Permit Appendix D for 40 CFR pt. 63, subp. MMMM

Contents of this appendix:

-  Emission limits – new and existing sources

o  Alternative 1: predominant activity

o  Alternative 2: facility-specific emissions limit

§  Equation M1: facility-specific emissions limit

-  Compliant material option requirements

o  Volume fraction calculation

§  Equation MC1: volume fraction of coating solids

o  Organic HAP content calculation

§  Equation MC2: organic HAP content of a coating

-  Emission rate without add-on controls option requirements

o  Volume fraction calculation

§  Equation MC1: volume fraction of coating solids

o  Organic HAP emissions

§  Equation ME1: monthly total mass of organic HAP emissions

§  Equation ME1a: total mass of organic HAP in coatings used during the month

§  Equation ME1b: total mass of organic HAP in thinners/additives used during the month

§  Equation ME1c: total mass of organic HAP in cleaning materials used during the month

§  Organic HAP in waste materials used in Equation ME1

o  Total volume used

§  Equation ME2: monthly total volume coating solids used

o  Organic HAP emission rate

§  Equation ME3: average organic HAP emission rate for the compliance period

-  Mass fraction determination for solvent blends

o  Tables 1 and 2: [not used in this appendix]

o  Table 3: Default organic HAP mass fraction for solvents and solvent blends

o  Table 4: Default organic HAP mass fraction for petroleum solvent groups

D.1 Emission limits – new and existing sources

Emission limit alternatives

D.1.1 Alternative 1

Alternative 1: Facilities with surface coating operations that are predominantly either general use or magnet wire 40 CFR Section 63.3890(c)(1); Minn. R. 7011.8090

If the general use or magnet wire surface coating operations subject to only one of the emission limits specified in 40 CFR sections 63.3890(a)(1), (3), (b)(1), or (3) account for 90 percent or more of the surface coating activity at the facility (i.e., it is the predominant activity at the facility), then compliance with that one emission limitation for all surface coating operations constitutes compliance with the other applicable emission limits.

The determination of predominant activity shall accurately reflect current and projected coating operations and shall be verifiable through appropriate documentation. The Permittee shall use gallons (gal) of solids used as a measure of relative surface coating activity over a representative period of operation.

The Permittee may estimate the relative volume of coating solids used from parameters other than coating consumption and volume solids content (e.g., design specifications for the parts or products coated and the number of items produced). The use of parameters other than coating consumption and volume solids content must be approved by the Administrator.

The Permittee may use data for any reasonable time period of at least 1 year in determining the relative amount of coating activity, as long as these data represent the way the source will continue to operate in the future and are approved by the Administrator.

D.1.2 Alternative 2

Alternative 2: Facility-specific emissions unit

40 CFR Section 63.3890(c)(2); Minn. R. 7011.8090

If the Permittee elects to comply with the applicable subcategory emissions limits described in 40 CFR paragraphs 63.3890(a)(1)-(5) and (b)(1)-(5) using the facility-specific emission limit alternative, then compliance with the facility-specific emission limit and the emission limitations in 40 CFR pt. 63, subp. MMMM constitutes compliance with this and all other applicable surface coating NESHAP.

In calculating a facility-specific emission limit, the Permittee shall include all coating activities at the facility that meet the applicability criteria of the other subcategories and constitute more than 1 percent of total coating activities. The Permittee shall include in the compliance calculation all coating activities that meet the applicability criteria of other surface coating NESHAP but comprise less than 1 percent of coating activities, but may exclude these activities from the determination of predominant activity.

The Permittee shall calculate the facility-specific emission limit for each 12-month compliance period using Equation M1.

Equation M1: Facility-Specific Emission Limit = i=1nLimitiSolidsii=1nSolidsi

Where:

Facility-Specific Emission Limit = Facility-specific emission limit for each 12-month compliance period. (lb organic HAP per lb coating solids used)

Limiti = The new source or existing source emission limit applicable to coating operation, i, included in the facility-specific emission limit, converted to lb organic HAP per lb coating solids used, if the emission limit is not already in those units. All emission limits included in the facility-specific emission limit must be in the same units. (lb organic HAP per lb coating solids used)

Solids i = The volume of solids used in coating operation, i, in the 12-month compliance period that is subject to emission limit, i. The Permittee may estimate the volume of coating solids used from parameters other than coating consumption and volume solids content (e.g., design specifications for the parts or products coated and the number of items produced). The use of parameters other than coating consumption and volume solids content must be approved by the Administrator. (gal)

n = The number of different coating operations included in the facility-specific emission limit.

To convert an emission limit in another surface coating NESHAP from lb organic HAP per lb coating solids used to lb organic HAP per gallon coating solids used, the Permittee shall use the default solids density of 10.5 lb solids per gal solids (1.26 kg solids per liter solids).

D.2 Compliant material option requirements

Compliance Equations

D.2.1 Volume Fraction calculation

40 CFR Section 63.3941(b)(4); Minn. R. 7011.8090

Calculation of volume fraction of coating solids. The Permittee may determine the volume fraction of coating solids by using the following equation (Equation MC1):

Equation MC1: 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 D1475-98, "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.

D.2.2 Organic HAP Content calculation

40 CFR Section 63.3941(d); Minn. R. 7011.8090

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 the following equation (Equation MC2):

Equation MC2: 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 above.

