SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Transcription

1 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT Guideline for Expedited Application Review (GEAR) 12a-Motor Vehicles and Mobile Equipment Coating Operations with a Burner for Paint Drying and In-Booth Priming Approved By: SIGNED David Warner Director of Permit Services Date: _August 15, 2005_ Purpose: To outline procedures for expedited processing of Authority to Construct (ATC) applications for motor vehicle and mobile equipment coating operations. These procedures will apply to processing of applications received over the counter or through the mail. I. Applicability This policy applies to processing of applications for Authority to Construct for new motor vehicle and mobile equipment coating operations that: emit up to 10 tons/year of VOCs, and are equipped with drying provisions with an oven capacity of less than 2.0 MMBtu/hr, and priming is performed inside the booth. II. Permit Application and Supplementary Forms The applicant must complete a regular application form and the Painting and Coating Operations Supplemental Form (see Attached Supplemental Application). III. Priority Processing The applications will be processed on an expedited basis if a complete application, complete supplemental form and correct filing fees for each permit unit are submitted. In order to meet the expedited time frame, the engineer assigned for preliminary review will deem the project complete (if appropriate) as of the date received. The project will then be automatically assigned for final review to the same engineer, who must then write the application review and finalize the GEAR 12a-1

2 project within seven days. The application review and final ATC will be submitted to the lead engineer for review. Final action on all projects will occur within thirty days after the submittal of the complete package. The priority processing will be pre-empted if: The application is subject to any public noticing requirements, including school notice per CH&SC (within 1000 feet of any K-12 school), or The application is part of a stationary source project where issuance of the permit will affect the outcome of the stationary source project. IV. Application Review In order to standardize the application reviews for this source category, the application review (as found on the AIRnet, under Policies/GEARs) will be used as a base document. The document is based on a new facility that is limited to 10 tons/year of VOC emissions. Minor revisions will be needed if higher or lower limits are requested/required. The following pages are a hard copy version of this standard review. This hard copy version for the GEAR Policy manual includes a copy of the required supplemental application form (see Attached Supplemental Application), the up-to-date Best Available Control Technology (BACT) analysis (see Attached BACT analysis), and the standard Authority to Construct (ATC) conditions (see Attached General Conditions). These attachments will be referred to, but will not be included in the actual application review done for a specific application. Of the attachments the application review will only include the draft ATC conditions. This will minimize the number of pages for the expedited application review. The use of this standard Application Review will ensure: A. That the proposed project complies with BACT requirements as specified in the District s current BACT Clearinghouse. B. That the proposed project is either exempt from offsets or the emissions from the project do not trigger offset requirements. C. That the permit has enforceable daily emission limitations (DELs) D. That the proposed project complies with all applicable prohibitory rules. Health Risk Assessment: A site-specific HRA must be conducted for all applications. GEAR 12a-2

3 V. Equipment Description To ensure uniformity, one of the following standard descriptions will be used: {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. Authority to Construct Conditions To ensure uniformity, a standard set of conditions will be used as a base for all applications (see Attached ATC Conditions). Additional conditions may be necessary on a site-specific basis due to New Source Review requirements or health risk assessment. See PAS Category GEAR 12-A for general conditions. VII. Updates This GEAR will be updated as necessary to accommodate any changes in prohibitory rules, changes in the BACT Clearinghouse, or changes in cost information for the top-down BACT Analysis. The Permitting Handbook will also be updated whenever this GEAR document is updated. Each update will be submitted to the GEAR coordinator for review and the coordinator will forward the updates for Director approval. GEAR 12a-3

