METAL COIL SURFACE COATING MACT QUESTION & ANSWERS 40 CFR PART 63, SUBPART SSSS May 2006

Questions/Answers #1 If the facility builds a new building next to a current building, does the new building become a new source?

Questions/Answers #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 #2 If an effected source is using an add-on control device, such as an oxidizer to comply with the rule, is a performance test necessary?

Q/A #2 If an add-on control device is used by the effected source, the source must conduct a performance test to establish the destruction or removal efficiency of the control device or the outlet HAP concentration achieved by the device, according to methods and procedures in §63.5160

Q/A #3 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 #3 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 #4 Does a metal coil coating facility have to comply with the emission limitations during periods of startup, shutdown and malfunction?

Q/A #4 The effected facility must be in compliance with the emissions limitations, work practice standards, and operation and maintenance requirements in Subpart SSSS at all times.

Q/A #5 Does a Subpart SSSS affected facility have to comply with NSPS requirements?

Q/A #5 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 #6 What are the installation, operation and maintenance requirements for the effected source monitors?

Q/A #6 For each capture system that is subject to Subpart SSSS, the facility must install, operate, and maintain each CPMS according to the requirements in § 63.5150 and63.5160.

Q/A #7 How does the facility demonstrate continuous compliance with the work practice standards that apply to the effected source?

Q/A #7 The facility must maintain records that document continuous compliance noted in § 63.5170

Q/A #8 What are the Health Effects Associated with HAP Emissions From the Surface Coating of Metal Coil?

Q/A #8 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 effects which include chronic health disorders (e.g., birth defects and effects on the central nervous system, liver, and heart) and acute health disorders (e.g., irritation of the lung, skin, and mucous membranes, effects on the central nervous system and possibly cancer.

Q/A #9 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 #9 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 #10 What does a deviation from the rule mean?

Q/A #10 Deviation means any instance in which an affected source fails to meet any obligations required by Subpart SSSS. This is not limited to any emissions limitation, work practice standard, or operation and maintenance requirement; (cont’d. on next slide)

Q/A #10 (Answer continued) The affected source fails to meet any terms or conditions adopted to implement an applicable under Subpart SSSS The affected source fails to meet emissions limitations, including operating limits or work practice standards in this Subpart.

Q/A #11 If a failure to meet the emissions limitation is permitted by Subpart SSSS, is the affected source exonerated from the non-compliant condition?

Q/A #11 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 SSSS.

Q/A #12 How flexible is Subpart SSSS regarding compliance with the rule?

Q/A #12 The effected source can choose from several compliance options in Subpart SSSS to achieve the emission limit that applies to the effected source.

Q/A #13 Do the operating limits apply to all effected source?

Q/A #13 If the effected 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 liquid-liquid material balance), the operating limits apply to the source.

Q/A #14 How does an effected source comply with Subpart SSSS of the source demonstrates compliance based on the emissions rates without add-on controls option?

Q/A #14 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.

Q/A #15 Does Subpart SSSS cover the processing of metal foil?

Q/A #15 The metal coil rule as promulgated specified that operations performing both foil coating and coil coating on the same equipment would be subject to the metal coil NESHAP only. The 85 per cent primary use provision allows facilities to comply with the NESHAP representing their principal coating activity.