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Shipbuilding and Ship Repair Surface Coating NESHAP Compliance Inspection an Overview

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Shipbuilding and Ship Repair Surface Coating NESHAP Compliance Inspection an Overview Shipbuilding and Ship Repair Surface Coating NESHAP Compliance Inspection How to Perform the Inspection Atlantic Marine, Inc., Mobile, Alabama Shipyard The Waste Reduction Resource Center 1639 Mail Service Center Raleigh, NC 27699-1639 October 15, 2003 Ship Building and Ship Repair Surface Coating NESHAP Compliance Inspection Table of Contents Overview.........................................................................................................................1 Getting Ready for Inspection..........................................................................................4 Pre-Inspection Checklist.................................................................................................6 Inspection........................................................................................................................9 Inspection Checklist......................................................................................................11 Data Collection.............................................................................................................15 Figuring Compliance.....................................................................................................19 P2 Opportunities in Shipyard Coating Operations........................................................24 References.....................................................................................................................31 Tables Table 1. Volatile Organic HAP (VOHAP) Limits for Marine Coatings .......................2 Table 2. Summary of Recordkeeping and Reporting Requirements ...........................14 Table 3. Shipyard Marine Coating Expressions and Equations...................................19 Figures Figure 1. Compliance Options Flow Chart ....................................................................3 Figure 2 Example Shipyard Layout ..............................................................................9 Figure 3. Compliance Procedures Flow Chart.............................................................25 ii Appendices Appendix A National Emission Standards for Hazardous Air Pollutants for Shipbuilding and Ship Repair (Surface Coating) Operations — 40 CFR Part 63 — Federal Register / Vol. 60 / No. 241, p. 64330 Appendix B Conducting Environmental Compliance Inspections, EPA Region 10 Appendix C A Guidebook on How to Comply with the Shipbuilding and Ship Repair (Surface Coating) Operations National Emission Standards for Hazardous Air Pollutants, EPA 453/B-97-001 Appendix D 1. Method 24 – Determination of Volatile Matter Content, Density, Volume of Solids and Weight of Solids of Surface Coatings, EPA-340/1- 91-011 2. Standard Procedure for Collection of Coating and Ink Samples for Analysis by Reference Methods 24 and 24A, EPA-340/1-91-010 Appendix E Accredited Testing Laboratories (showing only laboratories accredited for Clean Air Act (CAA) testing) iii Shipbuilding and Ship Repair Surface Coating NESHAP Compliance Inspection An Overview In November of 1995, the U. S. Environmental Protection Agency (EPA) issued national regulations to control hazardous air pollutant (HAP) materials from shipbuilding and ship repair facilities coating operations that are designated as major sources. The regulation appeared in the December 15, 1995 edition of the Federal Register [volume 60, beginning on page 64330]. Major sources are shipbuilding and repair facilities coating operations emitting over 9.1 mega grams per year (Mg/yr) (10 tons/yr) of an individual HAP or over 23 Mg/yr (25 tons/yr) of total HAP are regulated. Approximately 35 shipyards in the United States are estimated to be major sources of HAP emissions. The table on page C-2, Appendix C lists the U. S shipyards estimated to be NESHAP major sources. Section 112 of the Clean Air Act as amended in 1990 (CAA) requires the EPA to evaluate and control HAP emissions. EPA inspectors may be assigned to inspect shipbuilding and repair facilities to make certain that the location is compliant with the volatile organic hazardous air pollutants (VOHAP) emission limits set forth in the federal regulation cited above. The job of the inspector is to insure that a facility is complying with the emission limits set in the regulations. The determination of compliance may be viewed in the following steps: 1. Preparation for the inspection at the office. 2. An onsite inspection of the selected facility to insure that required records are being kept, proper storage and handling of coatings, employees are properly trained and that coatings as applied do not exceed VOHAP limits. 