4 Facility Name: Facility s Name Authority to Construct Application Review Motor Vehicle and Mobile Equipment Coating (with dryer and in-booth priming) Facility s Mailing Address Mailing Address: Facility s City, CA Zip Code 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 Date: Completion Date Engineer: Engineer s Name Lead Engineer: Engineer s Name I. Proposal The primary business of facility name is the repairing and painting 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. All painting, including the application of primer, will be conducted inside of the paint booth. II. Applicable Rules Rule 2010 Permits Required (12/17/92) Rule 2201 New and Modified Stationary Source Review Rule (12/19/02) Rule 2520 Federally Mandated Operating Permits (6/21/01) Rule 4101 Visible Emissions (11/15/01) Rule 4102 Nuisance (12/17/92) Rule 4201 Particulate Matter Concentration (12/17/92) Rule 4301 Fuel Burning Equipment (12/17/92) Rule 4602 Motor Vehicle and Mobile Equipment Refinishing Operations (12/20/01) Rule 4801 Sulfur Compounds (12/17/92) CH&SC CH&SC GEAR 12a-4

5 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 N. Street Rd. in Any City, CA. The applicant states that the equipment is/is not located within 1,000 feet of a K-12 school. Therefore, the public notification requirement of California Health and Safety Code 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 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 MMBtu/hr or if the LPG-fired burner rating is 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 > MMBtu/hr or the LPG-fired burner rating is > 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: D for burners between 0.65 to 1.5 MMBtu/hr at $268/yr versus 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 NO x emissions 2.0 lbs/day and the record-keeping requirement to maintain the exemption. For example: Daily operation of a natural gasfired burner = 2.0 lbs-nox/day [Burner Rating (MMBtu/hr) x 0.1 lb-no x /MMBtu] or Daily operation of a LPG-fired burner = 2.0 lbs-nox/day [Burner Rating (MMBtu/hr) x 0.15 lb-no x /MMBtu] District approved gun cleaner GEAR 12a-5

6 {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 PM 10 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 PM 10 control, High Volume Low Pressure (HVLP) spray equipment for PM 10 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 PM 10 emissions by filtering air from inside the paint booth before it is exhausted to the atmosphere. The HVLP spray equipment will control PM 10 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 NO x, SO x, PM 10, CO, and VOC from the burner the applicant has proposed the combustion of {natural gas or LPG} to keep emissions at a minimum. GEAR 12a-6

7 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 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 NO x, add the following assumption:} To avoid triggering BACT for NO x, 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 NO x 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 the Applicant has proposed BACT for NO x (i.e. a natural gasfired burner), add the following assumption:} To avoid record keeping for operation of the dryer, operation is assumed to be 24 hr/day (per Applicant). GEAR 12a-7

8 B. Emission Factors For unit -X-X, the new motor vehicle coating operation: PM 10 emission factor (EF) for enamel paint (worst case) is 5.5 lb/gal, assuming all particulate matter (PM) emissions are PM 10 (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 PM 10 emissions). PM 10 EF for primer (worst case) is 3.0 lb/gal, assuming all PM emissions are PM 10 (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 VOC bc = 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 VOC Thinner bc = 6.80 lb-voc/gal EF VOC Hardener 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: GEAR 12a-8

9 EF VOC bc 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 VOC bc 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 VOC bc 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 VOC cc = 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 VOC Thinner cc = 4.80 lb-voc/gal EF VOC Hardener 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 VOC cc 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 VOC cc 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 VOC cc 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 VOC mc = 2.50 lb-voc/gal GEAR 12a-9

10 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 VOC mc = 1.80 lb-voc/gal EF VOC mc = 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 VOC mc 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 VOC mc 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 VOC mc 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 VOC gc = 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 VOC Thinner gc = 5.50 lb-voc/gal EF VOC Hardener 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 VOC gc 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 GEAR 12a-10

11 EF VOC gc 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 VOC gc 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 VOC Two Stage MS (lb-voc/gal) = [EF VOC bc (lb-voc/gal) + 2 x EF VOC cc (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 VOC Two 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 VOC Three Stage MS (lb-voc/gal) = [EF VOC bc (lb-voc/gal) + EF VOC mc (lb- VOC/gal) + 2 x EF VOC cc (lb-voc/gal)] 4 EF VOC Three Stage MS lb-voc/gal = [3.37 lb-voc/gal lb-voc + 2 x (4.05 lb- VOC)] 4 EF VOC Three 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 VOC Four Stage MS (lb-voc/gal) = [EF VOC gc (lb-voc/gal) + EF VOC bc (lb- VOC/gal) + EF VOC mc (lb-voc/gal) + 2 x EF VOC cc (lb-voc/gal)] 5 EF VOC Four Stage MS lb-voc/gal = [4.96 lb-voc/gal lb-voc/gal lb- VOC + 2 x (4.05 lb-voc)] 5 EF VOC Four 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.} GEAR 12a-11

