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

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

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Page 1: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

METAL COIL SURFACE COATING MACT

OVERVIEW

40 CFR PART 63, SUBPART SSSS40 CFR PART 63, SUBPART SSSS

May 2006May 2006

40 CFR PART 63, SUBPART SSSS40 CFR PART 63, SUBPART SSSS

May 2006May 2006

Page 2: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

INTRODUCTION

On June 02, 2002, USEPA On June 02, 2002, USEPA promulgated the Federal standard, promulgated the Federal standard, METAL COIL SURFACE COATING METAL COIL SURFACE COATING NESHAP (National Emission Standards NESHAP (National Emission Standards for Hazardous Air Pollutants) 40 CFR for Hazardous Air Pollutants) 40 CFR Part 63, Subpart SSSS in the Federal Part 63, Subpart SSSS in the Federal Register; 67 FR 39794.Register; 67 FR 39794.

On June 02, 2002, USEPA On June 02, 2002, USEPA promulgated the Federal standard, promulgated the Federal standard, METAL COIL SURFACE COATING METAL COIL SURFACE COATING NESHAP (National Emission Standards NESHAP (National Emission Standards for Hazardous Air Pollutants) 40 CFR for Hazardous Air Pollutants) 40 CFR Part 63, Subpart SSSS in the Federal Part 63, Subpart SSSS in the Federal Register; 67 FR 39794.Register; 67 FR 39794.

Page 3: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

What we are reviewing? Rule applicabilityRule applicability

NSR,NSPS & NESHAP focusNSR,NSPS & NESHAP focus Covered operationsCovered operations Operations not coveredOperations not covered

Rule applicabilityRule applicability NSR,NSPS & NESHAP focusNSR,NSPS & NESHAP focus Covered operationsCovered operations Operations not coveredOperations not covered

Page 4: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Review (Cont’d.)

Standards to be followed, including Standards to be followed, including work practice standardswork practice standards

Operating Limits Operating Limits Important datesImportant dates Synthetic minor sourcesSynthetic minor sources

Standards to be followed, including Standards to be followed, including work practice standardswork practice standards

Operating Limits Operating Limits Important datesImportant dates Synthetic minor sourcesSynthetic minor sources

Page 5: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Review (cont’d.)

New or existing source New or existing source determinationdetermination

General rule requirementsGeneral rule requirements Initial compliance demonstration Initial compliance demonstration Notification, Recordkeeping and Notification, Recordkeeping and

Reporting requirementsReporting requirements Compliance optionsCompliance options Compliance examplesCompliance examples

New or existing source New or existing source determinationdetermination

General rule requirementsGeneral rule requirements Initial compliance demonstration Initial compliance demonstration Notification, Recordkeeping and Notification, Recordkeeping and

Reporting requirementsReporting requirements Compliance optionsCompliance options Compliance examplesCompliance examples

Page 6: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Review (cont’d.)

Facility Inspection ProtocolFacility Inspection Protocol Pre-Inspection ReviewPre-Inspection Review Facility File ReviewFacility File Review Facility InspectionFacility Inspection Post-Inspection MeetingPost-Inspection Meeting Follow-upFollow-up

Frequently asked questionsFrequently asked questions

Facility Inspection ProtocolFacility Inspection Protocol Pre-Inspection ReviewPre-Inspection Review Facility File ReviewFacility File Review Facility InspectionFacility Inspection Post-Inspection MeetingPost-Inspection Meeting Follow-upFollow-up

Frequently asked questionsFrequently asked questions

Page 7: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

APPLICABILITY: Who is covered by this rule? (Subpart SSSS, §63.5090)

Own or operate an Own or operate an EFFECTED EFFECTED SOURCESOURCE at a facility that is a major at a facility that is a major source,source,

Located at a major source, orLocated at a major source, or Part of a major source of hazardous air Part of a major source of hazardous air

pollutants (HAPs),pollutants (HAPs), NSPS for NSPS for NEWNEW sources of VOC sources of VOC

