METAL CAN SURFACE METAL CAN SURFACE COATING MACT COATING MACT COMPLIANCE COMPLIANCE ASSURANCEASSURANCE

METAL CAN SURFACE METAL CAN SURFACE COATING MACT COATING MACT COMPLIANCE COMPLIANCE ASSURANCEASSURANCE

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART KKKKKKKK

June 2006June 2006

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART KKKKKKKK

June 2006June 2006

Compliance TimelineCompliance Timeline

IMPORTANT COMPLIANCE IMPORTANT COMPLIANCE INFORMATION SOURCEINFORMATION SOURCE

http://http://www.epa.gov/ttn/atw/www.epa.gov/ttn/atw/mcanpg/mcanpg/mcantimeline.pdfmcantimeline.pdf

Compliance DatesCompliance Dates

The final rule was published on The final rule was published on November 13, 2003 , under November 13, 2003 , under 68 FR 68 FR 6443264432

The final rule was published on The final rule was published on November 13, 2003 , under November 13, 2003 , under 68 FR 68 FR 6443264432

Compliance Dates Compliance Dates (cont’d.)(cont’d.)

Existing major sources must comply Existing major sources must comply with:with: Emissions limitations;Emissions limitations; Work practices standard;Work practices standard; Operation & Maintenance Operation & Maintenance

requirement;requirement; Major source status Major source status

determination;determination;

Compliance Dates Compliance Dates (cont’d.)(cont’d.)

New affected sources operating on or after January15, 2003 (63.3482e) should have complied by November 13, 2003, or startup, whichever was later. Existing sources must comply by November 13, 2006.

Compliance Dates Compliance Dates (cont’d.)(cont’d.)

If the METAL CAN COATING FACILITY If the METAL CAN COATING FACILITY is an area source, but becomes a is an area source, but becomes a major source of HAP, compliance of major source of HAP, compliance of [[§ 63.3483(e)(1)]§ 63.3483(e)(1)] i is required upon s required upon startup.startup.

If the METAL CAN COATING FACILITY If the METAL CAN COATING FACILITY is an area source, but becomes a is an area source, but becomes a major source of HAP, compliance of major source of HAP, compliance of [[§ 63.3483(e)(1)]§ 63.3483(e)(1)] i is required upon s required upon startup.startup.

Compliance Dates Compliance Dates (cont’d.)(cont’d.)

Compliance Dates Compliance Dates (cont’d.)(cont’d.)

The affected sources must meet The affected sources must meet the notification and scheduling the notification and scheduling requirements in requirements in [[§ 63.3510(b)].§ 63.3510(b)]. Some of these notifications must Some of these notifications must be submitted before the affected be submitted before the affected source compliance date.source compliance date.

The affected sources must meet The affected sources must meet the notification and scheduling the notification and scheduling requirements in requirements in [[§ 63.3510(b)].§ 63.3510(b)]. Some of these notifications must Some of these notifications must be submitted before the affected be submitted before the affected source compliance date.source compliance date.

Operations & Maintenance Operations & Maintenance Requirements (§63.6(1)-(2)Requirements (§63.6(1)-(2)

affected facilities must operate and affected facilities must operate and maintain the sources, including air maintain the sources, including air pollution control and monitoring pollution control and monitoring equipment in a manner consistent equipment in a manner consistent with good air pollution practices that with good air pollution practices that minimizes air emissions to the level minimizes air emissions to the level required in Subpart KKKK.required in Subpart KKKK.

affected facilities must operate and affected facilities must operate and maintain the sources, including air maintain the sources, including air pollution control and monitoring pollution control and monitoring equipment in a manner consistent equipment in a manner consistent with good air pollution practices that with good air pollution practices that minimizes air emissions to the level minimizes air emissions to the level required in Subpart KKKK.required in Subpart KKKK.

O & M Requirements O & M Requirements (cont’d.)(cont’d.)

affected sources must prepare and affected sources must prepare and operate at all times according to a operate at all times according to a written operation and maintenance written operation and maintenance plan for each capture and collection plan for each capture and collection control device controlling emissions control device controlling emissions subject to Subpart KKKK.subject to Subpart KKKK.

affected sources must prepare and affected sources must prepare and operate at all times according to a operate at all times according to a written operation and maintenance written operation and maintenance plan for each capture and collection plan for each capture and collection control device controlling emissions control device controlling emissions subject to Subpart KKKK.subject to Subpart KKKK.

O & M Requirements O & M Requirements (cont’d.)(cont’d.)

