Surface coating of wood building products mact

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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 then the average mass of the organic HAP in the coating, thinner and cleaning material used and the volume fraction of coating solids in each coating used 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 manufacturer’s data. The volume fraction of coating solids used may be determined by using either one of the two referenced ASTM methods (ASTM D2697-86, 1998, or ASTM D6093-97) or by using the calculations using the total volatile matter content of the coating and the average density of the volatile matter in the coating.

If a facility chooses to demonstrate compliance based on the emission rate without add-on controls, then the facility would use the same criteria and methods for the coating materials applied. In addition, the affected sources would be required to determine the quantity of each coating, thinner, and cleaning material applied, calculate the total mass of organic HAP in all materials and the total volume of coating solids used each month, calculate the total mass of organic HAP emissions, calculate the ratio of total mass of organic HAP to total volume of coating solids used.

If a facility chooses to demonstrate compliance based on the emission rate with add-on controls (other than solvent recovery system) for which a liquid-liquid material balance is conducted, then an initial performance test must be conducted to determine the overall control efficiency of the capture and control equipment and to establish operating limits. Facilities must also determine the mass fraction of organic HAP in each material and the volume of coating solids, calculate the total mass of organic HAP in all materials and the total volume of coating solids used each month, calculate the total mass of organic HAP emissions, calculate the ratio of total mass of organic HAP to total volume of coating solids used.  

When using control devices, a facility must determine the emission destruction or removal efficiency of that device by using EPA Method 204 of 40 CFR part 51, Appendix M to verify the presence of a PTE or by using one of the protocols in §63.4765 of the final rule to measure the capture efficiency.

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 coating operation 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. This efficiency rate must be applied to the ratio of organic HAP to coating solids for materials used.

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 must install, calibrate, maintain, and continuously operate all monitoring equipment according to the manufacturer’s specification and be in accordance with 63.4768.

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 temperature in the firebox or immediately downstream of the firebox must be recorded at least every 15 minutes.  For catalytic oxidizer, the temperature immediately before and after the catalyst bed must be recorded at least every 15 minutes or the temperature immediately before the catalyst bed must be recorded at least every 15 minutes.

Facilities with affected sources that use a condenser must monitor the outlet gas temperature.

Facilities with affected sources that use a carbon absorber and do not conduct liquid-liquid material balances 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.

Facilities with affected sources that use a concentrator must monitor the desorption gas stream temperature and the pressure drop in the stream.

Facilities with affected sources that use capture system bypass lines may use one of the following to ensure that capture equipment is not being bypassed:

• Flow control position indicator
• Car-seal or lock-and-key valve closures
• Valve closure monitoring
• Automatic shutdown system