Permit Appendix H for 40 CFR pt. 63, subp. QQQQ
Contents of this appendix:
- Equations for Compliant Material Option Requirements
o Volume fraction calculation
§ Equation QC1: Volume fraction of coating solids
o Organic HAP content calculation
§ Equation QC2: Organic HAP content of a coating
- Equations for Emission Rate without Add-On Controls Option Requirements
o Volume fraction calculation
§ Equation QC1: Volume fraction of coating solids
o Organic HAP Emissions
§ Equation QE3: Organic HAP emission calculations (includes supporting Equations QE3-A, QE3-B, and QE3-C)
o Total Volume Calculation
§ Equation QE4: Total volume of coating solids used per month
o Organic HAP Emission Rate
§ Equation QE5: Organic HAP emission rate for 12-month period
- Tables for Mass fraction determination for solvent blends (for both compliance options)
o Table 5: Default organic HAP mass fraction for solvents and solvent blends
o Table 6: Default organic HAP mass fraction for petroleum solvent groups
H.1 Volume Fraction calculation
40 CFR Section 63.4741(b)(3); 40 CFR Section 63.4751(b); Minn. R. 7011.8000
Calculation of volume fraction of coating solids. If the volume fraction of coating solids cannot be determined using the ASTM methods or Information from supplier or manufacturer, as specified in the Volume Fraction requirement of the permit, the Permittee shall determine the volume fraction of coating solids by using the following equation (Equation QC1):
Equation QC1: Vs = 1 - mvolDavg
Where:
Vs = Volume fraction of coating solids, gallon coating solids per gallon coating.
mvol = Total volatile matter content of the coating, including HAP, VOCs, water, and exempt compounds, determined according to Method 24 in appendix A of 40 CFR part 60, lb-mass volatile matter per gallon coating.
Davg = Average density of volatile matter in the coating, lb-mass volatile matter per gallon volatile matter, determined from test results using ASTM Method D1475-90, "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR Section 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. If there is disagreement between ASTM Method D1475-90 test results and other information sources, the test results will take precedence.
H.2 Organic HAP Content calculation
40 CFR Section 63.4741(d); Minn. R. 7011.8000
Organic HAP Content: The Permittee shall calculate the organic HAP content, pounds of organic HAP emitted per gallon coating solids used, of each coating used during the compliance period using Equation QC2.
Equation QC2: Hc = Dc*WcVs
Where:
Hc = Organic HAP content of the coating, lb-mass organic HAP emitted per gallon coating solids used.
Dc = Density of coating, lb-mass coating per gallon coating, determined according to the Density requirement in the NESHAP subp. RRRR: COMPLIANCE REQUIREMENTS section of this permit.
Wc = Mass fraction of organic HAP in the coating, lb-mass organic HAP per lb-mass coating, determined according to the Mass Fraction requirement in the NESHAP subp. RRRR: COMPLIANCE REQUIREMENTS section of this permit.
Vs = Volume fraction of coating solids, gallon coating solids per gallon coating, determined according to the Volume Fraction requirement (Equation QC1) above.
H.4 Organic HAP emission calculation
40 CFR Section 63.4751(e); Minn. R. 7011.8000
Organic HAP Emissions: The organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners, and cleaning materials used during the previous month minus the organic HAP in certain waste materials. By the 15th of the month, the Permittee shall calculate the mass of organic HAP emissions for the previous month, using the following equations (Equations QE3, QE3-A, QE3-B, and QE3-C).
Equation QE3: He = A + B + C - Rw
Where:
He = Total mass of organic HAP emissions during the month, pounds.
A = Total mass of organic HAP in the coating used during the month, pounds, as calculated in Equation QE3-A.
B = Total mass of organic HAP in the thinners used during the month, pounds, as calculated in Equation QE3-B.
C = Total mass of organic HAP in the cleaning materials used during the month, pounds, as calculated in Equation QE3-C.
Rw = Total mass of organic HAP in waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal during the month, pounds, determined according the section below. (The Permittee may assign a value of zero to Rw if you do not wish to use this allowance.)
Calculate the mass of organic HAP in the coatings used during the month using Equation QE3-A.
