reinforced plastic composites production mact

7. What are the options for demonstrating compliance?

The final rule provides several options for compliance for certain operations. These options are provided to afford industry the flexibility to decide which method is best suited for each particular situation. Operations not listed in this section have only one option for demonstrating compliance.

For open molding and centrifugal casting operations, sources must determine compliance with the HAP emissions limits by determining HAP emissions factors for the operations at the facility, and comparing the HAP emissions factors to the appropriate HAP emission limits for each open molding and centrifugal casting operation. To determine your HAP emissions factor sources may use the HAP emissions factor equations in Table 1 to subpart WWWW, or HAP emissions factors based on facility HAP emissions testing.

For open molding operations at existing and new sources, the final rule allows sources to choose to comply by meeting the individual HAP emissions limits shown in Table 3 to subpart WWWW of Part 63 for each operation at an affected source, or by meeting the weighted average HAP emissions limit for all open molding operations at an affected source. In addition, if a source produces parts with any combination of manual resin application, mechanical resin application, filament application, or centrifugal casting operations at an affected source, they can comply using the an alternative method shown in Table 7 to subpart WWWW of part 63. Sources must determine the highest allowable HAP resin for each individual operation from Table 3 to subpart WWWW of part 63. This same resin can then be used in all open molding and centrifugal casting operations as shown in Table 7 to subpart WWWW of part 63.

For open molding and centrifugal casting operations where the rule would require a source to meet a percent reduction, an add-on control device can be used to achieve the required reduction, or the source may choose to meet a HAP emissions limit that corresponds to that particular operation’s percent reduction.

For continuous lamination/casting operations at existing and new sources, EPA will allow sources to demonstrate that each continuous casting line and each continuous lamination line meets the appropriate standard in Table 3 to subpart WWWW of part 63, or § 63.5805(b) or (d) of the final rule. Alternatively, sources can average all continuous casting and continuous lamination lines together and demonstrate that they meet the appropriate standard.

An additional alternative for sources that emit less than the 100 TPY threshold would be to capture the HAP emissions from the wet-out area in a permanent total enclosure that meets EPA’s criteria, as specified in Method 204 of appendix M of 40 CFR part 51, and vent the captured wet-out HAP emissions through a closed vent system to a control device achieving 95 percent reduction of HAP emissions. Under the final rule, these alternatives can be used in combination to demonstrate compliance.

The standards for continuous lamination/casting operations are expressed as a percent reduction of HAP emissions. As an alternative, facilities can elect to meet a HAP emissions limit.  For existing and new pultrusion operations, facilities can capture and vent their HAP emissions to a control device that achieves the required percent reduction of HAP emissions. For all existing sources and for new sources that emit less than the 100 TPY threshold, facilities may use a wet-area enclosure with a resin drip collection system, direct die injection or perform injection systems that meet the criteria specified in § 63.5830 of the final rule to meet the 60 percent HAP emissions reduction requirement. For pultrusion machines that produce parts with 1000 or more reinforcements and a cross sectional area of 60 inches or more, facilities must implement the work practice standards in Table 4 to Subpart WWWW of part 63. For SMC manufacturing operations at new sources that exceed the 100 TPY threshold, EPA will allow facilities to meet a 95 percent HAP emissions reduction requirement, or the HAP emissions limit specified in Table 5 to subpart WWWW of part 63.