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Technical Support DocumentforDraft Air Emission Permit No. 12300755-002This technical support document (TSD) is intended for all parties interested in the draft permit and to meet therequirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850,subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement orpolicy decision considered in the preliminary determination to issue the draft permit.1.General information1.1Applicant and stationary source locationTable 1. Applicant and source addressApplicant/AddressStationary source/Address(SIC Code: See NAICS)Central Sandblasting Co2299 County Road HMounds View, Minnesota 55112Central Sandblasting Co2299 County Road HMounds View, MN 55112Contact: Lucas HerbstPhone: 763-452-75401.2Facility descriptionCentral Sandblasting Company operates a metal sandblasting and coating facility located in Mounds View,Minnesota. The facility consists of four spray booths and cleaning solvent use. Each spray booth is operatedwith particulate control consisting of two panel filters in series. There are also several activities that qualifyas insignificant under Minnesota Rules. These are listed in Appendix A of the permit.The primary pollutants emitted from the existing facility are volatile organic compounds (VOCs), particulatematter, particulate matter less than 10 microns, and particulate matter less than 2.5 microns(PM/PM10/PM2.5), and hazardous air pollutants (HAPs).1.3Description of the activities allowed by this permit actionThis permit action is Part 70 Permit.1.4Facility emissionsTable 2. Total facility potential to emit summaryPMtpyPM10tpyPM2.5tpyTotal facilitylimited potentialemissions95.095.095.0Total facilityactual emissions(2016)12.412.412.4*Not reported in Minnesota emission inventory.Technical Support Document, Permit Number: ge 1 of 13
Table 3. Facility classificationClassificationNew Source ReviewPart 70Part 632.MajorXXSynthetic minor/areaXMinor/AreaRegulatory and/or statutory basis2.1New source review (NSR)The facility was previously operated under the Minnesota Option D Registration Permit thresholds. Thispermit establishes new limits on the facility such that it remains a minor source under New Source Reviewregulations.The installation of EQUI 7 was subject to NSR injunctive relief. This is discussed in more detail in section 3.1of this TSD.2.2Part 70 permit programThe facility is a major source under the Part 70 permit program.2.3New source performance standards (NSPS)The Permittee has stated that no New Source Performance Standards apply to the operations at this facility.2.4National emission standards for hazardous air pollutants (NESHAP)The facility is an existing major source of HAPs and is subject to 40 CFR pt. 63, subp. MMMM (NationalEmission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts andProducts).2.5Compliance assurance monitoring (CAM)The table below lists the sources subject to CAM, the control equipment used, whether the source is a largeor other pollutant specific emission unit (PSEU), and the pollutants triggering CAM.Table 4. CAM summaryUnitEQUI 4EQUI 5EQUI 6EQUI 7ControlTREA 1, TREA 5TREA 2, TREA 6TREA 3, TREA 7TREA 4, TREA 8CAM PM2.5PM/PM10/PM2.5PM/PM10/PM2.5PM/PM10/PM2.5The controlled PM/PM10/PM2.5 PTE of each spray booth exceeds 100 tpy, however these units are eachsubject to the COMG 2 PM/PM10/PM2.5 emissions limits of 95.0 tons per year and therefore are notconsidered large PSEUs.CAM applicability has been evaluated for the three abrasive blasting booths listed as conditionallyinsignificant activities under Minn. R. 7008.4110. Through this evaluation, it has been determined that CAMdoes not apply for these abrasive blasting booths. Further discussion may be found in section 3.5 of this TSD.For large pollutant specific emission units, records of the monitored parameter must be made at a minimumof four times per hour, or once every 15 minutes. For other PSEUs (not large), records must be made at aminimum of once per 24 hours. See Attachment 4 to this document for the CAM Plan submitted by theapplicant.Technical Support Document, Permit Number: 12300755-002Page 2 of 13
