July 20, 1999

TO:	Metal Coil Coating PMACT/MACT Stakeholders

FROM:	Trish Koman, EPA/OAQPS/ESD/CCPG

SUBJECT:	Update on the Status of MACT Standards Development

The purpose of this memorandum is to update Metal Coil Coating Stakeholders on the status of maximum achievable control technology (MACT) development for the Metal Coil Coating source category. First, there has been a change of project leaders. Mrs. Rhea Jones has assumed the EPA Lead from Mr. George Smith. Mrs. Jones has been involved with the Metal Coil MACT Standard development since September of 1998, approximately the time when ICR responses were being received. Mrs. Jones' telephone number is (919) 541-2940 and her E-mail address is jones.rhea@epa.gov.

Technical work is proceeding on the project. To date, MACT information collection request (ICR) responses have been received from 91 coil coating plants. The ICR responses have been entered into a data base and the preliminary data analysis is complete. The focus of the current work is the development of the MACT floor, which is expected to be completed by the end of July.

Also work on developing the model plants that will be used to estimate the environmental, cost, and economic impacts of regulatory options is in progress. Since emissions from coating lines using organic-solvent based coatings are typically controlled by the use of thermal or catalytic incinerators, the model plants will reflect the level of HAP emission control currently being achieved. One task that EPA will be undertaking will be to identify and estimate the cost of measures that will be taken to reduce the HAP emission rate from facilities with emission controls that do not achieve the MACT floor HAP emission rate. For example, a facility might chose to reformulate a coating to reduce the HAP content or to upgrade the emission control system by improving the capture efficiency or the destruction efficiency of the incinerator. We would like to hear from you concerning approaches that might be taken in specific situations to lower the HAP emission rate if required to do so to meet the MACT standard.

We appreciate your continued interest and cooperation in this effort.