Facility Name {This field is to be edit by the engineer, the following field is auto-filled by the filename.}

GEAR 12b.doc

Authority to Construct

Application Review

Motor Vehicle and Mobile Equipment Coating

(with dryer and outside the booth priming)

Facility Name: / Facility’s Name / Date: /

Completion Date

Mailing Address: / Facility’s Mailing Address
Facility’s City, CA Zip Code / Engineer: / Engineer’s Name
Lead Engineer: / Engineer’s Name
Contact Person: / Contact Person’s Name
Telephone: / (XXX) XXX-XXXX, ext. XXXX
Application # (#’s): / X-XXXX-X-X, -X-X, -X-X, and –X-X (as necessary)
Project #: / X-XXXXXXX
Deemed Complete: /

Project Complete Date

I. Proposal

The primary business of facility name is the repairing andpainting of motor vehicles and mobile equipment. Facility name is applying for an Authority to Construct (ATC) for a motor vehicle and mobile equipment painting operation with a paint spray booth. The facility will be drying the paint by using a X.X MMBtu/hr {natural gas-fired or a Liquefied Petroleum Gas (LPG) fired} burner that is installed inside of the paint booth. The applicant has proposed that priming be allowed outside of the paint booth. In order to allow priming outside of the paint booth the applicant agrees to limit PM10 emissions from priming to 2.0 lbs/day. This is required so that Best Available Control Technology (BACT) will not be required on the priming operation.

II. Applicable Rules

Rule 2010Permits Required (12/17/92)

Rule 2201New and Modified Stationary Source Review Rule (12/19/02)

Rule 2520Federally Mandated Operating Permits (6/21/01)

Rule 4101Visible Emissions (11/15/01)

Rule 4102Nuisance (12/17/92)

Rule 4201Particulate Matter Concentration (12/17/92)

Rule 4301Fuel Burning Equipment (12/17/92)

Rule 4602Motor Vehicle and Mobile Equipment Refinishing Operations (12/20/01)

Rule 4801Sulfur Compounds (12/17/92)

CH&SC 41700

CH&SC 42301.6

III. Project Location

{If the painting operation is or is not located within 1,000 ft of the outermost boundary of a K-12 school, edit the following statement as necessary:}

The project is located at 12345 N. Street Rd. in Any City, CA. The applicant states that the equipment is not located within 1,000 feet of a K-12 school. Therefore, the public notification requirement of California Health and Safety Code 42301.6 is/is not applicable to this project.

IV. Process Description

This paint spray booth will be used solely for automotive body repair and refinishing. The paint spray operation occurs in two stages, automotive body preparation (including application of primer and sanding) and application of topcoat. At this facility, auto body prep work, including the application of primer (which includes primer pretreatment, surfacer, and sealer) takes place outside of the paint spray booth. The application of the topcoat will take place inside of the paint spray booth. After the application of the topcoat heat from the {natural gas-fired or LPG-fired} burner will be used to dry the paint before the equipment is removed from the paint booth.

V. Equipment Listing

One XX' L X XX' W X XX' H paint spray booth

XX hp exhaust fan

Dry/Water/Oil-wash Filter System

Approved HVLP Spray Gun(s) or Electrostatic Spray Gun(s)

## hp electric air compressor

XX.X MMBtu/hr drying burner {If the natural gas-fired burner rating is ≤ 0.833 MMBtu/hr or if the LPG-fired burner rating is ≤ 0.556 MMBtu/hr, this burner is permit exempt and the burner rating is not stated in the equipment description. If the natural gas-fired burner is > 0.833 MMBtu/hr or the LPG-fired burner rating is 0.556 MMBtu/hr, then the engineer can list the burner in the equipment description and the facility will be billed at the higher rate (for example: 3020-02-D for burners between 0.65 to 1.5 MMBtu/hr at $268/yr versus 3020-01-A for electric motors up to and including 25 hp at $74/yr) or the applicant can limit the hours of operation of the burner and keep records of operation. Note: For the third option, the limit of daily operation and records of hours of operation IS NOT listed as a permit condition. Instead the applicant must be given a permit exemption letter with the limit of daily hours of operation that will keep NOx emissions ≤ 2.0 lbs/day and the record-keeping requirement to maintain the exemption. For example: Daily operation of a natural gas-fired burner = 2.0 lbs-NOx/day ÷ [Burner Rating (MMBtu/hr) x 0.1 lb-NOx/MMBtu] or Daily operation of a LPG-fired burner = 2.0 lbs-NOx/day ÷ [Burner Rating (MMBtu/hr) x 0.15 lb-NOx/MMBtu]

