global environmental legislation guide - National Marine ...

1. National emission standards for hazardous air pollutants: shipbuilding and ship repair(surface coating) operationsIn 2007, EPA took a direct final action on the amendments to the national emissionstandards for hazardous air pollutants (NESHAP) for shipbuilding and ship repair (surfacecoating) operations under the authority of the Clean Air Act (CAA). These direct finalregulation amendments close an unintended gap in the scope of activities subject to theNESHAP by amending the definition of ‘‘ship’’ to include all marine or freshwater vessels thatare (1) 20 meters or more in length.Issues for the recreational marine and superyacht industriesThe EPA direct final regulation did not clarify the difference between larger pleasure craft -superyachts and ships. The issue is of importance to the large yacht industry. It wasinappropriate of the agency to delete the definition of “pleasure craft” and amend thedefinition of “ship” to include surface coating operations of recreational boats over 20meters in the shipbuilding and ship repair (surface coating) operations MACT (“ShipbuildingMACT”).ResultsThe EPA direct rule was redrawn after receiving the comments from NNMA, ICOMIA and thepaint industry.Further actionsBased on the comments, EPA will propose a new regulation coordinated with the industry. Apositive detail is that the former competent EPA officer would like to be informed how tointegrate the EU averaging approach. This is based on his input and the results of theInternational Superyacht Coatings Conference.UpdateSee below the update of the CTG’s2. Control techniques guidelines in lieu with regulations for miscellaneous metalproduct coatings etc.EPA proposed for Control Techniques Guidelines (CTGs) in lieu of regulations formiscellaneous metal products coatings, plastic parts coatings, auto and light-duty truckassembly coatings, fibreglass boat manufacturing materials and miscellaneous industrialadhesives. The purpose of the CTGs is efficiency of national regulations regarding VOC/HAPemissions from coating activities and boat manufacturing.Issues for the recreational marine and superyacht industriesThe proposed CTGs will potentially impact the control of emissions at the productionfacilities and will overlap other EPA regulations, like NESHAP.Further actionsEPA adopted the comments from the industry relating to production of fibreglass boats. Thecomments relating to the coating activities are still pending. ICOMIA and the paint industryreceived a proposal from EPA regarding to the averaging approach, which will be supportedby industry.24