§ 129.104. Compliance procedures and monitoring requirements.
(a) Compliance methods. An owner or operator of a facility subject to the emission standards in § 129.102 (relating to emission standards) shall demonstrate compliance with those provisions by using one or more of the following methods:
(1) To support that each sealer, topcoat and strippable spray booth coating meets the requirements of § 129.102(1) (relating to emission standards):
(i) Maintain CPDSs for each of the coatings.
(ii) Maintain documentation showing the VOC content of the as applied coating in lbs VOC/lb solids, if solvent or other VOC is added to the coating before application.
(iii) Perform sampling and testing in accordance with the procedures and test methods in Chapter 139 (relating to sampling and testing).
(2) To comply through the use of a control system as described in § 129.102(3):
(i) Calculate the required overall control efficiency needed to demonstrate compliance using the following equation:
O = (1 - E/C) x 100 Where:
C = the VOC content of the as applied coating, lbs VOC/lb solids
E = the Table IV emission limit which shall be achieved by the affected emission point(s), lbs VOC/lb solids
O = the overall control efficiency of the control system, expressed as a percentage
(ii) Document that the value of C in the equation in subparagraph (i) is obtained from the VOC and solids content of the as applied coating.
(iii) Determine the overall control efficiency of the control system using the procedures and test methods in Chapter 139 and demonstrate that the value of O calculated by the following equation is equal to or greater than the value of O calculated by the equation in subparagraph (i):
O = (F x N) (100) Where:
F = the control device efficiency, expressed as a fraction
N = the capture device efficiency, expressed as a fraction
(b) Initial compliance.
(1) Compliant coatings. An owner or operator of a facility subject to § 129.102(1) that is complying through the procedures in subsection (a)(1) shall submit an initial compliance status report as required by § 129.106(a) (relating to reporting requirements), stating that compliant sealers, topcoats and strippable spray booth coatings are being used by the facility.
(2) Continuous coaters. An owner or operator of a facility subject to § 129.102(1) that is complying through the procedures in subsection (a)(1) and is applying sealers, topcoats, or both, using continuous coaters shall demonstrate initial compliance by either:
(i) Submitting an initial compliance status report as required by § 129.106(a) stating that compliant sealers, topcoats, or both, as determined by the VOC content of the coating in the reservoir and as calculated from records, are being used.
(ii) Submitting an initial compliance status report as required by § 129.106(a) stating that compliant sealers, topcoats, or both, as determined by the VOC content of the coating in the reservoir, are being used and the viscosity of the coating in the reservoir is being monitored. The facility shall also provide data that demonstrates the correlation between the viscosity and the VOC content of the coating in the reservoir.
(3) Control systems. An owner or operator of a facility using a control system to comply with this section and § § 129.101—129.103 and 129.105—129.107 shall demonstrate initial compliance by submitting a report to the Department that:
(i) Identifies the operating parameter value to be monitored for the capture device and discusses why the parameter is appropriate for demonstrating ongoing compliance.
(ii) Includes the results of the initial performance testing using the procedures and test methods specified in Chapter 139.
(iii) Includes calculations of the overall control efficiency (O) using the equation in subsection (a)(2)(iii).
(iv) Defines those operating conditions of the control system critical to determining compliance and establishes operating parameter values that will ensure compliance with the standard:
(A) For compliance with a thermal incinerator, minimum combustion temperature shall be the operating parameter value.
(B) For compliance with another control system, the operating parameter value shall be established using the procedures identified in subsection (c)(3)(iv).
(v) An owner or operator of a facility complying with this paragraph shall calculate the site-specific operating parameter value as the arithmetic average of the maximum or minimum operating parameter values, as appropriate, that demonstrate compliance with the standards, using the procedures in Chapter 139.
(4) Work practice implementation plan. An owner or operator of a facility subject to the work practice standards of § 129.103 (relating to work practice standards) shall submit an initial compliance status report as required by § 129.106(a), stating that the work practice implementation plan has been developed and procedures have been established for implementing the provisions of the plan.
(c) Continuous compliance demonstrations. An owner or operator of a facility subject to the requirements of this section and § § 129.101—129.103 and 129.105—129.107 shall submit, in writing, to the Department a compliance certification with the semiannual report required by § 129.106(b).
(1) Compliant coatings. An owner or operator of a facility subject to § 129.102 that is complying through the procedures specified in subsection (a)(1) shall demonstrate continuous compliance by the following:
(i) Using compliant coatings.
