456R05005
Compliance Guide for Small Businesses
to the
Reinforced Plastic Composites Production
NESHAP
40 CFR 63, Subpart WWWW
United States Environmental Protection Agency
Office of Air Quality Planning and Standards
Information Transfer and Program Integration Division
Program Implementation Review Group
Research Triangle Park, NC 27711
E:?A
456
R-
05-
005
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EPA-456/R-05-005
September 2005
Compliance Guide for Small Businesses
to the
Reinforced Plastic Composites Production
NESHAP
40 CFR 63, Subpart WWWW
Prepared for:
U.S. Environmental Protection Agency
Prepared by:
MACTEC FEDERAL PROGRAMS, INC.
5001 S. Miami Blvd., Suite 300
PO Box 12077
Research Triangle Park, NC 27709-2077
(919) 941-0333, FAX (919) 941-0234
EPA Contract No. 68D01077
Work Assignment No. 11-6
PES Project No. 805703N863.006
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Information Transfer and Program Integration Division
Program Implementation Review Group
Research Triangle Park, NC 27711
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Compliance Guide for Small Businesses
to the
Reinforced Plastic Composites Production
NESHAP
40 CFR 63, Subpart WWWW
EPA Publication Number: EPA-456/R-05-005
September 2005
NOTICE
THIS DOCUMENT IS NOT INTENDED, NOR CAN IT BE RELIED UPON, TO CREATE ANY RIGHTS
ENFORCEABLE BY ANY PARTY IN LITIGATION WITH THE UNITED STATES. The statements in this
document are intended solely as guidance to small businesses to aid you in complying with the National
Emissions Standards for Hazardous Air Pollutants (NESHAP): Reinforced Plastic Composites Production
Rule (40 CFR Part 63; OAR-2003-0003; FRL-7957-7, RIN 2060-AM233, signed on August 16, 2005).
The final rule (as amended) and other supporting documents are available online at:
http: //www. epa. go v/ttn/atw/rpc/rpcpg .html.
While the guidance contained in this document may assist you in applying regulatory requirements, the
guidance is not a substitute for those legal requirements, nor is it a regulation itself. Thus it does not
impose any legally-binding requirements on any party, including EPA, States, or the regulated
community. In any civil or administrative action against a small business, small government or small
nonprofit organization for a violation of the National Emissions Standards for Hazardous Air Pollutants
(NESHAP) for Reinforced Plastic Composites Production Rule, the content of this guide may be
considered in determining the reasonableness or appropriateness of proposed fines, penalties or
damages. EPA may decide to revise this guide without public notice to reflect changes in EPA's
approach to implementing the Revised National Emissions Standards for Hazardous Air Pollutants
(NESHAP) for Reinforced Plastic Composites Production Rule or to clarify and update text. To determine
whether EPA has revised this guide and/or obtain copies, please check the following website:
http://www.epa.gov/ttn/atw/rpc/rpcpq.html. Small Business Ombudsman Office Contact Info:
http://www.epa.gov/sbo/
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
TABLE OF CONTENTS
CHAPTER 1: INTRODUCTION I
Why should I use this document? 1
Is there anything I should know before using this document? I
Where can I get additional help? I
Where do I get additional copies of this document? 3
CHAPTER 2: WHAT THIS RULE COVERS - AN OVERVIEW 4
Why was this rule developed? 4
How do I know if I am subject to this rule? 4
Are there any facility exemptions? 5
What parts of my plant are subject to this rule? 5
What if I also manufacture boats or parts that are used in boats?. 7
What if I do not use any reinforcements in my operations? ..9
Am I a new source or existing source? 9
CHAPTERS: REQUIREMENTS MATRIX 10
What is the Requirements Matrix? 10
How do I use it? 10
Requirements Matrix 12
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
CHAPTER!: INTRODUCTION
Why should I use this document?
