Facility Name {This field is to be edit by the engineer, the following field is auto-filled by the filename.}
GEAR 12c Motor Vehicle (with no burner and booth priming) - Manual, 07 19 05.doc
Authority to Construct
Application Review
Motor Vehicle and Mobile Equipment Coating
(with air drying and in-booth priming)
Facility Name: / Facility’s Name / Date: /Completion Date
Mailing Address: / Facility’s Mailing AddressFacility’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 air-drying the paint inside of the paint booth. All painting, including the application of primer, will be conducted inside of the paint booth.
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 4602Motor Vehicle and Mobile Equipment Refinishing Operations (12/20/01)
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 inside of the paint spray booth. The application of the topcoat will also take place inside of the paint spray booth. After the application of the topcoat the paint will be allowed to air-dry 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
District approved gun cleaner
{To ensure uniformity, the following standard equipment description will be used. Note: add the gun cleaner if applicant proposed.}
X-XXXX-X-X:
MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATION WITH HVLP SPRAY GUN(S)(, A/AND A) PAINT SPRAY BOOTH WITH DRY EXHAUST FILTERS, AND AN ENCLOSED SPRAY GUN CLEANER
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 a paint spray booth with a dry exhaust filter system for PM10 control, High Volume Low Pressure (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.
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.}
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.}
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, thenew motor vehicle coating operation:
The post-project Potential to Emit (PE2) is determined by using the daily VOC emissions limit, the VOC and PM10 content of the paint, the HVLP gun transfer efficiency, and the dry exhaust filter removal efficiency.
a. Daily PE2 (lb/day)
Emissions from the coating operation (PE2Painting):
First the daily VOC emissions for painting are determined:
PE2Painting VOC= VOC limit (lb-VOC/day)
= 54.7 lb-VOC/day
Then the daily enamel paint usage is determined:
Daily Paint Usage (gal/day) =PE2Painting(lb-VOC/day) ÷ Enamel Paint VOC Content (lb-VOC/gal)
Daily Paint Usage= 54.7 lb-VOC/day ÷2.0 lb-VOC/gal
= 27.4 gal/day
Next the daily PM10 emissions from painting are determined:
PE2Painting PM10(lb/day) = Daily Paint Usage (gal/day) x Enamel Paint PM10Content (lb-PM10/gal) x (1 – HVLP Transfer Efficiency) x (1 – Dry Filter Control Efficiency)
PE2Painting PM10= 27.4 gal/day x 5.5 lb-PM10/gal x (1 – 0.75) x (1 – 0.66)
= 12.8 lb-PM10/day
Table 1: Daily PE2Pollutant / PE2Painting (lb/day)
NOx / 0
SOx / 0
PM10 / 12.8
CO / 0
VOC / 54.7
b. Annual PE2 (lb/yr)
Annual post-project emissions from unit -X-X, thenew motor vehicle coating operation:
The annual post-project Potential to Emit (PE2) is determined by using the daily PE2 calculated previously in Section VII.C.2.a and operation of 365 day/year.
PE2Annual (lb/yr) =PE2 (lb-Pollutant/day) x 365 day/yr
PE2Annual NOx= 0.0 lb-NOx/day x 365 day/yr
= 0 lb-NOx/yr
PE2Annual SOx= 0.0 lb-SOx/day x 365 day/yr
= 0 lb-SOx/yr
PE2Annual PM10= 12.8 lb-PM10/day x 365 day/yr
= 4,672 lb-PM10/yr
PE2Annual CO= 0.0 lb-CO/day x 365 day/yr
= 0 lb-CO/yr
PE2Annual VOC= 54.7 lb-VOC/day x 365 day/yr
= 19,966 lb-VOC/yr
{Note: The following table multiplies column 1 by 365 with the result presented in column 2. After entering the data in column 1, highlight column 2 and press F9.}
Table 2: Annual PE2Pollutant / PE2 (lb/day) / PE2 (lb/yr)
NOx / 0 / 0
SOx / 0 / 0
PM10 / 12.8 / 4,672
CO / 0 / 0
VOC / 54.7 / 19,966
3. Pre-Project Stationary Source Potential to Emit (SSPE1)
{Calculate the SSPE1 for the entire facility (See Rule 2201, Section 4.9). SSPE1 is used to determine if the offset threshold will be surpassed during this project, and to determine if public notice is required for a 20,000 lb/yr SSIPE.}
Pursuant to Section 4.9 of District Rule 2201, the Pre-Project Stationary Source Potential to Emit (SSPE1) is the Potential to Emit (PE) from all units with valid ATCs or PTOs at the Stationary Source and the quantity of Emission Reduction Credits (ERCs) which have been banked since September 19, 1991 for Actual Emissions Reductions that have occurred at the source, and which have not been used on-site.
