SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Transcription

1 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT Guideline for Expedited Application Review (GEAR) Motor Vehicles and Mobile Equipment Coating Operations Approved By: Signed Seyed Sadredin Director of Permit Services Date: 12/18/97 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 10 tons/year of VOCs, and if equipped with a drying provisions the oven capacity is less than 2.0 MMBtu/day. II. Permit Application and Supplementary Forms The applicant must complete a regular application form and the Painting & Coating Operations Supplemental Form (see Attachment I). 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, write the application review, and finalize the project. The application review and final ATC will be submitted to the lead engineer for review. GEAR 12-1

2 Final action on all projects will occur within thirty days after the submittal of the complete package. The priority processing will be preempted 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. The application requires a site specific health risk assessment (HRA). IV. Application Review In order to standardize the application reviews for this source category, the application review found in G:/per/gear/mvmecoat.doc 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 (Attachment I), the up-to-date Best Available Control Technology (BACT) analysis (Attachment II), the standard Authority to Construct (ATC) conditions (Attachment III) and a general health risk assessment (HRA) (Attachment IV). 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. GEAR 12-2

3 Health Risk Assessment The HRA process included in Attachment IV may be used in lieu of a site specific HRA provided the applicant agrees to a prohibition on the use of chromium containing coatings. Where chromium containing coatings are proposed or if there are special receptor considerations, a site specific HRA must be conducted. V. Equipment Description To ensure uniformity, the following standard description will be used: MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATION WITH HVLP SPRAY GUN(S), PAINT SPRAY BOOTH WITH EXHAUST FILTERS AND SPRAY GUN CLEANER, AND [XX] MMBTU/HR DRYING OVEN VI. Authority to Construct Conditions To ensure uniformity, a standard set of conditions will be used as a base for all applications (See Attachment III). Additional conditions may be necessary on a site specific basis due to New Source Review requirements or health risk assessment. 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 12-3

4 APPLICATION REVIEW FOR MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS GEAR 12-4

5 ATC APPLICATION REVIEW MOTOR VEHICLE AND MOBILE EQUIPMENT COATING Facility Name: Mailing Address: Processing Engineer: Lead Engineer: Date: Contact Name: Phone: Project Number: Permit Number: I. PROPOSAL: [Facility Name] is applying for an Authority to Construct for an motor vehicle and mobile equipment paint coating operation with a paint spray booth [and describe drying provisions if proposes]. II. APPLICABLE RULES: Rule 2010 Permit Required (December 17, 1992) Rule 2201 New and Modified Stationary Source Review Rule (June 15, 1995) Rule 4101 Visible Emissions (December 17, 1992) Rule 4102 Nuisance (December 17, 1992) Rule 4201 Particulate Matter Concentration (December 17, 1992) Rule 4602 Motor Vehicle and Mobile Equipment Refinishing Operations (September 17, 1997) CH&SC California Health and Safety Code (School Notice) III. PROJECT LOCATION: The project is located at [Street Address] in [City], CA. in a CO attainment/nonattainment area. The facility is [not] located within 1000' of a kindergarten through 12th grade school. IV. PROCESS DESCRIPTION: This paint spray booth will be used solely for automotive body repair and refinishing. It will typically operate [hours per day, days per week, weeks per year]. GEAR 12-5

6 V. EQUIPMENT LISTING: One ' Wide X ' Long X ' High Paint Spray Booth (Number) HP Exhaust Fan (Type, i.e. paper, mesh, etc.) Filter System Approved HVLP Spray Gun(s) or Electrostatic Spray Gun(s) (Number) HP Electric Compressor Approved Gun Cleaner [ XX MMBTU/HR Natural Gas/Propane Burner (delete if no drying oven)] VI. EMISSION CONTROL TECHNOLOGY EVALUATION: A. Control Techniques The operation includes a paint spray booth an with exhaust filter system for particulate matter control, HVLP spray equipment for PM-10 and VOC control and an approved gun cleaner for VOC control during spray equipment clean-up. B. Best Available Control Technology (BACT) 1. Applicability: The applicant is proposing to install a paint spray operation with an enclosed booth which will result an increase in permitted emissions of VOC and PM10 greater than 2 lb/day. Therefore, BACT is required for both pollutants. The applicant is also proposing to install a drying oven. The emission of each air contaminant is less than 2 lb/day for the drying oven therefore, BACT is not required 2. BACT Guidance: Existing BACT determination 4-1 for Automotive Paint Spraying Operation will be used for the top down BACT analysis. GEAR 12-6

