A.3.2 Minn. R. for Material Usage and Processing Operations (non Fiberglassing) placed in operation on or after July 9, 1969

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1 A.3 Material Usage and Processing Operations (non Fiberglassing) The following are Minnesota Standards of Performance for Industrial Process Equipment A.3.1 Minn. R. for Material Usage and Processing Operations (non Fiberglassing) placed in operation before July 9, 1969 What to do Why to do it Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20% opacity except for one-six-minute period per hour of not more than 60% opacity. Minn. R , subp. 1(A); Minn. R , subp. 1(B) A.3.2 Minn. R. for Material Usage and Processing Operations (non Fiberglassing) placed in operation on or after July 9, 1969 What to do Why to do it Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R or Minn. R Minn. R , subp. 1(A); Opacity: less than or equal to 20% opacity. Minn. R , subp. 1(B) aq-12-01n 4/30/15 Page 43

2 A.3.3 NESHAP subp. HHHHHH The following are National Emission Standards for Hazardous Air Pollutants for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources - Paint Stripping using chemical strippers that contain methylene chloride (MeCl) - Autobody refinishing operations that encompass motor vehicle and mobile equipment spray-applied surface coating operations - Spray application of coatings containing target HAP: chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) Subject to NESHAP HHHHHH Affected Source for NESHAP subp. HHHHHH: The collection of all items listed below: 1) The affected source is an area source of HAP that performs one of the activities described in the paragraphs 2) through 4) below. An area source is a source of HAP that is not a major source of HAP, is not located at a major source, and is not part of a major source of HAP emissions. 2) Paint stripping using chemical strippers that contain methylene chloride (MeCl), Chemical Abstract Number 75092, for the removal of dried paint (including, but not limited to, paint, enamel, varnish, shellac, and lacquer) from wood, metal, plastic, and other substrates; 3) Spray application of coatings, as defined in , to motor vehicles and mobile equipment that are located in stationary structures at fixed locations, and mobile repair and refinishing operations that travel to the customer s location. a. The Permittee may petition the Administrator for an exemption if the Permittee can demonstrate that no spray coatings used at the facility contain the target HAP, as defined below. Petitions must include a description of the coatings spray-applied and a certification that no spray-applied coatings contain the target HAP. If circumstances change such that the Permittee intends to spray apply coatings containing the target HAP, the Permittee must submit the initial notification required by and comply with the requirements of NESHAP HHHHHH. 4) Spray application of coatings that contain the target HAP as defined below to plastic and/or metal substrate on a part or product, except spray coating applications that meet the definition of facility maintenance. 5) The affected source is the collection of all the following: a. Mixing rooms and equipment; b. Spray booths, ventilated prep stations, curing ovens, and associated equipment; c. Spray guns and associated equipment; d. Spray gun cleaning equipment; e. Equipment used for storage, handling, recovery, or recycling of cleaning solvent or waste paint, and f. Equipment used for paint stripping materials containing MeCl at paint stripping facilities. aq-12-01n 4/30/15 Page 44

3 New Source: The Permittee commenced construction after September 17, 2007 by installing new paint stripping or surface coating equipment. Construction does not include the purchase and installation of spray booths, enclosed spray gun cleaners, paint stripping equipment to reduce MeCl emissions, or new spray guns to comply with this subpart at an existing source; these actions do not make an existing source a new source. However, an affected facility with new paint stripping or surface coating equipment that was not actively engaged in paint stripping and/or miscellaneous surface coating prior to September 17, 2007 is a new source. Reconstructed Source: An affected source is reconstructed if it meets the definition of reconstruction in Existing Source: An affected source that is not a new or reconstructed source. Compliance dates: All compliance dates have passed for this standard. For an existing affected source the compliance date was January 10, For a new or reconstructed affected source with initial startup after September 17, 2007, the compliance date was January 9, If the initial startup of the affected source occurred after January 9, 2008, the compliance date was the date of initial startup of the affected source (Also see (a) and (b)). Definitions: (Also see ) Architectural coating means a coating to be applied to stationary structures or their appurtenances at the site of installation, to portable buildings at the site of installation, to pavements, or to curbs. Coating: For the purposes of this subpart, a material spray-applied to a substrate for decorative, protective, or functional purposes. For the purposes of this subpart, coating does not include the following materials: (1) Decorative, protective, or functional materials that consist only of protective oils for metal, acids, bases, or any combination of these substances. (2) Paper film or plastic film that may be pre-coated with an adhesive by the film manufacturer. (3) Adhesives, sealants, maskants, or caulking materials. (4) Temporary protective coatings, lubricants, or surface preparation materials. (5) In-mold coatings that are spray-applied in the manufacture of reinforced plastic composite parts. Facility maintenance: Includes surface coating performed as part of the routine repair or renovation of the tools, equipment, machinery, and structures that comprise the infrastructure of the facility and that are necessary for the facility to function in its intended capacity. Facility maintenance also includes surface coating associated with the installation of new equipment or structures, and the application of any surface coating as part of janitorial activities. Facility maintenance includes the application of coatings to stationary structures or their appurtenances at the site of installation, to portable buildings, to pavements, or to curbs. Facility maintenance also includes the refinishing of mobile equipment in the field or at the site where they are used in service. Such mobile equipment includes, but is not limited to, farm equipment and mining equipment for which it is not practical or feasible to move to a dedicated mobile equipment refinishing facility. Such mobile equipment also includes items, such as fork trucks, that are used in a manufacturing facility and which are refinished in that same facility. Facility maintenance does not include surface coating of motor vehicles, mobile equipment, or items that routinely leave and return to the facility, such as delivery trucks, rental equipment, or containers used to transport, deliver, distribute, or dispense commercial products to customers, such as compressed gas canisters. aq-12-01n 4/30/15 Page 45

