METAL FURNITURE SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART RRRR July 2006.

METAL FURNITURE METAL FURNITURE SURFACE COATING SURFACE COATING MACT OVERVIEWMACT OVERVIEW

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART RRRRRRRR

July 2006July 2006

INTRODUCTIONINTRODUCTION

• On May 23, 2003, USEPA On May 23, 2003, USEPA promulgated the Federal standard, promulgated the Federal standard, Metal Furniture Surface Coating Metal Furniture Surface Coating NESHAP (National Emission NESHAP (National Emission Standards for Hazardous Air Standards for Hazardous Air Pollutants) 40 CFR Part 63, Subpart Pollutants) 40 CFR Part 63, Subpart RRRR.RRRR.

What we are What we are reviewing?reviewing?

• Rule applicabilityRule applicability– NSPS & NESHAP focusNSPS & NESHAP focus– Covered operationsCovered operations– Operations not coveredOperations not covered

• Standards to be followed, Standards to be followed, including work practice including work practice standardsstandards– Operating Limits Operating Limits

What we are reviewing?What we are reviewing?(cont’d)(cont’d)

•Important datesImportant dates•Compliance sample calculations Compliance sample calculations •Synthetic minor sourcesSynthetic minor sources•New or existing source New or existing source determinationdetermination•General rule requirementsGeneral rule requirements

What we are reviewing?What we are reviewing?(cont’d)(cont’d)

• Initial compliance demonstration Initial compliance demonstration • Notification, Recordkeeping and Notification, Recordkeeping and

Reporting requirementsReporting requirements• Compliance optionsCompliance options• Compliance examplesCompliance examples

What we are reviewing?What we are reviewing?(cont’d.)(cont’d.)

• Facility Inspection ProtocolFacility Inspection Protocol– Pre-Inspection ReviewPre-Inspection Review– Facility File ReviewFacility File Review– Facility InspectionFacility Inspection– Post-Inspection MeetingPost-Inspection Meeting– Follow-upFollow-up

• Frequently asked questionsFrequently asked questions

TYPICAL FACILITYTYPICAL FACILITY

• Video Separate “touch” accessVideo Separate “touch” access• I will reference the video in the I will reference the video in the

scriptscript

APPLICABILITY: APPLICABILITY: Who is Who is covered by this rule?covered by this rule? (Subpart (Subpart

RRRR, §63.4881)RRRR, §63.4881)• Own or operate an Own or operate an AFFECTED SOURCEAFFECTED SOURCE

at a facility that is a major source,at a facility that is a major source,• Located at a major source, orLocated at a major source, or• Part of a major source of hazardous air Part of a major source of hazardous air

pollutants (HAPs).pollutants (HAPs).• NSPS for NSPS for NEWNEW sources of VOC sources of VOC

Affected SourceAffected Source

• NSPS; Surface Coating operations NSPS; Surface Coating operations involve applying a thin layer of involve applying a thin layer of coating to an object for decorative coating to an object for decorative or protective purposesor protective purposes

• NESHAP similar definition; stops NESHAP similar definition; stops herehere

• VOCs vs HAPs; change in criteria VOCs vs HAPs; change in criteria and stringencyand stringency

Affected Source Affected Source (cont’d.)(cont’d.)

• Any new or existing facility that Any new or existing facility that is a major source and applies is a major source and applies Coatings to a metal surface,Coatings to a metal surface,

• Metal surface is, but not limited Metal surface is, but not limited to:to:– Components of furniture Components of furniture

constructed either entirely or constructed either entirely or partially from metalpartially from metal

Affected Source Affected Source (cont’d.)(cont’d.)

– Components and products of Components and products of the types:the types:•Household,Household,•Office, Office, •Institutional,Institutional,•Laboratory,Laboratory,•Hospital,Hospital,•Public building,Public building,•Restaurant,Restaurant,

Affected Source Affected Source (cont’d.)(cont’d.)

•Barber Shop,Barber Shop,•Beauty Shop, andBeauty Shop, and•Dental furniture,Dental furniture,•Office and store fixtures,Office and store fixtures,•Partitions,Partitions,

Affected Source Affected Source (cont’d.)(cont’d.)

•Shelving,Shelving,•Lockers,Lockers,•Lamps,Lamps,•Lighting fixtures, andLighting fixtures, and•Waste baskets.Waste baskets.

What are some coatings What are some coatings impacted by Subpart impacted by Subpart

RRRR?RRRR?• Materials applied to a substrate Materials applied to a substrate

for decorative, protective, or for decorative, protective, or functional purposes,functional purposes,

• These include, but are not These include, but are not limited to:limited to:– PaintsPaints– SealantsSealants

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What are some coatings What are some coatings impacted by Subpart RRRR? impacted by Subpart RRRR?

(cont’d.)(cont’d.)

