METAL CAN SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART KKKK June 2006 40 CFR PART 63, SUBPART KKKK June 2006

METAL CAN SURFACE METAL CAN SURFACE COATING MACT COATING MACT

OVERVIEWOVERVIEW

METAL CAN SURFACE METAL CAN SURFACE COATING MACT COATING MACT

OVERVIEWOVERVIEW

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART KKKKKKKK

June 2006June 2006

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART KKKKKKKK

June 2006June 2006

INTRODUCTIONINTRODUCTIONINTRODUCTIONINTRODUCTION On November 13, 2003, USEPA On November 13, 2003, USEPA

promulgated the Federal standard, promulgated the Federal standard, METAL CAN SURFACE COATING METAL CAN 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 KKKK in the Federal Register; 68 FR KKKK in the Federal Register; 68 FR 64432.64432.

On November 13, 2003, USEPA On November 13, 2003, USEPA promulgated the Federal standard, promulgated the Federal standard, METAL CAN SURFACE COATING METAL CAN 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 KKKK in the Federal Register; 68 FR KKKK in the Federal Register; 68 FR 64432.64432.

What we are reviewing?What we are reviewing? Rule applicabilityRule applicability

NSR, NSPS & NESHAP focusNSR, NSPS & NESHAP focus

Covered operationsCovered operations

Operations not coveredOperations not covered Standards to be followed, including Standards to be followed, including

work practice standardswork practice standards

Rule applicabilityRule applicability

NSR, NSPS & NESHAP focusNSR, NSPS & NESHAP focus

Covered operationsCovered operations

Operations not coveredOperations not covered Standards to be followed, including Standards to be followed, including

work practice standardswork practice standards

Review? (cont’d.)Review? (cont’d.) Operating Limits Operating Limits Important datesImportant dates Synthetic minor sourcesSynthetic minor sources New or existing source New or existing source

determinationdetermination General rule requirementsGeneral rule requirements

Operating Limits Operating Limits Important datesImportant dates Synthetic minor sourcesSynthetic minor sources New or existing source New or existing source

determinationdetermination General rule requirementsGeneral rule requirements

Review (cont’d.)Review (cont’d.)

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

Reporting requirementsReporting requirements Compliance optionsCompliance options Compliance examplesCompliance examples

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

Reporting requirementsReporting requirements Compliance optionsCompliance options Compliance examplesCompliance examples

Review? (cont’d.)Review? (cont’d.)

Facility Inspection ProtocolFacility Inspection ProtocolPre-Inspection ReviewPre-Inspection ReviewFacility File ReviewFacility File ReviewFacility InspectionFacility InspectionPost-Inspection MeetingPost-Inspection MeetingFollow-upFollow-up

Frequently asked questions.Frequently asked questions.

Facility Inspection ProtocolFacility Inspection ProtocolPre-Inspection ReviewPre-Inspection ReviewFacility File ReviewFacility File ReviewFacility InspectionFacility InspectionPost-Inspection MeetingPost-Inspection MeetingFollow-upFollow-up

Frequently asked questions.Frequently asked questions.

TYPICAL FACILITYTYPICAL FACILITY

Video:Video:

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

(Subpart KKKK, §63.3481)(Subpart KKKK, §63.3481)

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

(Subpart KKKK, §63.3481)(Subpart KKKK, §63.3481)

Own or operate an Own or operate an AFFECTED AFFECTED SOURCESOURCE at a facility that is a at a facility that is a major source,major source,

Located at a major source, orLocated at a major source, or

Own or operate an Own or operate an AFFECTED AFFECTED SOURCESOURCE at a facility that is a at a facility that is a major source,major source,

Located at a major source, orLocated at a major source, or

APPLICABILITY (cont’d.)APPLICABILITY (cont’d.)APPLICABILITY (cont’d.)APPLICABILITY (cont’d.)

