Transcript NESHAP Title - Illinois Environmental Protection Agency

METAL COIL SURFACE
COATING MACT
OVERVIEW
40 CFR PART 63, SUBPART SSSS
May 2006
INTRODUCTION

On June 02, 2002, USEPA promulgated
the Federal standard, METAL COIL
SURFACE COATING NESHAP (National
Emission Standards for Hazardous Air
Pollutants) 40 CFR Part 63, Subpart SSSS
in the Federal Register; 67 FR 39794.
What we are reviewing?
 Rule
applicability
 NSR,NSPS
& NESHAP focus
 Covered operations
 Operations not covered
Review (Cont’d.)
Standards to be followed, including work
practice standards
 Operating Limits
 Important dates
 Synthetic minor sources

Review (cont’d.)
New or existing source determination
General rule requirements
Initial compliance demonstration
Notification, Recordkeeping and Reporting
requirements
 Compliance options
 Compliance examples




Review (cont’d.)
Facility Inspection Protocol
 Pre-Inspection Review
 Facility File Review
 Facility Inspection
 Post-Inspection Meeting
 Follow-up
 Frequently asked questions

APPLICABILITY: Who is covered by
this rule? (Subpart SSSS, §63.5090)
Own or operate an EFFECTED 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

Effected Source
 All
coating operations;
 Web unwind or feed stations
 Wet section
 Coating application stations
 Curing ovens & Quench station
Effected Source (cont’d.)
 NSPS;
COATING operations involve
VOCs
 NESHAP similar definition;
 VOCs vs VOHAPs; similar criteria
and an increase in stringency
Effected Source (cont’d.)
Any new or reconstructed source (as
defined in § 63.2) before July 18, 2000 is
an existing facility and,
 that is a major source and is a Metal
Coil Surface Coating facility
 Any new or reconstructed source after
July 18, 2000 is a new source.

What are Some Operations’
Emissions Impacted by
Subpart SSSS?
 An effected source is the collection of all
the metal coil coating lines at the source.
 Coil coating lines are the collection of
equipment used to apply an organic
coating to the surface of a metal coil.
What are Some Operations’
Emissions Impacted by
Subpart SSSS (Cont’d.)?

Coating lines include web unwind or
feed stations, wet section, coating
application stations, curing ovens, and
quench station.
What are Some Operations’
Emissions Impacted by
Subpart SSSS (Cont’d.)?

