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METAL COIL SURFACE METAL COIL SURFACE COATING MACT COATING MACT
QUESTION & ANSWERSQUESTION & ANSWERS
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
Questions/AnswersQuestions/Answers#1#1
Q.Q. If the facility builds a new If the facility builds a new building next to a current building next to a current building, does the new building building, does the new building become a new source?become a new source?
Q.Q. If the facility builds a new If the facility builds a new building next to a current building next to a current building, does the new building building, does the new building become a new source?become a new source?
Questions/AnswersQuestions/Answers#1#1
A.A. The best source to answer this The best source to answer this question is the facility’s question is the facility’s permitting authority because permitting authority because the decision may rest on site-the decision may rest on site-specific factors.specific factors.
A.A. The best source to answer this The best source to answer this question is the facility’s question is the facility’s permitting authority because permitting authority because the decision may rest on site-the decision may rest on site-specific factors.specific factors.
Q/A #2Q/A #2
Q.Q. If an effected source is using If an effected source is using an add-on control device, an add-on control device, such as an oxidizer to comply such as an oxidizer to comply with the rule, is a with the rule, is a performance test necessary?performance test necessary?
Q.Q. If an effected source is using If an effected source is using an add-on control device, an add-on control device, such as an oxidizer to comply such as an oxidizer to comply with the rule, is a with the rule, is a performance test necessary?performance test necessary?
Q/A #2Q/A #2
A.A. If an add-on control device is used If an add-on control device is used by the effected source, the source by the effected source, the source must conduct a performance test must conduct a performance test to establish the destruction or to establish the destruction or removal efficiency of the control removal efficiency of the control device or the outlet HAP device or the outlet HAP concentration achieved by the concentration achieved by the device, according to methods and device, according to methods and procedures in procedures in §63.5160§63.5160
Q/A #3Q/A #3
Q.Q. For facilities that are complex or For facilities that are complex or collated with different coating collated with different coating operations, i.e. multiple surface operations, i.e. multiple surface coating operations; chromium and coating operations; chromium and organic HAP coatings, are any organic HAP coatings, are any consolidation options available to consolidation options available to compliance?compliance?
Q.Q. For facilities that are complex or For facilities that are complex or collated with different coating collated with different coating operations, i.e. multiple surface operations, i.e. multiple surface coating operations; chromium and coating operations; chromium and organic HAP coatings, are any organic HAP coatings, are any consolidation options available to consolidation options available to compliance?compliance?
Q/A #3Q/A #3
A.A. Section 112(d)(2) requires that all Section 112(d)(2) requires that all major sources within a major major sources within a major source category must meet source category must meet maximum emission reduction maximum emission reduction determined to be achievable. determined to be achievable. Therefore, due to the complexity of Therefore, due to the complexity of allowing such options, none are allowing such options, none are allowed in the rule, but c/c options allowed in the rule, but c/c options can be used on a c/c operation can be used on a c/c operation basis. This is particularly true basis. This is particularly true under the Title V process.under the Title V process.
A.A. Section 112(d)(2) requires that all Section 112(d)(2) requires that all major sources within a major major sources within a major source category must meet source category must meet maximum emission reduction maximum emission reduction determined to be achievable. determined to be achievable. Therefore, due to the complexity of Therefore, due to the complexity of allowing such options, none are allowing such options, none are allowed in the rule, but c/c options allowed in the rule, but c/c options can be used on a c/c operation can be used on a c/c operation basis. This is particularly true basis. This is particularly true under the Title V process.under the Title V process.
Q/A #4Q/A #4
Q.Q. Does a metal coil coating facility Does a metal coil coating facility have to comply with the emission have to comply with the emission limitations during periods of limitations during periods of startup, shutdown and startup, shutdown and malfunction?malfunction?
Q.Q. Does a metal coil coating facility Does a metal coil coating facility have to comply with the emission have to comply with the emission limitations during periods of limitations during periods of startup, shutdown and startup, shutdown and malfunction?malfunction?