Part of a major source of Part of a major source of hazardous air pollutants (HAPs),hazardous air pollutants (HAPs),

The source uses 5,700 liters(1500 The source uses 5,700 liters(1500 gal) or more of coating per year.gal) or more of coating per year.

Part of a major source of Part of a major source of hazardous air pollutants (HAPs),hazardous air pollutants (HAPs),

The source uses 5,700 liters(1500 The source uses 5,700 liters(1500 gal) or more of coating per year.gal) or more of coating per year.

Affected SourcesAffected Sources

All coating operations;All coating operations; CoatingsCoatings ThinnersThinners Cleaning materials storage Cleaning materials storage

containerscontainers

All coating operations;All coating operations; CoatingsCoatings ThinnersThinners Cleaning materials storage Cleaning materials storage

containerscontainers

Affected Sources Affected Sources (cont’d.)(cont’d.)

Mixing vesselsMixing vessels Manual and automated Manual and automated

conveying equipment and conveying equipment and containerscontainers

Mixing vesselsMixing vessels Manual and automated Manual and automated

conveying equipment and conveying equipment and containerscontainers


Manual and automated conveying Manual and automated conveying equipment used for:equipment used for:Waste material storage containersWaste material storage containers

surface coating metal cans surface coating metal cans (including decorative tins), or (including decorative tins), or

metal crowns or closuresmetal crowns or closures

Manual and automated conveying Manual and automated conveying equipment used for:equipment used for:Waste material storage containersWaste material storage containers

surface coating metal cans surface coating metal cans (including decorative tins), or (including decorative tins), or

metal crowns or closuresmetal crowns or closures


NSPS; COATING operations involve NSPS; COATING operations involve VOCsVOCsNESHAP similar definition; NESHAP similar definition; VOCs vs VOHAPs; similar criteria VOCs vs VOHAPs; similar criteria and an increase in stringencyand an increase in stringency

NSPS; COATING operations involve NSPS; COATING operations involve VOCsVOCsNESHAP similar definition; NESHAP similar definition; VOCs vs VOHAPs; similar criteria VOCs vs VOHAPs; similar criteria and an increase in stringencyand an increase in stringency


Any new or reconstructed source Any new or reconstructed source (as defined in (as defined in § 63.2) § 63.2) before before January 15, 2003 is an existing January 15, 2003 is an existing facility and,facility and, that is a major source and is a that is a major source and is a

Metal Can Surface Coating Metal Can Surface Coating facilityfacility

Any new or reconstructed source Any new or reconstructed source (as defined in (as defined in § 63.2) § 63.2) before before January 15, 2003 is an existing January 15, 2003 is an existing facility and,facility and, that is a major source and is a that is a major source and is a

Metal Can Surface Coating Metal Can Surface Coating facilityfacility


Any new or reconstructed source Any new or reconstructed source after January 15, 2003 is a new after January 15, 2003 is a new source.source.

Any new or reconstructed source Any new or reconstructed source after January 15, 2003 is a new after January 15, 2003 is a new source.source.

What are Some Operations’ What are Some Operations’ Emissions Impacted by Emissions Impacted by Subpart KKKK?Subpart KKKK? Metal can surface coating includes, Metal can surface coating includes,

but is not limited to;but is not limited to; Any facility that coats metal cans Any facility that coats metal cans

or ends (including decorative or ends (including decorative tins), ortins), or

Metal can surface coating includes, Metal can surface coating includes, but is not limited to;but is not limited to; Any facility that coats metal cans Any facility that coats metal cans

or ends (including decorative or ends (including decorative tins), ortins), or

What are Some Operations’ What are Some Operations’ Emissions Impacted by Emissions Impacted by Subpart KKKK? (cont’d.)Subpart KKKK? (cont’d.)

