&EPA
United States
Environmental Protection
Agency
IMPLEMENTATION TOOL FOR
THE MISCELLANEOUS COATING
MANUFACTURING NESHAP
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
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EPA-305-B-06-003
September 2006
Implementation Tool for the
Miscellaneous Coating Manufacturing
NESHAP
Prepared for:
Air Compliance Branch
Compliance Assessment and Media Programs Division (CAMPD)
Office of Compliance (OC)
Office of Enforcement and Compliance Assurance (OECA)
U.S. Environmental Protection Agency
Washington, DC 20460
Prepared by:
RTI International*
3040 Cornwallis Road
Research Triangle Park, North Carolina 27709-2194
RTI International is a trade name of Research Triangle Institute.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Table of Contents
Disclaimer
The statements in this document are intended solely for compliance assistance. This document is
to be used in conjunction with the regulations, not in place of them. It is not intended, nor can it
be relied on, to create any rights enforceable by any party in litigation with the United States.
The U.S. Environmental Protection Agency (EPA) and State officials may decide to follow the
guidance provided in this document, or to act in variance with it, based on analysis of specific
site circumstances. This guidance may be revised without public notice to reflect possible rule
changes and changes in EPA's policy.
Please be aware that EPA has made its best effort to present an accurate summary of the
regulatory requirements in the miscellaneous coating manufacturing NESHAP as promulgated
on December 11, 2003, and amended on May 13, 2005, and December 21, 2005. Note that it is
not intended to summarize every option and detail of the rule. Finally, in the event that there are
typing errors or deviations from the final rule, the final rule stands.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Table of Contents
Table of Contents
Section Page
Disclaimer ii
Section 1 - Applicability and Compliance Dates 1-
Section 2 - Requirements for Process Vessels 2-
Section 3 - Requirements for Storage Tanks 3-
Section 4 - Requirements for Equipment Leaks 4-
Section 5 - Requirements for Wastewater and Heat Exchange Systems 5-
Section 6 - Requirements for Transfer Operations 6-
Section 7 - Requirements for Closed-Vent Systems and Control Devices 7-
Section 8 - Reporting Requirements 8-1
List of Figures
Figure Page
1-1 Applicability of subpartHHHHH 1-3
1-2 Timeline of compliance events for subpart HHHHH 1-6
2- Flowchart of applicability and control requirements for process vessels 2-3
3- Flowchart of applicability and control requirements for storage tanks 3-3
4- Flowchart of applicability and control requirements for equipment leaks 4-3
5 - Flowchart of applicability and control requirements for wastewater streams 5-3
6- Flowchart of applicability and control requirements for transfer operations 6-3
List of Tables
Table Page
1-1 Compliance Checklist for Subpart HHHHH Applicability Determination 1-7
1 -2 Identification of Applicable Emission Limits and Work Practice Standards 1-8
2-1 Compliance Checklist for Emissions Averaging for Process Vessel Vents 2-7
3-1 Compliance Checklist for Storage Tanks with an External Floating Roof 3-6
3-2 Compliance Checklist for Storage Tanks with an Internal Floating Roof 3-11
3-3 Compliance Checklist for Storage Tanks Equipped with a Control Device 3-16
3-4 Compliance Checklist for Storage Tanks Using Vapor Balancing 3-17
4-1 Compliance Checklist for Equipment Leaks Monitored by Monthly Sensory Observations 4-5
4-2 Compliance Checklist for the LDAR Program in Subpart TT for Equipment Leaks 4-7
4-3 Compliance Checklist for the LDAR Program in Subpart UU for Equipment Leaks 4-13
4-4 Compliance Checklist for Pressure Testing to Identify Equipment Leaks 4-22
4-5 Checklist for Determining Compliance with the Enclosed Process Alternative for Equipment
Leaks 4-24
5-1 Compliance Checklist for Wastewater 5-5
in
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Table of Contents
5 -2 Compliance Checklist for Heat Exchange Systems Requiring Leak Detection 5-7
7-1 Compliance Checklist for Bypass Line Provisions for Closed-Vent Systems 7-3
7-2 Compliance Checklist for Closed-Vent Systems 7-5
7-3 Compliance Checklist for Flares 7-7
7-4 Compliance Checklist for Thermal Incinerators 7-9
7-5 Compliance Checklist for Catalytic Incinerators 7-13
7-6 Compliance Checklist for a Boiler or Process Heater with a Design Heat Input Capacity Less
than 44 Megawatts and the Vent Stream Is Not Introduced with the Primary Fuel 7-17
7-7 Compliance Checklist for a Boiler or Process Heater with a Design Heat Input Capacity
Greater than 44 Megawatts or the Emission Stream Is Introduced with the Primary Fuel 7-21
7-8 Compliance Checklist for a Regenerative Carbon Adsorber 7-22
7-9 Compliance Checklist for an Absorber 7-25
7-10 Compliance Checklist for a Condenser 7-29
7-11 Compliance Checklist for a Control Device Not Specifically Listed 7-33
7-12 Compliance Checklist for a Scrubber 7-34
8-1 Inspection Checklist for Notification of Compliance Status Report 8-3
8-2 Inspection Checklist for Compliance Reports 8-5
IV
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
Section 1
Applicability and Compliance Dates
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 1
Do you manufacture
Are your coating
manufacturing operations
located at or part of a major source
of HAP emissions (i.e., Is the potential
to emit > 10 tpy for any
single HAP or > 25 tpy
for combined
HAP}?
Do you
process, use, or produce
any HAP in any of your coating
manufacturing operations?
Are any of your
coating manufacturing operations
part of an affected source under
another subpart of
part 63?
Do you have
a research and development
Continue at (A)
You are not subject to
subpart HHHHH
Your coating manufacturing
operations are not subject to
subpart HHHHH.
All coating manufacturing
operations that are part of another
affected source are not subject to
subpart HHHHH.
Subpart HHHHH does not apply to
research and development
facilities. Continue in the flowchart
at the point where you branched
off to this box to determine
applicability of other operations.
Figure 1-1. Applicability of subpart HHHHH.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 1
Do you have
''coating manufacturing
operations that are considerec
to be "affiliated operations"
associated with art affected source
under subpart GG,
KK, JJJJ, MMMM,
orSSSS?3
-Yes-
Do your
coating manufacturing
operations involve the use of "ancillary
equipment" (i.e.. equipment such as a boiler,
incinerator, or chiller/refrigeration system that is not
directly involved in the manufacturing of a coating
because it operates as a closed system
and materials are not combined with
_ material used to manufacture,
a coating)?
No
-Yes-
Do you have
a quality assurance/
quality control
laboratory?
These operations are not part of
the affected source under
subpart HHHHH. Continue in the
flowchart at the point where you
branched off to this box to
determine applicability of other
operations.
Yes-
You have "miscellaneous coating manufacturing operations," which is the affected source under
subpart HHHHH. The miscellaneous coating manufacturing operations consist of the facility-wide
collection of process vessels, storage tanks for feedstocks and products, components (e.g.,
pumps and valves), wastewater tanks, and transfer racks used to manufacture coatings. The
miscellaneous coating manufacturing operation also includes cleaning operations.
{ Continue at (§) )
Figure 1-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 1
Did you commence
construction {i.e., fabricate, erect,
or install the affected source)
of the affected source
after April 4, 2002?
Did you commence
reconstruction of the affected
source after April 4, 2002?"
Yes-
Yes-
You have a new affected source;
you must comply with the
requirements in sub part HHHHH
upon startup.
You have an existing affected source; you must comply with the requirements in
subpart HHHHH by December 11, 2006, unless your coating manufacturing
operations are part of a process unit group (PUG) under subpart FFFFS. If you add
equipment after December 11, 2006, the added equipment becomes part of the
existing affected source, and you must comply with subpart HHHHH upon startup of
the added equipment.
Key definitions:
1 "Coating" means a material such as a paint, ink, or adhesive that is intended to be applied to a substrate
and consists of a mixture of resins, pigments, solvents, and/or cither additives, where the material Is
produced by a manufacturing operation where materials are blended, mixed, diluted, or otherwise
formulated. Coating does not include materials made in processes where a formulation component is
synthesized by chemical reaction or separation activity and then transferred to another vessel where it is
formulated to produce a material used as a coating, where the synthesized or separated component Is not
stored prior to formulation. Typically, coatings include products described by the following North American
Industry Classification System (NAICS) codas, coda 325510, Paint and Coaling Manufacturing, code 325520,
Adhesive and Sealant Manufacturing, and code 325910, Ink Manufacturing.
1 "Research and development facility" means any stationary source whose primary purpose Is to conduct
research and development into new processes and products, where such source is operated under the
close supervision of technically trained personnel and is not engaged in the manufacture of products for
commercial sale in commerce, except in a de mini mis manner.
* "Affiliated operations" include, but are not limited to, mixing or dissolving of coating ingredients; coating
mixing for viscosity adjustment, color tint or additive blending, or pH adjustment; cleaning of coating lines
and coating line parts; handling and storage of coatings and solvent; and conveyance and treatment of
wastcwater.
* "Reconstruction" means the replacement of components of an affected or previousty unaffected stationary
source to such an extent that (1) the fixed capital cost of the new components exceeds 50 percent of the
fixed capital cost that would be required to construct a comparable.- new source and (2) It is technologically
and economically feasible for the reconstructed source to meet Wie requirements in subpart HHHHH,
' Section E3.8090(c] specified that a PUG that includes coaling manufacturing operations must be in
compliance with subpart FFFF by the applicable compliance date in §63.2445 (May 10, 2006 for an existing
sourcej,
Figure 1-1. (continued)
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is due no later
than 8/8/07. It covets the period from
12/11/06 through 6/11/07 (subsequent
reports are due 6 monttis after the
preceding report)
:irst semiannual reporting period ends
a111/07
Notification of a planned performance test
must be submitted at least 60 days before the
test. Tests to demonstrate Initial compliance
must be conducted before 5/1 Q'07
T
report
must be submitted no later than 5/10/07
Effective date of sufapart
HHHHHis 12,'11/03
is 12/11/061'
Initial notifications
due by 4/9/04
Pracampliance report
if necessary, must be
submitted no later than
Si 1/06
I
Dec 11,
20D3
Dec 11,
2004
Dsc 11,
2005
Dec 11,
2006
Dec 11,
2007
Dates shown are for existing sources The intervals between events are She same tor new sources, but the compliance date is the date of startup. Additionally, the
initial notification doesn't apply, but a r&quest for approval of construction or reconstruction must be submitted.
If coating manufacturing operations ara included in a process unit group (PUG) under subpart FFFF. the compliance date is May 10. 20ftB.
Figure 1-2. Timeline of compliance events for subpart HHHHH."
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
Table 1-1. Compliance Checklist for Subpart HHHHH Applicability Determination
Note: Use this checklist to determine if a facility is subject to subpart HHHHH. Refer to Figure 1-1 for
definitions and other information to help determine applicability of subpart HHHHH.
1. Does the facility manufacture a coating?
D Yes, or
Continue with this checklist
D No
Stop. Your facility is not subject to subpart HHHHH.
2. Are your coating manufacturing operations located at or part of a major source of HAP emissions?
D Yes, or
Continue with this checklist
D No
Stop. Your facility is not subject to subpart HHHHH.
3. Does the facility process, use, or produce HAP in the production of a coating?
D Yes, or
Continue with this checklist
D No
Stop. Your facility is not subject to subpart HHHHH.
4. Are your coating manufacturing operations part of an affected source under another subpart of
part 63?
D Yes, or
Your facility is not subject to subpart HHHHH.
D No
Your facility is subject to subpart HHHHH. Continue with the checklist in Table 2-1.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
Table 1-2. Identification of Applicable Emission Limits and Work Practice Standards
Note: Use the tabular summary in Section I of this checklist to identify the applicable emission limits
and work practice standards for the facility. Then use Sections II and III of this checklist and the
referenced checklists to determine compliance with the applicable emission limits and work
practice standards.
Note: A "yes" response to question in section II or III of this checklist means compliance with that
requirement, and a "no" response means noncompliance with the requirement. If a question is not
applicable, check the "N/A" box.
I. Summary of Requirements
1. Do you have process vessels (> 250 gal) that contain HAP when producing a D Y D N
coating at an existing source?
If yes, which of the following types of emission limits or work practice
standards in Table 1 to subpart HHHHH or §§63.8050 or 63.8055 apply to the
process vessels: (check all that apply)
D Equip portable vessels with a cover or lid that must be in place at all times
when the vessel contains HAP, except for material additions and sampling?
D Equip stationary vessels with a cover or lid and a capture system to route
emissions to a control device that achieves overall reduction in organic
HAP of 60 percent or 75 percent, depending on the HAP vapor pressure?
Note: The cover or lid must be closed at all times when the vessel contains
HAP, except for material additions and sampling.
D Equip stationary vessels with a tightly fitting vented cover or lid and a
closed-vent system to route emissions to a:
Note: The cover or lid must be closed at all times when the vessel contains
HAP, except for material additions and sampling.
D control device that reduces organic HAP emissions by 60 percent or 75
percent, depending on the HAP vapor pressure?
D flare?
D condenser that reduces the outlet gas temperature to levels specified in
item 2.b.iii in Table 1 to subpart HHHHH?
D Emissions average for stationary vessels?
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
Table 1-2. (continued)
I. Summary of Requirements
D Alternative 5 percent by weight HAP limit in coating products option?
Note: The HAP percentage may be determined by test methods as specified
in §63.8055(b)(l) through (3). Alternatively, as specified in
§63.8055(b)(4), formulation data from raw material suppliers may be used
to determine the HAP percent if the formulation data identify each organic
HAP that is present at 0.1 percent by mass or more for OSHA-defined
carcinogens (see 29 CFR 1910.1200(d)(4)), and at 1.0percent by mass or
more for other compounds.
2. Do you have process vessels (> 250 gal) that contain HAP when producing a D Y D N
coating at a new source?
If yes, which of the following types of emission limits or work practice
standards in Table 1 to subpart HHHHH apply to the process vessels: (check all
that apply)
D Equip portable and stationary vessels with a tightly fitting vented cover or
lid and a closed-vent system to route emissions to a:
Note: The cover or lid must be closed at all times when the vessel contains
HAP, except for material additions and sampling.
D non-flare control device that reduces organic HAP emissions by > 95
percent?
D flare?
D condenser that reduces the outlet gas temperature to levels specified in
item S.a.iii in Table 1 to subpart HHHHH?
3. Do you have Group la or Ib storage tanks? D Y D N
If yes, which of the following types of emission limits in Table 2 to subpart
HHHHH apply to the storage tanks:
D Internal floating roof? (go to checklist in Table 3-1)
D External floating roof? (go to checklist in Table 3-2)
D Vent through closed-vent system to a control device? (go to checklist in
Table 3-3)
D Vapor balance? (go to checklist in Table 3-4)
4. Do you have equipment (i.e., pumps, valves, etc.) in organic HAP service (i.e., D Y D N
fluid is at least 5 percent by weight of total organic HAP)?
If yes, which types of requirements in Table 3 to subpart HHHHH apply to the
equipment leaks: (check all that apply)
D Monitor for leaks once per month using sensory methods as specified in
subpart R? (go to checklist in Table 4-1)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
Table 1-2. (continued)
I. Summary of Requirements
D Use LDAR methods specified in subpart TT? (go to checklist in Table 4-2)
D Use LDAR methods specified in subpart UU? (go to checklist in Table 4-3)
D Pressure test? (go to checklist in Table 4-4)
D Enclosed process alternative? (go to checklist in Table 4-5)
5. Do you have Group 1 waste water streams? D Y D N
If yes, which of the following types of emission limits and work practice
standards in Table 4 to subpart HHHHH apply to the wastewater stream: (check
all that apply)
D Convey using hard piping to hazardous waste treatment (or to storage prior
to transfer offsite for treatment as hazardous waste)? (go to checklist in
Table 5-1)
D Convey to onsite enhanced biological treatment or to a wastewater tank
prior to transfer offsite for treatment in an enhanced biological treatment
unit? (go to checklist in Table 5-1)
6. Do you have a heat exchange system? (if yes, go to checklist in Table 5-2) D Y D N
7. Do you have Group 1 transfer operations? D Y D N
8. Do you have halogenated vent streams from process vessels (> 250 gal) and/or DY DN
Group 1 transfer operations that are controlled in a non-flare combustion
device?
If yes, which of the following control devices from Table 1 or 5 of subpart
HHHHH apply to the process vessels land/or transfer operations: (check all that
apply)
D Use a halogen reduction device after the combustion device to reduce
hydrogen halide and halogen HAP emissions? or
D Use a halogen reduction device before the combustion device to reduce
halogen atom mass emissions?
9. Do you use a control device to control emissions from process vessels D Y D N
(> 250 gal), Group la or Ib storage tanks, and/or Group 1 transfer operations?
If yes, which of the following control devices do you use: (check all that apply)
D Flares? (go to checklists in Tables 7-1, 7-2, and 7-3)
Note: A flare is allowed only for nonhalogenated vent streams.
D Thermal incinerator? (go to checklists in Tables 7-1, 7-2, and 7-4)
D Catalytic incinerator? (go to checklists in Tables 7-1, 7-2, and 7-5)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
Table 1-2. (continued)
I. Summary of Requirements
D Boiler or process heater with a design heat input capacity < 44 MW and the
vent stream is not introduced with the primary fuel? (go to checklists in
Tables 7-1, 7-2, and 7-6)
D Boiler or process heater with a design heat input capacity > 44 MW or the
emission stream is introduced with the primary fuel? (go to checklists in
Tables 7-1, 7-2, and 7-7)
D Regenerative carbon adsorber? Go to checklists in Tables 7-1, 7-2, and 7-8)
D Absorber? (go to checklists in Tables 7-1, 7-2, and 7-9)
D Condenser? (go to checklists in Tables 7-1, 7-2, and 7-10)
D Other control device not listed? (go to checklists in Tables 7-1, 7-2, and 7-
11)
D Halogen scrubber? (go to checklists in Tables 7-1, 7-2, and 7-12)
Note: If you use a series of control devices, the checklists in Tables 7-1 and 7-2
would be used only once.
