metal can surface coating mact question & answers 40 cfr part 63, subpart kkkk june, 2006 40 cfr...

METAL CAN SURFACE METAL CAN SURFACE COATING MACT QUESTION COATING MACT QUESTION

& ANSWERS& ANSWERS

METAL CAN SURFACE METAL CAN SURFACE COATING MACT QUESTION COATING MACT QUESTION

& ANSWERS& ANSWERS

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

Questions/AnswersQuestions/Answers#1#1

If the facility builds a new If the facility builds a new building next to a current building next to a current building, does the new building, does the new building become a new building become a new source?source?

Q/A (cont’d.) Q/A (cont’d.) #1#1

Q/A (cont’d.) Q/A (cont’d.) #1#1

The best source to answer The best source to answer this question is the facility’s this question is the facility’s permitting authority because permitting authority because the decision may rest on site-the decision may rest on site-specific factors.specific factors.

The best source to answer The best source to answer this question is the facility’s this question is the facility’s permitting authority because permitting authority because the decision may rest on site-the decision may rest on site-specific factors.specific factors.

Q/A (cont’d.)Q/A (cont’d.)#2#2

Q/A (cont’d.)Q/A (cont’d.)#2#2

Q.Q. Does Subpart KKKK consider Does Subpart KKKK consider post-coat repair spray for easy post-coat repair spray for easy open can ends?open can ends?

Q.Q. Does Subpart KKKK consider Does Subpart KKKK consider post-coat repair spray for easy post-coat repair spray for easy open can ends?open can ends?

Q/A (cont’d.)Q/A (cont’d.)#2#2

A.A. Using the coating data and Using the coating data and information provided by the information provided by the affected sources, USEPA have affected sources, USEPA have inserted a separate emission inserted a separate emission limit for repair spray coatings limit for repair spray coatings under the end coating under the end coating subcategory.subcategory.

A.A. Using the coating data and Using the coating data and information provided by the information provided by the affected sources, USEPA have affected sources, USEPA have inserted a separate emission inserted a separate emission limit for repair spray coatings limit for repair spray coatings under the end coating under the end coating subcategory.subcategory.

Q/A (cont’d.)Q/A (cont’d.)#3#3

Q.Q. For facilities that are complex or For facilities that are complex or collated with different coating collated with different coating operations, i.e. multiple surface operations, i.e. multiple surface coating operations; chromium coating operations; chromium and organic HAP coatings, are and organic HAP coatings, are any consolidation options any consolidation options available to compliance?available to compliance?

Q.Q. For facilities that are complex or For facilities that are complex or collated with different coating collated with different coating operations, i.e. multiple surface operations, i.e. multiple surface coating operations; chromium coating operations; chromium and organic HAP coatings, are and organic HAP coatings, are any consolidation options any consolidation options available to compliance?available to compliance?

Q/A (cont’d.)Q/A (cont’d.)#3#3

Q/A (cont’d.)Q/A (cont’d.)#3#3

A.A. Section 112(d)(2) requires that all Section 112(d)(2) requires that all major sources within a major source major sources within a major source category must meet maximum category must meet maximum emission reduction determined to be emission reduction determined to be achievable. Therefore, due to the achievable. Therefore, due to the complexity of allowing such options, complexity of allowing such options, none are allowed in the rule, but c/c none are allowed in the rule, but c/c options can be used on a c/c options can be used on a c/c operation basis. This is particularly operation basis. This is particularly true under the Title V process.true under the Title V process.

A.A. Section 112(d)(2) requires that all Section 112(d)(2) requires that all major sources within a major source major sources within a major source category must meet maximum category must meet maximum emission reduction determined to be emission reduction determined to be achievable. Therefore, due to the achievable. Therefore, due to the complexity of allowing such options, complexity of allowing such options, none are allowed in the rule, but c/c none are allowed in the rule, but c/c options can be used on a c/c options can be used on a c/c operation basis. This is particularly operation basis. This is particularly true under the Title V process.true under the Title V process.

Q/A (cont’d.)Q/A (cont’d.)#4#4

Q.Q. Does a metal can coating Does a metal can coating facility have to comply with the facility have to comply with the emission limitations during emission limitations during periods of startup, shutdown periods of startup, shutdown and malfunction?and malfunction?

Q.Q. Does a metal can coating Does a metal can coating facility have to comply with the facility have to comply with the emission limitations during emission limitations during periods of startup, shutdown periods of startup, shutdown and malfunction?and malfunction?

