Paper and Other Web Coating (Subpart JJJJ) Question and Answers (Q&A’s) FINAL 5/29/2003


Paper and Other Web Coating (Subpart JJJJ)

Question and Answers (Q&A's)

FINAL 5/29/2003

This file contains frequently answered questions for part 63, Subpart JJJJ, Paper and
Other Web Coating (POWC) NESHAP. While these questions and answers constitute
the best available information at this time, the EPA recommends that you consult your
State or local air pollution control agency for any final determinations. State and local
agencies may implement provisions that are more stringent than those contained in the
NESHAP.

Index

Question Categories

Page

Compliance Date

1

Applicability

2

Initial Notification

3

Compliance Options

4

Capture System Monitoring

5

Automatic Shutdown Systems

5

Performance Testing

5

Startup, Shutdown and Malfunction Plan

6

Recordkeeping Requirements

7

Reporting Requirements

8

Semiannual Reports

8

Compliance Date

Q1: Section 63.3330(a) lists the compliance date of Subpart JJJJ as December 5, 2005.
The effective date of the rule is December 4, 2002 (also referred to as the promulgation
date or date the final rule was published in the Federal Register). Usually the
compliance date is 3 years after the effective date. Shouldn't the compliance date then
be December 4, 2005?

A1: Although many part 63 rules do use a '3-year" compliance period, compliance dates
do vary. Subpart JJJJ requires existing affected sources to comply by December 5,
2005 (3 years + 1 day). The compliance date for new sources is upon start-up or
December 4, 2002, whichever is later. The proposed rule indicates that "The
compliance date for existing affected sources in this subpart is [INSERT DATE 3 YEARS
AFTER THE DATE OF PUBLICATION OF THE FINAL RULE IN THE FR], The date
three years after December 4, 2002 is December 5, 2005.

-1 -

Note: While these questions and answers constitute
recommends that you consult your State or local air
State and local agencies may implement provisions
NESHAP.

the best available information at this time, the EPA
pollution control agency for any final determinations
that are more stringent than those contained in the

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Applicability

Q2: Are affiliated operations that are performed at web-coating lines covered under
Subpart JJJJ or will they be subject to the Miscellaneous Organic Chemical
Manufacturing NESHAP and the Miscellaneous Coating Manufacturing NESHAP?

A2: As indicated in the final rule preamble (67 FR 72332, II.B), certain affiliated
operations performed at web-coating lines are part of the paper and other web source
category. These affiliated operations include: (1) mixing or dissolving of coating
ingredients prior to application; (2) coating mixing for viscosity adjustment, color tint or
additive blending, or pH adjustment; (3) cleaning of coating lines and coating line parts;
(4) handling and storage of coatings and solvents; (5) and conveyance and treatment of
wastewater. Although they are part of the paper and other web source category,
Subpart JJJJ has not set emission limits or other requirements for these affiliated
operations. These operations will not be covered by the MOCM or MCM NESHAPs.

Affiliated operations that go beyond those described above may be subject to MOCM or
MCM and will be identified as such in the MOCM and MCM rule.

Q3: If a line is added to an existing affected source, is the added line a new source or
an existing source?

A3: As long as you do not trigger reconstruction as defined in 63.2, the additional line
would be an existing source. Section 63.3300 defines an affected source as the
'collection of all web coating lines' at a facility. As discussed in the preamble to the final
rule (67 FR 72332.II.B), a web coating line is defined as any number of workstations.
This means that if your facility had at least one web coating line in existence as of the
proposed rule date (September 12, 2000), any lines that you add are also classified as
part of the existing affected source.

The preamble to the General Provision Amendments (67 FR 16588.11. B.6) published
April 5, 2001 provides additional guidance and indicates that EPA has adopted a
broader definition of affected source is some instances to provide affected sources more
flexibility in apply emission requirements to a larger group of processes, activities and
equipment and may thereby facilitate more innovative and economically efficient control
strategies.

Q4: The definition of fabric in section 63.3310 does not include cord (e.g., for strapping
tape). If the cord is to be used in the same manner as the other fabrics in the definition,
is it subject to Subpart JJJJ?

A4: The POWC rule covers the coating of a fabric substrate for pressure sensitive tape
and abrasive materials. The definition of fabric in §63.3310 includes non-woven
materials. This includes cord and thread. Therefore, if the coating of the cord is for use
in pressure sensitive or abrasive materials then it would be covered under subpart JJJJ.

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

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Q5: The preamble to the final rule (67 FR 72331 .II.A and 72332.II.B) and section
63.3300(e) indicate that coil coating is excluded from Subpart JJJJ except for certain
flexible packaging coating of metal or metallized substrate (by this we mean that the
metal or metallized substrate coating would be covered under Subpart JJJJ, not the
Metal Coil Coating NESHAP). Does this exemption include similar metal or metallized
web/substrate sensitive tape coating operations or coating of fabric used in flexible
packaging?

