DRAFT/PROPOSED. AIR EMISSION PERMIT NO Total Facility Operating Permit IS ISSUED TO. Cirrus Design Corp/Cirrus Aircraft

Transcription

1 DRAFT/PROPOSED AIR EMISSION PERMIT NO Total Facility Operating Permit IS ISSUED TO CIRRUS DESIGN CORP/CIRRUS AIRCRAFT Taylor Circle 4940 Airport Road (new finishing center) Duluth, St. Louis County, Minnesota The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the Permit Applications Table. This permit authorizes the Permittee to operate the stationary source at the addresses listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: Federal Permit; Part 70/Limits to Avoid NSR Operating Permit Issue Date: <issue date> Expiration Date: <expiration date> All Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for John Linc Stine Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit July 17, Major Amendment September 8, 2015 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendices Appendix I: Insignificant Activities and Applicable Requirements Appendix II: 40 CFR Section Equations for test methods and procedures (supplemental information under 40 CFR pt. 63, subp. GG) Appendix III: Maximum Contents of Materials

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. The permit shield shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance.

4 FACILITY DESCRIPTION: Cirrus Design Corp. aka Cirrus Aircraft (Cirrus) manufactures aircrafts at its facility in Duluth, Minnesota. The facility currently operates two paint booths and two primer booths, and three grit abrasive blasting booths. Each paint/primer booth is equipped with two high volume low pressure (HVLP) spray guns, and is controlled by a paint filter. The grit abrasive blasting booths consist of two room sized blasting booths and one table top size blasting cabinet that is a conditionally exempt insignificant activity under Minn. R The blasting booths are controlled by panel filters. Cirrus uses aluminum oxide for the blasting media. The facility also includes five natural gas fired makeup air units that combust natural gas only and are used for building heat. There are additional natural gas fired makeup air units that are considered insignificant activities under Minn. Rules Cirrus has proposed to replace its existing spray booth system with a new paint system for its production activities. The existing spray system will be maintained on site and used for R & D purposes or as a backup to the new paint system. The modification will include three paint booths, one primer booth and one parts cross draft booth. In addition, nine makeup air units will be installed as well as a water heater and a wash booth are all listed as insignificant activities.

5 Facility Name: Permit Number: A-1 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do SOURCE-SPECIFIC REQUIREMENTS This permit establishes limits on the facility to keep it a minor source under New Source Review. The Permittee cannot make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. hdr Why to do it under 40 CFR 52.21(b)(1)(i) and Minn. R Minn. R , subp. 2 The list shall correlate the units to the numbers used in this permit (EU, GP, CE) and shall include the data on GI-04, GI-05B, and GI-05C. The date of construction shall be the date the change was made for replaced, modified, or new equipment. Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate EU and GP numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. Permit Shield: This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. OPERATIONAL REQUIREMENTS Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). Minn. R , subp. 2 Minn. R (C)(2) Minn. R , subp. 2 hdr Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subps. 14 and 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A)

6 Facility Name: Permit Number: A-2 The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Minn. R , subp. 16 hdr Minn. R. ch Minn. R ; Minn. R , subps. 1-4, Minn. R , subps. 1-2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. MONITORING REQUIREMENTS Monitoring Equipment Calibration - The Permittee shall either: Minn. R , subp. 3 hdr Minn. R , subp. 4(D) 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. RECORDKEEPING Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. REPORTING/SUBMITTALS Minn. R , subp. 4(D) hdr Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4 hdr

7 Facility Name: Permit Number: A-3 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Minn. R , subp. 1 Minn. R , subp. 1 Minn. R ; Minn. R , subp. 3 Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. Extension Requests: The Permittee may apply for an Administrative Amendment to Minn. R , subp. 1(H) extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). Notwithstanding the previous sentence, the agency may do an administrative amendment to extend a testing deadline in a permit up to 365 days if the agency finds that the extension is needed to allow the permittee to test at worst case conditions as required by part , subpart 2. Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R permit issuance, to be submitted on a form approved by the Commissioner. Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R

