Metal can surface coating mact overview
Download
1 / 58

METAL CAN SURFACE COATING MACT OVERVIEW - PowerPoint PPT Presentation


  • 182 Views
  • Uploaded on

METAL CAN SURFACE COATING MACT OVERVIEW. 40 CFR PART 63, SUBPART KKKK June 2006. INTRODUCTION.

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about 'METAL CAN SURFACE COATING MACT OVERVIEW' - ethel


An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
Metal can surface coating mact overview l.jpg

METAL CAN SURFACE COATING MACT OVERVIEW

40 CFR PART 63, SUBPART KKKK

June 2006


Introduction l.jpg
INTRODUCTION

  • On November 13, 2003, USEPA promulgated the Federal standard, METAL CAN SURFACE COATING NESHAP (National Emission Standards for Hazardous Air Pollutants) 40 CFR Part 63, Subpart KKKK in the Federal Register; 68 FR 64432.


What we are reviewing l.jpg
What we are reviewing?

  • Rule applicability

    • NSR, NSPS & NESHAP focus

    • Covered operations

    • Operations not covered

  • Standards to be followed, including work practice standards


Review cont d l.jpg
Review? (cont’d.)

  • Operating Limits

  • Important dates

  • Synthetic minor sources

  • New or existing source determination

  • General rule requirements


Review cont d5 l.jpg
Review (cont’d.)

  • Initial compliance demonstration

  • Notification, Recordkeeping and Reporting requirements

  • Compliance options

  • Compliance examples


Review cont d6 l.jpg
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 kkkk 63 3481 l.jpg
APPLICABILITY: Who is covered by this rule? (Subpart KKKK, §63.3481)

  • Own or operate an AFFECTED SOURCE at a facility that is a major source,

  • Located at a major source, or


Applicability cont d l.jpg
APPLICABILITY (cont’d.) §63.3481)

  • Part of a major source of hazardous air pollutants (HAPs),

  • The source uses 5,700 liters(1500 gal) or more of coating per year.


Affected sources l.jpg
Affected Sources §63.3481)

  • All coating operations;

    • Coatings

    • Thinners

    • Cleaning materials storage containers


Affected sources cont d l.jpg
Affected Sources (cont’d.) §63.3481)

  • Mixing vessels

  • Manual and automated conveying equipment and containers


Affected sources cont d12 l.jpg
Affected Sources (cont’d.) §63.3481)

  • Manual and automated conveying equipment used for:

    • Waste material storage containers

      • surface coating metal cans (including decorative tins), or

      • metal crowns or closures


Affected sources cont d13 l.jpg
Affected Sources (cont’d.) §63.3481)

  • NSPS; COATING operations involve VOCs

  • NESHAP similar definition;

  • VOCs vs VOHAPs; similar criteria and an increase in stringency


Affected sources cont d14 l.jpg
Affected Sources (cont’d.) §63.3481)

  • Any new or reconstructed source (as defined in § 63.2) before January 15, 2003 is an existing facility and,

    • that is a major source and is a Metal Can Surface Coating facility


Affected sources cont d15 l.jpg
Affected Sources (cont’d.) §63.3481)

  • Any new or reconstructed source after January 15, 2003 is a new source.


What are some operations emissions impacted by subpart kkkk l.jpg
What are Some Operations’ Emissions Impacted by Subpart KKKK?

  • Metal can surface coating includes, but is not limited to;

    • Any facility that coats metal cans or ends (including decorative tins), or


What are some operations emissions impacted by subpart kkkk cont d l.jpg
What are Some Operations’ Emissions Impacted by Subpart KKKK? (cont’d.)

  • Metal crowns or closures for any type of can during any stage of the can manufacturing process, and

  • Coating metal sheets for subsequent processing into metal cans or can parts


Metal can operations examples l.jpg
METAL CAN Operations Examples KKKK? (cont’d.)

Subpart KKKK includes four subcategories:

  • One and two piece draw and iron (D&I) can body coating includes:

    • All coating processes involved in the manufacturing of can bodies by the D & I process

      (cont’d. on next slide)


Examples cont d l.jpg
Examples (cont’d.) KKKK? (cont’d.)

