process description all4 quality professional (aqp) seal tceq … · 2020. 4. 14. · majek...

Executive Summary Majek Boatworks, Inc. (Majek) is proposing to permit the operation of a fiberglass boat manufacturing facility at 7001 Saluki St. in Corpus Christi, TX (Facility). The Facility originally operated under the provisions of Permit by Rule 30 Texas Administrative Code (TAC) 106.392 - Fiberglass Reinforced Plastics and Cultured Marble Facilities. In 2008, the Facility applied for a Minor New Source Review (NSR) Permit and Permit No. 85144 was held through its expiration in 2018. Because the Facility did not renew the permit in a timely manner, this submittal is being treated as an initial Minor NSR Permit Application (Application) for the Facility operations. Majek Boatworks, Inc. Corpus Christi, TX CN601320245/RN102595410 Introduction This Application is submitted via the State of Texas Environmental Electronic Reporting System (STEERS) in accordance with the provisions of 30 TAC Chapter 116, Subchapter B: NSR Permits and consists of the following information. The bolded items are included in this section:

• Process Description • ALL4 Quality Professional (AQP) Seal • TCEQ 20833a: PI-1 – General Application, Version 4.0 • Electronic Modeling Evaluation Workbook (EMEW) • Figures

o Facility Location Map o Plot Plan o Process Flow Diagram

• Regulatory Applicability Analyses • Best Available Control Technology (BACT) Determinations • Summary of Emissions and Emissions Calculations • Equipment Specification Sheets

Should you have any questions related to this submittal, or require additional information, please contact Meghan Skemp at [email protected] or 281-937-7553 x307 or me at [email protected] or 361-991-3102.

mailto:[email protected]

mailto:jimmy@majek

Majek Boatworks, Inc.

Corpus Christi, TX Minor NSR Permit Application

2 Majek Boatworks, Inc. March 2020

PROCESS DESCRIPTION

The Facility produces fiberglass sport boats ranging in length from 20 to 25 feet (ft) using open

molds. The fiberglass boat manufacturing process consists of four basic stages as provided

below and shown in the Process Flow Diagram uploaded to STEERS.

• Gel coat spray application; • Resin and fiberglass application; • Surface finishing; and • Equipment cleanup.

All liquid process raw materials (e.g., gel coat, resin, cleanup solvents) are shipped and stored

onsite in 55-gallon drums and 220-gallon totes. Liquid raw materials are stored in a designated

chemical storage area at the Facility. The fiberglass boat manufacturing process is explained

below and broken down by the stages of operation and emission points.

Gel Goat Application

Pre-made boat molds are moved to the designated spray booth and are prepared for gel coat

application. Gel coat is a two-part catalyzed coating that is manually sprayed onto the mold to

form the clear outer layer of the part (i.e., hull, deck, or small parts). A wax mold release is first

applied by hand to the mold to ensure that the finished product can be easily removed from the

mold. The gel coat and catalyst are automatically mixed in the nozzle which atomizes the

mixture for efficient application. The catalyzed gel coats cure into a hard surface through cross

linking. Gel coats can be clear or pigmented. All spray application of gel coat is performed in a

negative pressure booth. Volatile organic Compounds (VOC) emissions associated with the

spraying operation are captured within the booth and exhausted to atmosphere through emission

point number (EPN) – 001.




Resin and Fiberglass Application

The gel coat sprayed mold is allowed to cure before moving to either of the adjacent Production

Areas for resin and fiberglass application. After the gel coat has cured, the inside of the gel coat

is coated with a skin coat of polyester resin and short glass fibers. Following the skin coat, pieces

of fiberglass mat are cut to size, applied to the inside of the mold, and saturated with catalyzed

polyester resin either by non-atomized spraying or by brush/roller to the inner surface of

hardened gel coat layer. The first layer of mat is applied to the mold, rolled out, and coated with

additional resin. The process is repeated until the boat hull has the necessary wall thickness.

Approximately 90% of the resin used at the Facility is applied using high volume/low pressure,

non-atomized spray applicators. The resin and catalyst are automatically mixed in the pump

system. Approximately 10% of the resin is applied manually using a brush/roller. Resin used

during manual application is poured into buckets and the catalyst is added before application.

The saturated fabric is then rolled with a metal or plastic roller to compact the fibers and remove

air bubbles.

When resin/fiberglass application is complete, the parts are allowed to cure in the enclosed

Production Area with the ventilation system operating. After hardening, the cured parts are then

removed from the molds and moved into the Finishing Area. The two Production Areas are in

large, enclosed buildings vented by three 40,000 cubic feet per minute (cfm) exhaust fans to 35 ft

vertical exhaust stacks and one 10,000 cfm exhaust fan to a 30 ft exhaust stack (EPN-002, EPN-

003, EPN-004 and EPN-005, respectively). The exhaust fans are operated continually while gel

coat and resin application and cleanup occur.

Finishing

ln the Finishing Area, portable power saws, grinders, and sanders are used to remove the casting

flash, smooth various surfaces, and refine the joints where parts will be fitted. The finishing area

is a large, semi-open room that is vented by a dedicated 12,000 cfm exhaust fan to a 30 ft vertical

exhaust stack (EPN-006). Before the dust is exhausted to the stack, it is routed through a Micro




Air Cleaners dust collector which filters the particles through filter cartridges. More information

around the dust collection system and efficiency is uploaded to STEERS.

Equipment Cleanup

The gel coat and resin application equipment and tools are cleaned after each use, otherwise the

gel coat and resin will harden and render the equipment unusable. Equipment cleaning

operations are conducted with the Spray Booth or Production Area ventilation systems operating

so that cleaning emissions are captured as well. The application equipment is cleaned by

circulating acetone through the equipment and capturing it in a container. Spray gun tips are

removed and soaked in a covered container of acetone. The mixer is cleaned by pouring in a

small amount of acetone and operating the mixer for a few minutes. The mixture of waste

solvent, gel coat, and resin is transferred to drums that remain covered except when more solvent

is added. The acetone solvent that does not evaporate is recovered and cycled through a filter-

cleaning system. The conservative assumption is that 50% of acetone is recovered and reused.

The Finish Area is swept daily. The dust collector and exhaust ventilation system operating at

all times. The waste material is placed in drums that remain covered except for the addition of

more sweepings and are stored and disposed of in accordance with applicable rules.







mailto:jimmy@majek

Texas Commission on Environmental QualityForm PI-1 General Application

General

Date: March 2020Permit #: TBD

Company: Majek Boatworks, Inc.

I agree

I acknowledge that I am submitting an authorized TCEQ application workbook and any necessary attachments. Except for inputting the requested data and adjusting row height and column width, I have not changed the TCEQ application workbook in any way, including but not limited to changing formulas, formatting, content, or protections.

https://www.sos.state.tx.us

Suite 170

Project Manager

Mailing Address:

Prefix (Mr., Ms., Dr., etc.): Mrs.

78414Telephone Number:

Texas

ALL4 LLC

(361) 991-3565Email Address: [email protected]

Address Line 2:

SkempTitle:

State:

(361) 991-3102Fax Number:

Majek Boatworks Inc.

Mailing Address: 7001 Saluki St.

City:

ZIP Code:

Corpus Christi

Last Name:

City: StaffordState: Texas

Company or Legal Name:

I. Applicant Information

Texas Secretary of State Charter/Registration Number (if given):

C. Technical Contact Information: This person must have the authority to make binding agreements and representations on behalf of the applicant and may be a consultant. Additional technical contact(s) can be provided in a cover letter.

A. Company Information

B. Company Official Contact Information: must not be a consultantPrefix (Mr., Ms., Dr., etc.): Mr. First Name: JamesLast Name: MajekTitle: Owner and Manager

Permits are issued to either the facility owner or operator, commonly referred to as the applicant or permit holder. List the legal name of the company, corporation, partnership, or person who is applying for the permit. We will verify the legal name with the Texas Secretary of State at (512) 463-5555 or at:

Company or Legal Name:

2819377553x307

D. Assigned Numbers

CN601320245Enter the CN. The CN is a unique number given to each business, governmental body, association, individual, or other entity that owns, operates, is responsible for, or is affiliated with a regulated entity.

Telephone Number:Fax Number:Email Address: [email protected]

The CN and RN below are assigned when a Core Data Form is initially submitted to the Central Registry. The RN is also assigned if the agency has conducted an investigation or if the agency has issued an enforcement action. If these numbers have not yet been assigned, leave these questions blank and include a Core Data Form with your application submittal. See Section VI.B. below for additional information.

N/A

ZIP Code: 77477

First Name: Meghan

10707 Corporate DriveAddress Line 2:

Version 4.0 Page 1

https://www.sos.state.tx.us/








General



No

How are/will MSS activities for sources associated with this project be authorized? This permit

B. MSS Activities

HAP Major Source [FCAA § 112(g)]: Not applicable, Initial, Major ModificationPAL: Not applicable, Initial, Amendment, Renewal, Renewal/Amendment, AlterationGHG PSD: Not applicable, Initial, Major Modification, Voluntary Update

Not applicable

Not applicable

Not applicable

Permit Number (if assigned)

Enter the RN. The RN is a unique agency assigned number given to each person, organization, place, or thing that is of environmental interest to us and where regulated activities will occur. The RN replaces existing air account numbers. The RN for portable units is assigned to the unit itself, and that same RN should be used when applying for authorization at a different location.

This cell intentionally left blank

Not applicable

II. Delinquent Fees and Penalties


Minor NSR (can be a Title V major source): Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Relocation/Alteration, Change of Location, Alteration, Extension to Start of Construction

Additional information regarding the different NSR authorizations can be found at:

RN102595410

Nonattainment: Not applicable, Initial, Major Modification

Flexible: Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

Not applicable

Action Type Requested(do not leave blank)

Does the applicant have unpaid delinquent fees and/or penalties owed to the TCEQ?This form will not be processed until all delinquent fees and/or penalties owed to the TCEQ or the Office of the Attorney General on behalf of the TCEQ are paid in accordance with the Delinquent Fee and Penalty Protocol. For more information regarding Delinquent Fees and Penalties, go to the TCEQ Web site at:https://www.tceq.texas.gov/agency/financial/fees/delin

Not applicable

Select from the drop-down the type of action being requested for each permit type. If that permit type does not apply, you MUST select "Not applicable".

Provide all assigned permit numbers relevant for the project. Leave blank if the permit number has not yet been assigned.

https://www.tceq.texas.gov/permitting/air/guidance/authorize.html

Initial

Permit Type

A. Permit and Action Type (multiple may be selected, leave no blanks)

Special Permit: Not applicable, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

III. Permit Information

De Minimis: Not applicable, Initial Not applicable

Not applicable

PSD: Not applicable, Initial, Major Modification

Version 4.0 Page 2

https://www.tceq.texas.gov/agency/financial/fees/delin















General



NoNo

No

No

attainment or unclassified for all pollutants

Is this facility located at a site required to obtain a site operating permit (SOP) or general operating permit (GOP)?

N/A

City: If the address is not located in a city, then enter the city or town closest to the facility, even if it is not in the same county as the facility.ZIP Code: Include the ZIP Code of the physical facility site, not the ZIP Code of the applicant's mailing address.

Longitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Longitude is the angular distance of a location west of the prime meridian and will always be between 93 and 107 degrees west (W) in Texas.

Latitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Latitude is the angular distance of a location north of the equator and will always be between 25 and 37 degrees north (N) in Texas.

Nueces

County attainment status as of Sept. 23, 2019

Are there any standard permits, standard exemptions, or PBRs to be incorporated by reference?Are there any PBR, standard exemptions, or standard permits associated to be incorporated by consolidation? Note: Emission calculations, a BACT analysis, and an impacts analysis must be attached to this application at the time of submittal for any authorization to be incorporated by consolidation.


Is this a project for a lead smelter, concrete crushing facility, and/or a hazardous waste management facility?

County: Enter the county where the facility is physically located.

78414

Street Address:

97:22:22.1 W

Site Location Description: If there is no street address, provide written driving directions to the site. Identify the location by distance and direction from well-known landmarks such as major highway intersections.

A. LocationIV. Facility Location and General Information

Will this permit be consolidated into another NSR permit with this action?

To ensure protectiveness, previously issued authorizations (standard permits, standard exemptions, or PBRs) including those for MSS, are incorporated into a permit either by consolidation or by reference. At the time of renewal and/or amendment, consolidation (in some cases) may be voluntary and referencing is mandatory. More guidance regarding incorporation can be found in 30 TAC § 116.116(d)(2), 30 TAC § 116.615(3) and in this memo:

https://www.tceq.texas.gov/assets/public/permitting/air/memos/pbr_spc06.pdf

C. Consolidating NSR Permits

TCEQ Region Region 14

27:38:53.5 N

Use USGS maps, county maps prepared by the Texas Department of Transportation, or an online software application such as Google Earth to find the latitude and longitude.

7001 Saluki St.

D. Incorporation of Standard Permits, Standard Exemptions, and/or Permits By Rule (PBR)

E. Associated Federal Operating Permits

No

Will NSR permits be consolidated into this permit with this action?

No

Corpus Christi

Version 4.0 Page 3

http://www.tceq.texas.gov/assets/public/permitting/air/memos/pbr_spc06.pdf








General



No

No

No

NoNo

D. Operating Schedule

Projected Start of Construction: Already Constructed - see application narrative

Permanent or portable facility?

B. General InformationSite Name:

Are there any schools located within 3,000 feet of the site boundary?C. Portable Facility

336612Principal NAICS code:

Permanent

Area Name: Must indicate the general type of operation, process, equipment or facility. Include numerical designations, if appropriate. Examples are Sulfuric Acid Plant and No. 5 Steam Boiler. Vague names such as Chemical Plant are not acceptable.

Fiberglass Boat Manufacturing Facility

D. Industry TypeFiberglass Sport Boats

B. Is the Core Data Form (Form 10400) attached?

All representations regarding construction plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued. (30 TAC § 116.116)

State Senator:

NAICS codes and conversions between NAICS and SIC Codes are available at:

Senator Juan 'Chur' Hinojosa

https://www.census.gov/eos/www/naics/

E. State Senator and Representative for this site

https://wrm.capitol.texas.gov/This information can be found at (note, the website is not compatible to Internet Explorer):

No

Boat Plant

Authorization must be obtained for many projects before beginning construction. Construction is broadly interpreted as anything other than site clearance or site preparation. Enter the date as "Month Date, Year" (e.g. July 4, 1776).

Will sources in this project be authorized to operate 8760 hours per year? If no, provide details in your permit application materials.

The facility produces by hand a variety of small, fiberglass sport boats ranging in length from 20 feet to 25 feet. The operations include gel coat spray application, resin and fiberglass application, finishing, and equipment cleanup.

Is this application in response to, or related to, an agency investigation, notice of violation, or enforcement action?

Upon Approval

Does this facility operate seasonally?

Provide a brief description of the project that is requested. (Limited to 500 characters).

A list of SIC codes can be found at:

VI. Application Materials

A. Confidential Application MaterialsIs confidential information submitted with this application?

https://www.naics.com/sic-codes-industry-drilldown/

Principal Company Product/Business:

C. Enforcement ProjectsProjected Start of Operation:

Represenative Todd A. Hunter

3732Principal SIC code:

District: Texas Senate District 20

B. Project Timing

A. DescriptionV. Project Information

Texas House District 32District:State Representative:



Version 4.0 Page 4







http://www.census.gov/eos/www/naics/






https://fyi.capitol.texas.gov/Home.aspx










General



Yes

Yes

YesYes

Yes

Yes

Yes

YesYes

Yes

Yes

Yes

Yes

N/AN/A

Yes

Yes

YesYes

H. Is a material balance (Table 2, Form 10155) attached?

C. Is a current area map attached?

Does the map show a 3,000-foot radius from the property boundary?

https://www.tceq.texas.gov/assets/public/permitting/centralregistry/10400.docx

The owner or operator of the facility must apply for authority to construct. The appropriate company official (owner, plant manager, president, vice president, or environmental director) must sign all copies of the application. The applicant’s consultant cannot sign the application. Important Note: Signatures must be original in ink, not reproduced by photocopy, fax, or other means, and must be received before any permit is issued.

G. Are detailed calculations attached? Calculations must be provided for each source with new or changing emission rates. For example, a new source, changing emission factors, decreasing emissions, consolidated sources, etc. You do not need to submit calculations for sources which are not changing emission rates with this project. Please note: the preferred format is an electronic workbook (such as Excel) with all formulas viewable for review. It can be emailed with the submittal of this application workbook.

Does the process description also explain how the facility or facilities will be operating when the maximum possible emissions are produced?

Is the area map a current map with a true north arrow, an accurate scale, the entire plant property, the location of the property relative to prominent geographical features including, but not limited to, highways, roads, streams, and significant landmarks such as buildings, residences, schools, parks, hospitals, day care centers, and churches?

VII. Signature

Are emission rates and associated calculations for planned MSS facilities and related activities attached?

J. Is a discussion of state regulatory requirements attached, addressing 30 TAC Chapters 101, 111, 112, 113, 115, and 117?For all applicable chapters, does the discussion include how the facility will comply with the requirements of the chapter?For all not applicable chapters, does the discussion include why the chapter is not applicable?K. Are all other required tables, calculations, and descriptions attached?

I. Is a list of MSS activities attached?


D. Is a plot plan attached?Does your plot plan clearly show a north arrow, an accurate scale, all property lines, all emission points, buildings, tanks, process vessels, other process equipment, and two bench mark locations?

Does your plot plan identify all emission points on the affected property, including all emission points authorized by other air authorizations, construction permits, PBRs, special permits, and standard permits?Did you include a table of emission points indicating the authorization type and authorization identifier, such as a permit number, registration number, or rule citation under which each emission point is currently authorized?E. Is a process flow diagram attached?F. Is a process description attached?Does the process description emphasize where the emissions are generated, why the emissions must be generated, what air pollution controls are used (including process design features that minimize emissions), and where the emissions enter the atmosphere?

Version 4.0 Page 5









General



Name:

Signature:

Date:

The signature below confirms that I have knowledge of the facts included in this application and that these facts are true and correct to the best of my knowledge and belief. I further state that to the best of my knowledge and belief, the project for which application is made will not in any way violate any provision of the Texas Water Code (TWC), Chapter 7; the Texas Health and Safety Code, Chapter 382; the Texas Clean Air Act (TCAA); the air quality rules of the Texas Commission on Environmental Quality; or any local governmental ordinance or resolution enacted pursuant to the TCAA. I further state that I understand my signature indicates that this application meets all applicable nonattainment, prevention of significant deterioration, or major source of hazardous air pollutant permitting requirements. The signature further signifies awareness that intentionally or knowingly making or causing to be made false material statements or representations in the application is a criminal offense subject to criminal penalties.

James Majek

Original signature is required.

Version 4.0 Page 6


Technical



Yes

No

No

No

B. Title 40 CFR Part 61

Does this project require an impacts analysis?

Is this facility located at a site within the Houston/Galveston nonattainment area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties)?


IX. Emissions ReviewA. Impacts AnalysisAny change that results in an increase in off-property concentrations of air contaminants requires an air quality impacts demonstration. Information regarding the air quality impacts demonstration must be provided with the application and show compliance with all state and federal requirements. Detailed requirements for the information necessary to make the demonstration are listed on the Impacts sheet of this workbook.


B. Disaster ReviewIf the proposed facility will handle sufficient quantities of certain chemicals which, if released accidentally, would cause off-property impacts that could be immediately dangerous to life and health, a disaster review analysis may be required as part of the application. Contact the appropriate NSR permitting section for assistance at (512) 239-1250. Additional Guidance can be found at:https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/disrev-factsheet.pdfDoes this application involve any air contaminants for which a disaster review is required?C. Air Pollutant Watch ListCertain areas of the state have concentrations of specific pollutants that are of concern. The TCEQ has designated these portions of the state as watch list areas. Location of a facility in a watch list area could result in additional restrictions on emissions of the affected air pollutant(s) or additional permit requirements. The location of the areas and pollutants of interest can be found at:https://www.tceq.texas.gov/toxicology/apwl/apwl.htmlIs the proposed facility located in a watch list area?D. Mass Emissions Cap and Trade

VIII. Federal Regulatory QuestionsIndicate if any of the following requirements apply to the proposed facility. Note that some federal regulations apply to minor sources. Enter all applicable Subparts.

Do MACT subpart(s) apply to a facility in this application? No

A. Title 40 CFR Part 60Do NSPS subpart(s) apply to a facility in this application?

Do NESHAP subpart(s) apply to a facility in this application? No

C. Title 40 CFR Part 63

No

I. Additional Questions for Specific NSR Minor Permit Actions

Version 4.0 Page 1

https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/disrev-factsheet.pdf






http://www.tceq.texas.gov/toxicology/apwl/apwl.html








Texas Commission on Environmental QualityForm PI-1 General ApplicationUnit Types - Emission Rates



Action Requested (only 1 action per FIN)

Include these emissions in annual (tpy) summary?

Facility ID Number (FIN)

Emission Point Number (EPN) Source Name Pollutant

Current Short-Term (lb/hr)

Current Long-Term (tpy)

ConsolidatedCurrent Short-Term (lb/hr)

Consolidated Current Long-Term (tpy)

Proposed Short-Term (lb/hr)

Proposed Long-Term (tpy)

Short-Term Difference (lb/hr)

Long-Term Difference (tpy)

Unit Type (Used for reviewing BACT and Monitoring Requirements)

Unit Type Notes (only if "other" unit type in Column O)

New/Modified Yes SPRAYBOOTH SPRAYBOOTH Spray Booth VOC 4.32 4.31 4.3151 4.3147 Process: CastingNew/Modified Yes SP1 SP1 Small Parts 1 VOC 0.70 0.52 0.7015 0.5235 Process: CastingNew/Modified Yes SP2 SP2 Small Parts 2 VOC 0.70 0.52 0.7015 0.5235 Process: CastingNew/Modified Yes PROD1 PROD1 Production Area 1 VOC 2.81 2.09 2.8058 2.0939 Process: CastingNew/Modified Yes PROD2 PROD2 Production Area 2 VOC 2.81 2.09 2.8058 2.0939 Process: CastingNew/Modified Yes FINISH1 FINISH1 Finishing Area 1 PM2.5 1.03 1.01 1.0286 1.008 Material Handling: SandingNew/Modified Yes SPRAYBOOTH SPRAYBOOTH Spray Booth HAPs 4.30 4.30 4.3001 4.3 Process: CastingNew/Modified Yes SP1 SP1 Small Parts 1 HAPs 0.69 0.51 0.6912 0.5135 Process: CastingNew/Modified Yes SP2 SP2 Small Parts 2 HAPs 0.69 0.51 0.6912 0.5135 Process: CastingNew/Modified Yes PROD1 PROD1 Production Area 1 HAPs 2.76 2.05 2.7648 2.0537 Process: CastingNew/Modified Yes PROD2 PROD2 Production Area 2 HAPs 2.76 2.05 2.7648 2.0537 Process: Casting

this cell is intentionally left blank

This cell intentionally left blankMechanical / Agricultural / ConstructionPermit primary industry (must be selected for workbook to function)

Version 4.0 Page 1


Stack Parameters



EPNIncluded in EMEW?

UTM Coordinates

ZoneEast (Meters)

North (Meters)

BuildingHeight (ft)

Height Above Ground (ft)

Stack Exit Diameter (ft)

Velocity (FPS)

Temperature (°F)

Fugitives - Length (ft)

Fugitives - Width (ft)

Fugitives - Axis Degrees

SPRAYBOOTH YesSP1 YesSP2 YesPROD1 YesPROD2 YesFINISH1 Yes

Emission Point Discharge Parameters

Version 4.0 Page 1


Public Notice



Yes

Pollutant Proposed Long-Term (tpy)

VOC 9.55PM 0.00PM10 0.00PM2.5 1.01NOx 0.00CO 0.00SO2 0.00Pb 0.00HAPs 9.434058

* Notice is required for PM, PM10, and PM2.5 if one of these pollutants is above the threshold.** Notice of a GHG action is determined by action type. Initial and major modification always require notice. Voluntary updates require a consolidated notice if there is a change to BACT. Project emission increases of CO2e (CO2 equivalent) are not relevant for determining public notice of GHG permit actions.

II. Public Notice Information

A. Contact InformationEnter the contact information for the person responsible for publishing. This is a designated representative who is responsible for ensuring public notice is properly published in the appropriate newspaper and signs are posted at the facility site. This person will be contacted directly when the TCEQ is ready to authorize public notice for the application.Prefix (Mr., Ms., Dr., etc.):

Last Name:Title:

Complete this section if public notice is required (determined in the above section) or if you are not sure if public notice is required.

