METAL FURNITURE METAL FURNITURE SURFACE COATING SURFACE COATING MACT COMPLIANCE MACT COMPLIANCE

ASSURANCEASSURANCE40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART

RRRRRRRR

July 2006July 2006

ComplianceCompliance Dates Dates

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

ComplianceCompliance Dates Dates (Cont’d)(Cont’d)

Initial startup after April 24, 2002; the Initial startup after April 24, 2002; the facility is a new source and must facility is a new source and must comply by May 23, 2003 or the initial comply by May 23, 2003 or the initial startup of the affected source startup of the affected source whichever is laterwhichever is later

Non-compliance may result in fines Non-compliance may result in fines and penalties of up to $25,000 per day and penalties of up to $25,000 per day per violationper violation

Compliance Compliance CalculationsCalculations

Compliance Option #1: The collected Compliance Option #1: The collected data for coatings, thinners, and cleaning data for coatings, thinners, and cleaning materials are used to calculate the materials are used to calculate the organic HAP content of each material organic HAP content of each material used each monthused each month

If supplier information is not available, If supplier information is not available, Method 24Method 24 is still the best choice to is still the best choice to determine HAP content for calculating determine HAP content for calculating compliance statuscompliance status

Compliance Options #2 & #3: An average Compliance Options #2 & #3: An average monthly emission rate is calculatedmonthly emission rate is calculated

Sample CalculationsSample Calculations

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

SAMPLE CALCULATION SAMPLE CALCULATION (cont’d)(cont’d)

Initial Notification of Compliance Initial Notification of Compliance Calculation Calculation (§63.4951(e - g)(§63.4951(e - g)

H H e e = A + B + C – R = A + B + C – R w where:w where:

H e = Total Mass Organic HAP during compliance periodH e = Total Mass Organic HAP during compliance period

A =A = Total mass of Organic HAP coatings usedTotal mass of Organic HAP coatings used

SAMPLE CALCULATION SAMPLE CALCULATION (cont’d)(cont’d)

B = Total mass Organic HAP in thinners usedB = Total mass Organic HAP in thinners used C = Total mass Organic HAP in cleaning C = Total mass Organic HAP in cleaning

materials usedmaterials used R w = Total mass of Organic HAP in waste materials

Calculate the mass of Organic HAP in the Calculate the mass of Organic HAP in the coatings usedcoatings used

Similar calculations are repeated for Similar calculations are repeated for thinners, cleaning materials and thinners, cleaning materials and waste materials used in the waste materials used in the compliance test periodcompliance test period

Average Organic HAP Emission Rate:Average Organic HAP Emission Rate: H H avg avg = H= He e / V / V stst

H H avg avg = Organic HAP Emission Rate = Organic HAP Emission Rate (kg/l) during compliance period(kg/l) during compliance period

SAMPLE CALCULATION SAMPLE CALCULATION (cont’d)(cont’d)

SAMPLE CALCULATIONS (cont’d)

He = Total Mass Organic HAP during compliance periodHe = Total Mass Organic HAP during compliance period Vst = Total volume of coating solids used during compliance Vst = Total volume of coating solids used during compliance

period (l)period (l)

The sample calculations contain The sample calculations contain similarity to other surface coating similarity to other surface coating rulesrules

SAMPLE CALCULATIONS (cont’d.)

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

Initial Compliance Initial Compliance DemonstrationDemonstration

• Initial Notification Initial Notification (§63.4910)(§63.4910) Initial Notification states that a Initial Notification states that a

facility is subject to the Metal facility is subject to the Metal Furniture Surface Coating Standards.Furniture Surface Coating Standards.

Facility must submit the Initial Facility must submit the Initial Notification no later than May 23, Notification no later than May 23, 2004 for an existing source (issue: 2004 for an existing source (issue: Section 112j connection)Section 112j connection)

September 30, 2003 or at startup, September 30, 2003 or at startup, whichever is later for a new sourcewhichever is later for a new source

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

• Notification of Intent to Conduct a Notification of Intent to Conduct a Performance Test Performance Test [63.9 (e)][63.9 (e)] If facility required to conduct If facility required to conduct

performance tests (e.g., add-on performance tests (e.g., add-on control equipment), facility must control equipment), facility must submit a notification of intent to submit a notification of intent to conduct a performance test 60 days conduct a performance test 60 days prior to the testprior to the test

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

Performance test is required no Performance test is required no later than May 23, 2006 for later than May 23, 2006 for existing sourcesexisting sources

New or reconstructed sources must New or reconstructed sources must conduct the performance test by conduct the performance test by November 19, 2003 or within 180 November 19, 2003 or within 180 days of startup, whichever is laterdays of startup, whichever is later

Notification of Notification of Compliance Status Compliance Status

[§63.4910][§63.4910]• Facility must submit a Notification of Facility must submit a Notification of

Compliance Status (NOCS) by July Compliance Status (NOCS) by July 30, 2006 for an existing source30, 2006 for an existing source

• For new sources, the NOCS must be For new sources, the NOCS must be submitted within 30 days after the submitted within 30 days after the end of the initial compliance periodend of the initial compliance period

Performance Test Performance Test Report [§63.4920]Report [§63.4920]

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

Startup, Shutdown, Startup, Shutdown, Malfunction Reports Malfunction Reports

[§634920][§634920] Compare to Exceedance or Incident Compare to Exceedance or Incident

Reports for VOC issues.Reports for VOC issues.

Reports [§634920] Reports [§634920] (Cont’d.)(Cont’d.)

A Startup, Shutdown, Malfunction A Startup, Shutdown, Malfunction (SSM) report must be submitted (SSM) report must be submitted immediately if there was a startup, immediately if there was a startup, shutdown, or malfunction of the control shutdown, or malfunction of the control device during the reporting period that device during the reporting period that is not consistent with the SSM Plan.is not consistent with the SSM Plan.