Each plan must contain the elements Each plan must contain the elements required in required in §63.6(e)(1)-(2) of the §63.6(e)(1)-(2) of the General Provisions.General Provisions. Equipment monthly inspectionsEquipment monthly inspections

(cont’d. on next slide)(cont’d. on next slide)

Each plan must contain the elements Each plan must contain the elements required in required in §63.6(e)(1)-(2) of the §63.6(e)(1)-(2) of the General Provisions.General Provisions. Equipment monthly inspectionsEquipment monthly inspections

(cont’d. on next slide)(cont’d. on next slide)

O & M Requirements O & M Requirements (cont’d.)(cont’d.)

Operating limits for each capture Operating limits for each capture systemsystem

Appropriate operating limit Appropriate operating limit parameters and design scope, i.e., parameters and design scope, i.e., control of multiple emissions sourcescontrol of multiple emissions sources

Operating limits for each capture Operating limits for each capture systemsystem

Appropriate operating limit Appropriate operating limit parameters and design scope, i.e., parameters and design scope, i.e., control of multiple emissions sourcescontrol of multiple emissions sources

O&M Requirements O&M Requirements (cont’d.)(cont’d.)

Preventative maintenance plan for Preventative maintenance plan for each control device including the each control device including the manufacturer’s recommended manufacturer’s recommended maintenance instructionsmaintenance instructions

Preventative maintenance plan for Preventative maintenance plan for each control device including the each control device including the manufacturer’s recommended manufacturer’s recommended maintenance instructionsmaintenance instructions

SSM Plan SSM Plan Requirements(§63.3500(Requirements(§63.3500(

c)c)If the affected sources uses an If the affected sources uses an emission capture system and add-on emission capture system and add-on control device for compliance control device for compliance purposes with Subpart KKKK, the purposes with Subpart KKKK, the source must develop and implement a source must develop and implement a written startup, shutdown and written startup, shutdown and malfunction plan (SSMP);malfunction plan (SSMP);

If the affected sources uses an If the affected sources uses an emission capture system and add-on emission capture system and add-on control device for compliance control device for compliance purposes with Subpart KKKK, the purposes with Subpart KKKK, the source must develop and implement a source must develop and implement a written startup, shutdown and written startup, shutdown and malfunction plan (SSMP);malfunction plan (SSMP);

SSMP (cont’d.)SSMP (cont’d.)

SSMP must meet provisions in SSMP must meet provisions in §63.6(e)(3).§63.6(e)(3).

SSMP must address startup, shutdown SSMP must address startup, shutdown and corrective actions in the event of and corrective actions in the event of a malfunction of the emissions a malfunction of the emissions capture system or the add-on device.capture system or the add-on device.

SSMP must meet provisions in SSMP must meet provisions in §63.6(e)(3).§63.6(e)(3).

SSMP must address startup, shutdown SSMP must address startup, shutdown and corrective actions in the event of and corrective actions in the event of a malfunction of the emissions a malfunction of the emissions capture system or the add-on device.capture system or the add-on device.

SSMP (cont’d.)SSMP (cont’d.)

The SSMP must also address any The SSMP must also address any coating operation equipment that coating operation equipment that may cause increased emissions or may cause increased emissions or that would affect capture efficiency that would affect capture efficiency if the process equipment if the process equipment malfunctions such as conveyors malfunctions such as conveyors that move parts among enclosures.that move parts among enclosures.

The SSMP must also address any The SSMP must also address any coating operation equipment that coating operation equipment that may cause increased emissions or may cause increased emissions or that would affect capture efficiency that would affect capture efficiency if the process equipment if the process equipment malfunctions such as conveyors malfunctions such as conveyors that move parts among enclosures.that move parts among enclosures.

General Compliance General Compliance Requirements (§63.3500)Requirements (§63.3500)

The affected source must be in The affected source must be in compliance with the:compliance with the:

emissions limitationsemissions limitationsWork practice standardsWork practice standardsOperations and maintenance;Operations and maintenance;Startup, Shutdown and Malfunction Startup, Shutdown and Malfunction PlanPlan

General Compliance General Compliance (cont’d.)(cont’d.)