You should use this guide to 1) determine if the Reinforced Plastic Composites NESHAP
applies to your facility, and 2) to understand the requirements of the rule if it does apply to your
facility. Chapter 2 of this document addresses primarily those aspects of the rule that will help
you determine if the rule applies to your facility. Chapter 3 of this document has a table that
shows you where to find specific requirements in the rule. This table is the "Requirements
Matrix."
Is there anything I should know before using this document?
First, when using this guide, remember that it does not replace the final rule. If there
seems to be a discrepancy between the rule and this guide, the rule has final say. Second, this
guide only covers requirements published on April 21, 2003, and the rule amendments published
in August/September of 2005. If the rule is revised after the date of this report, the revisions are
not incorporated in this document; therefore, you should keep up with any revisions, by
periodically checking the Federal Register and the Code of Federal Regulations (CFR). You
can download Federal Register notices by going to the Government Printing Office (GPO)
website at www.access.gpo.gov/su docs/aces/aces 140.htm 1. You can download an electronic
copy of the rule at the electronic code of Federal regulation website: http://ecfr.gpoaccess.gov/.
Where can I get additional help?
You can get additional help from EPA's Reinforced Plastic Composites Production web
site: http://vvw\v.epa.gov/ttn/atw/rpc/rpcpg.html. You can also contact your regional EPA air
toxics office for additional help. The table on the following page lists the contact information for
each of EPA's regional offices.
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
EPA Regional Office Contact Information
Address
States
Website/
Phone Number
Region 1
1 Congress Street
Suite 1100
Boston, MA
02114-2023
Region 2
290 Broadway
New York, NY
10007-1866
Region 3
1650 Arch Street
Philadelphia, PA
19103-2029
Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA
30303-3104
Region 5
77 W. Jackson Blvd
Chicago, II 60604
Region 6
1445 Ross Avenue
Suite 1200
Dallas, IX 75202
Region 7
901 N. 5lh Street
Kansas City, KS 66101
Region 8
999-18th St. Suite 300
Denver, CO
80202-2466
Region 9
75 Hawthorne St,
San Francisco, CA 94105
Region 10
1200 6th Avenue
Seattle, WA 98101
CT, MA, ME,
NH, RI.VT
NJ, NY, PR
DE, MD, PA,
VA, WV, DC
FL, NC, SC, KY,
TN, GA, AL, MS
IL, IN, Ml. Wl,
MN, OH
AR, LA, NM,
OK, TX
IA, KS, MO, NE
CO, MT, ND,
SD, UT, WY
CA, AZ, HI, NV
AK, ID, WA, OR
* For sources within the region, only
www. epa. qov/reqion 1
(888) 372-7341 (Main)
(617) 918-1656 (Air)
www.epa.gov/reqion2
(212) 637-3000 (Main)
(212) 637-4080 (Air)
www.epa.gov/region3
(800) 438-2474 (Main)
(215) 814-3297 (Main)
(215) 814-5796 (Air)
www epa.gov/region4
(800) 241-1754 (Main)
(404) 562-9063 (Air)
www.epa.gov/region5
(800)621-8431 (Main)
(312-886-3850 (Air)
www.epa.gov/region6
(800) 887-6063* (Main)
(214) 665-6444 (Air)
www.epa.gov/reoiDn7
(800) 223-0425 (Main)
(913) 551-7122 (Air)
www.epa.gov/region8
(800) 227-8917" (Main)
(303) 312-6312 (Air)
www,epa gov/region9
(415) 947-8000 (Main)
(415) 947-8715 (Air)
www.epa.gQv/region10
(800) 424-4372* (Main)
(206) 553-1200 (Main)
(206) 553-1814 (Air)
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
Where do I get additional copies of this document?
You can get copies of this document from EPA's Air Toxics Website, Rule and
Implementation Information for Reinforced Plastic Composites Production:
http://www.epa.gov/ttn/atw/rpc/rpcpg.html
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
CHAPTER 2; WHAT THIS RULE COVERS - AN OVERVIEW
Why was this rule developed?
