METAL FURNITURE SURFACE COATING MACT FACILITY INSPECTIONS

1. METAL FURNITURE SURFACE COATING MACT FACILITY INSPECTIONS 40 CFR PART 63, SUBPART RRRR July, 2006

2. 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.

3. 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.

4. Reasons for Inspections • Compliance determination • Complaint Investigation • Source Plan Approval • Review or Renewal of Permits • Special Studies

5. 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

6. Inspections at Affected Sources (Cont’d.) • Work Practice Requirements • Emission Limits • Determination of Mass Fraction of organic HAP density volume used • Other

8. Inspections at Affected Sources • Coating Lines • Storage handling (containers & Mixing Vessels) • Work Practices • Material transport • Excess materials handling • General M/R

9. Photos of Facilities

10. Typical Control Systems • Thermal Oxidizers • Carbon Adsorbers • Solvent Recovery • Emission Capture Systems

11. 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.

12. Pre-Inspection Procedures • File Review • MACT Initial Notification Report • Initial Compliance Status Report • Performance Test Report including capture • Continuing Compliance Report

13. Pre-Inspection Procedures (Cont’d.) • File Review (cont’d.) • Title V Reports • VOC/HAP reduction through NSPS/MACT implementation • Regulation Review • Equipment Checks

14. Facility File Review • Semiannual Compliance Reports • Control Equipment Removal Reports • Previous Inspection Reports • Enforcement Action • Complaints • Notice of Violations • Enforcement Actions taken • Variance history

15. 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

16. Pre-Inspection Meeting

17. 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

18. 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

19. Inspection/Documentation Report • Documentation of each determined violation • Recommendations for source testing/capture or engineering evaluation • Assessment of fugitive emissions and potential impacts