NR 465.28(1)(b)3.
3. Complete the compliance demonstration for the initial compliance period according to the requirements of
sub. (2). The initial compliance period begins on the applicable compliance date specified in
s. NR 465.21 (4) and ends on the last day of the first full month after the compliance date, or the date you conduct the performance tests of the emission capture systems and add-on control devices, or initiate the first liquid-liquid material balance for a solvent recovery system; whichever is later. The initial compliance demonstration includes the results of emission capture system and add-on control device performance tests conducted according to
subs. (5) to
(7); results of liquid-liquid material balances conducted according to
sub. (2) (g); calculations according to
sub. (2) and supporting documentation showing that, during the initial compliance period, the organic HAP emission rate was equal to or less than the emission limit in
s. NR 465.23 (1) (b); the operating limits established during the performance tests and the results of the continuous parameter monitoring required by
sub. (9); and documentation of whether you developed and implemented the work practice plan required by
s. NR 465.23 (4).
NR 465.28(1)(b)4.
4. Maintain a log detailing the operation and maintenance of the emission capture system, add-on control device and continuous parameter monitors during the period between the compliance date and the performance test conducted as specified in
subd. 1. Begin complying with the operating limits for your affected source on the date you complete the performance tests specified in
subd. 1. You do not need to comply with the operating limits for the emission capture system and add-on control device required by
s. NR 465.23 (3) until after you have completed the performance tests specified in
subd. 1. This requirement does not apply to solvent recovery systems for which you conduct liquid-liquid material balances according to
sub. (2) (g).
NR 465.28(2)
(2) How do I demonstrate initial compliance?. You may use the emission rate with add-on controls option for any coating operation, for any group of coating operations in the affected source or for all of the coating operations in the affected source. You may include both controlled and uncontrolled coating operations in a group for which you use this option. You shall use either the compliant material option or the emission rate without add-on controls option for any coating operation or operations in the affected source for which you do not use this option. To demonstrate initial compliance, the coating operation or operations for which you use the emission rate with add-on controls option shall meet the applicable emission limit in
s. NR 465.23 (1) and the work practice standards required in
s. NR 465.23 (4), and each controlled coating operation shall meet the operating limits required in
s. NR 465.23 (3). When calculating the organic HAP emission rate according to this subsection, do not include any coatings, thinners or cleaning materials used on coating operations for which you use the compliant material option or the emission rate without add-on controls option. You do not need to redetermine the mass of organic HAP in coatings, thinners or cleaning materials that have been reclaimed onsite and reused in the coating operation or operations for which you use the emission rate with add-on controls option. You shall meet all of the following requirements to demonstrate initial compliance with the emission limitations:
NR 465.28(2)(a)
(a) Except as provided in
sub. (1) (b) 4. and except for solvent recovery systems for which you conduct liquid-liquid material balances according to the requirements of
par. (g), establish and demonstrate continuous compliance during the initial compliance period with the operating limits required by
s. NR 465.23 (3), using the procedures specified in
subs. (8) and
(9).
NR 465.28(2)(c)
(c) Follow the procedures specified in
s. NR 465.27 (2) (a) to
(d), to determine the mass fraction of organic HAP, density and volume of each coating, thinner and cleaning material used during the compliance period, and the volume fraction of coating solids for each coating used during the compliance period.
NR 465.28(2)(d)
(d) Using Equation 1 in
s. NR 465.27 (2), calculate the total mass of organic HAP emissions before add-on controls from all coatings, thinners and cleaning materials used during the compliance period in the coating operation or group of coating operations for which you use the emission rate with add-on controls option.
NR 465.28(2)(e)
(e) Determine the mass of organic HAP emissions reduced for each controlled coating operation during the compliance period. The emissions reduction determination quantifies the total organic HAP emissions that pass through the emission capture system and are destroyed or removed by the add-on control device. Use the procedures in
par. (f) to calculate the mass of organic HAP emissions reduction for each controlled coating operation using an emission capture system and add-on control device other than a solvent recovery system for which you conduct liquid-liquid material balances. For each controlled coating operation using a solvent recovery system for which you conduct a liquid-liquid material balance, use the procedures in
par. (g) to calculate the organic HAP emissions reduction.