II. Review of Records
1. Are records of the following information, as applicable, kept for each storage
tank? §§63.1065(a) and 63.8075(d)(2)ft)
(a) Dimensions of the storage tank? D Y D N/A D N
(b) Capacity of storage tank? DY DN/A DN
(c) Identification of the liquid stored in the storage tank? D Y D N/A D N
Note: Section 63.1065 (a) explicitly requires all of these records for
Group 1 storage tanks that are equipped with floating roofs. Although
subpart HHHHH does not explicitly require these records for Group 2
storage tanks or Group 1 storage tanks not controlled using floating
roofs, §63.8075(d)(2)(i) requires the results of applicability
determinations to be included in the notification of compliance status
report. The information described by these records is needed to make
those applicability determinations. Thus, all of the records are required
for Group 1 storage tanks that are part of an affected source under
subpart HHHHH. Any individual record is sufficient to demonstrate that
a storage tank is a Group 2 storage tank. These are the only
requirements for Group 2 storage tanks.
2. Has the facility submitted a notification of compliance status report? D Y D N/A D N
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 1
Table 1-2. (continued)
III. Visual Inspections
1. Is each process vessel that contains HAP equipped with the appropriate type D Y D N/A D N
of cover or lid as noted in the tabular summary of requirements above, and is
it closed?
Note: These requirements do not apply if the process vessel has a capacity
< 250 gal, or the facility is complying with the 5 percent by weight HAP in the
coating product alternative.
Note: The cover or lid may be opened for material addition and sampling.
2. If the control device is a condenser that reduces the outlet gas temperature to DY DN/A DN
levels as specified in Table 1 to subpart HHHHH, is the outlet gas temperature
at or below the specified temperature?
3. If a capture system is used to collect emissions from process vessels, is its DY DN/A DN
design consistent with the description of the system in the notification of
compliance status report, and is the exhaust operating (i.e., air is flowing)?
§63.8075(d)(2)(ii)
4. If transfer operation emissions are vapor balanced to the originating storage D Y D N/A D N
tank, is the vapor balancing system in place and operating?
IV. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 2
Section 2
Requirements for Process Vessels
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 2
Use this flowchart for each
miscellaneous process vessel in
which coating manufacturing
operations occur.
Is the
capacity of the vessel
> 250 gal?
The process vessel
requirements In subpart
HHHHH do not apply.
Does the
miscellaneous coating
manufacturing operation in
the vessel process, use, or
produce any HAP?
Is the
HAP content of the coating
product > 5% by weight?
process vessel part
of a new source
under subpart
Is the vessel a
stationary process
vessel?
Equip the vessel(s) with a
tight fitting vented cover
as specified in item 3 to
Table 1 to subpart HHHHH
For the process vessels
used to make the subject
coating, you may comply
with the 5% weight HAP
limit specified in §63.8055
as an alternative to the
requirements in Table 1
to subpart HHHHH.*
Equip the portable process
vessel with a cover or lid as
specified In item 1 of Table 1 to
subpart HHHHH.
Continue at (A)for
each emission
stream from the
vessel.
Equip the stationary
vessel with a tight
fitting vented cover
as specified in
item 2.b to Table 1.
Equip the stationary vessel with a cover or lid and
comply with the capture and control requirements
specified in item 2,a to Table 1. Also comply with
item 4 to Table 1, if applicable. Details of options
are presented at(B).
The HAP percentage rnsy he determined by test methods as specified in §63 8055(b)(1) through (3) Alternatively, as specified in §63,8055(b)^4).
formulation data from raw material suppliers may be used to determine the HAP percenl if the forrmulatksn data identify each argaftie HAP that is presem at
0.1 percent by mass « more tor OSHA-defined carcinogens (see29GFR 1910.1200(d)(4)). and at 1.0 percent fay mass or more for other compounds.
Figure 2-1. Flowchart of applicability and control requirements for process vessels.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 2
Does the
vented emission stream contain
HAP concentrations
< 50 ppmv?
Is the vented
emission stream routed to
a fyel gas system?
Is the vented
emission stream routed
to a process?
s a
flexible elephant
trunk system used to draw vapors
away from operators when the
vessel is opened?
Such an emission stream is
not a process vessel vent, and
no control is required.
The emission stream is not a
process vessel vent, and no
control is required.
The flexible elephant trunk
system is not a process vessel
vent, and no control is
required.
All other vented emissions, including those from automatic cleaning operations,
are process vessel vent streams that must b* controlled. Control options are
specified al(C),
Figure 2-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 2
Do any of the
emitted organic HAP
compounds have a vapor
pressure at 25° C
> 0.6 kPa?
Yes-
Considering both capture and
control, reduce collective emissions
of organic HAP by > 60 percent
Considering both capture and control.
reduce collective emissions of organic
HAP with a vapor pressure > 0.6 kPa by
> 75 percent and reduce collective
emissions of organic HAP with a vapor
pressure < 0.6 kPa by > 60 percent
Additional requirements apply if
you use a combustion device to
control a halogenated vent stream
-or
Use a halogen reduction device
before the combustion device to
reduce the halogen atom mass
emissions rate to £0.45 hg/hr
Use a halogen reduction device
after the combustion device to
reduce emissions of hydrogen
halicle and halogen HAP by
95 percent or to <.0.45kg/hr
Figure 2-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 2
from a process vessel
at a new source?
Reduce emissions using any of the options
below. The requirements arc specified in
Items 2,b and 4 of Table 1
Reduce emissions using any of the
options below. The requirements are
specified in Items 2.a and 4 of Table 1
For non-halog©nat©d vent streams only, vent omissions
through a closed-vent system to a flare
Use a condenser that
Use a condenser that
reduces the outlet gas
temperature to < -30*0
reduces tine outlet gas
temperature to -5°C
Do any of
the emitted org
a vapor pressure
0.7 kPa?
Use a condenser that
Use a condenser that
Use a condenser that
reduces the outle
temperature to < -4DC
reduces me outlet gas
reduces the outlet gas
temperature to < TC
temperature to -2CTC
Reduce collective emissions of
these HAP with a vapor pressure
> 0.6 kPa by >75 percent and
reduce collective emissions of
HAP wrth a vapor pressure < O.S
kPa by > 60 percent.
Reduce emissions of
organic HAP by
> 95 percent
Additional requirements apply if you use
a combustion device to control a
halogenated venl stream
Use a halogen reduction device
before the combustion device to
reduce the halogen atom mass
emission rate to < 0.45 kg/hr
Use a halogen reduction device
after the combustion device to
reduce emissions of hydrogen
halitlc and halogen HAP by > 95
percent or to < 0,45 kg/hr
Comply with the emissions averaging
alternative as specified in §63,8050
Figure 2-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 2
Table 2-1. Compliance Checklist for Emissions Averaging for Process Vessel Vents
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the requirement is not applicable,
check the "N/A" box.
Note: Also use the checklists for closed vent systems and applicable control devices as referenced in
item 1.6 of Table 1-2.
I. Review of Records
1. Does the facility maintain a monthly log of the number of batches produced D Y D N/A D N
that can be correlated with the emission estimates per batch as documented in
the notification of compliance status report? §63.8050(d)(l)
2. Does the facility sum the actual emissions for all process vessels in the D Y D N/A D N
emissions averaging group every 3 months? §63.8050(d)(2)
3. Is each quarterly sum of actual emissions less than the calculated estimate of DY DN/A DN
emissions if the vessels had been controlled as specified in Table 1 to subpart
HHHHH? §63.8050(d) (2)
4. Are all records kept for at least 5 years? §63.10(b)(l) D Y D N/A D N
II. Visual Inspections
1. Is the emissions averaging group limited to stationary process vessels? DY D N/A DN
§63.8050(a)
2. Are the stationary vessels equipped with tightly fitting vented covers? D Y D N/A D N
§6 3.80 50 (b) (2)
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Section 3
Requirements for Storage Tanks
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 3
Start
Does the
stored liquid contain any
HAP?
Is the vessel
permanently attached to a
motor vehicle?
Is the
vessel designed
to operate in excess of
204.9 kPa (29.7 psia) and
without emissions to
the atmosphere?
The vessel is a storage tank
Continue at
Use this flowchart for each tank or vessel that is used to store organic
liquids as raw material feedstocks or product. Note that this flowchart
does not apply to process vessels (see flowchart 2) or wastewater
storage vessels (see flowchart 5),
The storage tank
requirements in subpart
HHHHH do not apply.
Yes-
Yes-
Yes-
The vessel is not
a storage tank.
Figure 3-1. Flowchart of applicability and control requirements for storage tanks.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 3
You have a Group 2 storage tank. No control is required
Is the
MTVP of the total
organic HAP > 0.69 kPa
> 0.1 psial?
You have a Group 1b storage tank. Contro
emissions as specified in Hem 2 of Table 2
to subpart HHHHH. Control options are
described at (g)
You have a Group 1a storage tank. Control
emissions as specified in item 1 of Table 2
to subpart HHHHH. Control options are
described at (§)
Figure 3-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 3
or
or
or
Install and maintain an Internal
floating roof or an external
floating roof in accordance with
subpart WW of 40 CFR part 63.
Vent emissions through a closed-
vent system to a flare; this option
is only allowed If the vent stream
does not contain halogen atoms in
organic compounds at a
concentration >.20 ppmv (i,e,, if it
is not a "halogenated vent
stream"),
Implement a vapor balancing
system that is designed and
operated to route organic HAP
vapors from the storage tank to
the railcar or tank truck from which
the storage tank is loaded.
Reduce total organic HAP
emissions by > 90 percent by
weight by venting emissions
through a closed-vent system
to any control device other
than a flare.
Reduce total organic HAP
emissions by >_ 80 percent by
weight by venting emissions
through a closed-vent system
to any control device other
than a flare.
or
or
or
Figure 3-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-1. Compliance Checklist for Storage Tanks with an External Floating Roof
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If a question is not applicable, check
the "N/A" box.
Identification of Storage Tank(s):
I. Review of Records
1. Are all records kept for at least 5 years? §§63.1065 and 63.10(b)(1) D Y D N
2. Do records indicate that seal gap measurements have been made every 5 D Y D N/A D N
years for the primary seal? §63.1063(c)(2)(ii)
3. Do records indicate that seal gap measurements have been made annually DY DN/A DN
for the secondary seal?a §63.1063(c)(2)(ii)
4. Do records indicate the floating roof deck, deck fittings, and rim seals are DY DN/A DN
visually inspected each time the tank is completely emptied and degassed or
every 10 years? §63.1063(c)(2)(iii)
5. Were both of the following recorded for all visual inspections and seal gap
measurements: §63.1065(b)(l)(i) and (ii)
• Identification of the storage vessel? D Y D N
• Date of the inspection? D Y D N
6. For all seal gap measurements, was all of the following information
recorded: §63.1065(b)(2)
• All of the raw data that were obtained? D Y D N
• All calculations that were performed (e.g., total gap area)? DY DN
7. When a failure was detected during a visual inspection or seal gap
measurement, was all of the following information recorded:
§63.1065(b)(l)(iii) through (v)
• A description of all inspection failures? DY DN/A DN
• A description of all repairs and the dates they were made? DY DN/A DN
• The date the storage tank was removed from service (if the inspection D Y D N/A D N
was performed while the tank was in operation and repairs can not be
completed while operating)?
8. Whenever a floating roof was set on its legs or other supports, was all of the
following information recorded: §63.1065(c)
• The date when the floating roof was set on it legs or other supports? DY DN/A DN
• The date when the floating roof was refloated? DY DN/A DN
• An indication of whether the process of refloating was continuous? DY DN/A DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-1. (continued)
I. Review of Records
9. If a tank was taken out of service to complete repairs, but it could not be
emptied within 45 days of detecting a failure, was all of the following
information kept to document the decision to request up to two 30-day
extensions: §§63.1063(e)(2), 63.1065(d), and 63.1066(b)(4)
• A description of the failure? DY DN/A DN
• Documentation that alternate storage capacity was not available? DY DN/A DN
• Schedule of actions taken to make repairs or empty the tank as soon as D Y D N/A D N
possible?
10. If performing a required seal gap measurement was determined to be unsafe,
and the vessel could not be emptied within 45 days, was all of the following
information kept to document the decision to request up to two 30-day
extensions: §§63.1063(c)(2)(iv)(B), 63.1065(d), and 63.1066(b)(4)
• Explanation of why it was unsafe to perform the seal gap measurement? DY D N/A DN
• Documentation that alternate storage capacity was unavailable? D Y D N/A D N
• Schedule of actions taken to make repairs or empty the tank as soon as DY DN/A DN
possible?
11. Was the Administrator or delegated state or local agency notified at least 30 D Y D N/A D N
days before each internal inspection or seal gap measurement (7 days if the
inspection was unplanned and could not be foreseen 30 days in advance)?
§63.1066(b)(l)
Note: a delegated state or local agency may waive this requirement.
12. When a failure was detected during a visual inspection or seal gap D Y D N/A D N
measurement, was a copy of the inspection records submitted in the next
compliance report? §63.1066(b)(2)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-1. (continued)
II. Visual Inspection
Note: The inspector should not perform the inspection while on the EFR if the roof is below 4 feet of
the top of the tank and if the inspector is not equipped with the proper respiratory protection.
Based on the inspector's assessment of the availability of records documenting the design of the
control equipment, an adequate inspection without respiratory protection may be performed with
a combination of a record inspection and a visual inspection conducted from the platform with the
aid of vision-enhancing devices (binoculars). If the inspector feels that it is necessary to be on the
EFR when the roof is below 4 feet of the top of the tank, please be aware of the requirements
under EPA Order 1440.2 and the safety information in Guidance on Confined Space Entry in
NESHAP Inspections of Benzene Storage Vessels (EPA 455/R-92-003, September 1992).
1. Does the EFR float on the surface of the stored liquid? §63.1063(b)(l) and Y N/A N
(2)
Note: The EFR is not required to be floating on the liquid when it is
supported by its leg supports either because the liquid depth is insufficient
to float the EFR or the tank is empty.
2. Is the floating roof deck free of pools of standing liquid? §63.1063(d)(l)(i) Y N
3. Inspect the secondary seal.
• Is the secondary seal free of holes and tears ?b §63.W63(d)(l)(ii) Y N/A N
• Is the secondary seal continuously attached around the circumference of Y N/A N
the EFR?
4. Perform seal gap measurement of the secondary seal.b
• Is the accumulated area of gaps between the tank wall and the secondary Y N/A N
seal no greater than 21.2 cm2 meter of tank diameter?
• Is the maximum gap width between the tank wall and the seal no greater Y N/A N
than 1.27 cm?
Note: Procedures for performing the seal gap measurements and
determining the total gap area and maximum gap width are specified in
§63.1063(d)(3).
5. Inspect the primary seal.
• Is the primary seal either a mechanical/metallic shoe seal or a liquid- Y N
mounted seal?b §63.1063(a)(l)(ii) and see definitions of "mechanical
shoe seal" and "liquid-mountedseal" in §63.1061
• Is the primary seal free of holes and tears? §63.1063(d)(l)(ii) Y N
• Is the primary seal continuously attached around the circumference of the Y N
EFR?
• If the primary seal is a mechanical/metallic shoe seal:
- Does the lower end of the mechanical/metallic shoe seal extend into Y N/A N
the stored liquid (no specific distance)?
- Does the upper end of the mechanical/metallic shoe seal extend a Y N/A N
minimum vertical distance of 61 cm above the stored liquid surface?
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-1. (continued)
II. Visual Inspection
- Does a flexible coated fabric span the space between the metal shoe Y N/A N
and the tank wall?
• If the primary seal is a liquid-mounted seal, is the seal in contact with the Y N/A N
liquid between the wall of the storage tank and the EFR?
6. Perform seal gap measurements of the primary seal.
• Is the accumulated area of gaps between the tank wall and the primary Y N
seal no greater than 212 cm2 per meter of tank diameter?
• Is the maximum gap width between the tank wall and the seal no more Y N
than 3.81cm?
Note: Procedures for performing the seal gap measurements and
determining the total gap area and maximum gap width are specified in
§63.1063(d)(3).
1. Inspect deck openings.
• Is the lower edge of each opening in the floating roof, except automatic Y N/A N
bleeder vents and rim space vents, below the surface of the stored
liquid?0 §63.1063(a)(2)(i)
• Except for automatic bleeder vents, rim space vents, deck drains, and leg Y N/A N
sleeves, does each opening in the roof have a gasketed cover?0
§63.1063(a)(2)(ii)
• Is each gasketed cover, seal, or lid on any opening in the EFR closed, Y N/A N
except when it must be open for access?0 §63.1063(b)(3)
• Is the cover on each access hatch and gauge float well designed to be Y N/A N
bolted or fastened when closed?0 §63.1063(a) (2) (vi)
• Does each deck fitting gasket, seal, and wiper fit between the surfaces it Y N/A N
is intended to seal without any gaps larger than 0.32 cm (1/8 in)?
