How do I demonstrate initial compliance?
§ 63.3161 How do I demonstrate initial compliance?
(a) You must meet all of the requirements of this section to demonstrate initial compliance. To demonstrate initial compliance, the organic HAP emissions from the combined electrodeposition primer, primer-surfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operations plus all coatings and thinners, except for deadener materials and for adhesive and sealer materials that are not components of glass bonding systems, used in coating operations added to the affected source pursuant to § 63.3082(c) must meet the applicable emission limitation in § 63.3090(a) or § 63.3091(a) and the applicable operating limits and work practice standards in §§ 63.3093 and 63.3094.
(b) Compliance with operating limits. Except as provided in § 63.3160(a)(4), you must establish and demonstrate continuous compliance during the initial compliance period with the operating limits required by § 63.3093, using the procedures specified in §§ 63.3167 and 63.3168.
(c) Compliance with work practice requirements. You must develop, implement, and document your implementation of the work practice plans required by § 63.3094(b) and (c) during the initial compliance period, as specified in § 63.3130.
(d) Compliance with emission limits. You must follow the procedures in paragraphs (e) through (o) of this section to demonstrate compliance with the applicable emission limit in § 63.3090(a) or § 63.3091(a). You may also use the guidelines presented in “Protocol for Determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Primer-Surfacer and Topcoat” EPA-453/R-08-002 (incorporated by reference, see § 63.14) in making this demonstration.
(e) Determine the mass fraction of organic HAP, density, and volume used. Follow the procedures specified in § 63.3151(a) through (c) to determine the mass fraction of organic HAP and the density and volume of each coating and thinner used during each month. For electrodeposition primer operations, the mass fraction of organic HAP, density, and volume used must be determined for each material added to the tank or system during each month.
(f) Determine the volume fraction of coating solids for each coating. You must determine the volume fraction of coating solids (liter of coating solids per liter of coating) for each coating used during the compliance period by a test or by information provided by the supplier or the manufacturer of the material, as specified in paragraphs (f)(1) and (2) of this section. For electrodeposition primer operations, the volume fraction of solids must be determined for each material added to the tank or system during each month. If test results obtained according to paragraph (f)(1) of this section do not agree with the information obtained under paragraph (f)(2) of this section, the test results will take precedence unless, after consultation, the facility demonstrates to the satisfaction of the enforcement authority that the facility's data are correct.
(1) ASTM Method D2697-03 (Reapproved 2014) or ASTM Method D6093-97 (Reapproved 2016). You may use ASTM D2697-03 (Reapproved 2014) (incorporated by reference, see § 63.14), or ASTM D6093-97 (Reapproved 2016) (incorporated by reference, see § 63.14), to determine the volume fraction of coating solids for each coating. Divide the nonvolatile volume percent obtained with the methods by 100 to calculate volume fraction of coating solids.
(2) Information from the supplier or manufacturer of the material. You may obtain the volume fraction of coating solids for each coating from the supplier or manufacturer.
(g) Determine the transfer efficiency for each coating. You must determine the transfer efficiency for each primer-surfacer and topcoat coating, and for all coatings, except for deadener and for adhesive and sealer that are not components of glass bonding systems, used in coating operations added to the affected source pursuant to § 63.3082(c) using ASTM Method D5066-91 (Reapproved 2017), “Standard Test Method for Determination of the Transfer Efficiency Under Production Conditions for Spray Application of Automotive Paints-Weight Basis” (incorporated by reference, see § 63.14), or the guidelines presented in “Protocol for Determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Primer-Surfacer and Topcoat” EPA-453/R-08-002 (incorporated by reference, see § 63.14). You may conduct transfer efficiency testing on representative coatings and for representative spray booths as described in “Protocol for Determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Primer-Surfacer and Topcoat” EPA-453/R-08-002 (incorporated by reference, see § 63.14). You may assume 100 percent transfer efficiency for electrodeposition primer coatings, glass bonding primers, and glass bonding adhesives. For final repair coatings, you may assume 40 percent transfer efficiency for air atomized spray and 55 percent transfer efficiency for electrostatic spray and high volume, low pressure spray. For blackout, chip resistant edge primer, interior color, inline repair, lower body anti-chip coatings, or underbody anti-chip coatings, you may assume 40 percent transfer efficiency for air atomized spray, 55 percent transfer efficiency for electrostatic spray and high volume-low pressure spray, and 80 percent transfer efficiency for airless spray.