This rule was developed to comply with the requirements of section 112(d) of the Clean
Air Act, which requires EPA to develop Hazardous Air Pollutant (HAP) emission standards
reflecting Maximum Achievable Control Technology (MACT) for major sources in this and
other source categories. This MACT standard protects the public health by reducing emissions
of HAP from reinforced plastic composite production facilities. Facilities subject to this rule
emit a variety of HAP, including styrene, methyl methacrylate, and methylene chloride. These
HAP have adverse health effects including headache, fatigue, depression, and irritation of skin.
eyes, and mucous membranes. Methylene chloride has been classified as a probable carcinogen.
EPA estimates that this NESHAP will reduce nationwide emissions of HAP by 7,682 tons per
year. The final rule was published on April 21, 2003. A revision is scheduled to be published in
the August/September 2005 time frame that make clarification to rule requirements and correct
come minor errors in Table 3.
How do I know if I am subject to this rule?
You are subject to this rule if you own or operate a reinforced plastic composites
production facility that is located at a major source of HAP emissions.
For purposes of this NESHAP, reinforced plastic composites production is limited to
operations in which reinforced or non-reinforced plastic composites or plastic molding
compounds are manufactured using thermoset resins and/or gel coats that contain styrene to
produce plastic composites. The rule also applies to several operations that are ancillary to
reinforced plastic composites production. These operations are cleaning, mixing, HAP-
containing materials storage, and repair operations associated with the production of plastic
composites. (See §63.5785(a).)
You are a major source if you emit or have the potential to emit (considering controls)
10 tons per year or more of any single HAP or 25 tons per year or more of any combination of
HAP. The pollutanls to be considered for purposes of determining whether you are a major
source are those pollutants identified as HAP in the Clean Air Act. Some states have their own
lists of HAP or similarly designated air pollutants. Those state lists are not used to determine if
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
your source is a major source and are not the basis for this rule. You can find the list of HAP
on EPA's website at wwu .epa.gov/ttn/atw/188poiIs.html.
For determining your potential to emit, you must consider the maximum emissions
from your facility if it operates at full capacity. Emission reductions achieved through
emission controls must be included in the determination of potential to emit. Federally
enforceable limits or restrictions must also be considered. To illustrate, consider "Facility A,"
a major source with a federally enforceable permit requirement that limits annual operation to
6,000 hours. The potential to emit for Facility A would be calculated based on the emission
potential if the facility operates at maximum capacity for 6,000 hours per year only. On the
other hand, if a similar facility, "Facility B," chooses to operate only 6,000 hours due to
product market conditions but does not have a federally enforceable limit on operating hours,
Facility B must calculate potential to emit based on operation at full capacity for 8,760 hours
per year, even though the facility is not currently operating for that many hours.
Are there any facility exemptions?
Yes, there are three exemptions.
You are not subject to this subpart if your facility only repairs reinforced plastic
composites (including boat parts). Repair is defined in the rule as follows: "application of
resin or gel coat to a part to correct a defect, where the resin or gel coat application occurs after
the part has gone through all the steps of its typical production process, or the application
occurs outside the normal production area." The definition also states that "for purposes of this
subpart, rerouting a part back through the normal production line, or part of the normal
production line, is not considered repair." Note that operations to repair reinforced plastic
composite parts that were produced at your facility are not covered by this exemption and are
subject to this rule. (See §63.5785(b) and §63.5935.)
You are not subject to this rule if your facility is a research and development facility as
defined in section 112(c)(7) of the Clean Air Act. (See §63.5785(c).)
You are also not subject to this rule if all of your reinforced plastic composites
operations use less than 1.2 tons per year (tpy) of thermoset resins and gel coats that contain
styrene combined. (See §63.5785(d).)
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
What parts of my facility are subject to this rule?
Covered Operations (xSec §63.5790(c).)
This rule applies to each new or existing affected source at reinforced plastic composites
production facilities. The affected source consists of all parts of your facility engaged in the
following operations:
" Open molding
Closed molding
Centrifugal casting
Continuous lamination
» Continuous casting
Polymer casting
Pultrusion
Sheet molding compound (SMC) manufacturing
Bulk molding compound (BMC) manufacturing
Mixing
Cleaning of equipment used in reinforced plastic composites manufacture
HAP-containing materials storage
Repair on parts you also manufacture
Operations with no requirements (See §63.5790(c).)
