Surface Coating of Miscellaneous Metal Parts and Products
NESHAP Summary

4. What Are the Testing and Initial Compliance Requirements?

Emission Limits
There are three options for complying with the final emission limits, and the testing and initial compliance requirements vary accordingly. Sources may choose to use one compliance option for the entire affected source, or they may use different compliance options for different coating operations within the affected source. See the rule for more possible combinations.

Option 1: Compliant materials
This option is a pollution prevention option that allows the facility to demonstrate compliance by using low-HAP or non-HAP coatings and other materials. If the facility uses coatings that, based on their organic HAP content, individually meet the applicable emission limits and they use non-HAP thinners and other additives and cleaning materials, this compliance option is available. For this option, the US EPA have minimized recordkeeping and reporting requirements. The facility may demonstrate compliance by using manufacturer’s formulation data and readily available purchase records to determine the organic HAP content of each coating or other material and the amount of each material used. The facility does not need to perform any detailed emission rate calculations. If this information is not available, then the source can use results from US EPA test methods 311 or 24. They may also use alternative test methods provided they get prior approval.

Note that ‘‘no organic HAP’’ is not intended to mean absolute zero. Typical reporting levels only count organic HAP that are present at 0.1 percent or more by mass for OSHA-defined carcinogens and at 1.0 percent or more by mass for other compounds.

Option 2: Compliance based on the emission rate without add-on controls
This option is a pollution prevention option that allows the source to demonstrate compliance based on the organic HAP contained in the mix of coatings, thinners and/or other additives, and cleaning materials they use. This option offers the flexibility to use some individual coatings that do not, by themselves, meet the applicable emission limits. The facility can combine with low-HAP or non-HAP coatings so that overall emissions from the affected source over a 12-month period meet the emission limits. The facility must use this option if they use HAP containing thinners and/or other additives, and cleaning materials and do not have add-on controls.

The facility keeps track of the mass of organic HAP in each coating, thinner or other additive, and cleaning material, and the amount of each material used by the affected source each month of the compliance period. The facility uses this information to determine the total mass of organic HAP in all applicable materials divided by the total volume of coating solids used during the compliance period.

The facility may use readily available purchase records and manufacturer’s formulation data to determine the amount of each coating or other material used and the organic HAP in each material. The final rule contains equations that show how to perform the calculations to demonstrate compliance.

Option 3: Compliance based on using a capture system and add-on control device
This option allows sources to use a capture system and an add-on pollution control device, such as a combustion device or a recovery device, to meet the emission limits. According to the US EPA, fewer than 10 percent of the existing sources use control devices. Under this option, testing is required to demonstrate the capture system and control device efficiencies. The final rule provides equations to show how to use records of materials usage, organic HAP contents of each material, capture and control efficiencies, and coating solids content to calculate your emission rate during the compliance period. If the source demonstrates compliance based on this option, then they must show that their emission rate is less than the applicable emission limit.