A metal coil is a continuous metal strip
that is at least 0.15 mm(0.006 in) thick
and is packaged in a roll or coil prior to
coating, but does not include metal
webs that are coated for use in flexible
packaging.
METAL COIL Operations
Examples (cont’d.)
 USEPA Applicability
Determination Index Site
http://www.epa.gov/Compliance/planning/
data/air/adi.htm
Who is not covered by
Subpart SSSS? (§§63.5090 &
63.5110)
 The following sources are not
covered under this rule:
A coil coating line that is part of
research or laboratory equipment
Who is not covered? (Cont’d.)
A coil coating line on which 85% or
more of the metal coated, based upon
surface area, is less than 0.16
millimeters (0.006 inch) thick
Ancillary operations, such as cleaning,
coating mixing, thinning, and storage,
and wastewater operations
Who is not covered? (Cont’d.)
Surface coating subject to any other
NESHAP in Part 63;
Janitorial or building and facility
maintenance operations;
What Standards Require
Compliance? (63.5120)
 If the effected source is existing OR new
 HAP emissions are limited to no more
than…
OPTION 1:
• 2% of the organic HAP applied
during each month of the 12-month
compliance period (98% reduction)
What Standards Require
Compliance? (63.5120)
Cont’d.
OPTION 2 & 4:
• 0.046kg organic HAP/liter coating
solids applied during each 12-month
compliance period
What Standards Require
Compliance? (63.5120)
Cont’d.
OPTION 3:
20 parts per million by volume on a
dry basis when an oxidizer is used in
combination with a capture system
that achieves 100% capture
Options
 The effected source may apply any of
the compliance options to an individual
coil coating line, or
 to multiple lines as a group, or
 to the entire affected source.
Options (cont’d.)
 The effected source may use different
compliance options for different coil
coating lines, or
 At different times on the same line.
Options (cont’d.)
 However, the source may not use
different compliance options at the same
time on the same coil coating line.
 If the source switches between
compliance options for any coil coating
line or group of lines, you must document
this switch as required by § 63.5190(a),
and
Options (cont’d.)
 The source must report it in the next
semiannual compliance report required
in§ 63.5180.
Operating Limits
 Operating limits are the site-specific
parameter limits determined by the
capture and control devices during the
performance test.
 The source operating limits must be
monitored by a continuous parameter
monitoring system (CPMS)
Important dates
 The final rule was published on June
10, 2002, under 67 FR 39794,
Important dates (cont’d.)
 Existing major sources (ON OR BEFORE
July 18, 2000 ) must comply with:
 Emissions limitations;
 Operation & Maintenance requirement;
 Major source status determination;
no later than, June 10, 2005.
Important Dates (cont’d.)
 New effected sources operating after July,
18, 2000, must comply with the
regulatory requirements by June 10, 2002
or upon initial startup of the effected
sources whichever is later.
Important dates (cont’d.)
 If the METAL COIL COATING FACILITY is
an area source, but becomes a major
source of HAP, compliance of § 63.5130
upon startup.
Important dates (cont’d.)
 The effected sources must meet the
notification and scheduling requirements
in § 63.5180
 Some of these notifications must be
submitted before the effected source
compliance date.
Operations & Maintenance
Requirements (§63.5180)
 Effected 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 SSSS.
Operations & Maintenance
Requirements (§63.5180)
(Cont’d.)
 Effected 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 SSSS.
Operations & Maintenance
Requirements (§63.5180)
(Cont’d.)
 Each plan must contain the elements
required in §63.6(e) of the General
Provisions.
General Compliance
Requirements (§63.5170)
 The effected source must be in
compliance with the:
emissions standards
Operating limits
Operations and maintenance program;
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 a effected
source
General Compliance (cont’d.)
 The source may comply with the
emission limits by completing any
of the following:
 Compliant
 Each
Material Option,
coating used must not exceed
the HAP limit in Options 1,2,3 & 4;
 Determined each month for the subcategory during the 12-month
compliance period.
General Compliance (cont’d.)
 Emission Rate With Add-on
Controls,
The organic HAP emission rate,
calculated as a 12-month
rolling average on a monthly
basis;
General Compliance (cont’d.)
For coatings and thinners
(including emission capture and
control efficiency)
Must not exceed the HAP limits
in OPTION.
General Compliance (cont’d.)
 Control Efficiency/Outlet
Concentration Option
 HAP emissions must be reduced
by an overall control efficiency
of at least 98%
 For new and reconstructed
sources, and
General Compliance (cont’d.)
The outlet organic HAP
concentration must be no
greater
Than 20 parts per million (ppm)
by volume on a dry basis.
General Compliance (cont’d.)
 Initial Compliance Requirements
(§63.5180)
 Additional Performance Test
Requirements (§63.5180)
Compliance Calculations
(§63.5170)
 For Compliance Options #1, #2 and
#4, the collected data for regulated
materials are used to calculate the
organic HAP
 Content
of each material used during
the 12-month rolling average
compliance period.
Compliance Calculations
(cont’d.)
 For Compliance Options # 3, and
#4, the source must calculate the
overall organic HAP control
efficiency of the add-on controls.
Compliance Calculations
(cont’d.)
 For Compliance Option #4, an
organic HAP emission rate for the
12-month rolling average
compliance period must be
calculated.
Test Methods
 Subpart SSSS clearly defines the
test methods and other
procedures in the rule
These methods are used to
demonstrate initial compliance
with the emissions limitations
Test Methods (Cont’d.)
Typically, for each capture system that
is a PTE, the data and documentation
the source uses to support
Test Methods (cont’d.)
A determination that the capture
system meets the criteria in Method
204A, and
Additional methods 24 and 25 as
specified in §63.5150, 5160 and
outlined in 40CFR part 60 and 51.
Test Methods (cont’d.)
The rule provides the necessary
test methods and procedures for
an effected source’s HAP control
device to comply with Subpart
SSSS.