2.6Minnesota State RulesPortions of the facility are subject to the following Minnesota Standards of Performance: Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process EquipmentTable 5. Regulatory overview of facilitySubject item*Applicable regulationsRationaleCOMG 240 CFR pt. 64, to avoid largePSEU, Title I Condition: Avoidmajor source under 40 CFR §52.21CAM (Compliance Assurance Monitoring), PSD (Prevention ofSignificant Deterioration). Limits on PM, PM10, and PM2.5emissions to avoid large PSEU classification under CAM andmajor source classification under PSD.Title I Condition: Avoid majorsource under 40 CFR § 52.21PSD (Prevention of Significant Deterioration). Limit on VOCemissions to avoid major source classification under PSD.40 CFR pt. 63, subp. MMMMNational Emission Standards for Hazardous Air Pollutants forSurface Coating of Miscellaneous Metal Parts and Products.This is an existing affected source under this standard. ThePermittee is complying with the emission rate withoutcontrols compliance option. If the Permittee’s coatingoperations include high performance or extreme performancefluoropolymer coatings, the Permittee has the option to eithercomply separately with each subcategory emission limit, or tocomply with a facility-specific emission limit as described in 40CFR § 63.3890(c)(2). The Permittee has rejected the option toclaim waste credit in organic HAP emission calculations.Title I Condition: Avoid majorsource under 40 CFR § 52.21PSD. Control efficiency and other operating parameterrequirements to limit PM/PM10/PM2.5 PTE to avoid majorsource classification under PSD.40 CFR pt. 64CAM. The panel filters are used to comply with the IndustrialProcess Equipment Rule (IPER) particulate limit, and theuncontrolled potential from each of these booths is greaterthan 100 tpy, so CAM applies.Title I Condition: Avoid majorsource under 40 CFR § 52.21PSD. Control efficiency and other operating parameterrequirements to limit PM/PM10/PM2.5 PTE to avoid majorsource classification under PSD. Reflects total enclosure.TREA 4, TREA 8Minn. R. 7007.0800, subps. 2and 14Requirement to operate two panel filters in series at EQUI 7 inorder to demonstrate compliance with Minn. R. 7011.0715,subp. 1(A).COMG 6Title I Condition: Avoid majorsource under 40 CFR § 52.21PSD. Control efficiency and other operating parameterrequirements to limit PM/PM10/PM2.5 PTE to avoid majorsource classification under PSD. Reflects hood capture.TREA 1-3, 5-7Minn. R. 7007.0800, subps. 2and 14Requirement to operate two panel filters in series at EQUI 4,EQUI 5, and EQUI 6 in order to demonstrate compliance withMinn. R. 7011.0715, subp. 1(A).EQUI 4, EQUI 5,EQUI 6Minn. R. 7011.0715, subp. 1Standards of Performance for Post-1969 Industrial ProcessEquipment. All equipment is post-1969.CAAA of 1990, Title ICondition: Avoid major sourceunder 40 CFR § 52.21BACT-equivalent limits on VOC, PM, PM10, and PM2.5 emissionsand emission unit requirements related to particulate matteremissions as a result of injunctive relief.VOC andParticulate CoatingLimitsEQUI 4-7, EQUI 8Spray Booths 1-4,Cleaning SolventsCOMG 3NESHAP MMMM:Surface Coating ofMiscellaneousMetal Parts andProductsEQUI 4-7, EQUI 8Spray Booths 1-4,Cleaning SolventsCOMG 4Individual PanelFilterRequirementsTREA 1-8COMG 5Panel Filters w/Total EnclosurePanel Filters w/Hood CaptureSpray Booths 1-3EQUI 7Spray Booth 4Technical Support Document, Permit Number: 12300755-002Page 3 of 13
Subject item*EQUI 8Applicable regulationsRationaleMinn. R. 7011.0715, subp. 1Standards of Performance for Post-1969 Industrial ProcessEquipment. This booth was constructed after 1969.Minn. R. 7011.0715, subp. 1Standards of Performance for Post-1969 Industrial ProcessEquipment. This emission source commenced after 1969.Cleaning SolventsTREA 4CAAA of 1990, Title IBACT-equivalent control efficiency limits as a result ofCondition:Avoidmajorsourceinjunctive relief.Panel Filterunder 40 CFR § 52.21*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).3.Technical information3.1Injunctive ReliefThe Permittee constructed EQUI 7 (Spray Booth 4) on October 1, 2007 without obtaining the appropriatepermit prior to construction. After this change, the total facility PTE was confirmed to have crossed themajor source thresholds for PSD, Part 70/Title V, and Part 63 NESHAP.The facility was required to submit a BACT (Best Achievable Control Technology) analysis, as specified in theFebruary 22, 2010 stipulation agreement between the Permittee and the Minnesota Pollution ControlAgency (MPCA). Specifically, the stipulation agreement required the submittal of“a Prevention of Significant Deterioration and Best Available Control Technology (BACT) analysis for the facility. Theprocedures outlined in the EPA’s New Source Review Workshop Manual dated October 1990, shall be followed forthese analyses. In particular, the BACT analysis shall follow the top-down procedures.”3.1a BACT-Equivalent Emission Limit SummaryA top-down analysis for best available control technologies (BACT) for PM, PM10, PM2.5, and VOC wasconducted for the installation of EQUI 7 (Spray Booth 4).Table 6 summarizes the source subject to the top-down BACT analysis, BACT pollutants, and proposed BACTequivalent limit.Table 6. Source Subject to BACT AnalysisSubjectItem IDEQUI 7SIDescriptionSprayBooth 4TREA SIIDTREA 4,TREA 8*Stack/Vent SI IDSTRU 4,STRU 5,STRU 6BACTPollutantsPM, PM10,PM2.5BACT-Equivalent1. 88.0 ton per year emission limit2. Fiberglass wall filter with an overall control efficiencyof 85%3. Airless spray guns with a transfer efficiency of 45%VOC1. 