8 Facility Name: Permit Number: Subject Item: GP 001 Existing Emission Units Subject to NESHAP GG A-4 Associated Items: EU 004 Primer Booth #1-Spraying Equipment EU 005 Primer Booth #2-Spraying Equipment EU 006 Paint Booth #1-Spray Booth/Coating Line EU 007 Paint Booth #2-Spray Booth/Coating Line EU 010 Cleaning Adhesion-Adhesion Equipment What to do Why to do it These requirements below are applicable to all the emission units under GP 001. Minn. R , subp. 2 The Permittee shall comply with the requirements of 40 CFR pt. 63, subp. GG and of 40 CFR pt. 63, subp. A, except as specified in 40 CFR Section (a) and Table 1 of 40 CFR pt. 63, subp. GG. The affected sources to which the provisions of 40 CFR pt. 63, subp. GG apply are specified below. The activities subject to Subpart GG are limited to the manufacture or rework of aerospace vehicles or components as defined in Subpart GG. Where a dispute arises relating to the applicability to a specific activity, the Permittee shall demonstrate whether or not the activity is regulated under this Subpart GG. 40 CFR (b); Minn. R CFR (c); Minn. R (a) Each cleaning operation as follows constitutes an affected source: (i) All hand-wipe cleaning operations. (ii) Each spray gun cleaning operation. (iii) All flush cleaning operations. (b) For organic HAP or VOC emissions, each primer application operation, which is the total of all primer applications at the facility. (c) For organic HAP or VOC emissions, each topcoat application operation, which is the total of all topcoat applications at the facility. (d) Each waste storage and handling operation, which is the total of all topcoat applications at the facility. The Permittee shall obtain an operating permit from MPCA. The Permittee shall apply for and obtain such permit in accordance with the regulations contained in part 70 of this chapter and in applicable State regulations. All wastes that are determined to be hazardous wastes under the Resource Conservation and Recovery Act of 1976 (PL ) (RCRA) as implemented by 40 CFR parts 260 and 261, and that are subject to RCRA requirements as implemented in 40 CFR parts 262 through 268, are exempt from the requirements of 40 CFR pt. 63, subp. GG. Startup, shutdown, and malfunction plan (SSMP). The Permittee that uses an air pollution control device or equipment to control HAP emissions shall prepare a SSMP in accordance with 40 CFR Section Dry particulate filter systems operated per the manufacturer's instructions are exempt from a SSMP. Instead of complying with the individual coating limits in 40 CFR Sections and , the Permittee may choose to comply with the averaging provisions specified 40 CFR Section (d)(1) through (d)(6). The Permittee of an existing source shall use any combination of primers, topcoats (including self-priming topcoats), Type I chemical milling maskants, or Type II chemical milling maskants such that the monthly volume-weighted average organic HAP and VOC contents of the combination of primers, topcoats, Type I chemical milling maskants, or Type II chemical milling maskants, as determined in accordance with the applicable procedures set forth in 40 CFR Section , complies with the specified content limits in 40 CFR Sections (c) and (c), unless MPCA specifies a shorter averaging period as part of an ambient ozone control program. 40 CFR (d); Minn. R CFR (e); Minn. R CFR Section (b); Minn. R CFR (d); Minn. R CFR (d); Minn. R Averaging is allowed only for uncontrolled primers, topcoats (including self-priming topcoats), Type I chemical milling maskants, or Type II chemical milling maskants. 3) Averaging is not allowed between primers and topcoats (including self-priming topcoats). (4) Averaging is not allowed between Type I and Type II chemical milling maskants. (5) Averaging is not allowed between primers and chemical milling maskants, or between topcoats and chemical milling maskants. (6) Each averaging scheme shall be approved in advance by the permitting agency and adopted as part of the facility's title V permit. 40 CFR (d); Minn. R