7 Per District Policy a top-down BACT analysis for this application is required. The proposed operation is within the scope of the top-down analysis included as Appendix II in District policy Motor Vehicle and Mobile Equipment Coating Operations permit processing guidelines (GEAR-12) dated / /. The top-down analysis for this project will therefore, rely on that determination. BACT for this operation is: PM10 Spray booth with exhaust filters. VOC Use of HVLP spray guns, coating compliant with District Rules and District approved gun cleaner. VII. CALCULATIONS Coating Operation A. Assumptions VOC emissions 54.8 lb/day (10 tons per year) HVLP gun transfer efficiency (TE) = 75% (STAPPA ALAPCO Vol. 2) Dry exhaust filter removal efficiency (RE) = 66% (STAAPPA ALAPCO Vol. 2) Average enamel paint VOC content 3.0 lb/gal (typical) B. Emission Factors - PM emission factor (EF) for enamel paint (worst case) = 5.5 lb/gal (assuming all PM emissions are PM10) (STAPPA ALAPCO Vol. 2) C. Emission Calculations VOC potential to emit (PE) is based upon the VOC offset threshold of 10 tons per year. VOC PE = 54.8 lb/day = 10.0 tons/year PM10 potential to emit is calculated below: Maximum enamel paint usage = 1 Gallon/3.0 lb VOC X 54.8 lb VOC/day Maximum enamel paint usage = gallon/day GEAR 12-7

8 Uncontrolled PM10 PE = gallon/day x 5.5 lb/gal Uncontrolled PM10 PE = lb/day Controlled PM10 PE = lb/day * (1-0.66) * (1-0.75) Controlled PM10 PE = 8.5 lb/day D. Daily Emission Limitations (DELS) The lb/day emission rates calculated above will be included in the ATC and PTO as daily emission limitations. E. Best Available Control Technology This is a new emissions unit. For new emissions units the BACT IPE is equal to the PE. The IPE exceeds 2 lbs/day for VOC and PM10 therefore, BACT is required for VOC and PM10. The following section may be deleted if the applicant is not proposing a drying oven. Drying Oven A. Assumptions Heating value of natural gas 1000 Btu/scf Maximum daily drying oven usage 20.0 MMBtu B. Emission Factors Emission factors shown below are from AP-42, Table 1.4-1, and dated 10/96 for commercial boilers (< 10 MMBtu/hr). C. Emission Calculations PM10: (11.9 lb/mmscf)(20.0 MMBtu/day)(scf/1000 Btu) = 0.24 lb/day SO 2 : (0.6 lb/mmscf)(20.0 MMBtu/day)(scf/1000 Btu) = 0.01 lb/day NO x : (100 lb/mmscf)(20.0 MMBtu/day)(scf/1000 Btu) = 2.00 lb/day CO: (21 lb/mmscf)(20.0 MMBtu/day)(scf/1000 Btu) = 0.04 lb/day VOC's: (2.8 lb/mmscf)(20.0 MMBtu/day)(scf/1000 Btu) = 0.06 lb/day GEAR 12-8

9 D. Daily Emission Limitations The emission factors and rating used above will be included in the ATC and PTO to establish daily emission limits for the oven. E. Best Available Control Technology For new emissions units the BACT IPE is equal to the PE. The IPE does not exceed 2 lbs/day for each pollutant therefore, BACT is not required. VIII. COMPLIANCE Rule New and Modified Stationary Source Review Rule The applicant is proposing BACT by the use of a paint spray booth with an exhaust filter system, HVLP spray guns, coatings compliant with District rules and District approved gun cleaner. This source will emit less than 10 tons per year of VOC's. (The source will be limited to 54.8 lb/day VOC.) All other contaminants will also be below offset threshold levels. (PM-10 emissions will be limited to 8.5 lb/day, as per STAPPA/ALAPCO "Air Quality Permits", Volume II). Consequently, no offsets are required. Public notice is not required as no emissions unit has an increase in NOx or VOC exceeding 100 lb/day, the NSR balance is below 70 lbs/day PM10, 140 lb/day SOx and 550 lb/day CO and the source is not major stationary source. All applicable requirements of this rule are satisfied. Rule Visible Emissions Visible emissions are expected to be less than 5% opacity with the use of HVLP spray equipment, paint booth, and exhaust filters. Rule Nuisance Select the applicable section of the following: The applicant has agreed to a prohibition on the use of chromium containing coatings and the facility proposed by the applicant is represented by the prescreened HR approval included in Appendix IV of District policy Motor Vehicle and Mobile Equipment Operation Coating Operation Permit Processing Guidelines (GEAR-12) dated / /97. Therefore, no additional HRA is required. GEAR 12-9

