to you.

REMINDER: New facilities will be subject to case by case MACT review (Section 112G of the 1990 Clean Air Act) until the source specific MACT Rules are published.