Metal Can Surface Coating Facility Inspections: Compliance Guidelines

1. METAL CAN SURFACE COATING MACT FACILITY INSPECTIONS 40 CFR PART 63, SUBPART KKKK June, 2006

2. An Affected Source is . . . All coating operations; coatings, thinners, and cleaning materials storage containers; mixing vessels and manual and automated conveying equipment and containers; waste (continued on next slide)

3. material storage containers; and manual and automated conveying equipment containers used for surface coating metal cans (including decorative tins), or metal crowns or closures.

4. A facility is covered if you own or operate an affected source at a facility that is a major source, is located at a major source, or is part of a major source of hazardous air pollutants (HAP) and you use 5,700 liters (1,500 gal) or more of coating per year.

5. Applicability • Metal can surface coating includes but is not limited to. . . Any facility that coats metal cans or ends (including decorative tins) or metal crowns or closures for any type of can during any stage or the can manufacturing process and coating metal sheets for subsequent processing into metal cans or can parts. The source category includes four subcategories.

6. Applicability (cont’d.) • The one and two piece draw and iron (D&I) can body coating subcategory includes. . . All coating processes involved in the manufacture of can bodies by the D&I process including two-piece beverage cans, two-piece food cans and one-piece aerosol can body coating.

7. Applicability (cont’d.) • The sheet coating subcategory includes. . . All the flat metal sheet coating operations associated with the manufacture of three-piece cans, decorative tins, crowns, and closures.

8. Applicability (cont’d.) • The three-piece can body assembly coating subcategory includes. . . All coating processes involved in the assembly of three-piece metal can bodies, including inside spray-on food cans, aseptic and nonaseptic side seam stripes on food cans, side seam stripes on general line and aerosol nonfood cans.

9. Applicability (cont’d.) • The end coating subcategory includes. . . The application of end seal compounds and repair spray coatings to metal can ends including aseptic and nonaseptic end seal compounds, and repair spray coatings.

10. Compliance Options An affected Source may comply with your emission limits by doing any of the following: • Compliant Material Option - Each coating you use must not exceed the HAP limit in Table 1, determined each month for the subcategory during the 12-month compliance period. Each thinner used must contain no organic HAP.

11. Options (cont’d.) • Emission Rate Without Add-on Controls - The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis, for coatings and thinners must not exceed the HAP limits in Table 1.

12. Options (cont’d.) • Emission Rate With Add-On Controls - The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis, for coatings and thinners (including emission capture and control efficiency) must not exceed the HAP limits in Table 1.

13. Options (cont’d.) • Control Efficiency/Outlet Concentration Option - HAP emissions must be reduced by an overall control efficiency of at least 97 percent for new or reconstructed sources and 95 percent for existing sources or the outlet organic HAP concentration must be no greater than 20 parts per million by volume on a dry basis.

14. Reasons for Inspections • Compliance determination • Complaint Investigation • Source Plan Approval • Review or Renewal of Permits • Special Studies

15. Inspections at Affected Sources Basically; determine how each facility is demonstrating compliance. Compliance demonstration can be with: • Emission rate w/add on controls • Operating limits

16. Inspections at Affected Sources (cont’d.) • Work Practice Requirements • Emission Limits • Determination of Mass Fraction of organic HAP density volume used • Other

17. Inspections at Affected Sources (cont’d.) • Coating Lines • Storage handling (containers & Mixing Vessels) • Work Practices

18. Inspections at Affected Sources (cont’d.) • Material transport • Excess materials handling • General M/R

19. Typical Control Systems • Thermal Oxidizers • Carbon Adsorbers • Solvent Recovery • Emission Capture Systems

20. Typical Control Systems (Cont’d.) • Subpart KKKK requires specific data and compliance calculations for each of the above control systems. O & M plans for these systems are also required in the regulation.

21. Pre-Inspection Procedures • File Review • MACT Initial Notification Report • Initial Compliance Status Report • Performance Test Report including capture • Continuing Compliance Report (cont’d on next slide)

22. Pre-Inspection Procedures (Cont’d.) File Review (cont’d.) Title V Reports VOC/HAP reduction through NSPS/MACT implementation Regulation Review Equipment Checks

23. Facility File Review • Semiannual Compliance Reports • Control Equipment Removal Reports • Previous Inspection Reports • Enforcement Action • Complaints • Notice of Violations • Enforcement Actions taken

24. Facility File Review (cont’d.) • Variance history • Compliance test data • Equipment Malfunction reports • SSM Plan and any events • Permit to construct P/C and permit to operate P/O • Collection and control system design plan

25. Pre-Inspection Meeting

26. On-site Physical Inspection • Collection and control equipment • Comparison between source records and visual inspection • Observation of leaks and maintenance • Operation according to site specific collection system and design plan

27. Post-Inspection Meeting • Discuss any additional information needed from the owner/operator • Advise source representative of the facility specific requirements in the rules based on the type of compliance demonstration • Discuss any additional identified issues

28. Inspection/Documentation Report • Documentation of each determined violation • Recommendations for source testing/capture or engineering evaluation • Assessment of fugitive emissions and potential impacts