Own or operate an Own or operate an EFFECTED EFFECTED SOURCESOURCE at a facility that is a major at a facility that is a major source,source,

Located at a major source, orLocated at a major source, or Part of a major source of hazardous air Part of a major source of hazardous air

pollutants (HAPs),pollutants (HAPs), NSPS for NSPS for NEWNEW sources of VOC sources of VOC

Page 8: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Effected Source

All coating operations;All coating operations; Web unwind or feed stationsWeb unwind or feed stations Wet sectionWet section Coating application stationsCoating application stations Curing ovens & Quench stationCuring ovens & Quench station

All coating operations;All coating operations; Web unwind or feed stationsWeb unwind or feed stations Wet sectionWet section Coating application stationsCoating application stations Curing ovens & Quench stationCuring ovens & Quench station

Page 9: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Effected Source (cont’d.) NSPS; COATING operations NSPS; COATING operations

involve VOCsinvolve VOCs NESHAP similar definition; NESHAP similar definition; VOCs vs VOHAPs; similar VOCs vs VOHAPs; similar

criteria and an increase in criteria and an increase in stringencystringency

NSPS; COATING operations NSPS; COATING operations involve VOCsinvolve VOCs

NESHAP similar definition; NESHAP similar definition; VOCs vs VOHAPs; similar VOCs vs VOHAPs; similar

criteria and an increase in criteria and an increase in stringencystringency

Page 10: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Effected Source (cont’d.) Any Any new or reconstructednew or reconstructed source (as source (as

defined in defined in § 63.2) § 63.2) before July 18, before July 18, 20002000 is an existing facility and, is an existing facility and, that is a major source and is a that is a major source and is a

Metal Coil Surface Coating facilityMetal Coil Surface Coating facility Any Any new or reconstructednew or reconstructed source source

after July 18, 2000after July 18, 2000 is a new source. is a new source.

Any Any new or reconstructednew or reconstructed source (as source (as defined in defined in § 63.2) § 63.2) before July 18, before July 18, 20002000 is an existing facility and, is an existing facility and, that is a major source and is a that is a major source and is a

Metal Coil Surface Coating facilityMetal Coil Surface Coating facility Any Any new or reconstructednew or reconstructed source source

after July 18, 2000after July 18, 2000 is a new source. is a new source.

Page 11: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

What are Some Operations’ Emissions Impacted by Subpart SSSS?

An effected source is the collection An effected source is the collection of all the metal coil coating lines at of all the metal coil coating lines at the source.the source.

Coil coating lines are the collection Coil coating lines are the collection of equipment used to apply an of equipment used to apply an organic coating to the surface of a organic coating to the surface of a metal coil.metal coil.

An effected source is the collection An effected source is the collection of all the metal coil coating lines at of all the metal coil coating lines at the source.the source.

Coil coating lines are the collection Coil coating lines are the collection of equipment used to apply an of equipment used to apply an organic coating to the surface of a organic coating to the surface of a metal coil.metal coil.

Page 12: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

What are Some Operations’ Emissions Impacted by Subpart SSSS (Cont’d.)? Coating lines include web unwind Coating lines include web unwind

or feed stations, wet section, or feed stations, wet section, coating application stations, curing coating application stations, curing ovens, and quench station.ovens, and quench station.

Coating lines include web unwind Coating lines include web unwind or feed stations, wet section, or feed stations, wet section, coating application stations, curing coating application stations, curing ovens, and quench station.ovens, and quench station.

Page 13: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

What are Some Operations’ Emissions Impacted by Subpart SSSS (Cont’d.)?

A metal coil is a continuous metal A metal coil is a continuous metal strip that is at least 0.15 mm(0.006 strip that is at least 0.15 mm(0.006 in) thick and is packaged in a roll or in) thick and is packaged in a roll or coil prior to coating, but does not coil prior to coating, but does not include metal webs that are coated include metal webs that are coated for use in flexible packaging.for use in flexible packaging.

