Transcript NESHAP Title - Illinois Environmental Protection Agency

METAL FURNITURE
SURFACE COATING MACT
OVERVIEW
40 CFR PART 63, SUBPART RRRR
July 2006
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.
What we are reviewing?
• Rule applicability
– NSPS & NESHAP focus
– Covered operations
– Operations not covered
• Standards to be followed, including
work practice standards
– Operating Limits
What we are reviewing?
(cont’d)
•Important dates
•Compliance sample calculations
•Synthetic minor sources
•New or existing source determination
•General rule requirements
What we are reviewing?
(cont’d)
• Initial compliance demonstration
• Notification, Recordkeeping and
Reporting requirements
• Compliance options
• Compliance examples
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
TYPICAL FACILITY
• Video Separate “touch” access
• I will reference the video in the
script
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
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
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
Affected Source (cont’d.)
– Components and products of the
types:
• Household,
• Office,
• Institutional,
• Laboratory,
• Hospital,
• Public building,
• Restaurant,
Affected Source (cont’d.)
• Barber Shop,
• Beauty Shop, and
• Dental furniture,
• Office and store fixtures,
• Partitions,
Affected Source (cont’d.)
•Shelving,
•Lockers,
•Lamps,
•Lighting fixtures, and
•Waste baskets.
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)
What are some coatings
impacted by Subpart RRRR?
(cont’d.)
– Caulks
– Inks
– Adhesives
– Maskants
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)
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
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
NON-Applicability (cont’d.)
• Coating applications using hand-held nonrefillable aerosol containers, touch-up
markers, or marking pens.
Coating Operations
Examples
1. Coatings operations at facilities
subject to wood furniture rule (40
CFR Part 63, Subpart JJ) would
continue to be subject to the rule.
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.
EXAMPLES (cont’d.)
2. 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.
EXAMPLES (cont’d.)
3. 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.
EXAMPLES (cont’d.)
4. 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
EXAMPLES #4 (cont’d.)
4. 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.
EXAMPLES (cont’d.)
5. The surface coating of this shelving
unit would be regulated under the
metal furniture rule.
(continued on next 2 slides)
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.
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.
EXAMPLES (cont’d.)
6. 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)
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)
EXAMPLES (cont’d.)
7. 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.
EXAMPLES (cont’d.)
8. USEPA Applicability
Determination Index Site
http://www.epa.gov/Compliance/
planning/data/air/adi.htm
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
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
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
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
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)
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.