METAL CAN SURFACE COATING MACT COMPLIANCE ASSURANCE

1. METAL CAN SURFACE COATING MACT COMPLIANCE ASSURANCE 40 CFR PART 63, SUBPART KKKK June 2006

2. Compliance Timeline • IMPORTANT COMPLIANCE INFORMATION SOURCE • http://www.epa.gov/ttn/atw/mcanpg/mcantimeline.pdf

3. Compliance Dates • The final rule was published on November 13, 2003 , under 68 FR 64432

4. Compliance Dates (cont’d.) Existing major sources must comply with: Emissions limitations; Work practices standard; Operation & Maintenance requirement; Major source status determination;

5. Compliance Dates (cont’d.) • New affected sources operating on or after January15, 2003 (63.3482e) should have complied by November 13, 2003, or startup, whichever was later. Existing sources must comply by November 13, 2006.

6. Compliance Dates (cont’d.) • If the METAL CAN COATING FACILITY is an area source, but becomes a major source of HAP, compliance of [§ 63.3483(e)(1)] is required upon startup.

7. Compliance Dates (cont’d.) The affected sources must meet the notification and scheduling requirements in [§ 63.3510(b)]. Some of these notifications must be submitted before the affected source compliance date.

8. Operations & Maintenance Requirements (§63.6(1)-(2) • affected facilities must operate and maintain the sources, including air pollution control and monitoring equipment in a manner consistent with good air pollution practices that minimizes air emissions to the level required in Subpart KKKK.

9. O & M Requirements (cont’d.) affected sources must prepare and operate at all times according to a written operation and maintenance plan for each capture and collection control device controlling emissions subject to Subpart KKKK.

10. O & M Requirements (cont’d.) • Each plan must contain the elements required in §63.6(e)(1)-(2) of the General Provisions. • Equipment monthly inspections (cont’d. on next slide)

11. O & M Requirements (cont’d.) • Operating limits for each capture system • Appropriate operating limit parameters and design scope, i.e., control of multiple emissions sources

12. O&M Requirements (cont’d.) • Preventative maintenance plan for each control device including the manufacturer’s recommended maintenance instructions

13. SSM Plan Requirements(§63.3500(c) • If the affected sources uses an emission capture system and add-on control device for compliance purposes with Subpart KKKK, the source must develop and implement a written startup, shutdown and malfunction plan (SSMP);

14. SSMP (cont’d.) • SSMP must meet provisions in §63.6(e)(3). • SSMP must address startup, shutdown and corrective actions in the event of a malfunction of the emissions capture system or the add-on device.

15. SSMP (cont’d.) • The SSMP must also address any coating operation equipment that may cause increased emissions or that would affect capture efficiency if the process equipment malfunctions such as conveyors that move parts among enclosures.

16. General Compliance Requirements (§63.3500) • The affected source must be in compliance with the: • emissions limitations • Work practice standards • Operations and maintenance; • Startup, Shutdown and Malfunction Plan

17. General Compliance (cont’d.) • Maintain a log detailing the operation and maintenance of the process and emissions control equipment related to the initial performance test and the applicable operating limits for an affected source

18. Initial Compliance Requirements (§63.3510) • Performance Test: A performance test must be conducted no later than 180 calendar days after the compliance date specific to an affected source using add-on equipment.(§63.3483)

19. Initial Compliance (cont’d.) • Notification of Compliance Status; For each work practice standard and operation and maintenance requirement that applies to an affected source where an initial performance (cont’d on next slide)

20. Initial Compliance (cont’d.) test is not demonstrated, the affected source must demonstrate initial compliance no later than 30 calendar days after the specific compliance date for the affected source.

21. Initial Compliance (cont’d.) • Notification of Intent to Conduct Performance Test; In the General Provisions [§63.9(e)]requiremnet if the affected source is required to conducts performance tests (e.g., those with add-on equipment), the affected source must submit a notification of intent to conduct a performance test 60 days prior to the test.