  • Includes the two- piece beverage cans

  • Two-piece food cans, and

  • One-piece aerosol can body coating


Examples cont d20 l.jpg
Examples (cont’d.) KKKK? (cont’d.)

  • The sheet-coating subcategory includes:

    • All the flat metal sheet-coating operations associated with the manufacture of three-piece cans,

      • decorative tins, crowns and closures.


Examples cont d21 l.jpg
Examples (cont’d.) KKKK? (cont’d.)

  • The three-piece can body assembly coating subcategory includes:

    • All coating processes involved in the assembly of three-piece metal can bodies,

      • including inside spray-on food cans, side seam stripes


Examples cont d22 l.jpg
Examples (cont’d.) KKKK? (cont’d.)

  • On food cans, side seam stripes on general line and aerosol non-food cans.


Examples cont d23 l.jpg
Examples (cont’d.) KKKK? (cont’d.)

  • The end coating category includes:

    • The application of end seal compounds and repair spray coatings to metal can ends,

      • including aseptic and non-septic end seal compounds

    • Repair spray coatings


Examples cont d24 l.jpg
EXAMPLES (cont’d.) KKKK? (cont’d.)

  • USEPA Applicability Determination Index Site

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


Who is not covered by subpart kkkk l.jpg
Who is not covered by Subpart KKKK? KKKK? (cont’d.)

  • The following sources are not covered under this rule;

    • Sources that only use coatings, thinners, and cleaning materials containing NO ORGANIC HAP;


Not covered sources cont d l.jpg
Not covered sources (cont’d.) KKKK? (cont’d.)

  • Surface coating subject to any other NESHAP in Part 63;

  • Research or laboratory facilities;

  • Janitorial or building and facility maintenance operations;


Not covered sources cont d27 l.jpg
Not Covered Sources (cont’d.) KKKK? (cont’d.)

  • Surface coating of metal coil that may be subsequently used in the manufacturing of cans;

  • Surface coating of metal pails, buckets and drums;


Not covered sources cont d28 l.jpg
Not Covered Sources (cont’d.) KKKK? (cont’d.)

  • Coating application using hand-held non-refillable aerosol containers, touch-up markers, or marking pens.


Compliance with work practice standards 63 3493 l.jpg
Compliance with Work Practice Standards KKKK? (cont’d.)(63.3493)

  • If the source uses capture and control devices, the source must develop and operate according to a work practice plan.


Work practice standards cont d l.jpg
Work Practice Standards (cont’d.) KKKK? (cont’d.)

  • The Plan should include actions to:

    • Cover mixing and storage vessels containing organic HAP-containing coating, thinners and cleaning materials except when

      • Adding, removing, or mixing contents.


Work practice standards cont d31 l.jpg
Work Practice Standards (cont’d.) KKKK? (cont’d.)

  • Used closed containers or pipes to store and convey organic HAP-containing coatings, thinners and cleaning materials.

  • Minimize spills of organic HAP-containing coatings, thinners, cleaning materials, and waste materials.


Work practice standards cont d32 l.jpg
Work Practice Standards (cont’d.) KKKK? (cont’d.)

  • Minimize organic HAP emissions during cleaning of storage, mixing, and conveying equipment.


What standards require compliance 63 3490 l.jpg
What Standards Require Compliance? (63.3490) KKKK? (cont’d.)

  • Emissions Limitations are the site-specific parameter limits the source determines for the functional

  • Capture and control devices during the performance test.


What standards require compliance cont d l.jpg
What Standards Require Compliance? (cont’d.) KKKK? (cont’d.)

  • The operating limits must be monitored by a continuous parameter monitoring system (CPMS).


Important dates l.jpg
Important dates KKKK? (cont’d.)

  • The final rule was published on November 13, 2003, under 68 FR 64432,

  • Existing major sources (ON OR BEFORE 01/15/03) must comply with:

    • Emissions limitations;


Important dates cont d l.jpg
Important dates (cont’d.) KKKK? (cont’d.)

  • Work practices standard;

  • Operation & Maintenance requirement;

  • Major source status determination; no later than, November 13, 2006.


