Surface Coating of Wood building Products

7. How is initial compliance demonstrated and when must affected sources show initial compliance with emission limits?

Initial Compliance Demonstration

A facility may use the emission rate without add-on controls option for any individual coating operation, for any group of coating operations in the affected source, or for all the coating operations in the affected sources.  The facility must use either the compliant material option or the emission rate with add-on controls option for any operation within an affected source for which this option is not chosen.

Initial compliance demonstration for each option is as follows:

• For Option 1 (Compliance Material Option), a facility must determine the mass of organic HAP in all coatings, thinners and cleaning materials used and the volume fraction of coating solids in all coating used. They must then demonstrate that the organic HAP content of each coating used is less than or equal to the applicable emission limit and that each thinner and cleaning material used does not contain an organic HAP.
• For Option 2 (Emission Rate Without Add-On Controls Option), a facility must determine the mass of organic HAP in all coatings, thinners and cleaning materials used. They must then demonstrate that the rolling 12-month average organic HAP emission rate from the combination of all materials used is less than or equal to the applicable emission limit.
• For Option 3 (Emission Rate With Add-On Controls Option), a facility must determine the mass of organic HAP in all coatings, thinners and cleaning materials used and the volume fraction  of coating solids in all coatings used.  Then, using performance test data, they must determine the operating limits that will result in a capture and control efficiency that will reduce the organic HAP rate to less than or equal to the applicable emission limit.  It must be demonstrated  that the rolling 12-month average organic HAP emission rate from the combination of all materials used is less than or equal to the applicable emission limit.

Initial Compliance Demonstration Timeline

New or reconstructed affected sources must show initial compliance upon initial startup of the affected source or by May 38, 2003, whichever is later. Existing affected sources must show compliance with the final standards no later than May 29, 2006.