Mr.TannerHensonStaff Engineer

Yes


I. Public Notice Applicability

Is this an application for an initial permit?

C. Is public notice required for this project as represented in this workbook?If no, proceed to Section III Small Business Classification.Note: public notice applicability for this project may change throughout the technical review.

A. Application Type

B. Project Increases and Public Notice Thresholds (for Initial and Amendment Projects)

Yes

First Name:

D. Are any HAPs to be authorized/re-authorized with this project? The category "HAPs" must be specifically listed in the public notice if the project authorizes (reauthorizes for renewals) any HAP pollutants.

Version 4.0 Page 1


Public Notice



Address Line 2:

First Name:

Has the public place granted authorization to place the application for public viewing and copying?

Title:

StaffordTX

10707 Corporate DrSuite 170

Telephone Number:

Email Address:Fax Number:

Name of Public Place:Physical Address:

Skemp

Prefix (Mr., Ms., Dr., etc.):

N/A

Last Name:

La Retama Central Library

City: Corpus Christi78401Nueces

Enter the contact information for the Technical Contact. This is the designated representative who will be listed in the public notice as a contact for additional information.

B. Public placePlace a copy of the full application (including all of this workbook and all attachments) at a public place in the county where the facilities are or will be located. You must state where in the county the application will be available for public review and comment. The location must be a public place and described in the notice. A public place is a location which is owned and operated by public funds (such as libraries, county courthouses, city halls) and cannot be a commercial enterprise. You are required to pre-arrange this availability with the public place indicated below. The application must remain available from the first day of publication through the designated comment period.

If this is an application for a PSD, nonattainment, or FCAA §112(g) permit, the public place must have internet access available for the public as required in 30 TAC § 39.411(f)(3).

If the application is submitted to the agency with information marked as Confidential, you are required to indicate which specific portions of the application are not being made available to the public. These portions of the application must be accompanied with the following statement: Any request for portions of this application that are marked as confidential must be submitted in writing, pursuant to the Public Information Act, to the TCEQ Public Information Coordinator, MC 197, P.O. Box 13087, Austin, Texas 78711-3087.

Company Name:Mailing Address:Address Line 2:City:State:

10707 Corporate DrSuite 170StaffordTX

ALL4 LLC

ALL4 LLC

[email protected]

State:

Yes

774772819377553 x307

ZIP Code:

2819377553 x308N/A

City:

Company Name:

ZIP Code:Telephone Number:Fax Number:Email Address:

Mrs.Meghan

77477

[email protected]

Project Manager

C. Alternate Language PublicationIn some cases, public notice in an alternate language is required. If an elementary or middle school nearest to the facility is in a school district required by the Texas Education Code to have a bilingual program, a bilingual notice will be required. If there is no bilingual program required in the school nearest the facility, but children who would normally attend those schools are eligible to attend bilingual programs elsewhere in the school district, the bilingual notice will also be required. If it is determined that alternate language notice is required, you are responsible for ensuring that the publication in the alternate language is complete and accurate in that language.

Mailing Address:Address Line 2:

ZIP Code:County:

805 Comanche

Version 4.0 Page 2


Public Notice



Yes

NoNoNoYes

Are the children who attend either the elementary school or the middle school closest to your facility eligible to be enrolled in a bilingual program provided by the district?

Spanish

Small business classification:Are the site emissions of all air contaminants combined greater than or equal to 75 tpy?Are the site emissions of any individual air contaminant greater than or equal to 50 tpy?Is the site a major source under 30 TAC Chapter 122, Federal Operating Permit Program?


Does the company (including parent companies and subsidiary companies) have fewer than 100 employees or less than $6 million in annual gross receipts?

If yes to either question above, list which language(s) are required by the bilingual program?

Yes

YesIs a bilingual program required by the Texas Education Code in the School District?

Complete this section to determine small business classification. If a small business requests a permit, agency rules (30 TAC § 39.603(f)(1)(A)) allow for alternative public notification requirements if all of the following criteria are met. If these requirements are met, public notice does not have to include publication of the prominent (12 square inch) newspaper notice.

III. Small Business Classification

Version 4.0 Page 3


Federal Applicability



Determination:

No

Pollutant Project Increase Threshold PSD Review Required?

CO 0 250 NoNOx 0 250 No

PM 1.03 250 NoPM10 1.03 250 NoPM2.5 1.03 250 NoSO2 0 250 No

Ozone (as VOC) 9.55 250 No

Ozone (as NOx) 0 250 No

Pb 0 250 NoH2S 0 250 No

TRS 0 250 NoReduced sulfur compounds (including H2S) 0 250 NoH2SO4 0 250 No

Fluoride (excluding HF) 0 250 No

CO2e 0 N/A No

This project will be located in an area that is in attainment for ozone as of Sept. 23, 2019. Select from the drop-down list to the right if you would like the project to be reviewed under a different classification.

Is netting required for the PSD analysis for this project?


I. County Classification

This project will be located in an area that is in attainment or unclassified for all pollutants. Nonattainment review is not required.

Nueces

II. PSD and GHG PSD Applicability SummaryThis cell intentionally left blank

County (completed for you from your response on the General sheet)Does the project require retrospective review? No

Version 4.0 Page 1


Fees



No

No


IV. Calculations - Non-RenewalFor GHG permits: A single PSD fee (calculated on the capital cost of the project per 30 TAC § 116.163) will be required for all of the associated permitting actions for a GHG PSD project. Other NSR permit fees related to the project that have already been remitted to the TCEQ can be subtracted when determining the appropriate fee to submit with the GHG PSD application. Identify these other fees in the GHG PSD permit application.

Ambient air monitoring network. $0.00Sub-Total: $212,500.00

Sub-Total: $7,500.00


III. Indirect Costs - Non-RenewalType of Cost AmountFinal engineering design and supervision, and administrative overhead. $7,500.00Construction expense, including construction liaison, securing local building permits, insurance, temporary construction facilities, and construction clean-up. $0.00

Contractor's fee and overhead. $0.00

Process and control equipment not previously owned by the applicant and not currently authorized under this chapter. $20,000.00

Auxiliary equipment, including exhaust hoods, ducting, fans, pumps, piping, conveyors, stacks, storage tanks, waste disposal facilities, and air pollution control equipment specifically needed to meet permit and regulation requirements.

$44,000.00

Freight charges. $0.00Site preparation, including demolition, construction of fences, outdoor lighting, road, and parking areas. $30,000.00

Auxiliary buildings, including materials storage, employee facilities, and changes to existing structures. $81,500.00

I. General Information - Non-Renewal

II. Direct Costs - Non-RenewalThis cell intentionally left blank

Is this project for new facilities controlled and operated directly by the federal government? (30 TAC § 116.141(b)(1) and 30 TAC § 116.163(a))

A fee of $75,000 shall be required if no estimate of capital project cost is included with the permit application. (30 TAC § 116.141(d)) Select "yes" here to use this option. Then skip sections II and III.

Select Application Type Minor Application

Installation, including foundations, erection of supporting structures, enclosures or weather protection, insulation and painting, utilities and connections, process integration, and process control equipment.

$37,000.00

Type of Cost Amount

Version 4.0 Page 1


Fees



$220,000.00

$900.00

$900.00

Yes900.00$

$900.00

NoNo

C. Total Paid

A. Payment One (required)

Is the estimated capital cost of the project above $2 million?Is the application required to be submitted under the seal of a Texas licensed P.E.?Note: an electronic PE seal is acceptable.

Greater than $25,000,000 $75,000 (maximum fee)

Less than $300,000 $900 (minimum fee)$300,000 - $7,500,000 N/A

$300,000 - $25,000,000 0.30% of capital costGreater than $7,500,000 N/A

Estimated Capital Cost Minor Application Fee


Your estimated capital cost: Minimum fee applies.Permit Application Fee: $900.00


VIII. Professional Engineer Seal Requirement


VII. Payment Information



VI. Total FeesNote: fees can be paid together with one payment or as two separate payments.Non-Renewal Fee

Total

In signing the "General" sheet with this fee worksheet attached, I certify that the total estimated capital cost of the project as defined in 30 TAC §116.141 is equal to or less than the above figure. I further state that I have read and understand Texas Water Code § 7.179, which defines Criminal Offenses for certain violations, including intentionally or knowingly making, or causing to be made, false material statements or representations.

Enter the check, money order, ePay Voucher, or other transaction number:Enter the Company name as it appears on the check:

STEERS


Enter the fee amount:Was the fee paid online?

Version 4.0 Page 2


Impacts



PollutantDoes this pollutant require PSD review?

How will you demonstrate that this project meets all applicable requirements?

Notes Additional Notes (optional)

VOC No Not applicable This pollutant is not a part of this project or does not require an impacts analysis.

PM2.5 No Modeling: screen or refined Attach a completed "Electronic Modeling Evaluation Workbook" (EMEW).

HAPs No Modeling: screen or refined Attach a completed "Electronic Modeling Evaluation Workbook" (EMEW).

Version 4.0 Page 1


BACT



Current Tier I BACT Confirm Additional Notes

Action Requested FINs Unit Type Pollutant Current Tier I BACT Confirm Additional NotesNew/Modified SPRAYBOOTH Process: Casting VOC See Additional Notes: Yes See Application Narrative

New/Modified SPRAYBOOTH Process: Casting MSS

Best management practices (maintenance is conducted indoors, roads are watered, traffic and speed are reduced) employed during maintenance, no additional controls required for startup and shutdown operations beyond normal operation BACT requirements. No bypassing of controls. Fabric filters should be in good repair with an acceptable pressure drop prior to the start of operation.

Removal of spent filters in such a manner to minimize PM emissions and placing the spent filters in sealable bags or other sealable containers prior to removal from the site. Bags or containers shall be kept closed at all times except when adding spent filters.

Yes See Application Narrative

New/Modified SP1 Process: Casting VOC See Additional Notes: Yes See Application Narrative

New/Modified SP1 Process: Casting MSS




New/Modified SP2 Process: Casting VOC See Additional Notes: Yes See Application Narrative

New/Modified SP2 Process: Casting MSS




New/Modified PROD1 Process: Casting VOC See Additional Notes: Yes See Application Narrative

New/Modified PROD1 Process: Casting MSS




New/Modified PROD2 Process: Casting VOC See Additional Notes: Yes See Application Narrative

New/Modified PROD2 Process: Casting MSS




Plant TypeThis cell intentionally blank.

Version 4.0 Page 1


BACT



Action Requested FINs Unit Type Pollutant Current Tier I BACT Confirm Additional Notes

New/Modified FINISH1 Material Handling: Sanding PM The emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. See Additional Notes: Yes See Application Narrative

New/Modified FINISH1 Material Handling: Sanding MSSBest management practices (conducting system maintenance in a manner which minimizes emissions) employed during handling system maintenance. No bypassing of controls.


Version 4.0 Page 2


Monitoring



FIN Unit Type Pollutant Minimum Monitoring Requirements Confirm Additional Notes for MonitoringProposed Measurement Technique (only complete for pollutants with a project increase above the PSD threshold)

Additional Notes for Measuring:

SPRAYBOOTH Process: Casting VOC See Additional Notes: Yes See Application NarrativeSP1 Process: Casting VOC See Additional Notes: Yes See Application NarrativeSP2 Process: Casting VOC See Additional Notes: Yes See Application NarrativePROD1 Process: Casting VOC See Additional Notes: Yes See Application NarrativePROD2 Process: Casting VOC See Additional Notes: Yes See Application Narrative

FINISH1 Material Handling: Sanding PM

The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. Quarterly observations for visible fugitive emissions and/or opacity observations

Recordkeeping of materials processed


Version 4.0 Page 1


Materials



How submitted Date submitted

STEERSSTEERSNot applicable

STEERSSTEERSSTEERSSTEERS

STEERS

Not applicableNot applicable

STEERSSTEERS

STEERS

STEERSSTEERSSTEERSSTEERSNot applicable

STEERSEmail

Electronic Modeling Evaluation Workbook: NonSCREEN3

Coatings Workbook

C. Federal Applicability

E. Impacts Analysis

D. Technical Information

F. Additional Attachments

Material Balance (if applicable)Calculations

Netting analysis (if required) - Tables 3F and 4F as needed

MERA analysis

PSD modeling protocol

Electronic Modeling Evaluation Workbook: SCREEN3

Qualitative impacts analysis

General Narrative

State regulatory requirements discussion

Area map

BACT discussion, if additional details are attachedMonitoring information, if additional details are attached

List of MSS activities

Process descriptionProcess flow diagram

Summary and project emission increase determination - Tables 1F and 2F

Plot plan

Item

Core Data Form

Form PI-1 General ApplicationHard copy of the General sheet with original (ink) signature

B. General Information

A. Administrative Information

Professional Engineer Seal

Copy of current permit (both Special Conditions and MAERT)

Version 4.0 Page 1

Texas Commission on Environmental QualityElectronic Modeling Evaluation Workbook for SCREEN3

General Information

Date: _12/11/19_Permit #: _TBD_

Company Name: _Majek Boatworks, Inc._

Create Headers Before Printing: 1. Right-click one of the workbook’s sheet tabs and "Select All Sheets." 2. Enter the "Page Layout View" by using the navigation ribbon's View > Workbook Views > Page Layout, or by clicking the page layout icon in the lower-right corner of Excel. 3. Add the date, company name, and permit number (if known) to the upper-right header. Note that this may take up to a minute to update your spreadsheet. Select any tab to continue working on the spreadsheet.

Printing Tips: While APD does not need a hard copy of the full workbook, you may need to print it for sending to the regional offices, local programs, and for public access if notice is required.1. The default printing setup for each sheet in the workbook is set for the TCEQ preferred format. The print areas are set up to not include the instructions on each sheet.2. You have access to change all printing settings to fit your needs and printed font size. Some common options include: -Change what area you are printing (whole active sheet or a selection); -Change the orientation (portrait or landscape); -Change the margin size; and -Change the scaling (all columns on one sheet, full size, your own custom selection, etc.).

Workbook Instructions:1. Save a copy of the workbook to your computer or desktop prior to entering data. 2. Complete all required sections leaving no blanks. You may use the "tab" button or the arrow keys to move to the next available cell. Use "enter" to move down a line. Note: drop-downs are case-sensitive.3. Fill in the workbook in order, do not skip around as this will cause errors. Use caution if changing a previously entered entry.4. Not applicable sections of this workbook will be hidden as data is entered. For example, answering "No" to "Is downwash applicable? " will hide these sections of the workbook required only for downwash entry.5. Email the workbook electronic file (EMEW) and any attachments to the Air Permits Initial Review Team. The subject line should read "Company Name - Permit Number (if known) - NSR Permit Application". Email address:

Purpose Statement: This workbook is completed by the applicant and submitted to the Texas Commission on Environmental Quality (TCEQ), specifically, the Air Dispersion Modeling Team (ADMT) for review. This workbook is a tool available for all projects using SCREEN3 for an impacts review and its use is required starting June 1, 2019. Provide the workbook with the permit application submittal for any Minor New Source Review project requiring a modeling impacts demonstration.

This workbook follows the guidance outlined in the Air Quality Modeling Guidelines (APDG 6232, September 2018) which can be found here:

EMEW Version No.: Version 2.2

https://www.tceq.texas.gov/assets/public/permitting/air/Modeling/guidance/airquality-mod-guidelines6232.pdf

https://www.tceq.texas.gov/permitting/air/guidance/newsourcereview/nsrapp-tools.html

[email protected]. If printing the EMEW, follow the directions below to create a workbook header.7. Printing the EMEW is not required for submitting to the Air Permits Division (APD); however, you may need to print it for sending to the regional offices, local programs, and for public access if notice is required. To print the workbook, follow the instructions below. Please be aware, several sheets contain large amounts of data and caution should be taken if printing, such as the Speciated Emissions sheet.8. Updates may be necessary throughout the review process. Updated workbooks must be submitted in electronic format to APD. For submittal to regional offices, local programs, or public places you only have to print sheets that had updates. Be sure to change the headers accordingly.

Note: Since this will be part of the permit application, follow the instructions in the Form PI-1 General Application on where to send copies of your EMEW and permit application. The NSR Application Workbook can

Page 1

http://www.tceq.texas.gov/assets/public/permitting/air/Modeling/guidance/airquality-mod-guidelines6232.pdf
















General Information


Company Name: _Majek Boatworks, Inc._Select from the drop down:

I agree

Data Type:

Project Number (6 Digits):Permit Number:Regulated Entity ID (9 Digits):Facility Name:Facility Address:Facility County (select one):Company Name:Company Contact Name:Company Contact Number:Company Contact Email:Modeling Contact Name:Modeling Company Name, as applicable:Modeling Contact Number:Modeling Contact Email:New/Existing Site (select one):Modeling Date (MM/DD/YYYY):UTM Zone (select one):

Section: Select an X from the dropdown menu if included:

1 X2 X3 X45 X6789 X101112 X1314 X15 X16 X17 X18 X1920 X21 X22

I acknowledge that I am submitting an authorized TCEQ Electronic Modeling Evaluation Workbook and any necessary attachments. Except for inputting the requested data, I have not changed the TCEQ Electronic Modeling Evaluation Workbook in any way, including but not limited to changing formulas, formatting, content, or protections.

Acknowledgement:

ALL4 LLC

Unit Impact MultipliersHealth Effects Modeling Results

Volume Source Emissions

Modeling ScenariosMonitor CalculationsBackground Justification

NAAQS/State Property Line (SPL) Modeling Results

Speciated Chemicals

Secondary PM2.5 Analysis (MERPs calculations)


General

Flare Source ParametersPoint Source Parameters

14

Table of Contents

11/9/2019

Sheet Title (Click to jump to specific sheet):

Existing Site

Jimmy [email protected]

Intermittent Sources

Boat Plant7001 Saluki St.Nueces

Modeling File Names

Area Source Emissions

Volume Source CalculationsVolume Source Parameters

Speciated Emissions

Point and Flare Source Emissions

Area Source Parameters

Rebekah Bowlds

678-460-0324 x214 [email protected]

Building Downwash

Sheet Instructions: Indicate in the Table of Contents which sections are applicable and included for this modeling demonstration. Select "X" from the drop down if the item below is included in the workbook. Note: This workbook is only for SCREEN3 analyses. Please use the separate Electronic Modeling Evaluation Workbook (EMEW) for the following air dispersion models: AERSCREEN, ISC/ISCPrime, and/or AERMOD.

Model Options

TBD102595410

Facility Information:Administrative Information:

Page 2


General Information



Select an X from the dropdown menu if included:

XXXX

XX

Select an X from the dropdown menu if included:

Choose an item

X

Choose an item

Choose an item

Plot Plan:

Area Map:

Included AttachmentsInstructions: The following are attachments that must be included with any modeling analysis. If providing the plot plan and area map with the permit application, ensure there is also a copy with the EMEW. The copy can be electronic.

Instructions: Mark all that apply in the attached plot plan. For larger properties or dense source areas, provide multiple zoomed in plot plans that are legible.Property/Fence Lines all visible and marked.North arrow included.Clearly marked scale.All sources and buildings are clearly labeled.

Annotate schools within 3,000ft of source's nearest property line.

Non-industrial receptors are identified.

Instructions: Mark all that apply in the attached area map.

All property lines are included.

Other AttachmentsProvide a list in the box below of additional attachments being provided that are not listed above:

Additional Attachments (as applicable):Note: These are just a few examples of attachments that may need to be included. There may be others depending on the scope of the modeling analysis.

Provide documentation on modeling techniques indicated in the workbook.

Include documentation on any calculations used with the UIMs (i.e., Step 3 of the MERA).

Post Processing using Unit Impact Multipliers (UIMs)

Modeling Techniques

Include Agreement, Order, and map defining each petitioner.

Single Property Line Designation

Page 3


Model Options



Yes

X State Property LineX

I. Project InformationA. Project Overview: In the box below, give a brief Project Overview. To type or insert text in box, double click in the box below. Please limit your response to 2000 characters.

Majek Boat Works (Majek) is proposing to permit the operation of a fiberglass boat manufacturing facility in Corpus Christi, TX. The boat production process includes particulate matter (PM) and volatile organic compound (VOC) emissions from gel and resin coatings on the boat as well as polishing the final product.

A. Building Downwash

B. Type of Analyses: (Select "X" in all that apply)

Instructions: Fill in the information below based on your modeling setup. The selections chosen in this sheet will carry throughout the sheet and workbook. Based on selections below, only portions of the sheet and workbook will be available. Therefore, it is vital the sheet and workbook are filled out in order, do NOT skip around.

For larger text boxes, double click to type or insert text.

This line was intentionally left blank.II. Air Dispersion Modeling Preliminary Information

Is downwash applicable? (Select "Yes" or "No")

Minor NSR NAAQSHealth Effects

Page 1


Model Options



X PM10

X PM2.5

NO2

Identify which averaging periods are being evaluated for NO2.

Identify the 1-hr NO2 tier used for SCREEN3.Identify the annual NO2 tier used for SCREEN3.

H2S SO2

H2SO4

UrbanX Rural

Health Effects: Fill in the Speciated Emissions sheet with all applicable pollutants, CAS numbers, and ESLs. D. Dispersion Options: Select "X" in the box to select an option. Note: if selecting both options, be sure to explain the reasoning for this in the box below.

State Property Line: List all pollutants that require an modeling review. (Select "X" in all that apply)

C. Constituents Evaluating: (Select "X" in all that apply)NAAQS: List all pollutants that require an modeling review. (Select "X" in all that apply)

Provide justification on the dispersion option selected above in the following box:The rural option was used because more than 50% of the area equivalent to a three kilometer radius surrounding the facility is considered rural based on the 2011 National Land Cover Data.

SO2

CO

Pb

Page 2


Model Options



Full Meteorological Data

Flat

Describe the receptor grid being modeled in the following text box:

E. Meteorological Data:Select Meteorological Dataset Modeled:

For justification on terrain selection, fill in the box below:

H. Modeling Techniques: Briefly describe any modeling techniques used for the SCREEN3 analyses. Provide additional attachments, if needed, to support the analyses.

Surrounding terrain is relatively flat and does not exceed the release height within the 5,000 m study area.

Select the terrain option being modeled:

The automated receptor grid was used starting at 10 m ranging to 5,000 m.

G. Terrain:

F. Receptor Grid:

Page 3


Building Downwash



Modeled Building ID Length (m) Width (m) Maximum Height (m) Tank Justification Additional InformationBLD_1 21.57 45.92 5.49 N/ABLD_2 31.8 15 5.49 N/A

Facility:

Page 1


Point + Flare Emissions



EPN Model IDModeling Scenario Pollutant Averaging Time Standard Type Review Context

Intermittent Source?

Modeled Emission Rate [lb/hr] Basis of Emission Rate

Scalars or Factors Used? Scalar/Factor in Use

Downwash Structure

Considered

Distance to Ambient Air

(m)SPRAYBOOTH SB Normal Health Effects Pollutant 1-hr Health Effects Project-Wide No 1.00 Generic Modeling at 1 lb/hr No BLD_1 5.00

SP1 SP1 Normal Health Effects Pollutant 1-hr Health Effects Project-Wide No 1.00 Generic Modeling at 1 lb/hr No BLD_1 1.00PROD1 PROD1 Normal Health Effects Pollutant 1-hr Health Effects Project-Wide No 1.00 Generic Modeling at 1 lb/hr No BLD_2 20.00

SP2 SP2 Normal Health Effects Pollutant 1-hr Health Effects Project-Wide No 1.00 Generic Modeling at 1 lb/hr No BLD_2 15.00PROD2 PROD2 Normal Health Effects Pollutant 1-hr Health Effects Project-Wide No 1.00 Generic Modeling at 1 lb/hr No BLD_2 25.00

FINISH1 FINISH1 Normal PM10 24-hr NAAQS Minor Full NAAQS No 0.342 24-hr average rate based on 8 hours of operation per day Yes 0.4 conversion factor BLD_2 33.00

FINISH1 FINISH1 Normal PM2.5 24-hr NAAQS Minor Full NAAQS No 0.342 24-hr average rate based on 8 hours of operation per day Yes 0.4 conversion factor BLD_2 33.00

FINISH1 FINISH1 Normal PM2.5 Annual NAAQS Minor Full NAAQS No 0.230 Maximum allowable Yes 0.08 conversion factor BLD_2 33.00

Facility:

Page 1


Modeling Scenarios



Modeling Scenario

Normal

Scenario Description:

The entire site is operating at full load for 1,960 hours/year.