The following operations are specifically excluded from any requirements in the rule:
" Application of mold sealing and release agents
Mold stripping and cleaning
Repair of parts that you did not manufacture, including non-routine
manufacturing of parts
» Personal activities that are not part of the manufacturing operations
" Pre-preg materials (defined as reinforcing fabric received precoated with resin
which is usually cured through the addition of heat)
Non-gel coat surface coatings
» Repair or production materials that do not contain resin or gel coat
Research and development operations as defined in section 112(c)(7) of the Clean
Air Act
Application of filler putties, polyputties, and adhesives.
Military Specification Resins
Production resins that must meet military specifications are allowed to meet the organic
HAP limit contained in the specification (rather than meeting the limits in this rule), but certain
requirements must be met to use this exemption. You must supply specifications certified by the
military procurement officer that state a requirement for a specific resin or specific HAP content.
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
and you must keep a record of the resins for which you use this exemption. Production resins for
which the exemption is used must be applied with nonatomizing equipment unless you can
demonstrate that such application is infeasible. (See §63.5790(d).)
What if I also manufacture boats or parts that are used in boats?
There is a NESHAP for Boat Manufacturing (40 CFR Subpart VVVV) that is similar to
this rule for reinforced plastic composites production. If you manufacture boats or parts that are
used in boats, you need to understand the applicability criteria of that rule as it relates to the
Reinforced Plastic Composites rule. The Boat Manufacturing NESHAP applies to boat
manufacturing facilities that are located at a major source of HAP. A boat manufacturing facility
is a facility that manufactures hulls or decks of boats from fiberglass or aluminum, or assembles
boats from premanufactured hulls and decks, or builds molds to make fiberglass hulls or decks.
A facility that manufactures only parts for boats (such as hatches, seats, or lockers) or boat
trailers is not considered a boat manufacturing facility for purposes of the Boat Manufacturing
NESHAP. (See §63.5683 for the full applicability criteria for the Boat Manufacturing NESHAP.)
If your source does not meet the applicability criteria of the Boat Manufacturing
NESHAP, but your source does meet the applicability criteria of the Reinforced Plastic
Composites NESHAP (see §63.5785), then you are subject to the Reinforced Plastic Composites
NESHAP regardless of the final use of the parts you manufacture. (See §63.5787(a).)
If you are subject to the Boat Manufacturing NESHAP and all of the reinforced plastic
composites you manufacture are used in manufacturing your boats, then you are not subject to
the Reinforced Plastic Composites NESHAP. (See §63.5787(b).)
If you are subject to the applicability criteria of the Reinforced Plastic Composites
NESHAP (see §63.5785) and you are subject to the Boat Manufacturing NESHAP and you
produce reinforced plastic composites that are not used in fiberglass boat manufacture at your
facility, then the operations associated with manufacturing the reinforced plastic composites that
are not used in manufacturing boats at your facility are subject to the Reinforced Plastic
Composites NESHAP. (See §63.5787(c).) If your facility is subject to both the Boat
Manufacturing NESHAP and the Reinforced Plastic Composites NESHAP, you can choose to
comply with the Boat Manufacturing NESHAP for your reinforced plastic composites operations
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
if you can demonstrate that doing so will not increase emissions compared to complying with the
Reinforced Plastic Composites NESHAP for those operations.
The table below presents examples of combinations of operations that might exist at a
single facility and i.he rule(s) to which the facility would be subject. The table is not intended to
be an exhaustive list of possible combinations of operations; it is simply a list of examples to
help illustrate how the two different NESHAP apply.
Boat Manufacturing vs. Reinforced Plastic Composite (RPC)
Applicability Based on Operation Type
Considerations
Source meets
§ 63.5785
applicability
criteria?
Source subject to
boat NESHAP?
