ACA Submits Comments to EPA on Proposed Amendment to NESHAP for MCM

摘要

ACA submitted comments to the U.S. Environmental Protection Agency (EPA) in August on the proposed amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coating Manufacturing (MCM) facilities. EPA's proposed amendments would establish inorganic HAP standards for process vessels, following the mandated technology review conducted under the Clean Air Act (CAA), originally promulgated in August 2020. The current MCM NESHAP does not regulate metal HAP from process vessels. Specifically, EPA is proposing to revise Table 1 of 40 CFR part 63 subpart HHHHH to include the emission limits that apply to process vessels based on the following findings by EPA: 1. Existing sources demonstrate initial compliance with the particulate matter (PM) emissions limit of 0.014 gr/dscf (grains per dry standard cubic foot); and 2. New sources demonstrate initial compliance with the PM emissions limit of 0.0079 gr/dscf.