District approved gun cleaner

{To ensure uniformity, the either of the following standard equipment descriptions will be used. Note: add the gun cleaner if applicant proposed, pick the correct fuel for the burner, and choose the appropriate burner description.}

X-XXXX-X-X:

{For coating operations with a permitted burner:}

MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATION WITH HVLP SPRAY GUN(S), A PAINT SPRAY BOOTH WITH DRY EXHAUST FILTERS, AN ENCLOSED SPRAY GUN CLEANER, AND A X.X MMBTU/HR (NATURAL GAS-FIRED or LPG-FIRED) DRYING BURNER

{For coating operations with a permit exempt burner:}

MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATION WITH HVLP SPRAY GUN(S), A PAINT SPRAY BOOTH WITH DRY EXHAUST FILTERS, AN ENCLOSED SPRAY GUN CLEANER, AND A PERMIT EXEMPT (NATURAL GAS-FIRED or LPG-FIRED) DRYING BURNER (< 20.0 MMBTU/DAY HEAT INPUT) for natural gas-fired burners, or (<13.5 MMBTU/DAY HEAT INPUT) for LPG fired burners

VI. Emission Control Technology Evaluation

For the coating operation:

Only PM10 and VOC are emitted from the priming and topcoating operation. The applicant has proposed that priming take place outside of the paint booth so PM10 emissions from the priming operation will be controlled only by the use of High Volume Low Pressure (HVLP) spray equipment. For the topcoating operation the applicant has proposed a paint spray booth with a dry exhaust filter system for PM10 control, HVLP spray equipment for PM10 and VOC control, and an approved gun cleaner for VOC control during spray equipment clean up. The paint spray booth with a dry exhaust filter system will control PM10 emissions by filtering air from inside the paint booth before it is exhausted to the atmosphere. The HVLP spray equipment will control PM10 and VOC emissions by having more paint transfer to the desired surfaces than traditional painting equipment. The approved gun cleaner will control VOC emissions by not allowing VOC containing liquids used during gun cleaning to evaporate into the atmosphere.

For the products of combustion from the drying operation:

All criteria pollutants are emitted from the paint drying operation. For NOx, SOx, PM10, CO, and VOC from the burner the applicant has proposed the combustion of {natural gas or LPG} to keep emissions at a minimum.

VII. General Calculations

A. Assumptions

  • To avoid triggering offsets, VOC emissions are limited to 54.7 lb/day = 19,966 lb/yr (per Applicant).
  • HVLP gun transfer efficiency (TE) is 75% (per STAPPA/ALAPCO Vol. 2, pg. 14-7, 5/30/91).
  • Dry exhaust filter removal efficiency (RE) is 66% (STAAPPA/ALAPCO Vol. 2, pg. 14-7, 5/30/91).
  • Exhaust fan for the paint booth is rated at 4,000 cfm (per Applicant).
  • For emissions calculations purposes the facility is assumed to operate 24 hr/day and 365 days/yr (District assumption to conservatively estimate emissions). {If Applicant proposes otherwise, change this assumption, calculate emissions based on the proposed limit, and add conditions limiting the facilities operation along with recordkeeping of the hours of operation.}
  • Heating value of natural gas is 1,000 Btu/scf, taken from District Policy APR-1720, dated 12/01. {For facilities that propose LPG use the following assumption:} Heating value of LPG is 0.0915 MMBtu/gal, taken from AP-42, Section 1.5, dated 10/96.
  • F-factor for natural gas, corrected to 60 ºF, is 8,578 dscf/MMBtu. {For facilities that propose LPG use the following assumption:} F-factor for LPG, corrected to 60 ºF, is 8,792 dscf/MMBtu.

{For facilities that propose LPG use the following assumption:}

  • LPG is assumed to contain 15 grain-S/100 scf (District guidance for worst case sulfur content).

