Transcript NESHAP Title - Illinois Environmental Protection Agency

METAL CAN SURFACE COATING
MACT QUESTION & ANSWERS
40 CFR PART 63, SUBPART KKKK
June, 2006
Questions/Answers
#1
 If the facility builds a new
building next to a current
building, does the new building
become a new source?
Q/A (cont’d.)
#1
 The best source to answer this
question is the facility’s permitting
authority because the decision
may rest on site-specific factors.
Q/A (cont’d.)
#2
Q. Does Subpart KKKK consider
post-coat repair spray for easy
open can ends?
Q/A (cont’d.)
#2
A. Using the coating data and
information provided by the affected
sources, USEPA have inserted a
separate emission limit for repair
spray coatings under the end
coating subcategory.
Q/A (cont’d.)
#3
Q. For facilities that are complex or
collated with different coating
operations, i.e. multiple surface
coating operations; chromium and
organic HAP coatings, are any
consolidation options available to
compliance?
Q/A (cont’d.)
#3
A. Section 112(d)(2) requires that all major
sources within a major source category
must meet maximum emission reduction
determined to be achievable. Therefore,
due to the complexity of allowing such
options, none are allowed in the rule, but
c/c options can be used on a c/c
operation basis. This is particularly true
under the Title V process.
Q/A (cont’d.)
#4
Q. Does a metal can coating facility
have to comply with the emission
limitations during periods of
startup, shutdown and malfunction?
Q/A (cont’d.)
#4
A. The affected facility must be in
compliance with the emissions
limitations, work practice standards,
and operation and maintenance
requirements in Subpart KKKK at all
times.
Q/A (cont’d.)
#5
Q. Does a Subpart KKKK affected
facility have to comply with NSPS
requirements?
Q/A (cont’d.)
#5
A. Since the NESHAP and NSPS
regulations focus on different
aspects of an affected facility,
organic VOCs, compliance must be
achieved with both regulations.
Q/A (cont’d.)
#6
Q. What are the installation,
operation and maintenance
requirements for the affected
source monitors?
Q/A (cont’d.)
#6
A. For each capture system that is
subject to Subpart KKKK, the
facility must install, operate, and
maintain each CPMS according to
the requirements in § 63.3492.
Q/A (cont’d.)
#7
Q. How does the facility demonstrate
continuous compliance with the work
practice standards that apply to the
affected source?
Q/A (cont’d.)
#7
A. The facility must maintain records that
document continuous compliance
noted in § 63.3493.
Q/A (cont’d.)
#8
Q. What are the Health affects
Associated with HAP Emissions From
the Surface Coating of Metal Cans?
Q/A (cont’d.)
#8
A. Ethylene glycol mono-butyl ether and
other glycol ethers, xylenes, hexane,
MEK and MIBK account for 95% of
the nationwide HAP emissions from
the source category. These HAPS are
associated with a variety of adverse
health affects (cont’d.)
Q/A (cont’d.)
#8
A. which include chronic health disorders
(e.g., birth defects and affects on the
central nervous system, liver, and
heart) and acute health disorders (e.g.,
irritation of the lung, skin, and mucous
membranes, affects on the central
nervous system and possibly cancer.
Q/A (cont’d.)
#9
Q. Can a facility be considered in
compliance with the Initial
Notification requirement if the
facility had filed their Section 112J
notice on time?
Q/A (cont’d.)
#9
A. The Section 112J notice requires
additional information above and
beyond the Initial Notification
requirement. As such, the facility
would be considered in compliance
with the IN requirement and filing
the Initial Notification would be
redundant.
Q/A (cont’d.)
#10
Q. What does a deviation from the
rule mean?
Q/A (cont’d.)
#10
A. Deviation means any instance in which
an affected source fails to meet any
obligations required by Subpart KKKK.
This is not limited to any emissions
limitation, work practice standard, or
operation and maintenance
requirement;
(continued on next slide)
Q/A (cont’d.)
#10
Answer Continued:
The affected source fails to
meet any terms or conditions
adopted to implement an
applicable under Subpart
KKKK.
Q/A (cont’d.)
#10
Answer Continued:
The affected source fails to
meet emissions limitations,
including operating limits or
work practice standards in this
Subpart.
Q/A (cont’d.)
#11
Q. If a failure to meet the emissions
limitation is permitted by Subpart
KKKK, is the affected source
exonerated from the non-compliant
condition?
Q/A (cont’d.)
#11
A. Failure to meet the emissions
limitation, including the operating
limits or work practice standards
during startup, shutdown or
malfunction is considered a deviation
and must be reported as an
exceedance under Subpart KKKK.
Q/A (cont’d.)
#12
Q. How flexible is Subpart KKK
regarding compliance with the
rule?
Q/A (cont’d.)
#12
 The affected source can choose
from several compliance options in
Subpart KKKK to achieve the
emission limit that applies to the
affected source.
Q/A (cont’d.)
#13
Q. Do the operating limits apply to
all affected source?
Q/A (cont’d.)
#13
A. If the affected source reduces
emissions by using a capture system
and add-on control device( other
than a solvent recovery system for
which a source conducts a liquidliquid material balance), the
operating limits apply to the source.
Q/A (cont’d.)
#14
Q. How does an affected source comply
with Subpart KKKK of the source
demonstrates compliance based on
the emissions rates without add-on
controls option?
Q/A (cont’d.)
#14
A. The source must determine the mass
of organic HAP in all coatings and
thinners used in each coating type
segment each month during the initial
compliance period, and the volume
fraction of coating solids in all coating
type segment used each month during
the initial compliance period.