(ii) Maintaining records that demonstrate the coatings are compliant.
(iii) Submitting a compliance certification which states that compliant sealers, topcoats, or both, and strippable spray booth coatings have been used each day in the semiannual reporting period or should otherwise identify the days of noncompliance and the reasons for noncompliance.
(2) Continuous coaters. An owner or operator of a facility subject to § 129.102 that is complying through the procedures specified in subsection (a)(1) and is applying sealers, topcoats, or both, using continuous coaters shall demonstrate continuous compliance by either:
(i) Using compliant coatings as determined by the VOC content of the coating in the reservoir and as calculated from records, and submitting a compliance certification which states that compliant sealers, topcoats, or both, have been used each day in the semiannual reporting period or should otherwise identify the days of noncompliance and the reasons for noncompliance.
(ii) Using compliant coatings, as determined by the VOC content of the coating in the reservoir, maintaining a viscosity of the coating in the reservoir that is no less than the viscosity of the initial coating by monitoring the viscosity with a viscosity meter or by testing the viscosity of the initial coating and retesting the viscosity of the coating in the reservoir each time solvent is added, maintaining records of solvent additions and submitting a compliance certification which states that compliant sealers, topcoats, or both, as determined by the VOC content of the coating in the reservoir, have been used each day in the semiannual reporting period. Additionally, the certification shall state that the viscosity of the coating in the reservoir has not been less than the viscosity of the initial coating, that is, the coating that is initially mixed and placed in the reservoir, for any day in the semiannual reporting period or should otherwise identify the days of noncompliance and the reasons for noncompliance.
(3) Control systems. An owner or operator of a facility subject to § 129.102 that is complying through the use of a control system shall demonstrate continuous compliance by the following:
(i) Installing, calibrating, maintaining and operating monitoring equipment approved, in writing, by the Department.
(ii) Using a device to monitor the site-specific operating parameter value established in accordance with subsection (b)(3)(i).
(iii) When a thermal incinerator is used, a temperature monitoring device equipped with a continuous recorder is required and shall be installed in the firebox or in the ductwork immediately downstream of the firebox at a location before any substantial heat exchange occurs.
(iv) An owner or operator using a control system not listed in this section shall submit, in writing, to the Department a description of the system, test data verifying the performance of the system, the appropriate operating parameter values that will be monitored and the monitoring device that will be used to demonstrate continuous compliance with the standard and receive, in writing, the Department’s approval prior to use.
(v) An owner or operator of a facility may not operate the control system at a daily average value greater than or less than (as appropriate) the operating parameter value. The daily average value shall be calculated as the average of all values for a monitored parameter recorded during the operating day.
(vi) Submitting a compliance certification which states that the control system has not been operated at a daily average value greater than or less than (as appropriate) the operating parameter value for each day in the semiannual reporting period or should otherwise identify the days of noncompliance and the reasons for noncompliance.
(4) Work practice implementation plan. An owner or operator of a facility subject to the work practice standards of § 129.103 shall demonstrate continuous compliance by following the work practice implementation plan and submitting a compliance certification which states that the work practice implementation plan is being followed, or should otherwise identify the periods of noncompliance with the work practice standards and the reasons for noncompliance.
(d) Compliance certification requirements. The compliance certification shall be signed by a responsible official of the company that owns or operates the facility. In addition to the certification requirements of this section, the certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the documents are true, accurate and complete.
Authority The provisions of this § 129.104 issued under section 5(a)(1) of the Air Pollution Control Act (35 P.S. § 4005(a)(1)).
Source The provisions of this § 129.104 adopted June 9, 2000, effective June 10, 2000, 30 Pa.B. 2995.
Cross References This section cited in 25 Pa. Code § 121.1 (relating to definitions); 25 Pa. Code § 129.52c (relating to control of VOC emissions from flat wood paneling surface coating processes); 25 Pa. Code § 129.91 (relating to control of major sources of NOx and VOCs); 25 Pa. Code § 129.96 (relating to applicability); 25 Pa. Code § 129.101 (relating to general provisions and applicability); 25 Pa. Code § 129.102 (relating to emission standards); 25 Pa. Code § 129.103 (relating to work practice standards); 25 Pa. Code § 129.105 (relating to recordkeeping requirements); 25 Pa. Code § 129.106 (relating to reporting requirements); 25 Pa. Code § 129.107 (relating to special provisions for facilities using an emissions averaging approach); and 25 Pa. Code § 129.111 (relating to applicability).
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