10 The applicant has agreed to a prohibition on the use of chromium containing coatings and an HRA using the CAPCOA Generic Coating Formulations was conducted for the source (see attached results). The prioritization score was less than 1 therefore, no significant health risk is expected. A site specific HRA was conducted for the source the results are attached. Conditions limiting the use of chromate containing materials will be included on the permit. The project is not expected to constitute a nuisance. Rule Particulate Matter Concentration Particulate matter emissions are not expected to exceed 0.1 gr./scf. Rule Motor Vehicle and Mobile Equipment Refinishing Operations This operation is expected to comply with all the VOC limit, application method (HVLP guns), control, evaporative loss minimization, administrative, and recordkeeping requirements listed in this rule. IX. RECOMMENDATION Issue ATC with the conditions listed on the attached draft Authority to Construct. X. BILLING PERMIT NUMBER FEE SCHEDULE FEE DESCRIPTION X-XXXX-XX-X 3020-XX-X GEAR 12-10

11 ATTACHMENT I Supplemental Form GEAR 12-11

12 San Joaquin Valley Unified Air Pollution Control District Supplemental Application Form PAINTING & COATING OPERATIONS This form must be accompanied by a completed Application for Authority to Construct and Permit to Operate form. PERMIT TO BE ISSUED TO: LOCATION WHERE THE EQUIPMENT WILL BE OPERATED: PROCESS DESCRIPTION Items Painted [ ] Motor Vehicles [ ] Wood Products [ ] Metal Parts and Products [ ] Aerospace Parts [ ] Can and Coil [ ] Other: Drying Method [ ] Air Dried [ ] Heat Dried [ ] UV Cured EQUIPMENT DESCRIPTION Application Method [ ] HVLP [ ] Electrostatic [ ] Electrodeposition [ ] Air-Assisted Airless [ ] Roll Coat [ ] Airless [ ] Conventional [ ] Brush [ ] Other: Applicator Data Manufacturer: Model: Manufacturer: Model: Compressor Data [ ] Electric [ ] Gasoline [ ] Diesel Motor HP Rating: Paint Booth Data Type [ ] Closed [ ] Open-Faced [ ] Conveyorized Manufacturer: Model: Dimensions Length: ft Width: ft Height: ft Filtration Method [ ] Dry Filters [ ] Water-Wash [ ] Oil-Wash Exhaust Filter(s): Qty Size (ea): w h t Fan: Dia. Motor HP Rating Exhaust Flow Rate: cfm Stack Diameter: ft Stack Height: ft (If the Paint Booth has a Natural Gas Burner, complete the following line) Maximum Heat Input Rating: Btu/hour Gun Cleaner Data Manufacturer: Model: Solvent (Brand/Trade Name): VOC: lb/gal 1. If a separate Dryer is used, include a completed BOILERS, STEAM GENERATORS, DRYERS, & PROCESS HEATERS form with this application. 2. For Conveyorized Paint Systems, include the HP Rating of all electric motors associated with the system.

13 COATING INFORMATION COATING Indicate Type of Coating next to number, such as: Topcoat, Primer, Basecoat, Clearcoat, Pretreatment Wash Primer, Extreme Performance, Specialty, etc. Motor Vehicle Refinishing: also specify if the coating is applied to Group I (I), Group II (II), or both (I,II) MANUFACTURER TRADE NAME / I.D # MIX RATIO VOC CONTENT OF EACH COMPONENT (lb/gal) VOC CONTENT OF COATING AS APPLIED (lb/gal) MAX USAGEI N ANY ONE DAY (gal) MAX USAGE PER YEAR (gal) 1. Thinner/Reducer Catalyst/Hardener 2. Thinner/Reducer Catalyst/Hardener 3. Thinner/Reducer Catalyst/Hardener 4. Thinner/Reducer Catalyst/Hardener Cleanup Solvent Surface Preparation Solvent ADDITIONAL INFORMATION 1. Operating Schedule: Hours per day Days per week Weeks per year. 2. Nearest Receptor: Receptor Description Distance from Stack to Receptor (ft) Hours of Operation per Day (Optional) Offsite Business 1 Sensitive Receptor 2 1 Examples of Offsite Businesses include, but are not limited to, office buildings, guard posts, and factories. 2 Examples of Sensitive Receptors include, but are not limited to, schools, day care centers, hospitals, apartments, and other places of residence. 3. Is a rain cap present on exhaust stack? [ ] Yes [ ] No Direction of exhaust from device or structure: [ ] Vertical [ ] Horizontal 4. Facility Location: [ ] Urban (area of dense population) [ ] Rural (area of sparse population) 5. If more than 5 types of coatings are used, make additional copies of the COATING INFORMATION table above. For multiple colors of the same type of coating, provide coating information on the color with the highest VOC content. 6. Submit all Material Safety Data Sheets (MSDS) along with this form. SA-4 1/97

