METAL COIL SURFACE MACT COMPLIANCE ASSURANCE

1. METAL COIL SURFACE MACT COMPLIANCE ASSURANCE 40 CFR PART 63, SUBPART SSSS May 2006

2. Compliance Timeline • IMPORTANT COMPLIANCE INFORMATION SOURCE http://www.epa.gov/ttn/atw/mcoil/mcoilpg.pdf

3. Compliance Dates • The final rule was published on June 10, 2002 , under 67 FR 39794 • Existing major sources must comply with: • Emissions limitations; • Operation & Maintenance requirement; • Major source status determination;

4. Compliance Dates (cont’d.) • New effected sources operating on or after July 18, 2002 (63.5130) should have complied by June 10, 2002 or startup, whichever was later. Existing sources must comply by June 10, 2005.

5. Compliance Dates (cont’d.) • If the METAL COIL COATING FACILITY is an area source, but becomes a major source of HAP, compliance of [§63.5130] is required upon startup.

6. Compliance Dates (cont’d.) • The effected sources must meet the notification and scheduling requirements in [§ 63.5180)]. Some of these notifications must be submitted before the effected source compliance date.

7. Compliance Options (§63.5170) 1)“AS PURCHASED” Compliant Material Option – Each coating the effected source uses during each 12-month compliance period must not exceed 0.046 kg HAP per liter solids, as purchased.

8. Compliance Options (§63.5170) • “AS APPLIED” Compliant Material Option- a)Each coating the source uses during each 12-month compliance period must not exceed 0.046 kg HAP per liter solids, as applied, determined monthly.

9. Compliance Options (Cont’d.) • “AS APPLIED” Compliant Material Option- (Cont’d.) • The rolling 12-month average of all coating materials must not exceed 0.046 kg HAP per liter solids determined monthly.

10. Compliance Options (cont’d.) • ADD-ON CONTROLS (OVERALL CONTROL EFFICIENCY) – • a) Each emission capture system and associated control device must reduce emissions by 98% (i.e., achieve an overall control efficiency of 98%)

11. Compliance Options (cont’d.) • ADD-ON CONTROLS (cont’d.) • b) The effected source may use a total enclosure (100% capture) and an oxidized to reduce organic HAP emissions to no more than a concentration of 20 parts ppm by volume on a dry basis at the outlet.

12. Compliance Options (cont’d.) • EMISSION RATE WITH ADD-ON CONTROLS- • The 12-month rolling average (determined monthly) of all coating materials used by the source, including the emission capture and control device efficiency, must not exceed 0.046 kg/liter solids, determined monthly.

13. Operations & Maintenance Requirements (§63.6(1)-(2) • Effected 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 SSSS.

14. Operations & Maintenance Requirements (Cont’d.) • Effected 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 SSSS.

15. O & M Requirements (cont’d.) • Each plan must contain the elements required in §63.6(e)(1)-(2) of the General Provisions. • Equipment monthly inspections • Operating limits for each capture system • Appropriate operating limit parameters and design scope, i.e., control of multiple emissions sources

16. O & M Requirements (cont’d.) • Preventative maintenance plan for each control device including the manufacturer’s recommended maintenance instructions

17. SSM Plan Requirements(§63.5180) • If the effected sources uses an emission capture system and add-on control device for compliance purposes with Subpart SSSS, the source must develop and implement a written startup, shutdown and malfunction plan (SSMP);

18. SSMP (cont’d.) • SSMP must meet provisions in §63.6(e)(3). • SSMP must address startup, shutdown and corrective actions in the event of a malfunction of the emissions capture system or the add-on device.

19. SSMP (cont’d.) • The SSMP must also address any coating operation equipment that may cause increased emissions or that would effect capture efficiency if the process equipment malfunctions such as conveyors that move parts among enclosures.

20. General Compliance Requirements (§63.5180) • The effected source must be in compliance with the: • emissions limitations • Operations and maintenance; • Startup, Shutdown and Malfunction Plan

21. 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 an effected source

22. Initial Compliance Requirements (§63.5180) • Performance Test: A performance test must be conducted no later than 180 calendar days after the compliance date specific to an effected source using add-on equipment.(§63.5170)

23. Initial Compliance (cont’d.) • Notification of Compliance Status; For each work practice standard & operation & maintenance requirement that applies to an effected source where an initial performance test is not demonstrated, the effected source must demonstrate initial compliance no later than 30 calendar days after the specific compliance date for the effected source.

