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METAL COIL SURFACE COATING MACT FACILITY INSPECTIONS

This guide provides an overview of metal coil surface coating lines, their applicability, reasons for inspections, compliance standards, control systems, and pre/post-inspection procedures.

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METAL COIL SURFACE COATING MACT FACILITY INSPECTIONS

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  1. METAL COIL SURFACE COATING MACT FACILITY INSPECTIONS 40 CFR PART 63, SUBPART SSSS May, 2006

  2. An Affected Source is . . . The collection of all the metal coil coating lines at your facility. Coil Coating Lines are . . . The collection of equipment used to apply an organic coating to the surface of metal coil. Coating lines include web unwind or feed stations, wet section, coating application stations, curing oven, and quench station.

  3. Applicability (cont’d.) Metal Coil is . . . A continuous metal strip that is at least 0.15 mm (0.006 in) thick and is packaged in a roll or coil prior to coating, but does not include metal webs that are coated for use in flexible purchasing.

  4. Applicability (cont’d.) The collection of all coating operations; storage containers and mixing vessels used for coatings, thinners and/or other additives, cleaning materials and wastes; and manual and automated conveying equipment and containers used for coatings, thinners and/or other additives, cleaning materials and wastes.

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

  6. Inspections at Effected Sources Basically; determine how each facility is demonstrating compliance. Compliance demonstration can be with: • Emission rate w/add on controls • Operating limits (Cont’d. on next slide)

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

  8. What emission standards must an effected source follow? [§63.5120] • If you are an existing or new source, limit your organic HAP emissions to no more than . . . • Option 1…2% of the organic HAP applied during each month during the 12-month compliance period (98% reduction)

  9. What emission standards must an effected source follow? (Cont’d.) • Option 2…0.046 kg organic HAP/liter coating solids applied during each 12-month compliance period • Option 3…20 parts per million by volume on a dry basis when an oxidizer is used in combination with a capture system that achieves 100% capture

  10. Inspections at Affected Sources • Coating Lines • Storage handling (containers & Mixing Vessels) • Work Practices

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

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

  13. Typical Control Systems (Cont’d.) • Subpart SSSS 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.

  14. Pre-Inspection Procedures • File Review • MACT Initial Notification Report • Initial Compliance Status Report • Performance Test Report including capture

  15. Pre-Inspection Procedures (Cont’d.) • Continuing Compliance Report • Title V Reports • VOC/HAP reduction through NSPS/MACT implementation • Regulation Review • Equipment Checks

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

  17. Facility File Review (Cont’d.) • 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

  18. Pre-Inspection Meeting

  19. 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

  20. 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

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

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