Transcript NESHAP Title - Illinois Environmental Protection Agency

METAL CAN SURFACE
COATING MACT
COMPLIANCE ASSURANCE
40 CFR PART 63, SUBPART KKKK
June 2006
Compliance Timeline
IMPORTANT COMPLIANCE
INFORMATION SOURCE
http://www.epa.gov/ttn/atw/mcanpg/m
cantimeline.pdf
Compliance Dates
The final rule was published on November
13, 2003 , under 68 FR 64432
Compliance Dates
(cont’d.)
Existing major sources must comply with:
 Emissions limitations;
 Work practices standard;
 Operation & Maintenance requirement;
 Major source status determination;
Compliance Dates (cont’d.)
New affected sources operating on or
after January15, 2003 (63.3482e)
should have complied by November 13,
2003, or startup, whichever was later.
Existing sources must comply by
November 13, 2006.
Compliance Dates (cont’d.)
If the METAL CAN COATING FACILITY is
an area source, but becomes a major
source of HAP, compliance of [§
63.3483(e)(1)] is required upon
startup.
Compliance Dates (cont’d.)
The affected sources must meet the
notification and scheduling requirements
in [§ 63.3510(b)]. Some of these
notifications must be submitted before
the affected source compliance date.
Operations & Maintenance
Requirements (§63.6(1)-(2)
affected 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 KKKK.
O & M Requirements (cont’d.)
affected 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 KKKK.
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
(cont’d. on next slide)
O & M Requirements (cont’d.)
 Operating limits for each capture system
 Appropriate operating limit parameters
and design scope, i.e., control of
multiple emissions sources
O&M Requirements (cont’d.)
Preventative maintenance plan for each
control device including the
manufacturer’s recommended
maintenance instructions
SSM Plan
Requirements(§63.3500(c)
If the affected sources uses an emission
capture system and add-on control device
for compliance purposes with Subpart
KKKK, the source must develop and
implement a written startup, shutdown and
malfunction plan (SSMP);
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.
SSMP (cont’d.)
 The SSMP must also address any coating
operation equipment that may cause
increased emissions or that would affect
capture efficiency if the process
equipment malfunctions such as
conveyors that move parts among
enclosures.
General Compliance
Requirements (§63.3500)
The affected source must be in
compliance with the:
emissions limitations
Work practice standards
Operations and maintenance;
Startup, Shutdown and Malfunction Plan
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
affected source
Initial Compliance
Requirements (§63.3510)
Performance Test: A performance
test must be conducted no later
than 180 calendar days after the
compliance date specific to an
affected source using add-on
equipment.(§63.3483)
Initial Compliance (cont’d.)
Notification of Compliance Status; For each
work practice standard and operation and
maintenance requirement that applies to an
affected source where an initial performance
(cont’d on next slide)
Initial Compliance (cont’d.)
test is not demonstrated, the affected
source must demonstrate initial compliance
no later than 30 calendar days after the
specific compliance date for the affected
source.
Initial Compliance (cont’d.)
Notification of Intent to Conduct
Performance Test; In the General
Provisions [§63.9(e)]requiremnet if the
affected source is required to conducts
performance tests (e.g., those with add-on
equipment), the affected source must
submit a notification of intent to conduct a
performance test 60 days prior to the test.
Initial Compliance (cont’d.)
The affected source must install and
maintain a CPMS specified in
(§63.3547).
Test Methods
Subpart KKKK clearly defines the
test methods and other procedures
in §63.3521 & §63.3522 used to
demonstrate initial compliance
with the emissions limitations
Test Methods (cont’d.)
The procedures in Subpart KKKK are
used to establish operating limits for:
Each capture system
Each Solvent Recovery System
Each combustion device
Compliance with Work Practice
Standards

For any coating operation(s) for which a
compliant material option or emissions
rate without add-on controls option is
chosen, the source is not required to
meet any work practice standards.
(§63.3493)
Work Practice Standards
(cont’d.)

If an emission rate with add-on controls or
the control efficiency/outlet concentration
option is used to comply with the emission
limitations, the source must develop and
implement a written work practice plan to
minimize organic HAP emissions from the
storage, mixing, and conveying of coatings,
(cont’d on next slide)
Work Practice Standards
(cont’d.)

thinners and cleaning materials used in and
waste materials generated by the affected
surface coating operations
The affected source has submitted a written
Plan and will operate at all times according
to that plan.
REPORTS

Compliance reports are required by
specific due dates;
REPORTS (cont’d.)

Performance Test Report [(§63.3511(b)];
if the affected 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.
REPORTS (cont’d.)

SSM Reports [§63.3511(c)]; 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.
REPORTS (cont’d.)

Semiannual Compliance reports
[63.3511(e)}; After the initial
compliance period, each affected
source must submit semiannual
compliance reports.
Startup, Shutdown,
Malfunction Reports
[§63.3500(c)]

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.
Startup, Shutdown, Malfunction
Reports (cont’d.)

If actions were consistent with the SSM
Plan, the report must be submitted
during the required reporting period.
Records [§63.3512 &
63.3513]

An affected 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 affected source may choose.
Records (cont’d.)


An affected 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.
Title V Connect
Check Facilities that have Federally
Enforceable Limits
Limited number of Major Facilities;
who are they?
Title V Connect (cont’d.)
Section 112j, T5 connection (<>3
years) on T5 Permit
Section 112j is no longer factor on
surface coaters
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).
Title V Issues (cont’d.)
If an affected source submits a compliance
report required by Subpart KKKK 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 organic HAP
(cont’d. on next slide)
Title V Issues (cont’d.)
emissions limitation (including any operating
limit) or work practice requirement in
subpart KKKK, 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.
TITLE V Issues (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)
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
Section 70.6 (a)(3)(iii)(A) or Section
(cont’d. on next slide)
Title V Compliance Report
Example (cont’d.)
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)
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;
NSR/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.
Section 112j Implications
Most States allow the Initial
Notification requirements under
Subpart KKKK to be satisfied by the
Section 112j Notification.
Pollution Prevention
Options
Remove HAP organic COMPONENTS
from coating operation,
Reduce the development of waste
surface coatings, excess thinners and
surface coating repair items.