14 ATTACHMENT II BACT Analysis (Updated on 10/1/97) GEAR 12-13

15 Top Down BACT Analysis for VOC emissions: Step 1 - Identify All Possible Control Technologies 1. HVLP spray guns, coatings compliant with District rules - achieved in pratice, and enclosed gun cleaner - achieved in practice 2. VOC capture and control system - technologically feasible, and enclosed gun cleaner achieved in practice Step 2 - Eliminate Technologically Infeasible Options None of the above listed technologies are technologically infeasible. Step 3 - Rank Remaining Control Technologies by Control Effectiveness 1. VOC capture and control system: 95% - technologically feasible 2. HVLP guns: 75% transfer efficiency - achieved in practice Enclosed gun cleaner is achieved in practice for either technology and will be required Step 4 - Cost Effectiveness Analysis - VOC capture and control systems. Design Parameters: Exhaust Gas Flow Rate (Q): VOC (lb/day): VOC (ton/year) 14,000 cfm 54.8 lb-voc/day 10 ton-voc/year GEAR 12-14

16 (1) Capture and Incineration The cost of a thermal incineration unit is estimated using the calculations from Chapter 11 of Air Pollution Control - A Design Approach by C. David Cooper and F.C. Alley. Capital Cost The purchase price for a packaged thermal incinerator fits the following formula: P($) = aq 50 b 11.5 Where Q 50 = flue gas flow rate (scfm) a,b = regression parameters from Table For a thermal incinerator, the average heat exchanger efficiency is 50%. At this efficiency, a = 4,920 and b = P = (4,920)14, = $201,748 Total Capital Investment The total capital investment is equal to 1.25 times the purchase cost. The sales tax and freight charges total 8% of the base equipment cost. Finally adjusting from 1988 dollars to 1992 dollars (multiply by 1.11). Therefore, TCI(1992 dollars) = $201,748 (1.25)(1.08)(1.11) = $301,482. Pursuant to the District's BACT Policy section X. (Revised 4/18/95), the annual cost of installing and maintaining the thermal oxidizer will be calculated as follows. The installation cost will be spread over the expected life of the thermal oxidizer which is estimated at 10 years and using the capital recovery equation (Equation 1). A 10% interest rate is assumed in this equation and the assumption will be made that the equipment has no salvage value at the end of the ten year cycle. Equation 1: A = [P * i(i+1) n ]/[(i+1) n -1] Where: A = Annual Cost P = Present Value i = Interest Rate (10%) n = Equipment (10 years) A = [$301,482 * 0.1(1.1) 10 ]/[(1.1) 10-1] = $49,064/year GEAR 12-15

17 Operating and Maintenance Costs. The Direct annual costs include labor (operating, supervisory, and maintenance), maintenance materials, electricity, and fuel. Heat of Combustion for waste gas stream All VOCs are assumed to be ethylene for calculation. Molecular Weight = heat of combustion -dhc = Btu/lb Daily VOC emissions rate = 46.5 lb/day Blower flow rate = 14,000 scfm = 20,160,000 ft 3 /day -dh(c) = 46.5 lb/day x Btu/lb / 20,160,000 ft 3 /day = Btu/ft 3 Assuming the waste gas is principally air, with a molecular weight of and a corresponding density of lb/scf, the heat of combustion per pound of incoming waste gas is: -dh(c) = Btu/ft 3 / lb/ft 3 = Btu/lb Fuel Flow Requirement Q(fuel) = Pw*Qw*{Cp*[1.1Tf-Tw-0.1Tr]-[-dh(c)]} P(ef) * [-dh(m) Cp * (Tf - Tr)] Pw = lb/ft 3 Cp = Btu/lb- o F Qw = 14,000 scfm -dh(m) = 21,502 Btu/lb for methane Tr = 77 o F assume ambient conditions P(ef) = lb/ft 3 m, methane at 77 o F, 1 atm Tf = 1600 o F Tw = 1150 o F -dh(c) = 3.52 Btu/lb GEAR 12-16