Q/A #4Q/A #4
A.A. The effected facility must be in The effected facility must be in compliance with the emissions compliance with the emissions limitations, work practice limitations, work practice standards, and operation and standards, and operation and maintenance requirements in maintenance requirements in Subpart SSSS at all times.Subpart SSSS at all times.
A.A. The effected facility must be in The effected facility must be in compliance with the emissions compliance with the emissions limitations, work practice limitations, work practice standards, and operation and standards, and operation and maintenance requirements in maintenance requirements in Subpart SSSS at all times.Subpart SSSS at all times.
Q/A #5Q/A #5
Q.Q. Does a Subpart SSSS affected Does a Subpart SSSS affected facility have to comply with facility have to comply with NSPS requirements?NSPS requirements?
Q.Q. Does a Subpart SSSS affected Does a Subpart SSSS affected facility have to comply with facility have to comply with NSPS requirements?NSPS requirements?
Q/A #5Q/A #5
A.A. Since the NESHAP and NSPS Since the NESHAP and NSPS regulations focus on different regulations focus on different aspects of an affected facility, aspects of an affected facility, organic VOCs, compliance must organic VOCs, compliance must be achieved with both be achieved with both regulations.regulations.
Q/A #6Q/A #6
Q.Q. What are the installation, What are the installation, operation and maintenance operation and maintenance requirements for the effected requirements for the effected source monitors?source monitors?
Q.Q. What are the installation, What are the installation, operation and maintenance operation and maintenance requirements for the effected requirements for the effected source monitors?source monitors?
Q/A #6Q/A #6
For each capture system that is For each capture system that is subject to Subpart SSSS, the subject to Subpart SSSS, the facility must install, operate, and facility must install, operate, and maintain each CPMS according to maintain each CPMS according to the requirements in the requirements in § 63.5150 § 63.5150 and63.5160.and63.5160.
For each capture system that is For each capture system that is subject to Subpart SSSS, the subject to Subpart SSSS, the facility must install, operate, and facility must install, operate, and maintain each CPMS according to maintain each CPMS according to the requirements in the requirements in § 63.5150 § 63.5150 and63.5160.and63.5160.
Q/A #7Q/A #7
Q.Q. How does the facility How does the facility demonstrate continuous demonstrate continuous compliance with the work compliance with the work practice standards that apply practice standards that apply to the effected source?to the effected source?
Q.Q. How does the facility How does the facility demonstrate continuous demonstrate continuous compliance with the work compliance with the work practice standards that apply practice standards that apply to the effected source?to the effected source?
Q/A #7Q/A #7
A.A. The facility must maintain The facility must maintain records that document records that document continuous compliance noted in continuous compliance noted in § 63.5170§ 63.5170
Q/A #8Q/A #8
Q.Q. What are the Health Effects What are the Health Effects Associated with HAP Emissions Associated with HAP Emissions From the Surface Coating of Metal From the Surface Coating of Metal Coil?Coil?
Q.Q. What are the Health Effects What are the Health Effects Associated with HAP Emissions Associated with HAP Emissions From the Surface Coating of Metal From the Surface Coating of Metal Coil?Coil?
Q/A #8Q/A #8
A.A. Ethylene glycol mono-butyl ether and other Ethylene glycol mono-butyl ether and other glycol ethers, xylenes, hexane, MEK and glycol ethers, xylenes, hexane, MEK and MIBK account for 95% of the nationwide MIBK account for 95% of the nationwide HAP emissions from the source category. HAP emissions from the source category. These HAPS are associated with a variety of These HAPS are associated with a variety of adverse health effects which include adverse health effects which include chronic health disorders (e.g., birth defects chronic health disorders (e.g., birth defects and effects on the central nervous system, and effects on the central nervous system, liver, and heart) and acute health disorders liver, and heart) and acute health disorders (e.g., irritation of the lung, skin, and (e.g., irritation of the lung, skin, and mucous membranes, effects on the central mucous membranes, effects on the central nervous system and possibly cancer.nervous system and possibly cancer.