4 Materials that contain HAP or HAP-containing materials: For the purposes of NESHAP HHHHHH, materials that contain 0.1 percent or more by mass of any individual HAP that is an OSHA-defined carcinogen as specified in 29 CFR (d)(4), or 1.0 percent or more by mass for any other individual HAP. Mobile equipment: Any device that may be drawn and/or driven on a roadway. Motor vehicle: Any self-propelled vehicle, including, but not limited to, automobiles, light duty trucks, golf carts, vans, and motorcycles. Motor vehicle and mobile equipment surface coating: The spray application of coatings to assembled motor vehicles or mobile equipment. For the purposes of this subpart, it does not include the surface coating of motor vehicle or mobile equipment parts or subassemblies at a vehicle assembly plant or parts manufacturing plant. Miscellaneous surface coating operation: The collection of equipment used to apply surface coating to miscellaneous parts and/or products made of metal or plastic, including applying cleaning solvents to prepare the surface before coating application, mixing coatings before application, applying coating to a surface, drying or curing the coating after application, and cleaning coating application equipment, but not plating. A single surface coating operation may include any combination of these types of equipment, but always includes at least the point at which a coating material is applied to a given part. A surface coating operation includes all other steps (such as surface preparation with solvent and equipment cleaning) in the affected source where HAP are emitted from the coating of a part. The use of solvent to clean parts (for example, to remove grease during a mechanical repair) does not constitute a miscellaneous surface coating operation if no coatings are applied. A single affected source may have multiple surface coating operations. Surface coatings applied to wood, leather, rubber, ceramics, stone, masonry, or substrates other than metal and plastic are not considered miscellaneous surface coating operations for the purposes of this subpart. Spray-applied coating operations: Coatings that are applied using a hand-held device that creates an atomized mist of coating and deposits the coating on a substrate. For the purposes of this subpart, spray-applied coatings do not include the following materials or activities: (1) Coatings applied from a hand-held device with a paint cup capacity that is equal to or less than 3.0 fluid ounces (89 cubic centimeters). (2) Surface coating application using powder coating, hand-held, non-refillable aerosol containers, or non-atomizing application technology, including, but not limited to, paint brushes, rollers, hand wiping, flow coating, dip coating, electrodeposition coating, web coating, coil coating, touch-up markers, or marking pens. (3) Thermal spray operations (also known as metallizing, flame spray, plasma arc spray, and electric arc spray, among other names) in which solid metallic or non-metallic material is heated to a molten or semi-molten state and propelled to the work piece or substrate by compressed air or other gas, where a bond is produced upon impact. Surface Coating Operations: For the purposes of this permit, surface coating operations refer collectively to motor vehicle and mobile equipment surface coating operations and miscellaneous surface coating operations. Target HAP: Compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd). aq-12-01n 4/30/15 Page 46

