Plastic Parts and products surface coating mact summary

3. How does this rule relate to other rules?

New source performance standards (NSPS) that could potentially apply to sources subject to this  rule include the Standards of Performance for Industrial Surface Coating: Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT). Because of the differences between the NSPS and the NESHAP, compliance with either rule cannot be deemed compliance with the other. A plastic parts and products surface coating operation that meets the applicability requirements of both the NSPS and the NESHAP must comply with both.

Affected sources that meet the applicability criteria in this rule may also meet the applicability criteria of other coating NESHAP. For example, some facilities that coat plastic and metal parts using the same or different coatings, coating application processes, and conveyance equipment, either simultaneously or at alternative times could be subject to both the Plastic Parts and Products Surface Coating NESHAP and the Miscellaneous Metal Parts and Products Surface Coating NESHAP.  EPA has minimized the burden of complying with multiple surface coating emission limits in this rule by offering two alternatives to complying separately with each applicable emission limit.

The first alternative allows a facility to have all applicable surface coating operations comply with the emission limit that represents the predominant type of coating activity at that facility. Predominant activity means the coating activity that represents 90 percent or more of the surface coating activities at a facility. For example, if a facility is subject to both the Plastic Parts and Miscellaneous Metal Parts NESHAP and the activities subject to the Miscellaneous Metal Parts NESHAP account for 90 percent or more of the surface coating activity at the facility, then the facility may comply with the emission limitations for miscellaneous metal parts and products for both types of surface coating operations.

However, the predominant activity alternative may be applied if 90 percent or more of the surface coating is in the general use or TPO coating subcategory and not for the assembled on-road vehicle or automotive lamp coating subcategories that represents the predominant activity. The emission limits for those two subcategories reflect specialized performance requirements and the need for higher-HAP-containing materials. When using this alternative, the facility must include all surface coating activities that meet the applicability criteria of a subcategory in a surface coating NESHAP and constitute more than 1 percent of total coating activities. Coating activities that meet the applicability criteria of a subcategory in a surface coating NESHAP but comprise less than 1 percent of total coating activities need not be included in the determination of predominant activity but they must be included in the compliance calculations.

The second alternative allows a facility to calculate and comply with a facility-specific emission limit for each 12-month rolling average compliance period. The facility would use the relative amount of coating activity subject to each emission limit in each NESHAP to calculate a weighted, or composite, emission limit for that facility. Compliance with that facility-specific emission limit for all surface coating activities included in the facility-specific emission limit constitutes compliance with the emission limits in the Plastic Parts NESHAP, as well as other applicable NESHAP. As with the predominant activity alternative, a facility must include all surface coating activities that meet the applicability criteria of a subcategory in a surface coating NESHAP and constitute more than 1 percent of total coating activities. Coating activities that meet the applicability criteria of a subcategory in a surface coating NESHAP but comprise less than 1 percent of total coating activities need not be included in the facility-specific emission limit calculation, but they must be included in the compliance calculations.