METAL COIL SURFACE METAL COIL SURFACE MACT COMPLIANCE MACT COMPLIANCE

ASSURANCEASSURANCE

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART SSSSSSSS

May 2006May 2006

Compliance TimelineCompliance Timeline

IMPORTANT COMPLIANCE IMPORTANT COMPLIANCE INFORMATION SOURCEINFORMATION SOURCE

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IMPORTANT COMPLIANCE IMPORTANT COMPLIANCE INFORMATION SOURCEINFORMATION SOURCE

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Compliance DatesCompliance Dates

The final rule was published on June The final rule was published on June 10, 2002 , under 10, 2002 , under 67 FR 3979467 FR 39794

Existing major sources must comply Existing major sources must comply with:with:– Emissions limitations;Emissions limitations;– Operation & Maintenance Operation & Maintenance

requirement;requirement;– Major source status determination;Major source status determination;

The final rule was published on June The final rule was published on June 10, 2002 , under 10, 2002 , under 67 FR 3979467 FR 39794

Existing major sources must comply Existing major sources must comply with:with:– Emissions limitations;Emissions limitations;– Operation & Maintenance Operation & Maintenance

requirement;requirement;– Major source status determination;Major source status determination;

Compliance Dates (cont’d.)Compliance Dates (cont’d.)

New effected sources operating on or New effected sources operating on or after July 18, 2002 after July 18, 2002 (63.5130)(63.5130) should should have complied by June 10, 2002 or have complied by June 10, 2002 or startup, whichever was later. startup, whichever was later. Existing sources must comply by Existing sources must comply by June 10, 2005.June 10, 2005.

New effected sources operating on or New effected sources operating on or after July 18, 2002 after July 18, 2002 (63.5130)(63.5130) should should have complied by June 10, 2002 or have complied by June 10, 2002 or startup, whichever was later. startup, whichever was later. Existing sources must comply by Existing sources must comply by June 10, 2005.June 10, 2005.

Compliance Dates Compliance Dates (cont’d.)(cont’d.)

If the METAL COIL COATING FACILITY If the METAL COIL COATING FACILITY is an area source, but becomes a is an area source, but becomes a major source of HAP, compliance of major source of HAP, compliance of [[§63.5130]§63.5130] i is required upon startup.s required upon startup.

If the METAL COIL COATING FACILITY If the METAL COIL COATING FACILITY is an area source, but becomes a is an area source, but becomes a major source of HAP, compliance of major source of HAP, compliance of [[§63.5130]§63.5130] i is required upon startup.s required upon startup.

Compliance Dates Compliance Dates (cont’d.)(cont’d.)

The effected sources must meet the The effected sources must meet the notification and scheduling notification and scheduling requirements in requirements in [[§ 63.5180)].§ 63.5180)]. Some Some of these notifications must be of these notifications must be submitted before the effected source submitted before the effected source compliance date.compliance date.

The effected sources must meet the The effected sources must meet the notification and scheduling notification and scheduling requirements in requirements in [[§ 63.5180)].§ 63.5180)]. Some Some of these notifications must be of these notifications must be submitted before the effected source submitted before the effected source compliance date.compliance date.

Compliance Options Compliance Options (§63.5170)(§63.5170)

1)1) “AS PURCHASED” Compliant “AS PURCHASED” Compliant Material Option – Each coating the Material Option – Each coating the effected source uses during each 12-effected source uses during each 12-month compliance period must not month compliance period must not exceed 0.046 kg HAP per liter solids, exceed 0.046 kg HAP per liter solids, as purchased.as purchased.

1)1) “AS PURCHASED” Compliant “AS PURCHASED” Compliant Material Option – Each coating the Material Option – Each coating the effected source uses during each 12-effected source uses during each 12-month compliance period must not month compliance period must not exceed 0.046 kg HAP per liter solids, exceed 0.046 kg HAP per liter solids, as purchased.as purchased.