Important dates cont d37 l.jpg
Important Dates (cont’d.) KKKK? (cont’d.)

  • New affected sources operating after January 15, 2003, must comply with the regulatory requirements by November 13, 2003 or upon initial startup of the affected sources whichever is later.


Important dates cont d38 l.jpg
Important Dates (cont’d.) KKKK? (cont’d.)

  • If the METAL CAN COATING FACILITY is an area source, but becomes a major source of HAP, compliance of § 63.3490 upon startup.


Important dates cont d39 l.jpg
Important Dates (cont’d.) KKKK? (cont’d.)

  • The affected sources must meet the notification and scheduling requirements in § 63.3510. Some of these notifications must be submitted before the affected source compliance date.


Operations maintenance requirements 63 3493 l.jpg
Operations & Maintenance Requirements (§63.3493) KKKK? (cont’d.)

  • 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.


O m requirements cont d l.jpg
O & M Requirements (cont’d.) KKKK? (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.


O m requirements cont d42 l.jpg
O & M Requirements (cont’d.) KKKK? (cont’d.)

  • Each plan must contain the elements required in §63.3493


General compliance requirements 63 3500 l.jpg
General Compliance Requirements (§63.3500) KKKK? (cont’d.)

  • The affected source must be in compliance with the:

    • emissions limitations

    • Work practice standards

    • Operations and maintenance;


General compliance cont d l.jpg
General Compliance (cont’d.) KKKK? (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 affected source


General compliance cont d45 l.jpg
General Compliance (cont’d.) KKKK? (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 Table 1;


General compliance cont d46 l.jpg
General Compliance (cont’d.) KKKK? (cont’d.)

  • Determined each month for the sub-category during the 12-month compliance period;

  • Each thinner used must contain no organic HAP.


General compliance cont d47 l.jpg
General Compliance (cont’d.) KKKK? (cont’d.)

  • Emissions Rate Without Add-on Controls

    • The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis;

    • For coatings and thinners must not exceed the HAP limits in Table 1.


General compliance cont d48 l.jpg
General Compliance (cont’d.) KKKK? (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 d49 l.jpg
General Compliance (cont’d.) KKKK? (cont’d.)

  • For coatings and thinners (including emission capture and control efficiency)

  • Must not exceed the HAP limits in Table 1.


General compliance cont d50 l.jpg
General Compliance (cont’d.) KKKK? (cont’d.)

  • Control Efficiency/Outlet Concentration Option

    • HAP emissions must be reduced by an overall control efficiency of at least 97%

    • For new and reconstructed sources, and


General compliance cont d51 l.jpg
General Compliance (cont’d.) KKKK? (cont’d.)

  • 95% for existing sources, or

  • The outlet organic HAP concentration must be no greater

  • Than 20 parts per million (ppm) by volume on a dry basis.


General compliance cont d52 l.jpg
General Compliance (cont’d.) KKKK? (cont’d.)

  • Initial Compliance Requirements (§63.3490)

  • Additional Performance Test Requirements (§63.3491)


Compliance calculations 63 3521 63 3557 l.jpg
Compliance Calculations (§§63.3521-63.3557 KKKK? (cont’d.))

  • For Compliance Option #1, 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 l.jpg
Compliance Calculations (cont’d.) KKKK? (cont’d.)

  • For Compliance Options #2 & 3, an organic HAP emission rate for the 12-month rolling average compliance

    • period must be calculated.


Compliance calculations cont d55 l.jpg
Compliance Calculations (cont’d.) KKKK? (cont’d.)

  • For Compliance Option #4, an overall organic HAP control efficiency or

    • outlet concentration is calculated for the compliance period.


Test methods l.jpg
Test Methods KKKK? (cont’d.)

  • Subpart KKKK 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 l.jpg
Test Methods (cont’d.) KKKK? (cont’d.)

  • Typically, for each capture system that is a PTE, the data and documentation the source uses to support

  • A determination that the capture system meets the criteria in Method 204, and


Test methods cont d58 l.jpg
Test Methods (cont’d.) KKKK? (cont’d.)

  • sub methods as specified in §63.3544(e) and outlined in 40CFR part 51.


ad