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 
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. II-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 

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.gov/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/rpcpg.html. Small Business Ombudsman Office Contact Info: 

http://www.epa.gov/sbo/ 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

i

TABLE OF CONTENTS 

CHAPTER 1: INTRODUCTION....................................................................................................1 

 Why should I use this document? .......................................................................................1 

 Is there anything I should know before using this document?.............................................1 

 Where can I get additional help? .........................................................................................1 

 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 

CHAPTER 3: REQUIREMENTS MATRIX................................................................................10 

 What is the Requirements Matrix? ....................................................................................10 

 How do I use it? .................................................................................................................10 

 Requirements Matrix .........................................................................................................12

 
Reinforced Plastic Composites NESHAP 

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1

CHAPTER 1: 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/aces140.html. 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://www.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. 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

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EPA Regional Office Contact Information 

Address States Website/ 

Phone Number 

Region 1 

1 Congress Street 

Suite 1100 

Boston, MA 

 02114-2023 

CT, MA, ME, 

NH, RI, VT 

www.epa.gov/region1

(888) 372-7341 (Main) 

(617) 918-1656 (Air) 

Region 2 

290 Broadway 

New York, NY 

10007-1866 

NJ, NY, PR 

www.epa.gov/region2

(212) 637-3000 (Main) 

(212) 637-4080 (Air) 

Region 3 

1650 Arch Street 

Philadelphia, PA 

19103-2029 

DE, MD, PA, 

VA, WV, DC 

www.epa.gov/region3

(800) 438-2474 (Main) 

(215) 814-3297 (Main) 

(215) 814-5796 (Air) 

Region 4 

Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, GA 

30303-3104 

FL, NC, SC, KY, 

TN, GA, AL, MS 

www.epa.gov/region4 

(800) 241-1754 (Main) 

(404) 562-9063 (Air) 

Region 5 

77 W. Jackson Blvd 

Chicago, IL 60604 

IL, IN, MI, WI, 

MN, OH 

www.epa.gov/region5

(800) 621-8431 (Main) 

(312-886-3850 (Air) 

Region 6 

1445 Ross Avenue 

Suite 1200 

Dallas, TX 75202 

AR, LA, NM, 

OK, TX 

www.epa.gov/region6

(800) 887-6063* (Main) 

(214) 665-6444 (Air) 

Region 7 

901 N. 5th Street 

Kansas City, KS 66101 

IA, KS, MO, NE 

www.epa.gov/region7

(800) 223-0425 (Main) 

(913) 551-7122 (Air) 

Region 8 

999-18th St. Suite 300 

Denver, CO 

80202-2466 

CO, MT, ND, 

SD, UT, WY 

www.epa.gov/region8

(800) 227-8917* (Main) 

(303) 312-6312 (Air) 

Region 9 

75 Hawthorne St., 

San Francisco, CA 94105 

CA, AZ, HI, NV 

www.epa.gov/region9

(415) 947-8000 (Main) 

(415) 947-8715 (Air) 

Region 10 

1200 6th Avenue 

Seattle, WA 98101 

AK, ID, WA, OR 

www.epa.gov/region10

(800) 424-4372* (Main) 

(206) 553-1200 (Main) 

(206) 553-1814 (Air) 

* For sources within the region, only. 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

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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
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

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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, HAPcontaining 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 pollutants 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 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

5

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 www.epa.gov/ttn/atw/188polls.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).) 
Reinforced Plastic Composites NESHAP 

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What parts of my facility are subject to this rule? 

Covered Operations (See §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, 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

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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 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

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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 the 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 

Example 

Facility 1 

Example 

Facility 2 

Example 

Facility 3 

Example 

Facility 4 

Source meets 

§ 63.5785 

applicability 

criteria? 

Yes Yes Yes Yes 

Source subject to 

boat NESHAP? 

No Yes Yes Yes 

Are all RPC 

products used on 

site to make boats? 

(§ 63.5787(b)) 

 Yes No No 

Source elects to 

only meet boat 

NESHAP and can 

demonstrate no 

organic HAP 

increase? 

 No Yes 

Then the RPC 

NESHAP: 

Applies Does not apply Applies to 

operations 

making RPC 

parts not used 

on site to make 

fiberglass boats 

Does not apply 

Relevant Citation 

from RPC 

NESHAP 

§ 63.5787(a) § 63.5787(b) § 63.5787(c) § 63.5787(d) 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

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Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

10

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 

meet 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. 
Reinforced Plastic Composites NESHAP 

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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 
Reinforced Plastic Composites NESHAP 

Compliance Guide for Small Businesses 

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in the column for the RPC 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. 
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 

13

Table 1: Requirements by Type of Operatio

Category Requirement Open 

Molding 

Centrifugal 

Casting 

Continuous 

Lamination/ 

Casting 

Pultrusion SMC 

Manufacturing 

BMC 

Manufacturing 

C

Existing source w/ <100 tpy emitted from centrifugal casting & continuous lamination/casting combined 

5805(b) Table 3 (1)-(6) 

5805(a)(2) Table 3 (7)-(8) 

5805(a)(2) Table 3 (10) 