Maintain a log detailing the Maintain a log detailing the operation and maintenance of operation and maintenance of the process and emissions the process and emissions control equipment related to the control equipment related to the initial performance test and the initial performance test and the applicable operating limits for an applicable operating limits for an affected sourceaffected source

Maintain a log detailing the Maintain a log detailing the operation and maintenance of operation and maintenance of the process and emissions the process and emissions control equipment related to the control equipment related to the initial performance test and the initial performance test and the applicable operating limits for an applicable operating limits for an affected sourceaffected source

Initial Compliance Initial Compliance Requirements Requirements (§63.3510)(§63.3510)

Performance Test: A performance Performance Test: A performance test must be conducted no later test must be conducted no later than 180 calendar days after the than 180 calendar days after the compliance date specific to an compliance date specific to an affected source using add-on affected source using add-on equipmentequipment.(§63.3483).(§63.3483)

Performance Test: A performance Performance Test: A performance test must be conducted no later test must be conducted no later than 180 calendar days after the than 180 calendar days after the compliance date specific to an compliance date specific to an affected source using add-on affected source using add-on equipmentequipment.(§63.3483).(§63.3483)

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

Notification of Compliance Status; For Notification of Compliance Status; For each work practice standard and each work practice standard and operation and maintenance operation and maintenance requirement that applies to an affected requirement that applies to an affected source where an initial performancesource where an initial performance

(cont’d on next slide)(cont’d on next slide)

Notification of Compliance Status; For Notification of Compliance Status; For each work practice standard and each work practice standard and operation and maintenance operation and maintenance requirement that applies to an affected requirement that applies to an affected source where an initial performancesource where an initial performance

(cont’d on next slide)(cont’d on next slide)

Initial Compliance (cont’d.)Initial Compliance (cont’d.)

test is not demonstrated, the affected test is not demonstrated, the affected source must demonstrate initial source must demonstrate initial compliance no later than 30 calendar compliance no later than 30 calendar days after the specific compliance days after the specific compliance date for the affected source.date for the affected source.

Initial Compliance (cont’d.)Initial Compliance (cont’d.)

Notification of Intent to Conduct Performance Test; In the General Provisions [§63.9(e)]requiremnet if the affected source is required to conducts performance tests (e.g., those with add-on equipment), the affected source must submit a notification of intent to conduct a performance test 60 days prior to the test.

Notification of Intent to Conduct Performance Test; In the General Provisions [§63.9(e)]requiremnet if the affected source is required to conducts performance tests (e.g., those with add-on equipment), the affected source must submit a notification of intent to conduct a performance test 60 days prior to the test.

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

The affected source must install and maintain a CPMS specified in (§63.3547).

Test MethodsTest Methods

Subpart KKKK clearly defines Subpart KKKK clearly defines the test methods and other the test methods and other procedures in procedures in §63.3521 & §63.3521 & §63.3522§63.3522 used to demonstrate used to demonstrate initial compliance with the initial compliance with the emissions limitationsemissions limitations

Subpart KKKK clearly defines Subpart KKKK clearly defines the test methods and other the test methods and other procedures in procedures in §63.3521 & §63.3521 & §63.3522§63.3522 used to demonstrate used to demonstrate initial compliance with the initial compliance with the emissions limitationsemissions limitations

Test Methods (cont’d.)Test Methods (cont’d.)

The procedures in The procedures in Subpart KKKK Subpart KKKK are used to establish operating limits are used to establish operating limits for:for:

Each capture systemEach capture system

Each Solvent Recovery SystemEach Solvent Recovery System

Each combustion deviceEach combustion device

Compliance with Work Compliance with Work Practice StandardsPractice Standards

For any coating operation(s) for For any coating operation(s) for which a compliant material option or which a compliant material option or emissions rate without add-on emissions rate without add-on controls option is chosen, the source controls option is chosen, the source is not required to meet any work is not required to meet any work practice standards. (§63.3493)practice standards. (§63.3493)

For any coating operation(s) for For any coating operation(s) for which a compliant material option or which a compliant material option or emissions rate without add-on emissions rate without add-on controls option is chosen, the source controls option is chosen, the source is not required to meet any work is not required to meet any work practice standards. (§63.3493)practice standards. (§63.3493)

Work Practice Standards Work Practice Standards (cont’d.)(cont’d.)

If an emission rate with add-on controls If an emission rate with add-on controls or the control efficiency/outlet or the control efficiency/outlet concentration option is used to comply concentration option is used to comply with the emission limitations, the with the emission limitations, the source must develop and implement a source must develop and implement a written work practice plan to minimize written work practice plan to minimize organic HAP emissions from the organic HAP emissions from the storage, mixing, and conveying of storage, mixing, and conveying of coatings,coatings,

(cont’d on next slide)(cont’d on next slide)

Work Practice Standards Work Practice Standards (cont’d.)(cont’d.)

thinners and cleaning materials used thinners and cleaning materials used in and waste materials generated by in and waste materials generated by the affected surface coating operationsthe affected surface coating operations

The affected source has submitted a The affected source has submitted a written Plan and will operate at all written Plan and will operate at all times according to that plan.times according to that plan.

thinners and cleaning materials used thinners and cleaning materials used in and waste materials generated by in and waste materials generated by the affected surface coating operationsthe affected surface coating operations

The affected source has submitted a The affected source has submitted a written Plan and will operate at all written Plan and will operate at all times according to that plan.times according to that plan.