{If this is a new facility use the following statement:}
Since this is a new facility, there are no existing permit units or any ERCs banked at this facility. Thus:
SSPE1 = 0.0 lb/yr
{If this is an existing facility use the following statement:}
Since this is an existing facility, SSPE1 is equal to the PE1Total Pre-Project from all units for all criteria pollutants.
{Note: Modify the following statement as necessary to meet the specifics of the facility.}
There are two existing permit units, one unimplemented ATC, and no banked ERCs at this facility. In this situation the worst-case scenario for the facility will be used for the SSPE1. For this project the worst case is with the ATC for the boiler, permit unit -3-0, being implemented. From the PE calculations done for the facility (see Appendix D),the following annual emissions were calculated. Thus:
{Note: The following table adds rows 1 thru X with the results presented in the SSPE1 row. After entering the data in rows 1 thru X, highlight the SSPE1 Total row and press F9:}
Table 3: SSPE1Permit Unit / NOx (lb/yr) / SOx (lb/yr) / PM10 (lb/yr) / CO (lb/yr) / VOC (lb/yr)
-1-0, gas dispensing operation / 0 / 0 / 0 / 0 / 5,000
-2-0, emergency IC engine / 125 / 5 / 58 / 250 / 6
-3-0, 10.0 MMBtu/hr boiler / 2,258 / 50 / 452 / 5,689 / 753
SSPE1 Total / 2,383 / 55 / 510 / 5,939 / 5,759
4. Post-Project Stationary Source Potential to Emit (SSPE2)
Pursuant to Section 4.10 of District Rule 2201, the Post-project Stationary Source Potential to Emit (SSPE2) is the Potential to Emit (PE) from all units with valid ATCs or PTOs, except for emissions units proposed to be shut down as part of the Stationary Project, at the Stationary Source and the quantity of Emission Reduction Credits (ERCs) which have been banked since September 19, 1991 for Actual Emissions Reductions that have occurred at the source, and which have not been used on-site.
{If this is a new facility use the following statement. Enter the calculated PE2 from Section VII.C.2.b into the SSPE2 table below. After entering the data in rows 1 thru X, highlight the SSPE2 Total row and press F9:}
Since this is a new facility, SSPE2 is equal to the change in emissions for the facility due to the installation of the new automotive coating operation, unit -X-X, as previously determined in Section VII.C.2.b. Thus:
Table 4: SSPE2Permit Unit / NOx (lb/yr) / SOx (lb/yr) / PM10 (lb/yr) / CO (lb/yr) / VOC (lb/yr)
-X-X, new automotive coating operation / 0 / 0 / 4,672 / 0 / 19,966
SSPE2 Total / 0 / 0 / 4,672 / 0 / 19,966
{If this is an existing facility use the following statement:}
Since this is a modification to an existing facility, SSPE2 is equal to the PE2Total Post-Project from all units for all criteria pollutants.
For this project the change in emissions for the facility is due to the installation of the new automotive coating operation, unit -X-X. Thus:
{Note: The following table adds rows 1 thru X with the results presented in the SSPE1 row. After entering the data in rows 1 thru X, highlight the SSPE2 Total row and press F9.}
Table 5: SSPE2Permit Unit / NOx (lb/yr) / SOx (lb/yr) / PM10 (lb/yr) / CO (lb/yr) / VOC (lb/yr)
-1-0, gas dispensing operation / 0 / 0 / 0 / 0 / 5,000
-2-0, emergency IC engine / 125 / 5 / 58 / 250 / 6
-3-0, 10.0 MMBtu/hr boiler / 2,258 / 50 / 452 / 5,689 / 753
-X-X, new automotive coating operation / 0 / 0 / 4,672 / 0 / 19,966
SSPE2 Total / 2,383 / 55 / 5,182 / 5,939 / 25,725
5. Major Source Determination
The following table compares the pre-project and post-project facility-wide annual emissions in order to determine if this facility is already an existing Major Source or if the facility is becoming a new Major Source as a result of this project.
Table 6: Major Source DeterminationPollutant / SSPE1 (lb/yr) / SSPE2 (lb/yr) / Major Source Levels (lb/yr) / Major Source?
NOx / 0 / 0 / 50,000 / No
SOx / 0 / 0 / 140,000 / No
PM10 / 0 / 4,672 / 140,000 / No
CO / 0 / 0 / 200,000 / No
VOC / 0 / 19,966 / 50,000 / No
The preceding table shows that this facility is not a Major Source for any criteria pollutant.