5805(b) Table 3 (9) 

Existing source w/ 100 tpy or more emitted from centrifugal casting & continuous lamination/casting combined 

5805(b) Table 3 (1)-(6) 

5805(a)(1) 5805(a)(1) 5805(b) 

Table 3 (9) 

New facility emitting <100 tpy HAP from combination of all open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC manufacturing, mixing, and BMC manufacturing 

5805(c) Table 3 (1)-(6) 

5805(c) Table 3 (7)-(8) 

5805(c) Table 3 (10) 

5805(c) Table 3 (9) 

Emission Limits 

New facility emitting 100 tpy or more HAP from combination of all open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC manufacturing, mixing, and BMC manufacturing 

5805(d) Table 5 (1)-(6) Large Parts: 5805(d)(2)(i)-(ii) Table 3 (1)-(6) 

5805(d) Table 5 (7)-(9) 

5805(d) 5805(d) 

Large Parts: 5805(d)(2) (i)-(ii) Table 3 (9) 

5805(d) Table 5 (9) 

5805(d) 

Options for Meeting Standards 

 5810 5810 5820 5830 

Calculations Data to collect 5865 
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 

14

Category Requirement Open 

Molding 

Centrifugal 

Casting 

Continuous 

Lamination/ 

Casting 

Pultrusion SMC 

Manufacturing 

BMC 

Manufacturing 

C

Determining HAP content of resins and gel coats 

5797 5797 5797 5797 5797 5797 5

Calculating percent reduction 

 Compliant 

line: 5885(a) Averaging: 5885(b) Combination: 5885(d) 

Calculating emission factor 

5796 Table 1(1) 

5796 Table 1(2) 

Compliant line:5890(a) Averaging: 5890(b) Combination: 5890(c) 

Calculating amount of resin and/or gel coat applied 

 5880 

Calculating facility tpy emissions 

5799 5799 5799 5799 5799 5799 5

Calculations for new application technology 

5798 5798 5798 5798 5798 5798 5

Emissions from wet-out area and oven 

 5870 

Determining capture efficiency 

 5875 

Work Practice Requirements 

Existing source w/ <100 tpy emitted from centrifugal casting & continuous lamination/casting combined 

 5805(a) 

Table 4 (9) 

5805(a) Table 4 (4)-(5) 

5805(a) Table 4 (6)-(8) 

5T
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 

15

Category Requirement Open 

Molding 

Centrifugal 

Casting 

Continuous 

Lamination/ 

Casting 

Pultrusion SMC 

Manufacturing 

BMC 

Manufacturing 

C

Existing source w/ 100 tpy or more emitted from centrifugal casting & continuous lamination/casting combined 

 5805(b) 

Table 4 (9) 

5805(b) Table 4 (4)-(5) 

5805(b) Table 4 (6)-(8) 

5T

New facility emitting <100 tpy HAP from combination of all open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC manufacturing, mixing, and BMC manufacturing 

 5805(c) 

Table 4 (9) 

5805(c) Table 4 (4)-(5) 

5805(c) Table 4 (6)-(8) 

5T

New facility emitting 100 tpy or more HAP from combination of all open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC manufacturing, mixing, and BMC manufacturing 

 5805(d) 

Table 4 (9) 

5805(d) Table 4 (4)-(5) 

5805(d) Table 4 (6)-(8) 

5T
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) 

16

Table 2: Requirements For All Operations 

Category Requirement All Operations 

Compliance Dates 5800, Table 2 

Comply with work practice standards and emission 

limits 

5835(a-b) 

General Compliance 

Requirements 

Startup, shutdown, malfunction 5835(c-d) 

Date for initial performance test or compliance 

demonstration 

5840, Table 2 

Demonstrating initial compliance 5860, Table 8, Table 9 

Date for subsequent performance tests 5845 

Conducting performance tests and evaluations 5850 

Testing & Initial 

Compliance 

Demonstration 

Monitor requirements 5855 

Continuous Compliance Monitoring and collecting data 5895 

Requirements Demonstrating continuous compliance 5900 

Existing Source 5905(a), Table 13 (1) 

New Sources 5905(a), Table 13 (2) 

Request for extension 5905(a), Table 13 (3) 

Using averaging option for compliance 5905(a), Table 13 (1) 

Complying using other provisions (not averaging) 5905(a), Table 13 (5) 

Using add-on control to comply 5905(a), Table 13 (6)(a-c) 

Notifications 

Changes to previous notifications 5905(b) 

What records must be kept 5915 

What form must records be in 5920(a),(d) 

Recordkeeping 

How long 5920(b),(c),(h),(i) 

Compliance Report 5910(a)-(e),(h), Table 14 

Exceedance of 100 tpy threshold 5910(f) 

Deviations 5910(a),(g), Table 14 

Reports 

Startup, shutdown, malfunction 5910(a),(h), Table 14 
Appendix A 

Reinforced Plastic Composites Production NESHAP 
United States 

Environmental Protection 

Agency 

Office of Air Quality Planning and Standards 

Air Quality Strategies & Standards Division 

Research Triangle Park, NC 

Publication No. 

EPA456/R-05-005 

September 2005