§63.1063(d)(l)(v)
8. Inspect automatic bleeder vents (vacuum breaker vents).
• Is each automatic bleeder vent closed, except when required to be open Y N
to relieve excess pressure or vacuum? §63.1063(b)(4)
• Does each automatic bleeder vent have a gasketed lid, pallet, flapper, or Y N/A N
other closure device?0 §63.1063(a)(2)(iii)
9. Inspect rim space vents.
• Is each rim space vent closed, except when required to be open to relieve Y N
excess pressure or vacuum? §63.1063(b)(4)
• Does each rim space vent have a gasketed lid, pallet, flapper, or other Y N/A N
closure device?0 §63.1063(a)(2)(in)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-1. (continued)
II. Visual Inspection
10. Does each deck drain that empties into the stored liquid have either a Y N/A N
gasketed cover or a slit fabric seal or similar device that covers at least 90
percent of the area of the opening?0 §63.1063(a)(2)(v)
11. Does each unslotted guide pole well have a pole wiper?0 Y N/A N
§63.1063(a)(2)(vii)
12. Does each unslotted guide pole have a gasketed cap on the end of the pole?0 Y N/A N
§63.1063(a)(2)(vii)
13. Is the cap on each unslotted guidepole closed, except when gauging the Y N/A N
liquid level or taking liquid samples? §63.1063(b)(5)
14. Does each slotted guide pole have either of the following: (1) a pole wiper Y N/A N
and pole float, or (2) a pole wiper and pole sleeve?0 §63.1063(a)(2)(viii)
15. Does each sample well have either a gasketed cover or a slit fabric seal or Y N/A N
similar device that covers at least 90 percent of the area of the opening?0
§63.1063(a)(2)(v)
III. Note All Deficiencies
EFR = external floating roof.
a If an EFR has a liquid-mounted or metallic shoe primary seal as of April 4, 2002, a secondary seal is
not required until the next time the tank is emptied and degassed or until December 11, 2013,
whichever is earlier. §63.1063(a)(l)(ii)(C)
b If the EFR is equipped, as of April 4, 2002, with either: (1) a liquid-mounted primary seal and no
secondary seal, (2) a metallic shoe primary seal and no secondary seal, or (3) a vapor-mounted primary
seal and a secondary seal, then the seal requirement of a liquid-mounted or metallic shoe primary seal
and secondary seal does not apply until the earlier of the following dates: (1) the next time the storage
tank is emptied and degassed, or (2) December 11, 2013. §63.1063(a)(l)(ii)(C)
0 If these requirements were not met for a floating roof in place as of April 4, 2002, then this requirement
does not apply until the earlier of the following dates: (1) the next time the storage tank is emptied and
degassed, or (2) no later than December 11, 2013. §63.1063(a)(2)(ix)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-2. Compliance Checklist for Storage Tanks with an Internal Floating Roof
Note: An external floating roof located in a storage tank to which a fixed roof has been added is defined
as an internal floating roof. §63.1061
A "yes" response to a question in this checklist means compliance with that provision, and a "no"
response means noncompliance with the requirement. If a question is not applicable, check the
"N/A" box.
Identification of Storage Tank(s):
I. Review of Records
1. Are all records kept for at least 5 years? §§63.1065 and 63.10(b)(l) DY DN
2. Do records show that visual inspections are conducted on either of the
following schedules: §63.1063(c)(i) and (ii)
(a) Internal and tank-top inspections are conducted as follows:
• Tank-top visual inspections are conducted at least once per year? D Y D N/A D N
• Internal visual inspections are conducted each time the storage tank D Y D N/A D N
is emptied and degassed, or every 10 years, whichever occurs first?
(b) Internal inspections are conducted each time the storage tank is emptied D Y D N/A D N
and degassed or every 5 years, whichever occurs first?
Note: The second option is allowed only for storage tanks with both
primary and secondary seals.
3. Were both of the following recorded for all visual inspections:
§63.1065(b)(l)(i) and (ii)
(a) Identification of the storage vessel? D Y D N
(b) Date of the inspection? D Y D N
4. When a failure was detected during a visual inspection, was all of the
following information recorded: §63.1065(b)(l)(iii) through (v)
(a) A description of all inspection failures? DY DN/A DN
(b) A description of all repairs and the dates they were made? DY DN/A DN
(c) The date the storage tank was removed from service (if the inspection D Y D N/A D N
was performed while the tank was in operation and repairs can not be
completed while operating)?
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-2. (continued)
I. Review of Records
5. Whenever a floating roof was set on its legs or other supports, was all of the
following information recorded: §63.1065(c)
(a) The date when the floating roof was set on it legs or other supports? DY DN/A DN
(b) The date when the floating roof was refloated? D Y D N/A D N
(c) An indication of whether the process of refloating was continuous? D Y D N/A D N
6. If a tank was taken out of service to complete repairs, but it could not be
emptied within 45 days of detecting a failure, was all of the following
information kept to document the decision to request up to two 30-day
extensions: §§63.1063(e)(2), 63.1065(d), and 63.1066(b)(4)
(a) A description of the failure? DY DN/A DN
(b) Documentation that alternate storage capacity was not available? D Y D N/A D N
(c) Schedule of actions taken to make repairs or empty the tank as soon as D Y D N/A D N
possible?
7. Was the Administrator or delegated State or local agency notified at least 30 DY DN/A DN
days before each visual inspection (7 days if the inspection was unplanned
and could not be foreseen 30 days in advance)? §63.1066(b)(l)
Note: a delegated State or local agency may waive this requirement.
8. When a failure was detected during a visual inspection, was a copy of the D Y D N/A D N
inspection records submitted in the next compliance report? §63.1066(b)(2)
II. Visual Inspection
Note: The inspector should be advised of the hazards of inspecting an internal floating roof tank that
contains a liquid hazardous air pollutant (HAP). An inspector may perform an external (tank-top)
visual inspection of a storage tank at any time (i.e., the tank does not need to be taken out of
service). However, the inspector will need to have proper respiratory protection before opening
the roof hatch to visually inspect, from the fixed roof, the floating deck and seal. An inspector
may perform the more thorough internal inspection only when the tank has been taken out of
service (i.e., emptied, degassed and cleaned). Unless a tank is taken out of service more
frequently than is required by subpart FFFF, this internal inspection can only take place once
every 10 years. The inspector should never enter a storage tank to inspect the IFR without first
consulting documents that address the safety issues to consider while entering a confined space
and while inspecting an IRF that contains HAP - EPA Order 1440.2 and the EPA document
Guidance on Confined Space Entry in NESHAP Inspections of Benzene Storage Vessels (EPA
455/R-92-003, September 1992).
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-2. (continued)
II. Visual Inspection
1. Does the IFR float on the surface of the stored liquid? §63.1063(b)(l) and DY D N/A DN
(2)
Note: The IFR is not required to be floating on the liquid when it is
supported by its leg supports either because the liquid depth is insufficient
to float the IFR or the tank is empty.
2. Is the floating roof deck free of pools of standing liquid? §63.1063(d)(l)(i) DY DN
3. Inspect the rim seal(s).
(a) Does the IFR have any one of the following closure devices:3 D Y D N/A D N
§63.1063(a)(l)
- A liquid-mounted primary seal? See definition of "liquid-mounted
seal" in §63.1061
- A mechanical/metallic shoe primary seal? See definition of
"mechanical shoe seal" in §63.1061
- Both a primary seal and a secondary seal?
(b) Is the primary seal continuously attached around the circumference of D Y D N
the IFR?
(c) If the IFR has a secondary seal, is it continuously attached around the DY DN/A DN
circumference of the IFR?
(d) Are there no visible gaps between the seal(s) and the wall of the storage DY DN
tank?
(e) Is the primary seal free of holes and tears? §63.1063(d)(l)(ii) DY DN
(f) If the IFR has a secondary seal, is it free of holes and tears? DY DN/A DN
§63.1063(d)(l)(ii)
(g) If the primary seal is a mechanical/metallic shoe seal:
- Does the lower end of the metallic shoe seal extend into the stored D Y D N/A D N
liquid (no specific distance)?
- Does a flexible coated fabric span the space between the metal shoe D Y D N/A D N
and the tank wall?
(h) If the primary seal is a liquid-mounted seal, is the seal is in contact with D Y D N/A D N
the liquid between the wall of the storage tank and the IFR?
4. Inspect deck openings.
(a) If the IFR is non-contact, is the lower edge of each opening in the DY DN/A DN
floating roof, except automatic bleeder vents and rim space vents, below
the surface of the stored liquid?b §63.1063(a)(2)(i)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-2. (continued)
II. Visual Inspection
(b) Except for automatic bleeder vents, rim space vents, deck drains, leg D Y D N/A D N
sleeves, and openings for fixed roof support columns, does each
opening in the roof have a gasketed cover?b §63.1063(a)(2)(ii)
(c) Is each gasketed cover, seal, or lid on any opening in the IFR closed, D Y D N/A D N
except when it must be open for access?b §63.1063(b)(3)
(d) Does each opening for a fixed roof support column have either a D Y D N/A D N
flexible fabric sleeve seal or a gasketed cover?b §63.1063(a)(2)(iv)
(e) Is the cover on each access hatch and gauge float well designed to be D Y D N/A D N
bolted or fastened when closed?b §63.1063(a)(2)(vi)
(f) Does each deck fitting gasket, seal, and wiper fit between the surfaces it D Y D N
is intended to seal without any gaps larger than 0.32 cm (1/8 in)?
§63.1063(d)(l)(v)
5. Inspect automatic bleeder vents (vacuum breaker vents).
(a) Is each automatic bleeder vent closed, except when required to be open D Y D N
to relieve excess pressure or vacuum? §63.1063(b)(4)
(b) Does each automatic bleeder vent have a gasketed lid, pallet, flapper, or D Y D N/A D N
other closure device?b §63.1063(a)(2)(iii)
6. Inspect each rim space vent.
(a) Is each rim space vent closed, except when required to be open to D Y D N
relieve excess pressure or vacuum? §63.1063(b)(4)
(b) Does each rim space vent have a gasketed lid, pallet, flapper, or other D Y D N/A D N
closure device?b §63.1063(a)(2)(iii)
1. Is each deck drain that empties into the stored liquid have either a gasketed D Y D N/A D N
cover or a slit fabric seal or similar device that covers at least 90 percent of
the area of the opening?b §63.1063(a)(2)(v)
8. Does each unslotted guide pole well have a pole wiper?b DY DN/A DN
§63.1063(a)(2)(vii)
9. Does each unslotted guide pole have a gasketed cap on the end of the pole?b DY DN/A DN
§63.1063(a)(2)(vii)
10. Is the cap on each unslotted guidepole closed, except when guaging the DY DN/A DN
liquid level or taking liquid samples? §63.1063(b)(5)
11. Does each slotted guide pole have either of the following: (1) a pole wiper DY DN/A DN
and pole float, or (2) a pole wiper and pole sleeve?b §63.1063(a)(2)(viii)
12. Does each sample well have either a gasketed cover or a slit fabric seal or DY DN/A DN
similar device that
§63.1063(a)(2)(v)
similar device that covers at least 90 percent of the area of the opening ?b
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-2. (continued)
III. Note All Deficiencies
IFR = internal floating roof.
a If the IFR has a vapor-mounted seal as of April 4, 2002, the requirement for a liquid-mounted seal,
mechanical/metallic shoe seal, or a secondary seal is not required until the next time the storage tank is
emptied and degassed or December 11, 2013, whichever is earlier. §63.1063(a)(l)(ii)(D)
b If these requirements were not met for a floating roof in place as of April 4, 2002, then this requirement
does not apply until the earlier of the following dates: (1) the next time the storage tank is emptied and
degassed, or (2) no later than December 11, 2013. §63.1063(a)(2)(ix)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-3. Compliance Checklist for Storage Tanks Equipped with a Control Device
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement.
Note: Use this checklist in addition to the checklists in Tables 7-1 and 7-2 for the closed vent system
and the applicable checklist from Tables 7-3 through 7-12 for the type of control device that is
used to reduce emissions from the storage tank.
Identification of Storage Tank(s):
I. Review of Records
1. Does the facility keep all of the following records of periods of planned routine
maintenance for the control device: §63.998(d)(2)(ii)
(a) Time of day and date when each period of planned routine maintenance starts? D Y D N
(b) Time of day and date when each period of planned routine maintenance ends? DY DN
(c) Description of the type of maintenance performed? D Y D N
2. Do both of the following occur each time the facility has periods of planned routine
maintenance that exceed 240 hr/yr: §63.8010(c)
(a) The facility submitted an application to the Administrator requesting approval of
an extension to no more than 360 hr/yr that contained both of the following:
• An explanation of why the extension is needed? DY DN
• A statement affirming that no material will be added to the storage tank D Y D N
between the time the 240 hr limit is exceeded and the date the control device is
returned to service?
(b) The application was submitted at least 60 days before the 240 hr/yr limit is D Y D N
exceeded?
3. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-4. Compliance Checklist for Storage Tanks Using Vapor Balancing
Note: Use this checklist when emissions from a storage tank are vapor balanced to the tank truck or
railcar that delivered material to the storage tank. A "yes" response to a question in this checklist
means compliance with that requirement, and a "no" response means noncompliance with the
requirement. If a question is not applicable, check the "N/A" box.
Identification of Storage Tank(s):
I. Review of Records
1. Does the facility have records that the tank trucks and/or railcars from which D Y D N
the storage tank is filled meet U.S. DOT pressure requirements in 49 CFR
part 180 or 173.31, respectively? §63.1253(f)(2) as referenced from
§63.8010(d)
2. Does the facility have a record of the pressure relief vent setting? DY DN
§63.1253(f)(5) as referenced from §63.8010(d)
3. If the setting in "2" is less than 2.5 psig, did the facility provide rationale in D Y D N/A D N
the notification of compliance status report explaining why the lower value is
sufficient to prevent breathing losses at all times? §63.8010(d)(2)
4. Does the facility have written certification from facilities that reload and/or D Y D N
clean the tank trucks and railcars that they will either reduce the HAP content
of the displaced vapor by >95 percent (and meet the compliance
requirements in subpart FFFF) or vapor balance to the tank from which the
tank truck or railcar is loaded? §63.1253(f)(7)(i) as referenced from
§63.8010(d)
5. For each leak detected during quarterly monitoring, does the facility have all
of the following records: §§63.1253(f)(5)(iii) and 63.1255(g)(4) as
referenced from §63.8010(d)
(a) The instrument? DY D N/A DN
(b) The equipment identification number? D Y D N/A D N
(c) The operator name, initials, or identification number? D Y D N/A D N
(d) Date the leak was detected? DY DN/A DN
(e) Date of first repair attempt? DY DN/A DN
(f) Date of successful repair? DY DN/A DN
(g) Maximum instrument reading measured by Method 21 after the leak is D Y D N/A D N
successfully repaired or determined to be nonrepairable?
6. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 3
Table 3-4. (continued)
II. Visual Inspections
1. Is there a pressure relief device on the storage tank, and does the pressure relief setting D Y D N
match the value specified in the notification of compliance status report?
III. Note All Deficiencies
U.S. DOT = U.S. Department of Transportation.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Section 4
Requirements for Equipment Leaks
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 4
I Use this flowchart for all equipment used in
coating manufacturing operations.1
V_
Does the equipment
either contain or contact a
non-process fluid (e.g., part of a
heating and cooling system that
does not combine fluid
with process
materials}?
Is the
equipment in vacuum
service?
Is the
equipment in organic
HAP service (i.e., is the fluid
that is in contact with a piece of
equipment > 5% organic
HAP by weight}?
The equipment Is exempt
from the requirements
for equipment leaks in
subpart HHHHH.
( Continue at (A)
1 Equipment consists of pumps, compressors, agitators, pressure relief devices, sampling connection
systems, open-ended lines, valves, connectors, and instrumentation systems.
2 Equipment is presumed to be In organic HAP service unless you demonstrate that it is not by following the
procedures in §63.180rdJ.
Figure 4-1. Flowchart of applicability and control requirements for equipment leaks.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 4
Is the
equipment in organic
HAP service
< 300 hr/yr?
Is the
equipment part
of an existing affected source
under subpart
HHHHH?
The equipment is
exempt from
emission control
requirements if its
identity (by list,
location, or other
method) is recorded.
Comply with the requirements in §63.424(a)
through (d> and |63.428(e), (f), and (hH4),
except as specified in §63,8015(b).
Note: These provisions require monthly
sensory monitoring of all equipment.
Comply with the requirements of 40 CFR
part 63, subpart TT.
Note: Subpart TT requires both instrument
and sensory monitoring.
Comply with the requirements of 40 CFR
part 63, subpart UU, except as specified in
§63.8015(c) and (d).
Note: Subpart UU requires both instrument
and sensory monitoring similar to subpart
TT, except instrument monitoring is
required for connectors and the leak
definitions for pumps and vatves are lower.
or
or
Figure 4-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-1. Compliance Checklist for Equipment Leaks Monitored
by Monthly Sensory Observations
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If a question is not applicable, check
the "N/A" box.
I. Review of Records
1. Does the facility have a log book that contains a list, summary description, D Y D N
or diagram showing the location of all equipment in organic HAP service?
§63.424(b)
2. Do records indicate that all equipment in organic HAP service is inspected D Y D N
monthly? §63.424(a) as referenced from Table 3 to subpartHHHHH
Note: Inspections are not required for equipment in service < 300 hr/yr in
vacuum service, or contacting nonprocess fluids. §63.8015(b)(4).
3. Is all of the following information recorded in the log book for each liquid
or vapor leak that is detected? §63.428(e) as referenced from Table 3 to
subpartHHHHH
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
4. Are
Equipment type and identification number?
Indication of whether the leak is liquid or vapor?
Detection method (i.e., sight, sound, or smell)?
Date leak was detected?
Date of each attempt to repair the leak?
Repair methods applied in each repair attempt?
All of the following information if the leak was not repaired within 15
calendar days after it was detected:
• Reason for the delay?
• Expected date of successful repair?
Date of successful repair?
all records kept for at least 5 years?
DY
DY
DY
DY
DY
DY
D Y D N/A
D Y D N/A
DY
DY
DN
DN
DN
DN
DN
DN
DN
DN
DN
DN
II. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-1. (continued)
I. Review of Records
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-2. Compliance Checklist for the LDAR Program in Subpart TT for Equipment Leaks
Note: Use this checklist to demonstrate compliance with the basic LDAR program requirements for
each type of equipment as specified in 40 CFR part 63, subpart TT. See the checklist in Table 4-
5 for enclosed process units with equipment leak emissions routed through a closed-vent system
to a control device in accordance with §63.1016. A "yes" response to a question in this checklist
means compliance with that requirement, and a "no" response means noncompliance with the
requirement. If a question is not applicable, check the "N/A" box.