12 Table 1: Burner Emission Factors Operation Emission Rate Source 0.10 lb-no x /MMBtu AP-42, Table & -2 (7/98) Natural gas combustion in the burner lb-so x /MMBtu APR-1720 (12/01) lb-pm 10 /MMBtu AP-42, Table & -2 (7/98) lb-co/mmbtu AP-42, Table & -2 (7/98) lb-voc/mmbtu AP-42, Table & -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 0.15 lb-no x /MMBtu AP-42, Table (10/96) LPG combustion in the burner lb-so x /MMBtu AP-42, Table (10/96), see calculation below lb-pm 10 /MMBtu AP-42, Table (10/96) lb-co/mmbtu AP-42, Table (10/96) lb-voc/mmbtu AP-42, Table (10/96) LPG Combustion SO x 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 MMBtu/gal Sulfur EF = lb-so x /MMBtu GEAR 12a-12

13 C. Calculations 1. Pre-Project Potential to Emit (PE1) Pre-project emissions from unit -X-X, the new 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, the daily hours of operation of the dryer, the daily VOC emissions limit, the VOC and PM 10 content of the paint, the HVLP gun transfer efficiency, and the dry exhaust filter removal efficiency. To make the VOC and PM 10 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 (PE2 Combustion ): PE2 Combustion (lb/day) = EF (lb/mmbtu) x Burner Rating (MMBtu/hr) x Operation (hr/day) PE2 Combustion NOx = 0.10 lb-no x /MMBtu x 1.0 MMBtu/hr x 24 hr/day = 2.4 lb-no x /day PE2 Combustion SOx = lb-so x /MMBtu x 1.0 MMBtu/hr x 24 hr/day = 0.1 lb-so x /day PE2 Combustion PM10 = lb-pm 10 /MMBtu x 1.0 MMBtu/hr x 24 hr/day = 0.2 lb-pm 10 /day PE2 Combustion CO = lb-co/mmbtu x 1.0 MMBtu/hr x 24 hr/day = 2.0 lb-co/day PE2 Combustion VOC = lb-voc/mmbtu x 1.0 MMBtu/hr x 24 hr/day = 0.1 lb-voc/day GEAR 12a-13

14 Emissions from the coating operation (PE2 Painting ): First the daily VOC emissions for painting are determined: PE2 Painting VOC (lb/day) = VOC limit (lb/day) PE2 Comb VOC (lb/day) PE2 Painting VOC = 54.7 lb-voc/day 0.1 lb-voc/day = 54.6 lb-voc/day Then the daily enamel paint usage is determined: Daily Paint Usage (gal/day) = PE2 Painting (lb-voc/day) Enamel Paint VOC Content (lb-voc/gal) Daily Paint Usage = 54.6 lb-voc/day 2.0 lb-voc/gal = 27.3 gal/day Next the daily PM 10 emissions from painting are determined: PE2 Painting PM10 (lb/day) = Daily Paint Usage (gal/day) x Enamel Paint PM 10 Content (lb-pm 10 /gal) x (1 HVLP Transfer Efficiency) x (1 Dry Filter Control Efficiency) PE2 Painting PM10 = 27.3 gal/day x 5.5 lb-pm 10 /gal x (1 0.75) x (1 0.66) = 12.8 lb-pm 10 /day {Note: The following table adds columns 1 and 2 with the result presented in column 3. After entering the data in columns 1 and 2, highlight column 3 and press F9.} Table 2: Daily PE2 Pollutant PE2 Combustion (lb/day) PE2 Painting (lb/day) PE2 Total (lb/day) NO x SO x PM CO VOC GEAR 12a-14

