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

INTRODUCTIONINTRODUCTION 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 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

What we are reviewing? Rule applicability Rule applicability NSR, NSPS & NESHAP focus Covered operations Operations not covered Standards to be followed, including work practice standards Standards to be followed, including work practice standards Rule applicability Rule applicability NSR, NSPS & NESHAP focus Covered operations Operations not covered Standards to be followed, including work practice standards Standards to be followed, including work practice standards

Review? (contd.) Operating Limits Operating Limits Important dates Important dates Synthetic minor sources Synthetic minor sources New or existing source determination New or existing source determination General rule requirements General rule requirements Operating Limits Operating Limits Important dates Important dates Synthetic minor sources Synthetic minor sources New or existing source determination New or existing source determination General rule requirements General rule requirements

Review (contd.) Initial compliance demonstration Initial compliance demonstration Notification, Recordkeeping and Reporting requirements Notification, Recordkeeping and Reporting requirements Compliance options Compliance options Compliance examples Compliance examples 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 Facility File Review Facility Inspection Post-Inspection Meeting Follow-up Frequently asked questions. Frequently asked questions. Facility Inspection Protocol Facility Inspection Protocol Pre-Inspection Review Facility File Review Facility Inspection Post-Inspection Meeting Follow-up Frequently asked questions. Frequently asked questions.

TYPICAL FACILITY Video: Video:

APPLICABILITY: Who is covered by this rule? (Subpart KKKK, § ) Own or operate an AFFECTED SOURCE at a facility that is a major source, Own or operate an AFFECTED SOURCE at a facility that is a major source, Located at a major source, or Located at a major source, or Own or operate an AFFECTED SOURCE at a facility that is a major source, Own or operate an AFFECTED SOURCE at a facility that is a major source, Located at a major source, or Located at a major source, or

APPLICABILITY (contd.) Part of a major source of hazardous air pollutants (HAPs), Part of a major source of hazardous air pollutants (HAPs), The source uses 5,700 liters(1500 gal) or more of coating per year. The source uses 5,700 liters(1500 gal) or more of coating per year. Part of a major source of hazardous air pollutants (HAPs), Part of a major source of hazardous air pollutants (HAPs), The source uses 5,700 liters(1500 gal) or more of coating per year. The source uses 5,700 liters(1500 gal) or more of coating per year.

Affected Sources All coating operations; Coatings Coatings Thinners Thinners Cleaning materials storage containers Cleaning materials storage containers All coating operations; Coatings Coatings Thinners Thinners Cleaning materials storage containers Cleaning materials storage containers

Affected Sources (contd.) Mixing vessels Mixing vessels Manual and automated conveying equipment and containers Manual and automated conveying equipment and containers Mixing vessels Mixing vessels Manual and automated conveying equipment and containers Manual and automated conveying equipment and containers

Affected Sources (contd.) Manual and automated conveying equipment used for: Waste material storage containers Waste material storage containers surface coating metal cans (including decorative tins), or metal crowns or closures Manual and automated conveying equipment used for: Waste material storage containers Waste material storage containers surface coating metal cans (including decorative tins), or metal crowns or closures

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

Affected Sources (contd.) 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 that is a major source and is a Metal Can Surface Coating facility 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 that is a major source and is a Metal Can Surface Coating facility

Affected Sources (contd.) Any new or reconstructed source after January 15, 2003 is a new source.

What are Some Operations Emissions Impacted by Subpart KKKK? Metal can surface coating includes, but is not limited to; Metal can surface coating includes, but is not limited to; Any facility that coats metal cans or ends (including decorative tins), or Any facility that coats metal cans or ends (including decorative tins), or Metal can surface coating includes, but is not limited to; Metal can surface coating includes, but is not limited to; Any facility that coats metal cans or ends (including decorative tins), or Any facility that coats metal cans or ends (including decorative tins), or

What are Some Operations Emissions Impacted by Subpart KKKK? (contd.) Metal crowns or closures for any type of can during any stage of the can manufacturing process, and 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 Coating metal sheets for subsequent processing into metal cans or can parts Metal crowns or closures for any type of can during any stage of the can manufacturing process, and 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 Coating metal sheets for subsequent processing into metal cans or can parts

METAL CAN Operations Examples Subpart KKKK includes four subcategories: 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 (contd. on next slide) Subpart KKKK includes four subcategories: 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 (contd. on next slide)

Examples (contd.) Includes the two- piece beverage cans Two-piece food cans, and One-piece aerosol can body coating Includes the two- piece beverage cans Two-piece food cans, and One-piece aerosol can body coating

Examples (contd.) The sheet-coating subcategory includes: All the flat metal sheet-coating operations associated with the manufacture of three-piece cans, All the flat metal sheet-coating operations associated with the manufacture of three-piece cans, decorative tins, crowns and closures. decorative tins, crowns and closures. The sheet-coating subcategory includes: All the flat metal sheet-coating operations associated with the manufacture of three-piece cans, All the flat metal sheet-coating operations associated with the manufacture of three-piece cans, decorative tins, crowns and closures. decorative tins, crowns and closures.