I. Review of Records
1. Does the facility have the following equipment identification records as an
alternative to physically tagging each piece of equipment:
(a) General identification of equipment that is subject to subpart HHHHH DY DN/A DN
(e.g., on a plant site plan, in log entries, designation of process unit or
affected source boundaries, etc.)? §§63.1003(a) and 63.1017(b)(l)
(b) Specific identification of connectors (either individually or the total D Y D N/A D N
number of connectors as a group in a designated area)?
§§63.1003(b)(l) and 63.1017(b)(l)
Note: Inaccessible, ceramic, or ceramic-lined connectors are exempt
from this recordkeeping requirement.
(c) Specific identification of pumps in light liquid service, agitators, D Y D N/A D N
pressure relief devices in gas and vapor service, and compressors from
which leaks are routed to a process, a fuel gas system, or through a
closed-vent system to a control device? §§63.1003(b)(2) and
63.1017(b)(l)
Note: Questions 13 and 14 are the only other questions in this
checklist (Table 4-2) that apply to this equipment if emissions are
routed to a control device. Only question 14 applies if emissions are
routed to a process or fuel gas system.
(d) Specific identification of pressure relief devices that are equipped with DY DN/A DN
rupture disks? §§63.1003(b)(3) and 63.1017(b)(l)
(e) Specific identification of instrumentation systems? §§63.1003(b)(4) DY D N/A DN
and63.1017(b)(l)
(f) Specific identification (either by list, location, or other method) of D Y D N/A D N
equipment in organic HAP service less than 300 hours per calendar
year within the affected source? §§63.1003(b)(5) and 63.1017(b)(l)
(g) Identification of equipment designated as unsafe-to-monitor or DY D N/A DN
difficult-to-monitor? §63.1003(c)(3)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-2. (continued)
I. Review of Records
2. If the facility has designated any valves, pumps, connectors, and/or agitators D Y D N/A D N
as unsafe to monitor, do they have a written plan describing the actual
monitoring frequency that will be used (but not more frequently than would
otherwise be required) and stating that any such equipment that is found to
be leaking will be repaired following the same procedures as for any other
leaking equipment? §§63.1003(c)(5)(i) and 63.1017(b)(2)
Note: No other records described in this checklist (i.e., Table 4-2) apply to
equipment that is designated as unsafe to monitor.
3. If the facility has designated any valves and/or agitators as difficult to D Y D N/A D N
monitor, do they have a written plan describing the actual monitoring
frequency that will be used (at least once per year) and stating that any such
equipment that is found to be leaking will be repaired following the same
procedures as for any other leaking equipment? §§63.1003(c)(5)(ii) and
63.1017 (b) (2)
Note: No other records described in this checklist (i.e., Table 4-2) apply to
equipment that is designated as difficult to monitor.
4. If the facility has designated any connectors as unsafe to repair, do records D Y D N/A D N
identify such connectors and explain why the connectors are unsafe to
repair? §§63.1003(d)(2) and 63.1017(b)(3)
5. If the facility has designated any compressors as operating with an DY D N/A DN
instrument reading of less than 500 ppm above background, do records
identify such compressors? §§63.1003(e)(3) and 63.1017(b)(4)
6. If the facility has designated any valves as operating with no detectable D Y D N/A D N
emissions (i.e., they have no external actuating mechanism and operate with
emissions less than 500 ppm above background), do they have all of the
following records: §§63.1006(e) (4) (i) and 63.1017(c) (1)
(a) All of the following compliance tests:
• Initial compliance test (upon designation emissions are <500 ppm D Y D N/A D N
above background?
• Annual compliance tests? D Y D N/A D N
Any other tests requested by the Administrator? D Y D N/A D N
(b) All of the following information for each compliance test:
Records of the test dates? DY DN/A DN
• The background level measured during each test? D Y D N/A D N
• Maximum instrument reading measured during each test? D Y D N/A D N
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-2. (continued)
I. Review of Records
7. When leaks are detected by instrument monitoring (for valves, pumps,
connectors, agitators, pressure relief devices, and compressors) or by
sensory monitoring (for pumps and agitators), does the facility maintain all
of the following records: §§63.1004(e)(2), 63.1005(e), and 63.1017(b)(5)
and (6)
Note: Although the rule does not explicitly require identification of leaking
equipment, the records must be sufficiently specific to allow an inspector to
determine compliance with the equipment leak repair requirements.
(a) The date of the first attempt to repair the leak? DY DN/A DN
(b) The date of successful repair of the leak? DY DN/A DN
(c) The maximum instrument reading measured by Method 21 at the time D Y D N/A D N
the leak was repaired or determined to be nonrepairable
(d) The reason for the delay if the leak was not repaired within 15 calendar DY DN/A DN
days after the leak was detected?
Note: Section 63.1005(c) specifies conditions under which delay of
repair is allowed.
Note: If delay of repair was caused by depletion of stocked parts, the
records must also document that the spare parts were sufficiently
stocked on-site before depletion and the reason for depletion.
(e) The dates of process unit (or affected source) shutdowns that occurred DY DN/A DN
while the equipment was unrepaired?
8. If complying with the skip period alternative for valves in gas and vapor
service or in light liquid service, does the facility keep records of both of the
following: §§63.1006(b)(6)(iv) and 63.1017(c)(l)
(a) The monitoring schedule? D Y D N/A D N
(b) Percent of valves found leaking during each monitoring period? DY D N/A DN
9. For pumps in light liquid service, does the facility keep all of the following
records:
(a) The occurrence and dates of weekly visual inspections for leaks? D Y D N/A D N
§§63.1007(b)(3) and (e)(l)(v) and 63.1017(c)(2) ft) and (ii)
Note: These inspections are not required for pumps with no external
shaft. §63.1007(e)(2)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-2. (continued)
I. Review of Records
(b) All of the following records for pumps equipped with a dual
mechanical seal system that includes a barrier fluid system:
§§63.100 7(e) (1) (i) and 63.1017(c) (2) (Hi)
• The design criteria related to the presence and frequency of drips D Y D N/A D N
that indicates failure of the seal system, the barrier fluid system, or
both?
• An explanation of the design criteria; any changes to these design D Y D N/A D N
criteria; and the reasons for any changes?
10. For agitators in gas and vapor service or in light liquid service, does the
facility maintain all of the following records:
(a) The occurrence and dates of weekly visual inspections for leaks? D Y D N/A D N
§§63.1009(b) (3) and 63.1017(c) (4) (i)
Note: According to §63.1009(e)(2), these inspections are not required
for agitators with no external shaft.
Note: Although §63.1009(e)(l)(iv) does not explicitly require records
documenting the inspection for agitators with dual mechanical seals, a
record would be required in order to demonstrate compliance (similar
to the requirement in §63.1007(e)(l)(v).
(b) For each agitator equipped with a dual mechanical seal system that D Y D N/A D N
includes a barrier fluid system, the design criteria related to the
presence and frequency of drips that indicates failure of the seal
system, the barrier fluid system, or both; an explanation of the design
criteria; any changes to the design criteria; and the reasons for any
changes? §§63.1009(e)(l)(vi)(B) and 63.1017(c)(4)(ii)
11. For pressure relief devices in gas and vapor service, does the facility
maintain records of the following information for monitoring within 5 days
after a pressure release ? §§63.1011 (c) (3) and 63.1017(c) (5)
Note: These requirements do not apply to pressure relief devices that are
equipped with a rupture disk upstream of the pressure relief device.
(a) Date the monitoring was conducted? D Y D N/A D N
(b) Background level measured, if the instrument reading was adjusted for D Y D N/A D N
background?
(c) Maximum instrument reading measured? D Y D N/A D N
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-2. (continued)
I. Review of Records
12. For each compressor that is equipped with a seal system that includes a
barrier fluid system, does the facility maintain records of either of the
following:
(a) the design criteria related to the presence and frequency of drips that DY DN/A DN
indicates failure of the seal system, the barrier fluid system, or both; an
explanation of the design criteria; any changes to the design criteria;
and the reasons for any changes, or §§63.1012(d)(2) and
63.1017 (c) (6) (i)
(b) If the facility complies with the alternative compressor standard (i.e.,
the compressor is designated as operating with an instrument reading
of less than 500 parts per million above background), all of the
following information for each compliance test: §§63.1012(f)(2) and
63.1017(c)(6)(n)
• Date of each compliance test? DY DN/A DN
• Background level measured? D Y D N/A D N
• Maximum instrument reading? D Y D N/A D N
13. If emissions from pumps, agitators, pressure relief devices, or compressors
are routed through a closed-vent system to a control device, are records
maintained of all of the following information: §63.998(d)(4) as referenced
from §§63.1015(b), 63.982(b) and (c)(3), and 63.986(c)
(a) Detailed schematics, design specifications of the control device, and D Y D N/A D N
piping and instrumentation diagrams?
(b) The dates and descriptions of any changes in the design specifications? D Y D N/A D N
(c) A description of the parameter or parameters monitored to ensure that D Y D N/A D N
the control device is operated and maintained as designed, and a
description of why each parameter was selected for monitoring?
(d) Dates and durations when the monitored parameter values indicate the D Y D N/A D N
closed-vent system and control device(s) were not being operated as
designed?
(e) Dates and durations when the monitoring device was inoperative? D Y D N/A D N
(f) Dates and durations of startup and shutdown of the control device? DY DN/A DN
14. Are all records kept for at least 5 years? §63.10(b)(l) D Y D N
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-2. (continued)
II. Visual Inspections
1. Are visible, weatherproof identifications attached to all equipment that has D Y D N/A D N
been determined to be leaking and has not yet been repaired, including
equipment determined to be nonrepairable? §63.1004(e)(l)
2. Are visible, weatherproof identifications attached to all valves that were DY DN/A DN
repaired less than 3 months ago? §63.1005(c)(l)
3. Is a rupture disk in place upstream of each pressure relief device for which the D Y D N/A D N
facility claims exemption from the otherwise required monitoring?
§63.1011 (e)
4. Are sampling connection systems equipped with a closed-purge, closed-loop, D Y D N/A D N
or closed-vent system? §63.1013(b)
Note: In-situ sampling systems are exempt from this requirement.
§63.1013(d)
5. Are open-ended valves and lines equipped with caps, blind flanges, plugs, or a D Y D N/A D N
second valve? §63.1014(b)(l)
Note: Open-ended valves and lines in an emergency shutdown system that are
designed to open automatically in the event of a process upset are exempt
from this requirement. Open-ended lines and valves containing materials that
would autocatalytically polymerize or would present an explosion, serious
overpressure, or other safety hazard are also exempt.
6. If the facility indicates equipment is vented to a control device, is a closed- D Y D N/A D N
vent system in place?
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. Compliance Checklist for the LDAR Program in Subpart UU for Equipment Leaks
Note: Use this checklist to demonstrate compliance with the basic LDAR program requirements for
each type of equipment as specified in 40 CFR part 63, subpart UU. See checklists in Tables 4-4
and 4-5 for equipment that is pressure tested in accordance with §63.1036(b) or process units are
enclosed with emissions routed to a control device in accordance with §63.1037, respectively. A
"yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If a question is not applicable, check the
"N/A" box.
I. Review of Records
1. Does the facility have the following equipment identification records as an
alternative to physically tagging each piece of equipment:
(a) General identification of equipment that is subject to subpart HHHHH D Y D N/A D N
(e.g., on a plant site plan, in log entries, designation of process unit or
affected source boundaries, etc.)? §§63.1022(a) and 63.1038(b)(l)
(b) Specific identification of connectors (either individually or the total DY D N/A DN
number of connectors as a group in a designated area)?
§§63.1022(b)(l) and 63.1038(b)(l)
Note: Inaccessible, ceramic, or ceramic-lined connectors are exempt
from this recordkeeping requirement.
(c) Specific identification of pumps in light liquid service, agitators, D Y D N/A D N
pressure relief devices in gas and vapor service, and compressors from
which leaks are routed to a process, a fuel gas system, or through a
closed-vent system to a control device? §§63.1022(b)(2) and
63.1038(b)(l)
Note: Questions 15 and 17 are the only other questions in this
checklist (i.e., Table 4-3) that apply to this equipment if emissions are
routed through a closed-vent system to a control device. Only question
17 applies if emissions are routed to a process or fuel gas system.
(d) Specific identification of pressure relief devices that are equipped with DY DN/A DN
rupture disks? §§63.1022(b)(3) and 63.1038(b)(l)
(e) Specific identification of instrumentation systems? §§63.l022(b)(4) DY D N/A DN
and63.1038(b)(l)
(f) Specific identification (either by list, location, or other method) of D Y D N/A D N
equipment in organic HAP service less than 300 hours per calendar
year within the affected source? §§63.1022(b)(5) and 63.1038(b)(l)
(g) Identification of equipment designated as unsafe-to-monitor or DY D N/A DN
difficult-to-monitor? §63.1022(c) (3)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
I. Review of Records
2. If the facility has designated any valves, pumps, connectors, and/or agitators D Y D N/A D N
as unsafe to monitor, do they have a written plan describing the actual
monitoring frequency that will be used (but not more frequently than would
otherwise be required) and stating that any such equipment that is found to be
leaking will be repaired following the same procedures as for any other
leaking equipment? §§63.1022(c)(4)(i) and 63.10 38 (b) (2)
Note: No other records described in this checklist (i.e., Table 4-3) apply to
equipment that is designated as unsafe to monitor.
3. If the facility has designated any valves and/or agitators as difficult to D Y D N/A D N
monitor, do they have a written plan describing the actual monitoring
frequency that will be used (at least once per year) and stating that any such
equipment that is found to be leaking will be repaired following the same
procedures as for any other leaking equipment? §§63.1022(c)(4)(ii) and
63.10 38 (b) (2)
Note: No other records described in this checklist (i.e., Table 4-3) apply to
equipment that is designated as difficult to monitor.
4. If the facility has designated any connectors as unsafe to repair, do records D Y D N/A D N
identify such connectors and explain why the connectors are unsafe to repair?
§§63.1022(d)(2) and 63.1038(b)(3)
5. If the facility has designated any compressors as operating with an instrument DY D N/A DN
reading of less than 500 ppm above background, do records identify such
compressors? §§63.1022(e) and 63.1038(b) (4)
6. If the facility has determined that any equipment is in heavy liquid service, do D Y D N/A D N
they have records of the information, data, and analyses used to make such
determinations? §§63.1022(f)(l) and 63.1038(b)(5)
7. When leaks are detected by instrument monitoring (for valves, pumps,
connectors, agitators, pressure relief devices, and compressors) or by sensory
monitoring (for pumps and agitators), does the facility maintain all of the
following records: §§63.1023(e)(2), 63.1024(f), and 63.1038(b)(6) and (7)
Note: Although the rule does not explicitly require identification of leaking
equipment, the records must be sufficiently specific to allow an inspector to
determine compliance with the equipment leak repair requirements.
(a) The date of the first attempt to repair the leak? DY DN/A DN
(b) The date of successful repair of the leak? DY DN/A DN
(c) The maximum instrument reading measured by Method 21 at the time DY DN/A DN
the leak was repaired or determined to be nonrepairable
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
I. Review of Records
(d) The reason for the delay if the leak was not repaired within 15 calendar D Y D N/A D N
days after the leak was detected?
Note: Section 63.1024(d) specifies conditions under which delay of
repair is allowed.
Note: If delay of repair was caused by depletion of stocked parts, the
records must also document that the spare parts were sufficiently stocked
on-site before depletion and the reason for depletion.
(e) The dates of process unit (or affected source) shutdowns that occurred DY DN/A DN
while the equipment was unrepaired?
8. For valves in gas and vapor service or in light liquid service, does the facility
keep records of both of the following, as applicable:
(a) The monitoring schedule? §§63.1025(b)(3)(vi) and 63.1038(c)(l)(i) D Y D N/A D N
(b) All of the following information for valve subgroups: §63.1025(b)(4)(iv)
and63.1038(c)(l)(ii)
Note: Subgroups for a process unit or affected source are allowed only
if less than 2 percent of the total number of valves in all subgroups are
determined to be leaking.
• Which valves are assigned to each subgroup? D Y D N/A D N
• Monitoring results and calculations made for each subgroup in each D Y D N/A D N
monitoring period (i.e., the total number of valves monitored, the
number found leaking, the number of nonrepairable valves, the
percent leaking in the subgroup, and the percent leaking for
determining the subsequent monitoring frequency for the subgroup as
specified in §63.1025(c)(l)(ii) and (2))?
• Which, if any, valves have been reassigned from one subgroup to DY D N/A DN
another, the last monitoring result prior to a reassignment, and the
date when the reassignment was made?
• The results of the semiannual overall performance calculations? D Y D N/A D N
9. For pumps in light liquid service, does the facility keep all of the following
records:
(a) The occurrence and dates of weekly visual inspections for leaks? D Y D N/A D N
§§63.1026(b)(4) and (e)(l)(v) and 63.1038(c)(2)(i) and (ii)
Note: These inspections are not required for pumps with no external
shaft.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
I. Review of Records
(b) All of the following records for pumps equipped with a dual mechanical
seal system that includes a barrier fluid system: §§63.1026(e)(l)(i) and
63.1038(c)(2)(iii)
• The design criteria related to the presence and frequency of drips that DY DN/A DN
indicates failure of the seal system, the barrier fluid system, or both?
• An explanation of the design criteria; any changes to these design D Y D N/A D N
criteria; and the reasons for any changes?
10. For connectors in gas and vapor service or in light liquid service, does the DY D N/A DN
facility maintain a record of the monitoring schedule (i.e., the start date and
end date of each monitoring period)? §§63.1027(b)(3)(v) and 63.1038(c)(3)
Note: The monitoring and recordkeeping requirements do not apply to
inaccessible, ceramic, or ceramic-lined connectors.
11. For agitators in gas and vapor service or in light liquid service, does the
facility maintain all of the following records:
(a) The occurrence and dates of weekly visual inspections for leaks? D Y D N/A D N
§§63.1028(c) (3) and 63.1038(c) (4) (i)
Note: According to §63.1028(e)(2), these inspections are not required
for agitators with no external shaft.