5 Target HAP containing coating: A spray-applied coating that contains any individual target HAP that is an Occupational Safety and Health Administration (OSHA)-defined carcinogen as specified in 29 CFR (d)(4) at a concentration greater than 0.1 percent by mass, or greater than 1.0 percent by mass for any other individual target HAP compound. For the purpose of determining whether materials you use contain the target HAP compounds, you may rely on formulation data provided by the manufacturer or supplier, such as the safety data sheet (SDS). COMPLIANCE REQUIREMENTS What to do Best management practices for paint stripping operations: Each affected area source must implement management practices to minimize the evaporative emissions of MeCl. The management practices must address, at a minimum, the following practices as applicable for the operations at the affected facility. 1. Evaluate each application to ensure there is a need for paint stripping (e.g., evaluate whether it is possible to re-coat the piece without removing the existing coating). 2. Evaluate each paint stripper operation containing MeCl is used to ensure that there is no alternative paint stripping technology that can be used. 3. Reduce exposure of all paint strippers containing MeCl to the air. 4. Optimize application conditions when using paint strippers containing MeCl to reduce MeCl evaporation (e.g., if the stripper must be heated, make sure that the temperature is kept as low as possible to reduce evaporation). 5. Practice proper storage and disposal of paint strippers containing MeCl (e.g., store stripper in closed, air-tight containers). Paint stripping operations with MeCl usage over 1 ton per year: Each paint stripping operation that has annual usage of more than one ton of MeCl must develop and implement a written plan to minimize the use and emissions of MeCl. The MeCl minimization plan must address, at a minimum, the management practices specified in paragraphs 1 through 5 above, as applicable for operations at the affected facility. Each operation must post a placard or sign outlining the MeCl minimization plan in each area where paint stripping operations subject to this subpart occur. Each operation with annual usage of more than one ton of MeCl must maintain a copy of their current MeCl minimization plan on site at all times. Paint stripping operations with MeCl usage under 1 ton per year: Paint stripping operations with annual usage of less than one ton of MeCl, must comply with the management practice requirements above, as applicable, but are not required to develop and implement a written MeCl minimization plan. All paint stripping operations: Each operation must maintain copies of annual usage of paint strippers containing MeCl on site at all times. hdr Why to do it (a) s (b) and (d) (b) (c) aq-12-01n 4/30/15 Page 47

6 Certification for surface coating operations: Each surface coating operation must ensure that all painters have been certified by completing training in the proper spray application of surface coatings and the proper setup and maintenance of spray equipment. The minimum requirements for training and certification are described in the training program requirements section below. The spray application of surface coatings is prohibited by persons who are not certified as having completed the training. The requirements do not apply to the students of an accredited surface coating training program who are under the direct supervision of an instructor who meets the certification requirements. Enclosure requirements for surface coating operations: Each surface coating operation must meet the following requirements. All spray-applied coatings must be applied in a spray booth, preparation station, or mobile enclosure that meets the requirements of paragraph i of this section and either paragraph ii, iii, or iv of this section as applicable. i. All spray booths, preparation stations, and mobile enclosures must be fitted with a type of filter technology that is demonstrated to achieve at least 98-percent capture of paint overspray. The procedure used to demonstrate filter efficiency must be consistent with the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) Method 52.1, Gravimetric and Dust-Spot Procedures for Testing Air-Cleaning Devices Used in General Ventilation for Removing Particulate Matter, June 4, 1992 (see 63.14). The test coating for measuring filter efficiency shall be a high solids bake enamel delivered at a rate of at least 135 grams per minute from a conventional (non-hvlp) air-atomized spray gun operating at 40 pounds per square inch (psi) air pressure; the air flow rate across the filter shall be 150 feet per minute. The Permittee may use published filter efficiency data provided by filter vendors to demonstrate compliance with this requirement and are not required to perform this measurement. The requirements of this paragraph do not apply to waterwash spray booths that are operated and maintained according to the manufacturer's specifications. ii. Spray booths and preparation stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed with a full roof, and four complete walls or complete side curtains, and must be ventilated at negative pressure so that air is drawn into any openings in the booth walls or preparation station curtains. However, if a spray booth is fully enclosed and has seals on all doors and other openings and has an automatic pressure balancing system, it may be operated at up to, but not more than, 0.05 inches water gauge positive pressure. iii. Spray booths and preparation stations that are used to coat miscellaneous parts and products or vehicle subassemblies must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth. The walls and roof of a booth may have openings, if needed, to allow for conveyors and parts to pass through the booth during the coating process (e)(1) (e)(2) aq-12-01n 4/30/15 Page 48

