Transcript NESHAP Title - Illinois Environmental Protection Agency

SUBPART N MACT
AMENDMENTS
QUESTIONS & ANSWERS
40 CFR PART 63, SUBPART N
Q/A
1. Does a facility have to comply with
the OSHA standard?
• OSHA had considered nonregulatory approaches, but feels
that rulemaking is a necessary step
to ensure that workers are
protected from the hazards of
hexavalent chromium. The U.S.
Court of Appeals has ordered OSHA
to move forward with a final rule.
Q/A
2. Are fume suppressants the only
means of emissions control on hard
chrome electroplating tanks?
•
USEPA has evaluated the results of
several emissions tests that
demonstrate the performance of
wetting agent fume suppressants in
controlling chromium emissions from
Subpart N effected sources. USEPA
concluded that surface tension is the
primary factor in determining chromium
emissions from electroplating baths.
Q/A
3. Would the Subpart N Amendment allow
existing add-on emissions controls to
be removed from Subpart N effected
sources?
• USEPA recognizes that under the Subpart
N final amendment, owners/operators of
hard chrome electroplating tanks that
choose to comply with the surface tension
limit could remove existing add-on
emission controls. In light of the pending
OSHA hexavalent chrome work place PEL
reduction, both approaches may be valid.
Q/A
4.
Are the wetting agent fume
suppressants equivalent to the add-on
control capability of controlling
chromium emissions from Subpart N
facilities?
•
USEPA has reviewed the available data on
the performance of wetting agent fume
suppressants and concluded the wetting
agent fume suppressants demonstrate
that control of chromium emissions
achieved by add-on controls is equivalent
to the level achieved by maintaining the
electroplating bath surface tension below
the limits specified in Subpart N.
Q/A
5. Should an effected source be required
to complete a performance test as
required for the use of add-on controls
in Subpart N?
• USEPA has concluded that Subpart N
facilities would not be required to conduct
performance tests under the Subpart N
amended requirements if the
owner/operators of effected sources
decided to comply with the surface tension
limits instead of the current add-on
emissions limits. An emissions test is not
required.
Q/A
6. Is the mass emissions limit determined
by calculations under §63.344 a
reasonable alternative to the emissions
concentration limit for enclosed hard
chrome electroplating tanks?
• USEPA concludes that the emissions rate
limit is a reasonable alternative to the
emissions concentration limit in the original
promulgated rule. Furthermore, USEPA
concluded that enclosing hoods increase
capture efficiency and provide an added
benefit by reducing worker exposure to
electroplating tank emissions.
Q/A
7. Why did USEPA increase the operating
limit for the pressure drop across a CMP
system from +/-1 in. w.c. to +/-2 in.
w.c.?
• USEPA became aware that the pressure
drop operating limit across a CMP often
exceeds the pressure drop operating limit
by more than +/-1 in. w.c. immediately
following the replacement or cleaning of
pads. Consequently, USEPA has increased
the allowable range of pressure drops from
+/-1 in. w.c. to +/-2 in. w.c.
Q/A
8.
How can an owner/operator establish
a new CPM operating limit?
•
The owner/operator can establish a new
operating limit for CPM pressure drop by
repeating the performance test. The
pressure drop across the CMP system
does not apply during automatic
washdown cycles of the CMP system.
Q/A
9. What must a facility do to
guarantee compliance with Subpart
N if the facility made any changes
due to the OSHA PEL requirement?
•
If approved, the facility must complete
performance tests and codify the
alternate in the operating permit.
Q/A
10. If a Subpart N source is located at a
Major source for HAPs, does the
Subpart N source require a Title V
permit?
•
An effected facility located at a Major
source must be included in the Title V
permit for the facility.
Q/A
11. Does a Subpart N facility have to comply
with the emission limitations during
periods of startup, shutdown and
malfunction?
• The effected facility must be in
compliance with the emissions limitations,
work practice standards, and operation
and maintenance requirements in Subpart
N at all times, EXCEPT during periods of
startup, shutdown and malfunction,
(i.e., during washdown cycles, startup
from washdown maintenance, etc.).
Q/A
12. Are the requirements for reporting
under Part 70, Title V fully covered in
Subpart N?
•
USEPA considered whether Title V would add
any significant compliance requirements to
those already required by NESHAP. After a
comparison of the compliance requirements of
the NESHAP to those of Title V, USEPA
concludes that they are substantially
equivalent. Historically, the NESHAP are
designed to stand alone with regard to
compliance requirements and reporting
compliance on a timely basis. USEPA has
therefore decided that taking all of the factors
together, Title V permitting would be
unnecessarily burdensome on area sources