Compliance Options Compliance Options (§63.5170)(§63.5170)

2)2) ““AS APPLIED” Compliant AS APPLIED” Compliant Material Option- Material Option-

a)a) Each coating the source uses Each coating the source uses during each 12-month during each 12-month compliance period must not compliance period must not exceed 0.046 kg HAP per liter exceed 0.046 kg HAP per liter solids, as applied, determined solids, as applied, determined monthly.monthly.

2)2) ““AS APPLIED” Compliant AS APPLIED” Compliant Material Option- Material Option-

a)a) Each coating the source uses Each coating the source uses during each 12-month during each 12-month compliance period must not compliance period must not exceed 0.046 kg HAP per liter exceed 0.046 kg HAP per liter solids, as applied, determined solids, as applied, determined monthly.monthly.

Compliance Options Compliance Options (Cont’d.)(Cont’d.)

2)2) ““AS APPLIED” Compliant AS APPLIED” Compliant Material Option- (Cont’d.)Material Option- (Cont’d.)

b)b) The rolling 12-month The rolling 12-month average of all coating average of all coating materials must not exceed materials must not exceed 0.046 kg HAP per liter solids 0.046 kg HAP per liter solids determined monthly.determined monthly.

2)2) ““AS APPLIED” Compliant AS APPLIED” Compliant Material Option- (Cont’d.)Material Option- (Cont’d.)

b)b) The rolling 12-month The rolling 12-month average of all coating average of all coating materials must not exceed materials must not exceed 0.046 kg HAP per liter solids 0.046 kg HAP per liter solids determined monthly.determined monthly.

Compliance Options Compliance Options (cont’d.)(cont’d.)

3)3) ADD-ON CONTROLS (OVERALL ADD-ON CONTROLS (OVERALL CONTROL EFFICIENCY) –CONTROL EFFICIENCY) –– a)a) Each emission capture Each emission capture

system and associated control system and associated control device must reduce emissions device must reduce emissions by 98% (i.e., achieve an overall by 98% (i.e., achieve an overall control efficiency of 98%)control efficiency of 98%)

3)3) ADD-ON CONTROLS (OVERALL ADD-ON CONTROLS (OVERALL CONTROL EFFICIENCY) –CONTROL EFFICIENCY) –– a)a) Each emission capture Each emission capture

system and associated control system and associated control device must reduce emissions device must reduce emissions by 98% (i.e., achieve an overall by 98% (i.e., achieve an overall control efficiency of 98%)control efficiency of 98%)

Compliance Options Compliance Options (cont’d.)(cont’d.)

3)3) ADD-ON CONTROLS (cont’d.)ADD-ON CONTROLS (cont’d.)– b)b) The effected source may use The effected source may use

a total enclosure (100% a total enclosure (100% capture) and an oxidized to capture) and an oxidized to reduce organic HAP emissions reduce organic HAP emissions to no more than a to no more than a concentration of 20 parts ppm concentration of 20 parts ppm by volume on a dry basis at by volume on a dry basis at the outlet.the outlet.

3)3) ADD-ON CONTROLS (cont’d.)ADD-ON CONTROLS (cont’d.)– b)b) The effected source may use The effected source may use

a total enclosure (100% a total enclosure (100% capture) and an oxidized to capture) and an oxidized to reduce organic HAP emissions reduce organic HAP emissions to no more than a to no more than a concentration of 20 parts ppm concentration of 20 parts ppm by volume on a dry basis at by volume on a dry basis at the outlet.the outlet.

Compliance Options Compliance Options (cont’d.)(cont’d.)

4)4) EMISSION RATE WITH ADD-ON EMISSION RATE WITH ADD-ON CONTROLS-CONTROLS-– The 12-month rolling average The 12-month rolling average

(determined monthly) of all coating (determined monthly) of all coating materials used by the source, materials used by the source, including the emission capture and including the emission capture and control device efficiency, must not control device efficiency, must not exceed 0.046 kg/liter solids, exceed 0.046 kg/liter solids, determined monthly.determined monthly.