– CaulksCaulks– InksInks– AdhesivesAdhesives– MaskantsMaskants

Applicability: Who is Applicability: Who is NOTNOT covered by this Rule covered by this Rule

(§63.4881)(§63.4881)• Sources that only use HAP FREE Sources that only use HAP FREE

COATINGS, thinners, and cleaning COATINGS, thinners, and cleaning materialsmaterials

• Surface coating metal components of Surface coating metal components of wood furniture in an activity subject wood furniture in an activity subject to the wood furniture MACT (40CFR to the wood furniture MACT (40CFR 63, Subpart JJ)63, Subpart JJ)

Non-Applicability Non-Applicability (cont’d.)(cont’d.)

• Surface coating of small items (e.g., Surface coating of small items (e.g., hinges, knobs, screws) that have a hinges, knobs, screws) that have a wider use beyond metal furniture and wider use beyond metal furniture and are not being coated at a metal are not being coated at a metal furniture sourcefurniture source

• Research or laboratory facilities or Research or laboratory facilities or part of a janitorial or building and part of a janitorial or building and facility maintenance operationsfacility maintenance operations

NON-Applicability NON-Applicability (cont’d.)(cont’d.)

• Surface coating for metal furniture for Surface coating for metal furniture for repair or maintenance and not for repair or maintenance and not for commerce, unless these activities commerce, unless these activities alone constitute a major sourcealone constitute a major source

• Sources that coat metal furniture Sources that coat metal furniture performed on-site at installations performed on-site at installations owned by the Military, including the owned by the Military, including the Coast Guard and the National Guard Coast Guard and the National Guard of any Stateof any State

NON-Applicability NON-Applicability (cont’d.)(cont’d.)

• Coating applications using hand-held Coating applications using hand-held non-refillable aerosol containers, non-refillable aerosol containers, touch-up markers, or marking pens.touch-up markers, or marking pens.

Coating Operations Coating Operations ExamplesExamples

1.1. Coatings operations at facilities Coatings operations at facilities subject to wood furniture rule subject to wood furniture rule (40 CFR Part 63, Subpart JJ) (40 CFR Part 63, Subpart JJ) would continue to be subject to would continue to be subject to the rule. the rule.

Examples #1 (cont’d.)Examples #1 (cont’d.)

– This would be the case even if This would be the case even if the items coated contained the items coated contained metal components as long as metal components as long as the items met the definition of the items met the definition of wood furniture or wood wood furniture or wood furniture component in furniture component in 63.801(a) of Subpart JJ.63.801(a) of Subpart JJ.

EXAMPLES (cont’d.)EXAMPLES (cont’d.)

2.2. Coating operations at facilities that Coating operations at facilities that coat metal furniture as defined in the coat metal furniture as defined in the rule, constructed either entirely or rule, constructed either entirely or partially from metal (but not partially from metal (but not qualifying as wood furniture qualifying as wood furniture components under Subpart JJ) would components under Subpart JJ) would be subject to the metal furniture rule.be subject to the metal furniture rule.

EXAMPLES (cont’d.)EXAMPLES (cont’d.)3.3. Facilities that coat only metal Facilities that coat only metal

furniture components such as furniture components such as knobs, hinges, and screws (that knobs, hinges, and screws (that is, components that are of a is, components that are of a more generic nature and could more generic nature and could have broader uses in products have broader uses in products other than metal furniture and other than metal furniture and provide these components provide these components exclusively to metal furniture exclusively to metal furniture mfg facilities, would be subject mfg facilities, would be subject to the metal furniture ruleto the metal furniture rule..

EXAMPLES (cont’d.)EXAMPLES (cont’d.)4.4. The applicability of the surface The applicability of the surface

coating rules when the item coating rules when the item coated is composed of both coated is composed of both metal and wood components in metal and wood components in approximately equivalent approximately equivalent percentages will depend percentages will depend primarily upon the functionality primarily upon the functionality of the entire unit. A common of the entire unit. A common example example

EXAMPLES #4 EXAMPLES #4 (cont’d.)(cont’d.)

4.4. of such an item is a commercial of such an item is a commercial shelving unit constructed of a shelving unit constructed of a metal base and wood backing. metal base and wood backing. For reasons related to structural For reasons related to structural rigidity or overall stability, the rigidity or overall stability, the functionality of this particular functionality of this particular shelving unit depends more on shelving unit depends more on the metal components than the the metal components than the wood components. wood components.

EXAMPLES (cont’d.)EXAMPLES (cont’d.)

5.5. The surface coating of this The surface coating of this shelving unit would be shelving unit would be regulated under the metal regulated under the metal furniture rule.furniture rule.

(continued on next 2 slides)(continued on next 2 slides)

EXAMPLES #5 EXAMPLES #5 (cont’d.)(cont’d.)