Page 1


Monitor Calculations



Pollutant:

AQS ID: Street Address and City: 5707 Up River Rd, Corpus Christi

Link to Data Source: County: Nueces

Select metric for short term averaging time below:

1st Year Concentration (µg/m3)

2nd Year Concentration (µg/m3)

3rd Year (most recent) Concentration (µg/m3)

Calculated Background Concentration (µg/m3)

24-hr 98 percentile 24.60000 21.00000 21.90000 23

Annual Average 6.90000 7.40000 6.70000 7.0

Pollutant:

AQS ID: Address: 5707 Up River Rd, Corpus Christi

Link to Data Source: County: Nueces

Select metric for short term averaging time below:

1st Year Concentration (µg/m3)

2nd Year Concentration (µg/m3)

3rd Year (most recent) Concentration (µg/m3)

Calculated Background Concentration (µg/m3)

H2H 24-hr Avg 45.00000 43.00000 79.00000 79

This line was intentionally left blank.

483550034

a&_program=dataprog.Annuals.sas&check=void&polnam

PM2.5

PM10

483550034

a&_program=dataprog.Annuals.sas&check=void&polnam



Page 1


Background Justification


Company Name: _Majek Boatworks, Inc._Pollutant:AQS ID:County:Distance to Project Site (km):

Category: 10 Kilometer PM2.5 Emissions Comparison Types of Nearby Sources County PM2.5 Emissions

ComparisonCounty Population

Comparison Land Use Comparison Regional Considerations

Project: 1,265.66 Petroleum Refining mixed industrial/residential coastal

Monitor: 1,265.66 Petroleum Refining mixed industrial/residential coastal

Data Source:

https://www.tceq.texas.gov/assets/public/implementation/air/ie/pseisums/2013thru2017statesum.xls

x

How are off-property sources accounted for?

Monitoring data set year(s)/Additional Justification:

Monitor Justification Data

Additional Information

The monitor was used in lieu of explicitly modeling off-property sources considering the quantity of emissions near the monitor compared to the quantity of emissions near the project site. No adjacent sites to the project site.

20.0

PM2.5

483550034Nueces

Page 1


Background Justification



Pollutant:AQS ID:County:Distance to Project Site (km):

Category: 10 Kilometer PM10 Emissions Comparison Types of Nearby Sources County PM10 Emissions

ComparisonCounty Population

Comparison Land Use Comparison Regional Considerations

Project: 1,571 Petroleum Refining mixed industrial/residential coastal

Monitor: 1,571 Petroleum Refining mixed industrial/residential coastal

Data Source:

https://www.tceq.texas.gov/assets/public/implementation/air/ie/pseisums/2013thru2017statesum.xls

x

How are off-property sources accounted for?

Monitoring data set year(s)/Additional Justification:

20.0

PM10

483550034Nueces

Monitor Justification Data

Additional Information

The monitor was used in lieu of explicitly modeling off-property sources considering the quantity of emissions near the monitor compared to the quantity of emissions near the project site. No adjacent sites to the project site.


Page 2


Secondary Formation of PM2.5


Company Name: Majek Boatworks, Inc.Facility:

Project Increases (tpy) Source Selection Emission Rate (tpy) Height (m) 24-hr Annual 24-hr PM2.5 Annual PM2.5

Nitrogen Oxide (NOx) 0Sulfur Dioxide (SO2) 0

0.00000 0.00000

Modeled Emission Rates for Precursors (MERPs) Demonstration Tool for Calculating Secondary PM2.5 Impacts

Precursor

Selection of Variables MERP Value Total Secondary Value (µg/m3)

Page 1


Secondary Formation of PM2.5


Company Name: Majek Boatworks, Inc.

C. If a site specific MERP value is selected, provide justification for the selected height variable(s) here. Please limit your response to 2000 characters.

MERPs Demonstration JustificationA. Provide justification for selection of worst-case MERP and/or site-specific source here. Please limit your response to 2000 characters.

No NOX or SO2 emissions.

B. If a site-specific source is selected, provide justification for the selected emission rate variable(s) here. Please limit your response to 2000 characters.

Page 2


NAAQS-SPL Modeling Results



Pollutant Averaging Time GLCmax (µg/m3) De Minimis (µg/m3)

SO2 1-hr 7.8*SO2 3-hr 25SO2 24-hr 5SO2 Annual 1PM10 24-hr 7.01200 5NO2 1-hr 7.5**NO2 Annual 1CO 1-hr 2000CO 8-hr 500

Table 3. Modeling Results for Minor NSR De Minimis

Additional information for the De Minimis values listed above can be found at:* www.tceq.texas.gov/assets/public/permitting/air/memos/appwso2.pdf** www.tceq.texas.gov/assets/public/permitting/air/memos/guidance_1hr_no2naaqs.pdf

Page 1

https://www.tceq.texas.gov/assets/public/permitting/air/memos/appwso2.pdf



https://www.tceq.texas.gov/assets/public/permitting/air/memos/guidance_1hr_no2naaqs.pdf











Pollutant Averaging Time GLCmax (µg/m3)Secondary PM2.5

Contribution (µg/m3)Total Conc. = Secondary PM2.5 + GLCmax

(µg/m3)De Minimis (µg/m3)

PM2.5 24-hr 7.01200 0 7.01200 1.2*PM2.5 Annual 0.94080 0 0.94080 0.2*

Pollutant Averaging Time GLCmax (µg/m3) Background (µg/m3)Total Conc. = [Background + GLCmax]

(µg/m3) Standard (µg/m3)

SO2 1-hr 0 0 196SO2 3-hr 0 0 1300SO2 24-hr 0 0 365SO2 Annual 0 0 80PM10 24-hr 7.01200 79.00 86.01200 150Pb 3-mo 0 0 0.15

NO2 1-hr 0 0 188NO2 Annual 0 0 100CO 1-hr 0 0 40000CO 8-hr 0 0 10000

Table 5. Total Concentrations for Minor NSR NAAQS (Concentrations > De Minimis)

Additional information for the De Minimis values listed above can be found at:* www.tceq.texas.gov/permitting/air/modeling/epa-mod-guidance.html

Table 4. PM2.5 Modeling Results for Minor NSR De Minimis

Page 2

http://www.tceq.texas.gov/permitting/air/modeling/epa-mod-guidance.html











Pollutant Averaging Time GLCmax (µg/m3)Secondary PM2.5

Contribution (µg/m3)Background (µg/m3)

Total Conc. = [Background + Secondary + GLCmax]

(µg/m3)Standard (µg/m3)

PM2.5 24-hr 7.01200 0 23 30.01200 35PM2.5 Annual 0.94080 0 7 7.94080 12

Table 6. Total Concentrations for Minor NSR NAAQS (Concentrations > De Minimis)

Page 3


Health Effect Modeling Results



Step 3 Step 4: Production Step 4: MSS Step 5: MSS Only Step 6 Step 7: Site Wide

Chemical Species CAS Number Averaging Time ESL [µg/m3]

10% ESL Step 3 Modeled GLCmax

[µg/m3]

25 % ESL Step 4 Production GLCmax since most recent site wide

modeling [µg/m3]

10% ESL Step 4 Production

Project Only GLCmax [µg/m3]

50% ESLStep 4 MSS GLCmax since most recent site wide modeling [µg/m3]

25% ESL Step 4 MSS Project Only

GLCmax [µg/m3]

Full ESL Step 5 GLCmax

[µg/m3] Was Step 6 relied on to fall out of

the MERA?Site Wide GLCmax

[µg/m3]Site Wide GLCni

[µg/m3]methyl methacrylate 1-hr Refer to Table A-1silica, amorphous (synthetic amorphous) 1-hr Refer to Table A-1

talc (no asbestos) 1-hr Refer to Table A-1titanium(IV) dioxide 1-hr Refer to Table A-1styrene 100-42-5 1-hr 110 Refer to Table A-1 Refer to Table A-1 Refer to Table A-1 N/A N/A N/A No (Proceed with Step 7) 107.59 107.59hydrogen peroxide 1-hr Refer to Table A-1methyl ethyl ketone 1-hr Refer to Table A-1methyl ethyl ketone peroxide 1-hr Refer to Table A-1sodium metaborate 1-hr Refer to Table A-1alpha-methylstyrene 1-hr Refer to Table A-1methyl methacrylate Annual Refer to Table A-1silica, amorphous (synthetic amorphous) Annual Refer to Table A-1talc (no asbestos) Annual Refer to Table A-1titanium(IV) dioxide Annual Refer to Table A-1styrene 100-42-5 Annual 140 Refer to Table A-1 Refer to Table A-1 Refer to Table A-1 N/A N/A N/A No (Proceed with Step 7) 8.61 8.61hydrogen peroxide Annual Refer to Table A-1methyl ethyl ketone Annual Refer to Table A-1methyl ethyl ketone peroxide Annual Refer to Table A-1sodium metaborate Annual Refer to Table A-1alpha-methylstyrene Annual Refer to Table A-1

Modeled Health Effect Results (MERA Guidance):Facility:

Page 1


Modeling File Names



Model File Base Name Pollutant Averaging Time File Extensions Additional File DescriptionSB generic 1-hr *.out project wideSP1 generic 1-hr *.out project wide

PROD1 generic 1-hr *.out project wideSP2 generic 1-hr *.out project wide

PROD2 generic 1-hr *.out project wideFINISH1 generic 24-hr *.out project wide

FINISH1_ann generic annual *.out project wide

Facility:

Page 1

(lb/hr) (tpy)Short-Term

(g/m3)Long-Term

(g/m3)Long-Term ESL ≥

10% Short-Term ESL?

Short-Term De Minimis Level

(lb/hr) (a)

Long-Term ESL > 10% of Short-Term ESL & Short-Term ESL ≤ De Minimis

Level?

Short-Term GLCmax

(g/m3) (b)(e)

Long-Term GLCmax

(g/m3) (b)(c)(e)GLCmax ≤ 10%

ESL?Short-Term GLCmax/ESL

Long-Term GLCmax/ESL

GLCmax/ESL < ERP/ERS? (d)

methyl methacrylate 80-62-6 0.54 0.54 860 210 Yes 0.1 No 542.70 54.27 No 0.631 0.258 Yessilica, amorphous (synthetic

amorphous) 7631-86-9 5.53E-03 7.19E-03 27 2 No 0.04 No 5.55 0.56 No 0.206 0.278 Yes

talc (no asbestos) 14807-96-6 1.11E-02 1.44E-02 20 2 Yes 0.04 Yestitanium(IV) dioxide 13463-67-7 3.32E-02 4.31E-02 50 5 Yes 0.04 Yes 33.32 3.33 No 0.666 0.666 Yes

styrene 100-42-5 10.67 8.89 110 140 Yes 0.04 No 10725.22 1072.52 No 97.502 7.661 Nohydrogen peroxide 7722-84-1 2.93E-02 2.87E-02 14 1.4 Yes 0.04 Yesmethyl ethyl ketone 78-93-3 7.50E-02 7.35E-02 18000 2600 Yes 0.4 Yes

methyl ethyl ketone peroxide 1338-23-4 2.93E-02 2.87E-02 15 1.5 Yes 0.04 Yessodium metaborate 7775-19-1 3.88E-02 3.96E-02 20 2 Yes 0.04 Yesalpha-methylstyrene 98-83-9 4.25E-02 4.17E-02 250 48 Yes 0.04 No 42.74 4.27 No 0.171 0.089 Yes

(a) MERA Step 2 De minimis levels:Production emissions increase de minimis ≤ 0.04 lb/hr if 2 g/m3 ≤ ESL < 500 g/m3.Production emissions increase de minimis ≤ 0.1 lb/hr if 500 g/m3 ≤ ESL < 3,500 g/m3.Production emissions increase de minimis ≤ 0.4 lb/hr if 3,500 g/m3 ≤ ESL.(b) Maximum ground level concentration (GLCmax) calculated assuming 1,185 (g/m3)/(1 lb/hr) as summarized in MERA APDG 5874 based on 35 ft stack height 3 ft from the property line, and the stack is impacted by building downwash.(c) U.S. EPA's AERSCREEN User's Guide annual ratio of 0.1 used to scale short-term (1-hour) predicted impacts to long-term (annual) predicted impacts.(d) The project increase emissions (ERP) divided by the proposed site wide emisions (ERS) is eqivalent to 1 since this is the first project at the site.(f) Per Appendix C of the March 2018 MERA guidance, linear interpolation between height and distance parameters was utilized to determine a more accurate unit impact multiplier.

Emissions Rate MERA Step 6

Pollutant CAS Number

Effects Screening Level (ESL)

MERA Step 2 MERA Step 3

Majek Boatworks, Inc. - Corpus Christi, TX

Table A-1Modeling and Effects Review Applicability (MERA) Flowchart

Majek Boat Minor NSR Permit Application December 2019

3057

000N

3058

000N

3059

000N

3060

000N

3061

000N

3062

000N

658000E 659000E 660000E 661000E 662000E 663000E

Majek Boatworks, Inc. Corpus Christi, TX

Figure 1 Area Map

Coordinate Datum: UTM NAD 83 Zone 14

3,000 ft radius from facility

Facility Boundary

Facility Location

Base Map: USGS Topo

Structure Location (Refer to EMEW for Building Dimensions) Majek Boatworks, Inc.Corpus Christi, TX

Figure A-2Plot Plan

Feet

0 100 200

Sources:SB (660,532 m E, 3,059,304 m N) FINISH1 (660,585 m E, 3,059,312 m N)SP1 (660,543 m E, 3,059,286 m N) SP2 (660,558 m E, 3,059,287 m N)PROD1 (660,562 m E, 3,059,295 m N) PROD2 (660,586 m E, 3,059,295 m N)

BLD_1BLD_3


660,438 m E 660,777 m E

3,05

9,25

0 m

N3,

059,

369

m N

FINISH1BLD_5

SP1

BLD_2

BLD_4SBPROD2

PROD2SP2







mailto:jimmy@majek

3057

000N

3058

000N

3059

000N

3060

000N

3061

000N

3062

000N

658000E 659000E 660000E 661000E 662000E 663000E

Majek Boatworks, Inc. Corpus Christi, TX

Figure 1 Area Map


3,000 ft radius from facility

Facility Boundary

Facility Location

Base Map: USGS Topo

Structure Location (Refer to EMEW for Building Dimensions) Majek Boatworks Inc. Corpus Christi, TX

Figure A-2Plot Plan

Feet

0 100 200

Sources:SB (660,532 m E, 3,059,304 m N) FINISH1 (660,585 m E, 3,059,312 m N)SP1 (660,543 m E, 3,059,286 m N) SP2 (660,558 m E, 3,059,287 m N)PROD1 (660,562 m E, 3,059,295 m N) PROD2 (660,586 m E, 3,059,295 m N)

BLD_1BLD_3


660,438 m E 660,777 m E

3,05

9,25

0 m

N3,

059,

369

m N

FINISH1BLD_5

SP1

BLD_2

BLD_4SBPROD2

PROD2SP2

Figure 3Process Flow DiagramMajek Boatworks, Inc.

Spray Booth

Raw Materials

VOC Emissions

Majek Boatworks, Inc. March 20203

Production Areas

VOC Emissions

Finishing Area

PM Emissions

Finished Product

Small Parts

VOC Emissions

Dust Collector







mailto:jimmy@majek




REGULATORY APPLICABILITY ANALYSES

Majek reviewed Federal and state of Texas air quality regulations to determine potentially

applicable regulations for the Facility. The regulations that potentially apply to the Facility

operations are described in the following subsections.

Standards of Performance for New Stationary Sources

The United States Environmental Protection Agency (U.S. EPA) has promulgated standards of

performance for specific new, reconstructed, and modified sources, otherwise known as

Standards of Performance for New Stationary Sources (NSPS), which are codified at 40 CFR

Part 60. Because the Facility will not be subject to any NSPS, it is not required to comply with

the applicable requirements of 40 CFR Part 60.

National Emission Standards for Hazardous Air Pollutants

The National Emission Standards for Hazardous Air Pollutants (NESHAP) originally required by

the 1970 Clean Air Act (CAA), codified at 40 CFR Part 61, apply to specific compounds emitted

from specific source categories. The Facility does not fall under any of the source categories

regulated by 40 CFR Part 61; therefore, 40 CFR Part 61 requirements are not applicable to the

Facility.

The provisions of 40 CFR Part 63 implement Maximum Achievable Control Technology

(MACT) standards which apply to specific source categories that are considered either major or

area sources of hazardous air pollutants (HAP). A major source of HAP is defined as a

stationary source that has the potential to emit (PTE) 10 tons per year (tpy) or more of any single

HAP, or 25 tpy or more of any combination of HAP. HAP emissions from the Facility are

limited by enforceable permit conditions that restrict HAP emissions to less than 10 tpy for any

individual HAP and less than 25 tpy for combined HAP. Therefore, the Facility is a synthetic

minor area source and not a major source of HAP.




40 CFR Part 63, Subpart II - National Emission Standards for Shipbuilding and Ship Repair The requirements of 40 CFR Part 63, Subpart II, National Emission Standards for Shipbuilding

and Ship Repair (Surface Coating), apply to shipbuilding and ship repair operations at any

facility that is a major source. 40 CFR §63.782 states that pleasure crafts, or boats used for

personal, family, or sportsman recreation, are not considered ships for the purposes of the

subpart. Therefore, 40 CFR 63, Subpart II requirements do not apply to operations at the

Facility.

40 CFR Part 63, Subpart VVVV - National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing The requirements of 40 CFR Part 63, Subpart VVVV, National Emission Standards for

Hazardous Air Pollutants for Boat Manufacturing, apply to sources that are boat manufacturing

facilities that build fiberglass or aluminum recreational boats that are a major source of HAP.

The Facility originally operated under the provisions of Permit by Rule (PBR) 30 TAC 106.392 -

Fiberglass Reinforced Plastics and Cultured Marble Facilities. The Facility met the general

requirements for PBRs specified at 30 TAC 106.4 and the provisions specific to 30 TAC 106.392

as related to the manufacture of fiberglass boats. In 2008, the Facility applied for and was

granted a Minor NSR Permit No. 85144 that included synthetic minor limits restricting HAP

emissions to less than 10 tpy of individual HAP and less than 25 tpy of combined HAP. Because

the Facility operated as a synthetic minor source of HAP prior to obtaining an NSR permit in

2008 and accepted enforceable limits in the NSR permit to remain an area source of HAP, the

Facility operated with the understanding 40 CFR Part 63 Subpart VVVV did not apply.

Majek wishes to remain an area source of HAP emissions and proposes again to accept

enforceable limitations in accordance with TCEQ-(APDG 6472v1, revised 11/18) Guidance for

Rescission of the Environmental Protection Agency’s “Once In, Always In (OIAI)” Policy for

MACT Standards. Majek is proposing federally enforceable limits to restrict resin and gel coat

usage as well as rolling 12-month limits on HAP emissions. More information regarding these

limits and the resulting PTE is provided in the emissions summary in Table 1 uploaded to

STEERS.




State of Texas Air Quality Regulations

Potentially applicable state of Texas regulations as codified in 30 TAC – Environmental Quality

are summarized below and discussed in the following subsections.

• 30 TAC Chapter 101 – General Air Quality Rules

• 30 TAC Chapter 111 – Control of Air Pollution from Visible Emissions and Particulate Matter

• 30 TAC Chapter 113 – Standards of Performance for Hazardous Air Pollutants and for Designated Facilities and Pollutants

• 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds

• 30 TAC Chapter 116 – Control of Air Pollution by Permits for New Construction or Modification

• 30 TAC Chapter 118 – Control of Air Pollution Episodes

• 30 TAC Chapter 122 – Federal Operating Permits Program

30 TAC Chapter 101 – General Air Quality Rules

30 TAC Chapter 101 specifies the general air quality rules for the State of Texas. The Facility

will demonstrate compliance with the requirements of 30 TAC §101 as applicable.

30 TAC Chapter 111 – Control of Air Pollution from Visible Emissions and Particulate Matter

Standards for visible emissions and PM are addressed in 30 TAC Chapter 111. Specifically, 30

TAC §111.111(a)(1)(B) prohibits visible emissions in excess of 20% averaged over a six-minute

period for any source. The dust collector controlling emissions from finishing operations will be

maintained and operated in accordance with manufacturer recommendations to demonstrate

compliance with this visible emissions requirement.

Allowable emissions limits for nonagricultural processes are addressed in 30 TAC §111.151.

Specifically, 30 TAC §111.151(a) prohibits PM from any source to exceed the allowable rates




specified in Table 1 of the rule. The dust collector will be maintained and operated in

accordance with the manufacturer recommendations. Thus, the source will demonstrate

compliance with the total suspended particulate (TSP) emissions requirements, as applicable.

30 TAC Chapter 113 – Standards of Performance for Hazardous Air Pollutants and for Designated Facilities and Pollutants

The provisions of 30 TAC Chapter 113, Subchapter C incorporate multiple Federal NESHAP by

reference. The Boat Manufacturing standards as specified in 40 CFR Part 63, Subpart VVVV

are incorporated by reference in 30 TAC §113.1050. As stated above, Majek proposes to accept

federally enforceable limits to restrict HAP emissions in accordance with TCEQ-(APDG

6472v1, revised 11/18) Guidance for Rescission of the Environmental Protection Agency’s

“OIAI” Policy for MACT Standards and therefore is not subject to Subpart VVVV.

30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds

The provisions of 30 TAC Chapter 115 apply to specific VOC emitting processes. The Facility

does not use marine coatings as defined in TAC §115.420(c)(11). There are no other surface

coating regulations as specified at 30 TAC §115.420(a) that apply to the Facility.

30 TAC Chapter 116 – Control of Air Pollution by Permits for New Construction or Modification

Pursuant to the provisions of 30 TAC Chapter 116, Majek is submitting this NSR Permit

Application to TCEQ. The provisions of 30 TAC §116.111(a)(2)(C) require applicants to

provide a BACT analysis for applicable new and modified facilities. The procedures for

conducting a BACT analysis are not explicitly defined in Texas regulations. In general, a Texas

BACT analysis follows a Three-Tiered Approach, which is comparable to the Federal Top Down

BACT requirements. Specifically, BACT is defined in 30 TAC §116.10 as:

“An air pollution control method for a new or modified facility that through experience and research, has proven to be operational, obtainable, and capable of reducing or eliminating emissions from the facility, and is considered technically practical and economically reasonable for the facility. The emissions




reduction can be achieved through technology such as the use of add-on control equipment or by enforceable changes in production processes, systems, methods, or work practice.”

Details regarding the required BACT analyses are provided in the BACT determinations

uploaded to STEERS. Majek initiated the BACT analysis for the gel coat and resin application

and grinding operation using the “Top Down” approach as described in TCEQ’s Air Permit

Reviewer Reference Guide for Air Pollution Control. This was chosen instead of the TCEQ

Three-Tiered Approach because there was not a Tier I BACT identified for the boat

manufacturing process. Additionally, the Top Down methodology provides a more conservative

approach to emissions control technologies.

30 TAC Chapter 118 – Control of Air Pollution Episodes

The provisions of 30 TAC Chapter 118 regulate control measures required when immediate

action is needed to control air pollution episodes. 30 TAC Chapter 118 is generally applicable to

the Facility, and Majek will comply with the requirements, whenever a pollution episode exists.

30 TAC Chapter 122 – Federal Operating Permits Program

The provisions of 30 TAC Chapter 122 specify the regulations applicable to the Federal

Operating Permit Program. Majek is not considered a major source of HAP as defined by 30

TAC 122.110(13)(A) because it emits less than 10 tpy of a single HAP and 25 tpy total HAP.

Additionally, the PTE of the regulated NSR pollutants is less than the major source threshold of

100 tpy. Therefore, the Federal Operating Permit Program requirements are not applicable.







mailto:jimmy@majek



Page 1 Majek Boatworks, Inc. March 2020

BEST AVAILABLE CONTROL TECHNOLOGY DETERMINATIONS

BACT determinations are case-by-case analyses that involve an assessment of the applicable

control technologies capable of reducing emissions of a pollutant and are conducted using either

the Texas Commission on Environmental Quality (TCEQ) Three Tier or the Top Down

approach. Both are accepted for evaluating BACT. Majek has chosen the Top Down approach

as a Tier I BACT has not been established for this industry and few facilities have employed the

control technology that Majek has conservatively put in place.

A Top Down approach considers technical feasibility, as well as economic, environmental, and

energy impacts. The Top Down BACT analysis conducted for the Facility included the

following five basic steps:

• Step 1: Identify Available Control Technologies

• Step 2: Eliminate Technically Infeasible Options

• Step 3: Rank Remaining Control Technologies by Control Effectiveness

• Step 4: Evaluate Economic, Environmental, and Energy Impacts of Technically Feasible Control Technologies

• Step 5: Identify BACT

The five-step approach taken to perform Top Down BACT analyses conducted for the VOC and

PM emissions is described below.