(h) Calculate the total mass of organic HAP emissions before add-on controls. Calculate the total mass of organic HAP emissions before consideration of add-on controls from all coatings and thinners used during each month in the combined electrodeposition primer, primer-surfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operations plus all coatings and thinners, except for deadener materials and for adhesive and sealer materials that are not components of glass bonding systems, used in coating operations added to the affected source pursuant to § 63.3082(c) using Equation 1 of this section:
Where:
HBC = Total mass of organic HAP emissions before consideration of add-on controls during the month, kg.
A = Total mass of organic HAP in the coatings used during the month, kg, as calculated in Equation 1A of this section.
B = Total mass of organic HAP in the thinners used during the month, kg, as calculated in Equation 1B of this section.
(1) Calculate the kg organic HAP in the coatings used during the month using Equation 1A of this section:
Where:
A = Total mass of organic HAP in the coatings used during the month, kg.
Volc, i = Total volume of coating, i, used during the month, liters.
Dc, i = Density of coating, i, kg coating per liter coating.
Wc, i = Mass fraction of organic HAP in coating, i, kg organic HAP per kg coating.
m = Number of different coatings used during the month.
(2) Calculate the kg of organic HAP in the thinners used during the month using Equation 1B of this section:
Where:
B = Total mass of organic HAP in the thinners used during the month, kg.
Volt, j = Total volume of thinner, j, used during the month, liters.
Dt, j = Density of thinner, j, kg per liter.
Wt, j = Mass fraction of organic HAP in thinner, j, kg organic HAP per kg thinner.
n = Number of different thinners used during the month.
(i) Calculate the organic HAP emission reduction for each controlled coating operation. Determine the mass of organic HAP emissions reduced for each controlled coating operation during each month. The emission reduction determination quantifies the total organic HAP emissions captured by the emission capture system and destroyed or removed by the add-on control device. Use the procedures in paragraph (j) of this section to calculate the mass of organic HAP emission reduction for each controlled coating operation using an emission capture system and add-on control device other than a solvent recovery system for which you conduct liquid-liquid material balances. For each controlled coating operation using a solvent recovery system for which you conduct a liquid-liquid material balance, use the procedures in paragraph (k) of this section to calculate the organic HAP emission reduction.
(j) Calculate the organic HAP emission reduction for each controlled coating operation not using liquid-liquid material balances. For each controlled coating operation using an emission capture system and add-on control device other than a solvent recovery system for which you conduct liquid-liquid material balances, calculate the mass of organic HAP emission reduction for the controlled coating operation, excluding all periods of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or control device serving the controlled coating operation occurred, during the month using Equation 2 of this section. The calculation of mass of organic HAP emission reduction for the controlled coating operation during the month applies the emission capture system efficiency and add-on control device efficiency to the mass of organic HAP contained in the coatings and thinners that are used in the coating operation served by the emission capture system and add-on control device during each month. Except as provided in paragraph (p) of this section, for any period of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement of the capture system or control device serving the controlled coating operation occurred, you must assume zero efficiency for the emission capture system and add-on control device. Equation 2 of this section treats the materials used during such a deviation as if they were used on an uncontrolled coating operation for the time period of the deviation.
Where:
HCn = Mass of organic HAP emission reduction, excluding all periods of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or control device serving the controlled coating operation occurred, for the controlled coating operation during the month, kg.
AC = Total mass of organic HAP in the coatings used in the controlled coating operation during the month, kg, as calculated in Equation 2A of this section.
BC = Total mass of organic HAP in the thinners used in the controlled coating operation during the month, kg, as calculated in Equation 2B of this section.
Aunc = Total mass of organic HAP in the coatings used during all periods of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or control device serving the controlled coating operation occurred for the controlled coating operation during the month, kg, as calculated in Equation 2C of this section.
Bunc = Total mass of organic HAP in the thinners used during all periods of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or control device serving the controlled coating operation occurred for the controlled coating operation during the month, kg, as calculated in Equation 2D of this section.
CE = Capture efficiency of the emission capture system vented to the add-on control device, percent. Use the test methods and procedures specified in §§ 63.3164 and 63.3165 to measure and record capture efficiency.
DRE = Organic HAP destruction or removal efficiency of the add-on control device, percent. Use the test methods and procedures in §§ 63.3164 and 63.3166 to measure and record the organic HAP destruction or removal efficiency.
