Paper and other web coating mact summary

8. What testing and monitoring are affected sources subject to?

Test Methods and Procedures

Since facilities with affected sources can choose among several options to comply with this standard, required test methods and procedures depend upon the option chosen.

If a facility chooses to demonstrate compliance based on the coating materials applied (low-HAP coating) on the web coating lines, then the average mass of the organic HAP in the coatings applied must be calculated to show that it is less than the organic HAP emission limit specified. The organic HAP content of the materials applied 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.

If a facility chooses to demonstrate compliance by using capture and control equipment (solvent recovery system and thermal or catalytic destruction), then the facility must demonstrate that the overall control efficiency of the equipment selected reduces the total organic HAP emissions by at least 95% for existing sources and 98% for new sources.

If the facility chooses to demonstrate compliance using a combined approach, then the overall control efficiency of the capture and control equipment and the organic HAP content of the materials applied on the web coating lines must be determined.  Compliance with one of the emissions limit can then be demonstrated.  If the facility chooses to demonstrate compliance based on coating solids applied, then the coating solids content of each coating material used must be determined for each monthly period. If choosing to demonstrate compliance with control equipment efficiency, then EPA Method 204 of 40 CFR 51, Appendix M must be used to confirm the capability of the capture system or EPA Methods 204A through F must be used to measure capture efficiency.

When using control devices, a facility must determine the emission destruction or removal efficiency of that device by conducting a performance test or using a continuous emissions monitoring system (CEMS). Use of a CEMS must be in accordance with performance specifications 8 or 9 in 40 CFR 60, Appendix B.  Performance test protocol using appropriate EPA methods must be followed.

If a solvent recovery system is used to comply with emissions requirements, then the overall control efficiency may be determined using a liquid-liquid material balance. When demonstrating compliance using a material balance, the amount of all coating materials applied each month to the web coating must be measured and the VOC content of these materials must be determined. The amount of VOC recovered by the solvent recovery system during each month must also be determined and the overall solvent recovery efficiency calculated. A testing protocol for determining the mass of VOC material retained or otherwise not emitted to the atmosphere must be developed, submitted and approved as part of a facility’s site-specific test plan.

All test methods required and discussed in this section are existing EPA methods that are familiar to the industry, readily available and appropriate to the device or the parameter being measured.  The selected tests are expected to establish whether the facility is complying with the standards.  For additional details, EPA maintains an Emissions Measurement Center that may be accessed at www.epa.gov/ttn/emc/ .

Monitoring Requirements

Monitoring of affected sources is required to determine the compliance status and whether the compliance is continuous or intermittent.

Facilities with affected sources that use capture and control systems to comply must demonstrate initial compliance through an initial performance test and ongoing compliance through continuous monitoring. EPA specifies the operating parameters that need to be monitored for certain control devices used in the paper and other web coating. 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 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.