plastic parts and products surface coating mact summary

6. What are the testing and initial compliance requires for this rule?

Existing affected sources must be in compliance with the final rule no later than April 19, 2007. New and reconstructed sources must be in compliance upon initial startup of the affected source or by April 19, 2004, whichever is later.

Compliance with the emission limits is based on a rolling 12-month organic HAP emission rate determined each month. Each 12-month period is a compliance period. The initial compliance period, therefore, is the 12- month period beginning on the compliance date. If the compliance date occurs on any day other than the first day of a month, then the initial compliance period begins on the compliance date and extends through the end of that month plus the following 12 months. This means that the initial compliance period could be almost 13 months, but all subsequent compliance periods will be 12 months long. EPA has defined ‘‘month’’ as a calendar month or a pre-specified period of 28 to 35 days to allow for flexibility at sources where data are based on a business accounting period.

Being ‘‘in compliance’’ means that the owner or operator of the affected source meets the requirements to achieve the final emission limitations during the initial compliance period. However, they will not have accumulated the records for the rolling 12-month organic HAP emission rate until the end of the initial compliance period. Therefore, affected sources are not required to demonstrate compliance until the end of the initial compliance period when they will have accumulated the necessary records to document the rolling 12-month organic HAP emission rate. At the end of the initial compliance period, the owner or operator uses the data and records generated to determine whether or not the affected source is in compliance with the organic HAP emission limit and other applicable requirements for that period. If the affected source does not meet the applicable limit and other requirements, it is out of compliance for the entire compliance period.

Emission Limits

There are three options for complying with the final emission limits, and the testing and initial compliance requirements vary accordingly. A facility may choose to use one compliance option for the entire affected source, or may use different compliance options for different coating operations within the affected source. A facility may also use different compliance options for the same coating operation at different times; different compliance options when different coatings are applied to the same part, or when the same coating is applied to different parts. However, a facility may not use different compliance options at the same time on the same coating operation.

Option 1: Compliant materials: This option allows a facility to easily demonstrate compliance by using low-HAP or non- HAP coatings and other materials. A facility may use this compliance option if the coatings used, based on their organic HAP content, individually meet the mass of organic HAP emitted per mass of coating solids used levels in the applicable emission limits and if the facility uses non-HAP thinners and other additives and cleaning materials.

Recordkeeping and reporting requirements have been minimized for this option.  A facility may demonstrate compliance by using manufacturer’s formulation data and readily available purchase records to determine the organic HAP content of each coating or other material and the amount of each material used. Detailed emission rate calculations are not required, however, it must be demonstrated the organic HAP content of each coating meets the emission limits for  the appropriate subcategory as shown in Tables 2 and 3, shown in this summary, and that no organic HAP-containing thinners and/or other additives, or cleaning materials were used.

For example, if a facility is using this option and their existing source has TPO coating operations, automotive lamp coating operations, assembled on-road vehicle coating operations, and general use coating operations, they must demonstrate that:

• Each coating used in the TPO coating operation has an organic HAP content no greater than 0.26 kg (0.26 lb) organic HAP emitted per kg (lb) coating solids used;

• Each coating used in the automotive lamp coating operations has an organic HAP content no greater than 0.45 kg (0.45 lb) organic HAP emitted per kg (lb) coating solids used;

• Each coating used in the assembled on-road vehicle coating operations has an organic HAP content no greater than 1.34 kg (1.34 lb) organic HAP emitted per kg (lb) coating solids used;

• Each general use coating has an organic HAP content no greater than 0.16 kg (0.16 lb) organic HAP emitted per kg (lb) coating solids used; and

• They used no organic HAP-containing thinners and/or other additives, or cleaning materials. Note that ‘‘no organic HAP’’ is not intended to mean absolute zero. Materials that contain ‘‘no organic HAP’’ means materials that contain organic HAP levels below the levels specified in  63.4541(a) of this rule, which are typical Occupational Safety and Health Administration (OSHA) reporting levels for material safety data sheets. These typical reporting levels only count organic HAP that are present at 0.1 percent or more by mass for OSHA defined carcinogens and at 1.0 percent or more by mass for other compounds.

Option 2: Compliance based on the emission rate without add-on controls: This option allows the facility to demonstrate compliance based on the organic HAP contained in the mix of coatings, thinners and/or other additives, and cleaning materials used.  It offers the flexibility to use some individual coatings that do not, by themselves, meet the kg (lb) organic HAP emitted per kg (lb) coating solids used levels in the applicable emission limits if the facility uses other low HAP or non- HAP coatings such that overall emissions from the affected source over a 12-month period meet the emission limits.

