Transcript NESHAP Title - Illinois Environmental Protection Agency

METAL FURNITURE SURFACE
COATING MACT FACILITY
INSPECTIONS
40 CFR PART 63, SUBPART RRRR
July, 2006
An Affected Source is . . .
The collection of all coating operations;
storage containers and mixing vessels used
for coatings, thinners and/or other additives,
cleaning materials and wastes; and manual
and automated conveying equipment and
containers used for coatings, thinners
and/or other additives, cleaning materials
and wastes.
Miscellaneous metal parts and products
includes, but is not limited to . . .
Metal components of the following types of
products: motor vehicle parts and accessories,
bicycles and sporting goods, recreational
vehicles, extruded aluminum structural
components, railroad cars, heavy duty trucks,
medical equipment, lawn and garden equipment,
electronic equipment, magnet wire, steel drums,
industrial machinery, metal pipes, and numerous
other industrial, household, and consumer
products.
Reasons for Inspections
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Compliance determination
Complaint Investigation
Source Plan Approval
Review or Renewal of Permits
Special Studies
Inspections at Affected
Sources
Basically; determine how each facility
is demonstrating compliance.
Compliance demonstration can be
with:
 Emission rate w/add on controls
 Operating limits
Inspections at Affected
Sources (Cont’d.)
 Work Practice Requirements
 Emission Limits
 Determination of Mass Fraction of
organic HAP density volume used
 Other
Inspections at Affected
Sources
 Coating Lines
 Storage handling (containers & Mixing
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Vessels)
Work Practices
Material transport
Excess materials handling
General M/R
Photos of Facilities
Typical Control Systems
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Thermal Oxidizers
Carbon Adsorbers
Solvent Recovery
Emission Capture Systems
Typical Control Systems
(Con’t.d)
 Subpart RRRR requires specific data
and compliance calculations for each of
the above control systems. O & M
plans for these systems are also
required in the regulation.
Pre-Inspection
Procedures
 File Review
• MACT Initial Notification Report
• Initial Compliance Status Report
• Performance Test Report including
capture
• Continuing Compliance Report
Pre-Inspection Procedures
(Cont’d.)
 File Review (cont’d.)
• Title V Reports
• VOC/HAP reduction through
NSPS/MACT implementation
 Regulation Review
 Equipment Checks
Facility File Review
Semiannual Compliance Reports
Control Equipment Removal Reports
Previous Inspection Reports
Enforcement Action
• Complaints
• Notice of Violations
 Enforcement Actions taken
 Variance history
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Facility File Review
(Cont’d.)
Compliance test data
Equipment Malfunction reports
SSM Plan and any events
Permit to construct P/C and permit to
operate P/O
 Collection and control system design plan
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Pre-Inspection Meeting
On-site Physical
Inspection
 Collection and control equipment
 Comparison between source records and
visual inspection
 Observation of leaks and maintenance
 Operation according to site specific
collection system and design plan
Post-Inspection Meeting
 Discuss any additional information needed
from the owner/operator
 Advise source representative of the
facility specific requirements in the rules
based on the type of compliance
demonstration
 Discuss any additional identified issues
Inspection/Documentation
Report
 Documentation of each determined
violation
 Recommendations for source
testing/capture or engineering evaluation
 Assessment of fugitive emissions and
potential impacts