9 Facility Name: Permit Number: Cleaning Operations: (a) Housekeeping measures. The Permittee of an existing cleaning operation shall comply with the requirements unless the cleaning solvent used is identified in Table 1 of 40 CFR 63, subp. GG or contains HAP and VOC below the de minimis levels specified in 40 CFR Section (f). (a) (1) Unless the Permittee satisfies the requirements in 40 CFR Section (a)(4), place used solvent-laden cloth, paper, or any other absorbent applicators used for cleaning in bags or other closed containers. Ensure that these bags and containers are kept closed at all times except when depositing or removing these materials from the container. Use bags and containers of such design so as to contain the vapors of the cleaning solvent. Cotton-tipped swabs used for very small cleaning operations are exempt from this requirement. (2) Unless the Permittee satisfies the requirements in 40 CFR Section (a)(4), store fresh and spent cleaning solvents, except semi-aqueous solvent cleaners, used in aerospace cleaning operations in closed containers. (3) The Permittee shall conduct the handling and transfer of cleaning solvents to or from enclosed systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or spent cleaning solvents in such a manner that minimizes spills. (4) Demonstrate to the Administrator (or delegated State, local, or Tribal authority) that equivalent or better alternative measures are in place compared to the use of closed containers for the solvent-laden materials described in 40 CFR Section (a)(1), or the storage of solvents described in 40 CFR Section (a)(2). Cleaning Operations: Hand wipe cleaning. The Permittee of an existing hand-wipe cleaning operation (excluding cleaning of spray gun equipment performed in accordance with 40 CFR Section (c)) shall use cleaning solvents that meet one of the requirements specified in 40 CFR Section (b)(1), (b)(2), and (b)(3). Cleaning solvent solutions that contain HAP and VOC below the de minimis levels specified in 40 CFR Section (f) are exempt from the requirements in 40 CFR Section (b)(1), (b)(2), and (b)(3). The Permittee shall have a composite vapor pressure of 45 mm Hg (24.1 in. H2 O) or less at 20 C (68 F) as required in 40 CFR Section (b)(2). Cleaning Operations: Spray gun cleaning. The Permittee of an existing spray gun cleaning operation in which spray guns are used for the application of coatings or any other materials that require the spray guns to be cleaned shall use one or more of the techniques, or their equivalent, 40 CFR Section (c)(1) through (c)(4). Spray gun cleaning operations using cleaning solvent solutions that contain HAP and VOC below the de minimis levels specified in 40 CFR Section (f) are exempt from the requirements in 49 CFR Section (c)(1) through (c)(4). The Permittee shall use the atomizing cleaning. Clean the spray gun by forcing the cleaning solvent through the gun and direct the resulting atomized spray into a waste container that is fitted with a device designed to capture the atomized cleaning solvent emissions as specified in 40 CFR Section (c)(4). Flush cleaning. The Permittee of a flush cleaning operation (excluding those in which 40 CFR pt. 63, subp. GG of Table 1 or semiaqueous cleaning solvents are used) shall empty the used cleaning solvent each time aerospace parts or assemblies, or components of a coating unit (with the exception of spray guns) are flush cleaned into an enclosed container or collection system that is kept closed when not in use or into a system with equivalent emission control. A-5 40 CFR (a); Minn. R CFR (a); Minn. R CFR (a)(4); Minn. R CFR (b); Minn. R CFR (c); Minn. R CFR (d); Minn. R

