Reinforced Plastic Composites Production Mact Summary

4. What are the HAP emission limits, operating limits and other standards?

EPA promulgated the requirements of the final NESHAP in the form of HAP emissions limits (i.e., HAP emissions factors, mass rate, or percent reduction), operating limits, and work practice standards. Work practice standards include design, equipment, work practices, and operational standards. The final rule contains a HAP emissions threshold that distinguishes between sources that typically can meet the HAP emissions limits using pollution prevention, and those that must use add-on controls. This threshold is called the ‘‘100 TPY threshold.’’

Existing sources must determine if they are below, above or equal to the 100 TPY threshold by summing all HAP emissions from centrifugal casting and continuous lamination/casting operations at the source. For centrifugal casting operations, only HAP emissions from venting of the centrifugal casting mold during spinning and/or curing are considered. The HAP emissions that occur from application of resin or gel coat to an open centrifugal casting mold are considered to be open molding HAP emissions. HAP emissions from other operations or processes are not included because the 100 TPY threshold does not apply to them. For existing sources that are equal to or above the 100 TPY HAP emissions threshold, centrifugal casting and continuous lamination/casting operations must meet an above-the-floor requirement based on 95 percent control of HAP emissions.

New sources must determine if they are below, above, or equal to the 100 TPY threshold by summing all HAP emissions from open molding, pultrusion, SMC and BMC manufacturing, centrifugal casting, continuous lamination/casting, and mixing operations at the source. The HAP emissions from closed molding, cleaning, repair and HAP-containing materials storage are not used in threshold determinations. The requirements for new sources that are equal to or above the 100 TPY HAP emissions threshold are also based on the floor level of control. The floor level of control for these sources is a 95 percent reduction of HAP emissions for open molding, pultrusion, SMC and BMC manufacturing, centrifugal casting, continuous lamination/casting, and mixing operations with one exception.

The requirements for new and existing sources that are below the 100 TPY threshold are based on the MACT floor level of control. For open molding and pultrusion operations at new sources that produce large parts, the floor level of control is the same as existing sources.

In developing final requirements for reinforced plastic composites affected sources, EPA provided an alternative format where possible. For example, a facility meeting a 95 percent HAP emissions reduction requirement for open molding processes can alternatively meet a HAP emissions limit. EPA also provided alternatives for meeting the limits for continuous lamination/casting and SMC manufacturing operations.