METAL FURNITURE SURFACE COATING MACT QUESTION

1
METAL FURNITURE SURFACE COATING MACT QUESTION
ANSWERS

• 40 CFR PART 63, SUBPART RRRR
• July 2006

2
Questions/Answers1

• Frequently Asked Questions
• If the facility builds a new building next to a
  current building, does the new building become a
  new source?

3
Q/A 1

1. The best source to answer these questions is the
   facilitys permitting authority because the
   decision may rest on site specific factors.

4
Q/A 2

1. A facility uses gel coat that contains alpha-
   methyl styrene. Should the percentage of this
   chemical be added to the styrene content?

5
Q/A 2

1. 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.

6
Q/A 3

1. For facilities that are complex or collated with
   different metal furniture surface coating
   operations, are any consolidation options
   available to compliance?

7
Q/A 3

1. 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.

8
Q/A 4

1. Does a metal furniture surface coating facility
   have to comply with the emission limitations
   during periods of startup, shutdown and
   malfunction?

9
Q/A 4 (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)

10
4 (Answer contd.)

1. 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 months period of
   time.

11
4 ( answer contd.)

• 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.

12
4 ( answer contd.)

1. 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.

13
Q/A 5

1. Does a Subpart RRRR affected facility have to
   comply with NSPS requirements?

14
Q/A 5

• 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.

15
Q/A 6

1. If a facility coats some metal parts and some
   plastic parts, is the source subject to Subparts
   MMMM and PPPP?

16
Q/A 6

1. 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.

17
Q/A 7

1. How can a facility determine the mass of organic
   HAP in coatings, thinners and cleaning materials
   and the volume coating solids?

18
Q/A 7

• A facility can determine the mass of organic-HAP
  values by
• Either relying on manufacturers 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.

19
Q/A 8

1. Can a facility be considered in compliance with
   the Initial Notification requirement if the
   facility had filed their Section 112J notice on
   time?

20
Q/A 8

1. 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.