Note: Although §63.1028(e)(l)(iv) does not explicitly require records
documenting the inspection for agitators with dual mechanical seals, a
record would be required in order to demonstrate compliance (similar to
the requirement in §63.1026(e)(l)(v).
(b) For each agitator equipped with a dual mechanical seal system that D Y D N/A D N
includes a barrier fluid system, the design criteria related to the presence
and frequency of drips that indicates failure of the seal system, the
barrier fluid system, or both; an explanation of the design criteria; any
changes to the design criteria; and the reasons for any changes?
§§63.1028(e) (1) (vi) (B) and 63.1038(c) (4) (ii)
12. For pressure relief devices in gas and vapor service, does the facility maintain
records of the following information for monitoring within 5 days after a
pressure release? §§63.1030 (c)(3) and 63.1038(c)(5)
Note: These requirements do not apply to pressure relief devices that are
equipped with a rupture disk upstream of the pressure relief device.
(a) Date the monitoring was conducted? D Y D N/A D N
(b) Background level measured? DY DN/A DN
(c) Maximum instrument reading measured? D Y D N/A D N
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
I. Review of Records
13. For each compressor that is equipped with a seal system that includes a barrier
fluid system, does the facility maintain records of either of the following:
(a) the design criteria related to the presence and frequency of drips that D Y
indicates failure of the seal system, the barrier fluid system, or both; an
explanation of the design criteria; any changes to the design criteria; and
the reasons for any changes, or §§63.1031(d)(2) and 63.1038(c)(6)(i)
(b) If the facility complies with the alternative compressor standard (i.e., the
compressor is designated as operating with an instrument reading of less
than 500 parts per million above background), all of the following
information for each compliance test: §§63.1031(f)(2) and
63.1038(c)(6)(ii)
• Date of each compliance test? DY
• Background level measured? D Y
• Maximum instrument reading? D Y
14. If the facility has implemented a quality improvement program for pumps, are
all of the following records maintained:
(a) All of the following data for each pump: §§63.1035(d)(2) and
63.1038(c)(7)(i)
• Pump type? D Y
• Pump manufacturer? D Y
• Seal type? D Y
• Seal manufacturer? D Y
• Pump design? D Y
• Materials of construction? DY
• Barrier fluid or packing material, if applicable? D Y
• Year installed? DY
• Service characteristics of the pumped stream? D Y
• Maximum instrument readings observed in each monitoring D Y
observation before repair, response factor for the stream (if
appropriate), instrument model number, and date of observation?
• If a leak was detected, the repair methods used and the instrument D Y
readings after repair?
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DN
DN
DN
DN
DN
DN
DN
DN
DN
DN
DN
DN
DN
DN
DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
I. Review of Records
• If the data will be analyzed as part of a larger analysis program D Y D N/A D N
involving data from other plants or other types of process units or
affected sources, a description of any maintenance or quality
assurance programs used in the process unit or affected source that are
intended to improve emission performance?
(b) A list identifying areas associated with poorer than average performance D Y D N/A D N
and the associated service characteristics of the stream, the operating
conditions and maintenance practices? §§63.1035(e)(3)(i) and
6 3.10 38 (c) (7) (v)
(c) All of the following information for each trial evaluation program:
§§63.1035(d)(6)(i), (d)(6)(iii), (d)(6)(vi), (e)(3)(ii), and (e)(3)(Hi); and
63.1038(c)(7)(ii) and (in)
Note: Section 63.1035(d)(6) describes the situations under which a trial
evaluation program must be conducted.
• A list of the candidate superior performing pump seal designs or DY D N/A DN
technologies to be evaluated?
• The reasons for rejecting any specific candidate superior emission D Y D N/A D N
performing pump technologies from performance trials?
• The stages for evaluating the candidate pump designs or pump seal D Y D N/A D N
technologies?
• The anticipated time period necessary to test the applicability of D Y D N/A D N
candidate designs or technologies?
• The frequency of monitoring or inspection of the equipment? DY D N/A DN
• The range of operating conditions over which the component will be D Y D N/A D N
evaluated?
• The beginning date and actual duration of performance trials for each DY DN/A DN
candidate superior emission performing technology?
• Conclusions regarding the emission performance and the appropriate D Y D N/A D N
operating conditions and services for the trial pump seal technologies
or pumps?
• If all alternatives are judged to be technically infeasible or incapable D Y D N/A D N
of reducing emissions, an engineering evaluation of each alternative
documenting the physical, chemical, or engineering basis for the
judgment?
(d) All of the following records of ongoing activities during the QIP:
• The rolling average percent leaking pumps? §§63.1035(e)(l)(i) and DY D N/A DN
63.1038(c)(7)(v)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
I. Review of Records
• Documentation of all inspections of pumps or pump seals that DY D N/A DN
exhibited frequent seal failures and were removed from the process
unit or affected source due to leaks? §§63.1035(d)(4) and (e)(l)(ii)
and63.1038(c)(7)(v)
• The beginning and end dates for the QIP? §§63.1035(e) (1) (Hi) and D Y D N/A D N
6 3.10 38 (c) (7) (v)
• If a leak is not repaired within 15 calendar days after its discovery, the D Y D N/A D N
reason for the delay and the expected date of successful repair?
§§63.1035(e) (2) and 63.1038(c) (7) (v)
(e) Quality assurance program documentation, including records indicating D Y D N/A D N
that all pumps replaced or modified during the period of the QIP are in
compliance with the quality assurance program? §§63.1035(d)(7) and
(e)(4) and 63.1038(c)(7)(iv) and (v)
(f) The following records related to the pump or pump seal replacement
requirements:
Note: The number of years after starting the QIP when replacements
must begin is specified in §63.1035(d)(8).
• Records documenting compliance with the 20 percent or greater D Y D N/A D N
annual replacement rate? §§63.1035(e)(5) and 63.1038(c)(7)(v)
• If complying with the schedule for corporations with fewer than 100 DY D N/A DN
employees, information documenting the number of employees,
including employees providing professional and technical contracted
services? §§63.1035(e)(6) and 63.1038(c)(7)(v)
15. If emissions from pumps, agitators, pressure relief devices, or compressors are
routed through a closed-vent system to a control device, are records
maintained of all of the following information: §63.998(d)(4) as referenced
from §§63.1034(b), 63.982(b) and (c)(3), and 63.986(c)
(a) Detailed schematics, design specifications of the control device, and D Y D N/A D N
piping and instrumentation diagrams?
(b) The dates and descriptions of any changes in the design specifications? D Y D N/A D N
(c) A description of the parameter or parameters monitored to ensure that the DY DN/A DN
control device is operated and maintained as designed, and a description
of why each parameter was selected for monitoring?
(d) Dates and durations when the monitored parameter values indicate the D Y D N/A D N
closed-vent system and control device(s) were not being operated as
designed?
(e) Dates and durations when the monitoring device was inoperative? D Y D N/A D N
(f) Dates and durations of startup and shutdown of the control device? DY DN/A DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
I. Review of Records
16. If the facility complies with the alternative equipment monitoring schedule for
batch processes as specified in §63.1036(c), are records maintained of all of
the following information: §§63.1036(d) and 63.1038(c)(8)(ii)
Note: All other items in this checklist also apply when the facility complies
with this alternative.
(a) A list of equipment added to the batch product process since the last DY DN/A DN
monitoring?
(b) For any components for which the facility adjusts the monitoring D Y D N/A D N
frequency in accordance with this alternative, documentation
demonstrating the proportion of time during the calendar year that the
equipment is in use?
(c) The following information related to monitoring any new equipment
added to a reconfigured batch process:
• Date of the monitoring? DY D N/A DN
Note: The monitoring must be conducted within 30 days of startup of
the process.
• Either the actual monitoring results if leaks were found or a statement D Y D N/A D N
that the monitoring was conducted if no leaks were found?
17. Are all records kept for at least 5 years? §63.W(b)(l) D Y D N
Note: Some records must be kept longer. For example, if connectors are
monitored once every 8 years, leak repair records must be kept 5 years
beyond the date of their last use. §63.1023(e)(2)
II. Visual Inspections
1. Are visible, weatherproof identifications attached to all equipment that has D Y D N/A D N
been determined to be leaking and has not yet been repaired, including
equipment determined to be nonrepairable? §63.1023(e)(l)
2. Are visible, weatherproof identifications attached to all valves and connectors DY DN/A DN
that were repaired less than 3 months ago? §63.1024(c)(l)
3. Is a rupture disk in place upstream of each pressure relief device for which the D Y D N/A D N
facility claims exemption from the otherwise required monitoring?
§63.1030(e)
4. Are sampling connection systems equipped with a closed-purge, closed-loop, D Y D N/A D N
or closed-vent system? §63.1032(b)
Note: In-situ sampling systems are exempt from this requirement.
§63.l032(d)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-3. (continued)
II. Visual Inspections
5. Are open-ended valves and lines equipped with caps, blind flanges, plugs, or a D Y D N/A D N
second valve? §63.1033(b)
Note: Open-ended valves and lines in an emergency shutdown system that are
designed to open automatically in the event of a process upset are exempt
from this requirement. Open-ended lines and valves containing materials that
would autocatalytically polymerize or would present an explosion, serious
overpressure, or other safety hazard are also exempt.
6. If the facility indicates equipment is vented to a control device, is a closed- D Y D N/A D N
vent system in place?
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-4. Compliance Checklist for Pressure Testing to Identify Equipment Leaks
Note: Use this checklist for each process that is pressure tested as specified in §63.1036(b). A "yes"
response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If a question is not applicable, check the
"N/A" box.
I. Review of Records §§63.1036(b)(7) and 63.1038(c)(8)(i)
1. Do records identify each product produced during the calendar year (or codes D Y D N/A D N
for those products)?
2. Is the process equipment either physically tagged, or is it identified on a plant DY D N/A DN
site plan, in log entries, or by some other method?
3. Is all of the following information recorded for each pressure test:
(a) Date of the test? DY DN/A DN
(b) The test pressure? DY DN/A DN
(c) The observed pressure drop, for a gas pressure/vacuum test? D Y D N/A D N
(d) Documentation of any visible, audible, or olfactory evidence of fluid D Y D N/A D N
loss, for a liquid pressure test?
4. Is all of the following information recorded anytime the process equipment
train does not pass two consecutive pressure tests:
Note: Section 63.1036(b)(7)(v) specifies that these records must be
maintained for only 2 years.
(a) The date of each pressure test? DY DN/A DN
(b) Repair methods applied in each attempt to repair the leak(s)? D Y D N/A D N
(c) All of the following information if repair is not completed within 30
calendar days after the second pressure test:
• Reason for the delay? DY DN/A DN
• Expected date for delivery of the replacement equipment? D Y D N/A D N
• Actual date of delivery of the replacement equipment? DY DN/A DN
(d) Date of successful repair? DY DN/A DN
5. Are all records kept for at least 5 years, except as noted above? §63.10(b)(l) DY DN/A DN
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Table 4-4. (continued)
II. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-5. Checklist for Determining Compliance with the Enclosed Process Alternative
for Equipment Leaks
Note: Use this checklist for each process or portion of a process that is enclosed and emissions from
equipment leaks are routed through a closed-vent system to a control device in accordance with
§63.1016 or §63.1037. A "yes" response to a question in this checklist means compliance with
that requirement, and a "no" response means noncompliance with the requirement. If a question
is not applicable, check the "N/A" box.
I. Review of Records
1. Does the facility have specific identification of equipment in enclosed process D Y D N/A D N
units from which equipment leaks are routed to a process, fuel gas system, or
through a closed-vent system to a control device? §63.1003(b)(2) or
§6 3.1022 (b) (2)
Note: No other records in this checklist (Table 4-5) apply if emissions are
routed to a process or fuel gas system.
2. Do records document all of the following information about the process unit
and the enclosure: §§63.103 7(b) and 63.1038(c) (9), or §§63.1016(b) and
63.1017(c)(7)
(a) Identification of the process unit and the organic HAP that it handles? DY DN/A DN
(b) A schematic of the process unit, enclosure, and closed-vent system? D Y D N/A D N
(c) A description of the system used to create a negative pressure in the DY DN/A DN
enclosure?
3. Do records document all of the following information, if emissions are routed
through a closed-vent system to a control device: §63.998(d)(4), as
referenced from §§63.10 37 (a) or 63.1016(a), 63.1034(b)(2) or 63.1015(b),
63.982(b) and (c)(3), and 63.986(c)
(a) Detailed schematics, design specifications of the control device, and D Y D N/A D N
piping and instrumentation diagrams?
(b) The dates and descriptions of any changes in the design specifications? DY DN/A DN
(c) A description of the parameter or parameters monitored to ensure that the DY DN/A DN
control device is operated and maintained as designed, and a description
of why each parameter was selected for monitoring?
(d) Dates and durations when the monitored parameter values indicate the D Y D N/A D N
closed-vent system and control device(s) were not being operated as
designed?
(e) Dates and durations when the monitoring device was inoperative? DY DN/A DN
(f) Dates and durations of startup and shutdowns of the control devices? DY DN/A DN
4. Are all records kept for at least 5 years? §63.10(b)(l) DY DN/A DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 4
Table 4-5. (continued)
II. Visual Inspections
1. Is the equipment enclosed, and is a closed-vent system in place? D Y D N
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 5
Section 5
Requirements for Wastewater and Heat Exchange Systems
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 5
Start
Do you
discard any liquid
streams from your
miscellaneous coating
manufacturing operations
that contain
water?
You have no
waste water streams
subject to subpart
HHHHH.
Yes
Is the
liquid stream
noncontact cooling
water?
Yes-
Noncontact cooling
water is not waste water
and is not subject to
subpart HHHHH.
You have a wastewater
stream that is subject to
subpart HHHHH.
Are you
designating the
wastewater stream as
Group 1?
Yes ^ Continue at (§)
Use the procedures in 63,144(b) and
the alternative test methods under
§63.8020(b)(2)(i) to establish PSHAP
and SHAP concentrations.1'2
( Continue at (A)
1 PSHAP means partially soluble HAP that are listed in Table 7 to subpart HHHHH.
! SHAP means soluble HAP that are listed in Table 8 to sybpart HHHHH.
Figure 5-1. Flowchart of applicability and control requirements for wastewater streams.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 5
Do
you have
an existing affected
source under subpart
HHHHH?
For this
wastewater stream
at your new affected source, is
the annual average concentration
of total PSHAP and SHAP
> 1,600 ppmw?
For this
wastewater stream
at your existing affected source, is
the annual average concentration
of total PSHAP and HAP
> 4,000 ppmw?
You have a Group 2
wastewater stream.
No control is
required.
Is the total
PSHAP and SHAP load in
the wastewater stream
> 750 Ib/yr?
You have a Group 1 wastewater
stream that must be controlled.
For any wastewater tank used to store the Group 1 wastewater stream, you must maintain a
fixed roof, which may have openings necessary for proper venting of the tank (e.g., a
pressure/vacuum vent or j-pipe vent).
9 .
\in the wastf
\^<50
1
Convey the wastewater stream using hard-piping
and treat the wastewater as a hazardous waste in
accordance with 40 CFR part 264, 265, or 266
either onsite or off site.
Yes-
Treat the wastewater in an enhanced
biological treatment system that is
located either onside or offsite.
Figure 5-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 5
Table 5-1. Compliance Checklist for Wastewater
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means non-compliance with the requirement. If a question is not applicable, check
the "N/A" box.
I. Review of Records (only applicable for treatment in an enhanced biological unit)
1. Do records indicate that the partially soluble HAP content of wastewater D Y D N
entering the enhanced biological treatment unit is < 50 ppmw? Table 4 to
subpartHHHHH
2. If the enhanced biological treatment unit is onsite, do records show that the
facility provided either of the following in their precompliance report?
§63.8020(c)
(a) Proposed operating limits, monitoring frequencies, and methods for
monitoring all of the following:
• Total suspended solids? DY DN/A DN
• Biological oxygen demand? D Y D N/A D N
• Biomass concentration? D Y D N/A D N
(b) A request to monitor other parameters along with a description of D Y D N/A D N
planned recordkeeping and reporting procedures?
3. If the enhanced biological treatment unit is onsite, does the facility keep D Y D N/A D N
records of the monitored parameters? §63.8020(c)
4. If Group 1 wastewater is shipped offsite for enhanced biological treatment, D Y D N/A D N
does the facility have written certification from the offsite facility that they
will comply with the requirements of subpart HHHHH? §63.8080(d)
5. Are records of monitored data, or certifications from offsite treatment DY DN/A DN
facilities, kept for at least 5 years? §63.10(b)(l)
II. Visual Inspections
1. For an onsite enhanced biological treatment unit, are monitoring devices in D Y D N/A D N
place and operating?
2. Are any wastewater tanks (prior to treatment or shipping offsite) equipped D Y D N/A D N
with a fixed roof? Table 4 to subpart HHHHH
3. If wastewater is treated as hazardous waste, is the wastewater conveyed onsite DY DN/A DN
using only hard-piping? Table 4 to subpartHHHHH
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 5
Table 5-1. (continued)
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 5
Table 5-2. Compliance Checklist for Heat Exchange Systems Requiring Leak Detection
Note: A "yes" response to a question in this checklist means compliance with that requirement, and
"no" responses means noncompliance with that requirement. If the requirement is not applicable,
check the "N/A" box.
I. Review of Records
1. Do records indicate that heat exchange systems are monitored for leaks by D Y D N D N/A
either of the following (provided they are not exempt from monitoring):
§63.104(b) and (c)
(a) Monitoring for the presence of one or more HAP or other representative
substances, or
(b) Monitoring using a surrogate indicator of leaks?
2. When monitoring of a surrogate indicator of heat exchange system leaks is
used, is a monitoring plan available that contains all of the following:
§63.104(c)(l)
(a) The procedures that will be used to detect leaks of process fluids into DY DN DN/A
cooling water?
(b) A description of the parameter(s) or condition(s) to be monitored? D Y D N D N/A
(c) An explanation of how the selected parameter(s) or condition(s) will D Y D N D N/A
reliably indicate the presence of a leak?
