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May 10, 2002 Applicability Update

May 10, 2002 Applicability Update. Miscellaneous Metal Parts and Products (Surface Coating) NESHAP 40 CFR 63 Subpart MMMM. Introduction. Scope Applicability Exclusions Approach and Format Draft Emission Limits Compliance Options Schedule Additional Information Definitions.

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May 10, 2002 Applicability Update

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  1. May 10, 2002Applicability Update Miscellaneous Metal Parts and Products (Surface Coating) NESHAP 40 CFR 63 Subpart MMMM teal.kim@epa.gov

  2. Introduction • Scope • Applicability • Exclusions • Approach and Format • Draft Emission Limits • Compliance Options • Schedule • Additional Information • Definitions teal.kim@epa.gov

  3. Scope--Applicability • Title V major source of HAP based on all facility operations • Engage in surface coating of metal parts or products not specifically covered by another NESHAP • Use 250 gallons coating material/year teal.kim@epa.gov

  4. Scope--Exclusions • Area Sources • Sources using no-HAP material • Surface coating subject to other NESHAP • Extrusion of plastic onto wire or cable • Research or laboratory facilities • Janitorial, building, and facility maintenance operations • Hobby shops • Handheld non-refillable aerosol containers teal.kim@epa.gov

  5. Approach and Format • 3 Subcategories • General Use Subcategory • General Use Coatings • High Performance Coatings • Magnet Wire Subcategory • Rubber-to-Metal Subcategory • Average of all materials used in coating-related operations • Mass organic HAP/Volume coating solids • Annual average calculated on a rolling monthly basis teal.kim@epa.gov 4

  6. Draft Emission LimitsExisting Sources DRAFT PRELIMINARY PRE-DECISIONAL teal.kim@epa.gov

  7. Draft Emission LimitsNew Sources DRAFT PRELIMINARY PRE-DECISIONAL teal.kim@epa.gov

  8. Compliance Options • Compliant Material • Compliant Coatings • Non-HAP thinners, other additives, and cleaning material • Emission Rate without Add-on Control • HAP/Solids  Emission Limit • Emission Rate with Add-on Control • Post-control HAP/Solids  Emission Limit teal.kim@epa.gov

  9. Schedule • Summer 2002 • Administrator Signature • Federal Register publication • Public comment period • Public hearing, if requested. • Summer 2003 • Promulgation of Final Rule in Federal Register teal.kim@epa.gov

  10. Additional Information • Status Reports & Notifications • Email teal.kim@epa.gov with request to be added to Subpart MMMM stakeholder list • Subpart MMMM web page • www.epa.gov/ttn/atw/coat/misc/misc_met.html • Air and Radiation Docket and Information Center (6102), Attention Docket Number A-97-34, U.S. EPA, 1200 Pennsylvania Avenue, NW, Washington, DC 20460 teal.kim@epa.gov

  11. Definitions • Coating—decorative, protective, or functional material; including, but not limited to, paints, sealants, caulks, inks, adhesives, and maskants. Materials that consist only of protective oils for metal, acids, bases, or any combination of these are not considered coatings • Coating solids--nonvolatile portion of the coating that makes up the dry film. teal.kim@epa.gov

  12. Definitions (continued) • Facility maintenance--routine repair and renovation of tools, equipment, machinery, and structures comprising the infrastructure of the facility and that are necessary for the facility to function in its intended capacity. • High Performance Architectural Coating--coatings applied to architectural subsections which are required to meet the specifications of Architectural Aluminum Manufacturer’s Association’s publication number AAMA 605.2-1980. teal.kim@epa.gov

  13. Definitions (continued) • High Performance Coating--includes “high performance architectural coating,” “high temperature coating,” or “military combat, tactical, and munitions coating” • High Temperature Coating--coating which, during normal use, must withstand temperatures of at least 538C (1000 F). teal.kim@epa.gov

  14. Definitions (continued) • Hobby Shop--surface coating operation, located at an affected source, that is used exclusively for personal, noncommercial purposes by the affected source’s employees or assigned personnel. • Magnet Wire Coating--coating applied to wire to be used in the fabrication of electrical devices such as motors or generators. teal.kim@epa.gov

  15. Definitions (continued) • Military Combat, Tactical, and Munitions Coating--materials that, singularly or in combination, provide military-unique performance and/or battlefield survival capabilities. This includes all components that have been military-qualified, or are compatible with military-qualified components, as providing military-unique performance and battlefield survival capabilities • Protective Oil—organic material applied to metal providing lubrication or protection from corrosion without forming a solid film including lubricating, evaporative, and extrusion oils. teal.kim@epa.gov

  16. Definitions (continued) • Research or laboratory facility--primary purpose is for research and development of new processes and products, conducted under close supervision of technically trained personnel, and not engaged in manufacture of final or intermediate products for commercial purposes, except in a deminimis manner • Rubber to Metal Coating--coatings applied to a metal substrate providing necessary adhesion for a rubber component to be bonded to the substrate. teal.kim@epa.gov

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