10 Facility Name: Permit Number: A-6 Exempt cleaning operations. 40 CFR (e); Minn. R The following cleaning operations are exempt from the requirements of 40 CFR section (b): (1) Cleaning during the manufacture, assembly, installation, maintenance, or testing of components of breathing oxygen systems that are exposed to the breathing oxygen; (2) Cleaning during the manufacture, assembly, installation, maintenance, or testing of parts, subassemblies, or assemblies that are exposed to strong oxidizers or reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine); (3) Cleaning and surface activation prior to adhesive bonding; (4) Cleaning of electronic parts and assemblies containing electronic parts; (5) Cleaning of aircraft and ground support equipment fluid systems that are exposed to the fluid, including air-to-air heat exchangers and hydraulic fluid systems; (6) Cleaning of fuel cells, fuel tanks, and confined spaces; (7) Surface cleaning of solar cells, coated optics, and thermal control surfaces; 40 CFR (e); Minn. R (8) Cleaning during fabrication, assembly, installation, and maintenance of upholstery, curtains, carpet, and other textile materials used in the interior of the aircraft; (9) Cleaning of metallic and nonmetallic materials used in honeycomb cores during the manufacture or maintenance of these cores, and cleaning of the completed cores used in the manufacture of aerospace vehicles or components; (10) Cleaning of aircraft transparencies, polycarbonate, or glass substrates; (11) Cleaning and cleaning solvent usage associated with research and development, quality control, and laboratory testing; 40 CFR (e); Minn. R (12) Cleaning operations, using nonflamable liquids, conducted within five feet of energized electrical systems. Energized electrical systems means any AC or DC electrical circuit on an assembled aircraft once electrical power is connected, including interior passenger and cargo areas, wheel wells and tail sections; and (13) Cleaning operations identified as essential uses under the Montreal Protocol for which the Administrator has allocated essential use allowances or exemptions in 40 CFR Section The Permittee of an existing primer or topcoat application operation shall comply 40 CFR (a); Minn. R with the requirements specified in 40 CFR Section (c) for those coatings that are uncontrolled (no control device is used to reduce organic HAP emissions from the operation), and in 40 CFR Section (d) for those coatings that are controlled (organic HAP emissions from the operation are reduced by the use of a control device). Aerospace equipment that is no longer operational, intended for public display, and not easily capable of being moved is exempt from the requirements of 40 CFR Section The Permittee shall conduct the handling and transfer of primers and topcoats to or 40 CFR (b); Minn. R from containers, tanks, vats, vessels, and piping systems in such a manner that minimizes spills. Uncontrolled coatings for organic HAP and VOC content levels. The Permittee shall 40 CFR (c); Minn. R comply with the organic HAP and VOC content limits specified in 40 CFR Section (c)(1) through (c)(4) for those coatings that are uncontrolled as listed below. HAPs - Organic: less than or equal to 2.9 lbs/gallon (350 g/l) of primer (less water), 40 CFR (c)(1); Minn. R as applied. Volatile Organic Compounds: less than or equal to 2.9 lbs/gallon (350 g/l) of 40 CFR (c)(2); Minn. R primer (less water and exempt solvents), as applied. HAPs - Organic: less than or equal to 3.5 lbs/gallon (420 g/l) of top coating (less 40 CFR (c)(3); Minn. R water), as applied. Volatile Organic Compounds: less than or equal to 3.5 lbs/gallon (420 g/l) of top 40 CFR (c)(4); Minn. R coating (less water and exempt solvents), as applied. Compliance methods. 40 CFR (e); Minn. R Compliance with the organic HAP and VOC content limits specified in 40 CFR Section (c)(1) through (c)(4) shall be accomplished by using the methods specified in 40 CFR Section (e)(1) and (e)(2) below either by themselves or in conjunction with one another. (e)(1) Use primers and topcoats (including self-priming topcoats) with HAP and VOC content levels equal to or less than the limits specified in 40 CFR Section (c)(1) through (c)(4); or (e) (2) Use the averaging provisions described in 40 CFR Section (d).

