METAL FURNITURE SURFACE COATING MACT FACILITY INSPECTIONS 40 CFR PART 63, SUBPART RRRR July, 2006

An Affected Source is... The collection of all coating operations; storage containers and mixing vessels used for coatings, thinners and/or other additives, cleaning materials and wastes; and manual and automated conveying equipment and containers used for coatings, thinners and/or other additives, cleaning materials and wastes.

Miscellaneous metal parts and products includes, but is not limited to... Metal components of the following types of products: motor vehicle parts and accessories, bicycles and sporting goods, recreational vehicles, extruded aluminum structural components, railroad cars, heavy duty trucks, medical equipment, lawn and garden equipment, electronic equipment, magnet wire, steel drums, industrial machinery, metal pipes, and numerous other industrial, household, and consumer products.

Reasons for Inspections Compliance determination Compliance determination Complaint Investigation Complaint Investigation Source Plan Approval Source Plan Approval Review or Renewal of Permits Review or Renewal of Permits Special Studies Special Studies

Inspections at Affected Sources Basically; determine how each facility is demonstrating compliance. Compliance demonstration can be with: Emission rate w/add on controls Emission rate w/add on controls Operating limits Operating limits

Inspections at Affected Sources (Contd.) Work Practice Requirements Work Practice Requirements Emission Limits Emission Limits Determination of Mass Fraction of organic HAP density volume used Determination of Mass Fraction of organic HAP density volume used Other Other

Inspections at Affected Sources Coating Lines Coating Lines Storage handling (containers & Mixing Vessels) Storage handling (containers & Mixing Vessels) Work Practices Work Practices Material transport Material transport Excess materials handling Excess materials handling General M/R General M/R

Photos of Facilities

Typical Control Systems Thermal Oxidizers Thermal Oxidizers Carbon Adsorbers Carbon Adsorbers Solvent Recovery Solvent Recovery Emission Capture Systems Emission Capture Systems

Typical Control Systems (Cont.d) Subpart RRRR requires specific data and compliance calculations for each of the above control systems. O & M plans for these systems are also required in the regulation. Subpart RRRR requires specific data and compliance calculations for each of the above control systems. O & M plans for these systems are also required in the regulation.

Pre-Inspection Procedures File Review File Review MACT Initial Notification Report MACT Initial Notification Report Initial Compliance Status Report Initial Compliance Status Report Performance Test Report including capture Performance Test Report including capture Continuing Compliance Report Continuing Compliance Report

Pre-Inspection Procedures (Contd.) File Review (contd.) File Review (contd.) Title V Reports Title V Reports VOC/HAP reduction through NSPS/MACT implementation VOC/HAP reduction through NSPS/MACT implementation Regulation Review Regulation Review Equipment Checks Equipment Checks

Facility File Review Semiannual Compliance Reports Semiannual Compliance Reports Control Equipment Removal Reports Control Equipment Removal Reports Previous Inspection Reports Previous Inspection Reports Enforcement Action Enforcement Action Complaints Complaints Notice of Violations Notice of Violations Enforcement Actions taken Enforcement Actions taken Variance history Variance history

Facility File Review (Contd.) Compliance test data Compliance test data Equipment Malfunction reports Equipment Malfunction reports SSM Plan and any events SSM Plan and any events Permit to construct P/C and permit to operate P/O Permit to construct P/C and permit to operate P/O Collection and control system design plan Collection and control system design plan

Pre-Inspection Meeting

On-site Physical Inspection Collection and control equipment Collection and control equipment Comparison between source records and visual inspection Comparison between source records and visual inspection Observation of leaks and maintenance Observation of leaks and maintenance Operation according to site specific collection system and design plan Operation according to site specific collection system and design plan

Post-Inspection Meeting Discuss any additional information needed from the owner/operator Discuss any additional information needed from the owner/operator Advise source representative of the facility specific requirements in the rules based on the type of compliance demonstration Advise source representative of the facility specific requirements in the rules based on the type of compliance demonstration Discuss any additional identified issues Discuss any additional identified issues

Inspection/Documentation Report Documentation of each determined violation Documentation of each determined violation Recommendations for source testing/capture or engineering evaluation Recommendations for source testing/capture or engineering evaluation Assessment of fugitive emissions and potential impacts Assessment of fugitive emissions and potential impacts