Boat Manufacturing MACT
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6. How Does an Affected Facility Demonstrate Compliance?
Unless an add-on control device is used, the HAP content
of all the materials regulated by the final NESHAP must
be measured and  recorded. HAP content may be determined
using test methods specified in the NESHAP, or documentation
provided by the material manufacturer, such as a material
safety data sheet (MSDS), can be used to show compliance.
Air pollution control inspectors will use the test method
results to determine compliance if they differ from the
manufacturer's documentation.
Compliance with the HAP content limits is based on the
weighted-average HAP content for each material on a 12-
month rolling-average basis. Compliance is determined at
the end of every month (12 times per year) based on the
past 12 months of data. To determine weighted-average HAP
content, facilities will also need to monitor and record
the amount of each regulated material used per month, as
well as HAP content. On the compliance date, new and existing
sources must begin collecting the data needed to demonstrate
compliance.
 If
all of the material in a particular operation meets the
applicable HAP content limit, then no records of the amount
of material used need to be kept. Likewise, there is no
need to perform and record any calculations to determine
weighted-average HAP content.
For open molding resin and gel coat operations, how to
show compliance will depend on which compliance option is
chosen. For example, if the facility chooses to average
among several open molding resin and gel coat operations,
they will have greater operating flexibility. But the facility
will also need to do more recordkeeping and calculations
to show compliance than if they complied with each individual
HAP content limit.
Also, a facility must complete an implementation plan for
the open molding operations at their facility that are included
in an averaging option. The implementation plan must describe
the resin and gel coat materials the facility plans to use,
their HAP contents, and the application process for these
materials to show compliance. The plan must also include
calculations showing that the choice of materials and application
methods that will achieve compliance. Records must be kept
of the HAP content of all materials that are subject to
HAP content limits.
Records must be kept of the amount of material used and
any calculations performed to determine compliance using
 weighted-average HAP contents or the averaging option for
open molding operations. Every month, inspections must be performed of the covers required by the work practice standards
for resin and gel coat mixing containers and aluminum recreational
boat coating spray gun cleaners. Facilities must also keep
records of the results of these inspections and any repairs
made to the covers. All records must be kept for 5 years
(at least the last 2 years of records must be kept onsite).
After the initial compliance demonstration, all sources
must complete semiannual compliance reports.
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