1 METAL FURNITURE SURFACE COATING MACT COMPLIANCE ASSURANCE 40 CFR PART 63, SUBPART RRRRJuly 2006
2 Compliance DatesInitial startup on or before April 24, 2002 (*determined by General Provisions requirement to decide new or existing sources using proposal date as cutoff date); the facility is an existing source and must comply by May 23, 2006
3 Compliance Dates (Cont’d) Initial startup after April 24, 2002; the facility is a new source and must comply by May 23, 2003 or the initial startup of the affected source whichever is laterNon-compliance may result in fines and penalties of up to $25,000 per day per violation
4 Compliance Calculations Compliance Option #1: The collected data for coatings, thinners, and cleaning materials are used to calculate the organic HAP content of each material used each monthIf supplier information is not available, Method 24 is still the best choice to determine HAP content for calculating compliance statusCompliance Options #2 & #3: An average monthly emission rate is calculated
5 Sample CalculationsThis example of calculations required by Subpart RRRR, and frankly, similar Surface Coatings NESHAP is provided in this context for objective review. The regulatory and affected sources must work through the Initial to Continued compliance issues using the mandated calculations if appropriate for a particular facility.
6 SAMPLE CALCULATION (cont’d) Initial Notification of Compliance Calculation (§ (e - g)H e = A + B + C – R w where:H e = Total Mass Organic HAP during compliance periodA = Total mass of Organic HAP coatings used
7 SAMPLE CALCULATION (cont’d) B = Total mass Organic HAP in thinners usedC = Total mass Organic HAP in cleaning materials usedR w = Total mass of Organic HAP in waste materialsCalculate the mass of Organic HAP in the coatings used
8 SAMPLE CALCULATION (cont’d) Similar calculations are repeated for thinners, cleaning materials and waste materials used in the compliance test periodAverage Organic HAP Emission Rate:H avg = He / V stH avg = Organic HAP Emission Rate (kg/l) during compliance period
9 SAMPLE CALCULATIONS (cont’d) He = Total Mass Organic HAP during compliance periodVst = Total volume of coating solids used during compliance period (l)The sample calculations contain similarity to other surface coating rules
10 SAMPLE CALCULATIONS (cont’d.) However, regulatory personnel must establish clear understanding of Subpart RRRR (generally true for all Subparts) in order to maximize source T5 permitting clarity, facility inspection efficiency and finally a high level of affected facility compliance assurance.
11 Initial Compliance Demonstration Initial Notification (§ )Initial Notification states that a facility is subject to the Metal Furniture Surface Coating Standards.Facility must submit the Initial Notification no later than May 23, 2004 for an existing source (issue: Section 112j connection)September 30, 2003 or at startup, whichever is later for a new source
12 Initial Compliance (cont’d.) Notification of Intent to Conduct a Performance Test [63.9 (e)]If facility required to conduct performance tests (e.g., add-on control equipment), facility must submit a notification of intent to conduct a performance test 60 days prior to the test
13 Initial Compliance (cont’d.) Performance test is required no later than May 23, 2006 for existing sourcesNew or reconstructed sources must conduct the performance test by November 19, 2003 or within 180 days of startup, whichever is later
14 Notification of Compliance Status [§63.4910] Facility must submit a Notification of Compliance Status (NOCS) by July 30, 2006 for an existing sourceFor new sources, the NOCS must be submitted within 30 days after the end of the initial compliance period
15 Performance Test Report [§63.4920] For facilities required to conduct performance tests (e.g., those with add-on control equipment), a performance test report must be submitted 60 days after completion of the performance test
16 Startup, Shutdown, Malfunction Reports [§634920] Compare to Exceedance or Incident Reports for VOC issues.
17 Reports [§634920] (Cont’d.)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.If actions were consistent with the SSM Plan, the report must be submitted semi-annually
18 Semi-Annual Compliance Reports (§63.4920) After the initial compliance period each affected source must submit semiannual compliance reports
19 Compliance OptionsCompliance Material Option: An affected facility may comply with the necessary emission limits using the following options:Each coating a facility uses (either “as pre-purchased” or “as-applied”) must not exceed 0.10 kg HAP per liter solids for existing sources, determined monthly.
20 Options (Cont’d.)New sources with an approved emissions limit must emit no more than kg HAP per liter solids determined monthlyEach thinner and cleaning material must contain no organic HAP
21 Options (cont’d.) Emission Rate Without Add-on Controls: The monthly organic HAP emission rate for coatings (including adhesives), thinners, and cleaning materials must not exceed 0.10 kg HAP per liter solids for existing sources
22 Options (cont’d.)0.094 kg HAP per liter solids for new sources with approval for an alternative emission limitNew sources without approval for an alternative emission limit must emit no organic HAP
23 Options (cont’d.) Emission Rate With Add-on Controls: The monthly organic HAP emission rate from coatings, thinners, and cleaning materials (including the emission capture and control efficiency) must not exceed 0.10 kg HAP per liter solids for existing sources
24 Options (cont’d.)0.094 kg HAP per liter solids for new sources with an approval for an alternative emission limitNew sources without an approval for an alternative emission limit must emit no organic HAP
26 Records [§ and § ]An affected facility is required to keep records of reported information and all the other information necessary to document compliance with the proposed rule for 5 yearsThere may be additional requirements depending on the compliance option that is chosen
27 Title V ConnectCheck Facilities that have Federally Enforceable LimitsLimited number of Major Facilities; who are they?Section 112j, T5 connection (<>3 years on T5 PermitSection 112j is no longer factor on surface coaters
28 Title V IssuesEach 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).
29 TITLE V (cont’d.)If an affected source submits a compliance report required by Subpart RRRR 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.
30 TITLE V (cont’d.)concerning deviations from any organic HAP emissions limitation (including any operating limit) or work practice requirement in subpart RRRR, 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
31 TITLE V (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)
32 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 Sec (a)(3)(iii)(A) or Sec. 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)
33 NESHAP Control Requirements Generally, speaking, if the affected source cannot meet the “no HAP” component requirement, or some use of compliant coatings to meet the facility compliance requirement, the facility must install add-on controls (i.e. Thermal Oxidation, Carbon Adsorber, Condenser), and operate and maintain according to supplier manuals.
34 SSM PLANSOnly facilities that use add-on control devices to comply with the standard must complete an SSM PlanData CollectionSupplier information on delivered/stored coatings, adhesives, thinners and cleaning materials
35 Section 112j Implications States approach to Initial Notification requirements connection to Section 112j
36 SURFACE COATING ALTERNATIVES Any option for surface coating needs?The facility can determine a compliant material option by demonstrating that the organic HAP content of each coating used in the coating operations is less than or equal to the applicable emission rate limit in and that each thinner and each cleaning material used contains no organic HAP.
37 Compliance Examples Combination HAP/no-HAP organic solids Handling cleaning materials and production materials