15 b. Annual PE2 (lb/yr) Annual post-project emissions from unit -X-X, the new 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. PE2 Annual (lb/yr) = PE2 (lb-pollutant/day) x 365 day/yr PE2 Annual NOx PE2 Annual SOx = 2.4 lb-no x /day x 365 day/yr = 876 lb-no x /yr = 0.1 lb-so x /day x 365 day/yr = 37 lb-so x /yr PE2 Annual PM10 = 13.0 lb-pm 10 /day x 365 day/yr = 4,745 lb-pm 10 /yr PE2 Annual CO PE2 Annual VOC = 2.0 lb-co/day x 365 day/yr = 730 lb-co/yr = 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 3: Annual PE2 Pollutant PE2 (lb/day) PE2 (lb/yr) NO x SO x PM ,745 CO VOC ,966 GEAR 12a-15

16 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 PE1 Total 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:} GEAR 12a-16

17 Table 4: SSPE1 Permit Unit NO x (lb/yr) SO x (lb/yr) PM 10 (lb/yr) CO (lb/yr) VOC (lb/yr) -1-0, gas dispensing operation -2-0, emergency IC engine -3-0, 10.0 MMBtu/hr boiler , , , SSPE1 Total 2, ,939 5, 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 5: SSPE2 Permit Unit NO x (lb/yr) SO x (lb/yr) PM 10 (lb/yr) CO (lb/yr) VOC (lb/yr) -X-X, new automotive coating operation , ,966 SSPE2 Total , ,966 GEAR 12a-17

18 {If this is an existing facility use the following statement:} Since this is a modification to an existing facility, SSPE2 is equal to the PE2 Total 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 6: SSPE2 Permit Unit NO x (lb/yr) SO x (lb/yr) PM 10 (lb/yr) CO (lb/yr) VOC (lb/yr) -1-0, gas dispensing operation -2-0, emergency IC engine -3-0, 10.0 MMBtu/hr boiler -X-X, new automotive coating operation , , , , ,966 SSPE2 Total 3, ,255 6,669 25, 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. GEAR 12a-18

19 Table 7: Major Source Determination Pollutant SSPE1 (lb/yr) SSPE2 (lb/yr) Major Source Levels (lb/yr) Major Source? NO x ,000 No SO x ,000 No PM , ,000 No CO ,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. 6. Annual Baseline Emissions (BE) The BE is required, unit by unit, pollutant by pollutant, to determine the Net Emissions Change (NEC), which is reported quarterly in the PAS emissions profile, and to calculate the amount of offsets required, where necessary, when the SSPE1 is greater than the offset threshold. BE are determined for each emissions unit in this project in pounds/year as follows: BE = Pre-project Potential to Emit for: Any unit located at a non-major Source, Any Highly-Utilized Emissions Unit (80% of pre-project emissions), located at a Major Source, Any Fully-Offset Emissions Unit (a unit for which offsets have been provided), located at a Major Source, or Any Clean Emissions Unit (a unit that has a control efficiency of 95%, or 85% for a clean burn IC engine, or has met AIP BACT for the five years immediately prior to the submission of the complete application), located at a Major Source. Otherwise, BE = Historic Actual Emissions (HAE) {For a GEAR project, the following statement will be true. If not, please speak to your supervisor; this project is NOT a GEAR.} GEAR 12a-19