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. MMMM: Compliant Material Option 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 MC1) above.

D.3 Emission rate without add-on controls option requirements

Compliance Equations

D.3.1 Volume Fraction calculation

40 CFR Section 63.3951(b)(4); Minn. R. 7011.8090

Calculation of volume fraction of coating solids. The Permittee may determine the volume fraction of coating solids by using the following equation (Equation MC1):

Equation MC1: 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 D1475-98, "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.

D.3.2 Organic HAP Emissions

40 CFR Section 63.3941(e); Minn. R. 7011.8090

Organic HAP Emissions: The mass of organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners and/or other additives, and cleaning materials used during each month minus the organic HAP in certain waste materials. The Permittee shall calculate the mass of organic HAP emissions, using the following equation (Equation ME1):

Equation ME1: He = A + B + C - Rw

Where:

He = Total mass of organic HAP emissions during the month, lb-mass

A = Total mass of organic HAP in the coatings used during the month, lb-mass, as calculated in Equation ME1a in this appendix

B = Total mass of organic HAP in the thinners and/or other additives used during the month, lb-mass, as calculated in Equation ME1b in this appendix

C = Total mass of organic HAP in the cleaning materials used during the month, lb-mass, as calculated in Equation ME1c in this appendix

Rw = Total mass of organic HAP in the waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal used during the month, lb-mass, determined according to “Organic HAP in Waste Materials” below. (The Permittee shall assign a value of zero to Rw if not using this allowance.)

D.3.3 Organic HAP in Coatings

40 CFR Section 63.3941(e)(1); Minn. R. 7011.8090

Total mass of organic HAP in coatings: The Permittee shall calculate the mass of organic HAP in the coatings used during the month using the following equation (Equation ME1a):

Equation ME1a: A = i=1m(Volc,i)(Dc,i)(Wc,i)

Where:

A = Total mass of organic HAP in the coatings used during the month, lb-mass

Volc,i = Total volume of coating, i, used during the month, gallons

Dc,i = Density of coating, i, used during the month, lb-mass per gallon coating

Wc,i = Mass fraction of organic HAP in coating, i, lb-mass organic HAP per lb-mass coating. For reactive adhesives as defined in 40 CFR Section 63.3981, the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP

m = Number of different coatings used during the month

D.3.4 Organic HAP in Thinners/Additives

40 CFR Section 63.3941(e)(2); Minn. R. 7011.8090

Total mass of organic HAP in thinners and/or other additives: The Permittee shall calculate the mass of organic HAP in the thinners and/or other additives used during the month using the following equation (Equation ME1b):

Equation ME1b: B = j=1n(Volt,j)(Dt,j)(Wt,j)

Where:

A = Total mass of organic HAP in the thinners and/or other additives used during the month, lb-mass

Volt,j = Total volume of thinner and/or other additive, j, used during the month, gallons

Dt,j = Density of thinner and/or other additive, j, used during the month, lb-mass per gallon coating

Wt,j = Mass fraction of organic HAP in thinner and/or other additive, j, lb-mass organic HAP per lb-mass thinner and/or other additive. For reactive adhesives as defined in 40 CFR Section 63.3981, the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP

n = Number of different thinners and/or other additives used during the month

D.3.5 Organic HAP in Cleaning Materials

40 CFR Section 63.3941(e)(3); Minn. R. 7011.8090

Total mass of organic HAP in cleaning materials: The Permittee shall calculate the mass of organic HAP in the cleaning materials used during the month using the following equation (Equation ME1c):

Equation ME1c: C = k=1p(Vols,k)(Ds,k)(Ws,k)

Where:

C = Total mass of organic HAP in the cleaning materials used during the month, lb-mass

Vols,k = Total volume of cleaning material, k, used during the month, gallons

Ds,k = Density of cleaning material, k, used during the month, lb-mass per gallon coating

Ws,k = Mass fraction of organic HAP in cleaning material, k, lb-mass organic HAP per lb-mass coating. For reactive adhesives as defined in 40 CFR Section 63.3981, the Permittee shall use the mass fraction of organic Hap that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP

p = Number of different cleaning materials used during the month

D.3.6 Organic HAP in Waste Materials

40 CFR Section 63.3941(e)(4); Minn. R. 7011.8090

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 ME1 in this appendix, then the Permittee shall determine the mass according to the following requirements:

Rw = Total mass of organic HAP in the waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal used during the month, lb-mass. (The Permittee shall assign a value of zero to Rw if not using this allowance.)

i)  The Permittee shall include in the determination only waste materials that:

·  Are generated by coating operations in the affected source for which Equation ME1 in this appendix is used; and

·  That will be treated or disposed of by a facility that is 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 shall 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. The Permittee shall not include in the determination any waste materials sent to a TSDF during a month if these materials have already been included in the amount collected and stored during that month or a previous month.

iii)  The Permittee shall determine the total mass of organic HAP contained in the waste materials specified above in paragraph (ii).

iv)  The Permittee shall document the methodology used to determine the amount of waste materials and the total mass of organic HAP they contain, as required in 40 CFR Section 63.3930(h). If waste manifests include this information, the Permittee may use them as part of the documentation of the amount of waste materials and mass of organic HAP contained in them.