18 Q = *14,000*{0.255*[1.1* *77]-0.633} *[ *0.255*( )] = 158,246/859.9 = ft 3 /min Fuel Cost = cfm x 1440 min/day x 300 day/yr x $0.0033/ft 3 = $262,596/yr Electricity Requirement Gas Flow rate (Q): 14,000 scfm Pressure drop (dp): 4 inch Motor Efficiency (e): 0.6 = 1.17 x 10-4 x Q x dp/e = 1.17 x 10-4 x 14,000 x 4/.6 = 11.2 kw Electric Cost = 11.2 kw x 24 hr/day x 300 day/yr x $0.059/kWh = $5,810 GEAR 12-17

19 Total Annualized Cost (Data From: Annual Costs for Thermal and Catalytic Incinerators, Table OAQPS Control Cost Manual, Fourth Edition) Operating Labor Operator 0.5 h/shift $12.96/h $1944 Supervisor 15% of operator $875 Maintenance Labor 0.5 h/shift $14.26 $2139 Material 100% of labor $2139 Utility Natural Gas $3.3/kft 3 $262,596 Electricity $0.059/kWh $5,810 Indirect Annual Cost (IC) Overhead 60% of Labor Cost $4258 Administrative Charge 2% TCI $852 Property Taxes 1% TCI $426 Insurance 1% TCI $426 Annualized Capital Cost $49,064 Total Annual Cost $330,529 Controlled Cost per ton of emissions = $330,529/10.0 ton = $33,053/ton Since the calculated controlled cost exceed the cost effective value of $5000/ton for VOC, incinerator is deemed not cost-effective for this operation. GEAR 12-18

20 (2) Carbon Adsorption Assumptions: Qe = 14,000 scfm TQe = 90 F Minimum Bed Depth = 1 ft # of Beds = 1 Overall Efficiency = 95% Life Expectancy of System = 10 years Carbon Replacement = 5 years (carbon cost $1.92/lb dollars) Carbon Bed superficial velocity (Ue) = 100 ft/min Density of Carbon = 30 lb/ft3 Adsorption capacity of carbon bed (AC) = 0.15 lb/lb carbon Disposal Cost = $300/55-gal Electricity Cost = $0.08/kwh Data obtained from South Coast Carbon Adsorption information - neglecting water cooling and regeneration costs, as current facilities use carbon canisters and ship used canisters to the supplier. System Design Calculations Stream Flow Rate at actual conditions - Qe,a Qe,a = (14,000 scfm) x [(90+460)/530] = 14,528 scfm Bed Area = Abed = Qe,a/Ue = (14,528 scfm)/(100 ft/min) = ft2 Volume of carbon in bed =Vcarbon = depth x area = (1 ft)x(145.3 ft 2 ) = ft3 Carbon requirements = Vcarbon = carbon required / density of carbon carbon required = (Vcarbon) x (density of carbon) = 4,358 lb carbon An oversized regenerable carbon system is more economical than a canister system, even if sized several times larger than necessary (BACT analysis from 4 quarter Cost Estimation GEAR 12-19