A.A. Ethylene glycol mono-butyl ether and other Ethylene glycol mono-butyl ether and other glycol ethers, xylenes, hexane, MEK and glycol ethers, xylenes, hexane, MEK and MIBK account for 95% of the nationwide MIBK account for 95% of the nationwide HAP emissions from the source category. HAP emissions from the source category. These HAPS are associated with a variety of These HAPS are associated with a variety of adverse health effects which include adverse health effects which include chronic health disorders (e.g., birth defects chronic health disorders (e.g., birth defects and effects on the central nervous system, and effects on the central nervous system, liver, and heart) and acute health disorders liver, and heart) and acute health disorders (e.g., irritation of the lung, skin, and (e.g., irritation of the lung, skin, and mucous membranes, effects on the central mucous membranes, effects on the central nervous system and possibly cancer.nervous system and possibly cancer.
Q/A #9Q/A #9
Q.Q. Can a facility be considered in Can a facility be considered in compliance with the Initial compliance with the Initial Notification requirement if the Notification requirement if the facility had filed their Section 112J facility had filed their Section 112J notice on time?notice on time?
Q.Q. Can a facility be considered in Can a facility be considered in compliance with the Initial compliance with the Initial Notification requirement if the Notification requirement if the facility had filed their Section 112J facility had filed their Section 112J notice on time?notice on time?
Q/A #9Q/A #9
A.A. The Section 112J notice requires The Section 112J notice requires additional information above and additional information above and beyond the Initial Notification beyond the Initial Notification requirement. As such, the facility requirement. As such, the facility would be considered in compliance would be considered in compliance with the IN requirement and filing with the IN requirement and filing the Initial Notification would be the Initial Notification would be redundant.redundant.
A.A. The Section 112J notice requires The Section 112J notice requires additional information above and additional information above and beyond the Initial Notification beyond the Initial Notification requirement. As such, the facility requirement. As such, the facility would be considered in compliance would be considered in compliance with the IN requirement and filing with the IN requirement and filing the Initial Notification would be the Initial Notification would be redundant.redundant.
Q/A #10Q/A #10
Q.Q. What does a deviation from the What does a deviation from the rule mean?rule mean?
Q/A #10Q/A #10
A.A. Deviation means any instance in which Deviation means any instance in which an affected source fails to meet any an affected source fails to meet any obligations required by Subpart SSSS. obligations required by Subpart SSSS. This is not limited to any emissions This is not limited to any emissions limitation, work practice standard, or limitation, work practice standard, or operation and maintenance operation and maintenance requirement;requirement; (cont’d. on next slide) (cont’d. on next slide)
A.A. Deviation means any instance in which Deviation means any instance in which an affected source fails to meet any an affected source fails to meet any obligations required by Subpart SSSS. obligations required by Subpart SSSS. This is not limited to any emissions This is not limited to any emissions limitation, work practice standard, or limitation, work practice standard, or operation and maintenance operation and maintenance requirement;requirement; (cont’d. on next slide) (cont’d. on next slide)
Q/A #10Q/A #10
(Answer continued)(Answer continued)•The affected source fails to meet any The affected source fails to meet any
terms or conditions adopted to terms or conditions adopted to implement an applicable under Subpart implement an applicable under Subpart SSSSSSSS
•The affected source fails to meet The affected source fails to meet emissions limitations, including emissions limitations, including operating limits or work practice operating limits or work practice standards in this Subpart.standards in this Subpart.
Q/A #11Q/A #11
Q.Q. If a failure to meet the emissions If a failure to meet the emissions limitation is permitted by Subpart limitation is permitted by Subpart SSSS, is the affected source SSSS, is the affected source exonerated from the non-exonerated from the non-compliant condition?compliant condition?
