METAL FURNITURE SURFACE COATING MACT COMPLIANCE ASSURANCE 40 CFR PART 63, SUBPART RRRR July 2006

Compliance Dates Initial startup on or before April 24, 2002 (*determined by General Provisions requirement to decide new or existing sources using proposal date as cutoff date); the facility is an existing source and must comply by May 23, 2006

Compliance Dates (Cont’d) Initial startup after April 24, 2002; the facility is a new source and must comply by May 23, 2003 or the initial startup of the affected source whichever is later Non-compliance may result in fines and penalties of up to $25,000 per day per violation

Compliance Calculations Compliance Option #1: The collected data for coatings, thinners, and cleaning materials are used to calculate the organic HAP content of each material used each month If supplier information is not available, Method 24 is still the best choice to determine HAP content for calculating compliance status Compliance Options #2 & #3: An average monthly emission rate is calculated

Sample Calculations This example of calculations required by Subpart RRRR, and frankly, similar Surface Coatings NESHAP is provided in this context for objective review. The regulatory and affected sources must work through the Initial to Continued compliance issues using the mandated calculations if appropriate for a particular facility.

SAMPLE CALCULATION (cont’d) Initial Notification of Compliance Calculation (§63.4951(e - g) H e = A + B + C – R w where: H e = Total Mass Organic HAP during compliance period A = Total mass of Organic HAP coatings used

SAMPLE CALCULATION (cont’d) B = Total mass Organic HAP in thinners used C = Total mass Organic HAP in cleaning materials used R w = Total mass of Organic HAP in waste materials Calculate the mass of Organic HAP in the coatings used

SAMPLE CALCULATION (cont’d) Similar calculations are repeated for thinners, cleaning materials and waste materials used in the compliance test period Average Organic HAP Emission Rate: H avg = He / V st H avg = Organic HAP Emission Rate (kg/l) during compliance period

SAMPLE CALCULATIONS (cont’d) He = Total Mass Organic HAP during compliance period Vst = Total volume of coating solids used during compliance period (l) The sample calculations contain similarity to other surface coating rules

SAMPLE CALCULATIONS (cont’d.) However, regulatory personnel must establish clear understanding of Subpart RRRR (generally true for all Subparts) in order to maximize source T5 permitting clarity, facility inspection efficiency and finally a high level of affected facility compliance assurance.

Initial Compliance Demonstration Initial Notification (§63.4910) Initial Notification states that a facility is subject to the Metal Furniture Surface Coating Standards. Facility must submit the Initial Notification no later than May 23, 2004 for an existing source (issue: Section 112j connection) September 30, 2003 or at startup, whichever is later for a new source

Initial Compliance (cont’d.) Notification of Intent to Conduct a Performance Test [63.9 (e)] If facility required to conduct performance tests (e.g., add-on control equipment), facility must submit a notification of intent to conduct a performance test 60 days prior to the test

Initial Compliance (cont’d.) Performance test is required no later than May 23, 2006 for existing sources New or reconstructed sources must conduct the performance test by November 19, 2003 or within 180 days of startup, whichever is later

Notification of Compliance Status [§63.4910] Facility must submit a Notification of Compliance Status (NOCS) by July 30, 2006 for an existing source For new sources, the NOCS must be submitted within 30 days after the end of the initial compliance period

Performance Test Report [§63.4920] For facilities required to conduct performance tests (e.g., those with add-on control equipment), a performance test report must be submitted 60 days after completion of the performance test

Startup, Shutdown, Malfunction Reports [§634920] Compare to Exceedance or Incident Reports for VOC issues.

Reports [§634920] (Cont’d.) A Startup, Shutdown, Malfunction (SSM) report must be submitted immediately if there was a startup, shutdown, or malfunction of the control device during the reporting period that is not consistent with the SSM Plan. If actions were consistent with the SSM Plan, the report must be submitted semi-annually

Semi-Annual Compliance Reports (§63.4920) After the initial compliance period each affected source must submit semiannual compliance reports

Compliance Options Compliance Material Option: An affected facility may comply with the necessary emission limits using the following options: Each coating a facility uses (either “as pre-purchased” or “as-applied”) must not exceed 0.10 kg HAP per liter solids for existing sources, determined monthly.

Options (Cont’d.) New sources with an approved emissions limit must emit no more than 0.094 kg HAP per liter solids determined monthly Each thinner and cleaning material must contain no organic HAP

Options (cont’d.) Emission Rate Without Add-on Controls: The monthly organic HAP emission rate for coatings (including adhesives), thinners, and cleaning materials must not exceed 0.10 kg HAP per liter solids for existing sources

Options (cont’d.) 0.094 kg HAP per liter solids for new sources with approval for an alternative emission limit New sources without approval for an alternative emission limit must emit no organic HAP

Options (cont’d.) Emission Rate With Add-on Controls: The monthly organic HAP emission rate from coatings, thinners, and cleaning materials (including the emission capture and control efficiency) must not exceed 0.10 kg HAP per liter solids for existing sources

Options (cont’d.) 0.094 kg HAP per liter solids for new sources with an approval for an alternative emission limit New sources without an approval for an alternative emission limit must emit no organic HAP

TIMELINE

Records [§63.4930 and §63.4931] An affected facility is required to keep records of reported information and all the other information necessary to document compliance with the proposed rule for 5 years There may be additional requirements depending on the compliance option that is chosen

Title V Connect Check Facilities that have Federally Enforceable Limits Limited number of Major Facilities; who are they? Section 112j, T5 connection (<>3 years on T5 Permit Section 112j is no longer factor on surface coaters

Title V Issues Each affected source that has obtained a title V operating permit required by 40 CFR part 70 or 71 must report all deviations as defined in the regulation for the semiannual monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A).

TITLE V (cont’d.) If an affected source submits a compliance report required by Subpart RRRR along with, or as part of, the semiannual monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), and the compliance report includes all required information.

TITLE V (cont’d.) concerning deviations from any organic HAP emissions limitation (including any operating limit) or work practice requirement in subpart RRRR, submission of the compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. In other words, no double jeopardy

TITLE V (cont’d.) However, submission of a compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permitting authority. (THIS IS VERY IMPORTANT)

Title V Compliance Report Example For each affected source that is subject to permitting requirements required by 40 CFR part 70 or 71, and if the permitting authority has established dates for submitting semiannual reports required by Sec. 70.6 (a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), you may submit the first and subsequent compliance reports according to the dates the permitting authority has established instead of according to the dates in paragraphs (b)(1) through (4) of this section. (NOTE WELL)

NESHAP Control Requirements Generally, speaking, if the affected source cannot meet the “no HAP” component requirement, or some use of compliant coatings to meet the facility compliance requirement, the facility must install add-on controls (i.e. Thermal Oxidation, Carbon Adsorber, Condenser), and operate and maintain according to supplier manuals.

SSM PLANS Only facilities that use add-on control devices to comply with the standard must complete an SSM Plan Data Collection Supplier information on delivered/stored coatings, adhesives, thinners and cleaning materials

Section 112j Implications States approach to Initial Notification requirements connection to Section 112j

SURFACE COATING ALTERNATIVES Any option for surface coating needs? The facility can determine a compliant material option by demonstrating that the organic HAP content of each coating used in the coating operations is less than or equal to the applicable emission rate limit in 63.4890 and that each thinner and each cleaning material used contains no organic HAP.

Compliance Examples Combination HAP/no-HAP organic solids Handling cleaning materials and production materials

Pollution Prevention Options Remove HAP organic solids from formulation Application equipment design; state-of-the-art Powder Coat Technology