{For facilities that the Applicant does not want to trigger BACT for NOx, add the following assumption:}

  • To avoid triggering BACT for NOx, the dryer is limited to operation of XX hr/day (per Applicant). {Note: If this option is proposed make sure the applicant is given a permit exemption letter with the limit of daily hours of operation that will keep NOx emissions ≤ 2.0 lbs/day and the record-keeping requirement to maintain the exemption, unless 24 hr operation does not trigger BACT.}

{For facilities that propose BACT for NOx (i.e. a natural gas-fired burner), add the following assumption:}

  • To avoid record keeping for operation of the dryer, operation is assumed to be 24 hr/day (per Applicant).
  • To avoid triggering BACT, daily PM10 emissions from priming outside of the paint booth will be limited to 2.0 lb/day (per Applicant).

B. Emission Factors

For unit -X-X, thenew motor vehicle coating operation:

  • PM10 emission factor (EF) for enamel paint (worst case) is 5.5 lb/gal, assuming all particulate matter (PM) emissions are PM10 (STAPPA/ALAPCO Vol. 2, pg. 14-4, 5/30/91).
  • Worst case enamel paint VOC content is 2.0 lb/gal as applied (District assumption to conservatively estimate PM10 emissions).
  • PM10 EF for primer (worst case) is 3.0 lb/gal, assuming all PM emissions are PM10 (STAPPA/ALAPCO Vol. 2, pg. 14-4, 5/30/91).
  • Average primer VOC content is 5.0 lb/gal (STAPPA/ALAPCO Vol. 2, pg. 14-4, 5/30/91).

{If the applicant has proposed a multi-stage coating insert the following calculation(s):}

VOC Emission Factor for Multi-Stage Coatings:

{If available from the manufacturer use the VOC content of the basecoat, clearcoat, midcoat, or groundcoat.}

For the basecoat:

The Material Safety Data Sheet (MSDS) for Brand XXX basecoat states that the VOC emission factor less water and exempt compounds is as follows:

EF VOCbc = 2.01 lb-VOC/gal

{If not available from the manufacturer, do the following calculations to determine the “as-applied” VOC content of the basecoat, clearcoat, midcoat, or groundcoat.}

This Brand XXX basecoat is mixed with additional components such as Brand YYY thinner and Brand ZZZ hardener. The MSDSs for these materials state that the VOC emissions factors less water and exempt compounds are as follows:

EF VOCThinner bc = 6.80 lb-VOC/gal

EF VOCHardener bc = 6.75 lb-VOC/gal

For this basecoat mixture 5 parts of coating are mixed with 1 part thinner and 1 part hardener. Thus, the VOC emission factor for this basecoat as applied is calculated as follows:

EF VOCbc as applied (lb-VOC/gal) ={[VOC content of the basecoat (lb-VOC/gal) x number of parts] + [VOC content of the thinner (lb-VOC/gal x number of parts] + [VOC content of the hardener (lb-VOC/gal x number of parts]} ÷total number of parts

EF VOCbc as applied lb-VOC/gal =[(2.01 lb-VOC/gal x 5 parts) + (6.80 lb-VOC/gal x 1 part) + (6.75 lb-VOC/gal x 1 part)] ÷7 parts

EF VOCbc as applied = 3.37 lb-VOC/gal

For the clearcoat:

The MSDS for Brand XXX clearcoat states that the VOC emission factor less water and exempt compounds is as follows:

EF VOCcc = 4.01 lb-VOC/gal

This Brand XXX clearcoat is mixed with additional components such as Brand YYY thinner and Brand ZZZ hardener. The MSDSs for these materials state that the VOC emissions factors less water and exempt compounds are as follows:

EF VOCThinner cc = 4.80 lb-VOC/gal

EF VOCHardener cc = 2.75 lb-VOC/gal

For this clearcoat mixture 4 parts of coating are mixed with 2 part thinner and 1 part hardener. Thus, the VOC emission factor for this clearcoat as applied is calculated as follows:

EF VOCcc as applied (lb-VOC/gal) ={[VOC content of the clearcoat (lb-VOC/gal) x number of parts] + [VOC content of the thinner (lb-VOC/gal x number of parts] + [VOC content of the hardener (lb-VOC/gal x number of parts]} ÷total number of parts

