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

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 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

What we are reviewing? Rule applicability Rule applicability NSR,NSPS & NESHAP focus NSR,NSPS & NESHAP focus Covered operations Covered operations Operations not covered Operations not covered Rule applicability Rule applicability NSR,NSPS & NESHAP focus NSR,NSPS & NESHAP focus Covered operations Covered operations Operations not covered Operations not covered

Review (Contd.) Standards to be followed, including work practice standards Standards to be followed, including work practice standards Operating Limits Operating Limits Important dates Important dates Synthetic minor sources Synthetic minor sources Standards to be followed, including work practice standards Standards to be followed, including work practice standards Operating Limits Operating Limits Important dates Important dates Synthetic minor sources Synthetic minor sources

Review (contd.) New or existing source determination New or existing source determination General rule requirements General rule requirements Initial compliance demonstration Initial compliance demonstration Notification, Recordkeeping and Reporting requirements Notification, Recordkeeping and Reporting requirements Compliance options Compliance options Compliance examples Compliance examples New or existing source determination New or existing source determination General rule requirements General rule requirements Initial compliance demonstration Initial compliance demonstration Notification, Recordkeeping and Reporting requirements Notification, Recordkeeping and Reporting requirements Compliance options Compliance options Compliance examples Compliance examples

Review (contd.) Facility Inspection Protocol Facility Inspection Protocol Pre-Inspection Review Pre-Inspection Review Facility File Review Facility File Review Facility Inspection Facility Inspection Post-Inspection Meeting Post-Inspection Meeting Follow-up Follow-up Frequently asked questions Frequently asked questions Facility Inspection Protocol Facility Inspection Protocol Pre-Inspection Review Pre-Inspection Review Facility File Review Facility File Review Facility Inspection Facility Inspection Post-Inspection Meeting Post-Inspection Meeting Follow-up Follow-up Frequently asked questions Frequently asked questions

APPLICABILITY: Who is covered by this rule? (Subpart SSSS, § ) Own or operate an EFFECTED SOURCE at a facility that is a major source, Own or operate an EFFECTED SOURCE at a facility that is a major source, Located at a major source, or Located at a major source, or Part of a major source of hazardous air pollutants (HAPs), Part of a major source of hazardous air pollutants (HAPs), NSPS for NEW sources of VOC NSPS for NEW sources of VOC Own or operate an EFFECTED SOURCE at a facility that is a major source, Own or operate an EFFECTED SOURCE at a facility that is a major source, Located at a major source, or Located at a major source, or Part of a major source of hazardous air pollutants (HAPs), Part of a major source of hazardous air pollutants (HAPs), NSPS for NEW sources of VOC NSPS for NEW sources of VOC

Effected Source All coating operations; All coating operations; Web unwind or feed stations Web unwind or feed stations Wet section Wet section Coating application stations Coating application stations Curing ovens & Quench station Curing ovens & Quench station All coating operations; All coating operations; Web unwind or feed stations Web unwind or feed stations Wet section Wet section Coating application stations Coating application stations Curing ovens & Quench station Curing ovens & Quench station

Effected Source (contd.) NSPS; COATING operations involve VOCs NSPS; COATING operations involve VOCs NESHAP similar definition; NESHAP similar definition; VOCs vs VOHAPs; similar criteria and an increase in stringency VOCs vs VOHAPs; similar criteria and an increase in stringency NSPS; COATING operations involve VOCs NSPS; COATING operations involve VOCs NESHAP similar definition; NESHAP similar definition; VOCs vs VOHAPs; similar criteria and an increase in stringency VOCs vs VOHAPs; similar criteria and an increase in stringency

Effected Source (contd.) Any new or reconstructed source (as defined in § 63.2) before July 18, 2000 is an existing facility and, 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 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. Any new or reconstructed source after July 18, 2000 is a new source. Any new or reconstructed source (as defined in § 63.2) before July 18, 2000 is an existing facility and, 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 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. Any new or reconstructed source after July 18, 2000 is a new source.

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. 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. Coil coating lines are the collection of equipment used to apply an organic coating to the surface of a metal coil. An effected source is the collection of all the metal coil coating lines at the source. 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. 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 (Contd.)? Coating lines include web unwind or feed stations, wet section, coating application stations, curing ovens, and quench station. 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 (Contd.)? 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. 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 (contd.) USEPA Applicability Determination Index Site USEPA Applicability Determination Index Site data/air/adi.htm data/air/adi.htm

Who is not covered by Subpart SSSS? (§§ & ) The following sources are not covered under this rule: The following sources are not covered under this rule: A coil coating line that is part of research or laboratory equipment The following sources are not covered under this rule: 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? (Contd.) 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 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? (Contd.) Surface coating subject to any other NESHAP in Part 63; Janitorial or building and facility maintenance operations; Surface coating subject to any other NESHAP in Part 63; Janitorial or building and facility maintenance operations;