A metal coil is a continuous metal A metal coil is a continuous metal strip that is at least 0.15 mm(0.006 strip that is at least 0.15 mm(0.006 in) thick and is packaged in a roll or in) thick and is packaged in a roll or coil prior to coating, but does not coil prior to coating, but does not include metal webs that are coated include metal webs that are coated for use in flexible packaging.for use in flexible packaging.

Page 14: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

METAL COIL Operations Examples (cont’d.) USEPA Applicability USEPA Applicability

Determination Index SiteDetermination Index Site

http://www.epa.gov/Compliance/planning/dathttp://www.epa.gov/Compliance/planning/data/air/adi.htma/air/adi.htm

USEPA Applicability USEPA Applicability Determination Index SiteDetermination Index Site

http://www.epa.gov/Compliance/planning/dathttp://www.epa.gov/Compliance/planning/data/air/adi.htma/air/adi.htm

Page 15: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Who is not covered by Subpart SSSS? (§§63.5090 & 63.5110)

The following sources are not The following sources are not covered under this rule:covered under this rule:

A coil coating line that is part A coil coating line that is part of research or laboratory of research or laboratory equipmentequipment

The following sources are not The following sources are not covered under this rule:covered under this rule:

A coil coating line that is part A coil coating line that is part of research or laboratory of research or laboratory equipmentequipment

Page 16: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Who is not covered? (Cont’d.)

A coil coating line on which 85% or A coil coating line on which 85% or more of the metal coated, based more of the metal coated, based upon surface area, is less than 0.16 upon surface area, is less than 0.16 millimeters (0.006 inch) thickmillimeters (0.006 inch) thickAncillary operations, such as cleaning, Ancillary operations, such as cleaning, coating mixing, thinning, and storage, coating mixing, thinning, and storage, and wastewater operationsand wastewater operations

A coil coating line on which 85% or A coil coating line on which 85% or more of the metal coated, based more of the metal coated, based upon surface area, is less than 0.16 upon surface area, is less than 0.16 millimeters (0.006 inch) thickmillimeters (0.006 inch) thickAncillary operations, such as cleaning, Ancillary operations, such as cleaning, coating mixing, thinning, and storage, coating mixing, thinning, and storage, and wastewater operationsand wastewater operations

Page 17: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Who is not covered? (Cont’d.)

Surface coating subject to any Surface coating subject to any other NESHAP in Part 63;other NESHAP in Part 63;

Janitorial or building and facility Janitorial or building and facility maintenance operations;maintenance operations;

Surface coating subject to any Surface coating subject to any other NESHAP in Part 63;other NESHAP in Part 63;

Janitorial or building and facility Janitorial or building and facility maintenance operations;maintenance operations;

Page 18: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

What Standards Require Compliance? (63.5120)

If the effected source is existing If the effected source is existing OROR newnew

HAP emissions are limited to no more HAP emissions are limited to no more than…than…

OPTION 1:OPTION 1:• 2% of the organic HAP applied 2% of the organic HAP applied

during each month of the 12-during each month of the 12-month compliance period (98% month compliance period (98% reduction)reduction)

If the effected source is existing If the effected source is existing OROR newnew

HAP emissions are limited to no more HAP emissions are limited to no more than…than…

OPTION 1:OPTION 1:• 2% of the organic HAP applied 2% of the organic HAP applied

during each month of the 12-during each month of the 12-month compliance period (98% month compliance period (98% reduction)reduction)

Page 19: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

What Standards Require Compliance? (63.5120) Cont’d.

OPTION 2 & 4:OPTION 2 & 4:• 0.046kg organic HAP/liter 0.046kg organic HAP/liter

coating solids applied during coating solids applied during each 12-month compliance each 12-month compliance periodperiod

OPTION 2 & 4:OPTION 2 & 4:• 0.046kg organic HAP/liter 0.046kg organic HAP/liter

coating solids applied during coating solids applied during each 12-month compliance each 12-month compliance periodperiod

Page 20: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

What Standards Require Compliance? (63.5120) Cont’d.

