plastic parts and products surface coating mact summary

5. What are the HAP emission limits, operating limits and other standards required by this rule?

Emission Limits

The organic HAP emissions from each existing affected source are limited according to Table 2 below.  The organic HAP emissions from each new or reconstructed affected source are limited according to Table 3 below.  For each of the subcategories, the emission limit is expressed as the mass of organic HAP emissions per mass of coating solids used during each 12-month compliance period.

TABLE 2 – EMISSION LIMITS FOR EXISTING AFFECTED SOURCES

TABLE 3 – EMISSION LIMITS FOR NEW OR RECONSTRUCTED AFFECTED SOURCES

The facility may choose from several compliance options to achieve the applicable emission limits. They could comply by applying materials (coatings, thinners and/or other additives, and cleaning materials) that already meet the emission limits, either individually or collectively, during each compliance period. The facility could also use a capture system and add-on control device to meet the emission limits, or comply by using a combination of both approaches.

Operating Limits

Operating limits are applicable to facilities that reduce emissions by using a capture system and add-on control device (other than a solvent recovery system for which they conduct a liquid-liquid material balance).  These limits are site-specific parameter limits that they must determine during the initial performance test of their system. For capture systems that are not permanent total enclosures, the average volumetric flow rates or duct static pressure limits for each capture device (or enclosure) in each capture system must be established.  For capture systems that are permanent total enclosures, limits on average facial velocity or pressure drop across openings in the enclosure must be established.

For thermal oxidizers, the facility must monitor the combustion temperature. For catalytic oxidizers, the facility must monitor the temperature immediately before and after the catalyst bed, or monitor the temperature before or after the catalyst bed and implement a site-specific inspection and maintenance plan for the catalytic oxidizer. For regenerative carbon adsorbers for which the facility does not conduct a liquid-liquid material balance, the carbon bed temperature and the amount of steam or nitrogen used to desorb the bed must be monitored.  For condensers, the outlet gas temperature from the condenser must be monitored.  For concentrators, the temperature of the desorption gas stream and the pressure drop across the concentrator must be monitored.

The site-specific parameter limits that the facility establishes must reflect operation of the capture system and control devices during a performance test that demonstrates achievement of the emission limits during representative operating conditions.

Work Practice Standards.

If a facility uses an emission capture system and control device for compliance, they must develop and implement a work practice plan to minimize organic HAP emissions from mixing operations; storage tanks and other containers; and handling operations for coatings, thinners and/or other additives, cleaning materials, and waste materials. If the affected source has an existing documented plan that incorporates steps taken to minimize emissions from affected sources, the facility may able to use the existing plan to satisfy the requirement for a work practice plan.

If a facility uses a capture system and control device for compliance, they are required to develop and operate according to a startup, shutdown, and malfunction plan (SSMP) during periods of startup, shutdown, or malfunction of the capture system and control device.