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Title V would mean that he needed a "major source" permit, because he either emitted or had the "potential to emit" 10 tons per year of any HAP (hazardous air pollutant)(10 tons per year is a mojor source of HAPs). Hexane, like most of the rest of the HAPS on the HAP list, is a HAP because the CAAA of 1990 says it is, not because of any inherent danger to the environment (There is no inherent equivalency regarding the health hazard or hazard to the environment among HAPs).

Nonetheless, it is a HAP (Because the EPA gave Congress the list, and Congress unquestioningly put it into the CAAA of 1990, and President Bush signed the law. Now the EPA falls back on the "Congress created the HAP list, not us" fiction as they crucify industries under Title V and Title III).

Potential to emit (PTE) is calculated by the EPA, persuming an operating scenario of 24/7/365, at the worst possible operating secnario (in McNabb's case, he would thoretically be manufacturing the one part that caused him to use the greatest amount of the solvent conceivable in any one hour, times 24 times 7 times 365.

Now, if he had that PTE of 10 tons, but didn't ever or didn't conceive that he ever would, operate in a manner to achieve the 10 tons per year, then he had to petition the state to grant him a "Synthetic Minor" source permit. In this permit, he would presume legally enforcable limitations on his operation (hours of operation, throughput of materials, product mix, etc. Thue "synthetically" creating a legally enforceable set of restrictions to ensure he would never be a "major source" of HAPS) that would hold him below the 10 ton threshold.

But he would have had to have establish himself as a synthetic minor source prior to the deadline for Major Sources to have filed for their Title V permits. Because with a PTE of 10 tons he needed a Title V permit, unless he had already proven to the state (Fed EPA) that he really didn't need one in the first place.

Confused?

So were and are the states and so are all of the regulated sources.

And you have a bunch of people who have never made anything in their lives running around telling industries just what they are doing wrong, and giving then magically simple sounding solutions that have no practicality in the real world.

Just like the "He could possibly find a roof coating mfg and give it away to be incorporated into the coating." comment. What self respecting businessman could conceive of incorporating an raw material that has dubious origins, virtually unknowable constituent makeup and uncertain availability into their product.

It sounds like a utopianly simplistic solution but it lacks somewhat in realistic grounding in an ISO 9002 kind of world.