NR 465.28(2)(f)
(f) For each controlled coating operation using an emission capture system and add-on control device other than a solvent recovery system for which you conduct liquid-liquid material balances, calculate the organic HAP emissions reduction by applying the emission capture system efficiency and add-on control device efficiency to the mass of organic HAP contained in the coatings, thinners and cleaning materials that are used in the coating operation served by the emission capture system and add-on control device during the compliance period. For any period of time a deviation specified in
sub. (4) (c) or
(d) occurs in the controlled coating operation, including a deviation during a period of startup, shutdown or malfunction, you shall assume zero efficiency for the emission capture system and add-on control device. For the purposes of completing the compliance calculations, you shall treat the materials used during a deviation on a controlled coating operation as if they were used on an uncontrolled coating operation for the time period of the deviation. You may not include those materials in the calculations of organic HAP emissions reduction in Equation 1. The organic HAP emissions reduction shall be calculated using the following equations:
(Equation 1)
where:
Hc is the mass of organic HAP emissions reduction for the controlled coating operation during the compliance period, kg
AI is the total mass of organic HAP in the coatings used in the controlled coating operation, kg, as calculated in Equation 1A
BI is the total mass of organic HAP in the thinners used in the controlled coating operation, kg, as calculated in Equation 1B
CI is the total mass of organic HAP in the cleaning materials used in the controlled coating operation during the compliance period, kg, as calculated in Equation 1C
CE is the capture efficiency of the emission capture system vented to the add-on control device, percent. Use the test methods and procedures specified in subs. (5) and (6) to measure and record capture efficiency.
DRE is the organic HAP destruction or removal efficiency of the add-on control device, percent. Use the test methods and procedures in subs. (5) and (6) to measure and record the organic HAP destruction or removal efficiency.
(Equation 1A)
where:
AI is the mass of organic HAP in the coatings used in the controlled coating operation, kg
Volc,i is the total volume of coating, i, used, liters
Dc,i is the density of coating, i, kg per liter
Wc,i is the mass fraction of organic HAP in coating, i, kg per kg
m is the number of different coatings used
(Equation 1B)
where:
BI is the mass of organic HAP in the thinners used in the controlled coating operation, kg
Volt,j is the total volume of thinner, j, used, liters
Dt,j is the density of thinner, j, kg per liter
Wt,j is the mass fraction of organic HAP in thinner, j, kg per kg
n is the number of different thinners used
(Equation 1C)
where:
CI is the mass of organic HAP in the cleaning materials used in the controlled coating operation, kg
Vols,k is the total volume of cleaning material, k, used, liters
Ds,k is the density of cleaning material, k, kg per liter
Ws,k is the mass fraction of organic HAP in cleaning material, k, kg per kg
p is the number of different cleaning materials used
NR 465.28(2)(g)
(g) For each controlled coating operation using a solvent recovery system for which you conduct liquid-liquid material balances, calculate the organic HAP emissions reduction by applying the volatile organic matter collection and recovery efficiency to the mass of organic HAP contained in the coatings, thinners and cleaning materials that are used in the coating operation controlled by the solvent recovery system during the compliance period. The mass of organic HAP emission reduction by the solvent recovery system shall be calculated using the following procedures and equations:
NR 465.28(2)(g)1.
1. For each solvent recovery system, install, calibrate, maintain and operate according to the manufacturer's specifications, a device that indicates the cumulative amount of volatile organic matter recovered by the solvent recovery system each compliance period. The device shall be initially certified by the manufacturer to be accurate to within
±2.0% of the mass of volatile organic matter recovered.
NR 465.28(2)(g)2.
2. For each solvent recovery system, determine the mass of volatile organic matter recovered for the compliance period, kg, based on measurement with the device required in
subd. 1.
NR 465.28(2)(g)3.
3. Determine the mass fraction of volatile organic matter for each coating used in the coating operation controlled by the solvent recovery system during the compliance period, kg volatile organic matter per kg coating. You may determine the volatile organic matter mass fraction using Method 24 in
40 CFR part 60, Appendix A, incorporated by reference in
s. NR 484.04 (13), or an EPA approved alternative method, or you may use information provided by the manufacturer or supplier of the coating. In the event of any inconsistency between information provided by the manufacturer or supplier and the results of Method 24, or an approved alternative method, the test method results will govern.
NR 465.28(2)(g)4.
4. Determine the density of each coating, thinner and cleaning material used in the coating operation controlled by the solvent recovery system during the compliance period, kg per liter, according to
s. NR 465.27 (2) (c).
NR 465.28(2)(g)5.
5. Measure the volume of each coating, thinner and cleaning material used in the coating operation controlled by the solvent recovery system during the compliance period, liters.
NR 465.28(2)(g)6.