OPTION 3:OPTION 3:20 parts per million by volume 20 parts per million by volume

on a dry basis when an oxidizer on a dry basis when an oxidizer is used in combination with a is used in combination with a capture system that achieves capture system that achieves 100% capture100% capture

OPTION 3:OPTION 3:20 parts per million by volume 20 parts per million by volume

on a dry basis when an oxidizer on a dry basis when an oxidizer is used in combination with a is used in combination with a capture system that achieves capture system that achieves 100% capture100% capture

Page 21: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Options

The effected source may apply any The effected source may apply any of the compliance options to an of the compliance options to an individual coil coating line, or individual coil coating line, or

to multiple lines as a group, or to multiple lines as a group, or to the entire affected source. to the entire affected source.

The effected source may apply any The effected source may apply any of the compliance options to an of the compliance options to an individual coil coating line, or individual coil coating line, or

to multiple lines as a group, or to multiple lines as a group, or to the entire affected source. to the entire affected source.

Page 22: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Options (cont’d.) The effected source may use The effected source may use

different compliance options for different compliance options for different coil coating lines, ordifferent coil coating lines, or

At different times on the same line.At different times on the same line.

The effected source may use The effected source may use different compliance options for different compliance options for different coil coating lines, ordifferent coil coating lines, or

At different times on the same line.At different times on the same line.

Page 23: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Options (cont’d.)

However, the source may not use However, the source may not use different compliance options at the different compliance options at the same time on the same coil coating same time on the same coil coating line. line.

If the source switches between If the source switches between compliance options for any coil compliance options for any coil coating line or group of lines, you coating line or group of lines, you must document this switch as must document this switch as required by required by § 63.5190(a),§ 63.5190(a), and and

However, the source may not use However, the source may not use different compliance options at the different compliance options at the same time on the same coil coating same time on the same coil coating line. line.

If the source switches between If the source switches between compliance options for any coil compliance options for any coil coating line or group of lines, you coating line or group of lines, you must document this switch as must document this switch as required by required by § 63.5190(a),§ 63.5190(a), and and

Page 24: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Options (cont’d.)

The source must report it in the The source must report it in the next semiannual compliance report next semiannual compliance report required inrequired in§ 63.5180.§ 63.5180.

The source must report it in the The source must report it in the next semiannual compliance report next semiannual compliance report required inrequired in§ 63.5180.§ 63.5180.

Page 25: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Operating Limits Operating limits are the site-specific Operating limits are the site-specific

parameter limits determined by the parameter limits determined by the capture and control devices during capture and control devices during the performance test.the performance test.

The source operating limits must be The source operating limits must be monitored by a continuous monitored by a continuous parameter monitoring system parameter monitoring system (CPMS)(CPMS)

Operating limits are the site-specific Operating limits are the site-specific parameter limits determined by the parameter limits determined by the capture and control devices during capture and control devices during the performance test.the performance test.

The source operating limits must be The source operating limits must be monitored by a continuous monitored by a continuous parameter monitoring system parameter monitoring system (CPMS)(CPMS)

Page 26: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Important dates

The final rule was published on The final rule was published on June 10, 2002, under 67 FR June 10, 2002, under 67 FR 39794,39794,

The final rule was published on The final rule was published on June 10, 2002, under 67 FR June 10, 2002, under 67 FR 39794,39794,

Page 27: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Important dates (cont’d.)

Existing major sources Existing major sources ((ON OR ON OR BEFOREBEFORE July 18, 2000 ) July 18, 2000 ) must comply must comply with:with: Emissions limitations;Emissions limitations; Operation & Maintenance Operation & Maintenance

requirement;requirement; Major source status determination;Major source status determination;

no later than, June 10, 2005.no later than, June 10, 2005.

