Extra Help for Question 26
Indicate whether there are any inherent constraints in your operation that restrict the amount of coating that can be applied each day. An inherent constraint must be a physical restriction that cannot be changed without physically modifying your process. For example, a spray booth that is also used as an oven can be considered an inherent constraint. The oven bake or cure time can be subtracted from the amount of time that coating can be applied. Only having enough operators to run one shift is NOT an inherent constraint. There is nothing physically limiting you from hiring more staff to run additional shifts. For more information on inherent constraints, see “Options for Limiting the Potential to Emit (PTE) of a Stationary Source Under Section 112 and Title V of the Clean Air Act (dated 1/25/95),” “Calculating Potential to Emit (PTE) and Other Guidance for Grain Handling Facilities (dated 11/14/95),” and “Clarification of Methodology for Calculating Potential to Emit (PTE) for Batch Chemical Production Operations (dated 8/29/96).” These documents are all available at: http://www.epa.gov/region07/programs/artd/air/title5/title5pg.htm. If you are unsure whether a limitation can be considered an inherent constraint, contact the Department at (302) 323-4542 or (302)739-9402.