21 Capital Costs: Cost correction factors: (based on Chemical Engineering magazine s fabricated cost index) = /226.2 = = /259.9 = = /336.2 = (Numbers have not been corrected to 1996 dollars, however, if 1987 values show that the equipment is not cost effective, then correcting to 1996 dollars will only raise the cost of the control equipment). Carbon adsorber package cost (Chapter 12 of Air Pollution Control - A Design Approach by C. David Cooper and F.C. Alley. Figure 1) Purchase cost (1988 dollars) = PEC = 129(M c ) = 129(4358 lb)^0.848 = $157, Freight and taxes = ($157,291) x (0.08) = $12, Total capital costs = ($157,291+$12,583) x (1.5)** = $254,812 ** Other Direct and Indirect Costs 6. Capital recovery cost (CRF) CRF (I = 10%, n = 10 years) = $254,812 x = $41,534 Variable Operating Costs 1. Carbon replacement costs ($1.92/lb-carbon) (4358 lb carbon) = $8,367 $8,367/5 years = $1673/year 2. Disposal cost (4358 lb carbon)(1 gal/6.5 lb)(1 drum/55 gal)($300/drum)/5 yr = $731/yr 3. Fan Electricity Requirements (FER) FER = (2x10e-4) x (air flow rate) x (pressure drop, in H2O) x (hours operation) FER = (0.0002) x (14,000) x (6) x (8760 hr/yr) FER = 147,168 kwh/yr (147,168 kwh/yr) x ($0.08/kwh) = $11,773/yr GEAR 12-20

22 Net Annualized Cost $/year 1. Electricity - 11, Disposal Carbon Replacement - 1, Insurance (1% of capital cost) - 1, Capital Recovery (CRF x total capital cost) - 41,534 Total - $57,410/year Cost Effectiveness of Control Equipment Cost Effectiveness of control equipment = Annualized cost / VOC s controlled = (57,410/yr) / (10.0 ton-voc/yr) = $5,7410/ton Cost effectiveness of achievable control equipment is set at $5,000/ton- VOC. As the cost of carbon adsorption exceeds this value, carbon adsorption is not cost effective for this project. Step 5 - Select BACT Capture and control is not cost effective, therefore the next highest level of control, HVLP spray guns, low VOC coatings in compliance with District rule 4602, and an enclosed gun cleaner is selected as BACT. GEAR 12-21

23 Top Down BACT Analysis for PM-10 emissions: Step 1 - Identify all control technologies. 1. Spray booth with exhaust filters. (achieved in practice) Step 2 - Eliminate Technologically Infeasible Options. 1. The above technology is technologically feasible. Step 3 - Rank Remaining Control Technologies by control effectiveness. 1. Spray booth with exhaust filters (66% control) BACT 4-1 Step 4 - Cost Effectiveness Analysis. 1. Only one control technology identified and this technology is achieved in practice, therefore, cost effectiveness analysis not necessary. Step 5 - Select BACT for PM10 1. Spray booth with exhaust filters. GEAR 12-22

24 ATTACHMENT III Authority to Construct Standard Conditions GEAR 12-23

25 Nuisance: 1. {118} No air contaminant shall be released into the atmosphere which causes a public nuisance [District Rule 4102]. Rule 4602: 2. {437} Only HVLP, electrostatic, brush, dip, or roll coating application equipment shall be used and shall be operated in accordance with the manufacturer's recommendations. [District Rule 4602] 3. {435} Volatile organic compound (VOC) content of coatings as applied shall not exceed the limits specified in Rule [District Rule 4602] 4. {436} Amount of precoat used shall not exceed the amount of primer surfacer used. Precoat use shall be limited to one application per vehicle. Precoat shall not be used to fill in surface imperfections. [District Rule 4602] 5. {438} Permittee shall demonstrate that HVLP guns manufactured prior to 1/1/96 operate between 0.1 and 10 psig air atomizing pressure, by manufacturer's published technical material or by use of a certified air pressure tip gauge. [District Rule 4602] 6. {439} VOC content of solvents used for surface preparation, except for surface preparation of plastic substrates and the application by hand held spray bottle for the removal of road tar, shall not exceed 0.6 lb/gallon. [District Rule 4602] 7. {440} Maximum VOC content of solvents used for surface preparation of plastic substrates shall not exceed 6.5 lb/gal. [District Rule 4602] 8. {441} Closed, non-absorbent containers shall be used for storage and disposal of all solvent-laden cloth or paper. [District Rule 4602] 9. {442} All fresh or spent coatings, adhesives, catalysts, thinners and solvents shall be stored in closed containers. [District Rule 4602] 10.. {443} Permittee shall not use VOC containing materials for spray equipment clean-up unless an enclosed system or equipment proven to be equally effective is used for cleaning. [District Rule 4602] 11. {444} VOC content of solvents used with an enclosed or approved cleaning system shall not exceed 7.9 lb/gallon and solvent vapor pressure shall not exceed 35 mm Hg at standard conditions. [District Rule 4602] 12. {445} VOC content of specialty coatings (as defined in Rule 4602) shall not exceed 7.0 lb/gallon. [District Rule 4602] GEAR 12-24