4)4) EMISSION RATE WITH ADD-ON EMISSION RATE WITH ADD-ON CONTROLS-CONTROLS-– The 12-month rolling average The 12-month rolling average

(determined monthly) of all coating (determined monthly) of all coating materials used by the source, materials used by the source, including the emission capture and including the emission capture and control device efficiency, must not control device efficiency, must not exceed 0.046 kg/liter solids, exceed 0.046 kg/liter solids, determined monthly.determined monthly.

Operations & Operations & Maintenance Maintenance

Requirements (§63.6(1)-Requirements (§63.6(1)-(2)(2)Effected facilities must operate and Effected facilities must operate and

maintain the sources, including air maintain the sources, including air pollution control and monitoring pollution control and monitoring equipment in a manner consistent equipment in a manner consistent with good air pollution practices that with good air pollution practices that minimizes air emissions to the level minimizes air emissions to the level required in Subpart SSSS.required in Subpart SSSS.

Effected facilities must operate and Effected facilities must operate and maintain the sources, including air maintain the sources, including air pollution control and monitoring pollution control and monitoring equipment in a manner consistent equipment in a manner consistent with good air pollution practices that with good air pollution practices that minimizes air emissions to the level minimizes air emissions to the level required in Subpart SSSS.required in Subpart SSSS.

Operations & Maintenance Operations & Maintenance Requirements (Cont’d.)Requirements (Cont’d.)

Effected sources must prepare and Effected sources must prepare and operate at all times according to a operate at all times according to a written operation and maintenance written operation and maintenance plan for each capture and collection plan for each capture and collection control device controlling emissions control device controlling emissions subject to Subpart SSSS.subject to Subpart SSSS.

Effected sources must prepare and Effected sources must prepare and operate at all times according to a operate at all times according to a written operation and maintenance written operation and maintenance plan for each capture and collection plan for each capture and collection control device controlling emissions control device controlling emissions subject to Subpart SSSS.subject to Subpart SSSS.

O & M Requirements O & M Requirements (cont’d.)(cont’d.)

Each plan must contain the elements Each plan must contain the elements required in required in §63.6(e)(1)-(2) of the §63.6(e)(1)-(2) of the General Provisions.General Provisions.– Equipment monthly inspectionsEquipment monthly inspections– Operating limits for each capture systemOperating limits for each capture system– Appropriate operating limit parameters Appropriate operating limit parameters

and design scope, i.e., control of and design scope, i.e., control of multiple emissions sourcesmultiple emissions sources

Each plan must contain the elements Each plan must contain the elements required in required in §63.6(e)(1)-(2) of the §63.6(e)(1)-(2) of the General Provisions.General Provisions.– Equipment monthly inspectionsEquipment monthly inspections– Operating limits for each capture systemOperating limits for each capture system– Appropriate operating limit parameters Appropriate operating limit parameters

and design scope, i.e., control of and design scope, i.e., control of multiple emissions sourcesmultiple emissions sources

O & M Requirements O & M Requirements (cont’d.)(cont’d.)

– Preventative maintenance plan Preventative maintenance plan for each control device including for each control device including the manufacturer’s the manufacturer’s recommended maintenance recommended maintenance instructionsinstructions

– Preventative maintenance plan Preventative maintenance plan for each control device including for each control device including the manufacturer’s the manufacturer’s recommended maintenance recommended maintenance instructionsinstructions

SSM Plan SSM Plan Requirements(§63.5180)Requirements(§63.5180)

If the effected sources uses an If the effected sources uses an emission capture system and add-emission capture system and add-on control device for compliance on control device for compliance purposes with Subpart SSSS, the purposes with Subpart SSSS, the source must develop and source must develop and implement a written startup, implement a written startup, shutdown and malfunction plan shutdown and malfunction plan (SSMP);(SSMP);

