    Wood Building Products Surface Coating MACT Risk and Technology Review
             National Tribal Air Association Meeting May 31, 2018
Twin Risk and Technology Review Goals:
 Determine the residual risk for cancer, non-cancer, and acute health impacts from the residual Hazardous Air Pollutants, or HAP remaining in the category source emissions after the implementation of the Maximum Achievable Control Technology or MACT rules in the Clean Air Act
 Determine if there are new technologies in the source category for new controls, new processes or new productions practices that would lead to reductions in HAP emissions if they were implemented broadly.
Other Goals:
 Review the Start Up, Shut Down and Malfunction rules in the standard
 Review the Testing and Reporting Procedures
 Review Compliance Demonstration Options
Who is affected?
Five Subcategories of Sources, No such thing as a "WBP" industry; Mention Wood Furniture/Kitchen Cabinets.  The facilities are spread throughout the country and the numbers of each are roughly equal:
 Window Manufacturers
 Door Manufacturers
 Flooring Manufacturers
 Wood Paneling Manufacturers
 Wood Siding Manufacturers
What is Required?
Facilities are required to Comply with the standard by 1) Using a compliant coating based on your subcategory or 2) install controls, typically oxidizers.  Typically, in this category oxidizers were installed to control Volatile Organic Compounds or VOC and control HAP coincidentally.
New Source limits are very restrictive; 4 of the 5 subcategories are set at Zero HAP emissions.
By the Numbers
 Before/After MACT HAP emissions: 14,311 tpy before, current inventory 260 tpy.
 55 major source facilities were identified prior to proposal.  Post-proposal we have identified 5 additional facilities
 At least a dozen facilities are not major sources but may have been prior to MACT.  We estimated that there were over 200 facilities at proposal, but that was not based on accurate survey information.
 No facilities identified are on tribal lands.
 Greatest Cancer Risk: 6 in a million; only one facility, all remaining facilities met the residual risk target of 1 in a million.  Our population impact estimates showed 800 people at a risk of greater than 1 in a million.
 Greatest Non-Cancer and Acute Exposure Risks  -  both less than 1, comparable to 1 in a million for cancer.

Key Dates
 Proposal: May 16, 2018
 Comments Due: Friday, June 15, 2018
 Final Rule Signature: Before December 31, 2018
 Deadline is based on a Court Order
Key Findings and Actions in Proposal
 EPA determined risks from the source category to be acceptable and that the rule provides an ample margin of safety to protect public health.
 The technology assessment for the source category did not identify any technological developments to reduce emissions of hazardous air pollutants. 
 Eliminate the startup, shutdown and malfunction exemption.
 Require facilities to submit electronic copies of compliance reports, including performance tests.
 Add an alternative compliance demonstration option. 
 Solicit input on periodic performance testing for facilities using add-on controls
 OMB's assessment was that the proposed rule would not have a significant impact




                        National Tribal Air Association
                                   U.S. EPA
                                       
                                       
                       NTAA- EPA Air Policy Update Call
                             Thursday May 31, 2018
                                   10 am AK
                                   11 am PT
                                   12 pm MT
                                    1 pm CT
                                    2 pm ET

Call into 1-805-309-2350 to help NTAA conserve funds or toll free into 1-800-309-2350
User Code 928-523-0526#

To view documents discussed on the call, please log on here: https://attendee.gotowebinar.com/register/1730695464315260162

When you register on the Gotowebinar screen, please type in your Tribe and Region after your last name so everyone can see who is on the call and we can avoid a lengthy roll call.

CALL AGENDA 

 OAQPS Updates
 Proposed Amendments to the Federal Implementation Plan for the Indian Country Minor New Source Review Program for the Oil and Natural Gas Industry  Presenter: Chris Stoneman, OAQPS (5 to 10 mins.)

On April 30, 2018, EPA signed proposed amendments to the 2016 federal implementation plan (FIP) for managing air emissions from new and modified true minor oil and natural gas sources in Indian country. The FIP limits emissions of harmful air pollutants, while providing streamlined construction authorization for new and modified "true minor sources" in the oil and natural gas production and natural gas processing segments of the oil and natural gas sector. The proposed amendments would allow the FIP to continue to apply in portions of the Uintah and Ouray Indian Reservation that may be included in an area EPA has designated as nonattainment for the 2015 national ambient air quality standards for ozone. The current FIP applies only in areas designated as attainment, attainment/unclassifiable or unclassifiable.  For more information on this proposal, refer to EPA's website Controlling Air Pollution from the Oil and Natural Gas Industry.
   
 NESHAP:  Surface Coating of Wood Building Products Residual Risk and Technology Review 
Presenter:  John Bradfield, OAQPS (5 to 10 mins.)

The  EPA is proposing amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface Coating of Wood Building Products to address the results of the residual risk and technology review (RTR) that EPA is required to conduct under the Clean Air Act (CAA). For more information, refer to EPA's website Surface Coating of Wood Building Products: NESHAP. Comments must be received on or before 6/15/18.  (Submit your comments, identified by Docket ID No. EPA - HQ - OAR - 2016 - 0678, at http://www.regulations.gov.)
 Proposed Rule: Review of the Primary National Ambient Air Quality Standard for Sulfur Oxides 
Presenter:  Nicole Hagan, OAQPS (5 to 10 mins)
      The EPA proposes to retain, without revision, the current primary (health-based) national ambient air quality standard (NAAQS) for sulfur oxides (SOX). This action falls within the context of the Clean Air Act requirement for the periodic review of the primary NAAQS for SOX.  For more information, refer to EPA's website https://www.epa.gov/naaqs/sulfur-dioxide-so2-primary-air-quality-standards

 Other EPA Updates from OAR, ORIA, OAP, OTAQ 

 National Tribal Caucus Updates

 Tribal Air Monitoring Support (TAMS) Center Updates

 Institute for Environmental Professionals (ITEP) Updates

 Clean Air Act Advisory Committee (CAAAC) Updates

 NTAA Updates and Announcements