Are all RPC
products used on
site to make boats?
(§ 63.5787(b))
Source elects to
only meet boat
NESHAP and can
demonstrate no
organic HAP
increase?
Then the RPC
NESHAP:
Relevant Citation
from RPC
NESHAP
Example
Facility 1
Yes
No
Applies
§ 63.5787(a)
Example
Facility 2
Yes
Yes
Yes
Does not apply
§ 63.5787(b)
Example
Facility 3
Yes
Yes
No
No
Applies to
operations
making RPC
parts not used
on site to make
fiberglass boats
§ 63.5787(c)
Example
Facility 4
Yes
Yes
No
Yes
Does not apply
§ 63.5787(d)
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
What if I do not use any reinforcements in my operations?
Not using reinforcements does not exclude you from this rule. As stated in §63.5785,
"reinforced plastic composites production is limited to operations in which reinforced and/or
nonreinforced plastic composites or plastic molding compounds are manufactured using
thermoset resins and/or gel coats that contain styrene to produce plastic composites." If you
meel these applicability criteria, you are subject to this rule even if you do not use
reinforcements in any reinforced plastic composites operation.
Am I a new source or existing source?
You need to know if your source is a new source or an existing source because new
sources are subject to more stringent requirements and different compliance dates than existing
sources. Your source is a new source if construction of the affected source began after August 2,
2001, and no other reinforced plastic composites production affected source existed at the site
when construction began. If your source does not meet the criterion for being a new source, then
your source is an existing source. Note that an area source that existed prior to August 2, 2001,
and subsequently becomes a major source is considered an existing source.
10
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
CHAPTER 3; REQUIREMENTS MATRIX
What is the Requirements Matrix?
The Requirements Matrix is a set of two tables that tells you where in the rule to find
information that is relevant to your facility in the rule. Table 1 addresses the rule requirements
that are specific to each type of operation. Table 2 lists the requirements that are the same for all
operations. Both tables are organized with the type of requirement (e.g., notification
requirements, emission limits) in rows and the type of operation (e.g., open molding, centrifugal
casting) in columns. Each cell lists the section(s) and/or table(s) in the rule where you will find
the specific type of requirement for each operation.
How do I use it?
Before using the matrix, you may wish to browse the tables to familiarize yourself with
the requirement categories and types of operations. Table 1, which lists specific requirements for
each type of operation, is broken down into the following main requirement categories, with each
category broken down further into specific items:
Emission Limits
Options for Meeting Standards
Calculations
Work Practice Requirements
Table 2, which lists requirements that are the same for all operations, is broken down into
the following main requirement categories, with each category broken down further into specific
items:
General Compliance Requirements
Testing & Initial Compliance Demonstration
Continuous Compliance Requirements
Notifications
Recordkeeping
Reports
To use the matrix, identify the type of information you are seeking based on the above
list of categories. Find the appropriate table; then find the row(s) in the table corresponding to
the information you need. Once you have found the correct row, read across that row to the cell
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Reinforced Plastic Composites NESHAP
Compliance Guide for Small Businesses
in the column for the RFC operation(s) at your facility. The information in each cell will direct
you to the specific section(s) and/or table(s) of the rule covering the requirement. You should
then read that section of the rule to identify the requirement. The text of the rule is included in
Appendix A.
Some cells will refer to more than one section of the rule if the requirement is addressed
in multiple sections of the rule. For example, there are many instances where a requirement is
addressed in a text section of the rule and some of the specifics of that requirement are addressed
in a table. In this situation, the cell in the matrix will direct you to both the text section of the
rule and the table that includes the detail of the requirements.