If the effected sources uses an If the effected sources uses an emission capture system and add-emission capture system and add-on control device for compliance on control device for compliance purposes with Subpart SSSS, the purposes with Subpart SSSS, the source must develop and source must develop and implement a written startup, implement a written startup, shutdown and malfunction plan shutdown and malfunction plan (SSMP);(SSMP);

SSMP (cont’d.)SSMP (cont’d.) SSMP must meet provisions in SSMP must meet provisions in

§63.6(e)(3).§63.6(e)(3). SSMP must address startup, SSMP must address startup,

shutdown and corrective actions in shutdown and corrective actions in the event of a malfunction of the the event of a malfunction of the emissions capture system or the add-emissions capture system or the add-on device.on device.

SSMP must meet provisions in SSMP must meet provisions in §63.6(e)(3).§63.6(e)(3).

SSMP must address startup, SSMP must address startup, shutdown and corrective actions in shutdown and corrective actions in the event of a malfunction of the the event of a malfunction of the emissions capture system or the add-emissions capture system or the add-on device.on device.

SSMP (cont’d.)SSMP (cont’d.) The SSMP must also address any The SSMP must also address any

coating operation equipment that coating operation equipment that may cause increased emissions or may cause increased emissions or that would effect capture efficiency if that would effect capture efficiency if the process equipment malfunctions the process equipment malfunctions such as conveyors that move parts such as conveyors that move parts among enclosures.among enclosures.

The SSMP must also address any The SSMP must also address any coating operation equipment that coating operation equipment that may cause increased emissions or may cause increased emissions or that would effect capture efficiency if that would effect capture efficiency if the process equipment malfunctions the process equipment malfunctions such as conveyors that move parts such as conveyors that move parts among enclosures.among enclosures.

General Compliance General Compliance Requirements Requirements

(§63.5180)(§63.5180) The effected source must be in The effected source must be in

compliance with the:compliance with the:emissions limitationsemissions limitationsOperations and maintenance;Operations and maintenance;Startup, Shutdown and Malfunction Startup, Shutdown and Malfunction PlanPlan

The effected source must be in The effected source must be in compliance with the:compliance with the:

emissions limitationsemissions limitationsOperations and maintenance;Operations and maintenance;Startup, Shutdown and Malfunction Startup, Shutdown and Malfunction PlanPlan

General Compliance General Compliance (cont’d.)(cont’d.)

Maintain a log detailing the Maintain a log detailing the operation and maintenance of operation and maintenance of the process and emissions the process and emissions control equipment related to the control equipment related to the initial performance test and the initial performance test and the applicable operating limits for an applicable operating limits for an effected sourceeffected source

Maintain a log detailing the Maintain a log detailing the operation and maintenance of operation and maintenance of the process and emissions the process and emissions control equipment related to the control equipment related to the initial performance test and the initial performance test and the applicable operating limits for an applicable operating limits for an effected sourceeffected source

Initial Compliance Initial Compliance Requirements Requirements

(§63.5180)(§63.5180) Performance Test: A Performance Test: A

performance test must be performance test must be conducted conducted no later than 180 no later than 180 calendar dayscalendar days after the after the compliance date specific to an compliance date specific to an effected source using add-on effected source using add-on equipmentequipment.(§63.5170).(§63.5170)

Performance Test: A Performance Test: A performance test must be performance test must be conducted conducted no later than 180 no later than 180 calendar dayscalendar days after the after the compliance date specific to an compliance date specific to an effected source using add-on effected source using add-on equipmentequipment.(§63.5170).(§63.5170)

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

Notification of Compliance Status; For Notification of Compliance Status; For each work practice standard & each work practice standard & operation & maintenance requirement operation & maintenance requirement that applies to an effected source that applies to an effected source where an initial performance test is not where an initial performance test is not demonstrated, the effected source demonstrated, the effected source must demonstrate initial compliance no must demonstrate initial compliance no later than 30 calendar days after the later than 30 calendar days after the specific compliance date for the specific compliance date for the effected source.effected source.

