METAL CAN SURFACE METAL CAN SURFACE COATING MACT COATING MACT

FACILITY INSPECTIONSFACILITY INSPECTIONS

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART KKKKKKKK

June, 2006June, 2006

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART KKKKKKKK

June, 2006June, 2006

An Affected Source is . . . All coating operations; coatings, thinners, and cleaning materials storage containers; mixing vessels and manual and automated conveying equipment and containers; waste

(continued on next slide)

An Affected Source is . . . All coating operations; coatings, thinners, and cleaning materials storage containers; mixing vessels and manual and automated conveying equipment and containers; waste

(continued on next slide)

material storage containers; and manual and automated conveying equipment containers used for surface coating metal cans(including decorative tins), or metal crowns or closures.

material storage containers; and manual and automated conveying equipment containers used for surface coating metal cans(including decorative tins), or metal crowns or closures.

A facility is covered if you own or operate an affected source at a facility that is a major source, is located at a major source, or is part of a major source of hazardous air pollutants (HAP) and you use 5,700 liters (1,500 gal) or more of coating per year.

A facility is covered if you own or operate an affected source at a facility that is a major source, is located at a major source, or is part of a major source of hazardous air pollutants (HAP) and you use 5,700 liters (1,500 gal) or more of coating per year.

ApplicabilityApplicabilityApplicabilityApplicability Metal can surface coating includes Metal can surface coating includes

but is not limited to. . .but is not limited to. . . Any facility Any facility that coats metal cans or ends (including that coats metal cans or ends (including decorative tins) or metal crowns or decorative tins) or metal crowns or closures for any type of can during any closures for any type of can during any stage or the can manufacturing process stage or the can manufacturing process and coating metal sheets for and coating metal sheets for subsequent processing into metal cans subsequent processing into metal cans or can parts. The source category or can parts. The source category includes four subcategories.includes four subcategories.

Metal can surface coating includes Metal can surface coating includes but is not limited to. . .but is not limited to. . . Any facility Any facility that coats metal cans or ends (including that coats metal cans or ends (including decorative tins) or metal crowns or decorative tins) or metal crowns or closures for any type of can during any closures for any type of can during any stage or the can manufacturing process stage or the can manufacturing process and coating metal sheets for and coating metal sheets for subsequent processing into metal cans subsequent processing into metal cans or can parts. The source category or can parts. The source category includes four subcategories.includes four subcategories.

Applicability (cont’d.)Applicability (cont’d.) The one and two piece draw and

iron (D&I) can body coating subcategory includes. . .All coating processes involved in the manufacture of can bodies by the D&I process including two-piece beverage cans, two-piece food cans and one-piece aerosol can body coating.

The one and two piece draw and iron (D&I) can body coating subcategory includes. . .All coating processes involved in the manufacture of can bodies by the D&I process including two-piece beverage cans, two-piece food cans and one-piece aerosol can body coating.

Applicability (cont’d.)Applicability (cont’d.)Applicability (cont’d.)Applicability (cont’d.)

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

Applicability (cont’d.)Applicability (cont’d.) The three-piece can body assembly

coating subcategory includes. . .All coating processes involved in the assembly of three-piece metal can bodies, including inside spray-on food cans, aseptic and nonaseptic side seam stripes on food cans, side seam stripes on general line and aerosol nonfood cans.

The three-piece can body assembly coating subcategory includes. . .All coating processes involved in the assembly of three-piece metal can bodies, including inside spray-on food cans, aseptic and nonaseptic side seam stripes on food cans, side seam stripes on general line and aerosol nonfood cans.

Applicability (cont’d.)Applicability (cont’d.)Applicability (cont’d.)Applicability (cont’d.)

The end coating subcategory includes. . .The application of end seal compounds and repair spray coatings to metal can ends including aseptic and nonaseptic end seal compounds, and repair spray coatings.

The end coating subcategory includes. . .The application of end seal compounds and repair spray coatings to metal can ends including aseptic and nonaseptic end seal compounds, and repair spray coatings.

Compliance OptionsCompliance OptionsAn affected Source may comply with your emission limits by doing any of the following:

1. Compliant Material Option - Each coating you use must not exceed the HAP limit in Table 1, determined each month for the subcategory during the 12-month compliance period. Each thinner used must contain no organic HAP.

An affected Source may comply with your emission limits by doing any of the following:

1. Compliant Material Option - Each coating you use must not exceed the HAP limit in Table 1, determined each month for the subcategory during the 12-month compliance period. Each thinner used must contain no organic HAP.

Options (cont’d.)Options (cont’d.)

