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METAL COIL SURFACE COATING MACT OVERVIEW. 40 CFR PART 63, SUBPART SSSS May 2006. INTRODUCTION.

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metal coil surface coating mact overview

METAL COIL SURFACE COATING MACT OVERVIEW

40 CFR PART 63, SUBPART SSSS

May 2006

introduction
INTRODUCTION
  • On June 02, 2002, USEPA promulgated the Federal standard, METAL COIL SURFACE COATING NESHAP (National Emission Standards for Hazardous Air Pollutants) 40 CFR Part 63, Subpart SSSS in the Federal Register; 67 FR 39794.
what we are reviewing
What we are reviewing?
  • Rule applicability
    • NSR,NSPS & NESHAP focus
    • Covered operations
    • Operations not covered
review cont d
Review (Cont’d.)
  • Standards to be followed, including work practice standards
  • Operating Limits
  • Important dates
  • Synthetic minor sources
review cont d5
Review (cont’d.)
  • New or existing source determination
  • General rule requirements
  • Initial compliance demonstration
  • Notification, Recordkeeping and Reporting requirements
  • Compliance options
  • Compliance examples
review cont d6
Review (cont’d.)
  • Facility Inspection Protocol
    • Pre-Inspection Review
    • Facility File Review
    • Facility Inspection
    • Post-Inspection Meeting
    • Follow-up
  • Frequently asked questions
applicability who is covered by this rule subpart ssss 63 5090
APPLICABILITY: Who is covered by this rule? (Subpart SSSS, §63.5090)
  • Own or operate an EFFECTED SOURCE at a facility that is a major source,
  • Located at a major source, or
  • Part of a major source of hazardous air pollutants (HAPs),
  • NSPS for NEW sources of VOC
effected source
Effected Source
  • All coating operations;
    • Web unwind or feed stations
    • Wet section
    • Coating application stations
    • Curing ovens & Quench station
effected source cont d
Effected Source (cont’d.)
  • NSPS; COATING operations involve VOCs
  • NESHAP similar definition;
  • VOCs vs VOHAPs; similar criteria and an increase in stringency
effected source cont d10
Effected Source (cont’d.)
  • Any new or reconstructed source (as defined in § 63.2) before July 18, 2000 is an existing facility and,
    • that is a major source and is a Metal Coil Surface Coating facility
  • Any new or reconstructed source after July 18, 2000 is a new source.
what are some operations emissions impacted by subpart ssss
What are Some Operations’ Emissions Impacted by Subpart SSSS?
  • An effected source is the collection of all the metal coil coating lines at the source.
  • Coil coating lines are the collection of equipment used to apply an organic coating to the surface of a metal coil.
what are some operations emissions impacted by subpart ssss cont d
What are Some Operations’ Emissions Impacted by Subpart SSSS (Cont’d.)?
  • Coating lines include web unwind or feed stations, wet section, coating application stations, curing ovens, and quench station.
what are some operations emissions impacted by subpart ssss cont d13
What are Some Operations’ Emissions Impacted by Subpart SSSS (Cont’d.)?
  • A metal coil is a continuous metal strip that is at least 0.15 mm(0.006 in) thick and is packaged in a roll or coil prior to coating, but does not include metal webs that are coated for use in flexible packaging.
metal coil operations examples cont d
METAL COIL Operations Examples (cont’d.)
  • USEPA Applicability Determination Index Site

http://www.epa.gov/Compliance/planning/data/air/adi.htm

who is not covered by subpart ssss 63 5090 63 5110
Who is not covered by Subpart SSSS? (§§63.5090 & 63.5110)
  • The following sources are not covered under this rule:
    • A coil coating line that is part of research or laboratory equipment
who is not covered cont d
Who is not covered? (Cont’d.)
  • A coil coating line on which 85% or more of the metal coated, based upon surface area, is less than 0.16 millimeters (0.006 inch) thick
  • Ancillary operations, such as cleaning, coating mixing, thinning, and storage, and wastewater operations
who is not covered cont d17
Who is not covered? (Cont’d.)
  • Surface coating subject to any other NESHAP in Part 63;
  • Janitorial or building and facility maintenance operations;
what standards require compliance 63 5120
What Standards Require Compliance? (63.5120)
  • If the effected source is existing OR new
  • HAP emissions are limited to no more than…
    • OPTION 1:
      • 2% of the organic HAP applied during each month of the 12-month compliance period (98% reduction)
what standards require compliance 63 5120 cont d
What Standards Require Compliance? (63.5120) Cont’d.
  • OPTION 2 & 4:
    • 0.046kg organic HAP/liter coating solids applied during each 12-month compliance period
what standards require compliance 63 5120 cont d20
What Standards Require Compliance? (63.5120) Cont’d.
  • OPTION 3:
    • 20 parts per million by volume on a dry basis when an oxidizer is used in combination with a capture system that achieves 100% capture
options
Options
  • The effected source may apply any of the compliance options to an individual coil coating line, or
  • to multiple lines as a group, or
  • to the entire affected source.
options cont d
Options (cont’d.)
  • The effected source may use different compliance options for different coil coating lines, or
  • At different times on the same line.
options cont d23
Options (cont’d.)
  • However, the source may not use different compliance options at the same time on the same coil coating line.
  • If the source switches between compliance options for any coil coating line or group of lines, you must document this switch as required by § 63.5190(a), and
options cont d24
Options (cont’d.)
  • The source must report it in the next semiannual compliance report required in§ 63.5180.
operating limits
Operating Limits
  • Operating limits are the site-specific parameter limits determined by the capture and control devices during the performance test.
  • The source operating limits must be monitored by a continuous parameter monitoring system (CPMS)
important dates
Important dates
  • The final rule was published on June 10, 2002, under 67 FR 39794,
important dates cont d
Important dates (cont’d.)
  • Existing major sources (ON OR BEFORE July 18, 2000 ) must comply with:
    • Emissions limitations;
    • Operation & Maintenance requirement;
    • Major source status determination;