Existing major sources Existing major sources ((ON OR ON OR BEFOREBEFORE July 18, 2000 ) July 18, 2000 ) must comply must comply with:with: Emissions limitations;Emissions limitations; Operation & Maintenance Operation & Maintenance

requirement;requirement; Major source status determination;Major source status determination;

no later than, June 10, 2005.no later than, June 10, 2005.

Page 28: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Important Dates (cont’d.) New effected sources operating after New effected sources operating after

July, 18, 2000, must comply with the July, 18, 2000, must comply with the regulatory requirements by June 10, regulatory requirements by June 10, 2002 or upon initial startup of the 2002 or upon initial startup of the effected sources whichever is later. effected sources whichever is later.

New effected sources operating after New effected sources operating after July, 18, 2000, must comply with the July, 18, 2000, must comply with the regulatory requirements by June 10, regulatory requirements by June 10, 2002 or upon initial startup of the 2002 or upon initial startup of the effected sources whichever is later. effected sources whichever is later.

Page 29: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Important dates (cont’d.) If the METAL COIL COATING FACILITY If the METAL COIL COATING FACILITY

is an area source, but becomes a is an area source, but becomes a major source of HAP, compliance of major source of HAP, compliance of § 63.5130§ 63.5130 upon startup. upon startup.

If the METAL COIL COATING FACILITY If the METAL COIL COATING FACILITY is an area source, but becomes a is an area source, but becomes a major source of HAP, compliance of major source of HAP, compliance of § 63.5130§ 63.5130 upon startup. upon startup.

Page 30: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Important dates (cont’d.) The effected sources must meet the The effected sources must meet the

notification and scheduling notification and scheduling requirements in requirements in § 63.5180§ 63.5180

Some of these notifications must be Some of these notifications must be submitted before the effected submitted before the effected source compliance date.source compliance date.

The effected sources must meet the The effected sources must meet the notification and scheduling notification and scheduling requirements in requirements in § 63.5180§ 63.5180

Some of these notifications must be Some of these notifications must be submitted before the effected submitted before the effected source compliance date.source compliance date.

Page 31: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Operations & Maintenance Requirements (§63.5180)

Effected facilities must operate and Effected facilities must operate and maintain the sources, including air maintain the sources, including air pollution control and monitoring pollution control and monitoring equipment in a manner consistent equipment in a manner consistent with good air pollution practices that with good air pollution practices that minimizes air emissions to the level minimizes air emissions to the level required in Subpart SSSS.required in Subpart SSSS.

Effected facilities must operate and Effected facilities must operate and maintain the sources, including air maintain the sources, including air pollution control and monitoring pollution control and monitoring equipment in a manner consistent equipment in a manner consistent with good air pollution practices that with good air pollution practices that minimizes air emissions to the level minimizes air emissions to the level required in Subpart SSSS.required in Subpart SSSS.

Page 32: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Operations & Maintenance Requirements (§63.5180) (Cont’d.) Effected sources must prepare and Effected sources must prepare and

operate at all times according to a operate at all times according to a written operation and maintenance written operation and maintenance plan for each capture and collection plan for each capture and collection control device controlling emissions control device controlling emissions subject to Subpart SSSS.subject to Subpart SSSS.

Effected sources must prepare and Effected sources must prepare and operate at all times according to a operate at all times according to a written operation and maintenance written operation and maintenance plan for each capture and collection plan for each capture and collection control device controlling emissions control device controlling emissions subject to Subpart SSSS.subject to Subpart SSSS.

Page 33: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

Operations & Maintenance Requirements (§63.5180) (Cont’d.)

Each plan must contain the Each plan must contain the elements required in §63.6(e) of the elements required in §63.6(e) of the General Provisions. General Provisions.

Each plan must contain the Each plan must contain the elements required in §63.6(e) of the elements required in §63.6(e) of the General Provisions. General Provisions.