2. Emission Rate Without Add-on Controls - 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.

2. Emission Rate Without Add-on Controls - 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.

Options (cont’d.)Options (cont’d.)Options (cont’d.)Options (cont’d.)

3. Emission Rate With Add-On Controls - The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis, for coatings and thinners (including emission capture and control efficiency) must not exceed the HAP limits in Table 1.

3. Emission Rate With Add-On Controls - The organic HAP emission rate, calculated as a 12-month rolling average on a monthly basis, for coatings and thinners (including emission capture and control efficiency) must not exceed the HAP limits in Table 1.

Options (cont’d.)Options (cont’d.)Options (cont’d.)Options (cont’d.)4. Control Efficiency/Outlet

Concentration Option - HAP emissions must be reduced by an overall control efficiency of at least 97 percent for new or reconstructed sources and 95 percent for existing sources or the outlet organic HAP concentration must be no greater than 20 parts per million by volume on a dry basis.

4. Control Efficiency/Outlet Concentration Option - HAP emissions must be reduced by an overall control efficiency of at least 97 percent for new or reconstructed sources and 95 percent for existing sources or the outlet organic HAP concentration must be no greater than 20 parts per million by volume on a dry basis.

Reasons for Reasons for InspectionsInspectionsReasons for Reasons for InspectionsInspections

Compliance determinationCompliance determination Complaint InvestigationComplaint Investigation Source Plan ApprovalSource Plan Approval Review or Renewal of PermitsReview or Renewal of Permits Special StudiesSpecial Studies

Compliance determinationCompliance determination Complaint InvestigationComplaint Investigation Source Plan ApprovalSource Plan Approval Review or Renewal of PermitsReview or Renewal of Permits Special StudiesSpecial Studies

Inspections at Affected Inspections at Affected SourcesSources

Inspections at Affected Inspections at Affected SourcesSources

Basically; determine how each Basically; determine how each facility is demonstrating compliance.facility is demonstrating compliance.

Compliance demonstration can be Compliance demonstration can be with:with:

Emission rate w/add on controlsEmission rate w/add on controls Operating limits Operating limits

Basically; determine how each Basically; determine how each facility is demonstrating compliance.facility is demonstrating compliance.

Compliance demonstration can be Compliance demonstration can be with:with:

Emission rate w/add on controlsEmission rate w/add on controls Operating limits Operating limits

Inspections at Affected Inspections at Affected Sources (cont’d.)Sources (cont’d.)

Inspections at Affected Inspections at Affected Sources (cont’d.)Sources (cont’d.)

Work Practice Requirements Work Practice Requirements Emission LimitsEmission Limits Determination of Mass Determination of Mass

Fraction of organic HAP Fraction of organic HAP density volume used density volume used

OtherOther

Work Practice Requirements Work Practice Requirements Emission LimitsEmission Limits Determination of Mass Determination of Mass

Fraction of organic HAP Fraction of organic HAP density volume used density volume used

OtherOther

Inspections at Inspections at Affected Sources Affected Sources

(cont’d.)(cont’d.)

Inspections at Inspections at Affected Sources Affected Sources

(cont’d.)(cont’d.) Coating LinesCoating Lines Storage handling (containers Storage handling (containers

& Mixing Vessels)& Mixing Vessels) Work PracticesWork Practices

Coating LinesCoating Lines Storage handling (containers Storage handling (containers

& Mixing Vessels)& Mixing Vessels) Work PracticesWork Practices

Inspections at Affected Inspections at Affected Sources (cont’d.)Sources (cont’d.)

Material transportMaterial transport Excess materials handlingExcess materials handling General M/RGeneral M/R

Material transportMaterial transport Excess materials handlingExcess materials handling General M/RGeneral M/R

Typical Control Typical Control SystemsSystems

Thermal OxidizersThermal OxidizersCarbon AdsorbersCarbon AdsorbersSolvent RecoverySolvent RecoveryEmission Capture SystemsEmission Capture Systems

Typical Control Systems Typical Control Systems (Cont’d.)(Cont’d.)

Typical Control Systems Typical Control Systems (Cont’d.)(Cont’d.)

Subpart KKKK requires Subpart KKKK requires specific data and compliance specific data and compliance calculations for each of the calculations for each of the above control systems. O & above control systems. O & M plans for these systems are M plans for these systems are also required in the also required in the regulation.regulation.

Subpart KKKK requires Subpart KKKK requires specific data and compliance specific data and compliance calculations for each of the calculations for each of the above control systems. O & above control systems. O & M plans for these systems are M plans for these systems are also required in the also required in the regulation.regulation.