(1) Calculate the mass of organic HAP in the coatings used in the controlled coating operation, kg, using Equation 2A of this section.
Where:
AC = Total mass of organic HAP in the coatings used in the controlled coating operation during the month, kg.
Volc, i = Total volume of coating, i, used during the month, liters.
Dc, i = Density of coating, i, kg per liter.
Wc, i = Mass fraction of organic HAP in coating, i, kg per kg.
m = Number of different coatings used.
(2) Calculate the mass of organic HAP in the thinners used in the controlled coating operation, kg, using Equation 2B of this section.
Where:
BC = Total mass of organic HAP in the thinners used in the controlled coating operation during the month, kg.
Volt, j = Total volume of thinner, j, used during the month, liters.
Dt, j = Density of thinner, j, kg per liter.
Wt, j = Mass fraction of organic HAP in thinner, j, kg per kg.
n = Number of different thinners used.
(3) Calculate the mass of organic HAP in the coatings used in the controlled coating operation during deviations specified in § 63.3163(c) and (d), using Equation 2C of this section:
Where:
Aunc = Total mass of organic HAP in the coatings used during all periods of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or control device serving the controlled coating operation occurred for the controlled coating operation during the month, kg.
VOLDi = Total volume of coating, i, used in the controlled coating operation during deviations, liters.
Di = Density of coating, i, kg per liter.
Wi = Mass fraction of organic HAP in coating, i, kg organic HAP per kg coating.
m = Number of different coatings.
(4) Calculate the mass of organic HAP in the thinners used in the controlled coating operation during deviations specified in § 63.3163(c) and (d), using Equation 2D of this section:
Where:
Bunc = Total mass of organic HAP in the thinners used during all periods of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or control device serving the controlled coating operation occurred for the controlled coating operation during the month, kg.
VOLDj = Total volume of thinner, j, used in the controlled coating operation during deviations, liters.
Dj = Density of thinner, j, kg per liter.
Wh = Mass fraction of organic HAP in thinner, j, kg organic HAP per kg coating.
n = Number of different thinners.
(k) Calculate the organic HAP emission reduction for each controlled coating operation using liquid-liquid material balances. For each controlled coating operation using a solvent recovery system for which you conduct liquid-liquid material balances, calculate the mass of organic HAP emission reduction for the coating operation controlled by the solvent recovery system using a liquid-liquid material balance during the month by applying the volatile organic matter collection and recovery efficiency to the mass of organic HAP contained in the coatings and thinners used in the coating operation controlled by the solvent recovery system during each month. Perform a liquid-liquid material balance for each month as specified in paragraphs (k)(1) through (6) of this section. Calculate the mass of organic HAP emission reduction by the solvent recovery system as specified in paragraph (k)(7) of this section.
(1) For each solvent recovery system, install, calibrate, maintain, and operate according to the manufacturer's specifications, a device that indicates the cumulative amount of volatile organic matter recovered by the solvent recovery system each month. The device must be initially certified by the manufacturer to be accurate to within ±2.0 percent of the mass of volatile organic matter recovered.
(2) For each solvent recovery system, determine the mass of volatile organic matter recovered for the month, kg, based on measurement with the device required in paragraph (k)(1) of this section.
(3) Determine the mass fraction of volatile organic matter for each coating and thinner used in the coating operation controlled by the solvent recovery system during the month, kg volatile organic matter per kg coating. You may determine the volatile organic matter mass fraction using EPA Method 24 of 40 CFR part 60, appendix A-7, or an EPA approved alternative method, or you may use information provided by the manufacturer or supplier of the coating. In the event of any inconsistency between information provided by the manufacturer or supplier and the results of EPA Method 24 of 40 CFR part 60, appendix A-7, or an approved alternative method, the test method results will govern unless after consultation, the facility demonstrates to the satisfaction of the enforcement authority that the facility's data are correct.
(4) Determine the density of each coating and thinner used in the coating operation controlled by the solvent recovery system during the month, kg per liter, according to § 63.3151(b).
(5) Measure the volume of each coating and thinner used in the coating operation controlled by the solvent recovery system during the month, liters.
(6) Each month, calculate the solvent recovery system's volatile organic matter collection and recovery efficiency, using Equation 3 of this section:
Where:
RV = Volatile organic matter collection and recovery efficiency of the solvent recovery system during the month, percent.
MVR = Mass of volatile organic matter recovered by the solvent recovery system during the month, kg.