A5: During the public comment period we became aware of coated metal substrates
that meet the definition for metal coil and which are used in flexible packaging. The web
coating operations for this type of substrate are part of the POWC source category and
were included in the database used to develop the emission limits in subpart JJJJ.
Section 63.3300 specifies that web coating lines engaged in the coating of metal webs
that are used in flexible packaging are part of the affected source under subpart JJJJ,
and not under the Metal Coil NESHAP. The intent of the subpart JJJJ is to cover similar
web coating lines. Therefore, web coatings lines that are engaged in the coating of metal
webs that are used in pressure sensitive tape are also part of the affected source under
subpart JJJJ.

In addition, we also became aware of coating of fabric used in flexible packaging
operations and addressed this issue in the newly promulgated Fabric, Printing, Coating
and Dyeing NESHAP (Subpart OOOO). In accordance with Section 63.4281 (68 FR
32171, 5/29/03), "Web coating lines specified in paragraphs (d)(1) through (3) of this
section are not part of the affected source of this subpart. (1) Any web coating operation
that is part of the affected source of subpart JJJJ of this part (national emission
standards for hazardous air pollutants for paper and other web coating). This would
include any web coating line that coats both a paper and other web substrate and a
fabric or other textile substrate for use in flexible packaging, pressure sensitive tape and
abrasive materials, or any web coating line laminating a fabric substrate to paper. The
intent of the subpart JJJJ is to cover similar web coating lines.

Q6: Section 63.3321 indicates that for any web coating lines where you use an add-on
control device (other than solvent recovery where liquid-liquid material balances are
performed), you must comply with section 63.3321. Where voluntary control devices are
used, must they comply with Subpart JJJJ?

A6: No, voluntary control devices do not have to comply with the requirements in
Subpart JJJJ. Voluntary control devices would only be considered voluntary if the
affected source is otherwise in compliance. This means that voluntary control devices
do not have to comply as long as the affected source demonstrates that JJJJ emission
limits under section 63.3370 are met independently of those control devices.

Initial Notification

Q7: Section 63.3400(b)(1) requires that existing affected sources submit an initial
notification no later than 1 year before the compliance date. Section 63.3400(b)(2)
requires new sources to submit an initial notification in accordance with section 63.9(b).
If my affected source began construction after the proposal of Subpart JJJJ (new

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

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source) but had an initial startup prior to the effective date, when must I submit an initial
notification?

A7: You should follow section 63.9(b)(2) if your affected source has an initial startup
before the effective date of Subpart JJJJ. Under 63.9(b)(2), you are required to submit
an initial notification within 120 calendar days after the effective date (December 4,
2002) or within 120 calendar days after the source becomes subject to the relevant
standard. As indicated in the preamble to Subpart JJJJ (67 FR 72334.VI.A), new or
reconstructed affected sources must submit their initial notification no later than 120
days after either the date of the initial startup or December 4, 2002, whichever is later.

Q8: Section 63.3400(b)(2) refers to 63.9(b) of Subpart A, General Provisions, for initial
notifications for new & reconstructed sources that become subject after the effective
date of the standard. Provisions under 63.9(b)(3) that address these types of sources
were removed April 5, 2002 with the Final Rule amendments. What requirements for
submitting initial notifications must a new or reconstructed source now follow?

A8: Section 63.9(b)(3) of the General Provisions was reserved with publication of the
Final Rule Amendments April 5, 2002. New or reconstructed sources should follow
63.9(b)(4) or (5) for their initial notification requirements depending on if the source is
required to submit an application for approval of construction or reconstruction under
63.5(d). Major emitting new source that begin construction after the effective date of the
standard are required to submit an application of approval of construction or
reconstruction as soon as practical before the actual construction and reconstruction
begins in accordance with section 63.5(d)(1)(i). Sources not required to submit an
application for approval of construction or reconstruction should submit their initial
notification in accordance with section 63.5(b)(4). Section 63.5(b)(4) references 63.9(b).
Section 63.9(b)(5) requires submittal [checking]

Compliance Options

Q9: In the preamble to the final standard (67 FR72333, 111 .A) it indicates that the 20 ppm
alternative compliance option is available to sources "using a thermal oxidizer." This
would preclude this option from being used for catalytic oxidizers. Section 63.3320(b)(4)
of the final rule indicates a more inclusive term "oxidizers." Can catalytic oxidizers use
the 20 ppm option?

