Regulations, Violations, Permits, VOC, HAP and Such

A:  At the time of writing (November 2001) the Miscellaneous Metal Parts and Products (MMPP) MACT (or NESHAP) has not yet been promulgated, but if we assume that it will follow the same trends of existing MACT standards, then metal parts will only fall under the MMPP MACT if the facility is a major source for Hazardous Air Pollutants (HAP); namely 10 tpy of a single HAP or 25 tpy of a combination of HAPs.

If the facility is already subject to an existing MACT (or NESHAP) such as that for Aerospace, then by definition it is a major source for HAPs, and the facility will automatically be subject to the MMPP MACT when painting metal parts and products.   Similarly, if plastic parts and composites are being painted, these operations will fall under a future Plastic Parts (PP) MACT Standard.

If the facility is not a major source for HAPs then the question is moot.

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