7 iv. Mobile ventilated enclosures that are used to perform spot repairs must enclose and, if necessary, seal against the surface around the area being coated such that paint overspray is retained within the enclosure and directed to a filter to capture paint overspray. Transfer efficiency requirements for surface coating operations: All sprayapplied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless spray gun, air-assisted airless spray gun, or an equivalent technology that is demonstrated by the spray gun manufacturer to achieve transfer efficiency comparable to one of the spray gun technologies listed above for a comparable operation, and for which written approval has been obtained from the Administrator. The procedure used to demonstrate that spray gun transfer efficiency is equivalent to that of an HVLP spray gun must be equivalent to the California South Coast Air Quality Management District's Spray Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1989 and Guidelines for Demonstrating Equivalency with District Approved Transfer Efficient Spray Guns, September 26, The requirements of this paragraph do not apply to painting performed by students and instructors at paint training centers. The requirements of this paragraph do not apply to the surface coating of aerospace vehicles that involves the coating of components that normally require the use of an airbrush or an extension on the spray gun to properly reach limited access spaces; to the application of coatings on aerospace vehicles that contain fillers that adversely affect atomization with HVLP spray guns; or to the application of coatings on aerospace vehicles that normally have a dried film thickness of less than centimeter ( in.). Spray gun cleaning requirements for surface coating operations: Each operation must meet the following requirements. All paint spray gun cleaning must be done so that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects used gun cleaning solvent. Spray gun cleaning may be done with, for example, hand cleaning of parts of the disassembled gun in a container of solvent, by flushing solvent through the gun without atomizing the solvent and paint residue, or by using a fully enclosed spray gun washer. A combination of non-atomizing methods may also be used. Training program requirements for surface coating operations: The Permittee must ensure and certify that all new and existing personnel, including contract personnel, who spray apply surface coatings, as defined above, are trained in the proper application of surface coatings. The training program must include, at a minimum, the following items. 1. A list of all current personnel by name and job description who are required to be trained; 2. Hands-on and classroom instruction that addresses, at a minimum, initial and refresher training in the following topics (e)(3) (e)(4) (f) aq-12-01n 4/30/15 Page 49

8 i. Spray gun equipment selection, set up, and operation, including measuring coating viscosity, selecting the proper fluid tip or nozzle, and achieving the proper spray pattern, air pressure and volume, and fluid delivery rate. ii. Spray technique for different types of coatings to improve transfer efficiency and minimize coating usage and overspray, including maintaining the correct spray gun distance and angle to the part, using proper banding and overlap, and reducing lead and lag spraying at the beginning and end of each stroke. iii. Routine spray booth and filter maintenance, including filter selection and installation. iv. Environmental compliance with the requirements of this subpart. 3. A description of the methods to be used at the completion of initial or refresher training to demonstrate, document, and provide certification of successful completion of the required training. Owners and operators who can show by documentation or certification that a painter's work experience and/or training has resulted in training equivalent to the training required in paragraph 2 above are not required to provide the initial training required by that paragraph to these painters. Training program requirement dates for surface coating operations: As required, all new and existing personnel at an affected motor vehicle and mobile equipment or miscellaneous surface coating source, including contract personnel, who spray apply surface coatings, as defined above, must be trained by the dates specified in the following paragraphs 1 and 2 of this section. Employees who transfer within a company to a position as a painter are subject to the same requirements as a new hire. 1. If the affected source is a new source, all personnel must be trained and certified no later than 180 days after hiring or no later than July 7, 2008, whichever is later. Painter training that was completed within five years prior to the date training is required, and that meets the requirements specified in the training program requirements above satisfies this requirement and is valid for a period not to exceed five years after the date the training is completed. 2. If the affected source is an existing source, all personnel must be trained and certified no later than 180 days after hiring or no later than January 10, 2011, whichever is later. Painter training that was completed within five years prior to the date training is required, and that meets the requirements specified in training program requirements above satisfies this requirement and is valid for a period not to exceed five years after the date the training is completed. 3. Training and certification will be valid for a period not to exceed five years after the date the training is completed, and all personnel must receive refresher training that meets the requirements of this section and be re-certified every five years (g) aq-12-01n 4/30/15 Page 50

9 General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in s 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. HHHHHH. The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B). NOTIFICATIONS Initial Notification. The Permittee must submit the initial notification required by 63.9(b) for paint stripping operations using paint strippers containing MeCl and/or a surface coating operations subject to this subpart. For a new affected source, the Permittee shall submit the Initial Notification no later than July 7, 2008, whichever is later. For an existing affected source, The Permittee must submit the initial notification no later than January 11, The initial notification must provide the information specified in the following paragraphs. 1. The company name, if applicable. 2. The name, title, street address, telephone number, address (if available), and signature of the Permittee or other certifying official; 3. The street address (physical location) of the affected source and the street address where compliance records are maintained, if different. If the source is a motor vehicle or mobile equipment surface coating operation that repairs vehicles at the customer's location, rather than at a fixed location, such as a collision repair shop, the notification should state this and indicate the physical location where records are kept to demonstrate compliance; 4. An identification of the relevant standard (i.e., this subpart, 40 CFR pt. 63, subp. HHHHHH); 5. A brief description of the type of operation as specified: i. For all surface coating operations, indicate whether the source is a motor vehicle and mobile equipment surface coating operation or a miscellaneous surface coating operation, and include the number of spray booths and preparation stations, and the number of painters usually employed at the operation. ii. For paint stripping operations, identify the method(s) of paint stripping employed (e.g., chemical, mechanical) and the substrates stripped (e.g., wood, plastic, metal). 6. Each paint stripping operation must indicate whether they plan to annually use more than one ton of MeCl after the compliance date. 7. A statement of whether the source is already in compliance with each of the relevant requirements of 40 CFR pt. 63, subp. HHHHHH, or whether the source will be brought into compliance by the compliance date. For paint stripping operations, the relevant requirements that must be evaluated in making this determination are specified in the paint hdr (a) Continued below aq-12-01n 4/30/15 Page 51

