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Limits on Ship Coating Emissions Expand

Tuesday, December 6, 2011

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After years of delay, federal emissions limits on shipyard coating operations are now in effect 24/7, in the wake of a new rule by the Environmental Protection Agency.

The final National Emission Standards for Shipbuilding and Ship Repair took effect Nov. 21, ending exemptions granted under the old rule and settling years of litigation between EPA and the Sierra Club.

No Exemptions

The rule affects about 85 shipbuilding and repair facilities covered by the Shipbuilding MACT (Maximum Achievable Control Technology) standard, which was first issued in 1995.

Included are facilities that build, repair, repaint, convert and alter ships. The standard covers the facilities’ surface coating operations during building and repair. More than 90 percent of those Hazardous Air Pollutant (HAP) emissions involve xylene, ethyl benzene and toluene.

 Atlantic Marine Inc. / EPA

 Atlantic Marine Inc. / EPA

Shipyard coating emissions rules are now in effect 24/7. Blasting emissions may be regulated next. 

The original standard limited the coatings that could be used and specified work practices to minimize spills and emissions. However, it granted exemptions from emissions limits during start-ups, shutdowns and malfunctions.

No more. The new rule eliminates the exemptions, making the standard consistent with court positions on other federal rules.

Risk Review

The revision stems from a Consent Decree with the Sierra Club that required EPA to conduct a Risk and Technology Review (RTR) of emissions sources in multiple industries, including shipbuilding. The Clean Air Act requires the agency to review and, if necessary, revise related standards every eight years.

RTRs are used to determine if there have been advances in practices, processes or control technologies since EPA issued the current standard.  Residual Risk Assessments are used to determine whether additional emission reductions are warranted to protect human health and the environment.

The decree required EPA to conduct the review and sign either a final rule that set additional standards or a determination that new standards were not required.

In the case of shipbuilding, the result was the rule imposing emission limits during startups, shutdowns and malfunctions. A malfunction is narrowly defined as “sudden, infrequent, not reasonably preventable, and not caused by poor maintenance and or careless operation.”

Blasting Standards Ahead?

The review yielded no other changes for ship coating operations, but it triggered new concerns by EPA over welding and blasting related to those operations.

As a result, EPA is now crafting new emission standards for blasting and welding during ship coating operations.

That rule would treat welding and blasting as a separate major emissions source category. EPA is currently gathering information on the HAPs emitted by those activities, to develop those standards.

No timetable has been set for that rule, which would join 96 air toxic (MACT) standards that require 174 industry sectors to eliminate 1.7 million tons of 187 toxic air pollutants listed in the Clean Air Act.

Revision Aborted

The shipbuilding coating rule was to have been revised in December 2006, when the EPA proposed what it considered minor amendments. The changes were part of a “direct final rule,” which EPA issues when it considers the amendments noncontroversial and unlikely to provoke comment, a spokeswoman said.

In this case, however, the rule prompted comments and EPA withdrew it until developing the current version.


Tagged categories: Abrasive blasting; EPA; Hazardous air pollutants; Marine; Marine Coatings; Shipyards; VOC emissions; Xylene

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