25 Pa. Code § 129.104 - Compliance procedures and monitoring requirements
(a)
Compliance methods. An
owner or operator of a facility subject to the emission standards in §
129.102 (relating to emission
standards) shall demonstrate compliance with those provisions by using one or
more of the following methods:
(1) To support
that each sealer, topcoat and strippable spray booth coating meets the
requirements of §
129.102(1)
(relating to emission standards):
(i)
Maintain CPDSs for each of the coatings.
(ii) Maintain documentation showing the VOC
content of the as applied coating in lbs VOC/lb solids, if solvent or other VOC
is added to the coating before application.
(iii) Perform sampling and testing in
accordance with the procedures and test methods in Chapter 139 (relating to
sampling and testing).
(2) To comply through the use of a control
system as described in §
129.102(3):
(i) Calculate the required overall control
efficiency needed to demonstrate compliance using the following equation:
O = (1 - E/C) x 100
Where:
C = the VOC content of the as applied coating, lbs VOC/lb solids
E = the Table IV emission limit which shall be achieved by the affected emission point(s), lbs VOC/lb solids
O = the overall control efficiency of the control system, expressed as a percentage
(ii) Document that the value of C in the
equation in subparagraph (i) is obtained from the VOC and solids content of the
as applied coating.
(iii) Determine
the overall control efficiency of the control system using the procedures and
test methods in Chapter 139 and demonstrate that the value of O calculated by
the following equation is equal to or greater than the value of O calculated by
the equation in subparagraph (i):
O = (F x N) (100)
Where:
F = the control device efficiency, expressed as a fraction
N = the capture device efficiency, expressed as a fraction
(b)
Initial compliance.
(1)
Compliant coatings. An
owner or operator of a facility subject to §
129.102(1) that
is complying through the procedures in subsection (a)(1) shall submit an
initial compliance status report as required by §
129.106(a)
(relating to reporting requirements), stating that compliant sealers, topcoats
and strippable spray booth coatings are being used by the facility.
(2)
Continuous coaters. An
owner or operator of a facility subject to §
129.102(1) that
is complying through the procedures in subsection (a)(1) and is applying
sealers, topcoats, or both, using continuous coaters shall demonstrate initial
compliance by either:
(i) Submitting an
initial compliance status report as required by §
129.106(a)
stating that compliant sealers, topcoats, or both, as determined by the VOC
content of the coating in the reservoir and as calculated from records, are
being used.
(ii) Submitting an
initial compliance status report as required by §
129.106(a)
stating that compliant sealers, topcoats, or both, as determined by the VOC
content of the coating in the reservoir, are being used and the viscosity of
the coating in the reservoir is being monitored. The facility shall also
provide data that demonstrates the correlation between the viscosity and the
VOC content of the coating in the reservoir.
(3)
Control systems. An
owner or operator of a facility using a control system to comply with this
section and §§
129.101-129.103 and
129.105-129.107 shall demonstrate initial
compliance by submitting a report to the Department that:
(i) Identifies the operating parameter value
to be monitored for the capture device and discusses why the parameter is
appropriate for demonstrating ongoing compliance.
(ii) Includes the results of the initial
performance testing using the procedures and test methods specified in Chapter
139.
(iii) Includes calculations of
the overall control efficiency (O) using the equation in subsection
(a)(2)(iii).
(iv) Defines those
operating conditions of the control system critical to determining compliance
and establishes operating parameter values that will ensure compliance with the
standard:
(A) For compliance with a thermal
incinerator, minimum combustion temperature shall be the operating parameter
value.
(B) For compliance with
another control system, the operating parameter value shall be established
using the procedures identified in subsection (c)(3)(iv).
(v) An owner or operator of a facility
complying with this paragraph shall calculate the site-specific operating
parameter value as the arithmetic average of the maximum or minimum operating
parameter values, as appropriate, that demonstrate compliance with the
standards, using the procedures in Chapter 139.
(4)
Work practice implementation
plan. An owner or operator of a facility subject to the work practice
standards of §
129.103 (relating to work practice
standards) shall submit an initial compliance status report as required by
§
129.106(a),
stating that the work practice implementation plan has been developed and
procedures have been established for implementing the provisions of the
plan.
(c)
Continuous compliance demonstrations. An owner or operator of
a facility subject to the requirements of this section and §§
129.101-129.103 and
129.105-129.107 shall submit, in writing,
to the Department a compliance certification with the semiannual report
required by §
129.106(b).
(1)
Compliant coatings. An
owner or operator of a facility subject to §
129.102 that is complying through
the procedures specified in subsection (a)(1) shall demonstrate continuous
compliance by the following:
(i) Using
compliant coatings.