Equation QE3-A: A = i=1m(Volc,i)(Dc,i)(Wc,i)
Where:
A = Total mass of organic HAP in the coatings used during the month, pounds.
Volc,i = Total volume of coating, i, used during the month, gallons.
Dc,i = Density of coating, i, pounds coating per gallons coating.
Wc,i = Mass fraction of organic HAP in coating, i, pounds organic HAP per pounds coating.
m = Number of different coatings used during the month.
Calculate the mass of organic HAP in the thinners used during the month using Equation QE3-B
Equation QE3-B: B = j=1n(Volt,j)(Dt,j)(Wt,j)
Where:
A = Total mass of organic HAP in the thinners used during the month, pounds.
Volt,j = Total volume of thinner, j, used during the month, gallons.
Dt,j = Density of thinner, j, pounds coating per gallons coating.
Wt,j = Mass fraction of organic HAP in thinner, j, pounds organic HAP per pounds coating.
n = Number of different thinners used during the month.
Calculate the mass of organic HAP in the cleaning materials used during the month using Equation QE3-C.
Equation QE3-C: C = k=1p(Vols,k)(Ds,k)(Ws,k)
Where:
C = Total mass of organic HAP in the cleaning materials used during the month, pounds.
Vols,k = Total volume of cleaning material, k, used during the month, gallons.
Ds,k = Density of cleaning material, k, pounds per gallon.
Ws,k = Mass fraction of organic HAP in cleaning material, k, pounds organic HAP per pound material.
p = Number of different cleaning materials used during the month.
Determine the total mass of organic HAP in waste materials (Rw)
If the Permittee elects to account for the mass of organic HAP contained in waste materials sent or designated for shipment to a hazardous waste TSDF in Equation QE3 above, then the Permittee shall determine it according to the following:
i) The Permittee shall include in the determination only waste materials that are generated by coating operations for which Equation QC3 of this section is used, and that will be treated or disposed of by a facility regulated as a TSDF under 40 CFR part 262, 264, 265, or 266. The TSDF may be either off-site or on-site. The Permittee may not include organic HAP contained in wastewater.
ii) The Permittee shall determine either the amount of the waste materials sent to a TSDF during the month or the amount collected and stored during the month and designated for future transport to a TSDF. Do not include in the determination any waste materials sent to a TSDF during a month if you have already included them in the amount collected and stored during that month or a previous month.
iii) Determine the total mass of organic HAP contained in the waste materials specified in the above paragraph.
iv) The Permittee may use any reasonable methodology to determine the amount of waste materials and the total mass of organic HAP they contain, and must document the methodology as required in the RECORDKEEPING section of the permit. To the extent that waste manifests include this information, they may be used as part of the documentation of the amount of waste materials and mass of organic HAP contained in them.
H.4 Calculation of total volume used
40 CFR Section 63.4751(f); Minn. R. 7011.8000
Total Volume Used: By the 15th of the month, the Permittee shall determine the total volume of coating solids used (gallons) which is the combined volume of coating solids for all the coatings used during the previous month, using Equation QE4.
Equation QE4: Vst = i=1m(Vc,i)(Vs,i)
Where:
Vst = Total volume of coating solids used during the month, gallons.
Volc,i = Total volume of coating, i, used during the month, gallons.
Vs,i = Volume fraction of coating solids for coating, i, gallon solids per gallon coating, as calculated using Equation QC1 above.
m = Number of coatings used during the month.
H.5 Calculation of organic HAP emission rate
40 CFR Section 63.4751(g); Minn. R. 7011.8000
Organic HAP Emission Rate: By the 15th of the month, the Permittee shall calculate the organic HAP emission rate for the 12-month compliance period, pounds organic HAP per gallon coating solids used, using Equation QE5.
Equation QE5: Hyr = y=112Hey=112Vst
Where:
Hyr = Organic HAP emission rate for the 12-month compliance period, pounds organic HAP per gallon coating solids.
He = Total mass of organic HAP emissions, pounds, from all materials used during month, y, as calculated by Equation QE3 above.
Vst = Total volume of coating solids used during month, y, gallons, as calculated by Equation QE4 above.
y = Identifier for months.