11 Facility Name: Permit Number: Application equipment. Except as provided in 40 CFR Section (f)(3), the Permittee of an existing primer or topcoat (including self-priming topcoat) application operation in which any of the coatings contain organic HAP or VOC shall comply with the requirements specified in 40 CFR Section (f)(1) and (f)(2). All primers and topcoats (including self-priming topcoats) shall be applied using high volume low pressure (HVLP) spraying. All application devices used to apply primers or topcoats (including self-priming topcoats) shall be operated according to company procedures, local specified operating procedures, and/or the manufacturer's specifications, whichever is most stringent, at all times. Equipment modified by the facility shall maintain a transfer efficiency equivalent to HVLP and electrostatic spray application techniques. The following situations are exempt from the requirements 40 CFR Section (f)(1): (i) Any situation that normally requires the use of an airbrush or an extension on the spray gun to properly reach limited access spaces; (ii) The application of coatings that contain fillers that adversely affect atomization with HVLP spray guns and that the permitting agency has determined cannot be applied by any of the application methods specified in 40 CFR Section (f)(1); (iii) The application of coatings that normally have a dried film thickness of less than inches ( centimeter) and that the permitting agency has determined cannot be applied by any of the application methods specified in 40 CFR Section (f)(1); (iv) The use of airbrush application methods for stenciling, lettering, and other identification markings; (v) The use of hand held spray can application methods; and (vi) Touch up and repair operations. Except as provided in 40 CFR Section (e), the Permittee that produces a waste that contains HAP shall conduct the handling and transfer of the waste to or from containers, tanks, vats, vessels, and piping systems in such a manner that minimizes spills. Compliance dates. (1) The Permittee of an existing affected source shall comply with the requirements of 40 CFR pt. 63, subp. GG by September 1, 1998, except as specified in 40 CFR Section (a)(2). In addition, the Permittee shall comply with the compliance dates specified in 40 CFR Section 63.6(b) and (c). (2) The Permittee of an existing primer or topcoat application operations and who construct or reconstruct a spray booth or hangar must comply with the new source requirements for inorganic HAP specified in 40 CFR Sections (g)(2)(ii) and (b)(4) for that new spray booth or hangar upon startup. Such sources must still comply with all other existing source requirements by September 1, General. Each facility subject to Subpart GG shall be considered in noncompliance if the Permittee fails to submit a SSMP as required by 40 CFR Section (b) or uses a control device other than one specified in Subpart GG that has not been approved by the Administrator, as required by 40 CFR Section (c). The SSMP is not applicable for this source. Cleaning operations. Each cleaning operation shall be considered in noncompliance if the Permittee fails to institute and carry out the housekeeping measures required under 40 CFR Section (a). Incidental emissions resulting from the activation of pressure release vents and valves on enclosed cleaning systems are exempt from 40 CFR Section (c). (1) Hand wipe cleaning. An affected hand-wipe cleaning operation shall be considered in compliance when all hand-wipe cleaning solvents, excluding those used for hand cleaning of spray gun equipment under 40 CFR Section (c)(3), meet either the composition requirements specified in 40 CFR Section (b)(1) or the vapor pressure requirement specified in 40 CFR Section (b)(2). (2) Spray gun cleaning. An affected spray gun cleaning operation shall be considered in compliance when each of the following conditions is met: (i) One of the four techniques specified in 40 CFR Section (c)(1) through (c)(4) is used; and (ii) The technique selected is operated according to the procedures specified in 40 CFR Section (c)(1) through (c)(4) as appropriate. (3) Flush cleaning. An affected flush cleaning operation shall be considered in compliance if the operating requirements specified in 40 CFR (d) are implemented and carried out. A-7 40 CFR (f); Minn. R CFR (f)(1); Minn. R CFR (f)(2); Minn. R CFR (f)(3); Minn. R CFR ; Minn. R CFR (a); Minn. R CFR (b); Minn. R CFR (c); Minn. R CFR (c)(1)-(3); Minn. R

