# Presentation: 039440

## The Paper and Other Web Coating (POWC) MACT – Executive Summary

- The executive summary is a power point presentation designed to be used for basic education and outreach of persons not knowledgeable with the requirements of the rule (such as upper management).

**Credits:**  This document was made possible through the efforts of the POWC Implementation Tool Development Partnership effort, an effort to bring together the regulated and regulatory community.  It was through a group effort that this document was developed.  The logo of the partner who was the lead for this tool is listed first below.  To see a description of our partners or to get more information about the partnership effort, see _http://wwww.epa.gov/ttn/atw/powc/powcpg.html_

## The Paper and Other Web Coating (POWC) MACT Executive Summary

- 2

## Overview of Rule

- Applies to major sources of HAP only
- HAP
- Hazardous Air Pollutant
- EPA listed 188
- Major Source:  Facilities with **potential to emit** of:
- 10 tpy or more of 1 HAP
- 25 tpy or more of all HAP
- This includes all sources of HAPs, not just from coating lines (e.g., HAP emissions from boilers)

- 3

## Typical HAP in the Coating Industry

- Toluene
- Adhesives, releases, topcoats, primers, cleaning
- Xylene
- Adhesives, releases
- Hexane
- Adhesives
- Methyl Ethyl Ketone*
- Adhesives, releases, topcoats, cleaning
- Methyl Isobutyl ketone
- Adhesives
- Methanol
- Water and solvent based adhesives

- Vinyl acetate
- Solvent and water-based adhesives
- Acetaldehyde
- Water-based adhesives
- Methyl methacrylate
- Water-based adhesives
- Benzene
- Contaminate in toluene
- Certain Glycol Ethers**
- Inks, cleaners

- * proposed for delisting

- **treated as one HAP

- 4

**Notes:**
MEK delisting proposed in May, currently reviewing public comments
EGBE will soon be proposed to be delisted- in many aqueous coatings
Remember– All VOC are NOT HAP

## Overview of Rule Continued

- Requires use of add-on control and/or low-HAP coatings
- Must include all HAP that are greater than:
- 0.1 % for carcinogens
- 1.0 % for non-carcinogens
- Applies to all coating lines not covered by other MACTs (including aqueous)
- Monitoring, reporting, and recordkeeping requirements
- Codified in 40 CFR Part 63, Subpart JJJJ

- 5

## Key Dates 

- September 13, 2000
- Rule proposed  (65 FR 55331)
- “Affected sources” built after this date are considered “new affected sources”
- December 4, 2002
- Rule promulgated
- Compliance date for _new_ affected sources

- 6

## More Key Dates

- December 5, 2004
- Initial Notifications due
- December 5, 2005
- Compliance date for _existing_ affected sources

- 7

## Affected Source

- All coating lines at a facility are defined as one affected source
- Additional line at existing facility is part of existing affected source- generally
- New affected sources are new lines installed at new facilities or facilities with no prior POWC operation.

- 8

**Notes:**
This gets into the whole “what is reconstruction” argument that we will talk more about in the next presentation.

## Exclusions from Affected Source

- Operations covered by other MACTs
- Printing and Publishing (Subpart KK)
- Magnetic Tape (Subpart EE)
- Metal Coil Coating (Subpart SSSS)
- Fabric Coating (Subpart OOOO)

- §63.3300

- 9

## More Exclusions

- Specific process exclusions:
- Lithography
- Screenprinting
- Letterpress
- Narrow web flexographic printing
- Research and development lines

- §63.3300

- 10

## Affiliated Operations 

- Coating formulation, mixing, and storage operations are specifically defined (in POWC preamble) as “affiliated equipment”
- Affiliated equipment have no POWC requirements
- POWC affiliated equipment specifically is exempted from other MACTs (i.e., MCM and MOCM)

- §63.7985(d)(2)
- §63.2435(c)(3)

- 11

## Rule Requirements- Existing Sources 

- Regulates “organic HAP”
- Must limit emissions to:
- Reduce emissions by **95** percent, **OR**
- Meet overall organic HAP emission rate of **0.04** kg HAP / kg coating applied, **OR**
- Meet overall organic HAP emission rate of **0.20** kg HAP / kg solids applied, **OR**
- No greater than **20** ppmv at outlet of an oxidizer and demonstrate **100** percent capture efficiency

- §63.3320(b)

- 12

**Notes:**
The preamble alluded to the fact that notification would be required to switch among options, but this language DID NOT MAKE IT TO THE REGULATORY LANGUAGE!!
We have had a misunderstanding by some that the fact that this regulates “organic HAP” somehow limits what you can include in the denominator- particularly w.r.t. solids.  The NUMERATOR is organic HAP, the bottom can be any compound (total coating or total solids)
Note that the 20 ppmv provision is not really one of the required rule levels.  It is an alternative compliance demonstration for assuring compliance with the MACT level.