Metal crowns or closures for any Metal crowns or closures for any type of can during any stage of the type of can during any stage of the can manufacturing process, andcan manufacturing process, and

Coating metal sheets for Coating metal sheets for subsequent processing into metal subsequent processing into metal cans or can partscans or can parts

Metal crowns or closures for any Metal crowns or closures for any type of can during any stage of the type of can during any stage of the can manufacturing process, andcan manufacturing process, and

Coating metal sheets for Coating metal sheets for subsequent processing into metal subsequent processing into metal cans or can partscans or can parts

METAL CAN Operations METAL CAN Operations ExamplesExamples

Subpart KKKK includes four Subpart KKKK includes four subcategories:subcategories:

One and two piece draw and iron One and two piece draw and iron (D&I) can body coating includes:(D&I) can body coating includes:

All coating processes involved All coating processes involved in the manufacturing of can in the manufacturing of can bodies by the D & I processbodies by the D & I process

(cont’d. on next slide)(cont’d. on next slide)

Subpart KKKK includes four Subpart KKKK includes four subcategories:subcategories:

One and two piece draw and iron One and two piece draw and iron (D&I) can body coating includes:(D&I) can body coating includes:

All coating processes involved All coating processes involved in the manufacturing of can in the manufacturing of can bodies by the D & I processbodies by the D & I process

(cont’d. on next slide)(cont’d. on next slide)

Examples (cont’d.)Examples (cont’d.)

Includes the two- piece Includes the two- piece beverage cansbeverage cans

Two-piece food cans, andTwo-piece food cans, and

One-piece aerosol can body One-piece aerosol can body coatingcoating

Includes the two- piece Includes the two- piece beverage cansbeverage cans

Two-piece food cans, andTwo-piece food cans, and

One-piece aerosol can body One-piece aerosol can body coatingcoating

Examples (cont’d.)Examples (cont’d.)The sheet-coating subcategory The sheet-coating subcategory includes:includes:All the flat metal sheet-coating All the flat metal sheet-coating

operations associated with the operations associated with the manufacture of three-piece manufacture of three-piece cans, cans,

• decorative tins, crowns and decorative tins, crowns and closures.closures.

The sheet-coating subcategory The sheet-coating subcategory includes:includes:All the flat metal sheet-coating All the flat metal sheet-coating

operations associated with the operations associated with the manufacture of three-piece manufacture of three-piece cans, cans,

• decorative tins, crowns and decorative tins, crowns and closures.closures.


The three-piece can body assembly The three-piece can body assembly coating subcategory includes:coating subcategory includes: All coating processes involved in the All coating processes involved in the

assembly of three-piece metal can assembly of three-piece metal can bodies, bodies, • including inside spray-on food including inside spray-on food

cans, side seam stripescans, side seam stripes

The three-piece can body assembly The three-piece can body assembly coating subcategory includes:coating subcategory includes: All coating processes involved in the All coating processes involved in the

assembly of three-piece metal can assembly of three-piece metal can bodies, bodies, • including inside spray-on food including inside spray-on food

cans, side seam stripescans, side seam stripes


On food cans, side seam On food cans, side seam stripes on general line and stripes on general line and aerosol non-food cans.aerosol non-food cans.

On food cans, side seam On food cans, side seam stripes on general line and stripes on general line and aerosol non-food cans.aerosol non-food cans.


The end coating category includes:The end coating category includes: The application of end seal The application of end seal

compounds and repair spray compounds and repair spray coatings to metal can ends,coatings to metal can ends,• including aseptic and non-septic including aseptic and non-septic

end seal compoundsend seal compounds Repair spray coatingsRepair spray coatings

The end coating category includes:The end coating category includes: The application of end seal The application of end seal

compounds and repair spray compounds and repair spray coatings to metal can ends,coatings to metal can ends,• including aseptic and non-septic including aseptic and non-septic

end seal compoundsend seal compounds Repair spray coatingsRepair spray coatings

EXAMPLES (cont’d.)EXAMPLES (cont’d.)