26 13. {446} 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] 14. {447} Permittee shall keep records of the quantity and type (Group I or III) of each vehicle coated, specific coatings used on each vehicle, mix ratios by volume of components added to the coating and VOC content of each coating as applied. [District Rule 4602] 15. {448} Permittee shall keep purchase and usage records showing the date, type and volume of each specific solvent or reducer used and the quantity and mix ratio of each specialty coating applied. [District Rule 4602] 16. {449} Records shall be retained for a minimum of two years and made available for inspection by the APCO upon request. [District Rule 4602] Rule 2201 Conditions (BACT and offsets): 17. {363} All painting shall be conducted in booth with filters in place, fan(s) operating, and doors closed. [District Rule 2201] 18. {366} VOC emission rate shall not exceed 54.8 lb/day. [District Rule 2201] 19. {1351} Particulate matter (PM10) emission rate shall not exceed 8.5 lb/day. [District Rule 2201] Health and Safety Code Section 41700: If general HRA utilized: 20. {369} No coatings, solvents, or additives containing chromium compounds shall be used. [District Rule 4102 and CH&SC 41700] If site specific HRA conducted: 21. {1352} The as-applied use of coatings containing (chromium or other toxic compound) shall not exceed xx pint(s) per day and xx pint(s) per year. [District Rule 4102 and CH&SC 41700] GEAR 12-25

27 ATTACHMENT IV Health Risk Assessment GEAR 12-26

28 General Health Risk Assessment procedure for Motor Vehicle and Mobil Equipment Coating Operations: Based on the CAPCOA Guidelines, automotive refinishing facilities complying with all the following conditions will have prescreened approval and not require site specific risk management review: 1. No use of coatings containing hexavalent chromium (chromate s). 2. Facility must have a paint booth with filters and HVLP gun. 3. The exhaust stack is greater than 7.6 meters in height. 4. Only one Paint booth exists at the facility. For facilities that do not meet the above criteria: 1. Facilities not using hexavalent chromium containing coatings, the District will perform an HRA based on the CAPCOA Generic Coating Formulations, (Appendix E of the CAPCOA Auto Bodyshop Industrywide Risk Assessment Guidelines). 2. Facilities using hexavalent chromium containing coatings, the District will perform an HRA using site specific data (MSDS s). Additionally, a use limit for all coatings containing hexavalent chromium will be placed on the permit. GEAR 12-27

29 BIBLIOGRAPHY GEAR 12-28

30 Rules and Regulations Rule Number Title Last Updated District Rule 2010 Permits Required 12/17/1992 District Rule 2201 New and Modified Stationary Source Review Rule 6/15/1995 District Rule 4101 Visible Emissions 12/17/1992 District Rule 4102 Nuisance 12/17/1992 District Rule 4201 Particulate Matter Concentration 12/17/1992 District Rule 4602 Motor Vehicle and Mobile Equipment Refinishing 9/17/1997 Operations CH&SC California Health and Safety Code Section Best Available Control Technology (BACT) Guidelines Guideline Number Title Last Updated 4-1 Automotive Paint Spraying Operation 4/1/1995 District Policies Policy Number Title Last Updated TOX 1 Risk Management Policy for Permitting New and 6/23/1997 Modified Sources BACT 1 Best Available Control Technology (BACT) Policy 4/18/1995 Electronic Documents Document Name Title Last Updated G:/per/gear/mvme coat.doc Standard Application Review for Motor Vehicle and Mobile Equipment Coating Operations 11/13/1997 Reference Materials Document Name Title Last Updated AP-42 Table Emission Factors for Sulfur Dioxide (SO 2 ), Nitrogen 10/1996 Oxides (NOx), and Carbon Monoxide (CO) from Natural Gas Combustion AP-42 Table Emission Factors for Particulate Matter (PM) from 10/1996 Natural Gas Combustion AP-42 Table Emission Factors for Carbon Dioxide (CO 2 ) and 10/1996 Total Organic Compounds (TOC) from Natural Gas Combustion STAPPA ALAOCO Vol. 2 Transfer Efficiency, Filter Removal Efficiency 1991 GEAR 12-29

31 Miscellaneous Item Title Last Updated Supplemental Form Supplemental Application Form for Painting and 1/97 Coating Operations General Conditions General Condition #s 118, 363, 366, 369, , 1351, /97 GEAR 12-30