## Regulates “organic HAP”
Must limit emissions to:
Reduce emissions by 98 percent, OR
Meet overall organic HAP emission rate of 0.016 kg HAP / kg coating (lb/lb) applied, OR
Meet overall organic HAP emission rate of 0.08 kg HAP / kg solids (lb/lb) applied, OR
No greater than 20 ppmv at outlet of an oxidizer and demonstrate 100 percent capture efficiency

- Must limit emissions to:
- Reduce emissions by **98** percent, **OR**
- Meet overall organic HAP emission rate of **0.016** kg HAP / kg coating (lb/lb) applied, **OR**
- Meet overall organic HAP emission rate of **0.08** kg HAP / kg solids (lb/lb) applied, **OR**
- No greater than **20** ppmv at outlet of an oxidizer and demonstrate **100** percent capture efficiency

- Rule Requirements- New Sources

- §63.3320(b)

- 13

**Notes:**
At this time it is not clear if only one option will be allowed without prior notification of EPA of a change to a different option.

## Options to Meet MACT

- Use Low-HAP Coatings
- Compliance on an individual coating basis
- Meet limits on monthly-average basis
- Average across all lines (including aqueous, hot melt, UV, etc.)
- Install Capture and Control System
- Solvent Recovery System (SRS)
- Thermal or catalytic destruction
- Combination of above

- §63.3370

- 14

## Low-HAP coatings

- Track total weight of each coating used each month if averaging
- Determine HAP content using EPA approved methods
- Demonstrate one of MACT requirements is met
- Each coating applied during a month meets the 0.04 lb HAP/lb coating or 0.20 lb HAP/lb solids
- The weighted-average of all coatings applied over a month meets the 0.04 or 0.20 limits

- 15

## Solvent Recovery (“Liquid-liquid balance”)

- Track total VOC delivered to coating line(s) [monthly]
- Coating usage
- VOC content
- Track total solvent recovered
- Determine percentage of VOC into coating line(s) that is recovered
- Demonstrate one of MACT requirements is met by applying VOC efficiency recovery

- 16

## Solvent Recovery (“Performance Test / CEMs”)

- Demonstrate capture efficiency
- Permanent total enclosure, OR
- Capture efficiency test
- Monitor control efficiency of solvent recovery using continuous emissions monitors (CEM) at inlet and outlet of system
- Demonstrate compliance with overall control efficiency (OCE) requirement
- 		OCE =  Capture Effic.  x  Control Effic.

- Percent Reduction

- 17

## Solvent Recovery (“Performance Test / CEMs”)

- Demonstrate capture efficiency
- Monitor control efficiency using                           CEMs
- Identify “uncontrolled” HAP from all coatings used
- Monthly tracking of coating usage
- HAP content
- Demonstrate compliance with either HAP content requirement by applying overall control efficiency to “uncontrolled” HAP usage

- HAP Content

- 18

## Capture and Control

- Demonstrate capture efficiency
- May require continuous or
- 	parametric monitoring
- Demonstrate control efficiency
- Initial performance test
- Demonstrate that required overall percent reduction is met
-   =  Capture Effic.  x  Control Effic.

- Percent Reduction

- Based on VOC %, assume to be equal to HAP

- 19

## Capture and Control

- Demonstrate capture efficiency
- Demonstrate control efficiency
- Identify “uncontrolled” HAP content
- Monthly tracking of coating usage
- HAP content
- Demonstrate compliance with either HAP content requirement by applying overall control efficiency to “uncontrolled” HAP usage

- HAP Content

- 20

## Multiple Controls- Key Provisions

- Allows for multiple capture and control systems
- More than one capture system on a line
- More than one control on a single line
- More than one type of control system in one interconnected group of sources

- 21

## Compliance Requirements

- Start-up, Shutdown, Malfunction plan
- Detailed plan of start-up and shutdown procedures and possible upsets and plans to minimize emissions during these periods
- Failure to follow the SSM plan requires immediate notification and may require a revision of the SSM plan
- SSM Plan not submitted; kept on-file at site
- EPA can request a copy of the SSM plan

- 22

## Compliance Requirements

- Monitoring
- Continuous emission or parametric monitoring to ensure sustained device performance (as applicable)
- Capture system
- Control system
- Recordkeeping
- Parametric and CEMS monitoring results
- Coating usage
- Compliance calculations

- 23

## Reporting Requirements

- Initial Notification
- Performance Test /Results
- Initial Compliance reports
- Ongoing- semiannual reports
- Non-compliance with SSM reports

- 24