Docstoc

subpart-mmmm

Document Sample
subpart-mmmm Powered By Docstoc
					40 CFR Part 63, Subpart MMMM

Miscellaneous Metal Parts
  and Products Surface
         Coating
   & P2 Opportunities for the
    Transportation Industry

             Hank Naour
             Illinois EPA
          September 23, 2003
    MISCELLANEOUS METAL PARTS &
      PRODUCTS, Subpart MMMM

• Rail Transportation; one of (14) sub-
  categories;
• The MACT standard will impact operations
  dealing with brakes, engines, freight cars,
  and locomotives;
• You are subject to this MACT standard if your
  facility is a major source of HAPs;
 The Organic HAPs Reduced by
        the Regulation
• Xylenes, toluene, methyl ethyl ketone (MEK),
  phenol, cresols/cresylic acid,
• Glycol ethers (including ethylene glycol
  monobutyl ether (EGBE)
• styrene, methyl isobutyl ketone (MIBK), and
• ethyl benzene.
       HAP Exposure Impacts

• Exposure to these substances has been
  demonstrated to cause adverse health effects
  such as irritation of the lung, skin, and
  mucous membranes, and effects on the
  central nervous system, liver, and heart. In
  general, these findings have only been shown
  with concentrations higher than those
  typically in the ambient air.
Operations Affected by the MACT
   Standard Subpart MMMM
• Application, drying, and curing of coatings;
• Spray gun in a spray booth or by dipping the
  substrate in a tank containing the coating;
• Open (flash-off) area;
• Drying/curing or air dry;
• Cleaning operations;
• Paint stripping;
• cleaning of spray guns & transfer lines;
• Cleaning of spray booth interiors;
• Applying of solvents to surfaces prior to coating
  application;
• Mixing and storage.
          Options to Compliance

Options for meeting the emissions limits; § 63.3891
• Must include all coatings, thinners and
  cleaning materials to determine if organic
  HAP emission rate is equal to or less than the
  applicable emissions limit in § 63.3890;
   1. The source can apply any of the
     compliance options to an individual coating
     operation or to multiple coating operations
     as a group or to the entire affected source;
         OPTIONS (cont)
  2. Can use different compliance options for
      different coating operations; or At different
      times on the same coating operation;
  3. Can use different compliance options when
      different coatings are applied to the same
      part, or when the same coating is applied to
      different parts;
– Cannot use different compliance options at
  the same time on the same coating
  operation;
– If source switches between compliance options
  for any coating or group of coating operations,
  source must document the switches and report in
  the next semi-annual compliance report.
            OPTIONS (cont)
• Compliance Material Option;
   – Must demonstrate that the organic HAP content of
     each coating used is less than or equal to the
     applicable emission limit (calculated under §
     63.3890);
   – Demonstrate that each thinner and cleaning
     material contains no organic HAP.
• Emissions Rate Without Add-on Controls;
   – Based upon a rolling 12-month emissions rate, the
     source must demonstrate the the total organic
     HAP contained in the coating, thinners and
     cleanings solvents is less than or equal to the
     applicable emission rate;
             OPTIONS (cont)
• Emissions Rate with Add-on Controls:
   – Demonstrate that, based upon the coatings,
     thinners and cleaning solvents used, and the
     emissions reductions achieved by emissions
     capture systems and add-on controls, the organic
     HAP emissions rate is less than or equal to the
     applicable emissions rate.
   – Operating limits to be met ;
   – Solvent recovery liquid-liquid material balances;
   – Work practice standards must be met.
      ADDITIONAL ITEMS FOR
          COMPLIANCE
• General Provisions (Subpart A)
• Notices
   – Initial Notification
   – Notification of Compliance Status
• Reports
   – Semi-annual Compliance Reports
   – Performance test reports
   – Startup, Shutdown, Malfunction
• Records [kept for(5) years]
   Compliance Date for Subpart
            MMMM
• Subpart MMMM has been signed by the USEPA
  Administrator and will be published in the Federal
  Register late September/early October;
• Existing sources must comply with Subpart MMMM
  (3) years from the date of publication;
• New sources must comply upon startup.
P2 IMPACT ON MMPP, SUBPART
           MMMM
• Compliant coatings
   – Water based coatings,
   – Powder-coat.
• New-age solvents
   – D-limonene;
   – Siloxanes;
   – Non-HAP Glycol-ethers;
   – New high-flash petroleum solvents.
• Enclosed cleaning operations (spray guns, rollers,
  etc,)
   GENERIC LETTER TO ALL
      TITLE V SOURCES
• Illinois has provided applicability
  determinations requested by a small number
  of potentially affected sources that are subject
  to the Section 112j “Hammer Provision” of the
  CAA.
• After the August, 2003 Final Listing MACT
  promulgation, Illinois EPA will send a generic
  letter to those affected Title V sources that
  may be subject to the listed 10-Year MACT
  Standards.
LETTER TO TITLE V SOURCES
Section 112j: MACT Source Category Promulgation for
  August 30, 2003 Court Ordered Deadline