20 As shown previously in Section VII.C.5 this facility is not a Major Source for any criteria pollutant. Thus, BE = PE1 for all criteria pollutants. Since this unit is also a new unit at this facility PE1 = 0 lb/yr for all criteria pollutants. Thus: BE = 0.0 lb/yr for all criteria pollutants 7. Contemporaneous Increase in Permitted Emissions (CIPE) and Title I Modification Determination {For a GEAR project, the following statement will be true. If not, please speak to you supervisor, this project is NOT a GEAR.} This facility is not becoming a Major Source, as previously shown in Section VII.C.5, as a result of this project. Since, for non Major-Sources, the Title I Modification thresholds are equivalent to the Major Source Thresholds, this project is not a Title I Modification (Major Modification). Therefore the CIPE will not be calculated. 8. Quarterly Net Emissions Change (QNEC) The QNEC is calculated solely to establish emissions that are used to complete the District s PAS database emissions profile screen. Detailed QNEC calculations are included in Appendix B. VIII. Compliance Rule New and Modified Stationary Source Review Rule A. Best Available Control Technology (BACT) 1. BACT Applicability BACT requirements are triggered on a pollutant-by-pollutant basis and on an emissions unit-by-emissions unit basis for the following*: a) Any new emissions unit with a potential to emit exceeding two pounds per day, b) The relocation from one Stationary Source to another of an existing emissions unit with a potential to emit exceeding two pounds per day, c) Modifications to an existing emissions unit with a valid Permit to Operate resulting in an AIPE exceeding two pounds per day, and/or d) When a Title I Major Modification is triggered for a modification project at a facility that is a Major Source. *Except for CO emissions from a new or modified emissions unit at a Stationary Source with an SSPE2 of less than 200,000 pounds per year of CO. GEAR 12a-20

21 For this project there is the installation of a new permit unit. This permit unit consists of two emissions units, the {natural gas-fired or LPG fired} burner and the painting operation. This will result in daily increases in all criteria pollutant emissions for permit unit -X-X, as calculated previously in Section VII.C.2.a and presented below. Table 8: BACT Applicability Pollutant PE2 Combustion (lb/day) PE2 Painting (lb/day) BACT Trigger Levels (lb/day) BACT Required? NO x > 2.0 Yes, for combustion SO x > 2.0 No PM > 2.0 Yes, for painting CO > 2.0 and SSPE2 > 200,000 lb/yr VOC > 2.0 Yes, for painting No Thus BACT will be triggered for NO x emissions from the combustion operation and PM 10 and VOC emissions from the painting operation for this project. 2. BACT Analysis Per District Policy APR 1305, Section IX, A top-down BACT analysis shall be performed as a part of the Application Review for each application subject to the BACT requirements pursuant to the District s NSR Rule for source categories or classes covered in the BACT Clearinghouse, relevant information under each of the following steps may be simply cited from the Clearinghouse without further analysis. Pursuant to the BACT guideline 4.2.1, (current quarter) (current year), and the Top-Down BACT analysis, both of which appear in Appendix A of this report, BACT is satisfied with: HVLP spray guns, coatings compliant with District rules, and enclosed paint gun cleaners {Natural gas-fired or LPG fired} burner Spray booth with exhaust filters used for the priming and painting operations GEAR 12a-21