A facility would use this option if they use HAP-containing thinners and/or other additives, and cleaning materials and do not have add-on controls. With this option, the facility must keep track of the mass of organic HAP in each coating, thinner or other additive, and cleaning material, and the amount of each material used in the affected source each month of the compliance period. This information is then used to determine the total mass of organic HAP in all coatings, thinners and/or other additives, and cleaning materials divided by the total mass of coating solids used during the compliance period.

In this option, a facility must demonstrate that their emission rate (in kg (lb) organic HAP emitted per kg (lb) coating solids used) meets the applicable emission limit. Readily available purchase records and manufacturer’s formulation data may be used to determine the amount of each coating or other material used and the organic HAP in each material. This rule also contains equations that show how to perform the calculations to demonstrate compliance.

In order to demonstrate compliance using this option, a facility is required to:

• Determine the quantity of each coating, thinner and/or other additive, and cleaning material used.

• Determine the mass of organic HAP in each coating, thinner and other additive, and cleaning material using the same types of data and methods previously described for Option 1, including the alternative methods for reactive coatings.

• Determine the mass fraction of coating solids for each coating using the same types of data or methods described under Option 1.

• Calculate the total mass of organic HAP in all materials and total mass of coating solids used each month.

• Calculate the total mass of organic HAP emissions and total mass of coating solids used for the initial compliance period by adding together all the monthly values for mass of organic HAP and for mass of coating solids used for the 12 months of the initial compliance period.

• Calculate the ratio of the total mass of organic HAP emitted for the materials used to the total mass of coating solids used (kg (lb) organic HAP emitted per kg (lb) of coating solids used) for the initial compliance period.

• Record the calculations and results and include them in the Notification of Compliance Status.

Option 3: Compliance based on using a capture system and add-on controls device:  This option allows sources to use a capture system and an add-on pollution control device, such as a combustion device or a recovery device, to meet the emission limits. Under this option, testing is required to demonstrate the capture system and control device efficiencies. Alternatively, facilities using this option may conduct a liquid-liquid material balance to demonstrate the amount of organic HAP collected by their recovery device.

Equations are provided in this rule to show how to use records of materials usage, organic HAP contents of each material, capture and control efficiencies, and coating solids content to calculate emission rate during the compliance period. If compliance is demonstrated based on this option, facilities must demonstrate that their emission rate, considering controls (in kg (lb) organic HAP emitted per kg (lb) of coating solids used), is less than the applicable emission limit.

For a capture system and add-on control device, other than a solvent recovery system for which a liquid-liquid material balance is conducted, the testing and initial compliance requirements are as follows:

• Conduct an initial performance test to determine the capture and control efficiencies of the equipment and to establish operating limits to be achieved on a continuous basis. The performance test must be completed no later than the compliance date for existing sources and 180 days after the compliance date for new and reconstructed sources.

• Calculate the mass of organic HAP in each coating and other material, and the mass fraction of coating solids for each coating used during each month of the initial compliance period.

• Calculate the total mass of organic HAP in all coatings and other materials, and total mass of coating solids used each month in the controlled operation or group of coating operations.

• Calculate the organic HAP emissions from the controlled coating operations each month using the capture and control efficiencies determined during the performance test, and the total mass of organic HAP in materials used in controlled coating operations that month.

• Calculate the total mass of organic HAP emissions and total mass of coating solids used for the initial compliance period by adding together all the monthly values for mass of organic HAP emissions and for mass of coating solids for the 12 months in the initial compliance period.

• Calculate the ratio of the total mass of organic HAP emissions to the total mass of coating solids used during the initial compliance period.

• Record the calculations and results and include them in your Notification of Compliance Status.

• Develop and implement a work practice plan to minimize emissions from storage, mixing, and handling of organic HAP-containing materials.

If a facility uses a capture system and add-on control device, other than a solvent recovery system for which they conduct liquid-liquid material balances, they must use specified test methods to determine both the efficiency of the capture system and the emission reduction efficiency of the control device.

To determine the capture efficiency, a facility would either verify the presence of a permanent total enclosure using EPA Method 204 of 40 CFR Part 51, Appendix M (and all materials must be applied and dried within the enclosure); or use one of three protocols described in 63.4565 of this rule to measure capture efficiency. If the facility has a permanent total enclosure and all materials are applied and dried within the enclosure and they route all exhaust gases from the enclosure to a control device, they can assume 100 percent capture.

To determine the emission reduction efficiency of the control device, a facility must conduct measurements of the inlet and outlet gas streams. The test consists of three runs, each run lasting 1 hour, using the EPA Methods described in 40 CFR Part 60, Appendix A. Alternatively, any other test method or data that have been validated according to the applicable procedures in Method 301 of 40 CFR part 63, appendix A, and approved by the Administrator, could be used.