Voli = Volume of coating, i, used in the coating operation controlled by the solvent recovery system during the month, liters.
Di = Density of coating, i, kg per liter.
WVc, i = Mass fraction of volatile organic matter for coating, i, kg volatile organic matter per kg coating.
Volj = Volume of thinner, j, used in the coating operation controlled by the solvent recovery system during the month, liters.
Dj = Density of thinner, j, kg per liter.
WVt, j = Mass fraction of volatile organic matter for thinner, j, kg volatile organic matter per kg thinner.
m = Number of different coatings used in the coating operation controlled by the solvent recovery system during the month.
n = Number of different thinners used in the coating operation controlled by the solvent recovery system during the month.
(7) Calculate the mass of organic HAP emission reduction for the coating operation controlled by the solvent recovery system during the month, using Equation 4 of this section:
Where:
HCSR = Mass of organic HAP emission reduction for the coating operation controlled by the solvent recovery system using a liquid-liquid material balance during the month, kg.
ACSR = Total mass of organic HAP in the coatings used in the coating operation controlled by the solvent recovery system, kg, calculated using Equation 4A of this section.
BCSR = Total mass of organic HAP in the thinners used in the coating operation controlled by the solvent recovery system, kg, calculated using Equation 4B of this section.
RV = Volatile organic matter collection and recovery efficiency of the solvent recovery system, percent, from Equation 3 of this section.
(i) Calculate the mass of organic HAP in the coatings used in the coating operation controlled by the solvent recovery system, kg, using Equation 4A of this section.
Where:
ACSR = Total mass of organic HAP in the coatings used in the coating operation controlled by the solvent recovery system during the month, kg.
Volc, i = Total volume of coating, i, used during the month in the coating operation controlled by the solvent recovery system, liters.
Dc, i = Density of coating, i, kg per liter.
Wc, i = Mass fraction of organic HAP in coating, i, kg per kg.
m = Number of different coatings used.
(ii) Calculate the mass of organic HAP in the thinners used in the coating operation controlled by the solvent recovery system, kg, using Equation 4B of this section.
Where:
BCSR = Total mass of organic HAP in the thinners used in the coating operation controlled by the solvent recovery system during the month, kg.
Volt, j = Total volume of thinner, j, used during the month in the coating operation controlled by the solvent recovery system, liters.
Dt, j = Density of thinner, j, kg per liter.
Wt, j = Mass fraction of organic HAP in thinner, j, kg per kg.
n = Number of different thinners used.
(l) Calculate the total volume of coating solids deposited. Determine the total volume of coating solids deposited, liters, in the combined electrodeposition primer, primer-surfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operations plus all coatings and thinners, except for deadener materials and for adhesive and sealer materials that are not components of glass bonding systems used in coating operations added to the affected source pursuant to § 63.3082(c) using Equation 5 of this section:
Where:
Vsdep = Total volume of coating solids deposited during the month, liters.
Volc,i = Total volume of coating, i, used during the month, liters.
Vs,i = Volume fraction of coating solids for coating, i, liter solids per liter coating, determined according to § 63.3161(f).
TEc,i = Transfer efficiency of coating, i, determined according to § 63.3161(g), expressed as a decimal, for example 60 percent must be expressed as 0.60.
M = Number of coatings used during the month.
(m) Calculate the mass of organic HAP emissions for each month. Determine the mass of organic HAP emissions, kg, during each month, using Equation 6 of this section.
Where:
HHAP = Total mass of organic HAP emissions for the month, kg.
HBC = Total mass of organic HAP emissions before add-on controls from all the coatings and thinners used during the month, kg, determined according to paragraph (h) of this section.
HCn, i = Total mass of organic HAP emission reduction for controlled coating operation, i, not using a liquid-liquid material balance, excluding all periods of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or control device serving the controlled coating operation occurred, for the controlled coating operation during the month, from Equation 2 of this section.
HCSR, j = Total mass of organic HAP emission reduction for coating operation, j, controlled by a solvent recovery system using a liquid-liquid material balance, during the month, kg, from Equation 4 of this section.
HDEV, k, m = Mass of organic HAP emission reduction, based on the capture system and control device efficiency approved under paragraph (p) of this section for period of deviation, m, for controlled coating operation, k, kg, as determined using Equation 8 of this section.
q = Number of controlled coating operations not using a liquid-liquid material balance.
r = Number of coating operations controlled by a solvent recovery system using a liquid-liquid material balance.
