On Dec. 21, 2010, the U.S. Environmental Protection Agency (EPA) published it proposed " residual risk" rule for National Emission Standards for Wood Furniture Manufacturing Operations. These standards specify Maximum Achievable Control Technolgy, and are commonly known as MACT rules. EPA is required eight years after promulgating MACT standards to reevaluate these rules to see if the rules need to be more stringent to address and remaining "residual risk."

ACA is working on comments on the proposed rule, due to EPA by Feb. 22, 2011.

EPA has proposed revisions to the Wood Furniture Manufacturing MACT rule, which include:
* Eliminating the Startup, Shutdown, and Malfunction exemption (EPA is proposing that standards in the rule apply at all times);
* Prohibiting the use of conventional spray guns;
* Limiting usage of formaldehyde in coatings and contact adhesives to 400 pounds per rolling 12-month period (facilities would have 2 years to comply after effective date); and
* Clarifying applicability for facilities that are subject to other surface coating rules.

Section 112 of the Clean Air Act establishes a two-stage regulatory process to address emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, after EPA has identified categories of sources emitting one or more of the HAP listed in section 112(b) of the CAA, section 112(d) of the CAA calls for the agency to promulgate national emission standards for those sources. "Major sources" are those that emit or have the potential to emit 10 TPY or more of a single HAP or 25 TPY or more of any combination of HAP. For major sources, these technology-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non-air quality health and environmental impacts), or MACT standards.

SOURCE: American Coatings Assn.

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