Dear Environmental Coordinator:

On May 8, 2003, the United States Environmental
  Protection Agency (U.S. EPA) promulgated
  amendments to the rule known as “Section 112(j)”.
  The amendments were the result of a settlement
  agreement (Agreement) reached between the U.S.
  EPA and the Sierra Club on November 26, 2002. The
  entire settlement agreement may be found at 67 FR
  72875.
             LETTER (cont)
• This Agreement concerned the promulgation
  schedule of MACT standards for certain remaining
  Industrial Source Categories under Section 112 of the
  Clean Air Act (CAA).

• The first agreed to milestone was May 15, 2003.
  The U.S. EPA has already promulgated MACT
  standards for this set of Source Categories. U.S. EPA
  expects to promulgate the agreed to listed MACT
  standards (October 30 list) by August 30, 2003.
  Note: The Part 2 Application is not required for MACT
  standards that have been promulgated in the August
  30, 2003 round.
              LETTER (cont)
The purpose of this letter is to inform you that if you
  desire an applicability determination for any of the
  Section 112(j) MACT standards to which you may be
  subject, you should submit the attached request to
  the Illinois EPA in accordance with Section 112(j) of
  the CAA no later than November XX, 2003, as
  indicated in the Section 112(j), General Provisions
  Tables 1 & 2 (copy enclosed).

The enclosed Application form may be used for this
  purpose. Please complete item number 14 on the
  form by noting the appropriate MACT Subpart
  identification letters to which each source is subject.
  NOTE: The Subparts should have been listed in the
  Part 1 filing.
            LETTER (cont)

Please mail the completed enclosed form or
  equivalent information no later than
  November 30, 2003 to:

    ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
     BUREAU OF AIR
     ATTN: DONALD SUTTON
     1021 NORTH GRAND AVENUE, EAST
     P.O. BOX 19506
    SPRINGFIELD, IL 62794-95076
          LETTER (cont)

Finally, remember that the Part 1 filing
  made by each of the affected facilities
  required by May 15, 2002, will serve as
  the Initial Notification required by the
  General Provisions for each
  NESHAP/MACT Standard to which a
  facility is subject. The Agency
  recognizes the need to reduce
  duplication of filing and supports
  paperwork reduction.
          LETTER (cont)
 If you have any questions, please call Hank
 Naour at 217/524-4343

 Sincerely,

 Donald E. Sutton
 Acting Manager, Air Quality Planning Section
 Bureau of Air

Attachments
GENERIC Applicability FORM
• Illinois EPA will send a generic Applicability
  form to all potentially effected Title V sources;
• The Applicability Form has to be returned no
  later than November 30, 2003 if an
  applicability determination is desired.
• IEPA is continuing to work directly with the 10-
  year MACT sources, particularly the coatings
  MACT sources which are typically good
  candidates for P2 reductions/eliminations of
  HAPs, e.g., compliant coatings & solvents,
  reformulations
APPLICABILITY FORM

 See available form copies on the IEPA
  Website for MACT Training!!!!
 INDUSTRY OUTREACH
• Illinois EPA will provide workshop
  and seminar information for the
  business community that may be
  impacted by Subpart MMMM;
• The Agency is planning on
  developing CD (DVD) and web-
  casting access for use by the
  business community.
   MY E-mail Address is:


• hank.naour@epa.state.il.us

• IEPA Website:

• www.epa.state.il.us/air/mact

				
DOCUMENT INFO