Sk = Number of periods of deviation in the month for which non-zero capture and control device efficiencies have been approved for controlled coating operation, k.
(n) Calculate the organic HAP emission rate for the month. Determine the organic HAP emission rate for the month, kg organic HAP per liter coating solids deposited, using Equation 7 of this section:
Where:
Hrate = Organic HAP emission rate for the month compliance period, kg organic HAP per liter coating solids deposited.
HHAP = Mass of organic HAP emissions for the month, kg, determined according to Equation 6 of this section.
Vsdep = Total volume of coating solids deposited during the month, liters, from Equation 5 of this section.
(o) Compliance demonstration. To demonstrate initial compliance, the organic HAP emissions from the combined electrodeposition primer, primer-surfacer, topcoat, final repair, glass bonding primer, and glass bonding adhesive operations plus all coatings and thinners, except for deadener materials and for adhesive and sealer materials that are not components of glass bonding systems, used in coating operations added to the affected source pursuant to § 63.3082(c) must be less than or equal to the applicable emission limitation in § 63.3090(a) or § 63.3091(a). You must keep all records as required by §§ 63.3130 and 63.3131. As part of the Notification of Compliance Status required by § 63.3110, you must submit a statement that the coating operation(s) was (were) in compliance with the emission limitations during the initial compliance period because the organic HAP emission rate was less than or equal to the applicable emission limit in § 63.3090(a) or § 63.3091(a) and you achieved the operating limits required by § 63.3093 and the work practice standards required by § 63.3094.
(p) You may request approval from the Administrator to use non-zero capture efficiencies and add-on control device efficiencies for any period of time in which a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or add-on control device serving a controlled coating operation occurred.
(1) If you have manually collected parameter data indicating that a capture system or add-on control device was operating normally during a CPMS malfunction, a CPMS out-of-control period, or associated repair, then these data may be used to support and document your request to use the normal capture efficiency or add-on control device efficiency for that period of deviation.
(2) If you have data indicating the actual performance of a capture system or add-on control device (e.g., capture efficiency measured at a reduced flow rate or add-on control device efficiency measured at a reduced thermal oxidizer temperature) during a deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or add-on control device serving a controlled coating operation, then these data may be used to support and document your request to use these values for that period of deviation.
(3) The organic HAP emission reduction achieved during each period of deviation, including a deviation during a period of startup, shutdown, or malfunction, from an operating limit or from any CPMS requirement for the capture system or add-on control device serving a controlled coating operation for which the Administrator has approved the use of non-zero capture efficiency and add-on control device efficiency values is calculated using Equation 8 of this section.
Where:
HDEV = Mass of organic HAP emission reduction achieved during a period of deviation for the controlled coating operation, kg.
ADEV = Total mass of organic HAP in the coatings used in the controlled coating operation during the period of deviation, kg, as calculated in Equation 8A of this section.
BDEV = Total mass of organic HAP in the thinners used in the controlled coating operation during the period of deviation, kg, as calculated in Equation 8B of this section.
CEDEV = Capture efficiency of the emission capture system vented to the add-on control device, approved for the period of deviation, percent.
DREDEV = Organic HAP destruction or removal efficiency of the add-on control device approved for the period of deviation, percent.
(4) Calculate the total mass of organic HAP in the coatings used in the controlled coating operation during the period of deviation using equation 8A of this section:
Where:
ADEV = Total mass of organic HAP in the coatings used in the controlled coating operation during the period of deviation, kg.
VOLCDEV, i = total volume of coating, i, used in the controlled coating operation during the period of deviation, liters.
Dc, i = Density of coating, i, kg per liter.
Wc, i = Mass fraction of organic HAP in coating, i, kg per kg.
m = Number of different coatings used.
(5) Calculate the total mass of organic HAP in the thinners used in the controlled coating operation during the period of deviation using equation 8B of this section:
Where:
BDEV = Total mass of organic HAP in the thinners used in the controlled coating operation during the period of deviation, kg.
VOLTDEV, j = Total volume of thinner, j, used in the controlled coating operation during the period of deviation, liters.
Dt, j = Density of thinner, j, kg per liter.
Wt, j = Mass fraction of organic HAP in thinner, j, kg per kg.
n = Number of different thinners used.
[69 FR 22623, Apr. 26, 2004, as amended at 72 FR 20233, Apr. 24, 2007; 85 FR 41129, July 8, 2020; 86 FR 66040, Nov. 19, 2021]
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