Title: NSPS APPLICABILITY TO COIL COATING OPERATIONS

Recipient: SWEITZER, TERRY A., IL EPA

Author: KERTCHER, LARRY F., AIR COMPLIANCE BRANCH, REGION V

Date: 09/19/88

Subparts: TT

References: 60.460, 60.463(i)

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The intent of Subpart TT is to regulate the VOCs applied and not the VOCs emitted from application. Also, testing using a temporary enclosure on only the coating applicator discounted the VOCs resulting from the subsequent evaporation of organic solvents in the coating, and does not satisfy the performance test requirements of 40 CFR 60.463(i)(B).

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Terry Sweitzer, P.E.

Manager of Permit Section

Division of Air Pollution Control

Illinois Environmental Protection Agency

P.O. Box 19276

Springfield, Illinois 62794­9276

Dear Mr. Sweitzer:

This letter is in response to your request for review of the applicability and compliance procedures of 40 C.F.R. 60 Subpart TT (60.460­60.466) ­ Standards of Performance for Metal Coil Coaters as applied to coil coating operations at Olin Corporation.

Olin has applied for a permit (Permit No. 72­08­003) to install and operate a coil coater on the #8 strip anneal that will be controlled with an activated carbon filter. The coating station does not have a flash off area or a curing oven. Based on a performance test done using a temporary enclosure on the coating applicator only, the VOC emissions were found to be 0.88 pounds per hour. Olin proposes to control 95% of that amount. However, the total amount of VOCs applied is 5.3 pounds per hour and according to Olin, it can be assumed that all the VOCs will evaporate.

It is U.S. Environmental Protection Agencys interpretation that the intent of 40 C.F.R. 60 Subpart TT is to regulate the VOCs applied and not the VOCs emitted from the application as Olin claims. Also, during the performance test, Olin by having temporary enclosure on the coating applicator only, has discounted the VOCs resulting from the subsequent evaporation or organic solvents in the coating. Based on these facts, U.S. EPA believes that the performance test does not satisfy the requirements of 40 C.F.R. 60 Section 60.463(i)(B).

If you have any questions or comments, please contact Spiros Bourgikos of my staff at (312) 886­6862.

Sincerely yours,

(signed)

Larry F. Kertcher, Chief

Air Compliance Branch (5AC­26)