Proposed amendments to the Reinforced Plastic Composites Manufacturing NESHAP were published in the Federal Register on Friday, May 17, 2019. The NESHAP regulates sources that use thermoset resins and gel coats to manufacture plastic composite products and includes supporting operations such as cleaning, mixing, storage, and repair.
SUMMARY OF THE PROPOSED CHANGES
EPA completed the residual risk and technology review of the original rule and determined that the risk for cancer and noncancer health effects are low and that, therefore, the current standards are acceptable and provide an ample margin of safety to protect public health. No revisions to emissions standards are proposed.
Language related to startup, shutdown, and malfunction (SSM) exemptions, development of an SSM plan, and recordkeeping and reporting requirements related to the SSM plan will be eliminated from the rule to be consistent with court decisions. This change would remove language that specifically precluded startup and shutdown periods from performance testing as not representative of normal operating conditions. To address the gap, EPA is proposing that sources record process operating data to document what is considered normal operation conditions during the performance test.
EPA is also proposing that notifications, performance test results, and semiannual compliance reports be submitted through EPA’s CEDRI.
For existing sources (sources that began construction on or before May 17, 2019), the effective date for the rule amendments will be 180 days after publication of the final rule in the Federal Register. New sources are subject on the effective date of the rule or upon startup, whichever is later.
More information about the proposed amendments can be found on the EPA website: https://www.epa.gov/stationary-sources-air-pollution/reinforced-plastic-composites-production-national-emission.
For more information on how this might impact your operations, please contact your EPS consultant.