plastic parts and products surface coating mact summary

8. What are the continuous compliance provisions for this rule?

Emission Limits

If using the compliant materials option, a facility must demonstrate continuously that each coating meets the applicable emission limit and that they use no organic HAP-containing thinners and/or other additives, or cleaning materials. If using the emission rate without add-on controls option, a facility must demonstrate continuously that  for each 12-month compliance period, the ratio of kg (lb) organic HAP emitted to kg (lb) coating solids used is less than or equal to the applicable emission limit. The same procedures for calculating the organic HAP emitted to coating solids used ratio that is used for the initial compliance period is used for continuous compliance.

For each coating operation in which the capture system and control device option is used (other than a solvent recovery system for which a liquid-liquid material balance is conducted), a facility must use continuous parameter monitoring results for the month as part of the determination of the mass of organic HAP emissions. If the monitoring results indicate no deviations from the operating limits and there were no bypasses of the control device, the facility can assume the capture system and control device is achieving the same percent emission reduction efficiency as it did during the most recent performance test in which compliance was demonstrated. The facility must then apply this percent reduction to the total mass of organic HAP in materials used in the controlled coating operations to determine the emissions from those operations during the month. If there were any deviations from the operating limits during the month or any bypasses of the control device, the facility must account for them in the calculation of the monthly emissions by assuming the capture system and control device were achieving zero emission reduction during the periods of deviation, unless they have other data indicating the actual efficiency of the emission capture system and add-on control device, and the use of these data is approved by your permitting authority. The organic HAP emission rate is determined by dividing the total mass of organic HAP emissions for the 12-month compliance period by the total mass of coating solids used during the 12-month compliance period. Every month, the facility must calculate the emission rate for the previous 12-month period.

For each coating operation on which a solvent recovery system is used and a liquid-liquid material balance is conducted each month, the facility must use the liquid-liquid material balance to determine control efficiency. To determine the overall control efficiency, the facility must measure the amount of all materials used during each month and determine the volatile matter content of these materials. They must also measure the amount of volatile matter recovered by the solvent recovery system during the month, calculate the overall control efficiency, and apply it to the total mass of organic HAP in the materials used to determine total organic HAP emissions each month. Then the 12- month organic HAP emission rate is determined in the same manner described above.

Operating Limits

If a capture system and control device is used, this rule requires a facility to achieve, on a continuous basis, the operating limits establish during the performance test. If the continuous monitoring shows that the capture system and control device are operating outside the range of values established during the performance test, then a deviation from the established operating limits has occurred.

If a capture system and control device is operated with bypass lines that could allow emissions to bypass the control device, then a facility must demonstrate that captured organic HAP emissions within the affected source are being routed to the control device by monitoring for potential bypass of the control device. A facility may choose from the following five monitoring procedures:

• Flow control position indicator to provide a record of whether the exhaust stream is directed to the control device.

• Car-seal or lock-and-key valve closures to secure the bypass line valve in the closed position when the control device is operating.

• Valve closure monitoring to ensure any bypass line valve or damper is closed when the control device is operating.

• Automatic shutdown system to stop the coating operation when flow is diverted from the control device.

• Flow direction indicator to provide a record of whether the exhaust stream is flowing toward the control device. A deviation would occur for any period of time the bypass monitoring indicates that emissions are not routed to the control device.

Work Practices

If an emission capture system and control device is used for compliance, a facility is required to implement, on an ongoing basis, the work practice plan developed during the initial compliance period. If a work plan has not been developed for reducing organic HAP emissions or if it has not been implemented, this would be a deviation from the work practice standard.

If a capture system and control device is used for compliance, a facility would be required to operate according to their SSMP during periods of startup, shutdown, or malfunction of the capture system and control device.