A9: Yes catalytic oxidizers may use the 20 ppm compliance demonstration. We did not
intend to limit the requirements in section 63.3320(b)(4) when we used the term
"thermal" oxidizer in the preamble. We were responding to a specific comment we
received on thermal oxidizers. Affected sources that use any type of oxidizer to comply
with the emission limits under Subpart JJJJ may use the option to maintain an outlet
organic HAP concentration of less than 20ppm by volume by compound on a dry basis
option as long as the affected source maintains a capture efficiency of 100% during the
covered web-coating operation.

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

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Capture System Monitoring

Q10: Section 63.3350(f)(5) of the rule requires that facilities must review and update the
capture system monitoring plan at least annually. What if no update was necessary?

A10: You may simply document in whatever fashion is appropriate that you have
reviewed the plan as required under section 63.3350(f)(5) and no updates were
necessary).

Automatic Shutdown Systems

Q11: Section 63.3350(c) requires that if you operate web coating lines with
intermittently-controlled work stations, you must monitor bypasses of the control device
and the mass of each coating material applied at the work station during any such
bypass. Section 63.3350(c)(4) allows for an automatic shutdown system to be used as
an option for demonstrating compliance with this requirement. Section 63.3550(c)(4)
indicates that the shutdown system must be one in which the web coating line is stopped
when the flow is directed away from the control device.

We have two situations where automatic shutdown systems exist. One system will not
allow the coating line to operate if the damper position is not in a position where it is
vented to a control device while solvent based coatings are applied. The other shuts
down the coating line automatically if other parameters such as set point concentration
of Lower Explosive Limit (LEL) in a bypass vent line are exceeded. Are these
considered "shutdown systems" that meet the intent of section 63.3350(c)(4)?

A11: Yes the two systems described in the above paragraph would be considered
automatic shutdown systems as described in § 63.335 (c) (4).

Performance Testing

Q12: Section 63.3360(c) allows a facility to determine organic HAP content using one of
the procedures in section 63.3360(c)(1) - (3). Under section 63.3360(c)(1 )(i), if you use
Method 311, you must include each organic HAP in quantities greater than or equal to
0.1 mass percent for carcinogens and greater than or equal to 1.0 mass percent for
other organic Hap compounds, as defined by OSHA. Another compliance option is
section 63.3360(c)(3) which allows the use of formulation data to provide information on
HAP quantities. Can manufacturers formulation data (based on "as purchased"
information) also be used to determine HAP quantities under 63.3360(c)(1)(i) or are
these quantities derived from some other means?

A12: Yes, manufacturers formulation data (based on "as purchased" information) can
also be used to determine HAP quantities under 63.3360(c)(1 )(i). The definition of
formulation data in §63.3310 states that Formulation data means data on the organic
HAP mass fraction, volatile matter mass fraction, or coating solids mass fraction of a
material that is generated by the manufacturer or means other than a test method
specified in this subpart or an approved alternative method.

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

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Q13: Can existing performance test data/operating limits be used to fulfill the
requirements for establishing control device efficiency and capture efficiency under
sections 63.3360(e), and (f)?

A13: Unless specified in a regulation, the EPA does not generally allow the use of
existing or past performance test data to establish operating limits, control device
efficiency or capture efficiency. Performance tests associated with the MACTs must be
conducted in accordance with the requirements of the applicable Standard. These tests
establish that the source is capable of complying with the rule and are used to establish
the operating limits that the source will monitor to demonstrate compliance. In addition,
it is important to provide an opportunity for state/regional personnel to witness these
tests whenever possible. To accept existing or past test data eliminates EPA/state
ability to witness the tests and pre-approve test plans. In addition, existing test data may
be old and no longer representative of the sources operations. Sources have the ability
to request a test waiver under 63.7(h). EPA can consider those requests on a case by
case basis.

Startup, Shutdown and Malfunction Plan

Q14: The preamble to the final rule (67 FR 72335.VI.E, 4th bullet) requires you to notify
the EPA when the actions taken during a startup, shutdown or malfunction of an
emission control device are consistent with the SSM Plan. This is inconsistent with
section 63.3400(g).

A14: We did not intend to use the term consistent in the preamble of the rule. Startup,
shutdown and malfunction (SSM) reports should be submitted in accordance with
63.3400(g) and Table 2 of the rule to determine which General Provision requirements
affect you. Under Table 2, sources subject to Subpart JJJJ are also subject to section
63.10(d)(5) of the General Provisions. This section governs the reporting of SSM.

Section 63.10(d)(5)(i) of the General Provisions requires that that if actions taken by an
owner or operator during SSM are consistent with the procedures specified in the
SSMP, the owner or operator shall state such information in the SSM report. As
indicated in the preamble (67 FR 72335, E), sources who's actions are consistent with
their SSMP may report such actions semiannually.