Page 34: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

General Compliance Requirements (§63.5170) The effected source must be in The effected source must be in

compliance with the:compliance with the:emissions standardsemissions standardsOperating limitsOperating limitsOperations and maintenance Operations and maintenance

program;program;

The effected source must be in The effected source must be in compliance with the:compliance with the:emissions standardsemissions standardsOperating limitsOperating limitsOperations and maintenance Operations and maintenance

program;program;

Page 35: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

General Compliance (Cont’d.)

Maintain a log detailing the Maintain a log detailing the operation and maintenance of the operation and maintenance of the process and emissions control process and emissions control equipment related to the initial equipment related to the initial performance test and the applicable performance test and the applicable operating limits for a effected operating limits for a effected sourcesource

Maintain a log detailing the Maintain a log detailing the operation and maintenance of the operation and maintenance of the process and emissions control process and emissions control equipment related to the initial equipment related to the initial performance test and the applicable performance test and the applicable operating limits for a effected operating limits for a effected sourcesource

Page 36: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

General Compliance (cont’d.) The source may comply with the The source may comply with the

emission limits by completing any emission limits by completing any of the following:of the following: Compliant Material Option,Compliant Material Option,

Each coating used must not Each coating used must not exceed the HAP limit in Options exceed the HAP limit in Options 1,2,3 & 4;1,2,3 & 4;

Determined each month for the Determined each month for the sub-category during the 12-month sub-category during the 12-month compliance period.compliance period.

The source may comply with the The source may comply with the emission limits by completing any emission limits by completing any of the following:of the following: Compliant Material Option,Compliant Material Option,

Each coating used must not Each coating used must not exceed the HAP limit in Options exceed the HAP limit in Options 1,2,3 & 4;1,2,3 & 4;

Determined each month for the Determined each month for the sub-category during the 12-month sub-category during the 12-month compliance period.compliance period.

Page 37: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

General Compliance (cont’d.)

Emission Rate With Add-on Emission Rate With Add-on Controls,Controls,The organic HAP emission The organic HAP emission rate, calculated as a 12-rate, calculated as a 12-month rolling average on a month rolling average on a monthly basis;monthly basis;

Emission Rate With Add-on Emission Rate With Add-on Controls,Controls,The organic HAP emission The organic HAP emission rate, calculated as a 12-rate, calculated as a 12-month rolling average on a month rolling average on a monthly basis;monthly basis;

Page 38: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

General Compliance (cont’d.)

For coatings and thinners For coatings and thinners (including emission capture (including emission capture and control efficiency)and control efficiency)

Must not exceed the HAP Must not exceed the HAP limits in OPTION.limits in OPTION.

For coatings and thinners For coatings and thinners (including emission capture (including emission capture and control efficiency)and control efficiency)

Must not exceed the HAP Must not exceed the HAP limits in OPTION.limits in OPTION.

Page 39: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

General Compliance (cont’d.)

Control Efficiency/Outlet Control Efficiency/Outlet Concentration OptionConcentration OptionHAP emissions must be HAP emissions must be reduced by an overall reduced by an overall control efficiency of at least control efficiency of at least 98%98%

For new and reconstructed For new and reconstructed sources, andsources, and

Control Efficiency/Outlet Control Efficiency/Outlet Concentration OptionConcentration OptionHAP emissions must be HAP emissions must be reduced by an overall reduced by an overall control efficiency of at least control efficiency of at least 98%98%

For new and reconstructed For new and reconstructed sources, andsources, and

Page 40: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

General Compliance (cont’d.)

The outlet organic HAP The outlet organic HAP concentration must be no concentration must be no greatergreater

Than 20 parts per million Than 20 parts per million (ppm) by volume on a dry (ppm) by volume on a dry basis.basis.

The outlet organic HAP The outlet organic HAP concentration must be no concentration must be no greatergreater

Than 20 parts per million Than 20 parts per million (ppm) by volume on a dry (ppm) by volume on a dry basis.basis.