Notification of Compliance Status; For Notification of Compliance Status; For each work practice standard & each work practice standard & operation & maintenance requirement operation & maintenance requirement that applies to an effected source that applies to an effected source where an initial performance test is not where an initial performance test is not demonstrated, the effected source demonstrated, the effected source must demonstrate initial compliance no must demonstrate initial compliance no later than 30 calendar days after the later than 30 calendar days after the specific compliance date for the specific compliance date for the effected source.effected source.

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

Notification of Intent to Conduct Notification of Intent to Conduct Performance Test; In the General Performance Test; In the General Provisions [§63.9(e)]requiremnet Provisions [§63.9(e)]requiremnet if the effected source is required if the effected source is required to conducts performance tests to conducts performance tests (e.g., those with add-on (e.g., those with add-on equipment), the effected source equipment), the effected source must submit a notification of must submit a notification of intent to conduct a performance intent to conduct a performance test 60 days prior to the test.test 60 days prior to the test.

Notification of Intent to Conduct Notification of Intent to Conduct Performance Test; In the General Performance Test; In the General Provisions [§63.9(e)]requiremnet Provisions [§63.9(e)]requiremnet if the effected source is required if the effected source is required to conducts performance tests to conducts performance tests (e.g., those with add-on (e.g., those with add-on equipment), the effected source equipment), the effected source must submit a notification of must submit a notification of intent to conduct a performance intent to conduct a performance test 60 days prior to the test.test 60 days prior to the test.

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

The effected source must install The effected source must install and maintain a CPMS specified in and maintain a CPMS specified in (§63.5180).(§63.5180).

Test MethodsTest Methods

Subpart SSSS clearly defines the Subpart SSSS clearly defines the test methods and other test methods and other procedures in procedures in §63.5160, 5170 & §63.5160, 5170 & §63.5180§63.5180 used to demonstrate used to demonstrate initial compliance with the initial compliance with the emissions limitationsemissions limitations

Subpart SSSS clearly defines the Subpart SSSS clearly defines the test methods and other test methods and other procedures in procedures in §63.5160, 5170 & §63.5160, 5170 & §63.5180§63.5180 used to demonstrate used to demonstrate initial compliance with the initial compliance with the emissions limitationsemissions limitations

Test Methods Test Methods (cont’d.)(cont’d.)

The procedures in The procedures in Subpart SSSS are Subpart SSSS are used to establish operating limits for:used to establish operating limits for:– Each capture systemEach capture system– Each combustion device.Each combustion device.

The procedures in The procedures in Subpart SSSS are Subpart SSSS are used to establish operating limits for:used to establish operating limits for:– Each capture systemEach capture system– Each combustion device.Each combustion device.

REPORTSREPORTS

Compliance reports are required Compliance reports are required by specific due dates;by specific due dates;

Compliance reports are required Compliance reports are required by specific due dates;by specific due dates;

REPORTS (cont’d.)REPORTS (cont’d.) Performance Test Report [(§63.5180]; Performance Test Report [(§63.5180];

if the effected source is required to if the effected source is required to conduct a performance tests (e.g., conduct a performance tests (e.g., those with add-on control equipment), those with add-on control equipment), the source must submit a performance the source must submit a performance test report within 60 days after test report within 60 days after completion of the performance test.completion of the performance test.

Performance Test Report [(§63.5180]; Performance Test Report [(§63.5180]; if the effected source is required to if the effected source is required to conduct a performance tests (e.g., conduct a performance tests (e.g., those with add-on control equipment), those with add-on control equipment), the source must submit a performance the source must submit a performance test report within 60 days after test report within 60 days after completion of the performance test.completion of the performance test.