USEPA Applicability USEPA Applicability Determination Index SiteDetermination Index Site

http://www.epa.gov/Complhttp://www.epa.gov/Compliance/planning/data/air/adiance/planning/data/air/adi.htmi.htm

Who is not covered by Who is not covered by Subpart KKKK?Subpart KKKK?

The following sources are not The following sources are not covered under this rule;covered under this rule; Sources that only use coatings, Sources that only use coatings,

thinners, and cleaning materials thinners, and cleaning materials containing containing NO ORGANIC HAPNO ORGANIC HAP;;

The following sources are not The following sources are not covered under this rule;covered under this rule; Sources that only use coatings, Sources that only use coatings,

thinners, and cleaning materials thinners, and cleaning materials containing containing NO ORGANIC HAPNO ORGANIC HAP;;

Not covered sources Not covered sources (cont’d.)(cont’d.)

Surface coating subject to any Surface coating subject to any other NESHAP in Part 63;other NESHAP in Part 63;

Research or laboratory facilities;Research or laboratory facilities; Janitorial or building and facility Janitorial or building and facility

maintenance operationsmaintenance operations;;

Surface coating subject to any Surface coating subject to any other NESHAP in Part 63;other NESHAP in Part 63;

Research or laboratory facilities;Research or laboratory facilities; Janitorial or building and facility Janitorial or building and facility

maintenance operationsmaintenance operations;;

Not Covered Sources Not Covered Sources (cont’d.)(cont’d.)

Surface coating of metal coil that Surface coating of metal coil that may be subsequently used in the may be subsequently used in the manufacturing of cans;manufacturing of cans;

Surface coating of metal pails, Surface coating of metal pails, buckets and drums;buckets and drums;

Surface coating of metal coil that Surface coating of metal coil that may be subsequently used in the may be subsequently used in the manufacturing of cans;manufacturing of cans;

Surface coating of metal pails, Surface coating of metal pails, buckets and drums;buckets and drums;

Not Covered Sources Not Covered Sources (cont’d.)(cont’d.)

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

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

Compliance with Work Compliance with Work Practice Standards Practice Standards

(63.3493)(63.3493)

If the source uses capture and If the source uses capture and control devices, the source must control devices, the source must develop and operate according to develop and operate according to a work practice plan.a work practice plan.

If the source uses capture and If the source uses capture and control devices, the source must control devices, the source must develop and operate according to develop and operate according to a work practice plan.a work practice plan.

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

The Plan should include actions to:The Plan should include actions to: Cover mixing and storage vessels Cover mixing and storage vessels

containing organic HAP-containing containing organic HAP-containing coating, thinners and cleaning coating, thinners and cleaning materials except whenmaterials except when• Adding, removing, or mixing Adding, removing, or mixing

contents.contents.

The Plan should include actions to:The Plan should include actions to: Cover mixing and storage vessels Cover mixing and storage vessels

containing organic HAP-containing containing organic HAP-containing coating, thinners and cleaning coating, thinners and cleaning materials except whenmaterials except when• Adding, removing, or mixing Adding, removing, or mixing

contents.contents.


Used closed containers or pipes to Used closed containers or pipes to store and convey organic HAP-store and convey organic HAP-containing coatings, thinners and containing coatings, thinners and cleaning materials.cleaning materials.

Minimize spills of organic HAP-Minimize spills of organic HAP-containing coatings, thinners, cleaning containing coatings, thinners, cleaning materials, and waste materials.materials, and waste materials.

Used closed containers or pipes to Used closed containers or pipes to store and convey organic HAP-store and convey organic HAP-containing coatings, thinners and containing coatings, thinners and cleaning materials.cleaning materials.

Minimize spills of organic HAP-Minimize spills of organic HAP-containing coatings, thinners, cleaning containing coatings, thinners, cleaning materials, and waste materials.materials, and waste materials.


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

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

What Standards Require What Standards Require Compliance? (63.3490)Compliance? (63.3490)

Emissions Limitations are the site-Emissions Limitations are the site-specific parameter limits the specific parameter limits the source determines for the source determines for the functionalfunctional

Capture and control devices during Capture and control devices during the performance test.the performance test.