(ii)
Maintaining records that demonstrate the coatings are compliant.
(iii) Submitting a compliance certification
which states that compliant sealers, topcoats, or both, and strippable spray
booth coatings have been used each day in the semiannual reporting period or
should otherwise identify the days of noncompliance and the reasons for
noncompliance.
(2)
Continuous coaters. An owner or operator of a facility subject
to §
129.102 that is complying through
the procedures specified in subsection (a)(1) and is applying sealers,
topcoats, or both, using continuous coaters shall demonstrate continuous
compliance by either:
(i) Using compliant
coatings as determined by the VOC content of the coating in the reservoir and
as calculated from records, and submitting a compliance certification which
states that compliant sealers, topcoats, or both, have been used each day in
the semiannual reporting period or should otherwise identify the days of
noncompliance and the reasons for noncompliance.
(ii) Using compliant coatings, as determined
by the VOC content of the coating in the reservoir, maintaining a viscosity of
the coating in the reservoir that is no less than the viscosity of the initial
coating by monitoring the viscosity with a viscosity meter or by testing the
viscosity of the initial coating and retesting the viscosity of the coating in
the reservoir each time solvent is added, maintaining records of solvent
additions and submitting a compliance certification which states that compliant
sealers, topcoats, or both, as determined by the VOC content of the coating in
the reservoir, have been used each day in the semiannual reporting period.
Additionally, the certification shall state that the viscosity of the coating
in the reservoir has not been less than the viscosity of the initial coating,
that is, the coating that is initially mixed and placed in the reservoir, for
any day in the semiannual reporting period or should otherwise identify the
days of noncompliance and the reasons for noncompliance.
(3)
Control systems. An
owner or operator of a facility subject to §
129.102 that is complying through
the use of a control system shall demonstrate continuous compliance by the
following:
(i) Installing, calibrating,
maintaining and operating monitoring equipment approved, in writing, by the
Department.
(ii) Using a device to
monitor the site-specific operating parameter value established in accordance
with subsection (b)(3)(i).
(iii)
When a thermal incinerator is used, a temperature monitoring device equipped
with a continuous recorder is required and shall be installed in the firebox or
in the ductwork immediately downstream of the firebox at a location before any
substantial heat exchange occurs.
(iv) An owner or operator using a control
system not listed in this section shall submit, in writing, to the Department a
description of the system, test data verifying the performance of the system,
the appropriate operating parameter values that will be monitored and the
monitoring device that will be used to demonstrate continuous compliance with
the standard and receive, in writing, the Department's approval prior to use.
(v) An owner or operator of a
facility may not operate the control system at a daily average value greater
than or less than (as appropriate) the operating parameter value. The daily
average value shall be calculated as the average of all values for a monitored
parameter recorded during the operating day.
(vi) Submitting a compliance certification
which states that the control system has not been operated at a daily average
value greater than or less than (as appropriate) the operating parameter value
for each day in the semiannual reporting period or should otherwise identify
the days of noncompliance and the reasons for noncompliance.
(4)
Work practice
implementation plan. An owner or operator of a facility subject to
the work practice standards of §
129.103 shall demonstrate
continuous compliance by following the work practice implementation plan and
submitting a compliance certification which states that the work practice
implementation plan is being followed, or should otherwise identify the periods
of noncompliance with the work practice standards and the reasons for
noncompliance.
(d)
Compliance certification requirements. The compliance
certification shall be signed by a responsible official of the company that
owns or operates the facility. In addition to the certification requirements of
this section, the certification shall state that, based on information and
belief formed after reasonable inquiry, the statements and information in the
documents are true, accurate and complete.
Notes
The provisions of this § 129.104 issued under section 5(a)(1) of the Air Pollution Control Act (35 P.S. § 4005(a)(1)).
This section cited in 25 Pa. Code § 121.1 (relating to definitions); 25 Pa. Code § 129.52c (relating to control of VOC emissions from flat wood paneling surface coating processes); 25 Pa. Code § 129.91 (relating to control of major sources of NOx and VOCs); 25 Pa. Code § 129.96 (relating to applicability); 25 Pa. Code § 129.101 (relating to general provisions and applicability); 25 Pa. Code § 129.102 (relating to emission standards); 25 Pa. Code § 129.103 (relating to work practice standards); 25 Pa. Code § 129.105 (relating to recordkeeping requirements); 25 Pa. Code § 129.106 (relating to reporting requirements); 25 Pa. Code § 129.107 (relating to special provisions for facilities using an emissions averaging approach); and 25 Pa. Code § 129.111 (relating to applicability).
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