If actions were consistent with the SSM If actions were consistent with the SSM Plan, the report must be submitted Plan, the report must be submitted semi-annuallysemi-annually

Semi-Annual Semi-Annual Compliance Reports Compliance Reports

(§63.4920)(§63.4920)

After the initial compliance period After the initial compliance period each affected source must submit each affected source must submit semiannual compliance reportssemiannual compliance reports

Compliance OptionsCompliance Options

Compliance Material Option: An Compliance Material Option: An affected facility may comply with the affected facility may comply with the necessary emission limits using the necessary emission limits using the following options:following options:• Each coating a facility uses (either Each coating a facility uses (either

“as pre-purchased” or “as-applied”) “as pre-purchased” or “as-applied”) must not exceed 0.10 kg HAP per must not exceed 0.10 kg HAP per liter solids for existing sources, liter solids for existing sources, determined monthly.determined monthly.

Options (Cont’d.)Options (Cont’d.)

• New sources with an approved New sources with an approved emissions limit must emit no more emissions limit must emit no more than 0.094 kg HAP per liter solids than 0.094 kg HAP per liter solids determined monthlydetermined monthly

• Each thinner and cleaning material Each thinner and cleaning material must contain no organic HAPmust contain no organic HAP

Options (cont’d.)Options (cont’d.)

Emission Rate Without Add-on Emission Rate Without Add-on Controls:Controls:• The monthly organic HAP emission The monthly organic HAP emission

rate for coatings (including rate for coatings (including adhesives), thinners, and cleaning adhesives), thinners, and cleaning materials must not exceed 0.10 kg materials must not exceed 0.10 kg HAP per liter solids for existing HAP per liter solids for existing sourcessources

Options (cont’d.)Options (cont’d.)

• 0.094 kg HAP per liter solids for new 0.094 kg HAP per liter solids for new sources with approval for an sources with approval for an alternative emission limitalternative emission limit

• New sources without approval for an New sources without approval for an alternative emission limit must emit alternative emission limit must emit no organic HAPno organic HAP

Options (cont’d.)Options (cont’d.)

Emission Rate With Add-on Controls:Emission Rate With Add-on Controls:• The monthly organic HAP emission The monthly organic HAP emission

rate from coatings, thinners, and rate from coatings, thinners, and cleaning materials (including the cleaning materials (including the emission capture and control emission capture and control efficiency) must not exceed 0.10 kg efficiency) must not exceed 0.10 kg HAP per liter solids for existing HAP per liter solids for existing sourcessources

Options (cont’d.)Options (cont’d.)

• 0.094 kg HAP per liter solids for 0.094 kg HAP per liter solids for new sources with an approval for new sources with an approval for an alternative emission limitan alternative emission limit

• New sources without an approval New sources without an approval for an alternative emission limit for an alternative emission limit must emit no organic HAPmust emit no organic HAP

TIMELINETIMELINE

Records [§63.4930 and Records [§63.4930 and §63.4931]§63.4931]

An affected facility is required to keep An affected facility is required to keep records of reported information and records of reported information and all the other information necessary to all the other information necessary to document compliance with the document compliance with the proposed rule for 5 yearsproposed rule for 5 years

There may be additional requirements There may be additional requirements depending on the compliance option depending on the compliance option that is chosenthat is chosen

Title V ConnectTitle V Connect

Check Facilities that have Federally Check Facilities that have Federally Enforceable LimitsEnforceable LimitsLimited number of Major Facilities; Limited number of Major Facilities; who are they?who are they?Section 112j, T5 connection (<>3 Section 112j, T5 connection (<>3 years on T5 Permityears on T5 PermitSection 112j is no longer factor on Section 112j is no longer factor on surface coaterssurface coaters

Title V IssuesTitle V Issues

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

TITLE V (cont’d.)TITLE V (cont’d.)

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

TITLE V (cont’d.)TITLE V (cont’d.)

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

TITLE V (cont’d.)TITLE V (cont’d.)

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

Title V Compliance Title V Compliance Report ExampleReport Example

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

NESHAP Control NESHAP Control RequirementsRequirements

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

SSM PLANSSSM PLANS Only facilities that use add-on control Only facilities that use add-on control

devices to comply with the standard devices to comply with the standard must complete an SSM Planmust complete an SSM Plan

Data CollectionData Collection Supplier information on Supplier information on

delivered/stored coatings, adhesives, delivered/stored coatings, adhesives, thinners and cleaning materialsthinners and cleaning materials

Section 112j Section 112j ImplicationsImplications

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

SURFACE COATING SURFACE COATING ALTERNATIVESALTERNATIVES

Any option for surface coating needs?Any option for surface coating needs?• The facility can determine a compliant The facility can determine a compliant

material option by demonstrating that material option by demonstrating that the organic HAP content of each the organic HAP content of each coating used in the coating operations coating used in the coating operations is less than or equal to the applicable is less than or equal to the applicable emission rate limit in emission rate limit in 63.489063.4890 and that and that each thinner and each cleaning each thinner and each cleaning material used contains no organic HAP.material used contains no organic HAP.

Compliance ExamplesCompliance Examples

Combination HAP/no-HAP organic Combination HAP/no-HAP organic solidssolids

Handling cleaning materials and Handling cleaning materials and production materialsproduction materials

Pollution Prevention Pollution Prevention OptionsOptions

Remove HAP organic solids from Remove HAP organic solids from formulationformulation

Application equipment design; Application equipment design; state-of-the-artstate-of-the-art

Powder Coat TechnologyPowder Coat Technology