REPORTS (cont’d.)REPORTS (cont’d.) SSM Reports SSM Reports [§63.5180];[§63.5180]; An SSM Report An SSM Report

must be submitted immediately if there must be submitted immediately if there is an SSM of the control device during the is an SSM of the control device during the reporting period that is not consistent reporting period that is not consistent with the SSM Plan. If actions taken were with the SSM Plan. If actions taken were consistent with the SSM Plan, the report consistent with the SSM Plan, the report must be submitted semi-annually.must be submitted semi-annually.

SSM Reports SSM Reports [§63.5180];[§63.5180]; An SSM Report An SSM Report must be submitted immediately if there must be submitted immediately if there is an SSM of the control device during the is an SSM of the control device during the reporting period that is not consistent reporting period that is not consistent with the SSM Plan. If actions taken were with the SSM Plan. If actions taken were consistent with the SSM Plan, the report consistent with the SSM Plan, the report must be submitted semi-annually.must be submitted semi-annually.

REPORTS (cont’d.)REPORTS (cont’d.) Semiannual Compliance reports Semiannual Compliance reports

[63.5180];[63.5180]; After the initial After the initial compliance period, each effected compliance period, each effected source must submit semiannual source must submit semiannual compliance reports.compliance reports.

Semiannual Compliance reports Semiannual Compliance reports [63.5180];[63.5180]; After the initial After the initial compliance period, each effected compliance period, each effected source must submit semiannual source must submit semiannual compliance reports.compliance reports.

Startup, Shutdown, Startup, Shutdown, Malfunction Reports Malfunction Reports

[§63.5180][§63.5180] A Startup, Shutdown, Malfunction A Startup, Shutdown, Malfunction

(SSM) report must be submitted (SSM) report must be submitted immediately if there was a startup, immediately if there was a startup, shutdown, or malfunction of the shutdown, or malfunction of the control device during the reporting control device during the reporting period that is not consistent with the period that is not consistent with the SSM Plan.SSM Plan.

A Startup, Shutdown, Malfunction A Startup, Shutdown, Malfunction (SSM) report must be submitted (SSM) report must be submitted immediately if there was a startup, immediately if there was a startup, shutdown, or malfunction of the shutdown, or malfunction of the control device during the reporting control device during the reporting period that is not consistent with the period that is not consistent with the SSM Plan.SSM Plan.

Startup, Shutdown, Startup, Shutdown, Malfunction Reports Malfunction Reports

(cont’d.)(cont’d.) If actions were consistent with the If actions were consistent with the

SSM Plan, the report must be SSM Plan, the report must be submitted during the required submitted during the required reporting period.reporting period.

If actions were consistent with the If actions were consistent with the SSM Plan, the report must be SSM Plan, the report must be submitted during the required submitted during the required reporting period.reporting period.

Records [§63.5190]Records [§63.5190] An effected source is required to An effected source is required to

keep records of reported keep records of reported information and all other information and all other information necessary to information necessary to document compliance with the document compliance with the rule for 5 years. There may be rule for 5 years. There may be additional requirements additional requirements depending on the compliance depending on the compliance option that the effected source option that the effected source may choose.may choose.

An effected source is required to An effected source is required to keep records of reported keep records of reported information and all other information and all other information necessary to information necessary to document compliance with the document compliance with the rule for 5 years. There may be rule for 5 years. There may be additional requirements additional requirements depending on the compliance depending on the compliance option that the effected source option that the effected source may choose.may choose.

Records (cont’d.)Records (cont’d.)An effected facility is required to keep An effected facility is required to keep records of reported information and records of reported information and all the other information necessary to all the other information necessary to document compliance with the final document compliance with the final rule for 5 yearsrule for 5 years

There may be additional requirements There may be additional requirements depending on the compliance option depending on the compliance option that is chosen.that is chosen.

Title V ConnectTitle V Connect

Check Facilities that have Federally Check Facilities that have Federally Enforceable LimitsEnforceable LimitsLimited number of Major Facilities; Limited number of Major Facilities; who are they?who are they?