22 The applicant is proposing BACT by using HVLP spay guns, coatings compliant with District rules, enclosed paint gun cleaners, a {natural gas-fired or LPG fired} burner, and a spray booth with exhaust filters used for the priming and painting operations. Therefore, the following conditions will be listed on the proposed ATC to ensure compliance: {2934} Only HVLP, electrostatic, brush, dip, or roll coating application equipment, or other application equipment approved by the District in writing, shall be used. All application equipment shall be operated in accordance with the manufacturer's recommendations. [District Rule 4602] {1776} VOC content of coatings as applied, excluding water and exempt compounds, used for Group I vehicles or Group II vehicles (when a color match is required) shall not exceed any of the following limits: pretreatment wash primer 780 g/l (6.5 lb/gal), precoat: 600 g/l (5.0 lb/gal) primer/primer surfacer: 250 g/l (2.1 lb/gal), primer sealer: 420 g/l (3.5 lb/gal), topcoat: 420 g/l (3.5 lb/gal), metallic/iridescent topcoat: 520 g/l (4.3 lb/gal), and multi-stage topcoat system: 540 g/l (4.5 lb/gal). [District Rule 4602] {1777} VOC content of coatings as applied, excluding water and exempt compounds, used for Group II vehicles (when a color match is not required) shall not exceed any of the following limits: pretreatment wash primer 780 g/l (6.5 lb/gal), precoat: 600 g/l (5.0 lb/gal), primer/primer surfacer: 250 g/l (2.1 lb/gal), primer sealer: 340 g/l (2.8 lb/gal), topcoat: 420 g/l (3.5 lb/gal), metallic/iridescent topcoat: 420 g/l (3.5 lb/gal), and camouflage: 420 g/l (3.5 lb/gal). [District Rule 4602] {1779} VOC content of temporary protective coatings shall not exceed 60 g/l (0.5 lb/gal) of material. [District Rule 4602] {1778} VOC content of specialty coatings (as defined in Rule 4602) as applied, excluding water and exempt compounds, shall not exceed 840 g/l (7.0 lb/gallon). If specialty coating usage, except anti-glare/safety coatings, exceeds 1 gallon per day, such coatings shall not exceed 5% (by volume) of total coatings applied in any month. [District Rule 4602] {1882} The permittee shall not use materials with a VOC content greater than 50 g/l (0.42 lb/gallon) for spray equipment clean-up unless an enclosed system or equipment proven to be equally effective is used for cleaning. [District Rule 4602] {1608} Only PUC quality natural gas, or LPG shall be used as fuel. [Rule 2201] GEAR 12a-22

23 B. Offsets {1986} All painting, including application of primer, shall be conducted inside the booth with filters in place, fan(s) operating, and doors closed. [District Rule 2201] 1. Offset Applicability Offset requirements shall be triggered on a pollutant-by-pollutant basis. Unless exempted pursuant to Section 4.6, offsets shall be required if the post-project SSPE2 equals or exceeds the following offset threshold levels. The following table compares the post-project facility-wide annual emissions in order to determine if offsets will be required for this project at this facility. Table 9: Offsets Applicability Pollutant SSPE2 (lb/yr) SSPE2 Offset Levels (lb/yr) Offsets Required? NO x ,000 No SO x 37 54,750 No PM 10 4,745 29,200 No CO ,000 No VOC 19,966 20,000 No Therefore, offsets will not be required for this project for any increases in criteria pollutant emissions since no criteria pollutants are above the offset threshold levels. C. Public Notification Public noticing is required for: a. A new facility, which is also a Major Source, b. Title I Modifications of an existing Major Source, c. Any new emissions unit with a PE of greater than 100 pounds during any one day for any pollutant, d. Any project, which results in the offset thresholds being reached or exceeded, and/or e. Any project with an SSIPE of greater than 20,000 lb/yr for any pollutant. GEAR 12a-23

24 1. Public Notice Applicability a. Major Source As shown previously in the Major Source Determination table in Section VII.C.5 this facility is not a new facility that is a new major source for any criteria pollutant emissions. Therefore, public noticing is not required for this project for new Major Source purposes because this facility is not becoming a new Major Source. b. Title I Modification As shown previously in Section VII.C.7, this project does not constitute a Title I Modification. Therefore, public noticing is not required for this project for exceeding the Title I Modification thresholds. c. PE > 100 lb/day There are two new emissions units at this facility. For new emissions units, public notification is required if the PE exceeds 100 lb/day for any criteria pollutant. The Daily PE for each emissions unit, as calculated previously in Section VII.C.2.a, is less than daily PE Public Notice threshold of 100 lb/day for all criteria pollutants. Therefore, public noticing is not required for this project for exceeding the PE Public Notice Thresholds. d. Offset Thresholds The following table compares the pre-project SSPE1 with the post-project SSPE2 in order to determine if any offset thresholds have been surpassed. GEAR 12a-24

