Boat Manufacturing MACT
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4. What Is the MACT Model Point Value and How Is it Used
in the Final Boat NESHAP?
The MACT model point value is a number calculated for each
open molding operation and is a substitute for emissions
levels. The MACT model point value is a way to rank the relative
performance of different resin and gel coat emissions reduction
techniques. This approach allows the creation of control
strategies using different resin and gel coat emissions reduction
techniques. The final NESHAP provides equations to calculate
MACT model point values based on HAP content and application
method for each material used. These MACT model point values
are then averaged and compared to limits in the final NESHAP
to determine if the molding operations are in compliance.
The
MACT model point values have units of kg of HAP per megagram
of resin or gel coat applied. It is important to note that
the MACT model point values are surrogates for emissions,
and the MACT model point value equations are used only
for determining compliance with the emission limits for
open molding operations. The MACT model point value equations
should not be used in other environmental programs for
estimating emissions in place of true emission factor equations
or site-specific data. 
The MACT model point value equations account only for
the HAP content and the application method. Other factors
(including curing time, part thickness, and operator technique)
can have significant effects on emissions, but these factors
are not accounted for in the MACT model point value equations.
Determining the HAP content of materials and the method
of application is relatively easy, but it is difficult
to determine the other factors. Also, part thickness and
curing time can be specific to the part being manufactured;
so limiting these factors would impede production. Therefore,
factors other than HAP content and application method are
not included in the MACT model point value equations.
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