Check Facilities that have Federally Check Facilities that have Federally Enforceable LimitsEnforceable LimitsLimited number of Major Facilities; Limited number of Major Facilities; who are they?who are they?

Title V Connect Title V Connect (cont’d.)(cont’d.)

Section 112j, T5 connection (<>3 Section 112j, T5 connection (<>3 years) on T5 Permityears) on T5 PermitSection 112j is no longer factor on Section 112j is no longer factor on surface coaterssurface coaters

Section 112j, T5 connection (<>3 Section 112j, T5 connection (<>3 years) on T5 Permityears) on T5 PermitSection 112j is no longer factor on Section 112j is no longer factor on surface coaterssurface coaters

Title V IssuesTitle V Issues

• Each affected source that has Each affected source that has obtained a title V operating permit obtained a title V operating permit required by 40 CFR part 70 or 71 required by 40 CFR part 70 or 71 must report all deviations as defined must report all deviations as defined in the regulation for the semiannual in the regulation for the semiannual monitoring report required by Sec. monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A).(A).

• Each affected source that has Each affected source that has obtained a title V operating permit obtained a title V operating permit required by 40 CFR part 70 or 71 required by 40 CFR part 70 or 71 must report all deviations as defined must report all deviations as defined in the regulation for the semiannual in the regulation for the semiannual monitoring report required by Sec. monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A).(A).

Title V Issues Title V Issues (cont’d.)(cont’d.)

• If an affected source submits a If an affected source submits a compliance report required by compliance report required by Subpart SSSS along with, or as part Subpart SSSS along with, or as part of, the semiannual monitoring report of, the semiannual monitoring report required by Sec. 70.6(a)(3)(iii)(A) or required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), and the Sec. 71.6(a)(3)(iii)(A), and the compliance report includes all compliance report includes all required information concerning required information concerning deviations from any deviations from any (continued on (continued on next slide)next slide)

• If an affected source submits a If an affected source submits a compliance report required by compliance report required by Subpart SSSS along with, or as part Subpart SSSS along with, or as part of, the semiannual monitoring report of, the semiannual monitoring report required by Sec. 70.6(a)(3)(iii)(A) or required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), and the Sec. 71.6(a)(3)(iii)(A), and the compliance report includes all compliance report includes all required information concerning required information concerning deviations from any deviations from any (continued on (continued on next slide)next slide)

Title V Issues (cont’d.)Title V Issues (cont’d.)

organic HAP emissions limitation organic HAP emissions limitation (including any operating limit) or work (including any operating limit) or work practice requirement in subpart SSSS, practice requirement in subpart SSSS, submission of the compliance report submission of the compliance report shall be deemed to satisfy any shall be deemed to satisfy any obligation to report the same obligation to report the same deviations in the semiannual deviations in the semiannual monitoring report. In other words, no monitoring report. In other words, no double jeopardy.double jeopardy.

TITLE V (cont’d.)TITLE V (cont’d.)

• However, submission of a compliance However, submission of a compliance report shall not otherwise affect any report shall not otherwise affect any obligation the affected source may obligation the affected source may have to report deviations from permit have to report deviations from permit requirements to the permitting requirements to the permitting authority. authority. (THIS IS VERY (THIS IS VERY IMPORTANT)IMPORTANT)

• However, submission of a compliance However, submission of a compliance report shall not otherwise affect any report shall not otherwise affect any obligation the affected source may obligation the affected source may have to report deviations from permit have to report deviations from permit requirements to the permitting requirements to the permitting authority. authority. (THIS IS VERY (THIS IS VERY IMPORTANT)IMPORTANT)

Title V Compliance Report Title V Compliance Report ExampleExample

For each affected source that is For each affected source that is subject to permitting requirements subject to permitting requirements required by 40 CFR part 70 or 71, and required by 40 CFR part 70 or 71, and if the permitting authority has if the permitting authority has established dates for submitting established dates for submitting semiannual reports required by Sec. semiannual reports required by Sec. 70.6 (a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)70.6 (a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), (A), (continued on next slide)(continued on next slide)