10 stripping operations requirements above. For surface coating operations, the relevant requirements are specified in the surface coating operations sections above. 8. If the affected source is a new source, certify in the initial notification whether the source is in compliance with each of the requirements of this 40 CFR pt. 63, subp. HHHHHH. If the affected source is existing, the Permittee may certify in the initial notification that the source is already in compliance. If the Permittee is certifying in the initial notification that the source is in compliance with the relevant requirements of 40 CFR pt. 63, subp. HHHHHH, then include also a statement by a responsible official with that official's name, title, phone number, address and signature, certifying the truth, accuracy, and completeness of the notification; a statement that the source has complied with all the relevant standards of 40 CFR pt. 63, subp. HHHHHH; and that this initial notification also serves as the notification of compliance status. Notification of Compliance Status. If the affected facility is a new source, the Permittee is not required to submit a separate notification of compliance status provided the Permittee was able to certify compliance on the date of the initial notification, as part of the initial notification, and the facility s compliance status has not since changed. If the Permittee did not certify in the initial notification that the affected source is already in compliance, then the Permittee must submit a Notification of Compliance Status on or before March 11, The Permittee is required to submit the information specified in the following paragraphs 1 through 4 with the Notification of Compliance Status: 1. The company name and the street address (physical location) of the affected source and the street address where compliance records are maintained, if different. 2. The name, title, address, telephone, address and signature of the owner and operator, or other certifying company official, certifying the truth, accuracy, and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart or an explanation of any noncompliance and a description of corrective actions being taken to achieve compliance. For paint stripping operations, the relevant requirements that must be evaluated in making this determination are specified in the paint stripping operations requirements above. For surface coating operations, the relevant requirements are specified in surface coating operations sections above. 3. The date of the Notification of Compliance Status. 4. If the Permittee owns or operates an existing affected paint stripping source that annually uses more than one ton of MeCl, the Permittee must submit a statement certifying that the Permittee has developed and is implementing a written MeCl minimization plan in accordance with the relevant Paint stripping operations requirements above (a) Continued from above (b) aq-12-01n 4/30/15 Page 52

11 RECORDKEEPING AND REPORTING Annual Notification of Changes Report. The Permittee is required to submit a report in each calendar year in which information previously submitted in a notification (e.g. in the Initial Notification, Notification of Compliance, or a previous Notification of Changes Report) has changed. Deviations from the relevant compliance requirements above will be deemed to be a change. Deviations for paint stripping affected sources include facilities that have not developed and implemented a written MeCl minimization plan and used more than one ton of MeCl in the previous calendar year. The annual notification of changes report must be submitted prior to March 1 of each calendar year when reportable changes have occurred and must include the information specified in the following paragraphs. 1. The company name and the street address (physical location) of the affected source and the street address where compliance records are maintained, if different. 2. The name, title, address, telephone, address (if available) and signature of the owner and operator, or other certifying company official, certifying the truth, accuracy, and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart or an explanation of any noncompliance and a description of corrective actions being taken to achieve compliance. 3. If the Permittee is an owner or operator of a paint stripping affected source that has not developed and implemented a written MeCl minimization plan, then the Permittee must submit a report for any calendar year in which more than one ton of MeCl. This report must be submitted no later than March 1 of the following calendar year. The Permittee must also develop and implement a written MeCl minimization plan in accordance with the Paint stripping operations requirements above no later than December 31. The Permittee shall then submit a Notification of Compliance Status report containing the information specified in the Notification of compliance status section above by March 1 of the following year and comply with the requirements in this permit for paint stripping operations that annually use more than one ton of MeCl. Records to keep. For surface-coating operations the Permittee shall keep the records specified in paragraphs 1-4 and paragraph 7 of this section. For paint stripping operations the Permittee shall keep the records specified in paragraphs 5-7 of this section, as applicable. 1. Certification that each painter has completed the training specified above with the date the initial training and the most recent refresher training was completed. 2. Documentation of the filter efficiency of any spray booth exhaust filter material, according to the procedure in the enclosure requirements for hdr s (a) and (b) aq-12-01n 4/30/15 Page 53