Examples (contd.) The three-piece can body assembly coating subcategory includes: All coating processes involved in the assembly of three-piece metal can bodies, All coating processes involved in the assembly of three-piece metal can bodies, including inside spray-on food cans, side seam stripes including inside spray-on food cans, side seam stripes The three-piece can body assembly coating subcategory includes: All coating processes involved in the assembly of three-piece metal can bodies, All coating processes involved in the assembly of three-piece metal can bodies, including inside spray-on food cans, side seam stripes including inside spray-on food cans, side seam stripes

Examples (contd.) On food cans, side seam stripes on general line and aerosol non- food cans. On food cans, side seam stripes on general line and aerosol non- food cans.

Examples (contd.) The end coating category includes: The application of end seal compounds and repair spray coatings to metal can ends, The application of end seal compounds and repair spray coatings to metal can ends, including aseptic and non-septic end seal compounds including aseptic and non-septic end seal compounds Repair spray coatings Repair spray coatings The end coating category includes: The application of end seal compounds and repair spray coatings to metal can ends, The application of end seal compounds and repair spray coatings to metal can ends, including aseptic and non-septic end seal compounds including aseptic and non-septic end seal compounds Repair spray coatings Repair spray coatings

EXAMPLES (contd.) USEPA Applicability Determination Index Site USEPA Applicability Determination Index Site planning/data/air/adi.htm planning/data/air/adi.htm

Who is not covered by Subpart KKKK? The following sources are not covered under this rule; The following sources are not covered under this rule; Sources that only use coatings, thinners, and cleaning materials containing NO ORGANIC HAP; Sources that only use coatings, thinners, and cleaning materials containing NO ORGANIC HAP; The following sources are not covered under this rule; The following sources are not covered under this rule; Sources that only use coatings, thinners, and cleaning materials containing NO ORGANIC HAP; Sources that only use coatings, thinners, and cleaning materials containing NO ORGANIC HAP;

Not covered sources (contd.) Surface coating subject to any other NESHAP in Part 63; Surface coating subject to any other NESHAP in Part 63; Research or laboratory facilities; Research or laboratory facilities; Janitorial or building and facility maintenance operations ; Janitorial or building and facility maintenance operations ; Surface coating subject to any other NESHAP in Part 63; Surface coating subject to any other NESHAP in Part 63; Research or laboratory facilities; Research or laboratory facilities; Janitorial or building and facility maintenance operations ; Janitorial or building and facility maintenance operations ;

Not Covered Sources (contd.) Surface coating of metal coil that may be subsequently used in the manufacturing of cans; Surface coating of metal coil that may be subsequently used in the manufacturing of cans; Surface coating of metal pails, buckets and drums; Surface coating of metal pails, buckets and drums; Surface coating of metal coil that may be subsequently used in the manufacturing of cans; Surface coating of metal coil that may be subsequently used in the manufacturing of cans; Surface coating of metal pails, buckets and drums; Surface coating of metal pails, buckets and drums;

Not Covered Sources (contd.) Coating application using hand-held non-refillable aerosol containers, touch-up markers, or marking pens. Coating application using hand-held non-refillable aerosol containers, touch-up markers, or marking pens.

Compliance with Work Practice Standards ( ) If the source uses capture and control devices, the source must develop and operate according to a work practice plan. If the source uses capture and control devices, the source must develop and operate according to a work practice plan.

Work Practice Standards (contd.) The Plan should include actions to: The Plan should include actions to: Cover mixing and storage vessels containing organic HAP-containing coating, thinners and cleaning materials except when Cover mixing and storage vessels containing organic HAP-containing coating, thinners and cleaning materials except when Adding, removing, or mixing contents. Adding, removing, or mixing contents. The Plan should include actions to: The Plan should include actions to: Cover mixing and storage vessels containing organic HAP-containing coating, thinners and cleaning materials except when Cover mixing and storage vessels containing organic HAP-containing coating, thinners and cleaning materials except when Adding, removing, or mixing contents. Adding, removing, or mixing contents.

Work Practice Standards (contd.) Used closed containers or pipes to store and convey organic HAP-containing coatings, thinners and cleaning materials. 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. Minimize spills of organic HAP-containing coatings, thinners, cleaning materials, and waste materials. Used closed containers or pipes to store and convey organic HAP-containing coatings, thinners and cleaning materials. 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. Minimize spills of organic HAP-containing coatings, thinners, cleaning materials, and waste materials.

Work Practice Standards (contd.) Minimize organic HAP emissions during cleaning of storage, mixing, and conveying equipment. Minimize organic HAP emissions during cleaning of storage, mixing, and conveying equipment.