REPORTSREPORTS

Compliance reports are required by Compliance reports are required by specific due dates;specific due dates;

REPORTS (cont’d.)REPORTS (cont’d.)

Performance Test Report Performance Test Report [(§63.3511(b)]; if the affected source [(§63.3511(b)]; if the affected source is required to conduct a performance is required to conduct a performance tests (e.g., those with add-on control tests (e.g., those with add-on control equipment), the source must submit a equipment), the source must submit a performance test report within 60 performance test report within 60 days after completion of the days after completion of the performance test.performance test.

REPORTS (cont’d.)

SSM Reports SSM Reports [§63.3511(c)];[§63.3511(c)]; An SSM An SSM Report must be submitted Report must be submitted immediately if there is an SSM of the immediately if there is an SSM of the control device during the reporting control device during the reporting period that is not consistent with the period that is not consistent with the SSM Plan. If actions taken were SSM Plan. If actions taken were consistent with the SSM Plan, the consistent with the SSM Plan, the report must be submitted semi-report must be submitted semi-annually.annually.

SSM Reports SSM Reports [§63.3511(c)];[§63.3511(c)]; An SSM An SSM Report must be submitted Report must be submitted immediately if there is an SSM of the immediately if there is an SSM of the control device during the reporting control device during the reporting period that is not consistent with the period that is not consistent with the SSM Plan. If actions taken were SSM Plan. If actions taken were consistent with the SSM Plan, the consistent with the SSM Plan, the report must be submitted semi-report must be submitted semi-annually.annually.

REPORTS (cont’d.)

Semiannual Compliance reports Semiannual Compliance reports [63.3511(e)};[63.3511(e)}; After the initial After the initial compliance period, each affected compliance period, each affected source must submit semiannual source must submit semiannual compliance reports.compliance reports.

Startup, Shutdown, Startup, Shutdown, Malfunction Reports Malfunction Reports

[§63.3500(c)][§63.3500(c)] A Startup, Shutdown, Malfunction A Startup, Shutdown, Malfunction

(SSM) report must be submitted (SSM) report must be submitted immediately if there was a startup, immediately if there was a startup, shutdown, or malfunction of the shutdown, or malfunction of the control device during the reporting control device during the reporting period that is not consistent with the period that is not consistent with the SSM Plan.SSM Plan.

Startup, Shutdown, Startup, Shutdown, Malfunction Reports Malfunction Reports

(cont’d.)(cont’d.)

If actions were consistent with the If actions were consistent with the SSM Plan, the report must be SSM Plan, the report must be submitted during the required submitted during the required reporting period.reporting period.

Records [§63.3512 & 63.3513]

An affected source is required to keep records of reported information and all other information necessary to document compliance with the rule for 5 years. There may be additional requirements depending on the compliance option that the affected source may choose.

An affected source is required to keep records of reported information and all other information necessary to document compliance with the rule for 5 years. There may be additional requirements depending on the compliance option that the affected source may choose.

Records (cont’d.)Records (cont’d.)

An affected facility is required to keep An affected facility is required to keep records of reported information and all records of reported information and all the other information necessary to the other information necessary to document compliance with the final document compliance with the final rule for 5 yearsrule for 5 years

There may be additional requirements There may be additional requirements depending on the compliance option depending on the compliance option that is chosen.that is chosen.

Title V ConnectTitle V Connect

Check Facilities that have Check Facilities that have Federally Enforceable LimitsFederally Enforceable Limits

Limited number of Major Limited number of Major Facilities; who are they?Facilities; who are they?

Check Facilities that have Check Facilities that have Federally Enforceable LimitsFederally Enforceable Limits

Limited number of Major Limited number of Major Facilities; who are they?Facilities; who are they?

Title V Connect (cont’d.)Title V Connect (cont’d.)

Section 112j, T5 connection (<>3 Section 112j, T5 connection (<>3 years) on T5 Permityears) on T5 Permit

Section 112j is no longer factor on Section 112j is no longer factor on surface coaterssurface coaters

Section 112j, T5 connection (<>3 Section 112j, T5 connection (<>3 years) on T5 Permityears) on T5 Permit

Section 112j is no longer factor on Section 112j is no longer factor on surface coaterssurface coaters

Title V IssuesTitle V Issues

Each affected source that has Each affected source that has obtained a title V operating permit obtained a title V operating permit required by 40 CFR part 70 or 71 required by 40 CFR part 70 or 71 must report all deviations as defined must report all deviations as defined in the regulation for the semiannual in the regulation for the semiannual monitoring report required by Sec. monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A).(A).