Emissions Limitations are the site-Emissions Limitations are the site-specific parameter limits the specific parameter limits the source determines for the source determines for the functionalfunctional

Capture and control devices during Capture and control devices during the performance test.the performance test.

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

The operating limits must be The operating limits must be monitored by a continuous monitored by a continuous parameter monitoring system parameter monitoring system (CPMS).(CPMS).

The operating limits must be The operating limits must be monitored by a continuous monitored by a continuous parameter monitoring system parameter monitoring system (CPMS).(CPMS).

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

November 13, 2003, under 68 FR November 13, 2003, under 68 FR 64432,64432,

Existing major sources (ON OR Existing major sources (ON OR BEFORE 01/15/03) must comply BEFORE 01/15/03) must comply with:with:

Emissions limitations;Emissions limitations;

The final rule was published on The final rule was published on November 13, 2003, under 68 FR November 13, 2003, under 68 FR 64432,64432,

Existing major sources (ON OR Existing major sources (ON OR BEFORE 01/15/03) must comply BEFORE 01/15/03) must comply with:with:

Emissions limitations;Emissions limitations;

Important dates (cont’d.)Important dates (cont’d.)

Work practices standard;Work practices standard;

Operation & Maintenance Operation & Maintenance requirement;requirement;

Major source status Major source status determination; determination; no later than, no later than, November 13, 2006.November 13, 2006.

Work practices standard;Work practices standard;

Operation & Maintenance Operation & Maintenance requirement;requirement;

Major source status Major source status determination; determination; no later than, no later than, November 13, 2006.November 13, 2006.

Important Dates (cont’d.)Important Dates (cont’d.)

New affected sources operating New affected sources operating after January 15, 2003, must after January 15, 2003, must comply with the regulatory comply with the regulatory requirements by November 13, requirements by November 13, 2003 or upon initial startup of the 2003 or upon initial startup of the affected sources whichever is later. affected sources whichever is later.

New affected sources operating New affected sources operating after January 15, 2003, must after January 15, 2003, must comply with the regulatory comply with the regulatory requirements by November 13, requirements by November 13, 2003 or upon initial startup of the 2003 or upon initial startup of the affected sources whichever is later. affected sources whichever is later.


If the METAL CAN COATING If the METAL CAN COATING FACILITY is an area source, but FACILITY is an area source, but becomes a major source of HAP, becomes a major source of HAP, compliance of compliance of § 63.3490§ 63.3490 upon upon startup.startup.

If the METAL CAN COATING If the METAL CAN COATING FACILITY is an area source, but FACILITY is an area source, but becomes a major source of HAP, becomes a major source of HAP, compliance of compliance of § 63.3490§ 63.3490 upon upon startup.startup.


The affected sources must meet The affected sources must meet the notification and scheduling the notification and scheduling requirements in requirements in § 63.3510. Some § 63.3510. Some of these notifications must be of these notifications must be submitted before the affected submitted before the affected source compliance date.source compliance date.

The affected sources must meet The affected sources must meet the notification and scheduling the notification and scheduling requirements in requirements in § 63.3510. Some § 63.3510. Some of these notifications must be of these notifications must be submitted before the affected submitted before the affected source compliance date.source compliance date.

Operations & Maintenance Operations & Maintenance Requirements (§63.3493)Requirements (§63.3493)

affected facilities must operate and affected 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 KKKK.required in Subpart KKKK.

affected facilities must operate and affected 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 KKKK.required in Subpart KKKK.

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

affected sources must prepare and affected 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 KKKK.subject to Subpart KKKK.

affected sources must prepare and affected 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 KKKK.subject to Subpart KKKK.