27.0 ton per year emission limit*TREA 8 was installed in series with TREA 4 on 9/1/17 in order for the Permittee to demonstrate compliance with Minn.R. 7011.0715, subp. 1(A) through calculation of the controlled hourly emission rate. The Permittee was not required toinstall or operate TREA 8 as a result of the BACT analysis.Compliance with the BACT-equivalent limit is demonstrated through material usage requirements, monthlycalculations, and recordkeeping.3.2Minnesota Performance Standards for Post-1969 Industrial Process EquipmentEach of the four spray booths is subject to Minnesota Performance Standards for Post-1969 IndustrialProcess Equipment. The calculation of the controlled hourly emission rate using the highest coating materialsolids content, maximum spray gun application rate, minimum transfer efficiency, and control efficiencyfrom a panel filter ( 85% control of PM/PM10/PM2.5) did not sufficiently demonstrate compliance with thisTechnical Support Document, Permit Number: 12300755-002Page 4 of 13
standard. The Permittee elected to install a second panel filter in series at each spray booth to achieve a97.8% control efficiency from the PM/PM10/PM2.5 emissions that are captured and vented through thestacks (80% capture achieved for EQUI 4, 5, and 6, and 100% capture achieved for EQUI 7). The calculation ofthe controlled hourly emission rate using this higher control efficiency sufficiently demonstrates compliancewith the Minnesota Performance Standards for Post-1969 Industrial Process Equipment. The permit requiresthat each of the four booths are controlled by two panel filters in series.3.3Permit ContentControl PreCapThis permit has control PreCap language for spray booths vented to panel filters (listed at COMG 4 andCOMG 5). The control equipment requirements for the panel filters have been written to apply to existing,new, and modified units and control equipment. The Permittee must comply with these requirements whenmaking changes in the future. This may enable proposed changes to be handled with a lower-levelamendment once the control equipment credit is taken. However, an amendment may still be needed tomake the change based on the hourly emissions increase and/or the non-emissions increase amendmenttriggers (e.g. change to monitoring, recordkeeping, etc.).Emissions PreCapThis permit has VOC, PM, PM10, and PM2.5 emissions PreCap language for COMG 4 units. VOC limits apply toall VOC-emitting equipment except for insignificant activities, and PM/PM10/PM2.5 limits apply to PMemitting coating equipment. If the Permittee adds new VOC or PM-emitting coating equipment or modifiesexisting equipment, such equipment is subject to the emissions cap. The emissions cap PreCap gives thePermittee the flexibility to potentially add, replace, or modify emission units or control equipment withinthese groups with a lesser permit amendment. However, an amendment may still be needed to make thechange based on the hourly emission increase and/or the non-emissions increase amendment triggers (e.g.reconstruction of a major source of HAPs, change to monitoring, recordkeeping, etc.).Typically, PM/PM10/PM2.5 emission limits to avoid major source classification under NSR are taken such thatthe total facility limited PTE for PM/PM10/PM2.5 is less than or equal to 225 tons per year. This practice isdone to account for emissions from insignificant activities, as well as uncertainties in emissions calculations.The Permittee has elected to take a more stringent limit of PM/PM10/PM2.5 95.0 tons per year, so that eachspray booth has an annual limited PTE of less than 100 tons per year. This limit makes each spray booth an“other PSEU” under Compliance Assurance Monitoring (CAM). CAM is discussed in more detail in section 2.5of this document.3.4Calculations of potential to emit (PTE)Attachment 1 to this TSD contains a facility emissions summary and detailed spreadsheets and supportinginformation prepared by the MPCA and the Permittee.Cleaning SolventsMethyl ethyl ketone (MEK) is used at the facility for cleaning miscellaneous parts. There is not a throughputcapacity that limits the use of this solvent; therefore, the Permittee calculated the PTE by multiplying the 3year annual average by a safety factor of 5 (i.e. 500% of the 3-year annual average solvent use). VOCemissions from cleaning solvents are included in the 225 ton per year VOC emission limit to avoid majorsource classification under NSR.Spray Booths (General)Unrestricted PTE for the spray booths is calculated by multiplying the highest material content for eachpollutant, as applied (lb/gal), by the maximum application rate. The Permittee applies coatings either with orwithout reducers, following the material manufacturer’s recommendations on the type and quantity ofreducers used. The Permittee identified the highest material contents under both scenarios (either addingTechnical Support Document, Permit Number: 12300755-002Page 5 of 13