For each affected source that is For each affected source that is subject to permitting requirements subject to permitting requirements required by 40 CFR part 70 or 71, and required by 40 CFR part 70 or 71, and if the permitting authority has if the permitting authority has established dates for submitting established dates for submitting semiannual reports required by Sec. semiannual reports required by Sec. 70.6 (a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)70.6 (a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), (A), (continued on next slide)(continued on next slide)

Title V Compliance Title V Compliance Report Example Report Example

(cont’d.)(cont’d.)you may submit the first and you may submit the first and subsequent compliance reports subsequent compliance reports according to the dates the permitting according to the dates the permitting authority has established instead of authority has established instead of according to the dates in paragraphs according to the dates in paragraphs (b)(1) through (4) of this section. (b)(1) through (4) of this section. (NOTE WELL)(NOTE WELL)

you may submit the first and you may submit the first and subsequent compliance reports subsequent compliance reports according to the dates the permitting according to the dates the permitting authority has established instead of authority has established instead of according to the dates in paragraphs according to the dates in paragraphs (b)(1) through (4) of this section. (b)(1) through (4) of this section. (NOTE WELL)(NOTE WELL)

New Source New Source Review/PSD Review/PSD ImplicationsImplications

NSR requires stationary sources of NSR requires stationary sources of air pollution to apply for permits air pollution to apply for permits before they can construct/pre-before they can construct/pre-construct/reconstruct. There are construct/reconstruct. There are three types of NSR permit three types of NSR permit requirements:requirements:– PSD permits require for new major PSD permits require for new major

sources, or major modification to sources, or major modification to an existing source in attainment an existing source in attainment areas;areas;

NSR requires stationary sources of NSR requires stationary sources of air pollution to apply for permits air pollution to apply for permits before they can construct/pre-before they can construct/pre-construct/reconstruct. There are construct/reconstruct. There are three types of NSR permit three types of NSR permit requirements:requirements:– PSD permits require for new major PSD permits require for new major

sources, or major modification to sources, or major modification to an existing source in attainment an existing source in attainment areas;areas;

New Source Review/PSD New Source Review/PSD Implications (cont’d.)Implications (cont’d.)

– Non-attainment NSR permits for Non-attainment NSR permits for new or modifications to existing new or modifications to existing sources;sources;

– Minor source permitsMinor source permits These permits must be included These permits must be included

in the Title V permit issued to an in the Title V permit issued to an affected facility.affected facility.

– Non-attainment NSR permits for Non-attainment NSR permits for new or modifications to existing new or modifications to existing sources;sources;

– Minor source permitsMinor source permits These permits must be included These permits must be included

in the Title V permit issued to an in the Title V permit issued to an affected facility.affected facility.

Section 112j Section 112j ImplicationsImplications

Most States allow the Initial Most States allow the Initial Notification requirements under Notification requirements under Subpart SSSS to be satisfied by the Subpart SSSS to be satisfied by the Section 112j Notification.Section 112j Notification.

Most States allow the Initial Most States allow the Initial Notification requirements under Notification requirements under Subpart SSSS to be satisfied by the Subpart SSSS to be satisfied by the Section 112j Notification.Section 112j Notification.

Pollution Prevention Pollution Prevention OptionsOptions

Remove HAP organic Remove HAP organic COMPONENTS from coating COMPONENTS from coating operation,operation,Reduce the development of waste Reduce the development of waste surface coatings, excess thinners surface coatings, excess thinners and surface coating repair items.and surface coating repair items.

Remove HAP organic Remove HAP organic COMPONENTS from coating COMPONENTS from coating operation,operation,Reduce the development of waste Reduce the development of waste surface coatings, excess thinners surface coatings, excess thinners and surface coating repair items.and surface coating repair items.