24. Initial Compliance (cont’d.) • Notification of Intent to Conduct Performance Test; In the General Provisions [§63.9(e)]requiremnet if the effected source is required to conducts performance tests (e.g., those with add-on equipment), the effected source must submit a notification of intent to conduct a performance test 60 days prior to the test.

25. Initial Compliance (cont’d.) • The effected source must install and maintain a CPMS specified in (§63.5180).

26. Test Methods • Subpart SSSS clearly defines the test methods and other procedures in §63.5160, 5170 & §63.5180 used to demonstrate initial compliance with the emissions limitations

27. Test Methods (cont’d.) • The procedures in Subpart SSSS are used to establish operating limits for: • Each capture system • Each combustion device.

28. REPORTS • Compliance reports are required by specific due dates;

29. REPORTS (cont’d.) • Performance Test Report [(§63.5180]; if the effected source is required to conduct a performance tests (e.g., those with add-on control equipment), the source must submit a performance test report within 60 days after completion of the performance test.

30. REPORTS (cont’d.) • SSM Reports [§63.5180]; An SSM Report must be submitted immediately if there is an SSM of the control device during the reporting period that is not consistent with the SSM Plan. If actions taken were consistent with the SSM Plan, the report must be submitted semi-annually.

31. REPORTS (cont’d.) • Semiannual Compliance reports [63.5180]; After the initial compliance period, each effected source must submit semiannual compliance reports.

32. Startup, Shutdown, Malfunction Reports [§63.5180] • A Startup, Shutdown, Malfunction (SSM) report must be submitted immediately if there was a startup, shutdown, or malfunction of the control device during the reporting period that is not consistent with the SSM Plan.

33. Startup, Shutdown, Malfunction Reports (cont’d.) • If actions were consistent with the SSM Plan, the report must be submitted during the required reporting period.

34. Records [§63.5190] • An effected source is required to keep records of reported information and all other information necessary to document compliance with the rule for 5 years. There may be additional requirements depending on the compliance option that the effected source may choose.

35. Records (cont’d.) • An effected facility is required to keep records of reported information and all the other information necessary to document compliance with the final rule for 5 years • There may be additional requirements depending on the compliance option that is chosen.

36. Title V Connect • Check Facilities that have Federally Enforceable Limits • Limited number of Major Facilities; who are they?

37. Title V Connect (cont’d.) • Section 112j, T5 connection (<>3 years) on T5 Permit • Section 112j is no longer factor on surface coaters

38. Title V Issues • Each affected source that has obtained a title V operating permit required by 40 CFR part 70 or 71 must report all deviations as defined in the regulation for the semiannual monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A).

39. Title V Issues (cont’d.) • If an affected source submits a compliance report required by Subpart SSSS along with, or as part of, the semiannual monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), and the compliance report includes all required information concerning deviations from any (continued on next slide)

40. Title V Issues (cont’d.) organic HAP emissions limitation (including any operating limit) or work practice requirement in subpart SSSS, submission of the compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. In other words, no double jeopardy.

41. TITLE V (cont’d.) • However, submission of a compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permitting authority. (THIS IS VERY IMPORTANT)

42. Title V Compliance Report Example • For each affected source that is subject to permitting requirements required by 40 CFR part 70 or 71, and if the permitting authority has established dates for submitting semiannual reports required by Sec. 70.6 (a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), (continued on next slide)

43. Title V Compliance Report Example (cont’d.) you may submit the first and subsequent compliance reports according to the dates the permitting authority has established instead of according to the dates in paragraphs (b)(1) through (4) of this section. (NOTE WELL)

44. New Source Review/PSD Implications • NSR requires stationary sources of air pollution to apply for permits before they can construct/pre-construct/reconstruct. There are three types of NSR permit requirements: • PSD permits require for new major sources, or major modification to an existing source in attainment areas;

45. New Source Review/PSD Implications (cont’d.) • Non-attainment NSR permits for new or modifications to existing sources; • Minor source permits • These permits must be included in the Title V permit issued to an affected facility.

46. Section 112j Implications • Most States allow the Initial Notification requirements under Subpart SSSS to be satisfied by the Section 112j Notification.

47. Pollution Prevention Options • Remove HAP organic COMPONENTS from coating operation, • Reduce the development of waste surface coatings, excess thinners and surface coating repair items.