Note that all citations and tables listed in the matrix refer to 40 CFR 63 Subpart
WWWW. So, for example, "5905(a)" in the matrix is 40 CFR 63.5905 (a), also designated as
§63.5905(a), and "Table 1" is the first table at the back of Subpart WWWW. Where a table
number is followed by another number in parenthesis, that means the table includes a list of
items, and only the number in parenthesis is relevant. For example, if a cell directs you to Table
13(2), that means the relevant requirement is the second item in the list of items in Table 13 of
40 CFR 63 Subpart WWWW.
Consider this example: if you have an existing source that emits less than 100 tpy from
continuous casting and continuous lamination/casting combined, and you want to know the
emission limit for centrifugal casting operations at your facility, go to Table 1 and look in the
first column for the "Emission Limits" section, then move to the next column to find the row for
"Existing source w/ <100 tpy emitted from continuous casting & continuous lamination/casting
combined" and then follow the row until you get to the Centrifugal Casting column. The cell
directs you to 5805(a), which will be §63.5805(a) in the rule, and Table 3 (7)-(8), which refers to
items (7) and (8) in Table 3 at the end of the rule.
Consider a second example: if you have a pultrusion operation and want to know the
how long you need to maintain records, go to Table 2 and look in the first column for the
"Recordkeeping" section, then move to the next column to find the row for "How Long" and
then follow the row until you get to the Pultrusion column. The cell directs you to 5920(b)(c),
which will be §63.5920(b) and §63.5920(c) in the rule.
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Reinforced Plastic Composites NESHAP
REQUIREMENTS MATRIX
40 CFR 63.5780-63.5935
(All subparts and tables listed in this matrix are in 40 CFR 63 Sub part WWWW)
Table 1 : Requirements by Ty
Category
Emission Limits
Options for
Meeting Standards
Calculations
Requirement
Kxistmg source w/ MOO
[py emitted from
centrifugal casting &
continuous
lamination/ casting
combined
Existing source w/ 100 tpy
or more emitted from
centrifugal casting &
continuous
lamination/casting
combined
New facility emitting
- 100 tpy HAP from
combination of all open
molding, centrifugal
casting, continuous
lamination/casting,
pultmsion, SMC
manufacturing, mixing.
and BMC manufacturing
New facility emitting 100
tpy or more 1 IAP from
combination of all open
molding, centrifugal
casnng. continuous
lamination/casting,
pultmsion. SMC
manufacturing, mixing.
and BMC manufacturing
Data to collect
Open
Molding
5805(b)
Table Ml V
(o)
5805i)
Table 3(1)-
(6)
5810
Centrifugal
Casting
5805
Large Parts
5805(dM3>
d)-(ii)
Table 3 (9)
5830
SMC
Manufact-
uring
5805
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Reinforced Plastic Composites NESHAP
REQUIREMENTS MATRIX
40 CFR 63.5780-63.5935
(All subparts and tables listed in this matrix are in 40 CFR 63 Subpart WWWW)
Category
Work Practice
Requirements
Requirement
Determining HAP content
of resins and gel coats
Calculating percent
reduction
Calculating emission
factor
Calculating amount of
resm and or gel coat
applied
Calculating facility tpy
emissions
Calculations for new
application technology
Emissions from wet-out
area and oven
Determining capture
efficiency
Existing .source w/ < 1 00
tpy emitted from
centrifugal casting &
continuous
lamination, caslin);
combined
Open
Molding
5797
5796
Table 1(1)
5799
5798
Centrifugal
Casting
5797
5796
!ablc!(2)
5799
5798
Continuous
Lamination/
Castine
5797
Compliant
line 5885(a)
Averaging
5885(b)
Combination.