(d) The parameter level(s) or condition(s) that constitute a leak, including D Y D N D N/A
supporting data and calculations?
(e) The monitoring frequency (which must be no less frequent than monthly D Y D N D N/A
for the first 6 months and quarterly thereafter?
(f) The records that will be maintained? DY DN DN/A
3. If monitoring results indicate a leak is detected, are records of all of the
following available: §63.104(d)(l), (f)(l)(i), and (f)(l)(ii)
(a) Monitoring records identifying the leak? D Y D N D N/A
(b) Date the leak was detected? D Y D N D N/A
(c) If the results were determined to be due to a condition other than a leak, D Y D N D N/A
the basis for that determination?
4. If the results are confirmed to be a leak, are records of all of the following
available: §63.104(f)(l)(Hi) and (iv)
(a) Date(s) of efforts to repair the leak?
(b) The method or procedure used to confirm repair of the leak?
(c) Date the repair was confirmed?
D Y D N D N/A
D Y D N D N/A
D Y D N D N/A
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 5
Table 5-2. (continued)
I. Review of Records
5. If repair of a leak has been delayed, do records indicate either of the DY DN DN/A
following, along with a schedule for completing the repair as soon as
practical: §63.104(e)(2)(i) and (ii)
(a) The basis of a determination that a shutdown for repair would cause
greater emissions than the emissions likely to result from delaying repair,
or
(b) Evidence that the necessary parts or personnel were not available to make
the repair?
Note: Documentation is not necessary if the leaking equipment is isolated
from the coating manufacturing operations, or if a shutdown is scheduled
within the next 2 months after determination that a delay of repair is
necessary. §63.104(e) introductory text and (e)(l)
6. Are all records kept for at least 5 years? §63.lO(b)(l) D Y D N D N/A
II. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 6
Section 6
Requirements for Transfer Operations
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 6
Use this flowchart for each transfer
rack loading arm.
Do you use
the transfer rack loading
arm to load any liquid coating
products that contain organic HAP
into tank trucks or railcars (i.e.,
definition of "bulk
loading")?
You have no transfer operations
under subpart HHHHH,
Is the loading
arm part of an affected source
under another subpart of
40 CFR part 63?
This transfer rack loading arm is
not subject to subpart HHHHH.
Does the loading
arm load any liquid products
In addition to coating
products?
o—H Continue at
f Continue at (A
Figure 6-1. Flowchart of applicability and control requirements for transfer operations.
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 6
Can the
predominant use of the
transfer rack be
determined?'
The transfer rack
loading arm must
be assigned
to the
miscellaneous
coating
manufacturing
operations.
Is the
predominant use
of the transfer rack
loading arm associated with
miscellaneous coating
manufacturing
operations?
This transfer
rack loading arm
is not subject to
subpart HHHHH.
Do the bulk
loaded liquid coating
products contain
> 3,0 million gal
of HAP/yr?
Is the
weighted average
HAP partial pressure
of the bulk loaded liquid
coating products (i.e., those
that contain HAP)
>1Q.34kPa
> 1.5psia}?
You have Group 1 transfer operations that
must be controlled as specified in Table 5
to subpart HHHHH. Continue at (£)
Results of the initial determination of predominant use must be included in the notification of compliance
status report. You must redetertnlne the predominant use at Jeast oncfc every 5 years after the compliance
date.
Figure 6-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP
Section 6
Does ihe vent
stream from Ihe transfer
operation contain halogen
atoms in organic compounds at a
concentration > 20 ppmv (i.e.,
is ii a "halogenated
vent stream*'}?
-Yes-
or
Vent organic HAP emissions
through a closed-vent system
to a flare
2.3
Use a vapor balancing system designed and
operated to route collected organic HAP vapors to the
storage tank from which the liquid being loaded
originated or to another storage tank connected by a
common header,
or
Reduce total organic HAP emissions
by > 75 percent by weight by venting emissions
through a closed-vent system to any combination of
control devices, except a flare."1
or
Additional requirements apply if you
use a combustion device to control a
halogenated vent stream.
•or
Use a halogen reduction device
before the combustion device to
reduce the halogen atom mass
emission rate to £0.45 kg/hr.
Use a halogen reduction device after
the combustion device to reduce
emissions of hydrogen halide and
halogen HAP by >_ 95 percent by
weight or to £0.45 kg/hr.
A closed-vent system is subject to the compliance requirements In §63.983 of subpart S3.
A five Is subject to the compliance requirements in §63.11 (b) of subpart A (General Provisions).
Figure 6-1. (continued)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Section 7
Requirements for Closed-Vent Systems and Control Devices
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-1. Compliance Checklist for Bypass Line Provisions for Closed-Vent Systems
Note: Complete this checklist for each closed-vent system that contains a bypass line that could divert a
vent stream away from a control device to the atmosphere. A "yes" response to a question
indicates compliance with that requirement, and a "no" response indicates noncompliance with
the requirement. If a question is not applicable, check the "N/A" box.
Note: The items in this checklist do not apply to low leg drains, high point bleeds, analyzer vents, open-
ended valves or lines, and pressure relief valves needed for safety purposes.
I. Review of Records
1. Are all of the following records available for a bypass line that is equipped
with a flow indicator: §63.998(d)(l)(ii)(A)
(a) Hourly records of whether the flow indicator in the bypass line was
operating? DY D N/A DN
(b) Whether a diversion was detected at any time during each hour? D Y D N/A D N
(c) The times of all periods when the vent stream was diverted from the
control device? DY D N/A DN
(d) The times of all periods when the flow indicator was not operating? D Y D N/A D N
2. Are all of the following records available for a bypass line that is equipped
with a seal mechanism: §63.998(d)(l)(ii)(B)
(a) Occurrence of each monthly inspection of the seals or closure
mechanism? DY D N/A DN
(b) All periods when the seal mechanism was broken, the bypass line valve
position was changed, or the key to unlock the bypass line valve was
checked out? DY DN/A DN
II. Visual Inspection
1. Is a flow indicator is present at the entrance to any bypass line that could
divert the vent stream flow away from the control device to the atmosphere,
or are all bypass line valves sealed in a closed position (e.g., with a car seal
or lock-and-key configuration). D Y D N/A D N
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-1. (continued)
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-2. Compliance Checklist for Closed-Vent Systems
Note: Complete this checklist for each closed-vent system. A "yes" response to a question indicates
compliance with that requirement, and a "no" response indicates noncompliance with the
requirement. If a requirement is not applicable, check the "N/A" box.
Note: This checklist does not apply to closed-vent systems that are operated under negative pressure.
§63.983(a)
I. Review of Records
1. Are records kept that identify all parts of closed-vent systems that are
designated as either unsafe-to-inspect or difficult-to-inspect? §63.998(d)(l)(i) D Y D N/A D N
2. For equipment that is designated as difficult to inspect, is a written plan kept
that describes the actual monitoring frequency that will be used (and is at least
once every 5 years)? §§63.983(b)(3)(ii) and 63.998(d)(l)(i) DY D N/A DN
3. For equipment that is designated as unsafe to inspect, is a written plan kept
that indicates equipment will be inspected as frequently as practicable during
safe-to-inspect times (but not more frequently than annually)?
§§63.983(b)(2)(ii)and63.998(d)(l)(i) DY D N/A DN
4. For each annual inspection during which a leak was detected, was all of the
following information recorded and reported:3 §63.998(d)(l)(iii)
(a) Identification information of the leaking closed-vent system? D Y D N/A D N
(b) Name or initials of operator conducting the inspection? D Y D N/A D N
(c) Instrument identification number, if instrument monitoring applies? DY D N/A DN
(d) Date the leak was detected? DY DN/A DN
(e) Date of the first attempt to repair the leak? DY DN/A DN
(f) Maximum instrument reading after the leak is repaired or determined to
be non-repairable? DY DN/A DN
(g) Explanation of delay in repair, if the leak was not repaired within 15 days
after it was discovered? D Y D N/A D N
(h) Date of successful repair of the leak? DY DN/A DN
5. For each inspection during which no leaks were detected, were records kept of
all of the following:3 §63.998(d)(l)(iv)
(a) Record that the inspection was performed? D Y D N/A D N
(b) Date of the inspection? DY DN/A DN
(c) Statement that no leaks were found? DY DN/A DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-2. (continued)
II. Note All Deficiencies
Annual visual inspections for visible, audible, or olfactory indications of leaks are required for closed-
vent systems that are constructed of hard-piping. Annual instrument monitoring using Method 21 of
40 CFR part 60, Appendix A, is required for closed-vent systems constructed of duct work.
§63.983(b)(l)(i)(B) and (ii)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-3. Compliance Checklist for Flares
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Flare Identification:
I. Review of Records
1. Is all of the following information recorded (and included in the flare
compliance assessment report): §63.998(a)(l)(i)(A) through (C)
(a) Flare design (i.e., steam-assisted, air-assisted, or non-assisted)? DY DN
(b) All visible emission readings, heat content determinations, flow rate D Y D N
measurements, and exit velocity determinations made during the flare
compliance assessment?
(c) All periods during the flare compliance assessment when all pilot flames D Y D N/A D N
are absent or, if only the flare flame is monitored, all periods when the
flare flame is absent?
2. Are hourly records kept of whether the monitor is continuously operating and D Y D N
whether the flare flame or at least one pilot flame is continuously present?
§63.998(a)(l)(ii)
3. Are records kept of the times and durations of all periods during which the D Y D N/A D N
flare flame or all pilot flames are absent? §63.998(a)(l)(iii)(A)
4. Are records kept of the times and durations of all periods during which the DY DN/A DN
monitor is not operating? §63.998(a)(l)(iii)(B)
5. Are all records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspection
1. Is a device for detecting pilot flames or the flare flame present and operating? D Y D N
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-3. (continued)
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-4. Compliance Checklist for Thermal Incinerators
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Thermal Incinerator Identification:
I. Review of Records
1. Does the facility maintain the initial compliance records in (a) or (b):
(a) The following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP or D Y D N/A D N
TOC? §63.998(a)(2)(ii)(B)(4)
• The firebox temperature averaged over the full period of the D Y D N/A D N
performance test? §63.998(a)(2)(ii)(B)(l)
(b) Documentation of the design evaluation in the notification of compliance DY D N/A DN
status report? §63.8075(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the thermal incinerator is a small control device.
§63.8000(d)(2)
2. Do records document that the facility continuously monitors the temperature D Y D N
of the gas stream in the firebox (or in the ductwork immediately downstream
of the firebox before any substantial heat exchange occurs) or does the facility
have documentation that they requested and received approval to conduct an
alternative to continuous monitoring or to monitor an alternative
parameter(s)? §§63.988(c)(l) and 63.996(d)
3. If the facility continuously monitors temperature (or other approved
parameters), has the facility:
(a) Established a site-specific operating range for the monitored parameter? D Y D N/A D N
§63.996(c)(6)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-4. (continued)
I. Review of Records
(c) Maintained records of continuously monitored values in one of the DY D N/A DN
following formats: §63.998(b)(l)
• all measured values, or
• all block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least one
measured data value per minute if measured more frequently than once
per minute), or
• all continuous records for only the most recent 3 valid hours of
records, and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods ofCPMS
breakdown and malfunction. (§63.998(b)(l)(iii)).
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §63.998(b)(3)
Note: If the owner or operator chooses this option and the daily average
value is not calculated and recorded, then continuous or short-term block
averages may not be discarded as otherwise allowed by the third option in
item "c" above. §63.998(b)(3)(ii)
Note: Averages may be over an operating block if the thermal incinerator
is used to control emissions from process vessel vents and the owner or
operator establishes separate operating limits for different emission
episodes. §63.8005 (f)
Note: Daily (or operating block) averages must be reported in the
compliance reports for all days when an excursion occurred. An
excursion is either a daily average value outside the established range or
a day for which insufficient monitoring data were collected.
§63.999 (c) (6)
(e) As an alternative to "c" and "d" above when the conditions for alternative
recordkeeping in §63.998(b)(5)(i)(A) through (F) are met, does the
facility meet both of the following requirements:
Note: This alternative is allowed if the thermal incinerator is used for
process vessel vents and transfer racks, but not storage tanks.
§63.998(b) (5) introductory paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? DY D N/A DN
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d)(5)(ii)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-4. (continued)
I. Review of Records
(f) Maintained records of the occurrence and cause of all periods when the DY DN/A DN
monitored temperature is outside the established range? §63.998(d)(5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator (§§63.999(d)(l)
and (2), 63.8(f), and 63.10(b)(2)(vii) for control devices used for all other
emissions)?
Note: If an alternative parameter is monitored continuously, the records
described above in item "3" would be required for the alternative parameter.
Alternative recordkeeping might be required if the alternative monitoring is
not continuous.
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? D Y D N/A D N
(b) The date and time of completion of calibration and preventive D Y D N/A D N
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY
(h) Documentation that there were no excess emissions during each startup, D Y
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? D Y
6. Are all required records kept for at least 5 years? §63.10(b)(l)
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DY
DN
DN
DN
DN
DN
DN
DN
II. Visual Inspection
1. Is a temperature monitoring device is present in the firebox or in the ductwork D Y D N
immediately downstream from the firebox, or is an approved alternative monitor
present and operating?
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-4. (continued)
III. Note All Deficiencies
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Table 7-5. Compliance Checklist for Catalytic Incinerators
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Catalytic Incinerator Identification:
I. Review of Records
1. Does the facility maintain either of the following initial compliance records:
(a) Both of the following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP D Y D N/A D N
orTOC? §63.998(a)(2)(ii)(B)(4)
• The upstream temperature, downstream temperature, and D Y D N/A D N
temperature difference across the catalyst bed, all averaged over the
full period of the performance test? §63.998(a)(2)(ii)(B)(2)
(b) Documentation of the design evaluation in the notification of compliance D Y D N/A D N
status report? §63.8075(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the catalytic incinerator is a small control device.
§6 3.8000 (d) (2)
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements to demonstrate ongoing compliance for the catalytic incinerator:
(a) Temperatures are monitored according to the following procedures:
§§63.988(c) (2) and 63.998(c)(2)(ii)
• continuous monitoring of the gas stream temperature immediately
before and after the catalyst bed?
• average temperature differential across the catalyst bed is determined
daily?
(b) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §63.996(d)
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range? §63.996(c)(6) DY DN/A DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-5. (continued)
I. Review of Records
(b) Maintained records of monitoring data in one of the following formats: DY D N/A DN
§§63.998(b)(l) and 63.147(d)
• All measured values, or
• All block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
• All continuous records for only the most recent 3 valid hours of
records, and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)).
(c) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §§63.998(b)(3) and
6 3.147 (d)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c" above.
§63.998(b)(3)(ii)
Note: Averages may be over an operating block if the catalytic
incinerator is used to control emissions from process vessel vents and the
owner or operator establishes separate operating limits for different
emission episodes. §63.8005(f)
Note: Daily (or operating block) averages must be reported in the
compliance reports for all days when an excursion occurred. An
excursion is either a daily average value outside the established range or
a day for which insufficient monitoring data were collected.
§63.999 (c) (6)
(d) As an alternative to "b" and "c" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) are met,
does the facility meet both of the following requirements:
Note: This alternative is allowed if the catalytic incinerator is used for
process vents and transfer racks, but not storage tanks. §63.998(b)(5)
introductory paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? D Y D N/A D N
Note: No record of the daily average is required if 6 months have
passed without an excursion. §§63.998(d) (5) (ii)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-5. (continued)
I. Review of Records
4. If the facility monitors the inlet and outlet temperatures as specified in D Y D N/A D N
§63.988(c)(2), have they established a site-specific operating range for the
temperature differential across the catalyst bed, and do they maintain records
of the daily average temperature differential? §§63.996(c)(6) and
63.998(c)(2)(ii)
5. If the facility received approval to monitor an alternative parameter, are they DY DN/A DN
performing the recordkeeping approved by the Administrator (§§63.999(d)(l)
and (2), 63.8(f), and 63.10(b)(2)(vii))?
Note: If an alternative parameter is monitored continuously, the records
described above in item "3" would be required for the alternative parameter.
Alternative recordkeeping might be required if the alternative monitoring is
not continuous.
6. Do records document the occurrence and cause of all periods when the daily D Y D N/A D N
averages of the continuously monitored parameters are outside their
established ranges? §§63.998(c)(2)(iii) and 63.998(d)(5)
Note: This requirement also applies to the temperature differential across the
catalyst.
7. For each CPMS, does the facility have manufacturer's or other written
specifications or recommendations for installation, operation, and calibration
of the monitoring equipment? §63.996(c)(l) and (3)
8. For each CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e)
(f)
(g)
(h)
(1)
The occurrence and duration of each startup, shutdown, and malfunction
of the CPMS during which excess emissions occur?
Documentation of whether procedures specified in the source's startup,
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
Documentation of each startup, shutdown, and malfunction event?
Documentation that there were no excess emissions during each startup,
shutdown, or malfunction event, as applicable?
The total duration of operating time during the reporting period?
DY
DY
DY
DY
DY
DN/A
DN/A
DN/A
DN/A
DN/A
DN
DN
DN
DN
DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-5. (continued)
I. Review of Records
9. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) Temperature monitoring devices before and after the catalyst bed D Y D N/A D N
(if complying with §63.988(c)(2))?
(b) Any other approved monitoring device (if complying with §63.996(d))? DY D N/A DN
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-6. Compliance Checklist for a Boiler or Process Heater with a Design Heat Input Capacity
Less than 44 Megawatts and the Vent Stream Is Not Introduced with the Primary Fuel
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Boiler or Process Heater Identification:
I. Review of Records
1. Does the facility maintain either of the following initial compliance records:
(a) All of the following records of performance tests:
• A description of the location at which the vent stream is introduced DY D N/A DN
into the boiler or process heater? §63.998(a)(2)(ii)(B)(5)
• Either the percent reduction or outlet concentration of organic HAP or D Y D N/A D N
TOC? §63.998(a)(2)(ii)(B)(6)
• The firebox temperature averaged over the full period of the D Y D N/A D N
performance test? §63.998(a)(2)(ii)(B)(3)
(b) Documentation of the design evaluation in the notification of compliance DY D N/A DN
status report? §63.80 75(d) (2) (ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the boiler or process heater is a small control device.