22. Initial Compliance (cont’d.) • The affected source must install and maintain a CPMS specified in (§63.3547).

23. Test Methods • Subpart KKKK clearly defines the test methods and other procedures in §63.3521 & §63.3522 used to demonstrate initial compliance with the emissions limitations

24. Test Methods (cont’d.) • The procedures in Subpart KKKK are used to establish operating limits for: • Each capture system • Each Solvent Recovery System • Each combustion device

25. Compliance with Work Practice Standards • For any coating operation(s) for which a compliant material option or emissions rate without add-on controls option is chosen, the source is not required to meet any work practice standards. (§63.3493)

26. Work Practice Standards (cont’d.) • If an emission rate with add-on controls or the control efficiency/outlet concentration option is used to comply with the emission limitations, the source must develop and implement a written work practice plan to minimize organic HAP emissions from the storage, mixing, and conveying of coatings, (cont’d on next slide)

27. Work Practice Standards (cont’d.) thinners and cleaning materials used in and waste materials generated by the affected surface coating operations • The affected source has submitted a written Plan and will operate at all times according to that plan.

28. REPORTS • Compliance reports are required by specific due dates;

29. REPORTS (cont’d.) • Performance Test Report [(§63.3511(b)]; if the affected source is required to conduct a performance tests (e.g., those with add-on control equipment), the source must submit a performance test report within 60 days after completion of the performance test.

30. REPORTS (cont’d.) • SSM Reports [§63.3511(c)]; An SSM Report must be submitted immediately if there is an SSM of the control device during the reporting period that is not consistent with the SSM Plan. If actions taken were consistent with the SSM Plan, the report must be submitted semi-annually.

31. REPORTS (cont’d.) • Semiannual Compliance reports [63.3511(e)}; After the initial compliance period, each affected source must submit semiannual compliance reports.

32. Startup, Shutdown, Malfunction Reports [§63.3500(c)] • 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.

33. Startup, Shutdown, Malfunction Reports (cont’d.) • If actions were consistent with the SSM Plan, the report must be submitted during the required reporting period.

34. Records [§63.3512 & 63.3513] • An affected source is required to keep records of reported information and all other information necessary to document compliance with the rule for 5 years. There may be additional requirements depending on the compliance option that the affected source may choose.

35. Records (cont’d.) • An affected facility is required to keep records of reported information and all the other information necessary to document compliance with the final rule for 5 years • There may be additional requirements depending on the compliance option that is chosen.

36. Title V Connect • Check Facilities that have Federally Enforceable Limits • Limited number of Major Facilities; who are they?

37. Title V Connect (cont’d.) • Section 112j, T5 connection (<>3 years) on T5 Permit • Section 112j is no longer factor on surface coaters

38. Title V Issues • Each 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).

39. Title V Issues (cont’d.) • If an affected source submits a compliance report required by Subpart KKKK 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 concerning deviations from any organic HAP (cont’d. on next slide)

40. Title V Issues (cont’d.) emissions limitation (including any operating limit) or work practice requirement in subpart KKKK, 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.

41. TITLE V Issues (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)

42. 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 Section 70.6 (a)(3)(iii)(A) or Section (cont’d. on next slide)

43. Title V Compliance Report Example (cont’d.) 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)

44. New Source Review/PSD Implications • NSR requires stationary sources of air pollution to apply for permits before they can construct/pre-construct/reconstruct. There are three types of NSR permit requirements: • PSD permits require for new major sources, or major modification to an existing source in attainment areas;

45. NSR/PSD Implications (cont’d.) • Non-attainment NSR permits for new or modifications to existing sources; • Minor source permits • These permits must be included in the Title V permit issued to an affected facility.

46. Section 112j Implications • Most States allow the Initial Notification requirements under Subpart KKKK to be satisfied by the Section 112j Notification.

47. Pollution Prevention Options • Remove HAP organic COMPONENTS from coating operation, • Reduce the development of waste surface coatings, excess thinners and surface coating repair items.