METAL FURNITURE SURFACE COATING MACT QUESTION & ANSWERS 40 CFR PART 63, SUBPART RRRR July 2006

Questions/Answers #1 Frequently Asked Questions Q. If the facility builds a new building next to a current building, does the new building become a new source?

Q/A #1 A. The best source to answer these questions is the facilitys permitting authority because the decision may rest on site specific factors.

Q/A #2 Q. A facility uses gel coat that contains alpha- methyl styrene. Should the percentage of this chemical be added to the styrene content?

Q/A #2 A. No, alpha-methyl styrene is not a HAP. It is important to remember that the surface coating industry uses glycol ethers, that as a family is a HAP. However, USEPA has designated specific glycol ethers that are NOT HAPs.

Q/A #3 Q. For facilities that are complex or collated with different metal furniture surface coating operations, are any consolidation options available to compliance?

Q/A #3 A. Section 112(d)(2) requires that all major sources within a major source category must meet maximum emission reduction determined to be achievable. Therefore, due to the complexity of allowing such options, none are allowed in the rule, but c/c options can be used on a c/c operation basis. This is particularly true under the Title V process.

Q/A #4 Q. Does a metal furniture surface coating facility have to comply with the emission limitations during periods of startup, shutdown and malfunction?

Q/A #4 (A) A. USEPA concluded that this CAA provision is not appropriate for the surface coating NESHAP. When these short-term tests and monitoring results are only one component of a compliance determination that determines emissions over a long period of time. (Continued on next page)

#4 (Answer contd.) A. Which in this case is a month. For the metal furniture rule, the source owner will use the performance test and continuous monitoring results in combination with data on coatings and other materials used over a months period of time.

# 4 ( answer contd.) A. These components will be used to calculate a monthly organic HAP emission rate. There may be many startups and shutdowns of a coating operation over the course of a month as part of a normal operation.

# 4 ( answer contd.) A. It is not appropriate to exempt such periods from compliance with the standards. The month long period will accommodate potential short term higher emission rates that might occur due to SSM.

Q/A #5 Q. Does a Subpart RRRR affected facility have to comply with NSPS requirements?

Q/A #5 A. Since the NESHAP and NSPS regulations focus on different aspects of an affected facility: Organic HAP vs VOCs, Organic HAP vs VOCs, NS date of 11/28/80 vs NS NESHAP date of 04/24/02, NS date of 11/28/80 vs NS NESHAP date of 04/24/02, NSPS based on amount of solids applied vs NESHAP organic HAP solids used at facility) compliance must be achieved with both regulations. NSPS based on amount of solids applied vs NESHAP organic HAP solids used at facility) compliance must be achieved with both regulations.

Q/A #6 Q. If a facility coats some metal parts and some plastic parts, is the source subject to Subparts MMMM and PPPP?

Q/A #6 A. If the coating of such parts as knobs, hinges and screws takes place at a facility that coats these parts for multiple types of products, (e.g., not exclusively metal or plastic furniture) the coating operations would be subject to Subparts MMMM and PPPP.

Q/A #7 Q. How can a facility determine the mass of organic HAP in coatings, thinners and cleaning materials and the volume coating solids?

Q/A #7 A. A facility can determine the mass of organic-HAP values by: Either relying on manufacturers data, or Either relying on manufacturers data, or On results from the test methods provided in Subpart RRRR. On results from the test methods provided in Subpart RRRR. The rule requires the determination of the mass of organic HAP in coatings, thinners and cleaning materials and waste materials. The rule requires the determination of the mass of organic HAP in coatings, thinners and cleaning materials and waste materials.

Q/A #8 Q. Can a facility be considered in compliance with the Initial Notification requirement if the facility had filed their Section 112J notice on time?

Q/A #8 A. The Section 112J notice requires additional information above and beyond the Initial Notification requirement. As such, the facility would be considered in compliance with the Initial Notification (IN) requirement and filing the IN would be redundant.