reinforced plastic composites production mact summary

8. What are the testing, initial and continuous compliance requirements?

Facilities must conduct an initial performance test using specified EPA test methods on all affected sources that use a control device to achieve compliance. The tests must be conducted at the inlet and outlet of the control device.  Test results must be used to calculate a percent reduction.

Facilities are also required to conduct a design evaluation, as specified by EPA Method 204 of appendix M of 40 CFR part 51, if they use permanent total enclosures to capture HAP emissions. If the enclosure does not meet the requirements for a permanent total enclosure, the enclosure must be tested to determine the capture efficiency by EPA Methods 204B through E of appendix M of 40 CFR part 51 or an alternative method that meets the data quality objectives and lower confidence limit approaches contained in 40 CFR part 63, subpart KK. Test runs for EPA Methods 204B through E or alternative test methods must be at least 3 hours.

Prior to the initial performance test, owners and operators of affected sources are required to install the parameter monitoring equipment to be used to demonstrate compliance with the operating limits. During the initial performance test, the owners and operators would use the parameter monitoring equipment to establish operating parameter limits.

If an add-on control device is used, EPA requires owner/operators to monitor and record the operating parameters established during the initial performance test, and calculate average operating parameter values averaged over the period of time specified in the final rule to demonstrate continuous compliance with the operating limits.

If the HAP emissions equations in Table 1 to Subpart WWWW of Part 63 are used to demonstrate that the facilities are maintaining a HAP emissions factor less than or equal to the appropriate HAP emissions limit listed in the final NESHAP, then EPA is requiring that facilities calculate the HAP emissions factor one time if the resins or gel coats used in the operation remain the same, or if all the resins and gel coats used individually meet the applicable HAP emissions limit. Facilities are required to calculate HAP emissions factors on a 12-month rolling average each month if the resin or gel coat varies between operations or varies over time, and not all resins or gel coats taken individually meet the required HAP emissions limit.

If facilities are complying with work practice standards, EPA is requiring that they demonstrate compliance with the work practice standards in the final NESHAP by performing the necessary work practices and by keeping a record certifying that they are in compliance with the work practices.