What Standards Require Compliance? ( ) If the effected source is existing OR new If the effected source is existing OR new HAP emissions are limited to no more than… 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) 2% of the organic HAP applied during each month of the 12-month compliance period (98% reduction) If the effected source is existing OR new If the effected source is existing OR new HAP emissions are limited to no more than… 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) 2% of the organic HAP applied during each month of the 12-month compliance period (98% reduction)

What Standards Require Compliance? ( ) Contd. OPTION 2 & 4: 0.046kg organic HAP/liter coating solids applied during each 12-month compliance period 0.046kg organic HAP/liter coating solids applied during each 12-month compliance period OPTION 2 & 4: 0.046kg organic HAP/liter coating solids applied during each 12-month compliance period 0.046kg organic HAP/liter coating solids applied during each 12-month compliance period

What Standards Require Compliance? ( ) Contd. 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 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 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 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 The effected source may apply any of the compliance options to an individual coil coating line, or 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 multiple lines as a group, or to the entire affected source. to the entire affected source. The effected source may apply any of the compliance options to an individual coil coating line, or 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 multiple lines as a group, or to the entire affected source. to the entire affected source.

Options (contd.) The effected source may use different compliance options for different coil coating lines, or The effected source may use different compliance options for different coil coating lines, or At different times on the same line. At different times on the same line. The effected source may use different compliance options for different coil coating lines, or The effected source may use different compliance options for different coil coating lines, or At different times on the same line. At different times on the same line.

Options (contd.) However, the source may not use different compliance options at the same time on the same coil coating line. 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 § (a), and If the source switches between compliance options for any coil coating line or group of lines, you must document this switch as required by § (a), and However, the source may not use different compliance options at the same time on the same coil coating line. 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 § (a), and If the source switches between compliance options for any coil coating line or group of lines, you must document this switch as required by § (a), and

Options (contd.) The source must report it in the next semiannual compliance report required in§ The source must report it in the next semiannual compliance report required in§

Operating Limits Operating limits are the site-specific parameter limits determined by the capture and control devices during the performance test. 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) The source operating limits must be monitored by a continuous parameter monitoring system (CPMS) Operating limits are the site-specific parameter limits determined by the capture and control devices during the performance test. 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) The source operating limits must be monitored by a continuous parameter monitoring system (CPMS)

Important dates The final rule was published on June 10, 2002, under 67 FR 39794, The final rule was published on June 10, 2002, under 67 FR 39794,

Important dates (contd.) Existing major sources (ON OR BEFORE July 18, 2000 ) must comply with: Existing major sources (ON OR BEFORE July 18, 2000 ) must comply with: Emissions limitations; Emissions limitations; Operation & Maintenance requirement; Operation & Maintenance requirement; Major source status determination; Major source status determination; no later than, June 10, no later than, June 10, Existing major sources (ON OR BEFORE July 18, 2000 ) must comply with: Existing major sources (ON OR BEFORE July 18, 2000 ) must comply with: Emissions limitations; Emissions limitations; Operation & Maintenance requirement; Operation & Maintenance requirement; Major source status determination; Major source status determination; no later than, June 10, no later than, June 10, 2005.

Important Dates (contd.) 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. 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 (contd.) If the METAL COIL COATING FACILITY is an area source, but becomes a major source of HAP, compliance of § upon startup. If the METAL COIL COATING FACILITY is an area source, but becomes a major source of HAP, compliance of § upon startup.

Important dates (contd.) The effected sources must meet the notification and scheduling requirements in § The effected sources must meet the notification and scheduling requirements in § Some of these notifications must be submitted before the effected source compliance date. Some of these notifications must be submitted before the effected source compliance date. The effected sources must meet the notification and scheduling requirements in § The effected sources must meet the notification and scheduling requirements in § Some of these notifications must be submitted before the effected source compliance date. Some of these notifications must be submitted before the effected source compliance date.

Operations & Maintenance Requirements (§ ) 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. 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 (§ ) (Contd.) 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. 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 (§ ) (Contd.) Each plan must contain the elements required in §63.6(e) of the General Provisions. Each plan must contain the elements required in §63.6(e) of the General Provisions.