Step 1 – Identify Available Control Technologies

In Step 1, “available” control options are identified. Available control options are those air

pollution control technologies or techniques (including lower-emitting processes and practices)

that have the potential for practical application to the emissions unit and pollutant under

evaluation, with a focus on technologies that are demonstrated to achieve the highest levels of

control for the pollutant in question, regardless of the source type in which the demonstration has

occurred.




Step 2 – Eliminate Technically Infeasible Options

In Step 2, available control techniques listed in Step 1 may be eliminated from further

consideration if not technically feasible for the specific source under review. A demonstration of

technical infeasibility must be documented and show, based on physical, chemical, or

engineering principles, that technical reasons would preclude the successful use of the control

option on the emissions unit under review. U.S. EPA generally considers a technology

technically feasible if it has been demonstrated and operated successfully on the same type of

emissions unit under review. An available technology from Step 1, however, cannot be

eliminated as technically infeasible simply because it has not been used on the same type of

source that is under review. If the technology has not been operated successfully on the type of

source under review, then questions regarding “availability” and “applicability” to the specific

source type under review should be considered prior to the elimination of the technology as

technically infeasible.

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

In Step 3, the remaining control technologies are listed in order of overall control effectiveness

for the pollutant under review. The most effective control alternative (i.e., the option that

achieves the greatest emissions reduction) should be listed as the top choice and the remaining

technologies listed in descending order of control effectiveness. The ranking of control options

in Step 3 determines where to start the “top-down” selection process in Step 4. In determining

and ranking technologies based on control effectiveness, facilities may include information on

control efficiency (e.g., percent pollutant removed), expected emissions rate (e.g., tpy, pounds

per hour [lb/hr], pounds per unit of product, pounds per unit of input, parts per million by volume

[ppmv], dry [ppmvd]), and expected emissions reduction (e.g., tpy). The metrics chosen for

ranking should best represent the array of control technology alternatives under consideration for

the pollutant included in the evaluation. If the top ranked control is selected prior to Step 4, then

Step 4 may not be necessary.




Step 4 – Evaluate Economic, Environmental and Energy Impacts of Technically Feasible Control Technologies

In Step 4, economic, environmental and energy impacts are evaluated for each remaining option

under consideration. Accordingly, after available and technically feasible control options have

been ranked in terms of control effectiveness (i.e., Step 3), facilities should consider specific

economic, environmental and energy impacts identified with those technologies to either confirm

that the “top” control alternative is appropriate or inappropriate. The “top” control option should

be established as BACT unless the applicant demonstrates that the economic, environmental, and

energy impacts are constraining such that the “top” control option is not “reasonable” in that

case. If the “top” control option is eliminated in this fashion, then the next most stringent

alternative is considered, and so on. Both direct and indirect impacts of the emissions control

option or strategy being evaluated should be considered.

Step 5 – Identify BACT

In Step 5, the most effective control option not eliminated in Step 4 should be selected as BACT

for the pollutant and emissions unit under review.

VOC Best Available Control Technology Analysis for the Gel Coat and Resin Application Operations

This section presents the VOC BACT discussion for the gel coat and resin operations. The gel

coat and resin are applied using high-volume low pressure (HVLP) spray guns. A small

percentage of resin is applied using manual application techniques as well. There is one

atomized gel coat spray gun and four non-atomized resin spray guns. The material is mixed with

catalyst at desired ratios within the application system onto the mold surface. The resin and gel

coat solutions include VOC constituents and therefore emit VOC during the application process.

Step 1 – Identify Available Control Technologies

To identify available control options for VOC emissions from fiberglass boat manufacturing,

Majek reviewed the following resources:




• U.S. EPA’s Reasonably Available Control Technology (RACT)/BACT/Lowest Achievable Emission Rate (LAER) Clearinghouse (RBLC) database

• TCEQ BACT Guidelines for Coating Sources

The following control technologies were identified for VOC reduction from the gel coating and

resin application:

• Low VOC Resin and Gel Coat • High Transfer Efficiency Spray Application Equipment • Collecting and Venting VOC to an Add-on Control Device (i.e., thermal oxidizer)

Low VOC resin and gel coat are raw materials that contain less styrene than traditional materials.

These will be discussed in more detail in Step 2.

Because HVLP spray guns are already in place at the Facility, the BACT evaluation will not

cover this control technology in the remaining steps.

There are several types of add-on control devices that can be used to abate VOC emissions from

industrial sources of evaporative VOC emissions. Add-on control devices for the control of

VOC emissions include oxidation, adsorption/recovery, condensation, and biofiltration. Of these

methods, thermal oxidation or a combination of concentration (via adsorption) followed by

desorption and oxidation are commonly utilized.

Thermal oxidation is the process of oxidizing combustible materials by raising the temperature

of the material above its auto-ignition point in the presence of oxygen and maintaining it at high

temperature for sufficient time to complete combustion to carbon dioxide (CO2) and water.

Time, temperature, turbulence (for mixing) and the availability of oxygen all affect the rate and

efficiency of the combustion process. These factors provide the basic design parameters for

VOC oxidation systems1. There are three main types of thermal oxidizers:

1. Straight-through oxidizers, or thermal afterburners, with no heat recovery. Typical VOC

destruction efficiency ranges from 98% to 99.99% (U.S. EPA Air Pollution Control

Technology Fact Sheet, EPA-452/F-03-022).




2. Regenerative oxidizers that use a medium to recover the heat and increase turbulence in

the unit. Typical VOC destruction efficiency ranges from 95% to 99% (U.S. EPA Air

Pollution Control Technology Fact Sheet, EPA-452/F-03-021).

3. Recuperative oxidizers that recover the heat by using a heat exchanger. Typical VOC

destruction efficiency ranges from 98% to 99.9999% (U.S. EPA Air Pollution Control

Technology Fact Sheet, EPA-452/F-03-020).

A thermal oxidizer supplements combustion air and fuel to the existing exhaust to allow for the

oxidation of VOC present in the exhaust stream within the combustion chamber. Thermal

oxidizers can be categorized as a thermal or catalytic design and can be even further categorized

based upon recovery of exhaust gas heat. Thermal oxidizers without heat recovery are used in

applications where the heating value of the exhaust streams routed to the oxidizer are high

enough so that additional amounts of supplemental fuel combustion or high levels of heat

recovery are not necessary to bring the exhaust gases to oxidation reaction temperatures. For this

category of thermal oxidizer, a VOC inlet concentration of greater than 1,500 ppmvd is required

in order to provide practical and efficient controls.

Thermal oxidizers with heat recovery are categorized as recuperative or regenerative depending

on the design of the incoming process gas to exhaust gas heat exchange system. Recuperative

thermal oxidation systems use a tube or plate heat exchanger to preheat the effluent stream prior

to oxidation in the combustion chamber and recover up to 70% of the heat present in the hot

exhaust to transfer it to the incoming process gas.2

Regenerative thermal oxidation (RTO) systems typically incorporate multiple ceramic heat

exchanger beds to produce heat recovery efficiencies as high as 99%. An RTO has a high level

of heat integration which is best suited for exhaust streams with high flow rates and low VOC

concentrations. RTOs have been used to efficiently control VOC emissions in exhaust streams

with VOC concentrations as low as 100 ppmvd.

1 Institute of Clean Air Companies (ICAC) website (http://www.icac.com/?VOC_Controls) 2 U.S. EPA, 2002. EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/452/B-02-001, January 2002. Available at: http://www.epa.gov/ttncatc1/dir1/c_allchs.pdf. Section 3 for VOC Control.




Low VOC resin and gel coat materials and a potential VOC control device will be further

discussed in Step 2.

Step 2 – Eliminate Technically Infeasible Options

Low VOC Resin and Gel Coat

The fiberglass boat manufacturing industry relies on gel coat and resin supplied by

manufacturers to produce the quality product their customers expect. Majek has tested various

low VOC resins and gel coats to find raw materials that meet manufacturing and quality

requirements while minimizing VOC emissions. Therefore, Majek considers lowering the VOC

concentration of the resin and gel coating materials a technically infeasible control option for

reducing VOC. As a result, low VOC gel coat and resin control technology is not evaluated

further herein.

Capture and Control VOC Emissions

There are numerous air pollution control methods to abate VOC emissions from industrial

processes including gel coat and resin application. Several available add-on techniques are

technically infeasible for this application including adsorption/recovery, condensation and

biofiltration. Adsorption/recovery systems are typically used when the compounds being

adsorbed are captured on sorbent, desorbed and recovered, and distilled for reuse. Condensation

is a feasible control option for low volume/high concentration VOC exhaust streams.

Biofiltration is a complex control option that relies on the capture of VOC species in an organic

matrix with the destruction of the VOC species by microorganisms. Based on the nature of the

VOC exhaust stream at Majek (e.g., intermittent, widely variable, low volume/high

concentration, VOC species not reused), adsorption/recovery, condensation, and biofiltration are

not technically feasible and are not discussed further.

Thermal oxidation is, in general, technically feasible for most industrial applications and is often

used with surface coating operations. There are several types of thermal oxidizers available

including “straight” thermal oxidizers (i.e., incinerators), recuperative thermal oxidizers,

regenerative thermal oxidizers, and catalytic oxidizers. The primary differences between thermal

oxidizers relate to their thermal efficiency. For high volume, low concentration sources such as




the gel coat and resin application operations, RTO or a concentrator/RTO combination are

typically the most effective option from a thermal efficiency and cost basis. VOC concentrators

(i.e., adsorption devices using zeolite or comparable materials) are often used for high volume,

low concentration VOC exhaust streams. VOC is captured by the adsorbent and then desorbed

using hot air. The concentrated VOC stream in the desorption gas is directed to a smaller RTO

(typically 10% of the total controlled exhaust) reflecting lower capital and operating (i.e., fuel)

costs. For the BACT analysis herein, Majek evaluated the economic feasibility of the RTO and

concentrator/RTO options as surrogates for all thermal oxidation options. While technically

feasible, recuperative, catalytic, and straight thermal oxidizers are not considered further.

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

For high volume, low concentration sources such as the gel coat and resin application operations,

an RTO or a concentrator/RTO combination are typically the most effective options from a

thermal efficiency and cost basis. As mentioned, for this analysis, Majek evaluated the

economic feasibility of the RTO and concentrator/RTO options as surrogates for all thermal

oxidation options. The technically feasible control options identified in Step 2 are ranked in

terms of control efficiency in Table 1.

Table 1 VOC Control Technology Ranking for the Resin and Gel Coating Application Process

Control Technology Option Control Efficiency Ranking

RTO 98% 1

Concentrator/RTO 95% 2

The table reveals that both the RTO and concentrator/RTO options have a high control efficiency

for VOC emissions.




Step 4 – Evaluate Economic, Environmental and Energy Impacts of Technically Feasible Control Technologies

Majek evaluated the cost of the remaining control options. The entire cost evaluation is provided

at the end of this section in Table 3 and Table 4. The U.S. EPA Air Pollution Control Cost

Manual was used to estimate the capital and annual operating costs of an RTO and

concentrator/RTO options. The summarized conclusions from those calculations are provided in

Table 2.

Table 2 VOC Control Technology Cost Analysis

Device Uncontrolled VOC

Emissions Capital

Cost Annualized

Cost Cost

Effectiveness a ton/yr $ $/year $/ton

Concentrator/RTO 9.55 $2,198,197 $328,992 $36,263 RTO 9.55 $1,418,457 $249,203 $26,627

a All cost information was calculated using assumptions from U.S. EPA’s Air Pollution Control Cost Manual

As shown in Table 2, both add-on control device options are not cost effective and are therefore

not considered BACT.

Table 3

Capital and Annualized Costs for Operation of 50,000 Standard Cubic Feet per Minute (scfm) Regenerative Thermal Oxidizer (RTO)

Majek Boatworks, Inc. - Corpus Christi

CAPITAL COSTS ANNUALIZED COSTSANNUAL

COST ITEM FACTOR COST ($) COST ITEM FACTOR UNIT COST COST ($)

Direct Capital Costs (a) Direct Annual Costs (a)

Purchased Equipment Costs Operating and Maintenance (c, d)

RTO (b) A $756,300 Operating labor 0.5 hr/shift $12.00 per hour $1,470

Instrumentation 0.10 A $75,630 Supervisory labor 15% of operating labor $221

Freight 0.05 A $37,815 Maintenance labor 0.5 hr/shift $12.00 per hour $1,470

Total Purchased Equipment Cost B $869,745 Maintenance materials 100% of maintenance labor $1,470

Direct Installation Costs Utilities

Foundations and supports 0.08 B $69,580 Electricity (e, f) 198 kW $0.080 per kWh $31,046

Handling and erection 0.14 B $121,764 Energy Costs (g, h) 2.16 MMBtu/hr $3.00 per MMBtu $12,695

Electrical 0.04 B $34,790

Piping 0.02 B $17,395 Total Direct Annual Costs $48,372

Insulation for ductwork 0.01 B $8,697

Painting 0.01 B $8,697 Indirect Annual Costs (a)

Direct Installation Cost $260,924 Overhead 60% of sum of operating, supervisor, $2,778.30

and maintenance labor and

Total Direct Capital Cost $1,130,669 maintenance materials

Administrative charges 2% of TCI $28,369

Indirect Capital Costs (a) Property taxes 1% of TCI $14,185

Engineering 0.10 B $86,975 Insurance 1% of TCI $14,185

Construction and field expenses - $62,650 Capital recovery 0.0996 CRF x TCI $141,315

Contractor fees 0.10 B $86,975 Expected lifetime of equipment: 15 years

Start-up - $16,400 at 6% interest

Performance test 0.01 B $8,697 Total Indirect Annual Costs $200,831

Contingencies 0.03 B $26,092

Total Indirect Cost $287,789 Total Annualized Costs $249,203

Cost Effectiveness ($/ton)

Control Efficiency(i): 98%

Total Capital Investment (TCI) $1,418,457 Uncontrolled Emissions Rate(j): 9.55 tons VOC/yr Annual Cost/Ton VOC Removed: $26,627

Potential Controlled Emissions: 9.36 tons VOC/yr

Page 9

Table 3

Capital and Annualized Costs for Operation of 50,000 Standard Cubic Feet per Minute (scfm) Regenerative Thermal Oxidizer (RTO)


(a) Direct and indirect capital and annual costs were estimated based on the U.S. EPA Office of Air Quality Planning and Standards (OAQPS) Control Cost Manual, Sixth Edition (January 2002), Section 1, Chapter 2 and Section 3.2, Chapter 2.

(b) Cost of 50,000 scfm RTO is an engineering estimate provided by ADWEST Technologies, Inc.

(c) Operating and maintenance costs assume the following:

Operating Schedule 1,960 hrs/yr

Number of Operators per Shift 1 operator/shift

Hours per Shift 8 hr/shift

(d) Wage information was assumed based on national average.

(e) Electrical requirement was calculated based on the fan energy usage provided by ADWEST Technologies, Inc.

Fan energy usage 198 kW

(f) Price of electricity (industrial) is based on information provided by ADWEST Technologies, Inc.

(g) Natural gas requirement was calculated based on the natural gas usage provided by ADWEST Technologies, Inc., and an assumed higher heating value as follows:

RTO/VOC concentrator natural gas usage 2.159 MMBtu/hr

Natural gas higher heating value 1,020 Btu/scf

(h) Energy costs provided by ADWEST Technologies, Inc.

(i) Post-control VOC emissions are based on ADWEST Technologies, Inc. documentation of overall system efficiency:

Total efficiency of RTO and VOC concentrator 98%

(j) Annual uncontrolled emissions are based on the maximum VOC emissions rate per building.

Page 10

Table 4

Capital and Annualized Costs for Operation of 50,000 scfm Concentrator/RTO


CAPITAL COSTS ANNUALIZED COSTSANNUAL

COST ITEM FACTOR COST ($) COST ITEM FACTOR UNIT COST COST ($)

Direct Capital Costs (a) Direct Annual Costs (a)

Purchased Equipment Costs Operating and Maintenance (c, d)

RTO with VOC Concentrator (b) A $1,179,400 Operating labor 0.5 hr/shift $12.00 per hour $1,470

Instrumentation 0.10 A $117,940 Supervisory labor 15% of operating labor $221

Freight 0.05 A $58,970 Maintenance labor 0.5 hr/shift $12.00 per hour $1,470

Total Purchased Equipment Cost B $1,356,310 Maintenance materials 100% of maintenance labor $1,470

Direct Installation Costs Utilities

Foundations and supports 0.08 B $108,505 Electricity (e, f) 69 kW $0.080 per kWh $10,819

Handling and erection 0.14 B $189,883 Energy Costs (g, h) 0.65 MMbtu/hr $3.00 per MMBtu $3,840

Electrical 0.04 B $54,252

Piping 0.02 B $27,126 Total Direct Annual Costs $19,289

Insulation for ductwork 0.01 B $13,563

Painting 0.01 B $13,563 Indirect Annual Costs (a)

Direct Installation Cost $406,893 Overhead 60% of sum of operating, supervisor, $2,778.30

and maintenance labor and

Total Direct Capital Cost $1,763,203 maintenance materials

Administrative charges 2% of TCI $43,964

Indirect Capital Costs (a) Property taxes 1% of TCI $21,982

Engineering 0.10 B $135,631 Insurance 1% of TCI $21,982

Construction and field expenses - $88,480 Capital recovery 0.0996 CRF x TCI $218,997

Contractor fees 0.10 B $135,631 Expected lifetime of equipment: 15 years

Start-up - $21,000 at 6% interest

Performance test 0.01 B $13,563 Total Indirect Annual Costs $309,703

Contingencies 0.03 B $40,689

Total Indirect Cost $434,994 Total Annualized Costs $328,992

Cost Effectiveness ($/ton)

Control Efficiency(i): 95%

Total Capital Investment (TCI) $2,198,197 Uncontrolled Emissions Rate(j): 9.55 tons VOC/yr Annual Cost/Ton VOC Removed: $36,263

Potential Controlled Emissions: 9.07 tons VOC/yr

Page 11

Table 4

Capital and Annualized Costs for Operation of 50,000 scfm Concentrator/RTO


(a) Direct and indirect capital and annual costs were estimated based on the U.S. EPA Office of Air Quality Planning and Standards (OAQPS) Control Cost Manual, Sixth Edition (January 2002), Section 1, Chapter 2 and Section 3.2, Chapter 2.

(b) Cost of 50,000 scfm RTO with 11.23 lb/hr VOC concentrator is an engineering estimate provided by ADWEST Technologies, Inc.

(c) Operating and maintenance costs assume the following:

Operating Schedule 1,960 hrs/yr

Number of Operators per Shift 1 operator/shift

Hours per Shift 8 hr/shift

(d) Wage information was assumed based on national average.

(e) Electrical requirement was calculated based on the fan energy usage provided by ADWEST Technologies, Inc.

Fan energy usage 69 kW

(f) Price of electricity (industrial) is based on information provided by ADWEST Technologies, Inc.

(g) Natural gas requirement was calculated based on the natural gas usage provided by ADWEST Technologies, Inc., and an assumed higher heating value as follows:

RTO/VOC concentrator natural gas usage 0.653 MMBtu/hr

Natural gas higher heating value 1,020 Btu/scf

(h) Energy costs provided by ADWEST Technologies, Inc.

(i) Post-control VOC emissions are based on ADWEST Technologies, Inc. documentation of overall system efficiency:

Total efficiency of RTO and VOC concentrator 95%

(j) Annual uncontrolled emissions are based on the maximum VOC emissions rate per building.

Page 12




Step 5 – Proposed BACT

Majek proposes that the current operating methods consisting of HVLP applicators, non-

atomizing resin application and good operating as BACT.

BACT for Finishing Operations

After the application of fiberglass, the boats are sent to the finishing operations section for

sanding and smoothing of the boats surface. This process produces PM consisting of plastic

resin dust.

Majek evaluated the finishing process and determined that the best control technology is a Fabric

Filter Dust Collector

Because PM emission from finishing are captured by local ventilation and controlled by a fabric

filter dust collector, the remaining steps were not considered. Majek proposes the dust collector

in connection with a good engineering practices (GEP) stack as BACT for the PM emissions

from finishing operations.







mailto:jimmy@majek




PROJECT EMISSIONS

Fiberglass boat manufacturing occurs in several steps in various parts of the Facility, each with at

least one dedicated vent and stack system. Because all resin and gel coat application is

performed consistently over an 8-hour day, the emissions were calculated on the basis of daily

raw material usage and completed in three different sections which were totaled: gel coat spray

booth, production areas and finishing operations. The following subsections describe the sources

and emissions from each of these areas in more detail. The summary of emissions is included in

Table 1.

Gel Coat Spray Booth

Gel coating is the first step in fiberglass boat manufacturing because it forms the outermost

layers of the boat which contain the pigment. The spray booth contains the gel coat spray gun

which is used to apply an atomized mixture of gel coat and catalyst to the mold. Additionally,

there is a small amount of styrene solution used when needed. All gel coating is performed in

one spray booth which has a dedicated ductwork and stack system.

The single, atomized spray gun operates intermittently throughout the 8-hour day. Because there

is only one gel coat spray gun, Majek calculated the potential emissions based on normal

operational practices. The short-term gel coat usage is determined using the maximum spray

setting for the spray gun of 72 lb/hr with no more than 20 minutes of spray time each hour.

Because spraying is performed only intermittently over the 8-hour day, this is a conservative

assumption.

Monthly usage of gel coat is documented by raw material shipment and return records. The

monthly usage record is used to calculate the usage on an annual basis. This assumption is

conservative because it implies that all received material is used in the spray gun, even though a

portion of the raw materials used is left to dry and discarded as waste. The hardening of material

would result in styrene emissions, but far less than if the materials were used in the spray gun.




Both hourly and annual raw material usages were converted to VOC and HAP emissions using

the emissions factors provided in the Table 2. As stated in the table, the American National

Standards Institute (ANSI) developed a reference guide for emission factors of fiberglass boat

manufacturing called “Unified Emission Factors for Open Molding Composites.” This document

provides styrene and methyl methacrylate emissions factors based on the styrene content of the

gel coat and the application method. The application method in this case is controlled spray

application.

The styrene content of the gel coat was calculated using the weighted average of styrene content

in received pigment gel coats. Each color of pigmented gel coat has a different styrene content

and can slightly vary by batch from the manufacturer. Majek produces the boats as custom

designs, which allows the color profile to change for each boat. Sampling data from each

shipment, which provides the styrene content, was used to calculate the weighted average of

styrene content of the gel coat as a whole. This value and explanation are described in Table 2.

Production Areas

All resin application is performed in two separate production areas ventilated and each with a

separate discharge stack: Small Parts 1 and 2 (SP-1 and SP-2) and Production Areas 1 and 2

(Prod1 and Prod2). The small parts area has one spray gun while the production area has four.

Both areas primarily use resin, putty, and catalyst. The resin is applied by spray gun with a

nozzle mixer to add in catalyst; however, the spray guns in the small parts and production areas

use non-atomized spray. Layers of resin and fiberglass mat are applied over cured gel coat to

build the boat. The putty is used for assembling parts and applied manually.

The emissions factors for the non-atomized spray guns are provided in Table 3, which were

obtained from the same source described in gel coating. Because there are two spray areas and

five spray guns, emissions were estimated using a different method than the gel coat. Majek’s

standard procedures cause the highest material usage day in any given week to be Monday.

Material use is based on production scheduling and Facility logistics associated with the boat

building process. Material use tapers during the work week to reflect the production status of the




builds in process. The resin application process is a combination of spraying, fiberglass

application, rolling out the material to remove air bubbles, and the occasional manual application

of resin. Spraying begins at 8:00 A.M and occurs intermittently until 5:00 P.M. in all five spray

guns with a one-hour lunch break. The short-term hourly emissions are calculated by dividing

the daily raw material usage for each process by the eight hours of operating time. Because the

work is naturally spread evenly across an entire day to accommodate drying and rolling, it is

reasonable to assume that the hourly emissions can be derived from the daily emissions.

The annual emissions are determined by summing up the monthly records of resin, catalyst and

putty usage and calculating VOC and HAP emissions based on the characteristics of the material

as stated on the safety data sheets. Majek believes the assumptions made in the PTE calculations

are conservative because they are based on raw material shipments. As with the gel coat, there is

a significant amount of material included in the PTE calculations that is not vented to the

atmosphere, which is why Majek believes this to be a conservative approach.