12 surface coating operations section above. 3. Documentation from the spray gun manufacturer that each spray gun with a cup capacity 3.0 fluid ounces (89 cc) that does not meet the definition of an HVLP spray gun, electrostatic application, airless spray gun, or air assisted airless spray gun, has been determined by the Administrator to achieve a transfer efficiency equivalent to that of an HVLP spray gun, according to the procedure in spray gun cleaning requirements for surface coating operations section above. 4. Copies of any notification submitted as required above and copies of any report submitted as required above. 5. Records of paint strippers containing MeCl used for paint stripping operations, including the MeCl content of the paint stripper used. Documentation needs to be sufficient to verify annual usage of paint strippers containing MeCl (e.g., material safety data sheets or other documentation provided by the manufacturer or the supplier of the paint stripper, purchase receipts, records of paint stripper usage, calculations). 6. If you are a paint stripping source that annually uses more than one ton of MeCl you are required to maintain a record of your current MeCl minimization plan on site for the duration of your paint stripping operations. You must also keep records of your annual review of, and updates to, your MeCl minimization plan. 7. Records of any deviation from the requirements of this permit. These records must include the date and time period of the deviation, and a description of the nature of the deviation and the actions taken to correct the deviation. 8. Records of any assessments of source compliance performed in support of the initial notification, notification of compliance status, or annual notification of changes report. Record maintenance. The Permittee shall maintain copies of records for a period of at least five years after the date of each record. Copies of records must be kept on site in a printed or electronic form that is readily accessible for inspection for at least the first two years after their date, and may be kept offsite after that two year period (a) aq-12-01n 4/30/15 Page 54

13 A.3.2 NESHAP subp. JJ The following are National Emission Standards for Hazardous Air Pollutants for Wood Furniture Manufacturing Operations (40 CFR pt. 63, subp. JJ) - Booths: Spraying/Coating (non Fiberglassing) - Dip Tanks Subject to NESHAP subp. JJ Affected source for NESHAP subp. JJ: The affected source to which this subpart applies is each facility that is engaged, either in part or in whole, in the manufacture of wood furniture or wood furniture components. Compliance dates: All compliance dates for the following sources have passed for this standard. The compliance date for existing affected sources emitting less than 50 tons per year of HAP in 1996 was December 7, The compliance date for existing affected sources emitting 50 tons or more of hazardous air pollutants in 1996 was November 21, New affected sources must comply with the provisions of this standard immediately upon startup or by December 7, 1995, whichever is later. If an existing area source increases its emissions (or its potential to emit) of HAP such that the source becomes a major source that is subject to NESHAP subp. JJ, then the Permittee shall comply with subp. JJ within one year of becoming a major source. New area sources that become major sources shall comply with the provisions of this standard immediately upon becoming a major source. Definitions: (Also see ) Adhesive: Any chemical substance that is applied for the purpose of bonding two surfaces together other than by mechanical means. Under this subpart, adhesives shall not be considered coatings or finishing materials. Products used on humans and animals, adhesive tape, contact paper, or any other product with an adhesive incorporated onto or in an inert substrate shall not be considered adhesives under this subpart. Coating: A protective, decorative, or functional film applied in a thin layer to a surface. Such materials include, but are not limited to, paints, topcoats, varnishes, sealers, stains, washcoats, basecoats, enamels, inks, and temporary protective coatings. Aerosol spray paints used for touch-up and repair are not considered coatings under this subpart. Research or laboratory facility: Any stationary source whose primary purpose is to conduct research and development to develop new processes and products where such source is operated under the close supervision of technically trained personnel and is not engaged in the manufacture of products for commercial sale in commerce, except in a de minimis manner. Wood furniture: Any product made of wood, a wood product such as rattan or wicker, or an engineered wood product such as particleboard that is manufactured at any facility that is engaged, either in part or in whole, in the manufacture of wood furniture or wood furniture components, including, but not limited to, facilities under any of the following standard industrial classification codes: 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, 2599, or Wood furniture component: Any part that is used in the manufacture of wood furniture. Examples include, but are not limited to, drawer sides, cabinet doors, seat cushions, and laminated tops. aq-12-01n 4/30/15 Page 55