reducers, or applying the coatings without reducers), and used the maximum value in calculating theunrestricted PTE. The Permittee has elected to take a COMG 2 VOC emission limit of 225 tons per year for allspray booths and cleaning solvents collectively. This emission limit effectively limits the total facility HAPemissions to 225 tons per year, because each HAP used in the coating materials is also a VOC.For calculation of particulate emissions, a transfer efficiency of 45% was assumed for the airless spray guns.The Permittee installed secondary panel filters in series at each spray booth, resulting in a control of PM,PM10, and PM2.5 of 97.8% from the captured portion of the particulate emissions. Booths 1, 2, and 3 eachhave a certified hood, resulting in a capture efficiency of 80% (overall control efficiency of 78.2%), whereasbooth 4 has a downdraft hood, resulting in a capture efficiency of 100% (overall control efficiency of 97.8%).Spray Booth 4 – Subject to BACT-equivalent emission limitSpray booth 4 is subject to a BACT-equivalent emission limit of 27.0 tons per year VOC and 88.0 tons peryear PM/PM10/PM2.5 (each calculated as a 12-month rolling sum). The 27.0 tons per year VOC emission limiteffectively limits the spray booth 4 HAP emissions to no more than 27.0 tons per year, because each HAPused in the coating materials is also a VOC.Insignificant ActivitiesPTE calculations for all natural gas combustion units have been included in Attachment 1 to this TSD. PTE forthe combustion units is calculated using the maximum rated heat input, along with emission factors fromAP-42 Section 1.4 and 40 CFR pt. 98.PTE calculations for each of the three abrasive blasting booths have also been included in Attachment 1 tothis TSD. PTE for the blasting booths is calculated using the maximum blasting rate, along with emissionfactors from the STAPPA/ALAPCO Blasting guidance document (May 1991).3.5CAM Applicability Evaluation of the Three Abrasive Blasting BoothsThe Permittee operates three abrasive blasting booths, which are listed as conditionally insignificantactivities under Minn. R. 7008.4110. CAM applies to an emission unit if the following 3 criteria are met:1) the emission unit is subject to an emission limitation or standard for an air pollutant regulated by Part 70;2) compliance with the applicable limit or standard is achieved through the use of add-on controlequipment; and 3) the emission unit has pre-controlled potential emissions of the applicable regulated airpollutant that are greater than or equal to 100 percent of the Part 70 major source level for that pollutant(equal to 100 tons per year for PM/PM10/PM2.5).Each of these three blasting booths is a PM/PM10/PM2.5 emitting unit subject to Minn. R. 7011.0715, subp. 1(Minnesota Standards of Performance for Post-1969 Industrial Process Equipment). Pre-controlled potentialemission calculations have been included in Attachment 1 to this TSD. Two of the blasting booths have precontrolled potential PM emissions of 62.1 tons per year, and the third booth has pre-controlled potentialPM emissions of 18.0 tons per year. On the basis of pre-controlled emissions, these booths are not subjectto CAM.The Permittee provided further justification that the air cleaning systems should not be considered airpollution control equipment for the purposes of air permitting, but are instead inherent to the abrasiveblasting process. The Permittee has provided the following reasons for why these air cleaning systems areinherent to the process: recirculation of air within each blasting booth is used to maintain a climate-controlled environmentwithin the booth; the air cleaning system provides improved visibility for the operator of the abrasive blasting equipment; the air cleaning system aids in the removal of contaminants from the blasting media so that it may becontinually recycled for reuse; andTechnical Support Document, Permit Number: 12300755-002Page 6 of 13
3.6the air cleaning system helps reduce wear on moving equipment outside of the blasting booth bykeeping the blasting media contained within the booth.MonitoringIn accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to havesufficient knowledge of the facility to certify that the facility is in compliance with all applicablerequirements.For CAM, the Permittee submitted a CAM proposal as required by 40 CFR § 64.3. It can be found inAttachment 4 to this TSD. Further discussion of decisions about CAM can be found in Table 4.In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for theemission unit; the technical and economic feasibilit
NESHAP MMMM: Surface Coating of Miscellaneous Metal Parts and Products . EQUI 4-7, EQUI 8 . Spray Booths 1-4, Cleaning Solvents . 40 CFR pt. 63, subp. MMMM : National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products. Thi