METAL FURNITURE SURFACE COATING MACT COMPLIANCE ASSURANCE

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METAL FURNITURE SURFACE COATING MACT COMPLIANCE
ASSURANCE

• 40 CFR PART 63, SUBPART RRRR
• July 2006

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Compliance Dates

• Initial startup on or before April 24, 2002
  (determined by General Provisions requirement to
  decide new or existing sources using proposal
  date as cutoff date) the facility is an existing
  source and must comply by May 23, 2006

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Compliance Dates (Contd)

• Initial startup after April 24, 2002 the
  facility is a new source and must comply by May
  23, 2003 or the initial startup of the affected
  source whichever is later
• Non-compliance may result in fines and penalties
  of up to 25,000 per day per violation

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Compliance Calculations

• Compliance Option 1 The collected data for
  coatings, thinners, and cleaning materials are
  used to calculate the organic HAP content of each
  material used each month
• If supplier information is not available, Method
  24 is still the best choice to determine HAP
  content for calculating compliance status
• Compliance Options 2 3 An average monthly
  emission rate is calculated

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Sample Calculations

• This example of calculations required by Subpart
  RRRR, and frankly, similar Surface Coatings
  NESHAP is provided in this context for objective
  review. The regulatory and affected sources must
  work through the Initial to Continued compliance
  issues using the mandated calculations if
  appropriate for a particular facility.

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SAMPLE CALCULATION (contd)

• Initial Notification of Compliance Calculation
  (63.4951(e - g)
• H e A B C R w where
• H e Total Mass Organic HAP during compliance
  period
• A Total mass of Organic HAP coatings used

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SAMPLE CALCULATION (contd)

• B Total mass Organic HAP in thinners used
• C Total mass Organic HAP in cleaning materials
  used
• R w Total mass of Organic HAP in waste
  materials
• Calculate the mass of Organic HAP in the coatings
  used

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SAMPLE CALCULATION (contd)

• Similar calculations are repeated for thinners,
  cleaning materials and waste materials used in
  the compliance test period
• Average Organic HAP Emission Rate
• H avg He / V st
• H avg Organic HAP Emission Rate (kg/l) during
  compliance period

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SAMPLE CALCULATIONS (contd)

• He Total Mass Organic HAP during compliance
  period
• Vst Total volume of coating solids used during
  compliance period (l)
• The sample calculations contain similarity to
  other surface coating rules

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SAMPLE CALCULATIONS (contd.)

• However, regulatory personnel must establish
  clear understanding of Subpart RRRR (generally
  true for all Subparts) in order to maximize
  source T5 permitting clarity, facility inspection
  efficiency and finally a high level of affected
  facility compliance assurance.

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Initial Compliance Demonstration

• Initial Notification (63.4910)
• Initial Notification states that a facility is
  subject to the Metal Furniture Surface Coating
  Standards.
• Facility must submit the Initial Notification no
  later than May 23, 2004 for an existing source
  (issue Section 112j connection)
• September 30, 2003 or at startup, whichever is
  later for a new source

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Initial Compliance (contd.)

• Notification of Intent to Conduct a Performance
  Test 63.9 (e)
• If facility required to conduct performance tests
  (e.g., add-on control equipment), facility must
  submit a notification of intent to conduct a
  performance test 60 days prior to the test

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Initial Compliance (contd.)

• Performance test is required no later than May
  23, 2006 for existing sources
• New or reconstructed sources must conduct the
  performance test by November 19, 2003 or within
  180 days of startup, whichever is later

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Notification of Compliance Status 63.4910

• Facility must submit a Notification of Compliance
  Status (NOCS) by July 30, 2006 for an existing
  source
• For new sources, the NOCS must be submitted
  within 30 days after the end of the initial
  compliance period

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Performance Test Report 63.4920

• For facilities required to conduct performance
  tests (e.g., those with add-on control
  equipment), a performance test report must be
  submitted 60 days after completion of the
  performance test

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Startup, Shutdown, Malfunction Reports 634920

• Compare to Exceedance or Incident Reports for VOC
  issues.

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Reports 634920 (Contd.)

• 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.
• If actions were consistent with the SSM Plan, the
  report must be submitted semi-annually

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Semi-Annual Compliance Reports (63.4920)

• After the initial compliance period each affected
  source must submit semiannual compliance reports

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Compliance Options

• Compliance Material Option An affected facility
  may comply with the necessary emission limits
  using the following options
• Each coating a facility uses (either as
  pre-purchased or as-applied) must not exceed
  0.10 kg HAP per liter solids for existing
  sources, determined monthly.

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Options (Contd.)

• New sources with an approved emissions limit must
  emit no more than 0.094 kg HAP per liter solids
  determined monthly
• Each thinner and cleaning material must contain
  no organic HAP

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Options (contd.)

• Emission Rate Without Add-on Controls
• The monthly organic HAP emission rate for
  coatings (including adhesives), thinners, and
  cleaning materials must not exceed 0.10 kg HAP
  per liter solids for existing sources

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Options (contd.)

• 0.094 kg HAP per liter solids for new sources
  with approval for an alternative emission limit
• New sources without approval for an alternative
  emission limit must emit no organic HAP

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Options (contd.)

• Emission Rate With Add-on Controls
• The monthly organic HAP emission rate from
  coatings, thinners, and cleaning materials
  (including the emission capture and control
  efficiency) must not exceed 0.10 kg HAP per liter
  solids for existing sources

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Options (contd.)

• 0.094 kg HAP per liter solids for new sources
  with an approval for an alternative emission
  limit
• New sources without an approval for an
  alternative emission limit must emit no organic
  HAP

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TIMELINE
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Records 63.4930 and 63.4931

• An affected facility is required to keep records
  of reported information and all the other
  information necessary to document compliance with
  the proposed rule for 5 years
• There may be additional requirements depending on
  the compliance option that is chosen

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Title V Connect

• Check Facilities that have Federally Enforceable
  Limits
• Limited number of Major Facilities who are they?
• Section 112j, T5 connection (ltgt3 years on T5
  Permit
• Section 112j is no longer factor on surface
  coaters

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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).

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TITLE V (contd.)

• If an affected source submits a compliance report
  required by Subpart RRRR 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.

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TITLE V (contd.)

• concerning deviations from any organic HAP
  emissions limitation (including any operating
  limit) or work practice requirement in subpart
  RRRR, 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

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TITLE V (contd.)

• 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)

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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), 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)

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NESHAP Control Requirements

• Generally, speaking, if the affected source
  cannot meet the no HAP component requirement,
  or some use of compliant coatings to meet the
  facility compliance requirement, the facility
  must install add-on controls (i.e. Thermal
  Oxidation, Carbon Adsorber, Condenser), and
  operate and maintain according to supplier
  manuals.

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SSM PLANS

• Only facilities that use add-on control devices
  to comply with the standard must complete an SSM
  Plan
• Data Collection
• Supplier information on delivered/stored
  coatings, adhesives, thinners and cleaning
  materials

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Section 112j Implications

• States approach to Initial Notification
  requirements connection to Section 112j

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SURFACE COATING ALTERNATIVES

• Any option for surface coating needs?
• The facility can determine a compliant material
  option by demonstrating that the organic HAP
  content of each coating used in the coating
  operations is less than or equal to the
  applicable emission rate limit in 63.4890 and
  that each thinner and each cleaning material used
  contains no organic HAP.

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Compliance Examples

• Combination HAP/no-HAP organic solids
• Handling cleaning materials and production
  materials

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Pollution Prevention Options

• Remove HAP organic solids from formulation
• Application equipment design state-of-the-art
• Powder Coat Technology