12 Facility Name: Permit Number: Organic HAP and VOC content levels for primer and topcoat application operations: (1) Performance test periods. For uncontrolled coatings that are not averaged, each 24 hours is considered a performance test. For compliant and non-compliant coatings that are averaged together, each 30-day period is considered a performance test, unless the permitting agency specifies a shorter averaging period as part of an ambient ozone control program. When using a control device other than a carbon adsorber, three 1-hour runs constitute the test period for the initial and any subsequent performance test. When using a carbon adsorber, each rolling material balance period is considered a performance test. Handling and storage of waste. For those wastes, failure to comply with the requirements specified in 40 CFR Section shall be considered a violation. Composition determination. Compliance with the hand-wipe cleaning solvent approved composition list specified in 40 CFR Section (b)(1) for hand-wipe cleaning solvents shall be demonstrated using data supplied by the manufacturer of the cleaning solvent. The data shall identify all components of the cleaning solvent and shall demonstrate that one of the approved composition definitions is met. Vapor pressure determination. The composite vapor pressure of hand-wipe cleaning solvents used in a cleaning operation shall be determined as follows: (1) For single-component hand-wipe cleaning solvents, the vapor pressure shall be determined using MSDS or other manufacturer's data, standard engineering reference texts, or other equivalent methods. (2) The composite vapor pressure of a blended hand-wipe solvent shall be determined by quantifying the amount of each organic compound in the blend using manufacturer's supplied data or a gas chromatographic analysis in accordance with ASTM E or 96 (incorporated by reference see 40 CFR Section 63.14) and by calculating the composite vapor pressure of the solvent by summing the partial pressures of each component. The vapor pressure of each component shall be determined using manufacturer's data, standard engineering reference texts, or other equivalent methods. The equation in Appendix II of this permit shall be used to determine the composite vapor pressure. Organic HAP content level determination compliant primers and topcoats. For those uncontrolled primers and topcoats complying with the primer and topcoat organic HAP content limits specified in 40 CFR Section (c) without being averaged, the following procedures shall be used to determine the mass of organic HAP emitted per volume of coating (less water), as applied. (1) For coatings that contain no exempt solvents, determine the total organic HAP content using manufacturer's supplied data or Method 24 of 40 CFR pt. 60, Appendix A, to determine the VOC content. The VOC content shall be used as a surrogate for total HAP content for coatings that contain no exempt solvent. If there is a discrepancy between the manufacturer's formulation data and the results of the Method 24 analysis, compliance shall be based on the results from the Method 24 analysis. When Method 24 is used to determine the VOC content of water-reducible coatings, the precision adjustment factors in Reference Method 24 shall be used. If the adjusted analytical VOC content is less than the formulation solvent content, then the analytical VOC content should be set equal to the formulation solvent content. (2) For each coating formulation as applied, determine the organic HAP weight fraction, water weight fraction (if applicable), and density from manufacturer's data. If these values cannot be determined using the manufacturer's data, the Permittee shall submit an alternative procedure for determining their values for approval by the Administrator. Recalculation is required only when a change occurs in the coating formulation. (3) For each coating as applied, the Permittee shall calculate the mass of organic HAP emitted per volume of coating (lb/gal) less water as applied using equations 1, 2, and 3 in Appendix II of this permit: A-8 40 CFR (d); Minn. R CFR (i); Minn. R CFR (a); Minn. R CFR (b); Minn. R CFR (b); Minn. R CFR (c); Minn. R CFR (c)(1); Minn. R CFR (c)(2); Minn. R CFR (c)(3); Minn. R

13 Facility Name: Permit Number: (d) Organic HAP content level determination averaged primers and topcoats. For those uncontrolled primers and topcoats that are averaged together in order to comply with the primer and topcoat organic HAP content limits specified in 40 CFR Section (c), the following procedure 40 CFR Section (d)(1) shall be used to determine the monthly volume weighted average mass of organic HAP emitted per volume of coating (less water) as applied, unless the permitting agency specifies a shorter averaging period as part of an ambient ozone control program. (1)(i) Determine the total organic HAP weight fraction as applied of each coating. If any ingredients, including diluent solvent, are added to a coating prior to its application, the organic HAP weight fraction of the coating shall be determined at a time and location in the process after all ingredients have been added. (ii) The Permittee shall determine the total organic HAP weight fraction of each coating as applied each month as follows below. (A) If no changes have been made to a coating, either as supplied or as applied, or if a change has been made that has a minimal effect on the organic HAP content of the coating, the value previously determined may continue to be used until a change in formulation has been made by either the manufacturer or the user. (B) If a change in formulation or a change in the ingredients added to the coating takes place, including the ratio of coating to diluent solvent, prior to its application, either of which results in a more than minimal effect on the organic HAP content of the coating, the total organic HAP weight fraction of the coating shall be redetermined. (iii) Manufacturer's formulation data may be used to determine the total organic HAP content of each coating and any ingredients added to the coating prior to its application. If the total organic HAP content cannot be determined using the manufacturer's data, the Permittee shall submit an alternative procedure for determining the total organic HAP weight fraction for approval by the Administrator. (2)(i) Determine the volume both in total gallons as applied and in total gallons (less water) as applied of each coating. If any ingredients, including diluent solvents, are added prior to its application, the volume of each coating shall be determined at a time and location in the process after all ingredients (including any diluent solvent) have been added. (ii) Determine the volume of each coating (less water) as applied each month, unless the permitting agency specifies a shorter period as part of an ambient ozone control program. (iii) The volume applied may be determined from company records. (3)(i) Determine the density of each coating as applied. If any ingredients, including diluent solvent, are added to a coating prior to its application, the density of the coating shall be determined at a time and location in the process after all ingredients have been added. (ii) Determine the density of each coating as applied each month, unless the permitting agency specifies a shorter period as part of an ambient ozone control program. (A) If no changes have been made to a coating, either as supplied or as applied, or if a change has been made that has a minimal effect on the density of the coating, then the value previously determined may continue to be used until a change in formulation has been made by either the manufacturer or the user. (B) If a change in formulation or a change in the ingredients added to the coating takes place, including the ratio of coating to diluent solvent, prior to its application, either of which results in a more than minimal effect on the density of the coating, then the density of the coating shall be redetermined. (iii) Manufacturer's formulation data may be used to determine the total organic HAP content of each coating and any ingredients added to the coating prior to its application. If the total organic HAP content cannot be determined using the manufacturer's data, the Permittee shall submit an alternative procedure for determining the total organic HAP weight fraction for approval by the Administrator. (4) Calculate the total volume in gallons as applied (less water) by summing the individual volumes of each coating (less water) as applied, which were determined under 40 CFR Section (d)(2). (5) The Permittee shall calculate the volume-weighted average mass of organic HAP in coatings emitted per unit volume (lb/gal) of coating (less water) as applied during each 30-day period using equation 4 in Appendix II of this permit. A-9 40 CFR (d)(1); Minn. R CFR (d)(1); Minn. R CFR (d)(1); Minn. R CFR (d)(2); Minn. R CFR (d)(3); Minn. R CFR (d)(3); Minn. R CFR (d)(4); Minn. R CFR (d)(5); Minn. R