14 However, foam seat cushions manufactured and fabricated at a facility that does not engage in any other wood furniture or wood furniture component manufacturing operation are excluded from this definition. Wood furniture manufacturing operations: The finishing, gluing, cleaning, and washoff operations associated with the production of wood furniture or wood furniture components. This subpart does not apply to any surface coating or coating operation that meets any of the criteria of the following paragraphs: a) Surface coating of metal parts and products other than metal components of wood furniture that meet the applicability criteria for miscellaneous metal parts and products surface coating (40 CFR pt. 63 subp. MMMM). b) Surface coating of plastic parts and products other than plastic components of wood furniture that meets the applicability criteria for plastic parts and products surface coating (40 CFR pt.63 subp. PPPP). c) Surface coating of wood building products that meets the applicability criteria for wood building products surface coating (40 CFR pt. 63 subp. QQQQ). The surface coating of millwork and trim associated with cabinet manufacturing are subject to NESHAP subp. JJ. d) Surface coating of metal furniture that meets the applicability criteria for metal furniture surface coating (40 CFR pt. 63 subp. RRRR). Surface coating of metal components of wood furniture performed at a wood furniture or wood furniture component manufacturing facility are subject to NESHAP subp. JJ. What to do INCIDENTAL AND SMALL SOURCE ALTERNATIVES FOR SUBP. JJ INCIDENTAL: The Permittee of a source that meets the definition for an incidental wood furniture manufacturer shall maintain purchase or usage records demonstrating that the source meets the following definition, and the source shall not be subject to any other provisions of 40 CFR pt. 63, subp. JJ. Incidental wood furniture manufacturer: a major source of HAP that is primarily engaged in the manufacture of products other than wood furniture or wood furniture components and that uses no more than 100 gallons per month of finishing material or adhesives in the manufacture of wood furniture or wood furniture components. SMALL SOURCE: A source that complies with all of the limits and criteria specified in paragraphs 1) - 3) below is an area source for the purposes of this subpart and is not subject to any other provisions of 40 CFR pt. 63, subp. JJ, provided that: In the case of paragraphs 1) and 2), finishing materials, adhesives, cleaning solvents and washoff solvents used for wood furniture or wood furniture component manufacturing operations account for at least 90 percent of annual HAP emissions at the plant site, and if the plant site has HAP emissions that do not originate from the listed materials, the Permittee shall keep any records necessary to demonstrate that the 90 percent criterion is being met. hdr Why to do it ; 40 CFR Section (a); Minn. R CFR section (b) and (f); Minn. R aq-12-01n 4/30/15 Page 56

15 What to do Why to do it A source that initially relies on the limits and criteria specified in paragraphs 1), 2), and 3) to avoid applicability of 40 CFR pt. 63, subp. JJ, but subsequently exceeds the relevant limit (without first obtaining and complying with other limits that keep its potential to emit hazardous pollutants below major source levels), must comply thereafter with all applicable provisions of this subpart within one year of becoming a major source. Nothing in this requirement precludes a source from limiting its potential to emit through other appropriate mechanisms. Paragraphs 1) - 3) below require the Permittee to maintain certain records. The Permittee shall maintain these records for five years. Upon request, the Permittee shall submit such records to the Administrator. A rolling 12-month period consists of 12 consecutive calendar months, and includes the previous 12 months of operation. 1) Limit: The Permittee shall use no more than 250 gallons per month, for every month, of coating, gluing, cleaning, and washoff materials at the source, including materials used for source categories other than wood furniture (surface coating), but excluding materials used in routine janitorial or facility grounds maintenance, personal uses by employees or other persons, the use of products for the purpose of maintaining motor vehicles operated by the facility, or the use of toxic chemicals contained in intake water (used for processing or noncontact cooling) or intake air (used either as compressed air or for combustion). Recordkeeping: By the 15 th of each month, the Permittee shall record and maintain the total gallons of coating, gluing, cleaning, and washoff materials used during the previous month. 2) Limit: The Permittee shall use no more than 3,000 gallons per rolling 12- month period, for every 12-month period, of coating, gluing, cleaning, and washoff materials at the source, including materials used for source categories other than wood furniture (surface coating), but excluding materials used in routine janitorial or facility grounds maintenance, personal uses by employees or other persons, the use of products for the purpose of maintaining motor vehicles operated by the facility, or the use of toxic chemicals contained in intake water (used for processing or noncontact cooling) or intake air (used either as compressed air or for combustion). Recordkeeping: By the 15 th of each month, the Permittee shall record and maintain the total gallons of coating, gluing, cleaning, and washoff materials used during the previous rolling 12-month period by summing the monthly usage totals during those months. Because records are needed over the previous set of 12 months, the Permittee shall keep monthly records beginning no less than one year before the compliance date specified in 40 CFR Section (e). Note: all compliance dates have passed. 3) Limit: The source shall emit no more than 5 tons of any one HAP per rolling aq-12-01n 4/30/15 Page 57

16 What to do 12-month period and no more than 12.5 tons of any combination of HAP per rolling 12-month period, and at least 90 percent of the plantwide emissions per rolling 12-month period are associated with the manufacture of wood furniture or wood furniture components. Recordkeeping: By the 15 th of each month, the Permittee shall calculate, record, and maintain the following: For the previous month: o The total individual HAP and combined HAP emitted by the facility; o The total individual HAP and combined HAP emitted by the wood furniture/wood furniture component manufacturing operations at the facility; and o The percent of plantwide emissions associated with the manufacture of wood furniture or wood furniture components. The sum for the previous rolling 12-month period: o The total individual HAP and combined HAP emitted by the facility; o The total individual HAP and combined HAP emitted by the wood furniture/wood furniture component manufacturing operations at the facility; and o The percent of plantwide emissions associated with the manufacture of wood furniture or wood furniture components. Why to do it aq-12-01n 4/30/15 Page 58