However, if actions taken are not consistent with your SSMP, then the facility must
report such actions immediately as required under section 63.3400(g) and 63.10(d)(5).
Section 63.10(d)(5)(ii) states that if actions taken by an owner or operator during SSM
are not consistent with the procedures specified in the SSMP, the owner or operator
must report the actions taken for that event within 2 working days after commencing
actions inconsistent with the plan followed by a letter within 7 working days after the end
of the event.

Recordkeeping Requirements

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Q15: The compliance date of the rule is December 4, 2005. If we are complying with
the monthly average emission limit for "as-applied" coating materials under section
63.3370(a)(2), when is the first monthly compliance demonstration required?

A15: As defined in 63.3310, Month means a calendar month or a pre-specified period of
28 days to 35 days to allow for flexibility in recordkeeping when data are based on a
business accounting period.

December 2004 will be your initial monthly compliance period. Although the compliance
date for Subpart JJJJ falls after the first of the month, the compliance date still falls
within the 28-35 day guideline. Therefore, your initial monthly compliance period will be
from December 4, 2005 through December 31, 2005.

Although the rule does not specify by which date you must have your monthly
compliance demonstration completed, the Summary of Public Comments and
Responses on the Proposed Rule, November 2002, EPA-453/R-02-005, page 2-36
addresses this issue. As the following excerpt from the response to comments
indicates, the deadline for compliance demonstration is allowed up to the end of the
following month:

Comment: Given the volume of data and calculations necessary to demonstrate
compliance, several commenters ... proposed allowing up to the end of the following
month as a deadline for when monthly compliance must be demonstrated.

Response: The proposed rule requires that compliance be demonstrated each
month (see 63.3370). Because you would need a complete month of data to perform
the compliance demonstration calculations, the month must be over before all of
these data are available. Thus, the compliance demonstration must be performed
during the following month. Because the proposed rule does not specify any
requirements in conflict with the commenters' statement, we made no changes to the
final rule in response to these comments.

Q16: Section 63.3350(c)(1) requires that the position of the flow control indicator must
be logged in hourly when an intermittently controlled work station is applying water
based coatings. Why is an hourly reading required?

A16: Section 63.3350(c) requires the monitoring of control device bypasses. Four
monitoring options are provided in 63.3350(c)(1)-(4). Section 63.3350(c)(1) provides the
option of installation, calibration, operation, maintenance and monitoring of flow control
position indicators. Of the monitoring options provided, this device presents a greater
potential for the control device to be bypassed. Consequently, this device has the more
frequent hourly monitoring requirement. Sections 63.3550(c)(2)-(4) provide other
monitoring options that provide greater assurance that the control device will not be
bypassed. These devices are required to be monitored once per month.

Reporting Requirements

Q17: In the preamble to the final rule (67 FR 72335.VI.E, second bullet), it indicates that
you must report material balance calculations for all months when the material balances

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deviate from the emission limit. If the material balance calculations are being used to
determine efficiency of the solvent recovery unit, why must they be reported?

A17: In accordance with section 63.3330(e)(2), if you use liquid-liquid material balance
to comply with the emission standard, then you must install a device that indicates the
cumulative amount of volatile matter recovered by the solvent recovery device on a
monthly basis. You will use these values in your compliance demonstration under
section 63.3370(i).

Section 63.3370(i)(1) allows you to show compliance with the emission limit by using a
liquid-liquid material balance. If your monthly mass balance calculations show that you
do not meet one of the requirements specified in section 63.3370(i)(1)(x), then you have
deviated from the requirements of Subpart JJJJ and should report such deviations in
your semiannual report.

At a minimum, you should include in your report the final value of your mass-balance
calculation and the specific values you used in your calculations. Provide at least one
example calculation on how you determined your mass balance using the values you
provided in the report.

Semiannual Reports

Q18: Section 63.3400(c) indicates that the first semiannual report for existing sources
covers the period beginning on the compliance date and ending on June 30 or
December 31, whichever date is the first date following the end of the calendar half
immediately following the compliance date. Does this mean the initial compliance report
under Subpart JJJJ should include information from December 5 through December 31
(which is the period immediately following the compliance date), or does the initial
semiannual report include the first 6 months of compliance information and thus should
cover the period from December 5 through June 30?

A18: Semiannual reports should cover a 6 month period of continuous compliance.

This means that the first compliance report required under section 63.3400(c)(1) should
cover the period between December 5, 2005 and June 30, 2006. The report should be
submitted by July 31, 2006. The next semiannual compliance reports would then cover
the period between July 1, 2006 and December 31, 2006 with a submittal date of
January 31, 2007.

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Note: While these questions and answers constitute the best available information at this time, the EPA
recommends that you consult your State or local air pollution control agency for any final determinations
State and local agencies may implement provisions that are more stringent than those contained in the
NESHAP.

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