Finishing Areas

The final step in fiberglass boat manufacturing is the finishing area where the boats are sanded

until smooth. Dust generated during the finishing process is captured by local ventilation and

directed to a fabric filter dust collector for control before discharge to atmosphere. The system

specifications are found in STEERS and the emissions calculations are in Table 4. An outlet

volumetric flowrate of 12,000 scfm with an outlet PM concentration of 0.01 grains/standard

cubic feet (gr/scf) was assumed based on the minimum efficiency reporting value (MERV) rating

of 11 provided by the vendor. These values were used to determine the short term and annual

PM emissions.

Table 5 reports the acetone usage for equipment cleaning. Acetone is exempt pursuant to 30

TAC 106.433(4). Table 6 is the HAP summary. It does not provide new information but is used

to prove the Facility is an Area source of HAPs.

lb/hr tpyVOCa 11.33 9.55PM 1.03 1.01

Total HAP 11.21 9.43

Table 1

a VOC includes the styrene, styrene monomer, methyl ethyl ketone (MEK), and methyl methacrylate used in the gel coat, resin, and putty operations.

Summary of Emissions from FacilityMajek Boatworks, Inc. - Corpus Christi, TX

PollutantPotential Emissions

Majek Boatworks, Inc. NSR Permit Application 1 March 2020

lb/hrc tpyd

Styrene 39% 313.00 lb/ton gel coat 3.76 3.76Methyl Methacrylate 3% 45.00 lb/ton gel coat 0.54 0.54

Styrene 99% - - 4.08E-03 4.00E-03

Methyl Ethyl Ketone (MEK)f 5% - - 1.50E-02 1.47E-02Total VOC - - - 4.32 4.31

Parameter Value

Max Spray Rate (lb/hr) 24.0

Annual Gel Coat Consumption(tpy) 24.0

Styrene Solution Consumption (tpy) 0.004

Operating Hours(hrs/year) 1,960

Parameter ValueCatalyst Usage (tpy) 1.47

MEK in Catalyst (%w) 5%Operating Hours

(hrs/year) 1960

Gel Coat Application

Styrene Solution e

e In rare instances, a styrene solution is used in the gel coat area and is conservatively assumed to have 100% evaporation.f MEK emissions were calculated assuming 100% evaporation and the operational parameters below:

a Chemical content was obtained from vendor provided safety data sheet (SDS) or recent vendor testing. Both documents are attached to this application.

Operational Parameters

Catalyst Usage

c The max spray rate is 72 lb/hr for no more than 20 min in an hour. This was derived from spray gun settings and normal application timing. Majek assumed the max spray rate to be 24 lb/hr.

Table 2Gel Coat Spray Booth VOC and HAP Emissions



VOCEmissions

Factorb Units

Potential EmissionsVOC Content in Material (%)a

b Emission factors for styrene solutions used for gel coating with controlled spray were obtained from the American National Standards Institute (ANSI) document "Unified Emission Factors for Open Molding Composites" as recommended by AP-42 Ch. 4.4-6.

d The annual emissions were determined using the known maximum gel coat consumption.


lb/hrb tpyc

Styrene 33% 71.00 lb/ton resin d 6.16 4.40



Alpha Methyl Styrene 5% 12.6 lb/ton resin e,f 4.25E-02 4.17E-02

MEK 5% - - g 6.00E-02 5.88E-02Total VOC - - - 7.01 5.23

Parameter ValueDaily Spray Usage (gal/day) For

6 Boats 168

Max Spray Rate (lb/hr) 193

Max Manual Application Rate(lb/hr) 17

Annual Resin Consumption(tpy) 138

Putty Consumption (tpy) 6.6



MEK in Catalyst (%w) 5%Operating Hours

(hrs/year) 1960

Table 3Production Area VOC and HAP Emissions


c The annual emissions were detmined using maximum resin consumption.d Emissions factors for styrene solutions used for manual and mechanical atomized controlled spray resin application were obtained from the American National Standards Institute (ANSI) document "Unified Emission Factors for Open Molding Composites" as recommended by AP-42 Ch. 4.4-6.

Manual Putty Application f

a Chemical content is obtained from vendor provided SDS that are attached to this application.b The max spray rate is determined by the raw material usage on a daily basis. Because spraying is performed intermittantly across an 8 hour day, the total usage was divided among the hours to get a maximum of 193 lb/hr with 90% spray application and 10% manual application.


Mechanical Non-Atomized Controlled Spray Application of Resin

Manual Application of Resin

VOCVOC Content in

Material (%)a Emissions Factor Units Reference

Potential Emissions


f Manual putty application was assumed to be the same emissions factor as manual resin application as it is a similar material and process.

e The emissions factor for alpha methyl styrene solution used for manual resin application was obtained from the 40 CFR Part 63, Subpart WWWW, Table 1.

Catalyst Usage g

g MEK emissions were calculated assuming 100% evaporation and the operational parameters below:


lb/hr tpy

PMa 1.03 1.01Total 1.03 1.01

a PM emissions are equivalent to PM10 and PM2.5 emissions.

Parameter ValueDust Collector

Discharge Rate (cfm) 12,000

Outlet Grain Loading(gr/scf) 0.01



Table 4Finishing Area Emissions


Pollutant

Potential Emissions


lb/hr tpy

Acetone 8.67 8.50Total 8.67 8.50

Parameter ValueMax Annual Solvent

Usage (tpy) 8.5

Recovery Rate 50%Operating Hours

(hrs/year) 1,960


Table 5Cleaning Area Emissions


Solvent

Potential Usagea

a Acetone is used purely for equipment cleaning and therefore is considered an exempt solvent that is less than the limits described in 30 TAC 106.433(4). Acetone is not regulated as a VOC.


lb/hr tpy

Styrene 10.67 8.89Methyl Methacrylate 0.54 0.54

Total 11.21 9.43




Table 6HAP Emissions


HAPaPotential Emissions

a The HAP emissions calculations are a summary of previous tables and are supported by Tables 2 and 3.








mailto:jimmy@majek

HP Baghouse CollectorsModels HPW/HPT 64-320

Reliable, versatile and high performance design handlesintermediate-to-high air volumes at low operating pressure drops.

160HPW8 160HPT8

Powerflo™ Cleaning System allows asignificantly higher air-to-cloth ratio,resulting in smaller overall system size.

Dura-Life™ bag technology provides bettersurface loading and pulse cleaning resultingin two-to-three times longer filter bag lifewhen changing bags due to pressure drop.

Dura-Life bags offer 30% fewer emissionsthan standard polyester bags.

Bag service from the clean-air side ofcollector makes filter changeout moreconvenient, easier and faster.

High air inlet reduces updraft velocities byusing gravity to separate heavier particles,extending bag life and lowering bagreplacement and maintenance costs.

Lower operating costs achieved through alow pressure drop.

Space-saving design offers a flexiblelow profile.

Compact design makes collector easier toship and install, lowering freight andinstallation costs.

All-Welded ConstructionHeavy-duty ribbed panelhousing construction isfactory assembled for easyfield installation. Heavy-dutytubesheet is 1/4-in steel plateconstruction.

Positive Seal Boltsafe™ CagesProvide electrical grounding,easy bag changeout, reducedbag sway, and an airtight sealto the tubesheet. Cages willnot rise out of positiononce they are installed.

Standard Rectangular Outlet

Powerflo Cleaning SystemSuper-sonic nozzles’“converging/diverging”design provides anintermittent jet ofpowerful highvolume induced air for efficientbag cleaning.

Oval Bags Provide more radial bagmovement during thecleaning cycle, resulting inlonger bag life and lowerpressure drop.

Operational Explanation

HP Baghouse Collectors

Service Railing andKickplate (HPT only)Standard compliancewith OSHAregulations.

High Inlet Design

19 x 14-in StandardAccess Panel

Standard SingleOutlet HopperTerminates to an18-in square opening.Double outlet hoppersare optional.

Standard Leg Pack48-in clearancefeatures structuraldesign. Optional legpack with 78-inclearance is available.

Easy to install–built to last.

O-ring collar assurespositive seal betweenclean and dirty airplenum.


Dimensions & Specifications

BE

H

H

J J

C

D

A

CL

CL

F FB

E

C

D

(48” standardoptional 78” available)

G

(48” standardoptional 78” available)

Clean-AirOutlet

Dirty-AirInlet

Walk-OnPlenum

Dirty-AirInlet

Clean-AirOutlet

Walk-InHousing

Baghouse(top view)

A

Model*

Nominal AirflowRange(cfm)**

FilterArea(ft2)

Dimensions (inches) ShippingWeight

(lbs)A B C D E F G H J

64 HPW 6400 - 10,200 637 102.0 315.8 116.0 199.8 261.8 192.5 52.0 30 x 58 20 x 25 5538

80 HPW 8000 - 12,800 795 102.0 315.8 116.0 199.8 261.8 189.5 62.0 30 x 58 20 x 31 6259

96 HPW 9600 - 17,280 954 102.0 315.8 116.0 199.8 261.8 186.0 72.0 30 x 58 20 x 38 6712

128 HPW 12,800 - 20,500 1272 102.0 315.8 116.0 199.8 261.8 180.0 92.0 30 x 58 20 x 50 7837

160 HPW 16,000 - 25,600 1590 102.0 315.8 116.0 199.8 261.8 173.5 112.0 30 x 58 20 x 63 8714

192 HPW 19,200 - 30,700 1908 192.0 331.5 131.7 199.8 277.5 196.7 72.0 40 x 47 32 x 48 12,500

256 HPW 25,600 - 41,000 2544 192.0 331.5 131.7 199.8 277.5 188.7 92.0 40 x 63 32 x 64 14,000

320 HPW 32,000 - 51,200 3180 192.0 331.5 131.7 199.8 277.5 183.2 112.0 40 x 78 32 x 80 17,000

64 HPT 6400 - 10,200 637 102.0 280.2 116.0 123.4 224.5 192.5 52.0 39 x 15.5 20 x 25 4890

80 HPT 8000 - 12,800 795 102.0 280.2 116.0 123.4 224.5 189.5 62.0 49 x 15.5 20 x 31 5581

96 HPT 9600 - 17,280 954 102.0 280.2 116.0 123.4 224.5 186.0 72.0 59 x 15.5 20 x 38 6006

128 HPT 12,800 - 20,500 1272 102.0 280.2 116.0 123.4 224.5 180.0 92.0 79 x 15.5 20 x 50 7087

160 HPT 16,000 - 25,600 1590 102.0 280.2 116.0 123.4 224.5 173.5 112.0 99 x 15.5 20 x 63 8018

192 HPT 19,200 - 30,700 1908 192.0 255.5 131.7 123.4 240.1 196.7 72.0 59 x 15.5 (2) 32 x 48 10,300

256 HPT 25,600 - 41,000 2544 192.0 255.5 131.7 123.4 240.1 188.7 92.0 79 x 15.5 (2) 32 x 64 11,700

320 HPT 32,000 - 51,200 3180 192.0 255.5 131.7 123.4 240.1 183.2 112.0 99 x 15.5 (2) 32 x 80 14,500

* Model number indicates quantity of 8-ft. long filter bags.** Based on clean filters.

HPW (Walk-In)Walk-in plenum providesweather protection duringmaintenance.

HPT (Top-Access)Bag maintenance is not subjectto confined space rules. Modelis often used in hot climates.


Information in this documentis subject to change without notice.

© 1999 Donaldson Co., Inc.Printed in U.S.A. on recycled paper

Data Sheet HP (09/05)

Significantly improve the performance of your collector withgenuine Donaldson Torit replacement filters and parts.

Visit us at www.donaldsondynamic.comDonaldson Company, Inc.Industrial Air FiltrationP.O. Box 1299Minneapolis, MN 55440Tel 800-365-1331(USA)Tel 800-343-3639 (within Mexico)[email protected]

Standard Features & Equipment Options

* Magnehelic and Photohelic are registered trademarks of Dwyer Instruments, Inc.

Collector DesignHPW walk-in clean air plenum withtop bag removal HPT walk-on clean air plenum withtop bag removal

All-Welded Design - 12 Gauge Minimum

Heavy-Duty 1/4-in Plate Steel Tubesheet

Ladder, Cage & Service Platform (OSHA Compliant)

Single Hopper Outlet 18-in. Square

Hopper Access Panel

Rectangular Outlet

Stainless Steel Construction

High Temperature Construction

Volume Control Damper

Fan Silencers

Fan Packages

Bags & Cages

Dura-Life Twice the Life Polyester Felt Bags

Positive Boltsafe™ Hardware

Variety of Bag Media Options

Paint SystemBlue Exterior Finish Coating Meets 250-Hour SaltSpray Corrosion Protection Test

Hostile Environment Paint

Custom Colors

Optional

Standard

Optional

Standard

Hopper Design

60° Pyramid Hoppers

Double Outlet Hopper

Trough Hopper

Hopper Discharge

Slide Gate

Rotary Valves

Support Structure

48" Clearance Leg Pack

78" Clearance Leg Pack

Electrical Controls, Gauges and Enclosures

Magnehelic®* Gauge

NEMA 4 Solenoid Valves, 50/60 Hz

NEMA 4 Pulse Controls, 120 VAC, 50-60 Hz

Photohelic® Gauge

Electrical Control Panels

Safety Features

Explosion Vents

Sprinkler Taps

Warranty

10-Year Warranty

Non AtomizedRRRRResinesinesinesinesin

Comparisonfor

Conformance

Manual

Produced for MVP EquipmentONLY.

Results on Competitive Equipmentwill Vary

Non AtomizedRRRRResinesinesinesinesin

Comparisonfor

Conformance

Manual

Produced for MVP EquipmentONLY.

Results on Competitive Equipmentwill Vary

TABLE OF CONTENTS

History ................................................................................................................................................ 1

Impingement Fan Examples .............................................................................................................. 4

Proper Adjustment for Non-Atomized Resin....................................................................................... 5

Styrene Source Test Report for the Underground Storage Tank Operation ..................................... 11

Revalidation of Emission Rates from Non-Atomizing Spray Equipment .......................................... 37

The purpose of this manual is to provide a guide to recognizing the subtle, yet significant, differences in non-atomized resin vs. atomized resin.

HISTORY

Emission reduction

In recent years, the awareness among government organizations of the problems caused by styrene emissions both insideand outside the workshop has increased. The industry struggles through research to develop equipment that meets currentstandards and anticipates future regulations. Recent studies by the Clean Manufacturing Technology and Safe MaterialsInstitute (CMTI) at Purdue University and the U.S. based Composites Fabricators Association (CFA) prove that FIT® technology(consisting of a low pressure pumping system, modular gun, combined with a unique nozzle and mix chamber) can significantlyreduce styrene emissions.

Research has shown that styrene emissions can be increased by atomization created by high pressures at the gun andspray techniques previously thought acceptable. The use of flowcoat technology was found to significantly reduce styreneemissions for wet-out. When correctly used, flow coat technology, which does not atomize the resin, reduces VOC’s duringwetout because of the simple geometry of the resin flow.

A flow coat style nozzle provides continuous streams of catalyzed resin continuously flowing onto the open mold. Theseresin streams reach the mold intact without atomizing. A spray fan, unlike flowcoat, breaks into droplets and atomizesbefore reaching the mold surface. Most of the research on VOC’s for spray is based on droplet size, and as the diametersof the resin droplets decrease, the overall surface area of the resin increases, which increases emission. In fact, if the“spray” droplets get too small, they don’t even reach their target; they drift off as fumes into the atmosphere.

The FRP industry embraced the new FloCoat technology as a viable and cost effective means for reducing styrene emissions,however the individual linear streams proved to be challenging for filled resin systems. The difficulty of chopping glass intothe resin streams required the operator to increase pump pressures to such a high level that the streams broke into droplets,producing atomization and misting. This high velocity creates a spray fan similar to airless spray techniques, thereforereducing the benefits of flow coating.

While flow coating worked well with unfilled resin, it did not work with filled systems as the fillers in the resin would plug theholes associated with a FloCoat nozzle. At this time, governmental agencies were demanding a reduction in the emissionlevels of filled resins applications. To reduce emissions in these applications meant an entirely new and radical technologywould have to be developed. That technology was Fluid Impingement Technology (FIT®).

The FIT® System uses low-pressure impinging streams to break resin into large droplets after mixing.

The unique 2-hole FIT® tip design creates a sheet when the two streams intersect. The sheet carries forward and breaks upinto ligaments which then break up into large droplets.

Atomized Systems

Standard nozzles require excessive pressures to develop patterns. True low pressure fluid impingement produces patternsthat are 50% wider at a fraction of the pressure with less overspray.

Competitive nozzles use 3 streams instead of 2 resulting in a loss of impingement energy at impingement point.

Why FIT® ?

In a recent independent field test conducted by order of a state environmental agency in the United States, emission factorswith an average emission level of 4.1% were reported for an FRP manufacturer using the newly patented Fluid ImpingementTechnology (FIT

®).

The state required the manufacturer to conduct independent tests measuring styrene emissions for conformance to EPAstandards. The manufacturer produces large underground storage tanks using polyester resins that contain liquid styrenemonomer. The test was conducted on the production of four different underground storage tanks ranging from an 8’ - 10’diameter mold, utilizing four complete MVP SuperFIT

® units with 3:1 pumps.

This stack test, conducted over two days in April, 2001 with 10,000 pounds of resin used, determined the styrene emissionrates from four different UST molding stations. The calculations showed the quantity of styrene emitted per pound of styrenemonomer consumed, and the quantity of styrene emitted per pound of raw resin consumed. In the only documented fieldtested measurements available today, emission levels as low as 2.2% were measured.

- 1 -

FLUID PRESSURES

Pressure plays a key role in obtaining a proper non-atomized pattern.

Typical pumps use compressed air to generate spray pressure.

Resin pumps can be 11:1, 6:1 or 3:1 ratio pumps. This means for every 1 psi (pound per square inch) you would get 11, 15or 20 psi of pump pressure.

The pump then forces the resin through the hose to the spray gun. While traveling through the hose there is significant lossof pressure due to friction called Line Loss or Pressure Drop.

The average resin spray system loses about 2 psi per foot. The average spray system has 25 feet of hose which results ina 50 psi pressure drop (2 psi x 25 ft.) See Figure 1 for Non-Atomized pressure drops, and Figure 1a for Atomizedresults.

200 psiFilter/Accumulator25 psi loss

Hose - 50 psi loss

Back of Nozzle25 psi loss

Fittings, Portings, & Valves25 psi loss

Turbulent Mixer - 25 psi loss

TIP PRESSURE25 - 50 psi

Figure 1 -Non-Atomized

- 2 -

600 psiFilter/Accumulator25 psi loss

Hose - 50 psi loss

Back of Nozzle25 psi loss

Fittings, Portings, & Valves25 psi loss

Turbulent Mixer - 50 psi loss

TIP PRESSURE400 - 450 psi

Figure 1a -Atomized

FLUID PRESSURES (continued)

- 3 -

IMPINGEMENT FAN

FIT® impinge pattern on a 3:1 pump at 20 psi. Note “defined wave” pattern continues nearly to target with a minimum ofatomization.

- 4 -

PROPER ADJUSTMENTS FOR NON-ATOMIZED RESIN APPLICATION

Fluid Pumps

The most common type of resin pump is termed an “air over fluid pump”. An air driven piston drives a fluidpiston, which forces the material out to the spray gun at high pressure. The difference between the diameter ofthe air piston and the fluid piston is termed the pump ratio. Pump ratios usually range from about 11:1 up to33:1. By multiplying the air input pressure by the pump ratio the fluid pressure at the spray tip can be determined.

Example:

• Pump Ratio = 11:1(11 psi of fluid pressure for every 1 psi of air pressure)

• Pump air pressure set at 40 psi• Multiply: Pump Ratio x Pump Pressure Setting to determine the tip pressure• 11 psi x 40 psi = 440 psi fluid tip pressure

SPRAY GUN SET-UP & PRESSURE CALIBRATION(courtesy of ACMA “Controlled Spray Training” Program)

1. Flow Rate

Flow rate is the amount of material sprayed in a given period. The flow rate is primarily controlled by the size ofthe spray tip, pump pressure, resin viscosity and resin temperature. Flow rate considerations include:

• Large parts, requiring large amounts of resin, are usually sprayed with larger size tips. Smaller parts, or partswith more detailed shapes, may be easier to spray with lower flow rates using smaller orifice fluid tips.

• The viscosity (thickness) of resin will affect both the flow rate and fan pattern.

• The formulated viscosity is normally adjusted by the material manufacturer, but is affected by temperature.Cooler material will be thicker and will reduce the flow rate; where warmer resin is lower in viscosity and flowsat a higher rate.

2. Determining Proper Fluid Pressure

Determining the ideal pump pressure for a specific combination of material and equipment is an importantelement of controlled spraying. Because of the many variables in the materials delivery system there is not aspecific set pressure for a spray gun, nor can a specific pressure limitation be set. These variables require thateach spray unit, with a specific material, operated under specific conditions be adjusted to produce an idealspray pattern. There are a myriad of variables that affect the optimal pressure selling of any given applicationunit. These variables include:

Equipment design

- Fluid pump ratio (air input pressure to fluid pressure generated)- Fluid tip design and configuration- Design of filter and fluid lines- Number of fittings or elbows in fluid lines- Requirement for a surge chamber- Internal or external initiator mixing

- 5 -

Material

- Inherent resin rheology- Formulated viscosity- Use of filled systems

Operating Conditions

- Material temperature- Residual build-up in fluid lines- Condition of pump packings- State of filter particle accumulation- Required spray distance from mold- Geometry of mold (i.e., highly contoured or flat)- Size of mold- Accuracy and wear of pressure gauges and air pressure regulators

Equipment Set-up

- Fluid tip orifice size Length of fluid lines ID of fluid lines- Size of filter screen mesh- Height of fluid lines with overhead boom Adjustment of spray gun fluid needles Adjustment of spray gun trigger Required flow rate- Required fan pattern width

2.1 The Objective of Spraying at Low Pressure

The objective of this spray gun pressure calibration method is to determine the lowest pressure at which anyapplication unit will operate, while acknowledging that the pressure range may vary widely based on thecombination of complex variables. It is always an advantage to spray at the lowest possible pressure. Thelowest pressure will:• Reduce Styrene Emissions• Minimize overspray• Create better working conditions• Enhance catalyst mixing• Reduce material usage / cost• Reduce equipment wear• Reduce high pressure hazards• Reduce static charge build-up• Increase product quality

In all cases, with resin application equipment, minimum pressure provides maximum performance in terms of,transfer efficiency, emissions, and finished product quality.

3. Pressure Calibration Procedure

The spray gun pressure calibration procedure is a simple and straightforward approach to determining theproper fluid pressure for any combination of equipment, material, and conditions. This procedure is appropriatefor all atomized and non-atomized application equipment, including both internal and external initiator deliverysystems.

Step I - Verify that the resin is the correct temperature, and has been properly mixed according to themanufacturer’s recommendations.

Step 2 - Verify that the fluid tip is in good condition (without excess wear and capable of producing an acceptablespray pattern); and the orifice size is within a suitable in flow rate range and fan pattern width for the given job.

- 6 -

Step 3 - Reduce the pump air input pressure down the level where the pump will no longer stroke.

Step 4 - If the unit uses external assist air, set the air assist pressure in the middle of the normal range andaccording to the manufacturers’ recommendations.

Step 5 - Aim the spray gun at a disposable surface covering on the floor, maintaining a distance of 12" to 18"and perpendicular to the floor.

Step 6 - Increase the pump pressure to the point where the pump just begins to stroke. Quickly pull and releasethe trigger to provide a “snapshot” spray pattern.

Step 7 - Record the results on the Spray Gun Calibration Worksheet.

Step 8 - Repeat the procedure, increasing pump pressure in 5 psi increments until the spray pattern is fullydeveloped.

Step 9 - If using air-assist equipment, once a fully-developed spray pattern is attained, fine-tune the air assistpressure for final shaping of the fan pattern. Use the lowest air-assist pressure that produces a symmetricalspray pattern.

Step 10 - Do not increase the pressure past this point. Any increase in pump pressure past the point of creatinga fully-developed spray pattern will result in an over-developed spray pattern.

Step 11 - Record this pressure the final pump pressure and air-assist pressure on the spray gun calibrationworksheet.

4. Determining the Proper Spray Pattern

The size and shape of a fan pattern results from a unique combination of orifice size, fluid tip geometry, andresin flow characteristics. The required fan pattern width is specific to the size and configuration of the partbeing sprayed. The size of the spray pattern should match the spraying requirements. For example, sprayinga large flat part benefits from producing a wide fan pattern. A small part or one with a complex shape mayrequire a narrow fan pattern. There is, however, one trait all spray patterns have in common; a symmetricalshape where the material is distributed evenly across the length and width of the spray pattern.