3. Returning to the office and using the data collected to determine compliance with emissions standards, and other requirements in the rules. 4. Writing a compliance report on the facility. VOHAP limits set by the regulation are summarized in Table 1 for all the types of coatings normally used at shipbuilding and ship repair facilities. VOHAP limits are increased for working at temperatures below 4.5 ˚C (40.1 ˚F). The shipyard is given four options for reporting the VOC or VOHAP contents of coatings as applied. • Option 1 is used for certifying the VOC content of coatings that are used without thinning. • Option 2 is for certifying coatings that have thinner added where compliance is determined on a coating-by-coating basis. • Option 3 is for certifying coatings that are thinned where compliance is determined on a group basis. • Option 4 is similar to Option 1 except that certification is based on the VOHAP content of coatings applied without thinning. 1 TABLE 1. VOLATILE ORGANIC HAP (VOHAP) LIMITS FOR MARINE COATINGS VOHAP limitsa.b.c Grams/liter d coating (minus Grams/liter solids water and exempt T > .5° C T < 4.5° Cc Coating category compounds) G1 General use 340 571 728 Specialty -- -- -- S1 Airflask 340 571 728 S2 Antenna 530 1,439 -- S3 Antifoulant 400 765 971 S4 Heat resistant 420 841 1,069 S5 High-gloss 420 841 1.069 S6 High-temperature 500 1,237 1,597 S7 Inorganic zinc high-build 340 571 728 S8 Military exterior 340 571 728 S9 Mist 610 2,235 -- S10 Navigational aids 550 1,597 -- S11 Nonskid 340 571 728 S12 Nuclear 420 841 1,069 S13 Organic zinc 360 630 802 S14 Pre-treatment wash primer 780 11,095 -- S15 Repair and maint. of thermoplastics 550 1,597 -- S16 Rubber Camouflage 340 571 728 S17 Sealant for thermal spray aluminum 610 2.235 -- S18 Special marking 490 1,178 -- S19 Specialty interior 340 571 728 S20 Tack coat 610 2,235 -- S21 Undersea weapons systems 340 571 728 S22 Weld-through precon. Primer 650 2,885 -- aThe limits are expressed in two sets of equivalent units. Either set of limits may be used for the compliance procedure described in §63.785(c)(1), but only the limits expressed in units of g/L (nonvolatiles) shall be used for the compliance procedures described §63.785(c)(2) through (4) bVOC (including compounds listed as HAP) shall be used as a surrogate for VOHAP for those compliance procedures described in §63.785(c)(1) through (3). cTo convert from g/L to lb/gal, multiply by (3.785 L/gal (1 lb/453.6 g) or 1/120. For compliance purposes, metric units define the standards. dVOHAP limits expressed in units of mass of VOHAPS per volume of solids (nonvolatiles) were derived from the VOHAP limits expressed in units of mass of VOHAP per volume of coating assuming the coatings contain no water or exempt compounds and that the volumes of all components within a coating are additive. eThese limits apply during cold weather time periods, as defined in §63.782. Cold weather allowances are not given to coatings in categories that permit over a 40 percent VOHAP content by volume. Such coatings are subject to the same limits regardless of weather conditions. 2 Compliance options are illustrated by the flow chart in Figure 1. START Determine coating category and VOHAP limit for each batch of coating Use VOHAP for VOC (as a OPTION 4 Certify VOHAP content surrogate) for demonstrating of each batch VOHAP compliance VOC (as a surrogate) Determine YES NO OPTIONS 1-3 Are thinners Determine compliance on a Certify VOC content of ever added to compliance group basis each batch (as the coating? on a coating- supplied) by-coating basis NO YES OPTION 1 OPTION 2 OPTION 3 Figure 1. Compliance options 3 Getting Ready for Inspection An inspector who has not been through recent training or is relatively inexperienced should study EPA Region 10’s training document for inspectors found in Appendix B. Additional comprehensive information for the inspector can also be found in Multi- Media Investigation Manual, US EPA Office of Enforcement EPA-330/9-89-003-R Inspectors are urged to conduct themselves in a professional manner and avoid conflict with the facility personnel. Keep in mind that your visit is simply to gather data to determine if the facility is in compliance. Compliance will be determined when you return to the office and analyze the data. The United States Environmental Protection Agency, Office of Air Quality, Planning and Standards, Research Triangle Park, NC 27711 has issued A Guidebook on How to Comply with the Shipbuilding and Ship Repair (Surface Coating) Operations National Emission Standards for Hazardous Air Pollutants, EPA 453/B-97-001, to instruct shipyards on how to comply with the emissions regulations. The inspector should become thoroughly familiar with this document, which is in Appendix C. The inspector who is not familiar with the shipbuilding and repair industry should review the EPA Sector Notebook, Profile of the Shipbuilding and Repair Industry, EPA/310-R-
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