§63.8000(d)(2)
2. Do records document that the facility continuously monitors the temperature D Y D N
of the gas stream in the firebox, or does the facility have documentation that
they requested and received approval to conduct an alternative to continuous
monitoring or to monitor an alternative parameter(s)? §§63.988(c)(l) and
63.996(d)
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the monitored parameter? D Y D N/A D N
§63.996(c)(6)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
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Table 7-6. (continued)
I. Review of Records
(c) Maintained records of continuously monitored values in one of the DY D N/A DN
following formats: §63.998(b)(l)
• all measured values, or
• all block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least one
measured data value per minute if measured more frequently than once
per minute), or
• all continuous records for only the most recent 3 valid hours of
records, and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods ofCPMS
breakdown and malfunction (§63.998(b)(l)(iii)).
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §63.998(b)(3)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c " above.
§63.998(b)(3)(ii)
Note: Averages may be over an operating block if the boiler or process
heater is used to control emissions from process vessel vents and the
owner or operator establishes separate operating limits for different
emission episodes. §63.8005(f)
Note: Daily (or operating block) averages must be reported in the
compliance reports for all days when an excursion occurred. An
excursion is either a daily average value outside the established range or
a day for which insufficient monitoring data were collected.
§63.999 (c) (6)
(e) As an alternative to "c" and "d" above when the conditions for alternative
recordkeeping in §63.998(b)(5)(i)(A) through (F) are met, does the
facility meet both of the following requirements:
Note: This alternative is not allowed if the boiler or process heater is
used only for storage tanks. §63.998(b)(5) introductory paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? DY D N/A DN
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d)(5)(ii)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-6. (continued)
I. Review of Records
(f) Maintained records of the occurrence and cause of all periods when the DY DN/A DN
monitored temperature is outside the established range?
§§63.998(c)(2)(iii) and 63.998(d)(5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator? §§63.999(d)(l)
and (2), 63.8(f), and 63.10(b)(2)(vii)
Note: If an alternative parameter is monitored continuously, the records
described above in item "3" would be required for the alternative parameter.
Alternative recordkeeping might be required if the alternative monitoring is
not continuous.
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY
(h) Documentation that there were no excess emissions during each startup, D Y
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? D Y
6. Are all required records kept for at least 5 years? §63.10(b)(l)
DN/A
DN/A
DN/A
DN/A
DN/A
DN/A
DY
DN
DN
DN
DN
DN
DN
DN
II. Visual Inspection
1. Is a temperature monitoring device is present in the firebox, or is an approved D Y D N
alternative monitor present and operating?
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Table 7-6. (continued)
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-7. Compliance Checklist for a Boiler or Process Heater with a Design Heat Input Capacity
Greater than 44 Megawatts or the Emission Stream Is Introduced with the Primary Fuel
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Boiler or Process Heater Identification:
I. Review of Records
1. Do records describe the location at which the vent stream is introduced into DY DN/A DN
the boiler or process heater? §63.998(a) (2) (ii) (B) (5)
II. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-8. Compliance Checklist for a Regenerative Carbon Adsorber
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Carbon Adsorber Identification:
I. Review of Records
1. Does the facility maintain the initial compliance records in (a) or (b):
(a) Both of the following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP D Y ON/A D N
orTOC? §63.998(a)(2)(ii)(C)(5)
• Either the concentration of organic HAP or TOC at the outlet of the DY ON/A DN
carbon adsorber averaged over the full period of the performance
test, or all of the following during the period of each performance
test: (1) the total regeneration stream mass or volumetric flow
during each regeneration, (2) the temperature of the carbon bed after
each regeneration, and (3) the temperature of the carbon bed within
15 minutes after the completion of each cooling cycle?
§63.998(a)(2)(ii)(C)(3) and (4)
(b) Documentation of the design evaluation in the notification of compliance DY ON/A DN
status report? §63.8075(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the carbon adsorber is a small control device.
§63.8000(d)(2)
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the carbon adsorber:
(a) Monitors the total regeneration stream mass or volumetric flow for each
regeneration cycle, the temperature of the carbon bed after each
regeneration, and the temperature of the carbon bed within 15 minutes
after the completion of the regeneration cooling cycle? §63.990(c)(3)
(b) Uses an "organic monitoring device" to continuously monitor a
parameter that provides an indication of the organic concentration at the
outlet of the carbon adsorber? §63.990(c) introductory paragraph
(c) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §63.996(d)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-8. (continued)
I. Review of Records
3. For the monitored parameters, has the facility:
(a) Established a site-specific operating range for each monitored parameter? D Y D N/A D N
§63.996(c)(6)
(b) Followed manufacturer's or other written specifications or D Y D N/A D N
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
(c) Maintained records of the following monitored parameters for each
regeneration cycle, if complying with monitoring identified in item 2(a)
of this checklist: §63.998(c)(3)(ii)
• Total regeneration stream mass or volumetric flow? D Y D N/A D N
• Temperature of the carbon bed after each regeneration? DY DN/A DN
• Temperature of the carbon bed within 15 minutes of completing any DY D N/A DN
cooling cycle?
(d) Maintained records of the periods of operation when a monitored DY DN/A DN
parameter was outside its established range and the cause of these
deviations? §§63.998(c)(3)(iii) and 63.998(d)(5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator? §§63.999(d)(l)
and (2), 63.8(f), and 63.10(b)(2)(vii)
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive D Y D N/A D N
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY DN/A DN
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-8. (continued)
I. Review of Records
(i) The total duration of operating time during the reporting period? DY D N/A DN
6. Are all required records kept for at least 5 years? §63.10(b)(l) D Y D N
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) Temperature monitoring device in the carbon bed and a regeneration D Y D N/A D N
stream mass or volumetric flow monitoring device (if complying with
§63.990(c)(3))?
(b) An organic monitoring device at the outlet of the carbon adsorber DY DN/A DN
(if complying with §63.990(c) introductory paragraph)?
(c) Any other approved monitoring device (if complying with §63.996(d))? D Y D N/A D N
III. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-9. Compliance Checklist for an Absorber
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Absorber Identification:
I. Review of Records
1. Does the facility maintain the initial compliance records in (a) or (b):
(a) The following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP D Y ON/A D N
orTOC? §63.998(a)(2)(ii)(C)(5)
• Either the concentration of organic HAP or TOC at the outlet of the DY ON/A DN
absorber averaged over the full period of the performance test, or
both the temperature and specific gravity of the exiting scrubber
liquid averaged over the full period of the performance test?
§63.998(a)(2)(ii)(C)(l) and (4)
(b) Documentation of the design evaluation in the notification of compliance DY ON/A DN
status report? §63.8075(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the absorber is a small control device.
§63.8000(d)(2)
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the absorber:
(a) Continuously monitors the temperature and specific gravity of the
scrubbing liquid exiting the absorber? §63.990(c)(l)
(b) Uses an "organic monitoring device" to continuously monitor a
parameter that provides an indication of the organic concentration at the
outlet of the absorber? §63.990(c)(l)
(c) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §63.996(d)
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the parameter? D Y D N/A D N
§63.996(c)(6)
(b) Followed manufacturer's or other written specifications or D Y D N/A D N
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
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Table 7-9. (continued)
I. Review of Records
(c) Maintained records of the monitoring data in one of the following D Y D N/A D N
formats: §63.998(b)(l)
• All measured values, or
• All block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
• All continuous records for only the most recent 3 valid hours of
records, and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)).
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §63.998(b)(3)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c" above.
§63.998(b)(3)(ii)
Note: Averages may be over an operating block if the absorber is used
to control emissions from process vessel vents and the owner or operator
has established separate operating limits for different emission episodes.
§63.8005 (f)
Note: Daily (or operating block) averages must be reported in the
compliance reports for all days when an excursion occurred. An
excursion is either a daily average value outside the established range or
a day for which insufficient monitoring data were collected.
§63.999 (c) (6)
(e) As an alternative to "c" and "d" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) are met,
does the facility meet both of the following requirements:
Note: This alternative is not allowed if the absorber is used only for
storage tanks. §63.998(b)(5) introductory paragraph
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? D Y D N/A D N
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d) (5) (ii)
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Table 7-9. (continued)
I. Review of Records
(f) Maintained records of both the periods of operation when the daily DY DN/A DN
average of any continuously monitored parameter was outside its
established range and the cause of these deviations? §§63.998(c)(3)(iii)
and 63.998 (d) (5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator? §§63.999(d)(l)
and (2), 63.8(f), and 63.10(b)(2)(vii)
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive D Y D N/A D N
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY DN/A DN
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? DY DN/A DN
6. Are all required records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) Temperature and specific gravity monitoring devices in the scrubbing D Y D N/A D N
fluid exit line (if complying with §63.990(c)(l))?
(b) An organic monitoring device at the outlet of the absorber (if complying D Y D N/A D N
with §63.990(c)(l))?
(c) Any other approved monitoring device (if complying with §63.996(d))? DY DN/A DN
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Table 7-9. (continued)
III. Note All Deficiencies
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Table 7-10. Compliance Checklist for a Condenser
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Condenser Identification:
I. Review of Records
1. Does the facility maintain the initial compliance records in (a) or (b):
Note: This information is not required when complying with the specified
temperature option in Table 1 to subpart HHHHH.
(a) The following records of performance tests:
• Either the percent reduction or outlet concentration of organic HAP D Y ON/A D N
orTOC? §63.998(a)(2)(ii)(C)(5)
• Either the concentration of organic HAP or TOC at the outlet of the DY DN/A DN
condenser averaged over the full period of the performance test, or
the exit (product side) temperature averaged over the full period of
the performance test? §63.998(a)(2)(ii)(C)(2) and (4)
(b) Documentation of the design evaluation in the notification of compliance DY ON/A DN
status report? §63.8075(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the condenser is a small control device.
§63.8000(d)(2)
(c) Calculations of the controlled emissions and corresponding percent D Y D N/A D N
reduction in the notification of compliance status report?
§63.8075(d)(2)(ii)
Note: This option only applies if the only emissions routed to the
condenser are from process vessel vents. §63.8005(d) (2)
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the condenser:
(a) Continuously monitors the product side exit temperature of the
condenser, or §63.990(c) (2)
(b) Uses an "organic monitoring device" to continuously monitor a
parameter that provides an indication of the organic concentration at the
outlet of the condenser, or §63.990(c)(2)
(c) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §63.996(d)
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Table 7-10. (continued)
I. Review of Records
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the parameter? DY DN/A DN
§63.996(c)(6)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
(c) Maintained records of the monitoring data in one of the following D Y D N/A D N
formats: §63.998(b)(l)
• All measured values, or
• All block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
• All continuous records for only the most recent 3 valid hours of
records, and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)).
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §63.998(b)(3)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c " above.
§63.998(b)(3)(ii)
Note: Averages may be over an operating block if the condenser is used
to control emissions from process vessel vents and the owner or operator
establishes separate operating limits for different emission episodes.
§63.8005(f)
Note: Daily (or operating block) averages must be reported in the
compliance reports for all days when an excursion occurred. An
excursion is either a daily average value outside the established range or
a day for which insufficient monitoring data were collected.
§6 3.999 (c) (6)
(e) As an alternative to "c" and "d" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) are met,
does the facility meet both of the following requirements:
Note: This alternative is not allowed if the condenser is used only for
storage tanks. §63.998(b)(5) introductory paragraph
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-10. (continued)
I. Review of Records
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? DY D N/A DN
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d) (5) (ii)
(f) Maintained records of both the periods of operation when the daily D Y D N/A D N
average of any continuously monitored parameter was outside its
established range and the cause of these deviations? §§63.998(c)(3)(iii)
and 63.998(d) (5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator? §§63.999(d)(l)
and (2), 63.8(f), and 63.10(b)(2)(vii)
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction DY D N/A DN
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY DN/A DN
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? DY DN/A DN
6. Are all required records kept for at least 5 years? §63.10(b)(l) DY DN
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Table 7-10. (continued)
II. Visual Inspection
1. Are any one of the following monitoring devices present and operating:
(a) A temperature monitoring device at the product side exit of the Y N/A N
condenser (if complying with §63.990(c)(2))?
(b) An organic monitoring device at the outlet of the condenser Y N/A N
(if complying with §63.990(c)(2))?
(c) Any other approved monitoring device (if complying with §63.996(d))? Y N/A N
III. Note All Deficiencies
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Table 7-11. Compliance Checklist for a Control Device Not Specifically Listed
Note: A "yes" response to a question indicates compliance with that requirement, and a "no" response
indicates noncompliance with the requirement. If a requirement is not applicable, check the
"N/A" box.
Control Device or Recovery Device Identification:
I. Review of Records
1. Does the facility maintain the initial compliance records in (a) or (b):
(a) Data collected during a performance test as approved by the D Y ON/A D N
Administrator? §63.998(a)(2)(i)
(b) Documentation of a design evaluation in the notification of compliance D Y ON/A D N
status report? §63.8075(d)(2)(ii)
Note: A design evaluation may be conducted as an alternative to a
performance test if the device is a small control device. §63.8000(d)(2)
2. If the facility received approval for any monitoring, are the parameters being DY D N/A DN
monitored and recorded as approved by the Administrator? §§63.999(d)(2),
63.8(f), and63.10(b)(2)(vii)l
3. Are all required records kept for at least 5 years? §63.10(b)(l) DY DN
II. Visual Inspection
1. Are all approved monitoring devices present and operating? Y N/A N
III. Note All Deficiencies
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Table 7-12. Compliance Checklist for a Scrubber
Note: Use this checklist for scrubbers that control halogen atoms in halogenated vent streams prior to a
combustion device or control hydrogen halide and halogen emissions that are generated by
combusting a halogenated vent stream. A "yes" response to a question indicates compliance with
that requirement, and a "no" response indicates noncompliance with the requirement. If a
requirement is not applicable, check the "N/A" box.
Scrubber Identification:
I. Review of Records
1. Does the facility maintain the initial compliance records in (a) or (b):
(a) Either of the following records of performance tests:
• If the scrubber is used before a combustion device to reduce the D Y ON/A D N
halogen atom mass emission rate, a record of the halogen
concentration prior to the combustion device? §§63.994(b)(2) and
63.998 (a) (4)
• If the scrubber is used to control hydrogen halide and halogen
emissions from process vents or after a combustion device, all of the
following records: §63.998(a)(2)(ii)(D)
*• The resulting percent reduction, mass emission rate, or outlet D Y ON/A D N
concentration?
*• The pH or caustic strength of the scrubber effluent averaged over DY ON/A DN
the time period of the performance test?
*• The scrubber liquid-to-gas ratio averaged over the time period of D Y ON/A D N
the performance test?
(b) Documentation of the design evaluation in the notification of compliance DY ON/A DN
status report? §63.8075(d)(2)(ii)
Note: A performance test is required if the scrubber is used to control
hydrogen halide and halogen emissions after a combustion unit that
controls halogenated vent streams, and the scrubber is a large control
device as defined in §63.8105(g). Either a design evaluation or
performance test is required in all other situations. §§63.994(b)(l),
63.8000(c)(3) and (d)(2)
2. Do records document that the facility meets one of the following monitoring D Y D N
requirements for the scrubber:
(a) Monitors all of the following parameters:
• Continuously monitors either the pH or the caustic strength of the
scrubber effluent? §§63.994(c)(l)(i) and 63.8000(d)(5)(iii)
• Continuously monitors the flow of the scrubber liquid influent?
§63.994(c)(l)(H)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-12. (continued)
I. Review of Records
• Has measured or otherwise determined the inlet gas flow?
§63.994(c)(l)(iii)
(b) Has documentation that they requested and received approval to conduct
an alternative to continuous monitoring or to monitor an alternative
parameter(s)? §63.996(d)
3. For each continuously monitored parameter, has the facility:
(a) Established a site-specific operating range for the parameter? DY DN/A DN
§63.996(c)(6)
(b) Followed manufacturer's or other written specifications or DY D N/A DN
recommendations for installation, operation, and calibration of the
monitoring equipment? §63.996(c)(l) and (3)
(c) Maintained records of the monitoring data in one of the following D Y D N/A D N
formats: §63.998(b)(l)
• All measured values, or
• All block average values for 15-minute or shorter periods calculated
from all measured data values during each period (or from at least
one measured data value per minute if measured more frequently
than once per minute), or
• All continuous records for only the most recent 3 valid hours of
records, and block hourly average values for earlier data?
Note: To use the third option, the data must be collected from an
automated CPMS, and the hourly averages must include periods of
CPMS breakdown and malfunction (§63.998(b)(l)(iii)).
(d) Maintained records of either daily average values or a statement that all D Y D N/A D N
values were within the established operating range? §63.998(b)(3)
Note: If the daily average value is not calculated and recorded, then
continuous or short-term block averages may not be discarded as
otherwise allowed by the third option in item "c" above.
§63.998(b)(3)(ii)
Note: Daily averages must be reported in the compliance reports for all
days when an excursion occurred. An excursion is either a daily average
value outside the established range or a day for which insufficient
monitoring data were collected. §63.999(c)(6)
(e) As an alternative to "c" and "d" above when the conditions for
alternative recordkeeping in §63.998(b)(5)(i)(A) through (F) are met,
does the facility meet both of the following requirements:
Note: This alternative is allowed if the scrubber is used only for process
vessel vent and transfer racks, not storage tanks. §63.998(b)(5)
introductory paragraph
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 7
Table 7-12. (continued)
I. Review of Records
• Document in their notification of compliance status report or a D Y D N/A D N
compliance report that they were implementing this alternative?