14 Facility Name: Permit Number: (e) VOC content level determination compliant primers and topcoats. For those uncontrolled primers and topcoats complying with the primer and topcoat VOC content levels specified in 40 CFR Section (c) without being averaged, the following procedure shall be used to determine the mass of VOC emitted per volume of coating (less water and exempt solvents) as applied. (1) Determine the VOC content of each formulation (less water and exempt solvents) as applied using manufacturer's supplied data or Method 24 of 40 CFR pt. 60, Appendix A, to determine the VOC content. The VOC content shall be used as a surrogate for total HAP content for coatings that contain no exempt solvent. If there is a discrepancy between the manufacturer's formulation data and the results of the Method 24 analysis, compliance shall be based on the results from the Method 24 analysis. When Method 24 is used to determine the VOC content of water-reducible coatings, the precision adjustment factors in Reference Method 24 shall be used. If the adjusted analytical VOC content is less than the formulation solvent content, then the analytical VOC content should be set equal to the formulation solvent content. 2) For each coating applied, the Permittee shall calculate the mass of VOC emitted per volume of coating (lb/gal) (less water and exempt solvents) as applied using equations 5, 6, and 7 in Appendix II of this permit. 3)(i) If the VOC content is found to be different when EPA Method 24 is used during an enforcement inspection from that used by the Permittee in calculating Ga, compliance shall be based, except as provided in 40 CFR Section (e)(3)(ii) upon the VOC content obtained using EPA Method 24. (ii) If the VOC content of a coating obtained using Method 24 would indicate noncompliance as determined under either 40 CFR Section (d)(3)(i) or (d)(4)(i), the Permittee may elect to average the coating with other uncontrolled coatings and recalculate Gi (using the procedure specified in 40 CFR Section (f)), provided appropriate and sufficient records were maintained for all coatings included in the average recalculation. The recalculated value of Gi (Ga in 40 CFR Section (f)) for the averaged coatings shall then be used to determine compliance. (f) VOC content level determination averaged primers and topcoats. For those uncontrolled primers and topcoats that are averaged within their respective coating category in order to comply with the primer and topcoat VOC content limits specified in 40 CFR Sections (c)(2) and (c)(4), the following procedure shall be used to determine the monthly volume-weighted average mass of VOC emitted per volume of coating (less water and exempt solvents) as applied, unless the MPCA specifies a shorter averaging period as part of an ambient ozone control program. (1)(i) Determine the VOC content (lb/gal) as applied of each coating. If any ingredients, including diluent solvent, are added to a coating prior to its application, the VOC content of the coating shall be determined at a time and location in the process after all ingredients have been added. (ii) Determine the VOC content of each coating as applied each month, unless the MPCA specifies a shorter period as part of an ambient ozone control program. (A) If no changes have been made to a coating, either as supplied or as applied, or if a change has been made that has a minimal effect on the VOC content of the coating, the value previously determined may continue to be used until a change in formulation has been made by either the manufacturer or the user. (B) If a change in formulation or a change in the ingredients added to the coating takes place, including the ratio of coating to diluent solvent, prior to its application, either of which results in a more than minimal effect on the VOC content of the coating, the VOC content of the coating shall be redetermined. A CFR (e); Minn. R CFR (e); Minn. R CFR (e)(2); Minn. R CFR (e)(3); Minn. R CFR (f); Minn. R CFR (f); Minn. R

