MACT Standards Surface Coating

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MACT Standards Surface Coating

• EnviroExpo
• May 6, 2003
• Stephen Kmiotek, Ph.D., P.E.
• EBI Consultants
• Air Waste Management Association

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Overall Approach to Surface Coating MACT Standards

• Coatings and Composites Coordinated Rule (CCCR)
• Goal is to develop consistent regulations for all
  coating operations

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Overview

• Review key provisions of several standards
• Applicability
• Standards
• Monitoring, Record keeping, Reporting
• Implementation schedule

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Source Categories

• Fabric Coating (63.4280 Subpart OOOO)
• Paper Other Web (63.3280. Subpart JJJJ)
• Metal Coil (63.5080, Subpart SSSS)
• Metal Can (63.3480, Subpart KKKK)
• Misc. Metal Parts (63.3880, Subpart MMMM)
• Misc. Plastic Parts (63.4480, Subpart PPPP)

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Applicability - General

• All standards apply to facilities that are Major
  HAP Sources and conduct the specific source
  category
• The individual source category does NOT have to
  be major just the facility.

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Applicability - General

• Exemptions include
• RD and laboratory facilities
• Maintenance, facilities, buildings and grounds..
• Hobby shops, consumptive non-commercial use
  unless source category is a Major HAP Source
• Coatings that contain no HAPs
• Sources subject to more defined standard
• Extrusion of plastic onto part is NOT coating

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Standards - General

• In all cases, if an oxidizer is used to meet a
  standard, an outlet concentration limit of 20
  ppmv may be used in lieu of the Overall Control
  Efficiency (OCE) limit.
• In all cases, none means lt 1 HAP (lt 0.1
  carcinogenic HAP) in the coating. It explicitly
  does not mean zero emissions.
• All NSPS Standards are for VOC, not HAP

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Applicability Fabric Coating

• Coating
• Printing
• Slashing (sizing)
• Dyeing
• Finishing
• Related activities

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Standards Fabric Coating
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Applicability Paper/Web Coating

• Excludes
• Printing and publishing
• Magnetic tape
• Pressure sensitive tape
• Coil coating
• Fabric coating
• Etc.

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Standards Paper/Web Coating
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Applicability Metal Coil Coating

• Metal coil at least 0.006 in thick
• Coil less than 0.006 subject to JJJJ
• Excludes flexible packaging

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Standards Metal Coil Coating
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Applicability Metal Can Coating

• All can coating activities at facilities that use
  at least 1,500 gal/yr
• Excludes
• Coil
• Misc. metal parts
• Drums, pails, etc.

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Standards Metal Can Coating
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Applicability Misc. Metal Parts Coating

• Coating of any metal not elsewhere regulated
• Includes mixed metal/other parts if gt 50 of
  coating is applied on a metal surface
• Excludes hand-held, non-refillable containers

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Applicability Misc. Metal Parts Coating (contd)

• Applies to facilities that use at least 250 gal
  coating per year
• Exempt individual coating used less than 50
  gal/yr total exemption of 250 gal/yr

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Standards Misc. Metal Parts
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Applicability Misc. Plastic Parts Coating

• Coating of any plastic not elsewhere regulated
• Excludes any forms of extrusion or fiberglassing

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Standards Misc. Plastic Parts
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Monitoring

• Thermal oxidizer temp
• Measure/record at least every 15 min
• Calculate record 3-hour average
• Adsorber
• Measure/record total regeneration gas
• Measure/record temp of bed
• Initial compliance test of control system

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Record keeping

• Purchase, waste, composition of all coatings
• Calculate emissions on monthly basis
• Monitoring data
• 2 years of data on-site
• 3 additional years of data

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Reporting

• Semiannual Compliance Report
• January 31 July 31
• Emissions
• Deviations
• Certain CEMS/CPMS data downtime

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Implementation Schedule