5885(d)
Compliant
line 5890(a)
Averaging
5890(b)
Combination
5890(c)
5880
5799
5798
5870
5875
Pullrusion
5797
5799
5798
5805(a)
Table 4 (9)
SMC
Manufact-
uring
5797
5799
5798
5805(a)
Table 4 (4)-
(5)
BMC
Manufact-
uring
5797
5->99
5798
58()5(a)
Table 4(6)-
(«>
f 'nm r»Tessi'jR
/ Injection
molding
5797
5799
5798
5 8051 a)
Table 4(1)
Clcatiiiig
5797
5799
5798
5805(a)
Table 4 (2)
Material
Storage
5797
5799
5798
5805U)
Table 4 (3)
Mining
5797
5799
5798
5805(a)
fable 4 (6V
<*)
Polymer
Casting
5797
5799
5798
Repair
Operations
5797
5799
5798
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Reinforced Plastic Composites NESHAP
REQUIREMENTS MATRIX
40 CFR 63.5780-63.5935
(All subparts and tables listed in this matrix are in 40 CFR 63 Subpart WWWW)
Category
Requirement
Enisling source w/ 100 Ipy
or more emitted from
centrifugal casting &
continuous
lamination/casting
combined
New facility emitting
<100 tpy HAP from
combination of all open
molding, centrifugal
casting, continuous
lamination/casting,
pultrusion. SMC
manufacturing, mixing,
and BMC manufacturing
New facility emitting 100
tpy or more HAP from
combination of all open
molding, centrifugal
casting, continuous
lamination/casting.
pultnjMon, SMC
manufacturing, mixing.
and BMC manufacturing
Open
Molding
Centrifugal
Casting
Continuous
Lamination/
Casting
Pultrusion
5g05(b)
Table 4 (9)
5805(c)
fable 4 (9)
5805(d)
Table 4 (9>
SMC
Manufact-
uring
5g05(b)
Table 4 (4)-
(51
5805{c)
Table 4 (4)-
(5>
5805(d)
Table 4 (4)-
(5)
BMC
Manufact-
uring
5»05(b)
Table 4 (6>-
(8)
5805
Table 4 (6)-
(8)
5805(d)
Table 4 {6>-
(8)
Compression
I Injection
molding
5805{b)
Table4(l)
5S05(c)
Table 4(1)
5805(d)
Table 4 {1}
Cleaning
5X0 5(b)
Table 4 (2)
5805{c)
Table 4 (2)
S805(d)
Table 4 (2)
Material
Storage
580<
Table 4 (3)
5805(d)
Table 4 (3)
Miving
5805(b)
Table 4(6 H
(8)
58(1 5(c)
Table 4 (6>-
(8)
5S05(d)
Table 4(6)-
(8)
Polymer
Casting
Repair
Operations
15
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DRAFT 9/30/04
Reinforced Plastic Composites NESHAP
REQUIREMENTS MATRIX
40 CFR 63.5780-63.5935
(All subparts and tables listed in this matrix are in 40 CFR 63 Subpart WWWW)
Table 2: Requirements For All Operations
Category
General Compliance
Requirements
Testing & Initial
Compliance
Demonstration
Continuous Compliance
Requirements
Notifications
Record keeping
Reports
Requirement
Compliance Dates
Comply with work practice standards and emission
limits
Startup, shutdown, malfunction
Date for initial performance test or compliance
demonstration
Demonstrating initial compliance
Date for subsequent performance tests
Conducting performance tests and evaluations
Monitor requirements
Monitoring and collecting data
Demonstrating continuous compliance
Existing Source
New Sources
Request for extension
Using averaging option for compliance
Complying using other provisions (not averaging)
Using add-on control to comply
Changes to previous notifications
What records must be kept
What form must records be in
I low long
Compliance Report
Excecdance of 100 tpy threshold
Deviations
Startup, shutdown, malfunction
All Operations
5800, Table 2
5835(a-b)
5835(c-d)
5840. Table 2
5860, Table 8, Table 9
5845
5850
5855
5895
5900
5905(a), Table 13(1)
5905(a),Tablel3(2)
5905(a).Tablel3(3)
5905(a), Table 13(1)
5905(a),Tablel3(5)
5905(a), Table I3(6)(a-c)
5905(b)
5915
5920(a),(d)
5920(b),(c),(h),(i)
591 0(a)-(e),(h). Table 14
5910(0
5910(a).(g). Table 14
5910(a).(h),Tablel4
16
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Appendix A
Reinforced Plastic Composites Production NESHAP
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United States Office of Air Quality Planning and Standards Publication No.
Environmental Protection Air Quality Strategies & Standards Division EPA456/R-05-OQ5
Agency Research Triangle Park, NC
September 2005
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