Permit Appendix E for 40 CFR pt. 63, subp. PPPP

Contents of this appendix:

-Emission limits – new and existing sources

  • Alternative 1: predominant activity
  • Alternative 2: facility-specific emissions limit
  • Equation P1: facility-specific emissions limit

-Compliant material option requirements

  • Organic HAP content calculation
  • Equation PC1: organic HAP content of a coating

-Emission rate without add-on controls option requirements

  • Organic HAP emissions
  • Equation PE1: monthly total mass of organic HAP emissions
  • Equation PE1a: total mass of organic HAP in coatings used during the month
  • Equation PE1b: total mass of organic HAP in thinners/additives used during the month
  • Equation PE1c: total mass of organic HAP in cleaning materials used during the month
  • Organic HAP in waste materials used in Equation PE1
  • Total mass of coating solids
  • Equation PE2: monthly total mass coating solids used
  • Organic HAP emission rate
  • Equation PE3: average organic HAP emission rate for the compliance period

-Mass fraction determination for solvent blends

  • Tables 1 and 2: [not used in this appendix]
  • Table 3: Default organic HAP mass fraction for solvents and solvent blends
  • Table 4: Default organic HAP mass fraction for petroleum solvent groups

E.1 Emission limits – new and existing sources

Emission limit alternatives

E.1.1 Alternative 1

Alternative 1: Facilities with surface coating operations that are predominantly either general use or TPO

40 CFR Section 63.4490(c)(1); Minn. R. 7011.8130

If the general use or TPO surface coating operations subject to only one of the emission limits specified in 40 CFR paragraphs 63.4490(a)(1), (b)(3), (b)(1), or (b)(3) account for 90 percent or more of the surface coating activity at the facility then compliance with that 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 pounds (lb) of solids used as a measure of relative surface coating activity over a representative period of operation.

The Permittee may estimate the relative mass of coating solids used from parameters other than coating consumption and mass 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 mass 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.

E.1.2 Alternative 2

Alternative 2: Facility-specific emissions unit

40 CFR Section 63.4490(c)(2); Minn. R. 7011.8130

If the Permittee elects to comply with the applicable subcategory emissions limits described in 40 CFR paragraphs 63.4490(a)(1)-(4) and (b)(1)-(4) 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. PPPP 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 P1.

E.1.2.1 Facility Specific Emission Limit

Equation P1:

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 mass of coating solids used from parameters other than coating consumption and mass 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 mass solids content must be approved by the Administrator. (lb)

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 gal coating solids used to lb organic HAP per lb coating solids used, the Permittee shall use the default solids density of 12.5 lb solids per gal solids (1.50 kg solids per liter solids).

E.2 Compliant material option requirements

Compliance Equations

E.2.1 Organic HAP Content calculation

40 CFR Section 63.4541(c); Minn. R. 7011.8130

Organic HAP Content: The Permittee shall calculate the organic HAP content, pounds of organic HAP emitted per pound coating solids used, of each coating used during the compliance period using the following equation (Equation PC1):

Equation PC1:

Where:

Hc = Organic HAP content of the coating, lb organic HAP emitted per lb coating solids used.

Wc = Mass fraction of organic HAP in the coating, lb organic HAP per lb coating, determined according to the Mass Fraction of Organic HAP requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit.

Sc = Mass fraction of coating solids, lb coating solids per lb coating, determined according to the Mass Fraction of Coating Solids requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit.

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

Compliance Equations

E.3.1 Organic HAP Emissions

40 CFR Section 63.4541(e); Minn. R. 7011.8130

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 PE1):

Equation PE1:

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 PE1a 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 PE1b in this appendix

C = Total mass of organic HAP in the cleaning materials used during the month, lb-mass, as calculated in Equation PE1c 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.)

E.3.2 Organic HAP in Coatings

40 CFR Section 63.4541(e)(1); Minn. R. 7011.8130

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 PE1a):

Equation PE1a:A

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 63.4581, 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

E.3.3 Organic HAP in Thinners/Additives

40 CFR Section 63.4541(e)(2); Minn. R. 7011.8130

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 PE1b):

Equation PE1b:B

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 63.4581, 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

E.3.4 Organic HAP in Cleaning Materials

40 CFR Section 63.4541(e)(3); Minn. R. 7011.8130

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 PE1c):

Equation PE1c:C

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 63.4581, 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

E.3.5 Organic HAP in Waste Materials

40 CFR Section 63.4541(e)(4); Minn. R. 7011.8130

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 PE1 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 PE1 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 63.4530(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.

E.3.6 Total Mass of Coating Solids

40 CFR Section 63.4541(f); Minn. R. 7011.8130

Total Mass of Coating Solids: The Permittee shall determine the total mass of coating solids used, lb-mass, which is the combined mass of coating solids for all the coatings used during each month, using the following equation (Equation PE2):

Equation PE2:

Where:

Mst = Total mass of coating solids used during the month, lb-mass

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

Dc,i = Density of coating, i, lb per gallon coating, determined according to the Density of Each Material requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit.

Ms,i = Mass fraction of coating solids for coating, i, lb solids per lb coating, determined according to the Mass Fraction of Coating Solids requirement in the NESHAP subp. PPPP: Compliant Material Option Requirements section of this permit.

m = Number of different coatings used during the month

E.3.7 Organic HAP Emission Rate

40 CFR Section 63.4541(g); Minn. R. 7011.8130

Organic HAP Emission Rate: The Permittee shall calculate the organic HAP emission rate for the compliance period, lb organic HAP emitted per lb coating solids used, using the following equation (Equation PE3):

Equation PE3:

Where:

Hyr = Average organic HAP emission rate for the compliance period, in lb organic HAP emitted per lb coating solids used

He = Total mass of organic HAP emissions from all materials used during the month, y, in lb-mass, as calculated by Equation PE1 in this appendix

Mst = Total mass of coating solids used during month, y, in lb-mass, as calculated by Equation PE2 in this appendix

y =Identifier for months

n = Number of full or partial months in the compliance period (for the initial compliance period, n equals 12 if the compliance date falls on the first day of a month; otherwise n equals 13; for all following compliance periods, n equals 12)

E.3.8 Mass fraction determination for solvent blends

Tables 3 and 4 of 40 CFR pt. 63, subp. PPPP; 40 CFR Sections 63.4541(a)(5) and 63.4542(a); Minn. R. 7011.8130

Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, he Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 below.

If the tables are used, the Permittee shall use the values in Table 3 for all solvent blends that match the Table 3 entries according to the instructions for Table 3, and Table 4 may be used only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct.

Table 3: 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 and which match either the solvent blend name or the chemical abstract series (CAS) number.

-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 4 below if neither the name nor CAS number match.

Solvent/solvent blend / CAS No. / Average organic HAP mass fraction / Typical organic HAP, percent by mass
Toluene / 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 4: 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 3 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 mass
Aliphatic* / 0.03 / 1% Xylene, 1% Toluene, and 1% Ethylbenzene
Aromatic** / 0.06 / 4% Xylene, 1% Toluene, and 1% Ethylbenzene

* 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.