METAL FURNITURE SURFACE COATING MACT OVERVIEW

1. METAL FURNITURE SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART RRRR July 2006

2. INTRODUCTION • On May 23, 2003, USEPA promulgated the Federal standard, Metal Furniture Surface Coating NESHAP (National Emission Standards for Hazardous Air Pollutants) 40 CFR Part 63, Subpart RRRR.

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

4. What we are reviewing?(cont’d) Important dates Compliance sample calculations Synthetic minor sources New or existing source determination General rule requirements

5. What we are reviewing?(cont’d) • Initial compliance demonstration • Notification, Recordkeeping and Reporting requirements • Compliance options • Compliance examples

6. What we are reviewing?(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 Separate “touch” access • I will reference the video in the script

8. APPLICABILITY: Who is covered by this rule?(Subpart RRRR, §63.4881) • Own or operate an AFFECTED SOURCE at a facility that is a major source, • Located at a major source, or • Part of a major source of hazardous air pollutants (HAPs). • NSPS for NEW sources of VOC

9. Affected Source • NSPS; Surface Coating operations involve applying a thin layer of coating to an object for decorative or protective purposes • NESHAP similar definition; stops here • VOCs vs HAPs; change in criteria and stringency

10. Affected Source (cont’d.) Any new or existing facility that is a major source and applies Coatings to a metal surface, Metal surface is, but not limited to: Components of furniture constructed either entirely or partially from metal

11. Affected Source (cont’d.) • Components and products of the types: • Household, • Office, • Institutional, • Laboratory, • Hospital, • Public building, • Restaurant,

12. Affected Source (cont’d.) • Barber Shop, • Beauty Shop, and • Dental furniture, • Office and store fixtures, • Partitions,

13. Affected Source (cont’d.) Shelving, Lockers, Lamps, Lighting fixtures, and Waste baskets.

14. What are some coatings impacted by Subpart RRRR? • Materials applied to a substrate for decorative, protective, or functional purposes, • These include, but are not limited to: • Paints • Sealants (continued on next slide)

15. What are some coatings impacted by Subpart RRRR? (cont’d.) • Caulks • Inks • Adhesives • Maskants

16. Applicability: Who is NOT covered by this Rule (§63.4881) • Sources that only use HAP FREE COATINGS, thinners, and cleaning materials • Surface coating metal components of wood furniture in an activity subject to the wood furniture MACT (40CFR 63, Subpart JJ)

17. Non-Applicability (cont’d.) Surface coating of small items (e.g., hinges, knobs, screws) that have a wider use beyond metal furniture and are not being coated at a metal furniture source Research or laboratory facilities or part of a janitorial or building and facility maintenance operations

18. NON-Applicability (cont’d.) • Surface coating for metal furniture for repair or maintenance and not for commerce, unless these activities alone constitute a major source • Sources that coat metal furniture performed on-site at installations owned by the Military, including the Coast Guard and the National Guard of any State

19. NON-Applicability (cont’d.) • Coating applications using hand-held non-refillable aerosol containers, touch-up markers, or marking pens.

20. Coating Operations Examples • Coatings operations at facilities subject to wood furniture rule (40 CFR Part 63, Subpart JJ) would continue to be subject to the rule.

21. Examples #1 (cont’d.) • This would be the case even if the items coated contained metal components as long as the items met the definition of wood furniture or wood furniture component in 63.801(a) of Subpart JJ.

22. EXAMPLES (cont’d.) • Coating operations at facilities that coat metal furniture as defined in the rule, constructed either entirely or partially from metal (but not qualifying as wood furniture components under Subpart JJ) would be subject to the metal furniture rule.

23. EXAMPLES (cont’d.) • Facilities that coat only metal furniture components such as knobs, hinges, and screws (that is, components that are of a more generic nature and could have broader uses in products other than metal furniture and provide these components exclusively to metal furniture mfg facilities, would be subject to the metal furniture rule.

24. EXAMPLES (cont’d.) • The applicability of the surface coating rules when the item coated is composed of both metal and wood components in approximately equivalent percentages will depend primarily upon the functionality of the entire unit. A common example

25. EXAMPLES #4 (cont’d.) • of such an item is a commercial shelving unit constructed of a metal base and wood backing. For reasons related to structural rigidity or overall stability, the functionality of this particular shelving unit depends more on the metal components than the wood components.

26. EXAMPLES (cont’d.) • The surface coating of this shelving unit would be regulated under the metal furniture rule. (continued on next 2 slides)

27. EXAMPLES #5 (cont’d.) • Thus the surface coating of all components of this shelving unit, regardless of whether they are made of metal or wood, would be regulated under the metal furniture rule, so long as the facility is a metal furniture facility.

28. EXAMPLES #5 (cont’d.) • This would be true even if the metal furniture mfg facility dedicated a coating line exclusively to the coating of wood components.

29. EXAMPLES (cont’d.) • Coating operations such as those presented in example 5 may not involve items that can be readily classified according to functionality. (continued on next slide)

30. EXAMPLES #6 (cont’d.) • For those situations, the applicability determination would be made on a c/c basis taking into account functionality and other relevant factors. • These factors may include primary NAICS code for the facility, amount of surface area coated for each type of substrate and how the coating operations have been classified for other surface coating rules (such as NSPS and State rules)

31. EXAMPLES (cont’d.) • A facility that is a new affected source is allowed to demonstrate on a c/c basis that organic HAP-free coating technologies cannot be used for their specific products. • If such a request is approved, the source would be required to meet an emissions limit of 0.094 kg organic HAP per liter coating solids used.

32. EXAMPLES (cont’d.) 8. USEPA Applicability Determination Index Site http://www.epa.gov/Compliance/planning/data/air/adi.htm

33. What Standards Require Compliance? (63.4890) • Existing Source: limit emissions to no more than 0.10 kg organic HAP per liter (0.83 #/gal) • New or reconstructed source; no emissions of organic HAP each month

34. What Standards Require Compliance? (Cont’d.) • New or reconstructed source and receive approval to use an alternative new source emission limit, emissions must be limited to no more than 0.094 kg organic HAP per liter of coatings solids used (0.78 lb/gal) each month

35. Work Practice Standards (63.4893) • Use capture and add-on control devices; • Develop and operate according to a work practice plan which should include: • Cover mixing and storage vessels containing organic HAP-containing coatings, thinners, cleaning materials, and waste materials except when adding, removing or mixing contents

36. Work Practice Standards (Cont’d.) • Use closed containers or pipes to store and convey organic HAP-containing coatings, thinners, cleaning materials, and waste materials • Minimize organic HAP emissions during cleaning of storage, mixing and conveying equipment

37. Operating Limits • The operating limits are the site-specific parameter limits the facility determines for the capture and control devices during the performance test. The facility operating limits must be monitored by a continuous parameter monitoring system (CPMs)

38. Important dates • The final rule was published on May 23, 2003 , under 68 FR28606, • Existing major sources must comply by, May 23, 2006, • Operating new major sources should have complied by April 24, 2002, or startup, whichever was later, • New major sources under construction must comply at startup.