Pre-Inspection Pre-Inspection ProceduresProcedures

Pre-Inspection Pre-Inspection ProceduresProcedures

File ReviewFile Review MACT Initial Notification ReportMACT Initial Notification Report Initial Compliance Status ReportInitial Compliance Status Report Performance Test Report Performance Test Report

including captureincluding capture Continuing Compliance ReportContinuing Compliance Report

(cont’d on next slide)(cont’d on next slide)

File ReviewFile Review MACT Initial Notification ReportMACT Initial Notification Report Initial Compliance Status ReportInitial Compliance Status Report Performance Test Report Performance Test Report

including captureincluding capture Continuing Compliance ReportContinuing Compliance Report

(cont’d on next slide)(cont’d on next slide)

Pre-Inspection Procedures Pre-Inspection Procedures (Cont’d.)(Cont’d.)

Pre-Inspection Procedures Pre-Inspection Procedures (Cont’d.)(Cont’d.)

File Review (cont’d.)File Review (cont’d.)Title V ReportsTitle V ReportsVOC/HAP reduction through VOC/HAP reduction through

NSPS/MACT implementationNSPS/MACT implementation

Regulation ReviewRegulation Review

Equipment ChecksEquipment Checks

File Review (cont’d.)File Review (cont’d.)Title V ReportsTitle V ReportsVOC/HAP reduction through VOC/HAP reduction through

NSPS/MACT implementationNSPS/MACT implementation

Regulation ReviewRegulation Review

Equipment ChecksEquipment Checks

Facility File ReviewFacility File ReviewFacility File ReviewFacility File ReviewSemiannual Compliance ReportsSemiannual Compliance ReportsControl Equipment Removal ReportsControl Equipment Removal ReportsPrevious Inspection ReportsPrevious Inspection ReportsEnforcement ActionEnforcement ActionComplaintsComplaintsNotice of ViolationsNotice of ViolationsEnforcement Actions takenEnforcement Actions taken

Semiannual Compliance ReportsSemiannual Compliance ReportsControl Equipment Removal ReportsControl Equipment Removal ReportsPrevious Inspection ReportsPrevious Inspection ReportsEnforcement ActionEnforcement ActionComplaintsComplaintsNotice of ViolationsNotice of ViolationsEnforcement Actions takenEnforcement Actions taken

Facility File Review Facility File Review (cont’d.)(cont’d.)

Facility File Review Facility File Review (cont’d.)(cont’d.)

Variance historyVariance historyCompliance test dataCompliance test dataEquipment Malfunction reportsEquipment Malfunction reportsSSM Plan and any eventsSSM Plan and any eventsPermit to construct P/C and permit to Permit to construct P/C and permit to operate P/Ooperate P/OCollection and control system design Collection and control system design planplan

Variance historyVariance historyCompliance test dataCompliance test dataEquipment Malfunction reportsEquipment Malfunction reportsSSM Plan and any eventsSSM Plan and any eventsPermit to construct P/C and permit to Permit to construct P/C and permit to operate P/Ooperate P/OCollection and control system design Collection and control system design planplan

Pre-Inspection Pre-Inspection MeetingMeeting

On-site Physical On-site Physical InspectionInspection

On-site Physical On-site Physical InspectionInspection

Collection and control equipmentCollection and control equipment

Comparison between source records Comparison between source records and visual inspectionand visual inspection

Observation of leaks and Observation of leaks and maintenancemaintenance

Operation according to site specific Operation according to site specific collection system and design plancollection system and design plan

Post-Inspection Post-Inspection MeetingMeeting

Discuss any additional information Discuss any additional information needed from the owner/operatorneeded from the owner/operator

Advise source representative of the Advise source representative of the facility specific requirements in the facility specific requirements in the rules based on the type of rules based on the type of compliance demonstration compliance demonstration

Discuss any additional identified Discuss any additional identified issuesissues

Discuss any additional information Discuss any additional information needed from the owner/operatorneeded from the owner/operator

Advise source representative of the Advise source representative of the facility specific requirements in the facility specific requirements in the rules based on the type of rules based on the type of compliance demonstration compliance demonstration

Discuss any additional identified Discuss any additional identified issuesissues

Inspection/Inspection/Documentation ReportDocumentation Report

Documentation of each determined Documentation of each determined violation violation

Recommendations for source Recommendations for source testing/capture or engineering testing/capture or engineering evaluationevaluation

Assessment of fugitive emissions Assessment of fugitive emissions and potential impactsand potential impacts

Documentation of each determined Documentation of each determined violation violation

Recommendations for source Recommendations for source testing/capture or engineering testing/capture or engineering evaluationevaluation

Assessment of fugitive emissions Assessment of fugitive emissions and potential impactsand potential impacts