Q/A (cont’d.)Q/A (cont’d.)#4#4

A.A. The affected facility must be in The affected facility must be in compliance with the emissions compliance with the emissions limitations, work practice limitations, work practice standards, and operation and standards, and operation and maintenance requirements in maintenance requirements in Subpart KKKK at all timesSubpart KKKK at all times..

A.A. The affected facility must be in The affected facility must be in compliance with the emissions compliance with the emissions limitations, work practice limitations, work practice standards, and operation and standards, and operation and maintenance requirements in maintenance requirements in Subpart KKKK at all timesSubpart KKKK at all times..

Q/A (cont’d.)Q/A (cont’d.)#5#5

Q/A (cont’d.)Q/A (cont’d.)#5#5

Q.Q. Does a Subpart KKKK affected Does a Subpart KKKK affected facility have to comply with facility have to comply with NSPS requirements?NSPS requirements?

Q.Q. Does a Subpart KKKK affected Does a Subpart KKKK affected facility have to comply with facility have to comply with NSPS requirements?NSPS requirements?

Q/A (cont’d.)Q/A (cont’d.)#5#5

A.A. Since the NESHAP and NSPS Since the NESHAP and NSPS regulations focus on different regulations focus on different aspects of an affected facility, aspects of an affected facility, organic VOCs, compliance must organic VOCs, compliance must be achieved with both be achieved with both regulations.regulations.

A.A. Since the NESHAP and NSPS Since the NESHAP and NSPS regulations focus on different regulations focus on different aspects of an affected facility, aspects of an affected facility, organic VOCs, compliance must organic VOCs, compliance must be achieved with both be achieved with both regulations.regulations.

Q/A (cont’d.)Q/A (cont’d.)#6#6

Q.Q. What are the installation, What are the installation, operation and maintenance operation and maintenance requirements for the affected requirements for the affected source monitors?source monitors?

Q.Q. What are the installation, What are the installation, operation and maintenance operation and maintenance requirements for the affected requirements for the affected source monitors?source monitors?

Q/A (cont’d.)Q/A (cont’d.)#6#6

A.A. For each capture system that is For each capture system that is subject to Subpart KKKK, the subject to Subpart KKKK, the facility must install, operate, facility must install, operate, and maintain each CPMS and maintain each CPMS according to the requirements according to the requirements in in § 63.3492§ 63.3492..

A.A. For each capture system that is For each capture system that is subject to Subpart KKKK, the subject to Subpart KKKK, the facility must install, operate, facility must install, operate, and maintain each CPMS and maintain each CPMS according to the requirements according to the requirements in in § 63.3492§ 63.3492..

Q/A (cont’d.)Q/A (cont’d.)#7#7

Q.Q. How does the facility How does the facility demonstrate continuous demonstrate continuous compliance with the work compliance with the work practice standards that apply to practice standards that apply to the affected source?the affected source?

Q.Q. How does the facility How does the facility demonstrate continuous demonstrate continuous compliance with the work compliance with the work practice standards that apply to practice standards that apply to the affected source?the affected source?

Q/A (cont’d.)Q/A (cont’d.)#7#7

Q/A (cont’d.)Q/A (cont’d.)#7#7

A.A. The facility must maintain records The facility must maintain records that document continuous that document continuous compliance noted in compliance noted in § 63.3493.§ 63.3493.

A.A. The facility must maintain records The facility must maintain records that document continuous that document continuous compliance noted in compliance noted in § 63.3493.§ 63.3493.

Q/A (cont’d.)Q/A (cont’d.)#8#8

Q.Q. What are the Health affects What are the Health affects Associated with HAP Emissions Associated with HAP Emissions From the Surface Coating of From the Surface Coating of Metal Cans?Metal Cans?

Q.Q. What are the Health affects What are the Health affects Associated with HAP Emissions Associated with HAP Emissions From the Surface Coating of From the Surface Coating of Metal Cans?Metal Cans?

Q/A (cont’d.)Q/A (cont’d.)#8#8

A.A. Ethylene glycol mono-butyl ether Ethylene glycol mono-butyl ether and other glycol ethers, xylenes, and other glycol ethers, xylenes, hexane, MEK and MIBK account hexane, MEK and MIBK account for 95% of the nationwide HAP for 95% of the nationwide HAP emissions from the source emissions from the source category. These HAPS are category. These HAPS are associated with a variety of associated with a variety of adverse health affects adverse health affects (cont’d.)(cont’d.)

A.A. Ethylene glycol mono-butyl ether Ethylene glycol mono-butyl ether and other glycol ethers, xylenes, and other glycol ethers, xylenes, hexane, MEK and MIBK account hexane, MEK and MIBK account for 95% of the nationwide HAP for 95% of the nationwide HAP emissions from the source emissions from the source category. These HAPS are category. These HAPS are associated with a variety of associated with a variety of adverse health affects adverse health affects (cont’d.)(cont’d.)

