Transcript NESHAP Title

METAL FURNITURE
SURFACE COATING
MACT QUESTION &
ANSWERS
40 CFR PART 63, SUBPART RRRR
July 2006
Questions/Answers
#1
Frequently Asked Questions
Q. If the facility builds a new building
next to a current building, does
the new building become a new
source?
Q/A #1
A.
The best source to answer these
questions is the facility’s
permitting authority because the
decision may rest on site specific
factors.
Q/A #2
Q. A facility uses gel coat that contains
alpha- methyl styrene. Should the
percentage of this chemical be
added to the styrene content?
Q/A #2
A. No, alpha-methyl styrene is not a
HAP. It is important to remember
that the surface coating industry
uses glycol ethers, that as a family
is a HAP. However, USEPA has
designated specific glycol ethers
that are NOT HAPs.
Q/A #3
Q. For facilities that are complex or collated
with different metal furniture surface
coating operations, are any
consolidation options available to
compliance?
Q/A #3
A.
Section 112(d)(2) requires that all major
sources within a major source category
must meet maximum emission reduction
determined to be achievable. Therefore,
due to the complexity of allowing such
options, none are allowed in the rule, but
c/c options can be used on a c/c operation
basis. This is particularly true under the
Title V process.
Q/A #4
Q. Does a metal furniture surface
coating facility have to comply
with the emission limitations
during periods of startup,
shutdown and malfunction?
Q/A #4 (A)
A. USEPA concluded that this CAA
provision is not appropriate for the
surface coating NESHAP. When these
short-term tests and monitoring
results are only one component of a
compliance determination that
determines emissions over a long
period of time.
(Continued on next page)
#4 (Answer cont’d.)
A. Which in this case is a month. For the
metal furniture rule, the source owner
will use the performance test and
continuous monitoring results in
combination with data on coatings
and other materials used over a
month’s period of time.
# 4 ( answer cont’d.)
A. These components will be used to
calculate a monthly organic HAP
emission rate. There may be many
startups and shutdowns of a
coating operation over the course
of a month as part of a normal
operation.
# 4 ( answer cont’d.)
A. It is not appropriate to exempt such
periods from compliance with the
standards. The month long period
will accommodate potential short term
higher emission rates that might
occur due to SSM.
Q/A #5
Q. Does a Subpart RRRR affected
facility have to comply with NSPS
requirements?
Q/A #5
A. Since the NESHAP and NSPS regulations
focus on different aspects of an affected
facility:



Organic HAP vs VOCs,
NS date of 11/28/80 vs NS NESHAP date of
04/24/02,
NSPS based on amount of solids applied vs
NESHAP organic HAP solids used at facility)
compliance must be achieved with both
regulations.
Q/A #6
Q. If a facility coats some metal parts
and some plastic parts, is the source
subject to Subparts MMMM and
PPPP?
Q/A #6
A. If the coating of such parts as knobs,
hinges and screws takes place at a
facility that coats these parts for
multiple types of products, (e.g., not
exclusively metal or plastic furniture)
the coating operations would be
subject to Subparts MMMM and PPPP.
Q/A #7
Q. How can a facility determine the
mass of organic HAP in coatings,
thinners and cleaning materials
and the volume coating solids?
Q/A #7
A. A facility can determine the mass of
organic-HAP values by:
 Either relying on manufacturer’s data, or
 On results from the test methods
provided in Subpart RRRR.
 The rule requires the determination of
the mass of organic HAP in coatings,
thinners and cleaning materials and
waste materials.
Q/A #8
Q. Can a facility be considered in
compliance with the Initial
Notification requirement if the
facility had filed their Section 112J
notice on time?
Q/A #8
A. The Section 112J notice requires
additional information above and
beyond the Initial Notification
requirement. As such, the facility
would be considered in compliance
with the Initial Notification (IN)
requirement and filing the IN would
be redundant.