If a facility uses a solvent recovery system, they could choose to determine the overall control efficiency using a liquid-liquid material balance instead of conducting an initial performance test. If this material balance alternative is used, facilities would be required to measure the amount of all materials used in the controlled coating operations served by the solvent recovery system during each month of the initial compliance period, and to determine the total volatile matter contained in these materials; and also measure the amount of volatile matter recovered by the solvent recovery system during each month of the initial compliance period. Then they must compare the amount recovered to the amount used to determine the overall control efficiency each month and apply this efficiency to the total mass of organic HAP in the materials used to determine total organic HAP emissions for the month. The facility must total these 12 monthly organic HAP emission values and divide by the total of the 12 monthly values for coating solids used to calculate the emission rate for the 12-month initial compliance period. The calculations and results must be recorded and included in the Notification of Compliance Status.

Operating Limits

Operating limits are established as part of the initial performance test of a capture system and control device, other than a solvent recovery system for which liquid-liquid material balances are conducted. The operating limits are the minimum or maximum (as applicable) values achieved for capture systems and control devices during the most recent performance test, conducted under representative conditions, that demonstrated compliance with the emission limits.

This rule specifies the parameters to monitor for the types of emission control systems commonly used in the industry. Facilities are required to install, calibrate, maintain, and continuously operate all monitoring equipment according to manufacturer’s specifications and ensure that the continuous parameter monitoring systems (CPMS) meet the requirements specified in 63.4568 of the final rule.

If a facility opts to use control devices other than those identified in the final rule, they must submit the operating parameters to be monitored to the Administrator for approval. The authority to approve the parameters to be monitored is retained by EPA and is not delegated to States. If the facility will use a thermal or catalytic oxidizer, they must continuously monitor the appropriate temperature and record it at least every 15 minutes. For thermal oxidizers, the temperature monitor is placed in the firebox or in the duct immediately downstream of the firebox before any substantial heat exchange occurs. The operating limit is the average temperature measured during the performance test and for each consecutive 3-hour period; the average temperature has to be at or above this limit.

For catalytic oxidizers, temperature monitors are placed immediately before and after the catalyst bed. The operating limits are the average temperature just before the catalyst bed and the average temperature difference across the catalyst bed during the performance test. For each 3-hour period, the average temperature and the average temperature difference must be at or above these limits. Alternatively, if the facility develops and implements an inspection and maintenance plan for the catalytic oxidizer, then they are allowed to monitor only the temperature before the catalyst bed and meet only the temperature operating limit before the catalyst bed and are not required to monitor the difference across the bed.

If a facility uses a regenerative carbon adsorber and does not conduct liquid-liquid material balances to demonstrate compliance, they must monitor the carbon bed temperature after each regeneration and the total amount of steam or nitrogen used to desorb the bed for each regeneration. The operating limits are the carbon bed temperature at the time the carbon bed is returned to service (not to be exceeded) and the amount of steam or nitrogen used for desorption (to be met as a minimum).

If a facility uses a condenser and does not conduct liquid-liquid material balances to demonstrate compliance, they must monitor the outlet gas temperature to ensure that the air stream is being cooled to a low enough temperature. The operating limit is the average condenser outlet gas temperature measured during the performance test and for each consecutive 3-hour period, the average temperature must be at or below this limit.

If a facility uses a concentrator, they must monitor the temperature of the desorption concentrate stream and the pressure drop across the concentrator. These values must be recorded at least once every 15 minutes. The operating limits must be the 3-hour average temperature (to be met as a minimum) and the 3- hour average pressure drop (to be met as a minimum) measured during the performance test.

For each capture system that is not a permanent total enclosure, the operating limits for gas volumetric flow rate or duct static pressure for each enclosure or capture device must be established.  The operating limit is the average volumetric flow rate or duct static pressure during the performance test, to be met as a minimum. For each capture system that is a permanent total enclosure, the operating limit requires the average facial velocity of air through all natural draft openings to be at least 200 feet per minute or the pressure drop across the enclosure to be at least 0.007 inches water.

Work Practices

If a facility uses a capture system and control device for compliance, they are required to develop and implement on an ongoing basis a work practice plan for minimizing organic HAP emissions from storage, mixing, material handling, and waste handling operations. This plan must include a description of all steps taken to minimize emissions from these sources (e.g., using closed storage containers, practices to minimize emissions during filling and transfer of contents from containers, using spill minimization techniques, placing solvent-laden cloths in closed containers immediately after use, etc.). The facility must make the plan available for inspection upon request by the Administrator.   If the facility uses a capture system and control device for compliance, they are required to develop and operate according to a SSMP during periods of startup, shutdown, or malfunction of the capture system and control device.