– Thus the surface coating of all Thus the surface coating of all components of this shelving components of this shelving unit, regardless of whether they unit, regardless of whether they are made of metal or wood, are made of metal or wood, would be regulated under the would be regulated under the metal furniture rule, so long as metal furniture rule, so long as the facility is a metal furniture the facility is a metal furniture facility.facility.

EXAMPLES #5 EXAMPLES #5 (cont’d.)(cont’d.)

– This would be true even if the This would be true even if the metal furniture mfg facility metal furniture mfg facility dedicated a coating line dedicated a coating line exclusively to the coating of exclusively to the coating of wood components.wood components.

EXAMPLES (cont’d.)EXAMPLES (cont’d.)

6.6. Coating operations such as those Coating operations such as those presented in example 5 may not presented in example 5 may not involve items that can be readily involve items that can be readily classified according to classified according to functionality.functionality.

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

EXAMPLES #6 EXAMPLES #6 (cont’d.)(cont’d.)

For those situations, the applicability For those situations, the applicability determination would be made on a c/c determination would be made on a c/c basis taking into account functionality and basis taking into account functionality and other relevant factors. other relevant factors. These factors may include primary NAICS These factors may include primary NAICS code for the facility, amount of surface code for the facility, amount of surface area coated for each type of substrate area coated for each type of substrate and how the coating operations have and how the coating operations have been classified for other surface coating been classified for other surface coating rules (such as NSPS and State rules)rules (such as NSPS and State rules)

EXAMPLES (cont’d.)EXAMPLES (cont’d.)

7.7. A facility that is a new affected A facility that is a new affected source is allowed to demonstrate source is allowed to demonstrate on a c/c basis that organic HAP-on a c/c basis that organic HAP-free coating technologies cannot free coating technologies cannot be used for their specific products.be used for their specific products.

If such a request is approved, the If such a request is approved, the source would be required to meet an source would be required to meet an emissions limit of 0.094 kg organic emissions limit of 0.094 kg organic HAP per liter coating solids used.HAP per liter coating solids used.

EXAMPLES (cont’d.)EXAMPLES (cont’d.)

8. 8. USEPA Applicability USEPA Applicability Determination Index SiteDetermination Index Sitehttp://www.epa.gov/http://www.epa.gov/Compliance/planning/data/air/Compliance/planning/data/air/adi.htmadi.htm

What Standards Require What Standards Require Compliance? (63.4890)Compliance? (63.4890)

• Existing Source: limit emissions to no Existing Source: limit emissions to no more than more than 0.10 kg organic HAP 0.10 kg organic HAP per liter (0.83 #/gal)per liter (0.83 #/gal)

• New or reconstructed sourceNew or reconstructed source; no ; no emissions of organic HAP each monthemissions of organic HAP each month

What Standards Require What Standards Require Compliance? (Cont’d.)Compliance? (Cont’d.)

• New or reconstructed source and New or reconstructed source and receive approval to use an alternative receive approval to use an alternative new source emission limit, emissions new source emission limit, emissions must be limited to no more than must be limited to no more than 0.094 kg organic HAP per liter of 0.094 kg organic HAP per liter of coatings solids used (0.78 lb/gal) coatings solids used (0.78 lb/gal) each montheach month

Work Practice Standards Work Practice Standards (63.4893)(63.4893)

• Use capture and add-on control Use capture and add-on control devices;devices;

• Develop and operate according to a Develop and operate according to a work practice plan which should work practice plan which should include:include:– Cover mixing and storage vessels Cover mixing and storage vessels

containing organic HAP-containing containing organic HAP-containing coatings, thinners, cleaning materials, coatings, thinners, cleaning materials, and waste materials except when and waste materials except when adding, removing or mixing contentsadding, removing or mixing contents

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

– Use closed containers or pipes to Use closed containers or pipes to store and convey organic HAP-store and convey organic HAP-containing coatings, thinners, containing coatings, thinners, cleaning materials, and waste cleaning materials, and waste materialsmaterials

– Minimize organic HAP emissions Minimize organic HAP emissions during cleaning of storage, mixing during cleaning of storage, mixing and conveying equipmentand conveying equipment

OperatingOperating Limits Limits

• The operating limits are the site-The operating limits are the site-specific parameter limits the facility specific parameter limits the facility determines for the capture and determines for the capture and control devices during the control devices during the performance test. The facility performance test. The facility operating limits must be monitored operating limits must be monitored by a continuous parameter by a continuous parameter monitoring system (CPMs)monitoring system (CPMs)

Important datesImportant dates• The final rule was published on May The final rule was published on May

23, 2003 , under 68 FR28606,23, 2003 , under 68 FR28606,• Existing major sources must comply Existing major sources must comply

by, May 23, 2006,by, May 23, 2006,• Operating new major sources should Operating new major sources should

have complied by April 24, 2002, or have complied by April 24, 2002, or startup, whichever was later,startup, whichever was later,

• New major sources under New major sources under construction must comply at startup.construction must comply at startup.