15 Facility Name: Permit Number: iii) Determine the VOC content of each primer and topcoat formulation (less water and exempt solvents) as applied using EPA Method 24 or from manufacturer's data. (2)(i) Determine the volume both in total gallons as applied and in total gallons (less water and exempt solvents) as applied of each coating. If any ingredients, including diluent solvents, are added prior to its application, the volume of each coating shall be determined at a time and location in the process after all ingredients (including any diluent solvent) have been added. (ii) Determine the volume of each coating (less water and exempt solvents) as applied each day. (iii) The volume applied may be determined from company records. (3) Calculate the total volume in gallons (less water and exempt solvents) as applied by summing the individual volumes of each coating (less water and exempt solvents) as applied, which were determined under 40 CFR Section (f)(2). (4) The Permittee shall calculate the volume-weighted average mass of VOC emitted per unit volume (lb/gal) of coating (less water and exempt solvents), as applied for each coating category during each 30-day period using equation 8 in Appendix II of this permit. (5)(i) If the VOC content is found to be different when EPA Method 24 is used during an enforcement inspection from that used by the Permittee in calculating Ga, recalculation of Ga is required using the new value. If more than one coating is involved, the recalculation shall be made once using all of the new values. (ii) If recalculation is required, the Permittee may elect to include in the recalculation of Ga uncontrolled coatings that were not previously included provided appropriate and sufficient records were maintained for these other coatings to allow daily recalculations. (iii) The recalculated value of Ga under either 40 CFR Sections (f)(5)(i) or (f)(5)(ii) shall be used to determine compliance. Monitoring Dry particulate filter, HEPA filter, and waterwash systems for primer and topcoat application operations. (1) The Permittee using a dry particulate filter system to meet the requirements of 40 CFR Section (g)(2) shall, while primer or topcoat application operations are occurring, continuously monitor the pressure drop across the system and read and record the pressure drop once per shift following the recordkeeping requirements of 40 CFR Section (d). (f) Reduction of monitoring data. (1) The data may be recorded in reduced or nonreduced form (e.g., parts per million (ppm) pollutant and % O2 or nanograms per Joule (ng/j) of pollutant). A CFR (f); Minn. R CFR (f)(3); Minn. R CFR (f)(4); Minn. R CFR (f)(5); Minn. R CFR (c); Minn. R CFR (f); Minn. R (2) All emission data shall be converted into units specified in 40 CFR pt. 63, subp. GG for reporting purposes. After conversion into units specified in 40 CFR pt. 63, subp. GG, the data may be rounded to the same number of significant digits as used to specify the emission limit (e.g., rounded to the nearest 1% overall reduction efficiency). (a) General. The Permittee subject to 40 CFR pt. 63, subp. GG shall fulfill all recordkeeping requirements specified in 40 CFR Section (a), (b), (d), and (f) below. The Permittee shall submit reports to the Commissioner and shall send a copy of each report to the Administrator. Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data must be retained on site. 40 CFR (a); Minn. R CFR (a); Minn. R ; 40 CFR 63.10(a); Minn. R CFR (a); Minn. R ; 40 CFR 63.10(b)(1); Minn. R , subp. 2(B