Title V Issues (cont’d.)Title V Issues (cont’d.)

If an affected source submits a If an affected source submits a compliance report required by Subpart compliance report required by Subpart KKKK along with, or as part of, the KKKK along with, or as part of, the semiannual monitoring report required by semiannual monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), and the compliance report includes all (A), and the compliance report includes all required information concerning required information concerning deviations from any organic HAPdeviations from any organic HAP

(cont’d. on next slide)(cont’d. on next slide)

Title V Issues (cont’d.)Title V Issues (cont’d.)

emissions limitation (including any emissions limitation (including any operating limit) or work practice operating limit) or work practice requirement in subpart KKKK, requirement in subpart KKKK, submission of the compliance report submission of the compliance report shall be deemed to satisfy any shall be deemed to satisfy any obligation to report the same obligation to report the same deviations in the semiannual deviations in the semiannual monitoring report. In other words, no monitoring report. In other words, no double jeopardy.double jeopardy.

TITLE V Issues TITLE V Issues (cont’d.)(cont’d.)

However, submission of a compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permitting authority. (THIS IS VERY IMPORTANT))

However, submission of a compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permitting authority. (THIS IS VERY IMPORTANT))

Title V Compliance Title V Compliance Report ExampleReport Example

For each affected source that is For each affected source that is subject to permitting requirements subject to permitting requirements required by 40 CFR part 70 or 71, and required by 40 CFR part 70 or 71, and if the permitting authority has if the permitting authority has established dates for submitting established dates for submitting semiannual reports required by semiannual reports required by Section 70.6 (a)(3)(iii)(A) or Section Section 70.6 (a)(3)(iii)(A) or Section

(cont’d. on next slide)

Title V Compliance Title V Compliance Report Example (cont’d.)Report Example (cont’d.)

71.6(a)(3)(iii)(A), you may submit the 71.6(a)(3)(iii)(A), you may submit the first and subsequent compliance first and subsequent compliance reports according to the dates the reports according to the dates the permitting authority has established permitting authority has established instead of according to the dates in instead of according to the dates in paragraphs (b)(1) through (4) of this paragraphs (b)(1) through (4) of this section. section. (NOTE WELL)(NOTE WELL)

71.6(a)(3)(iii)(A), you may submit the 71.6(a)(3)(iii)(A), you may submit the first and subsequent compliance first and subsequent compliance reports according to the dates the reports according to the dates the permitting authority has established permitting authority has established instead of according to the dates in instead of according to the dates in paragraphs (b)(1) through (4) of this paragraphs (b)(1) through (4) of this section. section. (NOTE WELL)(NOTE WELL)

New Source New Source Review/PSD Review/PSD ImplicationsImplications

NSR requires stationary sources of air pollution to apply for permits before they can construct/pre-construct/reconstruct. There are three types of NSR permit requirements: PSD permits require for new major

sources, or major modification to an existing source in attainment areas;

NSR/PSD Implications NSR/PSD Implications (cont’d.)(cont’d.)

Non-attainment NSR permits for new Non-attainment NSR permits for new or modifications to existing sources;or modifications to existing sources;

Minor source permitsMinor source permits These permits must be included in the These permits must be included in the

Title V permit issued to an affected Title V permit issued to an affected facilityfacility..

Section 112j Section 112j ImplicationsImplications

Most States allow the Initial Most States allow the Initial Notification requirements under Notification requirements under Subpart KKKK to be satisfied by Subpart KKKK to be satisfied by the Section 112j Notification.the Section 112j Notification.

Most States allow the Initial Most States allow the Initial Notification requirements under Notification requirements under Subpart KKKK to be satisfied by Subpart KKKK to be satisfied by the Section 112j Notification.the Section 112j Notification.

Pollution Prevention Pollution Prevention OptionsOptions

Remove HAP organic Remove HAP organic COMPONENTS from coating COMPONENTS from coating operation,operation,Reduce the development of waste Reduce the development of waste surface coatings, excess thinners surface coatings, excess thinners and surface coating repair items.and surface coating repair items.

Remove HAP organic Remove HAP organic COMPONENTS from coating COMPONENTS from coating operation,operation,Reduce the development of waste Reduce the development of waste surface coatings, excess thinners surface coatings, excess thinners and surface coating repair items.and surface coating repair items.