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

Each plan must contain the Each plan must contain the elements required in §63.3493elements required in §63.3493

Each plan must contain the Each plan must contain the elements required in §63.3493elements required in §63.3493

General Compliance General Compliance Requirements (§63.3500)Requirements (§63.3500) The affected source must be in The affected source must be in

compliance with the:compliance with the: emissions limitationsemissions limitations Work practice standardsWork practice standards Operations and maintenance;Operations and maintenance;

The affected source must be in The affected source must be in compliance with the:compliance with the: emissions limitationsemissions limitations Work practice standardsWork practice standards Operations and maintenance;Operations and maintenance;

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

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

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

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

The source may comply with the The source may comply with the emission limits by completing any emission limits by completing any of the following:of the following: Compliant Material Option,Compliant Material Option,

Each coating used must not Each coating used must not exceed the HAP limit in Table 1;exceed the HAP limit in Table 1;

The source may comply with the The source may comply with the emission limits by completing any emission limits by completing any of the following:of the following: Compliant Material Option,Compliant Material Option,

Each coating used must not Each coating used must not exceed the HAP limit in Table 1;exceed the HAP limit in Table 1;


Determined each month for Determined each month for the sub-category during the the sub-category during the 12-month compliance period;12-month compliance period;

Each thinner used must Each thinner used must contain no organic HAP.contain no organic HAP.

Determined each month for Determined each month for the sub-category during the the sub-category during the 12-month compliance period;12-month compliance period;

Each thinner used must Each thinner used must contain no organic HAP.contain no organic HAP.


Emissions Rate Without Add-on Emissions Rate Without Add-on ControlsControls The organic HAP emission rate, The organic HAP emission rate,

calculated as a 12-month rolling calculated as a 12-month rolling average on a monthly basis;average on a monthly basis;

For coatings and thinners must not For coatings and thinners must not exceed the HAP limits in Table 1.exceed the HAP limits in Table 1.

Emissions Rate Without Add-on Emissions Rate Without Add-on ControlsControls The organic HAP emission rate, The organic HAP emission rate,

calculated as a 12-month rolling calculated as a 12-month rolling average on a monthly basis;average on a monthly basis;

For coatings and thinners must not For coatings and thinners must not exceed the HAP limits in Table 1.exceed the HAP limits in Table 1.


Emission Rate With Add-on Emission Rate With Add-on Controls,Controls,The organic HAP emission rate, The organic HAP emission rate,

calculated as a 12-month calculated as a 12-month rolling average on a monthly rolling average on a monthly basis;basis;

Emission Rate With Add-on Emission Rate With Add-on Controls,Controls,The organic HAP emission rate, The organic HAP emission rate,

calculated as a 12-month calculated as a 12-month rolling average on a monthly rolling average on a monthly basis;basis;


For coatings and thinners For coatings and thinners (including emission capture (including emission capture and control efficiency)and control efficiency)

Must not exceed the HAP limits Must not exceed the HAP limits in Table 1.in Table 1.

For coatings and thinners For coatings and thinners (including emission capture (including emission capture and control efficiency)and control efficiency)

Must not exceed the HAP limits Must not exceed the HAP limits in Table 1.in Table 1.


Control Efficiency/Outlet Control Efficiency/Outlet Concentration OptionConcentration Option HAP emissions must be reduced HAP emissions must be reduced

by an overall control efficiency of by an overall control efficiency of at least 97%at least 97%

For new and reconstructed For new and reconstructed sources, andsources, and

Control Efficiency/Outlet Control Efficiency/Outlet Concentration OptionConcentration Option HAP emissions must be reduced HAP emissions must be reduced

by an overall control efficiency of by an overall control efficiency of at least 97%at least 97%

For new and reconstructed For new and reconstructed sources, andsources, and


95% for existing sources, or95% for existing sources, or The outlet organic HAP The outlet organic HAP

concentration must be no concentration must be no greatergreater

Than 20 parts per million (ppm) Than 20 parts per million (ppm) by volume on a dry basis.by volume on a dry basis.