no later than, June 10, 2005.

important dates cont d28
Important Dates (cont’d.)
  • New effected sources operating after July, 18, 2000, must comply with the regulatory requirements by June 10, 2002 or upon initial startup of the effected sources whichever is later.
important dates cont d29
Important dates (cont’d.)
  • If the METAL COIL COATING FACILITY is an area source, but becomes a major source of HAP, compliance of § 63.5130 upon startup.
important dates cont d30
Important dates (cont’d.)
  • The effected sources must meet the notification and scheduling requirements in § 63.5180
  • Some of these notifications must be submitted before the effected source compliance date.
operations maintenance requirements 63 5180
Operations & Maintenance Requirements (§63.5180)
  • Effected 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 SSSS.
operations maintenance requirements 63 5180 cont d
Operations & Maintenance Requirements (§63.5180) (Cont’d.)
  • Effected 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 SSSS.
operations maintenance requirements 63 5180 cont d33
Operations & Maintenance Requirements (§63.5180) (Cont’d.)
  • Each plan must contain the elements required in §63.6(e) of the General Provisions.
general compliance requirements 63 5170
General Compliance Requirements (§63.5170)
  • The effected source must be in compliance with the:
    • emissions standards
    • Operating limits
    • Operations and maintenance program;
general compliance cont d
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 a effected source
general compliance cont d36
General Compliance (cont’d.)
  • The source may comply with the emission limits by completing any of the following:
    • Compliant Material Option,
      • Each coating used must not exceed the HAP limit in Options 1,2,3 & 4;
      • Determined each month for the sub-category during the 12-month compliance period.
general compliance cont d37
General Compliance (cont’d.)
  • Emission Rate With Add-on Controls,
    • The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis;
general compliance cont d38
General Compliance (cont’d.)
  • For coatings and thinners (including emission capture and control efficiency)
  • Must not exceed the HAP limits in OPTION.
general compliance cont d39
General Compliance (cont’d.)
  • Control Efficiency/Outlet Concentration Option
    • HAP emissions must be reduced by an overall control efficiency of at least 98%
    • For new and reconstructed sources, and
general compliance cont d40
General Compliance (cont’d.)
  • The outlet organic HAP concentration must be no greater
  • Than 20 parts per million (ppm) by volume on a dry basis.
general compliance cont d41
General Compliance (cont’d.)
  • Initial Compliance Requirements (§63.5180)
  • Additional Performance Test Requirements (§63.5180)
compliance calculations 63 5170
Compliance Calculations (§63.5170)
  • For Compliance Options #1, #2 and #4, the collected data for regulated materials are used to calculate the organic HAP
    • Content of each material used during the 12-month rolling average compliance period.
compliance calculations cont d
Compliance Calculations (cont’d.)
  • For Compliance Options # 3, and #4, the source must calculate the overall organic HAP control efficiency of the add-on controls.
compliance calculations cont d44
Compliance Calculations (cont’d.)
  • For Compliance Option #4, an organic HAP emission rate for the 12-month rolling average compliance period must be calculated.
test methods
Test Methods
  • Subpart SSSS clearly defines the test methods and other procedures in the rule
    • These methods are used to demonstrate initial compliance with the emissions limitations
test methods cont d
Test Methods (Cont’d.)
  • Typically, for each capture system that is a PTE, the data and documentation the source uses to support
test methods cont d47
Test Methods (cont’d.)
  • A determination that the capture system meets the criteria in Method 204A, and
  • Additional methods 24 and 25 as specified in §63.5150, 5160 and outlined in 40CFR part 60 and 51.
test methods cont d48
Test Methods (cont’d.)
  • The rule provides the necessary test methods and procedures for an effected source’s HAP control device to comply with Subpart SSSS.
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