EF VOCcc as applied lb-VOC/gal =[(4.01 lb-VOC/gal x 4 parts) + (4.80 lb-VOC/gal x 2 parts) + (2.75 lb-VOC/gal x 1 part)] ÷7 parts

EF VOCcc as applied = 4.05 lb-VOC/gal

For the midcoat: {If applicable add the following calculation:}

The MSDS for Brand XXX midcoat states that the VOC emission factor less water and exempt compounds is as follows:

EF VOCmc = 2.50 lb-VOC/gal

This Brand XXX midcoat is mixed with additional components such as Brand YYY thinner and Brand ZZZ hardener. The MSDSs for these materials state that the VOC emissions factors less water and exempt compounds are as follows:

EF VOCmc = 1.80 lb-VOC/gal

EF VOCmc = 3.75 lb-VOC/gal

For this midcoat mixture 6 parts of coating are mixed with 1 part thinner and 1 part hardener. Thus, the VOC emission factor for this midcoat as applied is calculated as follows:

EF VOCmc as applied (lb-VOC/gal) ={[VOC content of the midcoat (lb-VOC/gal) x number of parts] + [VOC content of the thinner (lb-VOC/gal x number of parts] + [VOC content of the hardener (lb-VOC/gal x number of parts]} ÷total number of parts

EF VOCmc as applied lb-VOC/gal =[(2.50 lb-VOC/gal x 6 parts) + (1.80 lb-VOC/gal x 1 parts) + (3.75 lb-VOC/gal x 1 part)] ÷8 parts

EF VOCmc as applied = 2.57 lb-VOC/gal

For the groundcoat: {If applicable add the following calculation:}

The MSDS for Brand XXX groundcoat states that the VOC emission factor less water and exempt compounds is as follows:

EF VOCgc = 1.00 lb-VOC/gal

This Brand XXX groundcoat is mixed with additional components such as Brand YYY thinner and Brand ZZZ hardener. The MSDSs for these materials states that the VOC emissions factors less water and exempt compounds are as follows:

EF VOCThinner gc = 5.50 lb-VOC/gal

EF VOCHardener gc = 9.60 lb-VOC/gal

For this groundcoat mixture 4 parts of coating are mixed with 3 part thinner and 2 part hardener. Thus, the VOC emission factor for this groundcoat as applied is calculated as follows:

EF VOCgc as applied (lb-VOC/gal) ={[VOC content of the groundcoat (lb-VOC/gal) x number of parts] + [VOC content of the thinner (lb-VOC/gal x number of parts] + [VOC content of the hardener (lb-VOC/gal x number of parts]} ÷total number of parts

EF VOCgc as applied lb-VOC/gal =[(1.00 lb-VOC/gal x 4 parts) + (5.50 lb-VOC/gal x 3 parts) + (9.60 lb-VOC/gal x 2 part)] ÷8 parts

EF VOCgc as applied = 4.96 lb-VOC/gal

{For two stage multi-stage coating operations use the following calculation:}

For the two stage multi-stage coating:

EF VOCTwo Stage MS (lb-VOC/gal) =[EF VOCbc(lb-VOC/gal) + 2 x EF VOCcc (lb-VOC/gal)] ÷3

EF VOC Two Stage MS lb-VOC/gal =[3.37 lb-VOC/gal + 2 x (4.05 lb-VOC)] ÷3

EF VOCTwo Stage MS = 3.82 lb-VOC/gal {Note: If this is greater than 4.5 lb-VOC/gal, then this coating does not meet the as applied VOC content limit for multi-stage top coatings of District Rule 4602.}

{For three stage multi-stage coating operations use the following calculation:}

For the three stage multi-stage coating:

EF VOCThree Stage MS (lb-VOC/gal) =[EF VOCbc(lb-VOC/gal) + EF VOCmc(lb-VOC/gal) + 2 x EF VOCcc (lb-VOC/gal)] ÷4

EF VOC Three Stage MS lb-VOC/gal =[3.37 lb-VOC/gal + 2.57 lb-VOC + 2 x (4.05 lb-VOC)] ÷4

