Synthetic
Chemicals
MACT
Compliance
Strategy
Issue
 
Family
of
Materials
 
From
the
Floor
Information
request:

 
The
term
 
product
process
line 
is
a
collection
of
equipment
used
to
manufacture
a
product.
If
a
facility
manufactures
multiple
grades
of
the
same
product
or
different
variations
of
the
products
(
i.
e.
blue,
black,
and
red
resins),
it
can
group
those
products
and
report
a
single
product
process
line
so
long
as
the
facility
can
justify
the
grouping
based
in
similarities
of
raw
materials,
or
chemistry 
 
Products
that
involve
different
HAPs
or
different
process
equipment
in
case
of
dedicated
processes
should
not
be
grouped
together 

 
From
the
Preamble
of
the
Draft
Regulation:

 
we
believe
that
the
production
of
chemicals
that
vary
only
slightly
in
molecular
structure,
functional
groups
or
other
characteristics,
and
are
produced
by
procedures
that
have
essentially
identical
emissions
sources
and
emission
stream
characteristics
should
be
considered
as
one
process 

 
From
the
Definition
Section
of
the
Draft
Regulation:

Family
of
materials
means
grouping
of
materials
with
the
same
basic
composition,

produced
using
the
same
basic
feedstocks,
but
that
may
vary
for
example
by
molecular
weight,
functional
group,
or
manufacturing
equipment
configuration.

Examples
of
families
of
materials
include,
but
are
not
limited
to,
alkyd
resins,

polyester
resins,
and
synthetic
fatty
acids.
Synthetic
Chemicals
MACT
Compliance
Strategy
Issue
 
Family
of
Materials
 
Method
for
breakdown
of
chemicals
based
on
functionality
Level
1
Imaging
Chemicals
Level
2
Couplers
Coupler
Intermediates
Dyes
Dye
Intermediates
Stabilizers
Stabilizer
Intermediates
Addenda
Addenda
Intermediates
Suspension
Polymers,
 
Level
3
Yellow
Couplers
Magenta
Couplers
Cyan
Couplers
Masking
Couplers
Level
4
Class
1
Class
2
Class
3
Class
4
Level
5
Image
Coupler
Image
Modifier
Synthetic
Chemicals
MACT
Compliance
Strategy
Issue
 
Process
Vent
Definition
 
From
the
definition
section
of
the
regulation:

 .
Process
vent
means
a
vent
from
a
unit
operation
or
vents
from
multiple
unit
operations
within
a
process
that
are
manifolded
together
into
a
common
header,

through
which
a
HAP
containing
gas
stream
is
or
has
the
potential
to
be,
released
to
the
atmosphere.
Examples
include
but
are
not
limited
to
vents
on
condensers
used
for
product
recovery,
reactors,
filters,
centrifuges,
and
process
tanks.

 .
Emissions
streams
that
are
undiluted
and
uncontrolled
containing
<
50
ppmv
HAP,

as
determined
through
process
knowledge .
Are
not
considered
process
vents
