40 CFR Part 63, Subpart MMMM Miscellaneous Metal Parts and Products Surface Coating & P2 Opportunities for the Transportation Industry Hank Naour Illinois.

40 CFR Part 63, Subpart MMMM

Miscellaneous Metal Parts and Products

Surface Coating& P2 Opportunities for the

Transportation Industry

Hank NaourIllinois 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 AGENCYBUREAU OF AIRATTN: DONALD SUTTON1021 NORTH GRAND AVENUE, EASTP.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. SuttonActing Manager, Air Quality Planning SectionBureau 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:

• [email protected]

• IEPA Website:

• www.epa.state.il.us/air/mact