General Compliance Requirements (§ ) The effected source must be in compliance with the: The effected source must be in compliance with the: emissions standards emissions standards Operating limits Operating limits Operations and maintenance program; Operations and maintenance program; The effected source must be in compliance with the: The effected source must be in compliance with the: emissions standards emissions standards Operating limits Operating limits Operations and maintenance program; Operations and maintenance program;

General Compliance (Contd.) 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 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 (contd.) The source may comply with the emission limits by completing any of the following: The source may comply with the emission limits by completing any of the following: Compliant Material Option, Compliant Material Option, Each coating used must not exceed the HAP limit in Options 1,2,3 & 4; 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. Determined each month for the sub- category during the 12-month compliance period. The source may comply with the emission limits by completing any of the following: The source may comply with the emission limits by completing any of the following: Compliant Material Option, Compliant Material Option, Each coating used must not exceed the HAP limit in Options 1,2,3 & 4; 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. Determined each month for the sub- category during the 12-month compliance period.

General Compliance (contd.) Emission Rate With Add-on Controls, Emission Rate With Add-on Controls, The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis; The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis; Emission Rate With Add-on Controls, Emission Rate With Add-on Controls, The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis; The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis;

General Compliance (contd.) For coatings and thinners (including emission capture and control efficiency) For coatings and thinners (including emission capture and control efficiency) Must not exceed the HAP limits in OPTION. Must not exceed the HAP limits in OPTION. For coatings and thinners (including emission capture and control efficiency) For coatings and thinners (including emission capture and control efficiency) Must not exceed the HAP limits in OPTION. Must not exceed the HAP limits in OPTION.

General Compliance (contd.) Control Efficiency/Outlet Concentration Option Control Efficiency/Outlet Concentration Option HAP emissions must be reduced by an overall control efficiency of at least 98% HAP emissions must be reduced by an overall control efficiency of at least 98% For new and reconstructed sources, and For new and reconstructed sources, and Control Efficiency/Outlet Concentration Option Control Efficiency/Outlet Concentration Option HAP emissions must be reduced by an overall control efficiency of at least 98% HAP emissions must be reduced by an overall control efficiency of at least 98% For new and reconstructed sources, and For new and reconstructed sources, and

General Compliance (contd.) The outlet organic HAP concentration must be no greater The outlet organic HAP concentration must be no greater Than 20 parts per million (ppm) by volume on a dry basis. Than 20 parts per million (ppm) by volume on a dry basis. The outlet organic HAP concentration must be no greater The outlet organic HAP concentration must be no greater Than 20 parts per million (ppm) by volume on a dry basis. Than 20 parts per million (ppm) by volume on a dry basis.

General Compliance (contd.) Initial Compliance Requirements (§ ) Initial Compliance Requirements (§ ) Additional Performance Test Requirements (§ ) Additional Performance Test Requirements (§ ) Initial Compliance Requirements (§ ) Initial Compliance Requirements (§ ) Additional Performance Test Requirements (§ ) Additional Performance Test Requirements (§ )

Compliance Calculations (§ ) For Compliance Options #1, #2 and #4, the collected data for regulated materials are used to calculate the organic HAP 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. Content of each material used during the 12-month rolling average compliance period. For Compliance Options #1, #2 and #4, the collected data for regulated materials are used to calculate the organic HAP 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. Content of each material used during the 12-month rolling average compliance period.

Compliance Calculations (contd.) For Compliance Options # 3, and #4, the source must calculate the overall organic HAP control efficiency of the add-on controls. For Compliance Options # 3, and #4, the source must calculate the overall organic HAP control efficiency of the add-on controls.

Compliance Calculations (contd.) For Compliance Option #4, an organic HAP emission rate for the 12-month rolling average compliance period must be calculated. For Compliance Option #4, an organic HAP emission rate for the 12-month rolling average compliance period must be calculated.

Test Methods Subpart SSSS clearly defines the test methods and other procedures in the rule 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 These methods are used to demonstrate initial compliance with the emissions limitations Subpart SSSS clearly defines the test methods and other procedures in the rule 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 These methods are used to demonstrate initial compliance with the emissions limitations

Test Methods (Contd.) Typically, for each capture system that is a PTE, the data and documentation the source uses to support Typically, for each capture system that is a PTE, the data and documentation the source uses to support

Test Methods (contd.) A determination that the capture system meets the criteria in Method 204A, and A determination that the capture system meets the criteria in Method 204A, and Additional methods 24 and 25 as specified in § , 5160 and outlined in 40CFR part 60 and 51. Additional methods 24 and 25 as specified in § , 5160 and outlined in 40CFR part 60 and 51. A determination that the capture system meets the criteria in Method 204A, and A determination that the capture system meets the criteria in Method 204A, and Additional methods 24 and 25 as specified in § , 5160 and outlined in 40CFR part 60 and 51. Additional methods 24 and 25 as specified in § , 5160 and outlined in 40CFR part 60 and 51.

Test Methods (contd.) The rule provides the necessary test methods and procedures for an effected sources HAP control device to comply with Subpart SSSS. The rule provides the necessary test methods and procedures for an effected sources HAP control device to comply with Subpart SSSS.