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Surface Coating of Miscellaneous Metal Parts and Products
NESHAP Summary


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3. What Are the Emission Limits, Operating Limits, and Other Standards?

Spraying parts The final rule contains five subcategories: General use coating, high performance coating, magnet wirecoating, rubber-to-metal coating, and extreme performance fluoropolymer coating. The general use subcategory includes all surface coating operations in the miscellaneous metal parts and products source category that are not included in the other four subcategories. This includes operations that coat a wide variety of substrates, surfaces, and types of miscellaneous metal parts and products. It also includes asphalt/coal tar application to metal pipes. High performance coating is any coating that meets the definition of ‘‘high performance architectural coating’’ or ‘‘high temperature coating.’’ Specific definitions can be found in the final rule.

TABLE 2.—EMISSION LIMITS FOR EXISTING AFFECTED SOURCES
Coating type Emission limit (kilo-grams HAP/liter of coating solids) Emission limit (lbs HAP/gal of coating solids)
General use subcategory 0.31 2.6
High performance subcategory 3.3 27.5
Magnet wire subcategory 0.12 1.0
Rubber-to-metal subcategory 4.5 37.7
Extreme performance fluoropolymer subcategory 1.5 12.4


TABLE 3.—EMISSION LIMITS FOR NEW AND RECONSTRUCTED AFFECTED SOURCES
Coating type Emission limit (kilo-grams HAP/liter of coating solids) Emission limit (lbs HAP/gal of coating solids)
General use subcategory 0.23 1.9
High performance subcategory 3.3 27.5
Magnet wire subcategory 0.050 0.44
Rubber-to-metal subcategory 0.81 6.8
Extreme performance fluoropolymer subcategory 1.5 12.4

Emission Limits. The US EPA is limiting organic HAP emissions from each existing affected source using the emission limits in Table 2. For each new or reconstructed affected source, the final emission limits are given in Table 3. For each of the subcategories, the emission limit is expressed as the mass of organic HAP emissions per volume of coating solids (or density) used during each 12-month compliance period.

PCRC VOC, HAP Calculator

NEWMOA P2 Manual for Metal Paint and Coating Operations

Operating Limits
MixingIf the source reduces 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), the operating limits applies. These limits are site-specific parameter limits that the source determines during the initial performance test of the system.

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.

Startup, Shutdown, and Malfunction Plan
If a facility use a capture system and control device for compliance, you 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.


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