METAL CAN SURFACE COATING MACT OVERVIEW

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

2. INTRODUCTION • On November 13, 2003, USEPA promulgated the Federal standard, METAL CAN SURFACE COATING NESHAP (National Emission Standards for Hazardous Air Pollutants) 40 CFR Part 63, Subpart KKKK in the Federal Register; 68 FR 64432.

3. What we are reviewing? • Rule applicability • NSR, NSPS & NESHAP focus • Covered operations • Operations not covered • Standards to be followed, including work practice standards

4. Review? (cont’d.) • Operating Limits • Important dates • Synthetic minor sources • New or existing source determination • General rule requirements

5. Review (cont’d.) • Initial compliance demonstration • Notification, Recordkeeping and Reporting requirements • Compliance options • Compliance examples

6. Review? (cont’d.) • Facility Inspection Protocol • Pre-Inspection Review • Facility File Review • Facility Inspection • Post-Inspection Meeting • Follow-up • Frequently asked questions.

7. TYPICAL FACILITY • Video:

8. APPLICABILITY: Who is covered by this rule? (Subpart KKKK, §63.3481) • Own or operate an AFFECTED SOURCE at a facility that is a major source, • Located at a major source, or

9. APPLICABILITY (cont’d.) • Part of a major source of hazardous air pollutants (HAPs), • The source uses 5,700 liters(1500 gal) or more of coating per year.

10. Affected Sources • All coating operations; • Coatings • Thinners • Cleaning materials storage containers

11. Affected Sources (cont’d.) • Mixing vessels • Manual and automated conveying equipment and containers

12. Affected Sources (cont’d.) • Manual and automated conveying equipment used for: • Waste material storage containers • surface coating metal cans (including decorative tins), or • metal crowns or closures

13. Affected Sources (cont’d.) • NSPS; COATING operations involve VOCs • NESHAP similar definition; • VOCs vs VOHAPs; similar criteria and an increase in stringency

14. Affected Sources (cont’d.) • Any new or reconstructed source (as defined in § 63.2) before January 15, 2003 is an existing facility and, • that is a major source and is a Metal Can Surface Coating facility

15. Affected Sources (cont’d.) • Any new or reconstructed source after January 15, 2003 is a new source.

16. What are Some Operations’ Emissions Impacted by Subpart KKKK? • Metal can surface coating includes, but is not limited to; • Any facility that coats metal cans or ends (including decorative tins), or

17. What are Some Operations’ Emissions Impacted by Subpart KKKK? (cont’d.) • Metal crowns or closures for any type of can during any stage of the can manufacturing process, and • Coating metal sheets for subsequent processing into metal cans or can parts

18. METAL CAN Operations Examples Subpart KKKK includes four subcategories: • One and two piece draw and iron (D&I) can body coating includes: • All coating processes involved in the manufacturing of can bodies by the D & I process (cont’d. on next slide)

19. Examples (cont’d.) • Includes the two- piece beverage cans • Two-piece food cans, and • One-piece aerosol can body coating

20. Examples (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.

21. Examples (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, side seam stripes

22. Examples (cont’d.) • On food cans, side seam stripes on general line and aerosol non-food cans.

23. Examples (cont’d.) • The end coating category includes: • The application of end seal compounds and repair spray coatings to metal can ends, • including aseptic and non-septic end seal compounds • Repair spray coatings

24. EXAMPLES (cont’d.) • USEPA Applicability Determination Index Site http://www.epa.gov/Compliance/planning/data/air/adi.htm

25. Who is not covered by Subpart KKKK? • The following sources are not covered under this rule; • Sources that only use coatings, thinners, and cleaning materials containing NO ORGANIC HAP;

26. Not covered sources (cont’d.) • Surface coating subject to any other NESHAP in Part 63; • Research or laboratory facilities; • Janitorial or building and facility maintenance operations;

27. Not Covered Sources (cont’d.) • Surface coating of metal coil that may be subsequently used in the manufacturing of cans; • Surface coating of metal pails, buckets and drums;

28. Not Covered Sources (cont’d.) • Coating application using hand-held non-refillable aerosol containers, touch-up markers, or marking pens.

29. Compliance with Work Practice Standards (63.3493) • If the source uses capture and control devices, the source must develop and operate according to a work practice plan.

30. Work Practice Standards (cont’d.) • The Plan should include actions to: • Cover mixing and storage vessels containing organic HAP-containing coating, thinners and cleaning materials except when • Adding, removing, or mixing contents.

31. Work Practice Standards (cont’d.) • Used closed containers or pipes to store and convey organic HAP-containing coatings, thinners and cleaning materials. • Minimize spills of organic HAP-containing coatings, thinners, cleaning materials, and waste materials.

32. Work Practice Standards (cont’d.) • Minimize organic HAP emissions during cleaning of storage, mixing, and conveying equipment.

33. What Standards Require Compliance? (63.3490) • Emissions Limitations are the site-specific parameter limits the source determines for the functional • Capture and control devices during the performance test.

34. What Standards Require Compliance? (cont’d.) • The operating limits must be monitored by a continuous parameter monitoring system (CPMS).

35. Important dates • The final rule was published on November 13, 2003, under 68 FR 64432, • Existing major sources (ON OR BEFORE 01/15/03) must comply with: • Emissions limitations;

36. Important dates (cont’d.) • Work practices standard; • Operation & Maintenance requirement; • Major source status determination; no later than, November 13, 2006.

37. Important Dates (cont’d.) • New affected sources operating after January 15, 2003, must comply with the regulatory requirements by November 13, 2003 or upon initial startup of the affected sources whichever is later.

38. Important Dates (cont’d.) • If the METAL CAN COATING FACILITY is an area source, but becomes a major source of HAP, compliance of § 63.3490 upon startup.

39. Important Dates (cont’d.) • The affected sources must meet the notification and scheduling requirements in § 63.3510. Some of these notifications must be submitted before the affected source compliance date.

40. Operations & Maintenance Requirements (§63.3493) • affected facilities must operate and maintain the sources, including air pollution control and monitoring equipment in a manner consistent with good air pollution practices that minimizes air emissions to the level required in Subpart KKKK.

41. O & M Requirements (cont’d.) • affected sources must prepare and operate at all times according to a written operation and maintenance plan for each capture and collection control device controlling emissions subject to Subpart KKKK.

42. O & M Requirements (cont’d.) • Each plan must contain the elements required in §63.3493

43. General Compliance Requirements (§63.3500) • The affected source must be in compliance with the: • emissions limitations • Work practice standards • Operations and maintenance;

44. General Compliance (cont’d.) • Maintain a log detailing the operation and maintenance of the process and emissions control equipment related to the initial performance test and the applicable operating limits for a affected source

45. General Compliance (cont’d.) • The source may comply with the emission limits by completing any of the following: • Compliant Material Option, • Each coating used must not exceed the HAP limit in Table 1;

46. General Compliance (cont’d.) • Determined each month for the sub-category during the 12-month compliance period; • Each thinner used must contain no organic HAP.

47. General Compliance (cont’d.) • Emissions 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.

48. General Compliance (cont’d.) • Emission Rate With Add-on Controls, • The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis;

49. General Compliance (cont’d.) • For coatings and thinners (including emission capture and control efficiency) • Must not exceed the HAP limits in Table 1.

50. General Compliance (cont’d.) • Control Efficiency/Outlet Concentration Option • HAP emissions must be reduced by an overall control efficiency of at least 97% • For new and reconstructed sources, and