Q.Q. If a failure to meet the emissions If a failure to meet the emissions limitation is permitted by Subpart limitation is permitted by Subpart SSSS, is the affected source SSSS, is the affected source exonerated from the non-exonerated from the non-compliant condition?compliant condition?
Q/A #11Q/A #11
A.A. Failure to meet the emissions Failure to meet the emissions limitation, including the operating limitation, including the operating limits or work practice standards limits or work practice standards during startup, shutdown or during startup, shutdown or malfunction is considered a malfunction is considered a deviation and must be reported as deviation and must be reported as an exceedance under Subpart an exceedance under Subpart SSSS. SSSS.
Q/A #12Q/A #12
Q.Q. How flexible is Subpart SSSS How flexible is Subpart SSSS regarding compliance with regarding compliance with the rule?the rule?
Q.Q. How flexible is Subpart SSSS How flexible is Subpart SSSS regarding compliance with regarding compliance with the rule?the rule?
Q/A #12Q/A #12
The effected source can The effected source can choose from several choose from several compliance options in compliance options in Subpart SSSS to achieve the Subpart SSSS to achieve the emission limit that applies to emission limit that applies to the effected source.the effected source.
The effected source can The effected source can choose from several choose from several compliance options in compliance options in Subpart SSSS to achieve the Subpart SSSS to achieve the emission limit that applies to emission limit that applies to the effected source.the effected source.
Q/A #13Q/A #13
Q.Q. Do the operating limits apply Do the operating limits apply to all effected source?to all effected source?
Q.Q. Do the operating limits apply Do the operating limits apply to all effected source?to all effected source?
Q/A #13Q/A #13A.A. If the effected source reduces If the effected source reduces
emissions by using a capture emissions by using a capture system and add-on control system and add-on control device( other than a solvent device( other than a solvent recovery system for which a recovery system for which a source conducts a liquid-liquid source conducts a liquid-liquid material balance), the material balance), the operating limits apply to the operating limits apply to the source. source.
Q/A #14Q/A #14
Q.Q. How does an effected source How does an effected source comply with Subpart SSSS of the comply with Subpart SSSS of the source demonstrates compliance source demonstrates compliance based on the emissions rates based on the emissions rates without add-on controls option?without add-on controls option?
Q.Q. How does an effected source How does an effected source comply with Subpart SSSS of the comply with Subpart SSSS of the source demonstrates compliance source demonstrates compliance based on the emissions rates based on the emissions rates without add-on controls option?without add-on controls option?
Q/A #14Q/A #14
A.A. The source must determine the The source must determine the mass of organic HAP in all coatings mass of organic HAP in all coatings and thinners used in each coating and thinners used in each coating type segment each month during type segment each month during the initial compliance period, and the initial compliance period, and the volume fraction of coating the volume fraction of coating solids in all coating type segment solids in all coating type segment used each month during the initial used each month during the initial compliance period.compliance period.
A.A. The source must determine the The source must determine the mass of organic HAP in all coatings mass of organic HAP in all coatings and thinners used in each coating and thinners used in each coating type segment each month during type segment each month during the initial compliance period, and the initial compliance period, and the volume fraction of coating the volume fraction of coating solids in all coating type segment solids in all coating type segment used each month during the initial used each month during the initial compliance period.compliance period.
Q/A #15Q/A #15
Q.Q. Does Subpart SSSS cover the Does Subpart SSSS cover the processing of metal foil?processing of metal foil?
Q.Q. Does Subpart SSSS cover the Does Subpart SSSS cover the processing of metal foil?processing of metal foil?
Q/A #15Q/A #15
A.A. The metal coil rule as promulgated The metal coil rule as promulgated specified that operations performing specified that operations performing both foil coating and coil coating on both foil coating and coil coating on the same equipment would be the same equipment would be subject to the metal coil NESHAP subject to the metal coil NESHAP only. The 85 per cent primary use only. The 85 per cent primary use provision allows facilities to comply provision allows facilities to comply with the NESHAP representing their with the NESHAP representing their principal coating activity. principal coating activity.