25 Table 10: Offset Thresholds Pollutant SSPE1 (lb/yr) SSPE2 (lb/yr) SSPE2 Offset Levels (lb/yr) Public Notice Required? NO x ,000 No SO x ,750 No PM ,745 29,200 No CO ,000 No VOC 0 19,966 20,000 No Therefore, public noticing is not required for this project for reaching or surpassing the SSPE2 offset thresholds. e. SSIPE > 20,000 lb/yr The values for SSPE2 and SSPE1 are calculated according to Rule 2201, Sections 4.9 and 4.10, respectively, where SSIPE = SSPE2 - SSPE1. Public noticing is required if the SSIPE exceeds 20,000 lb/yr for any pollutant. The SSIPE is compared to the SSIPE Public Notice thresholds in the following table: {Note: The following table subtracts column 2 from 1 with the result presented in column 3. After entering the data in columns 1 and 2, highlight column 3 and press F9.} Table 11: SSIPE Thresholds Pollutant SSPE2 (lb/yr) SSPE1 (lb/yr) SSIPE (lb/yr) SSIPE Public Notice Levels (lb/yr) Public Notice Required? NO x ,000 No SO x ,000 No PM 10 4, ,745 20,000 No CO ,000 No VOC 19, ,966 20,000 No GEAR 12a-25

26 Therefore, public noticing is not required for this project for exceeding the SSIPE thresholds. 2. Public Notice Action As discussed above, public noticing pursuant to Section 5.4 of District Rule 2201 is not required for this project. D. Daily Emissions Limits (DEL) DELs are required by section The DELs are required to enforce the applicability of BACT. For this installation of a new automotive coating operation project the DELs are stated in the form of maximum daily emission rates for the painting operation and emissions factors for the burner. Therefore, the following conditions will be listed on the proposed ATC to ensure compliance: {1987} VOC emissions from the entire facility shall not exceed 54.7 pounds in any one day. [District Rule 2201] {2904} Particulate matter (PM10) emission rate (including painting and priming) shall not exceed 13.0 lb/day. [District Rule 2201] {2905} Emissions from the burner shall not exceed any of the following limits: 0.10 lb-nox/mmbtu, lb-sox/mmbtu, lb- PM10/MMBtu, lb-co/mmbtu, or lb-voc/mmbtu. [District Rule 2201] E. Compliance Assurance The following measures shall be taken to ensure continued compliance with District Rules: 1. Source Testing Per District Source Testing Frequency policy APR-1705, dated 10/9/97, source testing is not required for coating operations. As such, source testing will not be required of this permit unit. 2. Monitoring There is no monitoring required of this permit unit. GEAR 12a-26

27 3. Recordkeeping The permittee shall maintain records in accordance with Section 3.0 of District Rule 1070 as required by permit condition. Therefore, the following conditions will be listed on the proposed ATC to ensure compliance: {1792} Records shall be retained on-site for a minimum of five years and made available for District inspection upon request. [District Rule 4602] {1828} Permittee shall maintain daily records of the following: quantity and type (Group I, Group II vehicle with color match, or Group II vehicle without color match) of each vehicle coated; specific coatings used on each vehicle; mix ratios (by volume) of components added to each coating; volume of coatings applied; VOC content of each coating as applied; and purchase and usage of each specific solvent or reducer, showing the date, type and volume purchased or used. [District Rule 4602] {1885} Permittee shall keep the following records for solvent cleaning activities: manufacturers product data sheet or MSDS of solvents used, VOC content of solvents in g/l or lb/gal, and the type of cleaning activity for which each solvent is used. [District Rule 4602] 4. Reporting There is no reporting required of this permit unit. Rule Federally Mandated Operating Permits Since this facility s potential emissions do not exceed any major source thresholds of Rule 2201, as shown previously in the Major Source Determination table in Section VII.C.5, this facility is not a major source, and Rule 2520 does not apply. Rule Visible Emissions Rule 4101 states that no air contaminant shall be discharged into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is as dark as, or darker than, Ringelmann 1 or 20% opacity. As long as the equipment is properly maintained and operated, compliance with visible emissions limits is expected under normal operating conditions. The following condition will be listed on the proposed ATC to ensure compliance: {15} No air contaminant shall be discharged into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is as dark as, or darker than, Ringelmann 1 or 20% opacity. [District Rule 4101] GEAR 12a-27