17 A.3.3 NESHAP subp. MMMM The following are National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products (40 CFR pt. 63, subp. MMMM) - Booths: Spraying/Coating (non Fiberglassing) - Dip Tanks Subject to NESHAP subp. MMMM Affected Source for NESHAP subp. MMMM: The collection of all items listed below: 6) All coating operations as defined in ; 7) All storage containers and mixing vessels in which coatings, thinners and/or other additives, and cleaning materials are stored or mixed; 8) All manual and automated equipment and containers used for conveying coatings, thinners and/or other additives, and cleaning materials; and 9) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation. New Source: commenced construction or reconstruction after August 13, 2002 Existing Source: commenced construction or reconstruction on or before August 13, 2002 (Also see (c)) Compliance dates: All compliance dates have passed for this standard. For existing affected sources, the compliance date was January 2, For new affected sources, the compliance date was January 2, 2004, or the date of initial startup of the affected source, whichever was later. (Also see and s 63.6(b) and (c)) The Permittee is subject to the requirements below if the Permittee owns or operates a new, reconstructed, or existing affected source that uses 250 gallons or more per year of coatings that contain hazardous air pollutants (HAP) in the surface coating of miscellaneous metal parts and products. The Permittee is not required to include coatings that meet the definition of non-hap coating contained in in determining whether 250 gallons, or more, of coatings in the surface coating of miscellaneous metal parts and products is used. Definitions: (Also see ) Miscellaneous metal parts and products include, but are not limited to: Metal components of the following types of products as well as the products themselves: motor vehicle parts and accessories, bicycles and sporting goods, recreational vehicles, extruded aluminum structural components, railroad cars, heavy duty trucks, medical equipment, lawn and garden equipment, electronic equipment, magnet wire, steel drums, industrial machinery, metal pipes, and numerous other industrial, household, and consumer products. Coating operation: Equipment used to apply cleaning materials to a substrate to prepare it for coating application (surface preparation) or to remove dried coating; to apply coating to a substrate (coating application) and to dry or cure the coating after the application; or to clean coating operation equipment (equipment cleaning). A single coating operation may include any combination of these types of equipment, but always includes at least the point at which a given aq-12-01n 4/30/15 Page 59

18 quantity of coating or cleaning material is applied to a given part and all subsequent points in the affected source where organic HAP are emitted from the specific quantity of coating or cleaning material on the specific part. There may be multiple coating operations in an affected source. Coating application with handheld, non-refillable aerosol containers, touch-up markers, or marking pens is not a coating operation for the purposes of 40 CFR pt. 63, subp. MMMM. General use coating: Any material that meets the definition of coating but does not meet the definition of high performance coating, rubber-to-metal coating, magnet wire coating, or extreme performance fluoropolymer coating as defined in High performance coating: Any coating applied to architectural subsections which is required to meet the specifications of Architectural Aluminum Manufacturer s Association s publication number AAMA ; Any coating applied to a substrate which during normal use must withstand temperatures of at least 538 degrees Celsius (1000 degrees Fahrenheit). Magnet wire coatings (commonly referred to as magnet wire enamels): Coatings applied to a continuous strand of wire which will be used to make turns (windings) in electrical devices such as coils, transformers, or motors. Magnet wire coatings provide high dielectric strength and turn-to-turn conductor insulation. This allows the turns of an electrical device to be placed in close proximity to one another which leads to increased coil effectiveness and electrical efficiency. Rubber-to-metal coatings: Coatings that contain heat-activated polymer systems in either solvent or water that, when applied to metal substrates, dry to a non-tacky surface and react chemically with the rubber and metal during a vulcanization process. Extreme performance fluoropolymer coating: Coatings that are formulated systems based on fluoropolymer resins which often contain bonding matrix polymers dissolved in non-aqueous solvents as well as other ingredients. Once applied to a substrate, extreme performance fluoropolymer coatings undergo a curing process that typically requires high temperatures, a chemical reaction, or other specialized technology. What to do Based on the current and expected operations of the affected source, this permit only includes the compliant material option specified in (a) and the emission rate without add-on controls option specified in 40 CFR Section (b). If the Permittee later chooses to switch to or add the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. MMMM for those options. In addition, the Permittee shall apply for an individual Part 70 permit prior to making this switch. Unless otherwise noted, all equations for 40 CFR pt. 63, subp. MMMM referenced in the requirements for NESHAP subp. MMMM in this general permit can be found in Appendix D of this permit. Why to do it ; Minn. R ; Minn. R , subp. 2 Minn. R , subps. 4 and 5 aq-12-01n 4/30/15 Page 60