printing, coating, and dyeing of fabrics and other textiles

10.  What are the procedures for compliance with each operation?

Compliance Procedures

Since facilities with affected sources can choose among several options to comply with this standard, required procedures depend upon the option chosen. The web coating/printing and dyeing/finishing testing must be conducted under representative operating conditions. The testing for the emission capture system and add-on control device must be performed when they are operating at a representative flow rate and representative inlet concentration, respectively. The different options are based on the different subcategories.

For web coating and printing operations:

If a facility chooses to demonstrate compliance based on the materials, then the mass fraction of the organic HAP and the mass fraction of solids in all materials applied must be calculated to show that it is less than the organic HAP emission limit specified and the facility must show that there was no use of organic HAP-containing thinning or cleaning materials. The mass fraction of organic HAP must be determined using either EPA Method 311 of 40 CFR 63, Appendix A, an approved alternative method, or  by using the volatile organic content (as determined by EPA Method 24 of 40 CFR 60, Appendix A) of the applied coating as the value of the organic HAP content. The mass fraction of solids must be determined using EPA Method 24 of 40 CFR 60, Appendix A.

If a facility chooses to demonstrate compliance without add-on controls option, then the quantity of each coating, thinning, printing and cleaning material applied must be determined, the mass of organic HAP in each coating, thinning, printing and cleaning material applied must be determined, the mass fraction of solids for each coating and printing material applied must be determined, the total mass of organic HAP in all regulated materials applied and the total mass of solids for all coating and printing materials applied must be determined and the ratio of total mass of organic HAP to total mass of solids must be calculated and recorded.

For slashing operations:

A facility must use demonstrate compliance based on the materials option and demonstrate that the each slashing material applied contains no organic HAP (materials containing HAP levels below levels defined in final rule).

For dyeing and finishing operations:

If a facility chooses to demonstrate compliance by using the materials option, then the facility must show that the organic HAP content of each dyeing and finishing material applied meets the applicable emission limit rule. The mass of organic HAP can be determined from the manufacturer’s formulation data.

If a facility chooses to demonstrate compliance without add-on controls option, the facility must determine the mass of each dyeing and finishing material applied, calculate the mass or organic HAP in each dyeing and finishing material applied, calculate the total mass of organic HAP and the total mass of all regulated materials applied during the compliance period and the ratio of total mass of organic HAP in regulated material to total mass of regulated materials applied must be calculated and recorded.

If a facility chooses to demonstrate compliance with the equivalent emission rate option, the facility must determine the average organic HAP concentration of the affected wastewater stream using EPA Methods 305, 624, 625, 1624 and 1625, determine the mass flow rate of each wastewater stream, document the wastewater is discharged to a POTW or treated onsite, determine the mass of organic HAP contained in all wastewater streams, determine the fraction of organic HAP applied in the dyeing/finishing affected source that is discharged to the wastewater (at least 90%) and determine the organic HAP emissions from the dyeing/finishing affected source. This data must be recorded and included in the Notification of Compliance Status.

Monitoring Requirements

Monitoring of affected sources is required to determine the compliance status and whether the compliance is continuous or intermittent. Facilities are required to install, calibrate, maintain and continuously operate all monitoring equipment according to the manufacturer’s specifications and ensure that the continuous parameter monitoring systems meet the requirements of the final rule.

EPA specifies the operating parameters that need to be monitored for certain control devices used in the web coating, printing and dyeing and finishing operations by using a capture system and add-on control device. Facilities must set the value of these parameters that will demonstrate compliance during initial performance tests.  These values become the operating limits and if future monitoring shows that the system is operation outside the established range of values, then the system is deviating from the operational limits.   Use of a capture and control system requires the development and maintenance of a plan identifying the operation limit and monitoring procedures for the system.  Facilities must monitor in accordance with their plan.

Facilities with affected sources that use capture and control systems with bypass lines that allow emissions to bypass the add-on control device, must demonstrate that organic HAP emissions collected by the capture system are routed to the add-on control device by one of the following options:

• Flow control position indicator
• Car-seal or lock and key valve closures to secure the bypass line
• Valve closure continuous monitoring
• Automatic shutdown system

Facilities with affected sources that choose thermal or catalytic oxidizer to comply with the standards must monitor temperature using a continuous parameter monitoring system. For the thermal oxidizer, the average combustion temperature recorded during the performance test must be established as the operating limit.  For catalytic oxidizer, the average inlet gas temperature and temperature rise across the catalyst bed recorded during the perform test must be established as the operating limits. Alternatively, the average gas temperature at the inlet of the catalyst bed and the average catalyst activity level may be established as the operating limits.

For a solvent recovery system, a monthly liquid-liquid material balance must be conducted or continuous emissions monitors must be operated.