EPA Proposes Boat Manufacturing Residual Risk Review
On April 18, 2019, the U.S. Environmental Protection Agency (EPA) proposed Residual Risk amendments to the 2001 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Boat Manufacturing. EPA is proposing minor amendments to enhance the effectiveness of these rules by improving compliance and implementation.
The Boat Manufacturing NESHAP covers the production of fiberglass and aluminum boat hulls or decks, mold building to manufacture hulls or decks, and boat assembly from premanufactured parts. The regulated processes include fiberglass resin and gel coat operations, carpet and fabric adhesive operations, and painting operations.
The two main components of the Boat Manufacturing Residual Risk Review that NMMA dedicated significant resources to support boat builders and provide EPA with critical data were the risk assessment and the technology review.
RESIDUAL RISK ASSESSMENT
The CAA requires EPA to assess the risk remaining after application of the final air toxics emission standards. This is known as a residual risk assessment. Based on the completed risk assessments, available health information and associated uncertainties, EPA determined risks from the Boat Manufacturing source category to be acceptable and that the current rules provide an ample margin of safety to protect public health.
TECHNOLOGY REVIEW
The CAA also requires EPA to assess, review and revise air toxics standards, as necessary, considering developments in practices, processes and control technologies. The technology reviews of the standards for Boat Manufacturing facilities did not identify any developments that would further reduce hazardous air pollutant emissions beyond the original NESHAPs which are current practices at boat plants.
This proposal has yet to be published in the Federal Register, so it is fresh off the press, but on first review, EPA has asked questions in the proposal that NMMA will respond to with formal written comments. In the coming weeks, NMMA will also provide boat manufacturers with guidance so that they can submit comments addressing the industry position regarding the EPA questions and supporting the EPA risk and technology review determinations. If you would like to review the proposal it can be accessed at: https://www.epa.gov/stationary-sources-air-pollution/risk-and-technology-review-boat-manufacturing-and-reinforced.