Page 41: METAL COIL SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART SSSS May 2006 40 CFR PART 63, SUBPART SSSS May 2006

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

Requirements (§63.5180)Requirements (§63.5180) Additional Performance Test Additional Performance Test

Requirements (§63.5180)Requirements (§63.5180)

Initial Compliance Initial Compliance Requirements (§63.5180)Requirements (§63.5180)

Additional Performance Test Additional Performance Test Requirements (§63.5180)Requirements (§63.5180)

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Compliance Calculations (§63.5170) For Compliance Options #1, #2 For Compliance Options #1, #2

and #4, the collected data for and #4, the collected data for regulated materials are used to regulated materials are used to calculate the organic HAPcalculate the organic HAPContent of each material used Content of each material used

during the 12-month rolling during the 12-month rolling average compliance period.average compliance period.

For Compliance Options #1, #2 For Compliance Options #1, #2 and #4, the collected data for and #4, the collected data for regulated materials are used to regulated materials are used to calculate the organic HAPcalculate the organic HAPContent of each material used Content of each material used

during the 12-month rolling during the 12-month rolling average compliance period.average compliance period.

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Compliance Calculations (cont’d.)

For Compliance Options # 3, For Compliance Options # 3, and #4, the source must and #4, the source must calculate the overall organic calculate the overall organic HAP control efficiency of the HAP control efficiency of the add-on controls.add-on controls.

For Compliance Options # 3, For Compliance Options # 3, and #4, the source must and #4, the source must calculate the overall organic calculate the overall organic HAP control efficiency of the HAP control efficiency of the add-on controls.add-on controls.

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Compliance Calculations (cont’d.)

For Compliance Option #4, an For Compliance Option #4, an organic HAP emission rate for organic HAP emission rate for the 12-month rolling average the 12-month rolling average compliance period must be compliance period must be calculated.calculated.

For Compliance Option #4, an For Compliance Option #4, an organic HAP emission rate for organic HAP emission rate for the 12-month rolling average the 12-month rolling average compliance period must be compliance period must be calculated.calculated.

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Test Methods Subpart SSSS clearly defines Subpart SSSS clearly defines

the test methods and other the test methods and other procedures in procedures in the rulethe ruleThese methods are used to These methods are used to demonstrate initial demonstrate initial compliance with the compliance with the emissions limitationsemissions limitations

Subpart SSSS clearly defines Subpart SSSS clearly defines the test methods and other the test methods and other procedures in procedures in the rulethe ruleThese methods are used to These methods are used to demonstrate initial demonstrate initial compliance with the compliance with the emissions limitationsemissions limitations

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Test Methods (Cont’d.)

Typically, for each capture Typically, for each capture system that is a PTE, the data system that is a PTE, the data and documentation the source and documentation the source uses to support uses to support

Typically, for each capture Typically, for each capture system that is a PTE, the data system that is a PTE, the data and documentation the source and documentation the source uses to support uses to support

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Test Methods (cont’d.)A determination that the capture A determination that the capture

system meets the criteria in system meets the criteria in Method 204A, and Method 204A, and

Additional methods 24 and 25 as Additional methods 24 and 25 as specified in specified in §63.5150, 5160 and §63.5150, 5160 and outlined in 40CFR part 60 and outlined in 40CFR part 60 and 51.51.

A determination that the capture A determination that the capture system meets the criteria in system meets the criteria in Method 204A, and Method 204A, and

Additional methods 24 and 25 as Additional methods 24 and 25 as specified in specified in §63.5150, 5160 and §63.5150, 5160 and outlined in 40CFR part 60 and outlined in 40CFR part 60 and 51.51.

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Test Methods (cont’d.)

The rule provides the The rule provides the necessary test methods and necessary test methods and procedures for an effected procedures for an effected source’s HAP control device to source’s HAP control device to comply with Subpart SSSS.comply with Subpart SSSS.

The rule provides the The rule provides the necessary test methods and necessary test methods and procedures for an effected procedures for an effected source’s HAP control device to source’s HAP control device to comply with Subpart SSSS.comply with Subpart SSSS.