Planned Maintenance Startup and Shutdown for Surface Coating Industries

1. Planned Maintenance Startup and Shutdown for Surface Coating Industries May 3, 2012 Air Permits Division Texas Commission on Environmental Quality

2. Outreach Objectives • Discuss MSS authorization approach and activities • Receive feedback regarding activities • Discuss plan forward including completion of outreach

3. MSS Background Mike Coldiron, P.E. Coatings/Combustion Section

4. MSS Background • EPA concerns • MSS activities are a part of the facility maximum capacity to emit • MSS activities must be included as part of the permitting process • MSS activities are subject to all permit requirements such as PN, BACT, and impacts analysis

5. MSS Background • EPA concerns were addressed through rulemaking • 30 TAC §101.222(h) effective January 6, 2006 • For surface coating sources the submittal date is January 5, 2013

6. Rule Requirements • Planned MSS emissions must be reported if they exceed the reportable quantities • Follow the procedures in 30 TAC §101.211 • Following procedures provides for an affirmative defense only for state rules

7. Rule Requirements • Affirmative defense is preserved for the duration of the review process if a timely permit action is submitted • Emissions from planned MSS activities may be subject to enforcement action

8. What are Planned MSS Emissions? • Planned MSS emissions include air emissions resulting from the maintenance, startup, or shutdown of equipment or facilities at a site

9. What are Planned MSS Emissions? • Are part of normal or routine facility operations other than production operations • Are predictable to timing • MSS activities do not have to be scheduled for a specific date or time

10. What are Planned MSS Emissions? • Planned MSS emissions do not include unplanned MSS, upsets, or emission events • TCEQ does not permit unplanned MSS, upsets, or emission events • Emission events are covered under 30 TAC §101.201

11. Activity Categories for MSS • Process MSS • General facility MSS • Included in other industry submissions • Impacts issues are difficult to deal with

12. Coatings Industries MSS Permitting Goals • Lessons learned • Industry processes are very different in most categories from previous groups • Industry demographics is much different since the majority of sources are small businesses • Most affected sites are minor sources

13. Coatings Industries MSS Permitting Goals • Efficiently review MSS from the large number of permitted sources in surface coating industries • Reduce the amount of effort for staff and regulated community • Reduce processing times

14. MSS Authorization Requirements • Identify planned MSS activities • Identify potential authorizations • Quantify emissions • Best available control technology is required • May include restrictions on activities • May be work practices

15. MSS Authorization Requirements • Impacts analysis required • Use MERA • Air dispersion modeling may be required • Public notice may be required • New air contaminants • Increased emissions > PN Triggers

16. Summary • Applications are due by January 5, 2013 • Timely applications will preserve the affirmative defense • BACT and an impacts analysis will be required

17. Contact Information Mike Coldiron, P.E. (512) 239-5027 mike.coldiron@tceq.texas.gov

18. Coatings Industry Groupings Kate Stinchcomb Coatings/Combustion Section

19. Coatings Projects Spreadsheet • Spreadsheet maintained since 1998 • Tracks all initial, amendment, and renewal projects • Contains valuable information such as process types, BACT, and pollutant emission rates

20. Industry Types • Determined the different permitted industry types • Number of facilities in each type

21. Groupings • Evaluated possible maintenance activities for each industry type • Created groupings of similar industry types with similar maintenance activities • Discussed options for authorizing those activities

22. Industry Groupings

23. Summary • The TCEQ has authorized a large number of “coatings” permits covering many different industry types • The TCEQ has identified many possible MSS activities for each industry type

24. Contact Information Kate Stinchcomb (512) 239-1583 katherine.stinchomb@tceq.texas.gov

25. Common Process MSS Activities Steve Akers, P.E. Coatings/Combustion Section

26. Approach to Common Process MSS Activities • Identified specific facility types • Identified for each facility type - What is MSS - What is not MSS (normal process) • MSS activities may be common to different facilities • Authorization Options

27. Enclosed Painting • MSS • - Cleanup of overspray • - Booth filter change out • - Oxidizer MSS • - Ventilation system cleaning

28. Enclosed Painting (Cont.) • Not MSS - Gun cleaning - Spill cleanup

29. Enclosed Abrasive Blasting • MSS - Filter replacement (baghouse/ cartridge filter system)

30. Enclosed Abrasive Blasting(Cont.) • Not MSS - Blast media cleanup/disposal - Blast pot/hopper filling

31. FRP and Cultured Marble • MSS • - Storage tank degassing for • inspection and cleaning • - Filter replacement for trim/grind • booth and spray booth

32. FRP and Cultured Marble (Cont.) • MSS - Overspray cleanup - Ventilation system cleaning - Oxidizer MSS

33. FRP and Cultured Marble (Cont.) • Not MSS - Tank loading - Spill cleanup - Application equipment cleanup - Waste collection and storage

34. Printing • MSS - Oxidizer MSS - Filter replacement (baghouse/ cartridge filter system), usually associated w/book and magazine printing

35. Printing (Cont.) • Not MSS - Image or blanket cylinder cleaning - Line flushing - Parts washers - Spill cleanup

36. Coatings Manufacturing • MSS - Storage tank degassing for inspection and cleaning - Filter replacement (baghouse/ cartridge filter system) - Oxidizer MSS

37. Coatings Manufacturing (Cont.) - Fugitive component repair (valves, flanges, pumps, etc.) • Not MSS - Spill cleanup - equipment cleaning - waste collection and storage

38. Foam Manufacturing • MSS - Storage tank degassing for cleanup and inspection - Filter replacement (baghouse/ cartridge filter system) - Fugitive component repair

39. Foam Manufacturing (Cont.) • MSS - Oxidizer MSS • Not MSS - Material Handling

40. Authorization Options • Authorize in current permit • PBR – 30 TAC Chapter 106 - No registration in most cases - Simple (or no) recordkeeping - No BACT review or public notice - Limited (or no) impacts review

41. Authorization Options (Cont.) • De Minimis – 30 TAC §116.119 - No registration - Simple (or no) recordkeeping - No BACT review or public notice - Limited impacts review

42. Authorization Options (Cont.) • Some De Minimis authorizations are located in the rule • Remaining De Minimis authorizations are on the De Minimis list http://www.tceq.texas.gov/permitting/air/ newsourcereview/de_minimis.html

43. Summary • Facility Types - What is/is not MSS • Authorization Options - Use PBRs and/or De Minimis if possible - Keep it simple

44. Contact Information Steve Akers, P.E. (512) 239-1141 steve.akers@tceq.texas.gov

45. Common General Facility MSS Activities Eddie Mack, P.E. Coatings/Combustion Section

46. Common General Facility MSS Activities • General facility MSS • Not process-related • Being included for consistency

47. Approach for General Facility MSS • Identify common activities • Approach to authorization • Permit by Rule (PBR) • De Minimis under 30 TAC §116.119

48. Examples of Facility MSS PBRs • Facility painting/blasting: §106.263 • Parts cleaners: §106.454 • Welding: §106.227 • Hand-held equipment: §106.265

49. Examples of Facility MSSDe Minimis Under §116.119 • Glove box blasting cabinets • Aerosol cans (<64 ounces/day) • Vehicle/equipment washing

50. Examples of Facility MSSDe Minimis Under §116.119 (Cont.) • Instrument calibration/leak checking • Non-aerosol lubricants • Aqueous detergents