plastic parts and products surface coating mact summary

7. What are the compliance alternatives for facilities with multiple coating NESHAP requirements and multiple emission limits?

This rule allows facilities subject to more than one surface coating emission limit to comply with each applicable emission limit separately or to adopt one of two alternatives.

The first alternative allows all coating operations to comply with the emission limit representing the predominant surface coating activity at the facility (the predominant activity means the surface coating activity representing 90 percent or more of the total surface coating activity). The predominant activity approach is also available for sources that are subject to more than one subcategory emission limit.  A source may determine which subcategory represents 90 percent or more of the coating activities that take place at the facility, and then have all coating operations at the facility comply with the emission limit that represents the predominant activity.

The second alternative allows a facility to comply with a facility-specific emission limit calculated from the relative amount of coating activity that is subject to individual emission limits. The facility-specific emission limit may include separate emission limits from one or more applicable NESHAP.  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 must be included. 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.

Another approach that a facility might be able to consider is the equivalency by permit option described in 40 CFR Part 63, Subpart E (63.94). Under this approach, the facility may design an emissions control program that is suited for their process or plant as long as they can demonstrate that their program will achieve the same emissions reductions as the NESHAP. In choosing this route, a facility must work with their State, local or tribal air pollution control agency to submit an equivalency demonstration. This equivalency demonstration will be reviewed by the appropriate EPA Regional Office. The equivalency demonstration is approved as part of the operating permit approval process.