28 Rule Public Nuisance Rule 4102 states that no air contaminant shall be released into the atmosphere that causes a public nuisance. The following condition will be listed on the proposed ATC to ensure compliance: {98} No air contaminant shall be released into the atmosphere which causes a public nuisance. [District Rule 4102] Therefore pursuant to the District s Risk Management Policy for Permitting New and Modified Sources (APR 1905, 3/2/01), a risk management review has been performed for this project to analyze the impact of toxic emissions. For projects where the increase in cancer risk is greater than one per million, Toxic Best Available Control Technology (T-BACT) is required. {If the total facility Prioritization score including this project is 1.0, use the following statement:} District policy APR 1905 specifies that for an increase in emissions associated with a proposed new source or modification, the District perform an analysis to determine the possible impact to the nearest resident or worksite. A Health Risk Assessment (HRA) is not required for a project with a total facility prioritization score of less than or equal to one. According to the Technical Services Memo for this project (see Appendix C), the total facility prioritization score including this project was less than or equal to one. Therefore, no further analysis is required to determine the impact from this project. {If the total facility Prioritization score including this project > 1.0, use the following statement:} District policy APR 1905 specifies that for an increase in emissions associated with a proposed new source or modification, the District perform an analysis to determine the possible impact to the nearest resident or worksite. A Health Risk Assessment (HRA) is not required for a project with a total facility prioritization score of less than or equal to one. According to the Technical Services Memo for this project (see Appendix C), the total facility prioritization score including this project was greater than one. Therefore, an HRA was required to determine the short-term and long-term chronic exposure from this project. The HRA results for this project are shown below: Unit Acute Hazard Index Table 12: HRA Results Chronic Hazard Index Cancer Risk T-BACT Required? X-XXXX-X-X 0.XX 0.XXX 0.XX per million? GEAR 12a-28

29 CH&SC California Health & Safety Code (Health Risk Analysis) {If the Cancer risk is < 1.0 x 10-6 and the Hazard indices risk for this project is < 1.0 use the following statement:} BACT for toxic emission control (T-BACT) is required if the cancer risk exceeds one in a million. As demonstrated above, T-BACT is not required for this project because the HRA for this project (see Appendix B) indicates that the risk is not above the District s thresholds for triggering T-BACT requirements. {Scenario 1} The applicant has proposed that no paints containing {Note: Use applicable compounds as proposed by the applicant.} chromium compounds, lead compounds, and/or nickel compounds will be used at this facility. Because this was taken into account to determine this project s health risk, the ATC for this project will require that no paints containing {Note: Use applicable compounds as proposed by the applicant.} chromium compounds, lead compounds, and/or nickel compounds will be used at this facility. {Note: Use applicable general conditions depending on the compounds proposed by the applicant.} Therefore, the following conditions will be listed on the proposed ATC to ensure compliance: {369} No coatings, solvents, or additives containing chromium compounds shall be used. [District Rule 4102] {1984} No coatings, solvents, or additives containing lead compounds shall be used. [District Rule 4102] {1985} No coatings, solvents, or additives containing nickel compounds shall be used. [District Rule 4102] {Scenario 2} The applicant has proposed that paints containing {Note: List applicable compounds as proposed by the applicant. As of 2003, no automotive paints containing chromium or cadmium compounds can be used in California.} lead and/or nickel compounds, will be used at this facility. Because this was taken into account to determine this project s health risk, the ATC for this project will require that the use of paints containing {Note: Use applicable compounds as proposed by the applicant.} lead and/or nickel compounds be limited and that no paints containing chromium compounds be used at this facility. Therefore, the following conditions will be listed on the proposed ATC to ensure compliance: {1540} The as-applied use of coatings containing (list toxic compound) shall not exceed XX.X pint(s) per day and XX.X pint(s) per year. [District Rule 4102 and CH&SC 41700] {369} No coatings, solvents, or additives containing chromium compounds shall be used. [District Rule 4102] GEAR 12a-29