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

An Affected Source is... The collection of all the metal coil coating lines at your facility. Coil Coating Lines are... The collection of equipment used to apply an organic coating to the surface of metal coil. Coating lines include web unwind or feed stations, wet section, coating application stations, curing oven, and quench station. An Affected Source is... The collection of all the metal coil coating lines at your facility. Coil Coating Lines are... The collection of equipment used to apply an organic coating to the surface of metal coil. Coating lines include web unwind or feed stations, wet section, coating application stations, curing oven, and quench station.

Applicability (contd.) 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 purchasing. 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 purchasing.

Applicability (contd.) 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.

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

Inspections at Effected 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 (Contd. on next slide)

Inspections at Effected 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

What emission standards must an effected source follow? [§ ] If you are an existing or new source, limit your organic HAP emissions to no more than... If you are an existing or new source, limit your organic HAP emissions to no more than... Option 1…2% of the organic HAP applied during each month during the 12-month compliance period (98% reduction) Option 1…2% of the organic HAP applied during each month during the 12-month compliance period (98% reduction) If you are an existing or new source, limit your organic HAP emissions to no more than... If you are an existing or new source, limit your organic HAP emissions to no more than... Option 1…2% of the organic HAP applied during each month during the 12-month compliance period (98% reduction) Option 1…2% of the organic HAP applied during each month during the 12-month compliance period (98% reduction)

What emission standards must an effected source follow? (Contd.) Option 2…0.046 kg organic HAP/liter coating solids applied during each 12- month compliance period Option 2…0.046 kg organic HAP/liter coating solids applied during each 12- month compliance period 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 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 Option 2…0.046 kg organic HAP/liter coating solids applied during each 12- month compliance period Option 2…0.046 kg organic HAP/liter coating solids applied during each 12- month compliance period 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 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

Inspections at Affected Sources Coating Lines Coating Lines Storage handling (containers & Mixing Vessels) Storage handling (containers & Mixing Vessels) Work Practices Work Practices Coating Lines Coating Lines Storage handling (containers & Mixing Vessels) Storage handling (containers & Mixing Vessels) Work Practices Work Practices

Inspections at Affected Sources (Contd.) Material transport Material transport Excess materials handling Excess materials handling General M/R General M/R Material transport Material transport Excess materials handling Excess materials handling General M/R General M/R

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

Typical Control Systems (Contd.) Subpart SSSS 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 MACT Initial Notification Report Initial Compliance Status Report Performance Test Report including capture File Review MACT Initial Notification Report Initial Compliance Status Report Performance Test Report including capture

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

Facility File Review Semiannual Compliance Reports Control Equipment Removal Reports Previous Inspection Reports Enforcement Action Complaints Complaints Notice of Violations Notice of Violations Enforcement Actions taken Variance history Semiannual Compliance Reports Control Equipment Removal Reports Previous Inspection Reports Enforcement Action Complaints Complaints Notice of Violations Notice of Violations Enforcement Actions taken 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 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 Comparison between source records and visual inspection Observation of leaks and maintenance Operation according to site specific collection system and design plan Collection and control equipment Comparison between source records and visual inspection Observation of leaks and maintenance Operation according to site specific collection system and design plan

Post-Inspection Meeting 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 Discuss any additional identified issues 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 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 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