Fan patterns develop from a straight stream of resin, produced at very low fluid pressures, to an elongated ovalpattern with increasing pressure. An under-developed spray pattern does not exhibit an oval configuration. Apartially-developed spray pattern may have an irregular oval shape. A fully-developed spray pattern will be auniform oval shape of the proper working width, An over-developed spray pattern presents a uniform ovalshape that is wider than a fully-developed pattern, and produces increased atomization resulting from increasedtip fluid pressure. This excess atomization is apparent by the increase in overspray surrounding the spraypattern.

As the fluid pressure reaches a specific optimum level for a specific combination of factors, a symmetricalelliptical shaped spray pattern develops. This pattern may need slight fine-tuning, with incremental pressureadjustments; or in the case of an air-assist spray gun, may be refined with additional air-assist pressureadjustments. The goal of air-assist/fluid pressure adjustments is to determine the combination that requires thelowest pressures, while producing a workable spray pattern.

Pump pressures and/or air-assist pressures set to greater than required levels to produce a fully-developeduniform spray pattern are considered excessive.

- 7 -

EXAMPLES OF SPRAY PATTERN DEVELOPMENT

Note: These pressures are for illustration purposes only. Actual pressures will vary with specific equipment,resin, spray tip size and angle, material temperature and other factors.

20 psi - Undeveloped



35 psi - Partially Developed



50 psi - Fully Developedwithout Air Assist Fine Tuned

50 psi - Fully Developedwith Air Assist Fine Tuned

55 psi - Over Developed

60 psi - Over Developed

- 8 -

SPRAY GUN CALIBRATION WORKSHEET - EXAMPLE

Date:______________ Operator:____________________________________________

Spray Unit Designation:____________________________________________________________________

Resin Designation:________________________________________________________________________

Spray Tip Size & Angle:____________________________________________________________________

Spray Tip Condition: New_____ Used_____

Spray Gun Pressure Calibration Record

Pump Air Assist Spray Pattern Development

Pressure Pressure Under Partially FullySetting Setting Developed Developed Developed

10 psi

15 psi

20 psi

25 psi

30 psi

35 psi

40 psi

45 psi

50 psi

55 psi

60 psi

65 psi

70 psi

75 psi

80 psi

85 psi

90 psi

100 psi

Final Pump Pressure Setting: __________________ psi

Initial Air Assist Pressure Setting: __________________ psi

Final Air Assist Pressure Setting: __________________ psi

Signature:__________________________________________

- 9 -

Styrene Source Test Report for theUnderground Storage Tank Operation

April 25-26, 2001 Test Period

prepared for:

Mr. Christopher WheelingAir Quality Compliance Program

Air & Radiation Management AdministrationMaryland Department of the Environment

2500 Broening HighwayBaltimore, Maryland 21224

By a recognized authority on styrene emissions and testing

May 14, 2001

- 11 -

TABLE OF CONTENTS

List of Tables ................................................................................................................................... 13

I. Introduction ............................................................................................................................. 14

II. Discussion of Testing Procedures and Result ......................................................................... 14A. Plant Production Activity ................................................................................................ 14B. Source Description ........................................................................................................ 14C. Revised EPA Method 18 Test Procedures ..................................................................... 15D. Field QA/QC Procedurm ............................................................................................... 17E. Unusual Events During the Test .................................................................................... 17F. Laboratory QA/QC Data ................................................................................................. 17

III. Styrene Source Test Results .................................................................................................. 18

IV. Conclusions and Recommendations....................................................................................... 33

- 12 -

- 13 -

List of Tables

A. Stack Traverse locations (as durt diameters) ......................................................................... 14

B. Spike Load Recovery ............................................................................................................. 15

1a UST I Exhaust Flow Rate Calculation for DAY I ..................................................................... 18

1b UST 2 Exhaust Flow Rate Calculation for DAY I .................................................................... 19

1c UST 3 Exhaust Flow Rate Calculation for DAY I .................................................................... 20

1d UST 4 Exhaust Flow Rate Calculation for DAY I .................................................................... 21

2a UST I Exhaust Flow Rate Calculation for DAY 2 .................................................................... 22

2b UST 2 Exhaust Flow Rate Calculation for DAY 2 ................................................................... 23

2c UST 3 Exhaust Flow Rate Calculation for DAY 2 ................................................................... 24

2d UST 4 Exhaust Flow Rate Calculation for DAY 2 ................................................................... 25

3. Sampling Train Calibration Data for DAY 1 ............................................................................ 26

4. Sampling Train Calibration Data for DAY 2 ............................................................................ 27

5. Styrene, Sample Analysis Results for DAY 1 ......................................................................... 28

6. Styrene Sample Analysis Results for DAY 2 .......................................................................... 28

7. Material and Monomer Usages .............................................................................................. 29

8. Sample Recovery and Reported Concentrations................................................................... 30

9. Sample Recovery and Reported Concentrations for Day 2 ................................................... 31

10. Styrene Source Test Summary .............................................................................................. 36

SECTION I Introduction

The purpose of this report is to detail the test results for styrene vapor emissions from a fiberglass reinforcedplastic underground storage tank (UST) manufacturing operation at a facility located in ___________. Thisfacility is owned by the __________________ Corporation and is henceforth called the ___________. The_____________ produces large UST parts using polyester resins that contain liquid styrene monomer. Styrenevapor is emitted as a consequence of the lamination processes used at the plant.

This stack test determined the styrene emission rates from four different UST molding stations on two consecutive,days, April 25, 2001 and April 26, 2001, and calculated the quantity of styrene emitted per pound of styrenemonomer consumed and the quantity of styrene emitted per pound of raw resin consumed. This information isrequired as a condition of the Part 70 (Title V) operating permit issued to the __________by the MarylandDepartment of the Environment (MDE).

The test consisted of two simple field measurements. First the actual exhaust flow rate was determined usingstandard velocity traverse measurement techniques and flow calculation procedures for circular (and in onecase, rectangular) ducts, Second, the styrene concentration of the exhaust was determined using a precisionsampling train and several charcoal adsorption tubes. The sampling train pump drew a small measured volumeof the exhaust stream through the charcoal tube, where the styrene vapor was absorbed onto the activatedcarbon granules. The charcoal sample tube was carefully stored and then delivered to a certified laboratory forsubsequent GC analysis. The laboratory desorbed the styrene vapor trapped in the carbon using carbondisulfide and then determined the styrene content in the sample. A blank sample tube was also analyzed by thelaboratory to determine the, detection limit of the analysis procedure. The styrene content of each sample wasdivided by the sample volume to calculate the styrene concentration. Finally, the exhaust stack styrene emissionrate was calculated by multiplying the measured exhaust flow rate by the measured styrene concentration.

SECTION II Discussion of Testing Procedures and Results

II. A. Plant Production Activity

All general production activities were the same as described in the test protocol document submitted to theMDE on November 15, 2000. In order to complete the measured styrene emission rates with the correspondingproduction activity, the following plant production data was recorded by personnel during the test days:

• Production shift start and stop times - 6:00 am to 2:00 pm.• Number of work breaks - two 15-minute breaks and one 30-minute lunch period.• Resin usage per mold.• Resin analysis data - manufacturer’s resin certification sheet.

II. B. Source Description

The styrene vapor emission sources that were involved this test consisted of the following four (4) UST moldingstations:

UST I eight-foot diameter UST mold (Mold 1)UST 2 eight-foot diameter UST mold (Mold 2)UST 3 six-foot diameter UST mold (Mold 9)UST 4 ten-foot diameter UST mold (Mold 10)

These different mold sizes were selected to represent the range of UST part sizes produced at the plant.

The source testing simultaneously sampled each of the four exhaust streams from these four UST moldingstations. The exterior building doors were closed during the testing periods to the greatest extent possible. Thiscaused any styrene emissions that were fugitive to the building to be drawn towards the UST exhaust streams.

- 14 -

- 15 -

A vorticity survey was conducted during the pre-survey activities performed on April 24, 200 1. No vorticity wasobserved in the duct flow at the traverse points. However, the exhaust velocity in the 6-foot mold duct was toolow to be measured with a pitot tube/manometer, so the traverse location for UST 3 was relocated to therectangular exhaust duct inside the rotating mold. The relative locations of the duct traverse locations are givenin Table A.

TABLE AStack Traverse Locations (as duct diameters)

Source Upstream Downstream

UST I - 8' Deq = 30" 170" (5.7 D) > 60" (> 2.0 D)UST 2 - 8' Deq = 30" 17011 (5.7 D) > 60" (> 2.0 D)UST 3 - 6' Deq = 16.4" 142" (8.6 D) 20" (1.3 D)UST 4 - 10' Deq = 30" 170" (5.7 D) > 60" (> 2.0 D)

II. C. Revised EPA Method 18 Test Procedures

The, styrene vapor source test method employed for the ________ was the revised EPA Method 18, incorporatingNIOSH Method 1501 adsorption tube collection as specified in Section 7.4 and the new dual train “spiked” and“unspiked” recovery factor procedures as specified in Section 7.6. This method is henceforth simply referred toas “Method 18”. In general, the Method I 8 approach used standard procedures to measure the exhaust stackflow rates with a pitot tube/manometer combination. The sampling flow rates were provided by precision-metered and calibrated sampling trains. The NIOSH Method 1501 procedures were followed to collect andanalyze the styrene vapor concentration present in the exhaust. The actual flow rates through the sorbenttubes were set to prevent sample breakthrough and to keep the styrene-to-carbon mass loading ratio within thevalidated loading range.

Exhaust Flow Rates - the exhaust flow rate in each duct was calculated by multiplying the cross-sectional areaby the average exhaust velocity. The average velocity was measured with a standard digital micro manometerand a pitot tube. The manometer was a Dwyer Instruments Model #127-00 manometer, with a 0.0' to 4.00"water column static pressure range and a 0.01 scale precision. The pitot tube was a Dwyer model #160-36stainless steel pitot tube with a 36" insertion length-that complied with ASERAE and AMCA specifications (a 24'long pitot tube was-used inside UST 3). The equation used to calculate air velocity from the pitot pressuredifference reading was:

Air Velocity (fpm) = 1096.2 x Velocity pressure (in wg)0.5

Air density (Ib/ft3)0.5 [eq 1]

A pitot tube correction factor was not needed, because a standard “L-type’ pitot was used. The dry air densityof the exhaust was calculated by using the equations for the ASERAE psychrometric tables. The wet-bulbtemperature, dry-bulb temperature, static pressure, and the barometric pressure of the exhaust air were usedto accurately estimate the corresponding relative humidity and air density of the exhaust.

Spiking Procedures - the spiked sorbent tubes were prepared in accordance with the, procedures listed inMethod 18, Section 7.6.3. The spiked sorbent tubes were pre-loaded with an initial styrene mass by adding 15µl of lab-grade, styrene liquid to the top of main charcoal section in the sorbent tube. About 60 liters of pure airwere then passed through the tube to evaporate and aspirate the styrene through the main sorbent section.The spike mass (15 µl x 0.9 = 13.5 mg) was about 33% of the mass of styrene expected to be collected on theunspiked sorbent tube. For an uncoated activated charcoal tube with an 800 mg front section, the ideal maximumspike mass was about 15 mg. The spiking was conducted at the site on the afternoon of April 3, 2001, whichwas as close to the test period as was feasible. The spiked tubes were stored at 40ºF in a small refrigerator atthe plant site.

- 16 -

In order to further verify the accuracy of the laboratory analysis, a set of three field calibration samples wereincluded with the test samples for each test run. The results of the calibration samples and the correspondingstyrene recovery values are listed in Table B as follows:

TABLE B Spike Load Recovery

EXPECTED LOAD (mg) MEASURED LOAD (mg) RECOVERY (%)

DAY 1CAL 1 13.5 13.3 98.5 %CAL2 13.5 13.2 97.8 %CAL3 13.5 13.4 99.3 %

DAY 2CAL4 13.4 13.1 97.0%CAL5 13.4 13.0 96.3 %CAL6 13.4 13.3 98.5 %

average 97.9 %

As shown, the average recovery of the spike loads was nearly perfect.

Recovery Factor - as specified by Method 18, a recovery factor was calculated for each sample tube pair bycomparing the initial mass of styrene in the ‘spiked tubes” to the total mass of styrene collected. This recoveryfactor was computed as follows:

R = MS - (Vs/Vu) x MU [eq 1]

S

where Ms

= the mass of styrene measured on the spiked tube (mg)V

s= the volume of stack gas passed through the spiked tube (L)

Mu

= the mass of styrene measured on the unspiked tube (mg).V

u= the volume of stack gas passed through the unspiked tube (L) = the initial mass of styrene spiked onto the sorbent tube (mg)

The average value of R for all of the sample sets on Day 1 was 0.985 and on Day 2 was 0.994, which was wellwithin the acceptance range 0.70 < R

AVE < 1.30.

Styrene Concentration - the styrene concentration reported for each stack was given by:

Reported Concentration Result (ppm) = Measured Concentration (ppm)/R [eq 2]

Emission Rate - a styrene emission rate was calculated for each stack by multiplying the reported styreneconcentration in the measured exhaust flow rate adjusted by a density correction factor (to account for standardpressure, temperature, and moisture content) as follows:

Emission Rate = Reported Concentration x Measured Flow Rate x Density Factor [eq 3]

Emission Factor - a styrene emission factor was calculated for each test run by dividing the styrene emissionrate for each molding operation by the amount of resin used in each molding station:

Emission Factor = Ó Emission Rates ÷ Ó Resin Consumed [eq 4]

A styrene emission factor was calculated for each test run by dividing the styrene emission rate by the amountof styrene monomer used in each molding station:

- 17 -

Emission Factor = Ó Emission Rates ÷ Ó Styrene Monomer Consumed [eq 5]

II. D. Field QA/QC ProceduresThere were no changes to the QA/QC procedures detailed in the protocol document the pitot tube and manometerconnections were leak-checked before and after the test by creating a 3" negative static pressure within thetube barrel, and visually observing any change in the pressure readings over a three minute period. The sampletrains were also leak-checked before and after using the same technique. No leaks were detected at any time.The digital thermometers were calibrated against a certified glass-bulb laboratory thermometer before andafter the test. The calibration errors for both thermometers were less than 1º F at all calibration points acrossthe entire range from 50 to 90º F.

II. E. Unusual Events During the Test

Sample breakthrough - according to the laboratory analysis reported in Table 4, none of the sample tubes hada detectable amount of styrene in the backup sorbent section. This indicates that sample breakthrough did notoccur during the testing, and all of the styrene that was collected was reported.

Sample train flow rate fluctuations - none of the sampling trains exhibited variations in flow rate greater than± 4% between the pre-test and post-test calibration measurements. The largest variation was -3.2% for sample#5 on Day 2. The flow rate values for all sampling trains were adjusted by simply averaging the pre-calibrationand post-calibration flow rate values together. The sample trains flow rate values for Day 1 and Day 2 are notedin Table 3 and Table 4, respectively.

The rotameter log data for sample pair #13 and #S-13 indicated a steady decline in the sampling flow rateduring Day 2. However, the pre- and post-calibration data did not indicate a problem, and the sample recoveryfor this pair was 94.6%. For these reasons, the sample pair was retained. The rotameter log data did notindicate any problems with the other sampling flow rates.

Sample rejection - the low recovery value for sample OS-3 on Day 1 was rejected due to the poor recovery.This was the only recovery value that was rejected.

Open exterior doors - the exterior doors were opened periodically during the testing periods to move materialsand parts out of the building by forklift. These doors were only open for brief intervals of less than five minutes,and did not affect the capture of emissions inside the molds.

Weather related events - the sampling equipment was located indoors, so it was unaffected by the weather.However, the weather was ideal during the source testing.

II. F. Laboratory QAIQC DataThe MDE requested specific information regarding the laboratory analysis of the styrene samples. Some of thisoriginal raw data was provided in fan-fold and paper roll formats. For this reason, the original raw laboratoryinformation is included with the final report submitted to the MDE office. Please note that there are no othercopies of this data besides these originals.

The MDE should contact ______________, the AML IH Lab Manager by phone at _________ for answers toany further questions regarding the laboratory data or analytical procedures.

- 18 -

SECTION III Styrene Source Test Results

This section details the results of the April 25-26, 2001 styrene source test at the _______ Plant. These resultsare presented as Quattro Pro spreadsheets, which list the necessary parameters, the original data, and thesubsequent calculations.

The Day 1 exhaust flow rate calculations for UST 1 through UST 4 are listed in Table 1a through Table 1d,respectively. The Day2 exhaust flow rate calculations for UST 1 through UST 4 are listed in Table 2athrough and Table 2d, respectively. No flow vorticity which would have adversely affected the flowmeasurements, was detected during the pre-survey on April 24, 2001 Three separate velocity traverseswere conducted on each exhaust duct during each test day one traverse in the morning, one at midday, andone in the afternoon. The average measured exhaust flow rate values for each mold were in close agreementwith each other, and closely matched the expected exhaust flow rates.

The pre-calibration and post-calibration data calculations for the sampling train are shown in Table 3 forDay 1 and Table 4 for Day 2. These calculations were needed to determine the sampling volumes, and toverify a constant sampling flow rate during the test. This data confirmed that the flow rates for the acceptedsampling trains operated within normal performance limits during the test.

The results of the laboratory analysis of the styrene sample loads on both the front and back sections, andthe corresponding sample volumes, are listed in Table 5 for Day 1 and Table 6 for Day 2. None of thesource samples showed a detectable amount of styrene on the back section, so breakthrough did not occurduring the testing.

The amounts of resin and styrene monomer consumed by each molding station during both test days, asreported by are listed in Table 7.

The average sample recoveries and reported styrene concentrations for each set of UST molding stationsamples are computed in Table 8 for Day I and Table 9 for Day 2.

The average sample recoveries for the stack samples and calibration samples were:

DAY 1 DAY 2Samples: UST I 101.5% UST I 98.6%

UST 2 95.6% UST 2 95.1 %UST 3 104.7% UST 3 99.3 %UST 4 99.4% UST 4 101.7 %All molds 100.3% All molds 98.7%

Calibration: 98.5 % Calibration: 97.3 %which were internally consistent and well within the acceptable 70 to 130% range.

The summary of the test results and styrene emissions factors are given in Table 10 in the following Section IV.

- 19 -

TABLE 1a: UST 1 Exhaust Flow Rate Calculation for DAY 1

UST 1 – 8’ moldApril 25, 2001

Barometric 29.71 in Hg 29.74 in Hg 29.77 in HgStatic -1.10 in wg -1.10 in wg -0.98 in wgDry Bulb 67.6 F 70.5 F 66.4 FWet Bulb 54.9 F 53.4 F 57.8 F

Moisture 0.0064 Ib/lb 0.0048 lb/lb 0.0083 lb/lbDensity 0.0738 lb/ft3 0.0736 lb/ft3 0.0739 lb/ft3

L R L R L R1 0.02 0.02 0.02 0.02 0.01 0.022 0.03 0.02 0.02 0.02 0.02 0.033 0.04 0.03 0.04 0.03 0.04 0.034 0.05 0.04 0.05 0.03 0.05 0.045 0.05 0.05 0.05 0.04 0.05 0.046 0.04 0.04 0.04 0.04 0.04 0.047 0.04 0.04 0.04 0.04 0.04 0.048 0.04 0.04 0.04 0.04 0.04 0.049 0.04 0.04 0.04 0.04 0.04 0.0410 0.03 0.04 0.03 0.04 0.03 0.0311 0.03 0.03 0.02 0.03 0.02 0.0212 0.01 0.02 0.02 0.01 0.02 0.02

Duct Diameter 30.0 inDuct Area 4.91 sq ft

1 571 571 572 572 403 5702 699 571 572 572 570 6993 807 699 808 700 807 6994 903 807 904 700 902 8075 903 903 904 808 902 8076 807 807 808 808 807 8077 807 807 808 808 807 8078 807 807 808 808 807 8079 807 807 808 808 807 80710 699 807 700 808 699 69911 699 699 572 700 570 57012 404 571 572 404 570 570

Average Velocity 740 fpm 722 fpm 72i fpmActual Flow rate 3,634 acfm 3,545 acfm 3,538 acfmStandard Flow rate 3,576 dscfm 3,488 dscfm 3,472 dscfm

Mean Flow Rate 3,512 dscfmMean Air Density 0.0738 lb/cu ft

- 20 -

TABLE 1b: UST 2 Exhaust Flow Rate Calculation for DAY 1

UST 2 - 8' mold

April 25, 2001Barometric 29.71 in Hg 29.74 in Hg 29.77 in HgStatic -1.14 in wg -1.11 in wg -1.14 in wgDry Bulb 70.2 F 71.4 F 67.1 FWet Bulb 51.6 F 51.8 F 51.8 F

Moisture 0.0040 Ib/lb 0.0038 lb/lb 0.0048 lb/lbDensity 0.0737 lb/ft3 0.0736 lb/ft3 0.0742 lb/ft3

L R L R L R1 0.02 0.02 0.02 0.02 0.02 0.022 0.02 0.03 0.03 0.03 0.02 0.033 0.03 0.05 0.03 0.04 0.03 0.044 0.04 0.05 0.04 0.04 0.04 0.045 0.05 0.05 0.04 0.05 0.04 0.056 0.05 0.05 0.05 0.05 0.05 0.057 0.06 0.06 0.05 0.05 0.05 0.058 0.06 0.06 0.06 0.06 0.06 0.069 0.05 0.06 0.05 0.05 0.05 0.0510 0.04 0.05 0.04 0.04 0.05 0.0411 0.03 0.04 0.03 0.03 0.03 0.0312 0.01 0.02 0.02 0.02 0.03 0.01


1 571 571 572 572 569 5692 571 700 700 700 569 6973 700 903 700 808 697 8054 808 903 808 808 805 8055 903 903 808 904 805 9006 903 903 904 904 900 9007 989 989 904 904 900 9008 989 989 990 990 986 9869 903 989 904 904 900 90010 808 903 808 808 900 80511 700 808 700 700 697 69712 404 571 572 572 697 403

Average Velocity 808 fpm 789 fpm 783 fpmActual Flow rate 3,964 acfm 3,874 acfm 3,844 acfmStandard Flow rate 3,896 dscfm 3,807 dscf, 3,772 dscfm

Mean Flow Rate 3,825 dscfmMean Air Density 0.0738 lb/cu ft

- 21 -

TABLE 1c: UST 3 Exhaust Flow Rate Calculation for DAY 1

UST 3 – 6’ Mold

April 25, 2001

Sea-level Barometric 30.19 in Hg 30.25 in HgActual Barometric 29.71 in Hg 29.77 in HgStatic -1.42 in wg -1.46 in wgDry Bulb 67.1 F 70.0 FWet Bulb 51.1 F 50.7 F

Moisture 0.0044 lb/lb 0.0035 lb/lbDensity 0.0740 lb/ft3 0.0738 lb/ft3

1 2 3 1 2 31 0.22 0.25 0.23 0.25 0.25 0.202 0.32 0.37 0.22 0.33 0.44 0.283 0.28 0.41 0.27 0.32 0.42 0.244 0.28 0.34 0.30 0.32 0.34 0.285 0.32 0.32 N/A 0.29 0.31 N/A6 0.25 0.26 N/A 0.22 0.27 N/A7 0.19 N/A N/A 0.18 N/A N/A8 0.07 N/A N/A 0.07 N/A N/A

Equivalent Diameter 16.4 inDuct Area 1.46 sq ft

1 1,891 2,015 1,933 2,018 2,018 1,8052 2,280 2,452 1,891 2,391 2,677 2,1363 2,133 2,581 2,094 2,283 2,616 1,9774 2,133 2,350 2,208 2,283 2,354 2,1365 2,280 2,280 N/A 2,174 2,247 N/A6 2,015 2,055 N/A 1,893 2,097 N/A7 1,757 N/A N/A 1,712 N/A N/A8 1,068 N/A N/A 1,068 N/A N/A

Average Velocity 2,079 fpm 2,101 fpmActual Flow Rate 3,031 acfm 3,064 acfmStandard Flow Rate 2,991 dscfm 3,015 dscfm

Mean Flow Rate 3,003 dscfmMean Air Density 0.0493 lb/ft3

- 22 -

TABLE 1d: UST 4 Exhaust Flow Rate Calculation for DAY 1

UST 4 – 10’ Mold

April 25, 2001


Moisture 0.0047 lb/lb 0.0046 lb/lb 0.0043 lb/lbDensity 0.0737 lb/ft3 0.0737 lb/ft3 0.0735 lb/ft3