95% for existing sources, or95% for existing sources, or The outlet organic HAP The outlet organic HAP

concentration must be no concentration must be no greatergreater

Than 20 parts per million (ppm) Than 20 parts per million (ppm) by volume on a dry basis.by volume on a dry basis.


Initial Compliance Requirements Initial Compliance Requirements (§63.3490)(§63.3490)

Additional Performance Test Additional Performance Test Requirements (§63.3491)Requirements (§63.3491)

Initial Compliance Requirements Initial Compliance Requirements (§63.3490)(§63.3490)

Additional Performance Test Additional Performance Test Requirements (§63.3491)Requirements (§63.3491)

Compliance Calculations Compliance Calculations (§§63.3521-63.3557(§§63.3521-63.3557))

For Compliance Option #1, the For Compliance Option #1, the collected data for regulated collected data for regulated materials are used to calculate the materials are used to calculate the organic HAPorganic HAP Content of each material used Content of each material used

during the 12-month rolling during the 12-month rolling average compliance period.average compliance period.

For Compliance Option #1, the For Compliance Option #1, the collected data for regulated collected data for regulated materials are used to calculate the materials are used to calculate the organic HAPorganic HAP Content of each material used Content of each material used

during the 12-month rolling during the 12-month rolling average compliance period.average compliance period.

Compliance Calculations Compliance Calculations (cont’d.)(cont’d.)

For Compliance Options #2 & 3, an For Compliance Options #2 & 3, an organic HAP emission rate for the organic HAP emission rate for the 12-month rolling average 12-month rolling average compliance compliance period must be calculated.period must be calculated.

For Compliance Options #2 & 3, an For Compliance Options #2 & 3, an organic HAP emission rate for the organic HAP emission rate for the 12-month rolling average 12-month rolling average compliance compliance period must be calculated.period must be calculated.

Compliance Calculations Compliance Calculations (cont’d.)(cont’d.)

For Compliance Option #4, an For Compliance Option #4, an overall organic HAP control overall organic HAP control efficiency or efficiency or outlet concentration is calculated outlet concentration is calculated

for the compliance period.for the compliance period.

For Compliance Option #4, an For Compliance Option #4, an overall organic HAP control overall organic HAP control efficiency or efficiency or outlet concentration is calculated outlet concentration is calculated

for the compliance period.for the compliance period.

Test MethodsTest Methods

Subpart KKKK clearly defines the Subpart KKKK clearly defines the test methods and other procedures test methods and other procedures in the rulein the ruleThese methods are used to These methods are used to

demonstrate initial compliance demonstrate initial compliance with the emissions limitationswith the emissions limitations

Subpart KKKK clearly defines the Subpart KKKK clearly defines the test methods and other procedures test methods and other procedures in the rulein the ruleThese methods are used to These methods are used to

demonstrate initial compliance demonstrate initial compliance with the emissions limitationswith the emissions limitations

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

Typically, for each capture system Typically, for each capture system that is a PTE, the data and that is a PTE, the data and documentation the source uses to documentation the source uses to support support

A determination that the capture A determination that the capture system meets the criteria in system meets the criteria in Method 204, and Method 204, and

Typically, for each capture system Typically, for each capture system that is a PTE, the data and that is a PTE, the data and documentation the source uses to documentation the source uses to support support

A determination that the capture A determination that the capture system meets the criteria in system meets the criteria in Method 204, and Method 204, and

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

sub methods as specified in sub methods as specified in §63.3544(e) and outlined in §63.3544(e) and outlined in 40CFR part 51.40CFR part 51.

sub methods as specified in sub methods as specified in §63.3544(e) and outlined in §63.3544(e) and outlined in 40CFR part 51.40CFR part 51.

Documents

METAL CAN SURFACE COATING MACT OVERVIEW 40 CFR PART 63, SUBPART KKKK June 2006 40 CFR PART 63, SUBPART KKKK June 2006