• Retain only the daily average? DY D N/A DN
Note: No record of the daily average is required if 6 months have
passed without an excursion. §63.998(d) (5) (ii)
(f) Maintained records of both the periods of operation when the daily D Y D N/A D N
average of any continuously monitored parameter was outside its
established range and the cause of these deviations? §§63.998(c)(3)(iii)
and 63.998(d) (5)
4. If the facility received approval to monitor an alternative parameter, are they D Y D N/A D N
performing the recordkeeping approved by the Administrator?
§§63.999(d)(l)and(2), 63.8(f), and 63.10(b)(2)(vii)
5. For any CPMS, does the facility have records of all of the following:
§63.998(c)(l)(i) and (ii)
(a) The procedure used for calibrating the CPMS? DY DN/A DN
(b) The date and time of completion of calibration and preventive DY DN/A DN
maintenance of the CPMS?
(c) The "as found" and "as left" CPMS readings, whenever an adjustment is D Y D N/A D N
made that affects the CPMS reading and a "no adjustment" statement
otherwise?
(d) The start time and duration (or start and stop times) of any periods when D Y D N/A D N
the CPMS is inoperative?
(e) The occurrence and duration of each startup, shutdown, and malfunction D Y D N/A D N
of the CPMS during which excess emissions occur?
(f) Documentation of whether procedures specified in the source's startup, D Y D N/A D N
shutdown, and malfunction plan were followed for each startup,
shutdown, and malfunction during which excess emissions occurred?
(g) Documentation of each startup, shutdown, and malfunction event? DY DN/A DN
(h) Documentation that there were no excess emissions during each startup, D Y D N/A D N
shutdown, or malfunction event, as applicable?
(i) The total duration of operating time during the reporting period? DY DN/A DN
6. Are all required records kept for at least 5 years? §63.10(b)(l) DY DN
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Table 7-12. (continued)
II. Visual Inspection
1. Are either of the following monitoring devices present and operating:
(a) Effluent pH or caustic strength monitor and effluent liquid flow monitor D Y D N/A D N
(if complying with §63.994(c)(l))?
(b) Any other approved monitoring device (if complying with DY D N/A DN
§§63.994(c)(2) and 63.996(d))?
III. Note All Deficiencies
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Section 8
Reporting Requirements
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Table 8-1. Inspection Checklist for Notification of Compliance Status Report
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the question is not applicable,
check the "N/A" box.
I. Review of Records
1. Does the report include the results of all applicability determinations (e.g., DY DN/A DN
HAP content of coating products, halogenated vent stream determinations,
Group 1 or Group 2 determinations, and determinations of equipment in
organic HAP service)? §63.8075(d)(2)(i)
2. Does the report include all of the following information related to initial
compliance determinations, as applicable:
(a) Emissions profiles and descriptions of worst-case operating and/or testing D Y D N/A D N
conditions when a performance test is conducted for a control device that
is used to comply with an emission limit for process vessel vents?
§§63.8075(d)(2)(ii), 63.8005(d)(l), and 63.1257(b)(8)
(b) Performance test reports, including site-specific operating limits and D Y D N/A D N
supporting data and calculation records? §§63.8075(d)(2)(ii) and (Hi) and
63.999(a) (2) and (3)
(c) Flare compliance assessments? §§63.8075(d)(2)(ii) and 63.999(a)(2) DY D N/A DN
(d) Design evaluations, including site-specific operating limits? D Y D N/A D N
§§63.8075(d)(2)(ii) and (Hi) and 63.999(b)(2)(i) through (iv)
(e) Any calculations used to demonstrate initial compliance (e.g., calculations D Y D N/A D N
of uncontrolled and controlled emissions if complying with emissions
averaging for process vessel vents)? §63.8075(d)(2)(ii)
3. Does the report include descriptions of monitoring devices and monitoring
frequencies? §63.8075(d)(2)(Hi)
4. If complying with subpart UU for equipment leaks, does the report include all
of the following information about equipment leaks:
Note: If complying with subpart TT, some of this information must be included
in the initial compliance report, as indicated in Table 8-2.
(a) Identification of the affected facility? §63.1039(a)(l)(i) DY DN/A DN
(b) Number of each equipment type, excluding equipment in vacuum service? DY D N/A DN
§63.1039(a)(l)(ii)
(c) Method of compliance with the standards? §63.1039(a)(l)(iii) DY D N/A DN
(d) If the method of compliance is pressure testing, the products or product D Y D N/A D N
codes and the planned schedule for pressure testing? §63.1039(a)(2)
(e) If the method of compliance is to enclose the affected facility, DY DN/A DN
identification of the affected facility, a description of the system used to
create a negative pressure in the enclosure, and a description of the control
device to which the emissions are routed? §63.1039(a)(3)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-1. (continued)
I. Review of Records
5. If complying with subpart R for equipment leaks, does the report include the DY D N/A DN
types, identification numbers, and location of all equipment in organic HAP
service? §§63.428(f) and 63.8015(b)(2)
6. Does the report identify the following equipment and related information, if
applicable:
(a) Parts of the affected source that are subject to other rules and the authority D Y DN/A DN
under which the facility will comply for such equipment?
§63.8075(d)(2)(iv)
Note: Section 63.8090 identifies other rules that may overlap with
subpart HHHHH and the applicable compliance options.
(b) Storage tanks that comply with the vapor balancing option in D Y D N/A D N
§63.8010(e)? §63.8075(d)(2)(v)
(c) The following information if Group 1 wastewater is sent offsite for
treatment: §63.8075(d)(2)(vi)
• Name and location of the offsite treatment facility? D Y D N/A D N
• Description of the wastewater sent for treatment? D Y D N/A D N
• If treatment is in an enhanced biological treatment unit, the DY D N/A DN
certification from the offsite facility that they will comply with the
requirements of subpart HHHHH?
7. Has a responsible official of the affected source signed the report, certified its DY DN
accuracy, and attested to whether the source has complied with the
requirements in subpart FFFF? §63.9(h)(2)(i) introductory text
II. Note All Deficiencies
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-2. Inspection Checklist for Compliance Reports
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a
"no" response means noncompliance with the requirement. If the question is not applicable,
check the "N/A" box.
I. Review of Records
1. Do compliance reports include all of the following general information:
(a) Company name and address? §63.8075(e)(l) DY DN
(b) Date of the report, and beginning and ending dates of the reporting D Y D N
period? §63.8075(e)(3)
(c) Name, title, and signature by a responsible official of the company D Y D N
certifying the accuracy of the report? §§63.8075(e)(2)
2. If excess emissions occurred (e.g., a daily average operating parameter
exceeded an operating limit) with any startup, shutdown, and/or malfunction
during a reporting period, does the compliance report for that period include
the following records: §63.8075(e)(5)
(a) That procedures in the facility's SSMP were followed, or documentation DY DN/A DN
of actions taken that were inconsistent with the SSMP?
(b) A brief description of each malfunction? DY DN/A DN
3. If there were no deviations from any emission limit, operating limit, or work D Y D N/A D N
practice standard during a reporting period, does the compliance report for
that period include a statement documenting the absence of any such
deviations? §63.8075(e)(6)(i)
4. If a reporting period included deviations from any emission limits, operating
limits, and/or work practice standards where ongoing compliance is not
demonstrated by using a CMS, does the compliance report for the period
include the following information: §63.8075(e)(6)(ii)
(a) The total operating time of the affected source during the reporting D Y D N/A D N
period?
(b)
(c)
(d)
(e)
(f)
The total number of deviations?
The total duration of deviations?
The cause(s) of deviations (including unknown cause, if applicable)?
The corrective action(s) taken?
Operating logs for the day(s) during which the deviation occurred?
Note: Operating logs are not required for deviations of the work
practice standards for equipment leaks.
DY
DY
DY
DY
DY
DN/A
DN/A
DN/A
DN/A
DN/A
DN
DN
DN
DN
DN
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-2. (continued)
I. Review of Records
5. If a reporting period included any deviations from an emission limit or
operating limit where a CMS is used to demonstrate ongoing compliance,
does the compliance report for that period include the following information
for the days when the deviations occurred (e.g., daily average of the
monitored parameter does not meet the operating limit, or data availability
requirements are not met): §§63.80 75(e) (6) (Hi) and 63.999(c) (6) (i)
(a) Date and time each CMS was inoperative (except for zero [low-level] D Y D N/A D N
and high level checks)?
(b) For a CEMS, the date, time, and duration that the CEMS was out of DY DN/A DN
control, and corrective actions taken?
(c) Date and time that each deviation started and stopped, and indication of D Y D N/A D N
whether the deviation occurred during a period of SSM?
(d) Identification of each HAP known to be in the emission stream or D Y D N/A D N
wastewater stream?
(e) Identification of the CMS? DY DN/A DN
(f) Description of the product being produced? D Y D N/A D N
(g) Date of the most recent CMS certification or audit? DY DN/A DN
(h) Operating day averages of the operating parameter (or pollutant D Y D N/A D N
concentration)?
(i) Summary statistics regarding the total duration and causes for all D Y D N/A D N
deviations from emission limits and operating limits?
(j) Summary of the total duration of CMS downtime during the reporting D Y D N/A D N
period, and calculation of the total duration as a percentage of the total
operating time for the affected source during the reporting period?
6. For each CEMS that was never out of control during a reporting period, does D Y D N/A D N
the compliance report for that period include a statement documenting this
result? §63.8075(e)(7)
7. If a flare is used to comply with an emission limit in subpart HHHHH, does DY DN/A DN
the compliance report include records of periods when all pilot flames were
absent or the flare flame was absent? §63.999(c) (3)
8. If a carbon adsorber is used to comply with an emission limit in subpart DY DN/A DN
HHHHH, does the compliance report document all carbon bed regeneration
cycles during which a monitored parameter (e.g., regeneration stream flow or
carbon bed temperature) did not meet an applicable operating limit?
§63.999(c)(6)(ii)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-2. (continued)
I. Review of Records
9. If a closed-vent system is required to route emissions to a control device, does
the compliance report include the following information about the closed-vent
system: §63.999(c)(2)
(a) The following records when a leak is detected:
• Identification information of the leaking closed-vent system? D Y D N/A D N
• Name, initials, or identification number of operator conducting the D Y D N/A D N
inspection?
• Instrument identification number, if instrument monitoring applies? D Y D N/A D N
• Date the leak was detected? DY DN/A DN
• Date of the first attempt to repair the leak? DY DN/A DN
• Maximum instrument reading after the leak is repaired or determined D Y D N/A D N
to be non-repairable?
• Explanation of delay in repair, if the leak was not repaired within 15 DY D N/A DN
days after it was discovered?
• Date of successful repair of the leak? D Y D N/A D N
(b) The times when a vent stream is diverted from the control device through D Y D N/A D N
a bypass line?
(c) The times when maintenance is performed in car-sealed valves, when the D Y D N/A D N
seal is broken, when the bypass line valve position is changed, or the key
for a lock-and-key type configuration has been checked out?
10. If complying with the equipment leak requirements in §§63.424 and 63.428 of
subpart R, does the compliance report include the following information for
each occurrence of an equipment leak for which no repair attempt was made
within 5 days or for which repair was not completed within 15 days after
detection: §63.424(h)(4) as referenced from Table 3 to subpart HHHHH
(a) The date the leak was detected? DY DN/A DN
(b) The date of each attempt to repair the leak? DY DN/A DN
(c) The reasons for the delay of repair? D Y D N/A D N
(d) The date of successful repair? DY DN/A DN
11. If complying with the equipment leak requirements in subpart TT, does the
initial compliance report include the following information: §63.1018(a)(l)
(a) Identification of the affected facility? DY DN/A DN
(b) Number of valves subject to leak detection and repair requirements DY DN/A DN
(excluding valves designated for no detectable emissions)?
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-2. (continued)
I. Review of Records
(c) Number of pumps subject to leak detection and repair requirements D Y D N/A D N
(excluding pumps designated for no detectable emissions and pumps for
which leaks are routed through a closed-vent system to a control device)?
(d) Number of compressors subject to leak detection and repair requirements DY DN/A DN
(excluding compressors designated for no detectable emissions and
compressors for which leaks are routed through a closed-vent system to a
control device)?
12. If complying with the equipment leak requirements in subpart TT, do all
compliance reports include the following information: §63.1018(a)(2)
(a) Affected facility identification? DY DN/A DN
(b) All of the following information for each month in the reporting period:
• Number of valves for which leaks were detected? D Y D N/A D N
• Number of valves for which leaks were not repaired? DY DN/A DN
• Number of pumps for which leaks were detected? D Y D N/A D N
• Number of pumps for which leaks were not repaired? DY D N/A DN
• Number of compressors for which leaks were detected? D Y D N/A D N
• Number of compressors for which leaks were not repaired? D Y D N/A D N
• Explanation of each delay of repair and, if applicable, why the repair D Y D N/A D N
was technically infeasible without a shutdown of the affected facility?
(c) Dates of any shutdown of the affected facility that occurred during the DY DN/A DN
reporting period?
13. If complying with the equipment leak requirements in subpart UU, does the
compliance report include the following information:
(a) A summary of the following data for valves in gas and vapor service and
light liquid service, pumps in light liquid service, connectors in gas and
vapor service and light liquid service, agitators in gas and vapor service
and light liquid service, and compressors: §63.1039(b)(l)
• Number of each type of component for which leaks were detected? D Y D N/A D N
• The percent leakers for valves, pumps, and connectors? D Y D N/A D N
• Total number of components monitored? DY DN/A DN
• Number of leaking components that were not repaired? D Y D N/A D N
• The number of valves and connectors determined to be nonrepayable? D Y DN/A DN
(b) Documentation of the occurrence and number of times delay of repair DY D N/A DN
has been used? §63.1039(b)(2)
(c) The following records of any valve subgroups: §63.1039(b)(3)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-2. (continued)
I. Review of Records
• The valves assigned to each subgroup? D Y D N/A D N
• Monitoring results and calculations made for each subgroup for each D Y D N/A D N
monitoring period?
• Identification of any valves that have been reassigned from one D Y D N/A D N
subgroup to another during the reporting period, and the date of such
reassignments?
• Results of the semiannual overall performance calculation? D Y D N/A D N
(d) For pressure relief devices and compressors operating with an instrument D Y D N/A D N
reading less than 500 ppm above background, results of all monitoring
conducted during the reporting period to show compliance?
§63.10 39 (b) (4)
(e) Documentation of the initiation of a monthly monitoring program for D Y D N/A D N
valves, if applicable? §63.1039(b) (5)
(f) Documentation of the initiation of a quality improvement program for D Y D N/A D N
pumps, if applicable? §63.1039(b)(6)
(g) If compliance is demonstrated by pressure testing, records of the
following: §63.1039(b)(7)
• Process equipment train identification? D Y D N/A D N
• The number of pressure tests conducted? D Y D N/A D N
• The number of pressure tests where the equipment train failed the DY DN/A DN
pressure test?
• Explanation for any delay of repair? D Y D N/A D N
14. If a floating roof is used to meet the emission limit for a storage tank, does
each compliance report include the following information:
(a) Notification at least 30 days before a planned inspection (7 days if the DY DN/A DN
inspection is unplanned or the owner or operator could not have known
about it 30 days in advance)? §63.1066(b)(l)
(b) Records of inspection results when failures are identified (i.e., storage DY DN/A DN
tank identification, date of inspection, description of failure, description
of repairs and the dates they were made, and date storage tank is
removed from service, if applicable)? §63.1066(b)(2)
(c) Any request to use an alternate control device? §63.1066(b)(3) D Y D N/A D N
(d) Any request for extension to conduct inspection of a floating roof DY DN/A DN
determined to be unsafe to inspect or for an extension for repair if repair
could not be completed or the vessel emptied within 45 days after a
failed inspection? §63.1066(b)(4)
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-2. (continued)
I. Review of Records
15. If emissions from a storage tank are routed to a control device, does each
compliance report include all of the following information related to periods
of planned routine maintenance:
(a) All of the following records of periods of planned routine maintenance
during the reporting period: §63.999(c)(4)(i)
• The time of day and date when each period of planned routine DY DN/A DN
maintenance started?
• The time of day and date when each period of planned routine DY DN/A DN
maintenance ends?
• Description of the type of maintenance performed? DY D N/A DN
(b) Total number of hours in the current and preceding reporting periods DY D N/A DN
when the control device was not operating due to planned routine
maintenance? §63.999(c)(4)(ii)
(c) A description of the planned routine maintenance for the next reporting D Y D N/A D N
period (i.e., the type of maintenance to be performed, the expected
frequency of the maintenance, and the expected length of the
maintenance periods)? §63.999(c)(4)(iii)
16. If the facility sends Group 1 waste water to an onsite enhanced biological D Y D N/A D N
treatment unit, is the facility complying with approved reporting
requirements? §63.8020(c)
Note: The approved reporting requirements should be consistent with
reporting procedures described in the precompliance report or follow-up
documentation. See the checklist in Table 5-1 for example monitoring
parameters.
17. If the facility invokes the delay of repair provisions for heat exchange system
leaks, is the following information included in the next compliance report:
§63.104(f)(2) as referenced from §6 3.8075 (e) (4)
(a) Identification of the leak? DY DN/A DN
(b) The date the leak was detected? DY DN/A DN
(c) Whether or not the leak has been repaired? D Y D N/A D N
(d) Reason(s) for the delay of repair? DY DN/A DN
(e) Documentation of emissions estimates, if repair was delayed because D Y D N/A D N
emissions from shutdown could be greater than emissions likely to result
from delaying repair?
(f) Either the expected date of repair (if the leak remains unrepaired) or the D Y D N/A D N
date the leak was successfully repaired?
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Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP Section 8
Table 8-2. (continued)
I. Review of Records
18. Does the compliance report document any changes to information originally DY D N/A DN
reported in the notification of compliance status report (or the initial
compliance report, if complying with subpart TT for equipment leaks)?
§§63.8075(e)(8), 63.1018(a)(2)(iv), and 63.1039(b)(8)
Note: Advance notification is required for 3 types of planned changes: any
change in information submitted in the precompliance report, a change in
status of a control device from small to large, and a change in compliance
status.
II. Note All Deficiencies
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