L R L R L R1 0.14 0.24 0.14 0.24 0.14 0.232 0.17 0.25 0.20 0.28 0.18 0.263 0.27 0.31 0.28 0.33 0.25 0.304 0.31 0.31 0.33 0.33 0.31 0.325 0.30 0.30 0.32 0.31 0.30 0.296 0.29 0.28 0.29 0.29 0.27 0.267 0.27 0.26 0.27 0.28 0.26 0.268 0.26 0.26 0.28 0.27 0.27 0.259 0.27 0.26 0.29 0.25 0.29 0.2510 0.27 0.24 0.26 0.23 0.27 0.2211 0.16 0.19 0.16 0.19 0.19 0.1712 0.10 0.15 0.10 0.14 0.09 0.15


1 1,511 1,979 1,511 1,979 1,513 1,9402 1,665 2,020 1,806 2,137 1,716 2,0623 2,099 2,249 2,137 2,320 2,022 2,2154 2,249 2,249 2,320 2,320 2,252 2,2885 2,212 2,212 2,285 2,249 2,215 2,1786 2,175 2,137 2,175 2,175 2,102 2,0627 2,099 2,059 2,099 2,137 2,062 2,0628 2,059 2,059 2,137 2,099 2,102 2,0229 2,099 2,059 2,175 2,020 2,178 2,02210 2,099 1,979 2,059 1,937 2,102 1,89711 1,616 1,761 1,616 1,761 1,763 1,66812 1,277 1,564 1,277 1,511 1,213 1,566

Average Velocity 1979 fpm 2010 fpm 1968 fpmActual Flow Rate 9713 acfm 9867 acfm 9659 acfmStandard Flow Rate 9544 dscfm 9696 dscfm 9491 dscfm

Mean Flow Rate 9577 dscrfmMean Air Density 0.0736 lb/ft3

- 23 -

TABLE 2a: UST 2 Exhaust Flow Rate Calculation for DAY 2

UST 1 – 8’ Mold

April 26, 2001



L R L R L R1 0.01 0.02 0.01 0.01 0.01 0.022 0.02 0.02 0.02 0.02 0.02 0.023 0.04 0.03 0.04 0.03 0.045 0.034 0.05 0.03 0.05 0.03 0.05 0.035 0.05 0.03 0.05 0.04 0.05 0.036 0.04 0.04 0.04 0.04 0.05 0.047 0.04 0.04 0.03 0.03 0.04 0.048 0.04 0.04 0.03 0.03 0.04 0.049 0.04 0.04 0.03 0.04 0.04 0.0410 0.03 0.03 0.03 0.03 0.03 0.0311 0.02 0.03 0.02 0.03 0.02 0.0312 0.01 0.02 0.01 0.02 0.01 0.02


1 402 568 406 406 405 5732 568 568 574 574 573 5733 803 696 811 702 859 7014 898 696 907 702 906 7015 898 696 907 811 906 7016 803 803 811 811 906 8107 803 803 702 702 810 8108 803 803 702 702 810 8109 803 803 702 811 810 81010 696 696 702 702 701 70111 568 696 574 702 573 70112 402 568 406 574 405 573

Average Velocity 702 fpm 684 fpm 714 fpmActual Flow Rate 3,446 acfm 3,355 acfm 3,503 acfmStandard Flow Rate 3,423 dscfm 3,270 dscfm 3,424 dscfm


- 24 -

TABLE 2b: UST 2 Exhaust Flow Rate Calculation for DAY 2

UST 2 – 8’ Mold

April 26, 2001



L R L R L R1 0.01 0.02 0.01 0.02 0.02 0.012 0.02 0.03 0.02 0.03 0.02 0.033 0.03 0.04 0.03 0.04 0.03 0.044 0.03 0.04 0.03 0.04 0.04 0.045 0.04 0.04 0.04 0.04 0.04 0.056 0.04 0.04 0.04 0.04 0.04 0.047 0.05 0.05 0.05 0.05 0.05 0.058 0.04 0.04 0.05 0.05 0.05 0.059 0.05 0.04 0.05 0.04 0.05 0.0510 0.04 0.04 0.04 0.04 0.04 0.0411 0.03 0.03 0.03 0.03 0.03 0.0312 0.01 0.02 0.02 0.01 0.02 0.02


1 402 568 406 575 574 4062 468 696 575 704 574 7033 696 803 704 813 703 8124 696 803 704 813 812 8125 803 803 813 813 812 9086 803 803 813 813 812 8127 898 898 909 909 908 9088 803 803 909 909 908 9089 898 803 909 813 908 90810 803 803 813 813 812 81211 696 696 704 704 703 70312 402 568 575 406 574 574

Average Velocity 730 fpm 746 fpm 765 fpmActual Flow Rate 3,583 acfm 3,664 acfm 3,758 acfmStandard Flow Rate 3,559 dscfm 3,557 dscfm 3,652 dscfm


- 25 -

TABLE 2c: UST 3 Exhaust Flow Rate Calculation for DAY 2

UST 3 – 6’ Mold

April 26, 2001

Sea-level Barometric 30.25 in Hg 30.25 in Hg 30.25 in HgActual Barometric 29.77 in Hg 29.77 in Hg 29.77 in HgStatic -1.39 in wg -1.37 in wg -1.36 in wgDry Bulb 66.2 F 73.4 F 69.4 FWet Bulb 50.9 F 57.9 F 49.1 F


1 2 3 1 2 3 1 2 31 0.20 0.20 0.12 0.20 0.20 0.19 0.20 0.22 0.192 0.31 0.37 0.21 0.29 0.39 0.24 0.27 0.36 0.223 0.27 0.35 0.3 0.28 0.37 0.28 0.28 0.37 0.304 0.25 0.25 0.20 0.27 0.29 0.25 0.23 0.29 0.225 0.25 0.24 N/A 0.27 0.26 N/A 0.27 0.28 N/A6 0.19 0.20 N/A 0.20 0.21 N/A 0.19 0.23 N/A7 0.15 N/A N/A 0.14 N/A N/A 0.16 N/A N/A8 0.09 N/A N/A 0.10 N/A N/A 0.11 N/A N/A

Duct Diameter 16.4 in1.46 sq ftDuct Area

1 1,799 1,799 1,393 1,814 1,814 1,768 1,801 1,889 1,7562 2,240 2,447 1,843 2,184 2,533 1,987 2,093 2,417 1,8893 2,090 2,380 1,929 2,146 2,467 2,146 2,131 2,450 2,2064 2,011 2,011 1,799 2,107 2,184 2,028 1,932 2,169 1,8895 2,011 1,971 N/A 2,107 2,068 N/A 2,093 2,131 N/A6 1,753 1,799 N/A 1,814 1,858 N/A 1,756 1,932 N/A7 1,558 N/A N/A 1,672 N/A N/A 1,611 N/A N/A8 1,217 N/A N/A 1,282 N/A N/A 1,336 N/A N/A

Average Velocity 1,892 fpm 1,999 fpm 1,971 fpmActual Flow Rate 2,759 acfm 2,915 acfm 2,875 acfmStandard Flow Rate 2,733 dscfm 2,841 dscfm 2,840 dscfm


- 26 -

TABLE 2d: UST 4 Exhaust Flow Rate Calculation for DAY 2

UST 4 – 10’ Mold

April 26, 2001

Barometric 29.77 in Hg 29.77 in Hg 29.77 in HgStatic -2.28 in wg —2.29 in wg -2.41 in wgDry Bulb 64.0 F 74.1 F 69.4 FWet Bulb 49.5 F 56.7 F 52.5 F


L R L R L R1 0.15 0.25 0.16 0.24 0.13 0.232 0.19 0.26 0.18 0.25 0.15 0.253 0.25 0.33 0.24 0.32 0.23 0.314 0.33 0.31 0.29 0.33 0.30 0.325 0.32 0.29 0.30 0.29 0.29 0.286 0.29 0.26 0.28 0.26 0.28 0.257 0.27 0.26 0.24 0.26 0.26 0.258 0.28 0.26 0.27 0.26 0.27 0.249 0.30 0.26 0.29 0.26 0.28 0.2410 0.29 0.24 0.27 0.22 0.28 0.2111 0.20 0.20 0.18 0.19 0.18 0.1812 0.09 0.14 0.08 0.14 0.10 0.14


1 1,556 2,009 1,626 1,991 1,457 1,9382 1,751 2,048 1,724 2,032 1,565 2,0213 2,009 2,308 1,991 2,299 1,938 2,2504 2,308 2,237 2,188 2,335 2,214 2,2865 2,273 2,163 2,226 2,188 2,177 2,1396 2,163 2,048 2,150 2,072 2,139 2,0217 2,087 2,048 1,991 2,072 2,061 2,0218 2,126 2,048 2,112 2,072 2,100 1,9809 2,200 2,048 2,188 2,072 2,139 1,98010 2,163 1,968 2,112 1,906 2,139 1,85211 1,797 1,797 1,727 1,771 1,715 1,71512 1,205 1,503 1,149 1,521 1,278 1,512

Average Velocity 1,994 fpm 1,980 fpm 1,943 fpmActual Flow Rate 9,790 acfm 9,718 acfm 9,539 acfmStandard Flow Rate 9,724 dscfm 7,433 dscfm 9,361 dscfm


- 27 -

- 28 -

TABLE 5: Styrene Sample Analysis Results for Day 1

Sample Train Stack Flow Time Volume Styrene (mg)# # # (mL/min) (min.) (L) Front Back %1 1 UST 1 484 480 232.2 122.0 <0.011S1 S1 UST 1 336 480 161.4 98.7 <0.0112 2 UST 1 494 480 237.0 122.0 <0.011S2 S2 UST 1 321 480 153.9 92.7 <0.0113 3 UST 1 482 480 231.6 124.0 <0.011S3 S3 UST 1 312 480 149.9 90.3 <0.0114 4 UST 2 494 480 237.3 107.0 <0.011S4 S4 UST 2 305 480 146.2 77.1 <0.0115 5 UST 2 489 480 234.8 106.0 <0.011S5 S5 UST 2 309 480 148.1 82.7 <0.0116 6 UST 2 496 480 238.1 114.0 <0.011S6 S6 UST 2 312 480 149.6 83.3 <0.0117 7 UST 3 501 480 240.4 106.0 <0.011S7 S7 UST 3 326 480 156.6 82.6 <0.0118 8 UST 3 485 480 232.9 97.9 <0.011S8 S8 UST 3 313 480 150.0 76.5 <0.0119 9 UST 3 499 480 239.6 103.0 <0.011S9 S9 UST 3 325 480 156.1 82.5 <0.01110 10 UST 4 495 480 237.5 71.3 <0.011S10 S10 UST 4 305 480 146.3 59.1 <0.01111 11 UST 4 483 480 231.8 72.4 <0.011S11 S11 UST 4 314 480 150.7 60.4 <0.01112 12 UST 4 473 480 227.0 70.8 <0.011Blank N/A Blank N/A N/A N/A 0.0 <0.011Cal 1 N/A cal N/A N/A N/A 13.3 <0.011 98.5%Cal 2 N/A cal N/A N/A N/A 13.2 <0.011 97.8%Cal 3 N/A cal N/A N/A N/A 13.4 <0.011 99.3%

98.5%

TABLE 6: Styrene Sample Analysis Results for Day 2

Sample Train Stack Flow Time Volume Styrene (mg)# # # (mL/min) (min.) (L) Front Back %13 1 UST 1 487 480 233.9 83.0 <0.011S 13 S1 UST 1 341 480 163.5 70.8 <0.01114 2 UST 1 491 480 235.6 84.2 <0.011S 14 S2 UST 1 323 480 154.9 66.6 <0.01115 3 UST 1 498 480 239.0 81.2 <0.011S 15 S3 UST 1 312 480 149.8 66.8 <0.01116 4 UST 2 504 480 241.9 59.0 <0.011S 16 S4 UST 2 316 480 151.7 49.0 <0.01117 5 UST 2 496 480 238.3 57.5 <0.011S 17 S5 UST 2 314 480 150.9 49.8 <0.01118 6 UST 2 507 480 243.4 58.4 <0.011S 18 S6 UST 2 314 480 150.7 49.3 <0.01119 7 UST 3 497 480 238.4 78.3 <0.011S 19 S7 UST 3 328 480 157.3 64. <0.01120 8 UST 3 491 480 235.8 76.5 <0.011S 20 S8 UST 3 314 480 150.9 64.0 <0.01121 9 UST 3 501 480 240.3 79.3 <0.011S 21 S9 UST 3 501 480 240.3 79.3 <0.01122 10 UST 4 491 480 235.5 42.0 <0.011S 22 S10 UST 4 309 480 148.2 37.9 <0.01123 11 UST 4 485 480 232.7 37.8 <0.011S 23 S11 UST 4 312 480 149.5 40.7 <0.01124 12 UST 4 487 480 233.9 41.4 <0.011S 24 S12 UST 4 315 480 151.4 40.1 <0.011Blank N/A Blank N/A N/A N/A <0.011 <0.011Cal 1 N/A cal N/A N/A N/A 13.1 <0.011 97.0%Cal 2 N/A cal N/A N/A N/A 13.0 <0.011 96.3%Cal 3 N/A cal N/A N/A N/A 13.3 <0.011 98.5%

97.3%

- 29 -

TABLE 7: Material and Monomer Usages

Styrene Material Usages & Usage Rates – April 25, 2001Ave Hr

Volumetric ResinUsage Resin Resin Actual Usage Styrene Styrene

Source Amount Density Mass Time Rate Content Mass(gal) (lb/gal) (lb) (hr) (lb/hr) (lb/lb) (lb)

UST 1 (8’) 119.3 9.01 1074.9 8.00 134.4 43.6% 468.7UST 2 (8’) 127.4 9.01 1147.9 8.00 143.5 43.6% 500.5UST 3 (6’) 87.0 9.01 783.9 8.00 98.0 43.6% 341.8UST 4 (10’) 184.0 9.01 1657.8 8.00 207.2 43.6% 722.8

583.1 ave lb/hrAOC, Vipel F764-PTT-25, Lot #F-32028, 3/24/2001

Styrene Material Usages & Usage Rates – April 26, 2001Ave Hr

Volumetric ResinUsage Resin Resin Actual Usage Styrene Styrene

Source Amount Density Mass Time Rate Content Mass(gal) (lb/gal) (lb) (hr) (lb/hr) (lb/lb) (lb)

UST 1 (8’) 112.3 9.01 1011.8 8.00 126.5 43.6% 441.2UST 2 (8’) 144.2 9.01 1299.2 8.00 162.4 43.6% 566.5UST 3 (6’) 89.2 9.01 803.7 8.00 100.5 43.6% 350.4UST 4 (10’) 187.2 9.01 1686.7 8.00 210.8 43.6% 735.4

600.2 ave lb/hrAOC, Vipel F764-PTT-25, Lot #F-32028, 3/24/2001

- 30 -

TABLE 8: Sample Recovery and Reported Concentrations for Day 1Average Recover 100.3%Density Factor 0.97

UST 1 8’ mold “S” “Ms” Vs” (at STP)Spike Measured Sample Sample Sample Mass Volume “R”Amount Amount Amount Volume Volume Conc Conc Recovery

Sample Train (mg) (mg) (mg) (L) (L at STP) (mg/L) (ppm) Factor

Spiked S 1 13.5 98.7 85.2 161.4 156.5 0.544 125.7 1.033S 2 13.5 92.7 79.2 153.9 149.3 0.530 122.5 0998S 3 13.5 90.3 76.8 149.9 145.4 0.528 122.0 0.743

Ave: 124.1 1.015“Mu” “Vu”

Unspiked 1 122.0 122.0 232.3 225.3 0.541 125.02 122.0 122.0 237.0 229.9 0.531 122.63 124.0 124.0 231.6 224.6 0.552 127.5

Adjusted Conc. 121.9 ppm

Ave: 123.8


Sample Train (mg) (mg) (mg) (L) (L at STP) (mg/L) (ppm) FactorSpiked S 4 13.5 77.1 63.6 146.2 141.8 0.449 103.6 0.829

S 5 13.5 82.7 69.2 148.1 143.7 0.482 111.2 1.172S 6 13.5 83.3 69.8 149.6 145.1 0.481 111.1 0.866

Ave: 108.6 0.956“Mu” “Vu”

Unspiked 4 107.0 107.0 237.3 230.2 0.465 107.35 106.0 106.0 234.8 227.7 0.465 107.56 114.0 114.0 238.1 230.9 0.494 114.0


Ave: 109.6



S 8 13.5 76.5 63.0 150.0 145.5 0.433 100.0 0.996S 9 13.5 82.5 69.0 156.1 151.5 0.456 105.2 1.139

Ave: 103.4 1.047“Mu” “Vu”

Unspiked 7 106.0 106.0 240.4 233.2 0.455 105.08 97.9 97.9 232.9 225.9 0.433 100.19 103.0 103.0 239.6 232.4 0.443 102.4


Ave: 102.5



S 11 13.5 60.4 46.9 150.7 146.2 0.321 74.1 0.987S 12 13.5 58.3 44.8 149.2 144.7 0.310 71.5 0.871

Ave: 73.3 0.994“Mu” “Vu”

Unspiked 10 71.3 71.3 237.5 230.3 0.310 71.511 72.4 72.4 231.8 224.8 0.322 74.412 70.8 70.8 227. 220.2 0.322 74.3


Ave: 73.4

reject

- 31 -

TABLE 9: Sample Recovery and Reported Concentrations for Day 2average recover: 98.7%density factor 0.97



S 14 13.5 66.6 53.1 154.9 150.2 0.353 81.6 0.833S 15 13.5 66.8 53.3 149.8 145.3 0.367 84.7 1.177

Ave: 83.2 0.986“Mu” “Vu”

Unspiked 13 83.0 83.0 233.9 226.9 0.366 84.514 84.2 84.2 235.6 228.6 0.368 85.115 81.2 81.2 239.0 231.8 0.350 80.9


Ave: 83.5



S 17 13.5 49.8 36.3 150.9 146.4 0.248 57.3 0.991S 18 13.5 449.3 35.8 150.7 146.1 0.245 56.6 0.974

Ave: 56.5 0.951“Mu” “Vu”

Unspiked 16 59.0 59.0 241.9 234.6 0.251 58.117 57.5 57.5 238.3 231.2 0.249 57.418 58.4 58.4 243.4 236.1 0.247 57.1


Ave: 57.5



S 20 13.5 64.0 50.5 150.9 146.4 0.345 79.7 1.113S 21 13.5 65.4 51.9 159.2 154.4 0.336 77.6 0.953

Ave: 77.9 0.993“Mu” “Vu”

Unspiked 19 78.3 78.3 238.4 231.3 0.339 78.220 76.5 76.5 235.8 228.7 0.334 77.321 79.3 79.3 240.3 233.1 0.340 78.6


Ave: 78.0



S 23 13.5 40.7 27.2 149.5 145.0 0.188 43.3 1.215S 24 13.5 40.1 26.6 151.4 146.9 0.181 41.8 0.985

Ave: 41.4 1.017“Mu” “Vu”

Unspiked 22 42.0 42.0 235.5 228.4 0.184 42.523 37.8 37.8 232.7 225.7 0.167 38.724 41.4 41.4 233.9 226.8 0.183 42.1


Ave: 41.1

- 32 -

SECTION IV Conclusions and Recommendations

ConclusionsThe following test results were computed from the April 25-26, 2001 styrene source testing data:

DAY I DAY2

Average Flow Rates UST 1 - 8' dia 3,512. 3,372(dsfcm) UST 2 - 8' dia 3,825 3,589

UST 3 - 10' dia 3,003 2,805UST 4 - 10' dia 9,577 9,506

Average Styrene Emission Rate UST 1 - 8' dia 7.0 4.6for an 8- hour production shift UST 2 - 8' dia 7.1 3.5(lb styrene emitted per hour) UST 3 - 10' dia 4.8 3.6

UST 4 – 10’ dia 11.5 6.2All UST - TOTAL 30.3 18.0

Styrene Emission Factor UST I - 8' dia 0.052 0.037based on Raw Material Usage UST 2 - 8' dia 0.050 0.022(lb styrene per lb resin) UST 3 - 10' dia 0.049 0.036

UST 4 - 10' dia 0.055 0.030Average factors 0.0514 0.0309

Styrene Emission Factor UST 1- 8' dia 0.119 0.084based on Monomer Usage UST 2 - 8' dia 0.114 0.050(lb styrene per lb styrene UST 3 - 10' dia 0.112 0.082monomer used) UST 4 - 10’dia 0.127 0.068

A detailed summary of the April 25-26, 2001 UST source test results is listed in Table 10.

Source Test Daily Log

Plant: Date: 4/25/2001No. Time Tip Heat Flow Comments1 6:15 AM 9050 8 1.0+ 65 psi air motor pressure

6:32 AM 8 1.0 61 psi air motor pressure8:31 AM 6.5 1.02:00 PM Resin usage 119.3 gallons

2 6.20 AM 9050 7 0.9 61 psi air motor pressure,7:28 AM 7 0.9+ 60 psi air motor pressure10:17 AM 7.5 0.9+ 60 psi air motor pressure2:00 PM Resin usage 127.4 gallons

8 6:25 AM 9050 8 0.9 60 psi air motor pressure8:43 AM 9 1.0 60 psi air motor pressure2:00 PM Resin usage 87 gallons

9 6:30 AM 9050 8 1.1 70 psi air motor pressure7:22 AM 7 0.9 70 psi air motor pressure10:45 AM 1.1 70 psi air motor pressure1:12 PM 6.5 1.0 70-psi air motor pressure2:00 PM Resin usage 184 gallons

Filters were changed at 6:00, 8:00, 10:00, and 12:00Other molding station pressure readings were taken, but not recorded. These were monitoring readings only.

- 33 -

Source Test Daily Log

Plant: Date: 4/25/2001No. Time Tip Heat Flow Comments1. 6:09 AM 9050 9 1.0 60 psi air motor pressure

8:00 AM 60 psi air motor pressure9:55 AM 8 1.1 60 psi air motor pressure11:30 AM 0.9 60 psi air motor pressure2:00 PM Resin Usage 112.3 gallons

2 6:20 AM 9050 7 0.9+ 60 psi air motor pressure10:00 AM 7 60 psi air motor pressure12:30 AM 1.0 60 psi air motor pressure2.00 PM Resin Usage 144.2 gallons

8 6:03 AM 9050 9 0.8 50 psi air motor- pressure11:30 AM 8 0.9 50 psi air motor pressure12:30 AM 0.9 50 psi air motor pressure2:00 PM Resin usage 89.2 gallons

9 6:06 AM 9050 8 0.9+ 70 psi air motor pressure11:30 AM 9 70 psi air motor pressure12:30 PM 9 1.1 70 psi air motor pressure2:00 PM Resin usage 187.2

Filters were change at 6:00, 8:00, 10:00, and 12:00Other molding station pressure readings were taken, but not recorded. These were monitoring readings only.

- 34 -

- 35 -

TABLE 10: Styrene Source Test Summary

STYRENE EMISSION RATES & EMISSION FACTORS DAY 1 - April 25, 2001

HourlyAverage Reported Actual Period Styrene StyrenePeriod Styrene Time Styrene Emission Monomer EmissionFlow Rate Conc. Period Emissions Rate Usage Factor

Source (dscfm) (ppmv) (hr) (lb styrene) (lb/hr) (lb styrene) (lb/lb styrene lb/lbresin

UST 1-8’ 3,512 121.9 8.00 55.6 7.0 468.7 11.9% 5.2%UST 2-8’ 3,825 114.7 8.00 57.0 7.1 500.5 11.4% 5.0%UST 3-6’ 3,003 97.9 8.00 38.2 4.8 341.8 11.2% 4.9%UST 4-10’ 9,577 73.8 8.00 91.8 11.5 722.8 12.7% 5.5%

Totall Emission Rate 30.3 2,003.7 Avg. of 4 runs 5.14%

STYRENE EMISSION RATES & EMISSION FACTORS DAY 2 - April 26, 2001

HourlyAverage Reported Actual Period Styrene StyrenePeriod Styrene Time Styrene Emission Monomer EmissionFlow Rate Conc. Period Emissions Rate Usage Factor

Source (dscfm) (ppmv) (hr) (lb styrene) (lb/hr) (lb styrene) (lb/lb styrene lb/lbresin

UST 1-8’ 3,372 84.7 8.00 37.1 4.6 441.2 8.4% 3.7%UST 2-8’ 3,589 60.5 8.00 28.2 3.5 566.5 5.0% 2.2%UST 3-6’ 2,805 78.5 8.00 28.6 3.6 350.4 8.2% 3.6%UST 4-10’ 9,506 40.4 8.00 49.9 6.2 735.4 6.8% 3.0%

Totall Emission Rate 18.0 2,093.4 Avg. of 4 runs 3.09%

Avg. of 8 runs 4.11%CFA UEF factor 5.20%% of UEF 79.1%

- 36 -

Revalidation of Emission Rates from Non-Atomizing Spray EquipmentLarry Craigie, CCT

The advent of flow coater or multi-orifice application equipment went a long way towards reducing emissions generatedduring the lamination process. This technology made it to the market place just as the CFA emissions testing program wascoming to an end at the laboratories at Dow Chemical. The program was extended and data was generated which wasused to develop the Unified Emission Factors for mechanical non-atomized application. The technology did not work for allapplications but for those that were able to use the mufti- orifice equipment, they were able to claim reductions of 30 to 60per cent depending upon the styrene content of the resin being used.