EF VOCThree Stage MS = 3.51 lb-VOC/gal {Note: If this is greater than 4.5 lb-VOC/gal, then this coating does not meet the as applied VOC content limit for multi-stage top coatings of District Rule 4602.}

{For four stage multi-stage coating operations use the following calculation:}

For the four stage multi-stage coating:

EF VOCFour Stage MS (lb-VOC/gal) =[EF VOCgc(lb-VOC/gal) + EF VOCbc(lb-VOC/gal) + EF VOCmc(lb-VOC/gal) + 2 x EF VOCcc (lb-VOC/gal)] ÷5

EF VOC Four Stage MS lb-VOC/gal =[4.96 lb-VOC/gal + 3.37 lb-VOC/gal + 2.57 lb-VOC + 2 x (4.05 lb-VOC)] ÷5

EF VOCFour Stage MS = 3.80 lb-VOC/gal {Note: If this is greater than 4.5 lb-VOC/gal, then this coating does not meet the as applied VOC content limit for multi-stage top coatings of District Rule 4602.}

{For facilities that propose a natural gas-fired dryer, add the following Emissions Factors table. Note: Use either the following AP-42 emissions factors or the burner manufacturers emissions factors if supplied by the applicant.}

Table 1: Burner Emission Factors
Operation / Emission Rate / Source
Natural gas combustion in the burner / 0.10 lb-NOx/MMBtu / AP-42, Table 1.4-1 & -2 (7/98)
0.00285 lb-SOx/MMBtu / APR-1720 (12/01)
0.0076 lb-PM10/MMBtu / AP-42, Table 1.4-1 & -2 (7/98)
0.084 lb-CO/MMBtu / AP-42, Table 1.4-1 & -2 (7/98)
0.0055 lb-VOC/MMBtu / AP-42, Table 1.4-1 & -2 (7/98)

{For facilities that propose a LPG fired dryer, add the following Emissions Factors table. Note: Use either the following AP-42 emissions factors or the burner manufacturers emissions factors if supplied by the applicant.}

Table 1: Burner Emission Factors
Operation / Emission Rate / Source
LPG combustion in the burner / 0.15 lb-NOx/MMBtu / AP-42, Table 1.5-1 (10/96)
0.0164 lb-SOx/MMBtu / AP-42, Table 1.5-1 (10/96), see calculation below
0.0044 lb-PM10/MMBtu / AP-42, Table 1.5-1 (10/96)
0.021 lb-CO/MMBtu / AP-42, Table 1.5-1 (10/96)
0.0055 lb-VOC/MMBtu / AP-42, Table 1.5-1 (10/96)

LPG Combustion SOx Emission Factor Calculation:

Sulfur EF = 0.1 S lb/1,000 gal, with S in grain/100scf (AP-42, Table 1.5-1, 10/96)

Sulfur EF = 0.1 x (15 grain/100 scf) = 1.5 lb/1,000 gal

Sulfur EF = 1.5 lb/1,000 gal ÷ 0.0915 MMBtu/gal

Sulfur EF = 0.0164 lb-SOx/MMBtu

C. Calculations

1. Pre-Project Potential to Emit (PE1)

Pre-project emissions from unit -X-X, thenew motor vehicle coating operation:

Since this is a new unit at this facility the daily and annual pre-project emissions are zero for all criteria pollutants.

PE1 = 0.0 lb/day = 0.0 lb/yr

2.Post-Project Potential to Emit (PE2)

Post-project emissions from unit -X-X, the new motor vehicle coating operation:

The post-project Potential to Emit (PE2) is determined by using the emission factors for natural gas combustion, daily hours of operation of the dryer, the daily VOC emissions limit, the VOC and PM10 content of the paint, the HVLP gun transfer efficiency, the dry exhaust filter removal efficiency, and the daily PM10 emissions limit for priming. To make the VOC and PM10 daily emissions limits enforceable and to simplify Permittee compliance, VOC emissions from the new permit unit have been set to 54.7 lb/day. Then VOC emissions from the all emissions units will be added together to reach the daily VOC limit.

a. Daily PE2 (lb/day)

Emissions from the X.X MMBtu/hr {natural gas-fired or LPG fired} dryer (PE2Combustion):