What Standards Require Compliance? ( ) Emissions Limitations are the site- specific parameter limits the source determines for the functional Emissions Limitations are the site- specific parameter limits the source determines for the functional Capture and control devices during the performance test. Capture and control devices during the performance test. Emissions Limitations are the site- specific parameter limits the source determines for the functional Emissions Limitations are the site- specific parameter limits the source determines for the functional Capture and control devices during the performance test. Capture and control devices during the performance test.

What Standards Require Compliance? (contd.) The operating limits must be monitored by a continuous parameter monitoring system (CPMS). The operating limits must be monitored by a continuous parameter monitoring system (CPMS).

Important dates The final rule was published on November 13, 2003, under 68 FR 64432, 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: Existing major sources (ON OR BEFORE 01/15/03) must comply with: Emissions limitations; The final rule was published on November 13, 2003, under 68 FR 64432, 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: Existing major sources (ON OR BEFORE 01/15/03) must comply with: Emissions limitations;

Important dates (contd.) Work practices standard; Operation & Maintenance requirement; Major source status determination; no later than, November 13, Work practices standard; Operation & Maintenance requirement; Major source status determination; no later than, November 13, 2006.

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

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

Operations & Maintenance Requirements (§ ) 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. 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 (contd.) 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. 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 (contd.) Each plan must contain the elements required in § Each plan must contain the elements required in §

General Compliance Requirements (§ ) The affected source must be in compliance with the: The affected source must be in compliance with the: emissions limitations emissions limitations Work practice standards Work practice standards Operations and maintenance; Operations and maintenance; The affected source must be in compliance with the: The affected source must be in compliance with the: emissions limitations emissions limitations Work practice standards Work practice standards Operations and maintenance; Operations and maintenance;

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 affected 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 affected 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 Table 1; Each coating used must not exceed the HAP limit in Table 1; 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 Table 1; Each coating used must not exceed the HAP limit in Table 1;

General Compliance (contd.) 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; Each thinner used must contain no organic HAP. Each thinner used must contain no organic HAP. 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; Each thinner used must contain no organic HAP. Each thinner used must contain no organic HAP.

General Compliance (contd.) Emissions Rate Without Add-on Controls Emissions Rate Without 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; For coatings and thinners must not exceed the HAP limits in Table 1. For coatings and thinners must not exceed the HAP limits in Table 1. Emissions Rate Without Add-on Controls Emissions Rate Without 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; For coatings and thinners must not exceed the HAP limits in Table 1. For coatings and thinners must not exceed the HAP limits in Table 1.

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 Table 1. Must not exceed the HAP limits in Table 1. 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 Table 1. Must not exceed the HAP limits in Table 1.

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 97% HAP emissions must be reduced by an overall control efficiency of at least 97% 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 97% HAP emissions must be reduced by an overall control efficiency of at least 97% For new and reconstructed sources, and For new and reconstructed sources, and

General Compliance (contd.) 95% for existing sources, or 95% for existing sources, or 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. 95% for existing sources, or 95% for existing sources, or 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 Option #1, the collected data for regulated materials are used to calculate the organic HAP 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. Content of each material used during the 12-month rolling average compliance period. For Compliance Option #1, the collected data for regulated materials are used to calculate the organic HAP 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. Content of each material used during the 12-month rolling average compliance period.

Compliance Calculations (contd.) For Compliance Options #2 & 3, an organic HAP emission rate for the 12- month rolling average compliance For Compliance Options #2 & 3, an organic HAP emission rate for the 12- month rolling average compliance period must be calculated. period must be calculated. For Compliance Options #2 & 3, an organic HAP emission rate for the 12- month rolling average compliance For Compliance Options #2 & 3, an organic HAP emission rate for the 12- month rolling average compliance period must be calculated. period must be calculated.

Compliance Calculations (contd.) For Compliance Option #4, an overall organic HAP control efficiency or For Compliance Option #4, an overall organic HAP control efficiency or outlet concentration is calculated for the compliance period. outlet concentration is calculated for the compliance period. For Compliance Option #4, an overall organic HAP control efficiency or For Compliance Option #4, an overall organic HAP control efficiency or outlet concentration is calculated for the compliance period. outlet concentration is calculated for the compliance period.

Test Methods Subpart KKKK clearly defines the test methods and other procedures in the rule 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 These methods are used to demonstrate initial compliance with the emissions limitations Subpart KKKK clearly defines the test methods and other procedures in the rule 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 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 A determination that the capture system meets the criteria in Method 204, and A determination that the capture system meets the criteria in Method 204, and 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 A determination that the capture system meets the criteria in Method 204, and A determination that the capture system meets the criteria in Method 204, and

Test Methods (contd.) sub methods as specified in § (e) and outlined in 40CFR part 51. sub methods as specified in § (e) and outlined in 40CFR part 51.