METAL COIL SURFACE METAL COIL SURFACE COATING MACT FACILITY COATING MACT FACILITY

INSPECTIONSINSPECTIONS

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART SSSSSSSS

May, 2006May, 2006

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART SSSSSSSS

May, 2006May, 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 (cont’d.)Applicability (cont’d.)

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 (cont’d.)Applicability (cont’d.)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.

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 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 Effected Inspections at Effected SourcesSources

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

(Cont’d. on next slide)(Cont’d. on next slide)

Inspections at Effected Inspections at Effected Sources (Cont’d.)Sources (Cont’d.)

Work Practice Requirements Work Practice Requirements Emission LimitsEmission LimitsDetermination of Mass Fraction of Determination of Mass Fraction of

organic HAP density volume organic HAP density volume used used

OtherOther

What emission standards What emission standards must an effected source must an effected source follow? follow? [§63.5120][§63.5120]

If you are an existing or new source, If you are an existing or new source, limit your organic HAP emissions to limit your organic HAP emissions to no more than . . .no more than . . .

Option 1…2% of the organic HAP Option 1…2% of the organic HAP applied during each month during the applied during each month during the 12-month compliance period (98% 12-month compliance period (98% reduction)reduction)

If you are an existing or new source, If you are an existing or new source, limit your organic HAP emissions to limit your organic HAP emissions to no more than . . .no more than . . .

Option 1…2% of the organic HAP Option 1…2% of the organic HAP applied during each month during the applied during each month during the 12-month compliance period (98% 12-month compliance period (98% reduction)reduction)

What emission standards What emission standards must an effected source must an effected source follow? (Cont’d.)follow? (Cont’d.) Option 2…0.046 kg organic HAP/liter Option 2…0.046 kg organic HAP/liter

coating solids applied during each 12-coating solids applied during each 12-month compliance periodmonth compliance period

Option 3…20 parts per million by Option 3…20 parts per million by volume on a dry basis when an volume on a dry basis when an oxidizer is used in combination with a oxidizer is used in combination with a capture system that achieves 100% capture system that achieves 100% capturecapture

Option 2…0.046 kg organic HAP/liter Option 2…0.046 kg organic HAP/liter coating solids applied during each 12-coating solids applied during each 12-month compliance periodmonth compliance period

Option 3…20 parts per million by Option 3…20 parts per million by volume on a dry basis when an volume on a dry basis when an oxidizer is used in combination with a oxidizer is used in combination with a capture system that achieves 100% capture system that achieves 100% capturecapture

Inspections at Affected Inspections at Affected SourcesSources

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 SystemsTypical Control Systems

Thermal OxidizersThermal Oxidizers

Carbon AdsorbersCarbon Adsorbers

Solvent RecoverySolvent Recovery

Emission Capture SystemsEmission Capture Systems

Thermal OxidizersThermal Oxidizers

Carbon AdsorbersCarbon Adsorbers

Solvent RecoverySolvent Recovery

Emission Capture SystemsEmission Capture Systems

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

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

Pre-Inspection Pre-Inspection ProceduresProcedures

File ReviewFile ReviewMACT Initial Notification ReportMACT Initial Notification ReportInitial Compliance Status ReportInitial Compliance Status ReportPerformance Test Report including Performance Test Report including capturecapture

File ReviewFile ReviewMACT Initial Notification ReportMACT Initial Notification ReportInitial Compliance Status ReportInitial Compliance Status ReportPerformance Test Report including Performance Test Report including capturecapture

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

Continuing Compliance ReportContinuing Compliance ReportTitle V ReportsTitle V ReportsVOC/HAP reduction through VOC/HAP reduction through NSPS/MACT implementationNSPS/MACT implementation

Regulation ReviewRegulation ReviewEquipment ChecksEquipment Checks

Facility File ReviewFacility File Review

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

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

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

Compliance test dataCompliance test data Equipment Malfunction reportsEquipment Malfunction reports SSM Plan and any eventsSSM Plan and any events Permit to construct P/C and permit Permit to construct P/C and permit

to operate P/Oto operate P/O Collection and control system design Collection and control system design

planplan

Compliance test dataCompliance test data Equipment Malfunction reportsEquipment Malfunction reports SSM Plan and any eventsSSM Plan and any events Permit to construct P/C and permit Permit to construct P/C and permit

to operate P/Oto operate P/O Collection and control system design Collection and control system design

planplan

Pre-Inspection Pre-Inspection MeetingMeeting

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

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 compliance rules based on the type of compliance demonstration 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 compliance rules based on the type of compliance demonstration demonstration

Discuss any additional identified Discuss any additional identified issuesissues

Inspection/Documentation Inspection/Documentation ReportReport

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 and Assessment of fugitive emissions and potential impactspotential 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 and Assessment of fugitive emissions and potential impactspotential impacts