All facilities should make it a priority to monitor and reduce the hazardous air pollutants (HAPs) which are emitted by manufacturing. The National Emission Standards for Hazardous Air Pollutants govern HAP emissions during manufacturing. We will be discussing the changes to Subpart II for Surface Coatings of Automobiles and Light-Duty Trucks, focusing on how to demonstrate compliance with reference tables.

Who is subject to Subpart I of Part 63?

Part 63 Subpart IIII includes surface coating facilities for automobiles and light-duty trucks. This includes all facilities that coat new motor vehicle body panels, new motor vehicle body parts, or other parts intended for motor vehicles and aftermarket repair. The subpart requires that the facility is a major emitter located at or part of a major emitter of HAPs.

A major source of HAP emission is defined as a facility that emits or has the capacity to emit a single HAP or combination of HAPs with a rate greater than 9.07 Megagrams (Mg) (10 tons) per year.

This rule does not apply to you if:

• Your coating operation is at a molding facility for plastics
• The vehicles were not assembled in the same location.
• Your facility does not topcoat the entire body of any new car or light-duty vehicle.

Click on for the complete rule and exemptions.

Table 5: Changes to the 40 CFR Organic HAP List NESHAP

As of 2020, the OSHA list of carcinogens was used to classify chemicals. OSHA defines carcinogens as industrial agents capable of causing cancer. They are listed in Safety Data Sheets. Safety data sheets contain information on carcinogenicity to help manufacturers make the right decisions when using these products in their facilities.

In July 2020, the rule will be updated to include Table 5. This table contains a list of HAPs which must be included when calculating total organic HAPs if they are present at 0.1% by mass or higher. If present in 1% or greater by mass, all other organic HAPs not listed in Table 5 should also be included. You should no longer check for chemicals listed on the OSHA list of carcinogens but instead, refer to Table 5 in 40 CFR Part I Subpart I.

Table 5 , Part 63, Subpart I: List HAPs that Must be Counted towards Total Organic HAP content if present at 0.1 percent or more by mass.

Demonstrating compliance with the emission limits

You must comply with operation limits requirements for work practices and emissions limits. You must monitor your equipment constantly and reduce air pollution while maintaining a log detailing your maintenance and operation systems. In the compliance period, you should also add continuous parameter monitoring (CPMS) and control devices.

You must determine the mass-average organic HAP content and the amount of each material for every regulated material group that has a defined emissions limit. If each material is within the emission limit, you must document the materials’ name and organic HAP content. ERA’s software automates the calculations for all Table 5 blends and chemicals, as well as organic HAPs not listed in Table 5 if they are present at greater than 1% weight.

The mass fraction of organic HAP equals the ratio of organic material to total mass.

You can also rely upon the information provided by the supplier to determine HAP emissions if you do not use the EPA’s test methods or calculations. Check your SDS or EDS provided by your supplier to see if the paints and coatings you use contain any of the chemicals listed in Table 5 with a mass concentration of 0.1% or more or any other compounds that are 1.0% or more. If toluene is present in 0.5% mass and is not on the Table 5 list, then it shouldn’t be included.

You must then notify the EPA that your coating operations met emission limitations according to the Notification of Compliance Status Requirements . The EPA must receive a notification that the coating operation complied with the emission limits according to the Notification Status Requirements (40 CFR 63.3110).

Records and compliance reporting are essential

According to the EPA, you must keep records of compliance in a format that can be easily accessed by regulators. It could be electronic spreadsheets or databases. They must be submitted using EPA CEDRI. By maintaining them in electronic form, they are accessible for on-site evaluations.

You must submit NESHAP compliance reports every two years (June 30th to January 1st and July 1st until December 31st). Include any deviations to your stated limits if you have a Title V Operating Permit.

Note: This is not a substitute for the need to monitor and report to the EPA any deviations from your Title V permit. Include the variations in Title V as well as your semi-annual NESHAP reports.

MCL: A Short Description

ERA’s master chemical and regulatory list (MCL), which contains more than 200,000 chemical regulations, is regularly updated by ERA researchers. The MCL is the foundation of ERA software. Information on these chemicals is used for SDS authoring product certification and environmental reporting. ERA adds updated regulations. Below are the NESHAPs for September 2022.

Demonstrating compliance using NESHAP reporting software

ERA’s NESHAP- and MACT-reporting software performs all calculations necessary for NESHAP, including determining the mass average organic HAP contents for all of your chemical groups based on the density and volume used. The system allows you to access usage records and make reporting more straightforward. You can also check for any deviations in your Title V permit. The platform also documents the HAP contents for many chemicals. This reduces the amount of time it takes to investigate whether or not a product has HAPs. Schedule a call below to speak with a project consultant about this compliance solution.