Q/A (cont’d.)Q/A (cont’d.)#8#8

A.A. which include chronic health which include chronic health disorders (e.g., birth defects and disorders (e.g., birth defects and affects on the central nervous affects on the central nervous system, liver, and heart) and acute system, liver, and heart) and acute health disorders (e.g., irritation of health disorders (e.g., irritation of the lung, skin, and mucous the lung, skin, and mucous membranes, affects on the central membranes, affects on the central nervous system and possibly nervous system and possibly cancer.cancer.

A.A. which include chronic health which include chronic health disorders (e.g., birth defects and disorders (e.g., birth defects and affects on the central nervous affects on the central nervous system, liver, and heart) and acute system, liver, and heart) and acute health disorders (e.g., irritation of health disorders (e.g., irritation of the lung, skin, and mucous the lung, skin, and mucous membranes, affects on the central membranes, affects on the central nervous system and possibly nervous system and possibly cancer.cancer.

Q/A (cont’d.)Q/A (cont’d.)#9#9

Q.Q. Can a facility be considered in Can a facility be considered in compliance with the Initial compliance with the Initial Notification requirement if the Notification requirement if the facility had filed their Section facility had filed their Section 112J notice on time?112J notice on time?

Q.Q. Can a facility be considered in Can a facility be considered in compliance with the Initial compliance with the Initial Notification requirement if the Notification requirement if the facility had filed their Section facility had filed their Section 112J notice on time?112J notice on time?

Q/A (cont’d.)Q/A (cont’d.)#9#9

A.A. The Section 112J notice requires The Section 112J notice requires additional information above and additional information above and beyond the Initial Notification beyond the Initial Notification requirement. As such, the facility requirement. As such, the facility would be considered in would be considered in compliance with the IN compliance with the IN requirement and filing the Initial requirement and filing the Initial Notification would be redundant.Notification would be redundant.

A.A. The Section 112J notice requires The Section 112J notice requires additional information above and additional information above and beyond the Initial Notification beyond the Initial Notification requirement. As such, the facility requirement. As such, the facility would be considered in would be considered in compliance with the IN compliance with the IN requirement and filing the Initial requirement and filing the Initial Notification would be redundant.Notification would be redundant.

Q/A (cont’d.)Q/A (cont’d.)#10#10

Q.Q. What does a deviation from What does a deviation from the rule mean?the rule mean?

Q.Q. What does a deviation from What does a deviation from the rule mean?the rule mean?

Q/A (cont’d.)Q/A (cont’d.)#10#10

A.A. Deviation means any instance in Deviation means any instance in which an affected source fails to which an affected source fails to meet any obligations required by meet any obligations required by Subpart KKKK. This is not limited Subpart KKKK. This is not limited to any emissions limitation, work to any emissions limitation, work practice standard, or operation and practice standard, or operation and maintenance requirement;maintenance requirement;

(continued on next slide) (continued on next slide)

A.A. Deviation means any instance in Deviation means any instance in which an affected source fails to which an affected source fails to meet any obligations required by meet any obligations required by Subpart KKKK. This is not limited Subpart KKKK. This is not limited to any emissions limitation, work to any emissions limitation, work practice standard, or operation and practice standard, or operation and maintenance requirement;maintenance requirement;

(continued on next slide) (continued on next slide)

Q/A (cont’d.)Q/A (cont’d.)#10#10

Answer Continued:Answer Continued:The affected source fails The affected source fails to meet any terms or to meet any terms or conditions adopted to conditions adopted to implement an applicable implement an applicable under Subpart KKKK.under Subpart KKKK.

Answer Continued:Answer Continued:The affected source fails The affected source fails to meet any terms or to meet any terms or conditions adopted to conditions adopted to implement an applicable implement an applicable under Subpart KKKK.under Subpart KKKK.

Q/A (cont’d.)Q/A (cont’d.)#10#10

Answer Continued:Answer Continued:The affected source fails The affected source fails to meet emissions to meet emissions limitations, including limitations, including operating limits or work operating limits or work practice standards in this practice standards in this Subpart.Subpart.

Answer Continued:Answer Continued:The affected source fails The affected source fails to meet emissions to meet emissions limitations, including limitations, including operating limits or work operating limits or work practice standards in this practice standards in this Subpart.Subpart.

Q/A (cont’d.)Q/A (cont’d.)#11#11

Q/A (cont’d.)Q/A (cont’d.)#11#11

Q.Q. If a failure to meet the If a failure to meet the emissions limitation is emissions limitation is permitted by Subpart KKKK, is permitted by Subpart KKKK, is the affected source exonerated the affected source exonerated from the non-compliant from the non-compliant condition?condition?