H.6 Mass fraction determination for solvent blends
Tables 5 and 6 of 40 CFR pt. 63, subp. RRRR; 40 CFR Sections 63.4741(a)(5) and 63.4742(a); 40 CFR Sections 63.4751(a) and 63.4752(a); Minn. R. 7011.8000
Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends can contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data or manufacturer's data for solvent blends are not available, the Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 5 or 6 below. If the tables are used, the Permittee shall use the values in Table 5 for all solvent blends that match the Table 5 entries according to the instructions for Table 5, and Table 6 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 5 and it is known only whether the blend is aliphatic or aromatic.
Table 5: Default Organic HAP Mass Fraction for Solvents and Solvent Blends
The Permittee may use the mass fraction values in the following table for solvent blends for which the Permittee does not have test data or manufacturer’s formulation data.
Instructions for Table 5:
- If a solvent blend matches both the name and the CAS number for an entry, the Permittee shall use that entry’s organic HAP mass fraction for that solvent blend.
- Otherwise, the Permittee shall use the organic HAP mass fraction for the entry matching either the solvent blend name or CAS number;
- Or the Permittee shall use the organic HAP mass fraction from Table 6 below if neither the name nor CAS number match.
Solvent/solvent blend / CAS No. / Average organic HAP mass fraction / Typical organic HAP, percent by massToluene / 108-88-3 / 1.0 / Toluene
Xylene(s) / 1330-20-7 / 1.0 / Xylenes, ethylbenzene
Hexane / 110-54-3 / 0.5 / n-hexane
n-Hexane / 110-54-3 / 1.0 / n-hexane
Ethylbenzene / 100-41-4 / 1.0 / Ethylbenzene
Aliphatic 140 / 0 / None
Aromatic 100 / 0.02 / 1% xylene, 1% cumene
Aromatic 150 / 0.09 / Naphthalene
Aromatic naphtha / 64742-95-6 / 0.02 / 1% xylene, 1% cumene
Aromatic solvent / 64742-94-5 / 0.1 / Naphthalene
Exempt mineral spirits / 8032-32-4 / 0 / None
Ligroines (VM & P) / 8032-32-4 / 0 / None
Lactol spirits / 64742-89-6 / 0.15 / Toluene
Low aromatic white spirit / 64742-82-1 / 0 / None
Mineral spirit / 64742-88-7 / 0.01 / Xylenes
Hydrotreated naphtha / 64742-48-9 / 0 / None
Hydrotreated light distillate / 64742-47-8 / 0.001 / Toluene
Stoddard solvent / 8052-41-3 / 0.01 / Xylenes
Super high-flash naphtha / 64742-95-6 / 0.05 / Xylenes
Varsol® solvent / 8052-49-3 / 0.01 / 0.5% xylenes, 0.5% ethylbenzene
VM & P naphtha / 64742-89-8 / 0.06 / 3% toluene, 3% xylene
Petroleum distillate mixture / 68477-31-6 / 0.08 / 4% naphthalene, 4% biphenyl
Table 6: Default Organic HAP Mass Fraction for Petroleum Solvent Groups
- The Permittee may use the mass fraction values in the following table for solvent blends for which the Permittee does not have test data or manufacturer’s formulation data.
- The Permittee shall use this table only if the solvent blend does not match any of the solvent blends in Table 5 above by either solvent blend name or CAS number and the Permittee knows only whether the blend is aliphatic or aromatic.
Solvent type / Average organic HAP mass fraction / Typical organic HAP, percent by massAliphatic* / 0.03 / 1% Xylene, 1% Toluene, and 1% Ethylbenzene
Aromatic** / 0.06 / 4% Xylene, 1% Toluene, and 1% Ethylbenzene
* E.g., Mineral Spirits 135, Mineral Spirits 130 EC, Naphtha, Mixed Hydrocarbon, Aliphatic Hydrocarbon, Aliphatic Naphtha, Naphthol Spirits, Petroleum Spirits, Petroleum Oil, Petroleum Naphtha, Solvent Naphtha, Solvent Blend.
** E.g., Medium-flash Naphtha, High-flash Naphtha, Aromatic Naphtha, Light Aromatic Naphtha, Light Aromatic Hydrocarbons, Aromatic Hydrocarbons, Light Aromatic Solvent.
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