6. Calculate the solvent recovery system's volatile organic matter collection and recovery efficiency, using the following equation:
(Equation 2)
where:
RV is the volatile organic matter collection and recovery efficiency of the solvent recovery system during the compliance period, percent
MVR is the mass of volatile organic matter recovered by the solvent recovery system during the compliance period, kg
Voli is the volume of coating, i, used in the coating operation controlled by the solvent recovery system during the compliance period, liters
Di is the density of coating, i, kg coating per liter coating
CVi is the mass fraction of volatile organic matter for coating, i, kg volatile organic matter per kg coating
Volj is the volume of thinner, j, used in the coating operation controlled by the solvent recovery system during the compliance period, liters
Dj is the density of thinner, j, kg thinner per liter thinner
Volk is the volume of cleaning material, k, used in the coating operation controlled by the solvent recovery system during the compliance period, liters
Dk is the density of cleaning material, k, kg cleaning material per liter cleaning material
m is the number of different coatings used in the coating operation controlled by the solvent recovery system during the compliance period
n is the number of different thinners used in the coating operation controlled by the solvent recovery system during the compliance period
p is the number of different cleaning materials used in the coating operation controlled by the solvent recovery system during the compliance period
NR 465.28(2)(g)7.
7. Calculate the mass of organic HAP emissions reduction for the coating operation controlled by the solvent recovery system during the compliance period, using the following equation:
(Equation 3)
where:
HCSR is the mass of organic HAP emissions reduction for the coating operation controlled by the solvent recovery system using a liquid-liquid material balance during the compliance period, kg
AI is the total mass of organic HAP in the coatings used in the coating operation controlled by the solvent recovery system, kg, calculated using Equation 1A in par. (f)
BI is the total mass of organic HAP in the thinners used in the coating operation controlled by the solvent recovery system, kg, calculated using Equation 1B in par. (f)
CI is the total mass of organic HAP in the cleaning materials used in the coating operation controlled by the solvent recovery system, kg, calculated using Equation 1C in par. (f)
RV is the volatile organic matter collection and recovery efficiency of the solvent recovery system, percent, from Equation 2 in subd. 6.
NR 465.28(2)(h)
(h) Determine the total volume of coating solids used, liters, which is the combined volume of coating solids for all the coatings used during the compliance period, using Equation 2 in
s. NR 465.27 (2) (f).
NR 465.28(2)(i)
(i) Determine the organic HAP emission rate to the atmosphere, kg organic HAP per liter coating solids used during the compliance period, using the following equation:
(Equation 4)
where:
HHAP is the organic HAP emission rate to the atmosphere during the compliance period, kg organic HAP per liter coating solids used
He is the total mass of organic HAP emissions before add-on controls from all the coatings, thinners and cleaning materials used during the compliance period, kg, determined according to par. (d)
HC,i is the total mass of organic HAP emissions reduction for controlled coating operation, i, during the compliance period, kg, from Equation 1 in par. (f)
HCSR,j is the total mass of organic HAP emissions reduction for controlled coating operation, j, during the compliance period, kg, from Equation 3 in par. (g)
V
st is the total volume of coating solids used during the compliance period, liters, from Equation 2 in
s. NR 465.27 (2) (f)
q is the number of controlled coating operations except those controlled with a solvent recovery system
r is the number of coating operations controlled with a solvent recovery system
NR 465.28(2)(j)
(j) Demonstrate initial compliance with the emission limit, by ensuring that the organic HAP emission rate calculated using Equation 4 in
par. (i), is less than or equal to the applicable emission limit in
s. NR 465.25 (3). Keep all records as required by
s. NR 465.25 (3) and
(4). As part of the notification of compliance status required by
s. NR 465.25 (1), identify the coating operation or operations for which you used the emission rate with add-on controls option and submit a statement that the coating operation or operations was or were in compliance with the emission limitations during the initial compliance period because the organic HAP emission rate was less than or equal to the applicable emission limit in
s. NR 465.23 (1), and you achieved the operating limits and the work practice standards required by
s. NR 465.23 (3) and
(4) respectively.
NR 465.28(4)
(4) How do I demonstrate continuous compliance with the emission limitations?. NR 465.28(4)(a)(a) To demonstrate continuous compliance with the applicable emission limit in
s. NR 465.23 (1), the organic HAP emission rate for each compliance period determined according to the procedures in
sub. (2) shall be equal to or less than the applicable emission limit in
s. NR 465.23 (1). Each month following the initial compliance period described in
sub. (1) is a compliance period.
