If you operate a plastic composites facility that manufactures products with thermoset resins and/or gel coats containing styrene, you may have to comply with requirements of the USEPA National Emission Standard for Hazardous Air Pollutants (NESHAP) issued in the spring of 2003. Most facilities will probably opt to avoid or “cap out” from these requirements by amending their air pollution control permit or obtaining a registration from the New York State Department of Environmental Conservation (DEC).

The Small Business Environmental Assistance Program (SBEAP) is here to help you understand and comply with these requirements through a free and confidential consulting service. The SBEAP, administered by the New York State Environmental Facilities Corporation (EFC) in Albany, is a non-regulatory technical assistance program established in 1992. EFC’s primary mission is to help small businesses understand and comply with State and federal air pollution control requirements. EFC has helped thousands of New York businesses over the years and looks forward to serving you.

Registrations and permits help DEC document the effectiveness of air pollution control programs and verify that businesses are meeting annual emission limits and/or control requirements. Both large and small businesses need a permit or registration before they construct or operate any equipment or processes that could cause air pollution.

Plastic composites production facilities would include the following processes:

• open & closed molding
• continuous lamination/casting
• SMC/BMC manufacturing
• centrifugal casting
• Pultrusion
• filament winding
• foam fabricating
• Mixing & storage
• Equipment cleaning

DEC air registrations/permits are based on a three tiered system:

1. Title V Permit:  A Title V Permit is required for major sources of Hazardous Air Pollutants (HAP) that cannot limit their annual HAP emissions below major source emissions thresholds. A major source is a facility that emits, or has the potential to emit ten tons or more per year of any single HAP or 25 tons or more per year of any combination of HAP.
2. State Facility Permit: This permitting option is available to those facilities with actual
   annual emission levels that are less than the major source thresholds for Title V Permits but are greater than the registration thresholds for minor facilities explained below.
   The permit will set limits to “cap” annual facility emissions thus allowing a company to avoid having to obtain a Title V permit and comply with the NESHAP requirements.
3. Minor Facility Registration: In lieu of a permit, registrations are an option for facilities whose actual annual emissions do not exceed five tons or more per year of any single HAP or 12.5 tons or more per year of any combination of HAP, enabling these facilities to avoid the NESHAP requirements.

SBEAP can help companies with all phases of the permit process including:

• Information gathering on process equipment, materials usage rates, preparing an emission inventory, identifying applicable air regulations and preparing a compliance plan.
• Discussing the routine operating schedule and future plans to build some operational flexibility into the application and permit to allow for future facility growth/change.
• Completing the appropriate application and continuing to assist the small business through the review process should requests for additional information be made by DEC.
• Assisting the firm with evaluating any draft permit conditions that DEC proposes and understanding permit issues.

For more information on registrations and permits, contact the SBEAP toll-free at 1-800-780-7227.