Q.Q. If a failure to meet the If a failure to meet the emissions limitation is emissions limitation is permitted by Subpart KKKK, is permitted by Subpart KKKK, is the affected source exonerated the affected source exonerated from the non-compliant from the non-compliant condition?condition?

Q/A (cont’d.)Q/A (cont’d.)#11#11

Q/A (cont’d.)Q/A (cont’d.)#11#11

A.A. Failure to meet the emissions Failure to meet the emissions limitation, including the operating limitation, including the operating limits or work practice standards limits or work practice standards during startup, shutdown or during startup, shutdown or malfunction is considered a deviation malfunction is considered a deviation and must be reported as an and must be reported as an exceedance under Subpart KKKK. exceedance under Subpart KKKK.

A.A. Failure to meet the emissions Failure to meet the emissions limitation, including the operating limitation, including the operating limits or work practice standards limits or work practice standards during startup, shutdown or during startup, shutdown or malfunction is considered a deviation malfunction is considered a deviation and must be reported as an and must be reported as an exceedance under Subpart KKKK. exceedance under Subpart KKKK.

Q/A (cont’d.)Q/A (cont’d.)#12#12

Q.Q. How flexible is Subpart KKK How flexible is Subpart KKK regarding compliance with the regarding compliance with the rule?rule?

Q.Q. How flexible is Subpart KKK How flexible is Subpart KKK regarding compliance with the regarding compliance with the rule?rule?

Q/A (cont’d.)Q/A (cont’d.)#12#12

The affected source can choose The affected source can choose from several compliance from several compliance options in Subpart KKKK to options in Subpart KKKK to achieve the emission limit that achieve the emission limit that applies to the affected source.applies to the affected source.

The affected source can choose The affected source can choose from several compliance from several compliance options in Subpart KKKK to options in Subpart KKKK to achieve the emission limit that achieve the emission limit that applies to the affected source.applies to the affected source.

Q/A (cont’d.)Q/A (cont’d.)#13#13

Q/A (cont’d.)Q/A (cont’d.)#13#13

Q.Q. Do the operating limits apply Do the operating limits apply to all affected source?to all affected source?

Q.Q. Do the operating limits apply Do the operating limits apply to all affected source?to all affected source?

Q/A (cont’d.)Q/A (cont’d.)#13#13

Q/A (cont’d.)Q/A (cont’d.)#13#13

A.A. If the affected source reduces If the affected source reduces emissions by using a capture emissions by using a capture system and add-on control system and add-on control device( other than a solvent device( other than a solvent recovery system for which a source recovery system for which a source conducts a liquid-liquid material conducts a liquid-liquid material balance), the operating limits apply balance), the operating limits apply to the source. to the source.

A.A. If the affected source reduces If the affected source reduces emissions by using a capture emissions by using a capture system and add-on control system and add-on control device( other than a solvent device( other than a solvent recovery system for which a source recovery system for which a source conducts a liquid-liquid material conducts a liquid-liquid material balance), the operating limits apply balance), the operating limits apply to the source. to the source.

Q/A (cont’d.)Q/A (cont’d.)#14#14

Q/A (cont’d.)Q/A (cont’d.)#14#14

Q.Q. How does an affected source How does an affected source comply with Subpart KKKK of comply with Subpart KKKK of the source demonstrates the source demonstrates compliance based on the compliance based on the emissions rates without add-on emissions rates without add-on controls option?controls option?

Q.Q. How does an affected source How does an affected source comply with Subpart KKKK of comply with Subpart KKKK of the source demonstrates the source demonstrates compliance based on the compliance based on the emissions rates without add-on emissions rates without add-on controls option?controls option?

Q/A (cont’d.)Q/A (cont’d.)#14#14

A.A. The source must determine the The source must determine the mass of organic HAP in all coatings mass of organic HAP in all coatings and thinners used in each coating and thinners used in each coating type segment each month during type segment each month during the initial compliance period, and the initial compliance period, and the volume fraction of coating the volume fraction of coating solids in all coating type segment solids in all coating type segment used each month during the initial used each month during the initial compliance period.compliance period.

A.A. The source must determine the The source must determine the mass of organic HAP in all coatings mass of organic HAP in all coatings and thinners used in each coating and thinners used in each coating type segment each month during type segment each month during the initial compliance period, and the initial compliance period, and the volume fraction of coating the volume fraction of coating solids in all coating type segment solids in all coating type segment used each month during the initial used each month during the initial compliance period.compliance period.