Over the last few years, equipment manufacturers have developed new non- atomizing equipment and made improvementsso that it could be used in more applications, thus giving more fabricators the opportunity to use equipment that significantlylowers emissions. The improvements in the non-atomizing application equipment can be compared to the advances incomputer technology. The first computers were massive in size, consuming large rooms and enormous amounts of energy,where today’s computer’s are more powerful, fit in a briefcase and run on batteries. The internal speed of early personalcomputers was 4 million hertz, and today they are available at over 2 billion hertz, over 50,000 times as fast. But even moreto the point, the new computers that can be held in your hand do not look anything like the massive computers of the 1950’sand 1960’s. In the composites industry, the spray patterns from the new non-atomizing application equipment do not looklike the patterns from original multi-orifice application equipment. To an untrained eye, the spray patterns from new non-atomizing equipment look very similar to a spray pattern from typical atomizing application equipment. Yet, the equipmentis non-atomizing and provides the benefits of more utility and maintains or improves emission reductions.

In the case of faster and smaller computers, it was easy to measure the improvements in capabilities. But with laminationequipment, emission reduction is not as easily determined. The application equipment manufacturers published dataindicated that emission reductions are as good as or better than from mufti-orifice/flow coater equipment. But where is theproof?

When we realized that independent data had not been generated to support the low emission claims of new impingementand single orifice non-atomizing equipment, plans were made to develop the required data. The equipment manufacturershad spent considerable time and dollar’s developing the new non-atomizing equipment and had tested them at laboratoriessuch as CMTI. But there were problems with the data. Most of the data generated used a single resin, thus data was notavailable to generate a series of emission factors similar to the information in the Unified Emission Factor table. There wasnot data from a range of resins (HAP contents 25 per cent - 48 per cent) that could he used to evaluate an emission factormodel and back-up the claims of low emissions.

Atomized Spray Application

One of the most widely used pollution prevention technologies in open molding is based on non-atomizing applicationequipment. Fabricators will be depending upon non-atomized application to meet theexpected MACT requirements. The concern is that an air quality inspector might notunderstand how equipment that produces a pattern similar to an atomized pattern canproduce such low emission levels. If there is confusion about the technology, the optionto use it may be lost. It was decided that the data supporting this emission reductiontechnology must be readily available.

The definition of non-atomized application has evolved also. It started out as “maintaininga continuous stream of resin three inches from the gun”. This would have been verydifficult for an agent to enforce. It is difficult to observe the spray pattern when applyinggel coat. When spray/chopping, the view of the spray pattern is further clouded.

- 37 -

Non-Atomized Spray Application

Now, the following definition has been proposed to the EPA:

Mechanical non-atomized application means the use of a device for applying resin orgel coat that a) has been provided by the device manufacturer with documentationshowing that use of the device results in HAP emissions that are no greater than theemissions predicted by the applicable non-atomized application equation(s) in Table Ito Subpart WWWW of Part 63; and b) is operated according to the manufacturer’sdirections, including instructions to prevent the operation of the device at excessivespray pressures.

Table I to subpart WWVVW of Part 63 is the United Emissions Factors Table.

Test Development

Rob Haberlein of Engineering Consulting Services set up a test design that would generate the required data with aminimum number of individual tests. A call went out to suppliers and equipment manufacturers for funds, equipment,manpower and materials to conduct the study. GS Manufacturing and Magnum Venus Products graciously agreed tosupply the needed funds along with equipment and a technician to conduct the tests. Cook Composite Polymers, DowChemical, and InterPlastic Corporation provided the laminating resins. PPG supplied the gun roving for the tests.

The testing was conducted at the Indiana Clean Manufacturing Technology & Safe Materials Institute at Purdue University.

CMTI maintains the Coatings Application Research Laboratory (CARL) under the direction of Jim Noonan and Jean Hall.This laboratory is a comprehensive research and development facility to investigate emission technologies. All of theemissions testing associated with this test program was conducted at the CARL facility.

The CARL facility contains a spray booth enclosure that is ventilated through an exhaust stack. The spray booth enclosuremeets the EPA Method 204 criteria for a permanent total enclosure. Therefore, 100% of the emissions released inside thebooth are captured. The exhaust air, flow rate, styrene concentration in the booth exhaust, background concentration in thesupply air to the booth, exhaust air temperature, exhaust air humidity, and resin delivery rate are measured and recordedby a computerized data acquisition system that computes the corresponding styrene emission rate.

Laminating Resin Selection

The test setup at the CARL facility utilizes EPA Method 25A, which relies upon a flame ionization detector (FID) instrumentto measure the styrene concentration in the exhaust flow. However, this total organic analyzer will detect all organiccompounds (those containing carbon molecules) in the exhaust, and could falsely report these other compounds as styreneemissions. For this reason, the resin formulations used for the testing only contained styrene monomer, and did not containany monomer’s such as vinyl toluene.

Test Plan Description

The procedures detailed in the test protocol document entitled ‘CFA Styrene Emissions Test Protocol & Facility CertificationProcedures, Revision 2.1’ published by the CFA on November 18, 1998 was followed by CMTI to determine the styreneemission rate for each test run. The completed test matrix of the test runs is shown in Table 1.

- 38 -

Testing

The run parameters established included resin flow rate of 4 lbs/ minute, gel time of 15 minutes glass content of 30 percent. Tip pressures were adjusted to obtain a good fan pattern for each resin. After spray- up was completed, the laminatewas compacted (rolled) for four minutes. The gun operator was instructed to employ controlled spraying techniques, gunheld 12 to 18 inches from the mold and maintained at a near 900 angle to the surface. Spray was to cover the mold surfaceand up to 50% of the flange face surrounding the mold. Both the atomized and non-atomized application tests used thesame run and application parameters.

Control Tests

The first order was to establish that the operators could duplicate the data from the base line study. If similar results fromthe base line study were generated, then this would verify that the procedures and equipment were working property.

The control was designated as a 35 percent styrene bisphenol-A vinyl ester. The styrene content of the tested resin wasactually 34.0%. According to the UEF model, the emissions expected from the atomized spray of this resin should be 97pounds of emissions for every ton of resin applied. The results from the testing at CMTI gave emission values of 79 to 87pounds of emission per ton of product sprayed. This is well with the experimental range from the base line study. Theresults from all of the atomized application tests are found in Table 2.

Non Atomized Testing Results

A total of twenty-five runs were conducted during the testing program. Five runs were not used in the analysis for a varietyof reasons. There were 8 atomized application runs and 13 Non-atomized runs that were included in the final analysis.Table 3 contains a list of the excluded tests and the rationale. The emission results from the non- atomizing tests are foundin Table 4.

Graph 1 is the best way to explain how the testing portion of the proposed definition of non-atomized application is supposedto work. The red line represents the values in the UEF. Per the definition, for equipment to be classified as non-atomizing,data from the testing of the gun when fit to a curve, the curve must fall on or below the UEF curve for non-atomizedapplication.

In this case, all the data was below the values in the UEF. And when all of the data was combined, the results indicate betterperformance overall than predicted by the UEF. The data did not indicate that the emissions would be significantly less thanpredicted by the UEF. In some cases, the emissions were 20 per cent lower than predicted by the UEF, but in others it wasonly a 2 or 3 percentage drop.

Any equipment manufacturer that possesses this type of data should be able to state that their equipment meets thedefinition of non- atomizing equipment. For a shop to claim that they are spraying with non-atomizing equipment, they mustbe operating the equipment according to the manufacturer’s directions, including instructions to prevent the operation ofthe device at excessive spray pressures.

- 39 -

The equipment manufacturers have made equipment capable of non-atomized application. Now it is up to the user tofollow the recommended procedures of the equipment manufacturers to gain the advantage of low emissions. AtCOMPOSITES 2002, you will have the opportunity to learn how to do your part to employ non-atomized application. Therewill be demonstrations by several equipment manufacturers on how to set up spray equipment to meet the non-atomizingdefinition. Items to be covered include, tip selection, how to dial in the optimum pressure and proper use of air assist. Alsothe manufacturers will demonstrate what will happen if the equipment has not been adjusted properly. You will see theresults of proper and improper equipment set up and learn how to detect if the operating instructions are not being followedand the equipment is atomizing the resin.

- 40 -

Table 1 Completed Test Design (by run number)

Styrene Content 25 28 29 34 38 44 46 47

Atomized 2 7 4,6,20 16,17

Non-Atomized A 21 3 19,25 24 18

Non-Atomized B 11 8 15 12 13 22,23

Table 2 Atomized Application

Poundsof Resin Percent Emissions/

Test # Applied Styrene LB Resin

3 13.22 25.25 3.20%

4 13.99 34 3.87%

6 13.44 34 4.47%

7 12.67 29.17 4.35%

16 12.58 46.3 5.94%

17 13.08 46.3 7.59%

20 13.10 34.009 4.47%

Table 3 Excluded TestsRun Exclusion Reason1 Technician did not follow prescribed spray up sequence

5 10 prolonged glass jams

9 Aceton spilled in the chamber

10 Two resins inadvertently mixed yielding unknown styrene content

14 Computer locked up, data lost

- 41 -

Table 4 Non-Atomized ApplicationPoundsof Resin Percent Emissions/

Test # Applied Styrene LB Resin

2 12.30 28.25 2.52%

8 12.53 29.17 2.59%

11 10.62 25.51 2.52%

12 11.88 38.87 3.42%

13 13.70 44.56 5.20%

15 11.94 34 3.20%

18 12.09 46.3 5.51%

19 13.10 34.009 3.23%

21 11.71 25.51 2.47%

22 12.78 47.03 4.80%

23 12.70 47.03 4.71%

24 11.72 38.87 3.72%

25 13.43 34 3.15%

March 17, 2020 Sabrina Coty-Butler Coatings Team Manager – Mechanical/Coatings New Source Review Permits Section Texas Commission on Environmental Quality (TCEQ) 12100 Park 35 Circle Austin, TX 78753 Re: Majek Boatworks, Inc. CN601320245; RN102595410 Minor New Source Review Permit Application Coatings - Paint Emission Calculation and Impacts Analysis Spreadsheet Dear Ms. Sabrina Coty-Butler: Majek Boatworks, Inc. (Majek) is proposing to permit the operation of a fiberglass boat manufacturing facility at 7001 Saluki St. in Corpus Christi, TX (Facility). The application was submitted to the Texas Commission on Environmental Quality (TCEQ) via the State of Texas Environmental Electronic Reporting System (STEERS) in accordance with the provisions of 30 Texas Administrative Code (TAC) Chapter 116, Subchapter B: NSR Permit. Although Majek is a fiberglass manufacturing facility, the application was assigned to the mechanical and coatings division of the TCEQ Air Permits Division. Per the request of the permit reviewer, Majek completed a modified version of the TCEQ developed workbook: Coatings – Paint Emission Calculation and Impacts Analysis Spreadsheet. Upon the initial submittal of the NSR application, ALL4 LLC (ALL4), on behalf of Majek, reviewed the workbook with a member of the coatings review team. It was determined that the boat manufacturing process, although not a painting or coating process, must edit the workbook and complete it to the best of our ability. The tabs described below were marked as required while the remaining tabs were advised to be hidden. This letter provides a more in-depth description of why and how Majek was advised to complete the workbook and the modifications that were implemented. Fiberglass Boat Manufacturing – Open Mold Process Catalyzed thermosetting resins and polyester resin gel coats are used to manufacture fiberglass boats in an open molding process. The gel coat and resin materials are layered into an open mold where they catalytically harden into a composite structure, taking the rigid shape of the open mold. The gel coat is the first layer, with subsequent layers of resin and reinforced fiberglass mat. The gel coat and resin are layered using handheld applicators. The process of layering raw materials into an open mold is therefore associated with the manufacturing rigid structures, and not the painting or coating of a product. The process related emissions are volatile organic compounds (VOC), including styrene and methyl methacrylate (MMA). The resins contain styrene and the gel coats contain both compounds. Styrene and MMA are monomers, which indicates that they react with

of 3 Majek Boatworks, Inc. March 2020

themselves or similar compounds by a cross linking reaction, thereby creating the cured rigid structure. A fraction of each monomer compound evaporates during the layering and curing process. Unlike surface coating, not all the styrene and MMA evaporate because the majority of these compounds are bound in the cross-linking reaction between polymer molecules in the hardened resin or gel coat and become the finished product. Industry-specific emissions factors have been developed and are commonly used to calculate emissions of VOC associated with fiberglass boat manufacturing. The emission factors used in the application are provided from the American National Standards Institute (ANSI) developed reference guide for emission factors of fiberglass boat manufacturing called “Unified Emission Factors for Open Molding Composites.” This document provides styrene and MMA emissions factors based on the styrene content of the gel coat and the application method. Further details regarding emissions and emissions calculations are included in the application package. Approach to Workbook Completion Because fiberglass boat manufacturing is not painting, there are numerous worksheet tabs that are not amenable to the process and were therefore not completed. The highlighted tabs at the front of the workbook were completed, while the others were not, based on guidance provided by the TCEQ permit writer. Coatings Properties - Although the resins and gel coats are not paints, this tab was completed in entirety. Because the resins and gel coats are not paints and the components of the catalyst becomes part of the composite matrix, the materials were entered without mixing data. Superpaint Formulation – Although the resins and gel coats are not paints, this tab was completed in entirety. The only nuance was that the vendor was unable to provide the level of detail that an air quality data sheet would provide. The safety data sheets (SDS) were provided and used to enter the ingredients. This resulted in many chemicals not having a complete ingredient list, but as the only volatile compounds are known and provided in this section, Majek believed this to be the best option for completing this tab. All other compounds not listed were unavailable and entirely contained in the structure of the product upon completion.

of 3 Majek Boatworks, Inc. March 2020

Superthinner formulation - Although no painting occurs at the facility, this tab was completed in entirety. Acetone is the only chemical species used as a cleanup solvent and is not added to the resin or gel coat materials. It is volatile but is exempt from inclusion in facility wide emissions per 30 TAC 106.433(4). Species Impacts - This tab was completed in a different manner than the workbook design, per TCEQ guidance. The emissions were hard-entered based on emissions calculations that were completed using industry-specific emissions factors in a separate location. The industry-specific emissions factors for fiberglass boat manufacturing could not be built into this spreadsheet. Emissions calculations and associated documentation are provided in the respective section of the NSR application package. Screen3 Inputs and Model Results - These tabs were completed as required. NAAQS Analysis - This tab was intentionally left blank. Styrene and MMA are not criteria pollutants and therefore do not require NAAQS modeling. Note that a NAAQS analysis was conducted for particulate matter (PM) emissions associated with the finishing operations at the facility. Should you have any questions related to this submittal, or require additional information, please contact Meghan Skemp at [email protected] or 281-937-7553 x307 or me at [email protected] or 361-991-3102. Sincerely, Majek Boatworks, Inc. Jimmy Majek Jimmy Majek Owner and Operator cc: Meghan Skemp – ALL4


mailto:jimmy@majek

ATTACHMENT A COATINGS – PAINT EMISSION CALCULATION AND IMPACTS

ANALYSIS SPREADSHEET

Vendor Name Coating Name Coating Type Flash Data1 Components as Received

Components as Received



Components as Received Mixing Data As Mixed and

Thinned As Mixed and




Thinned

Vendor Coating Name Coating Type Flash Data1 Density(lb/gal)

VOC Content(lb/gal)

Exempt Solvent Content(lb/gal)

Water Content(lb/gal)

Solids Content(lb/gal)

Mixing RatioPart A/ Part B/ Part C/ Thinner

Density(lb/gal)

VOC Content(lb/gal)

Exempt Solvent Content(lb/gal)

Water Content(lb/gal)

Solids Content(lb/gal)

A. Schulman Majek Gray Ultrashield not a coating 9.00 3.60 1.00 9.00 3.60 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

A. Schulman NPG ISO W/UV Neutral Tint Base not a coating 9.00 5.85 1.00 10.85 3.83 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

Lyondellbasell Battleship Gray Ultrashield not a coating 9.00 6.30 1.00 9.00 6.30 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

Lyondellbasell 81-110580 Classic Bone not a coating 9.00 3.60 1.00 9.00 3.60 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

HK Research CorporationHDS-6700 Indigo not a coating 9.00 3.78 1.00 9.00 3.78 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC XC5324 PO3 Orange VE Tooling not a coating 9.00 3.50 1.00 9.00 3.50 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

A. Schulman 82-810130 Black Ultrashield not a coating 9.00 3.15 1.00 9.00 3.15 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

Lyondellbasell Charcoal Gray Ultrashield not a coating 9.00 6.30 1.00 9.00 6.30 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

A. Schulman 81-310180-Q Classic Blue Q not a coating 9.00 5.85 1.00 9.00 5.85 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

Lyondellbasell 82-103960 White U.S. Gelcoat not a coating 9.00 6.30 1.00 9.00 6.30 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

Duratec Grey Surface Primer not a coating 10.85 3.83 1.00 10.85 3.83 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC H864-MAI-25 not a coating 9.18 3.12 1.00 9.18 3.12 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC R937-UPF-11 not a coating 9.18 3.12 1.00 9.18 3.12 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC LPT-68000 not a coating 9.18 3.57 1.00 9.18 3.57 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC XC-2089 not a coating 9.18 3.11 1.00 9.18 3.11 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC R049-CPF-14 not a coating 9.18 3.83 1.00 9.18 3.83 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC H036-AKR-25 not a coating 9.18 3.11 1.00 9.18 3.11 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AOC, LLC H864-ICA-30 not a coating 9.18 3.16 1.00 9.18 3.16 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

AkzoNobel CADOX L-50A Catalyst not a coating 8.35 0.42 1.00 8.35 0.42 0.00 0.00 0.00N/A N/A N/A N/A N/AN/A N/A N/A N/A N/A

0.00 10.85 6.30 0.00 0.00 0.00 N/A 10.85 6.30 0.00 0.00 0.000.00 N/A N/A N/A N/A N/A N/A 8.35 0.42 0.00 0.00 0.00

1First hour flash fraction based on site specific testing using TCEQ protocol or Figure 655 (AP-40) flash curves

MaximumMinimum

Press TAB to move through input areas. Press UP or DOWN arrow in column A to read through the document.

Table 1Coatings Properties

Coating Name Majek Gray Ultrashield Part B As Mixed

NPG ISO W/UV Neutral Tint

BasePart B As Mixed Battleship Gray

Ultrashield Part B Part C As Mixed 81-110580 Classic Bone Part B As Mixed HDS-6700

Indigo Part B As MixedXC5324 PO3 Orange VE

ToolingPart B As Mixed

82-810130 Black

UltrashieldPart B As Mixed Charcoal Gray

Ultrashield Part B As Mixed 81-310180-Q Classic Blue Q Part B As Mixed

82-103960 White U.S.

GelcoatPart B As Mixed Grey Surface

Primer Part B As Mixed H864-MAI-25 Part B As

MixedR937-

UPF-11 Part B As Mixed

LPT-68000 Part B As

Mixed XC-2089 Part B As Mixed

R049-CPF-14 Part B As

MixedH036-

AKR-25 Part B As Mixed

H864-ICA-30 Part B As

Mixed

CADOX L-50A

CatalystPart B As

Mixed

Maximum of All Product

sMix Ratio 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 6.30 1.00 0.00 0.00 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 0.00 N/A 1.00 N/A N/A N/A

Density (lb/gal) 9.00 0.00 N/A 9.00 0.00 N/A 9.00 0.00 0.00 N/A 9.00 0.00 N/A 9.00 0.00 N/A 9.00 0.00 N/A 9.00 0.00 N/A 9.00 0.00 N/A 9.00 0.00 N/A 9.00 0.00 N/A 10.85 0.00 N/A 9.18 0.00 N/A 9.18 0.00 N/A 9.18 0.00 N/A 9.18 0.00 N/A 9.18 0.00 N/A 9.18 0.00 N/A 9.18 0.00 N/A 0.00 0.00 N/A N/A

Chemical Abstract

Service No. (CAS No.) Chemical Species

Volatile, Particulate, or

Not Emitted(V, P, NE) HAP? (Yes/No)

Carbomastic 15 PART AWeight %

Carbomastic 15 PART BWeight %

Carbomastic 15 as Mixed

Weight %

Carbothane 134 HG PART A

Weight %

Urethane 811 Converter

PART BWeight %

Carbothane 134 HG as

MixedWeight %

Carbozinc 11 HS PART AWeight %

Carbozinc 11 HS PART CWeight %

Zinc Filler PART B

Weight %

Carbozinc 11 HS as Mixed

Weight %

Carboguard 890 LT PART A

Weight %

Carboguard 890 LT PART B

Weight %

Carboguard 890 LT as

MixedWeight %

Bitumastic 300M PART A

Weight %

Bitumastic 300M PART B

Weight %

Bitumastic 300M as Mixed

Weight %

Macropoxy 646 PART A

Weight %

Macropoxy 646 PART B

Weight %

Macropoxy 646 as MixedWeight %

Dura Plate 235 PART A

Weight %

Dura Plate 235 PART B

Weight %

Dura Plate 235 as MixedWeight %

Interfine 979 White PART A

Weight %

Interfine 979 White PART B

Weight %

Interfine 979 White as Mixed

Weight %

Interseal 670 HS Part AWeight %

Interseal 670 HS Part BWeight %

Interseal 670 HS as Mixed

Weight %

Interseal 670 HS Part AWeight %

Interseal 670 HS Part BWeight

%


Weight % Weight %


%


Weight %

Interseal 670 HS Part

AWeight %

Interseal 670 HS Part

BWeight %

Interseal 670 HS

as MixedWeight

%

Interseal 670 HS Part AWeight

%


%

Interseal 670 HS

as MixedWeight

%


%


%

Interseal 670 HS

as MixedWeight

%


%


%

Interseal 670 HS

as MixedWeight

%


%


%

Interseal 670 HS

as MixedWeight

%


%


%

Interseal 670 HS

as MixedWeight

%


%


%

Interseal 670 HS

as MixedWeight

%


%


%

Interseal 670 HS

as MixedWeight

%

Weight %

Weight %

100-42-5 Styrene V Yes 30.0 30.0000 60.0000 60.0000 60.0000 60.0000 30.0000 30.0000 38.0000 38.0000 38.9000 38.9000 25.0000 25.0000 60.0000 60.0000 60.0000 60.0000 60.0000 60.0000 21.0000 21.0000 34.0000 34.0000 34.0000 34.0000 36.9000 36.9000 33.5000 33.5000 39.7000 39.7000 33.9000 33.9000 34.0000 34.0000 60.000013463-67-7 Titanium Dioxide NE No 30.0 30.0000 0.0000 10.0000 10.0000 30.0000 30.0000 0.0000 0.0000 0.0000 5.0000 5.0000 0.0000 30.0000 30.0000 1.0000 1.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 30.000014807-96-6 Talc NE No 10.0 10.0000 30.0000 30.0000 10.0000 10.0000 10.0000 10.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 35.0000 35.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 35.000080-62-6 Methyl Methacrylate V Yes 10.0 10.0000 5.0000 5.0000 10.0000 10.0000 10.0000 10.0000 4.0000 4.0000 0.0000 10.0000 10.0000 10.0000 10.0000 5.0000 5.0000 10.0000 10.0000 0.0000 0.0000 0.0000 2.0000 2.0000 0.0000 2.0000 2.0000 0.0000 0.0000 10.00001317-65-3 Limestone NE No 5.0 5.0000 5.0000 5.0000 5.0000 5.0000 5.0000 5.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5.0000 5.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5.00007631-86-9 Silicon Dioxide Amorph NE No 5.0 5.0000 5.0000 5.0000 5.0000 5.0000 5.0000 5.0000 0.0000 0.0000 5.0000 5.0000 5.0000 5.0000 5.0000 5.0000 5.0000 5.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5.000041556-26-7 bis(1,2,2,6,6-pentamethyl-4-piperidyl) sebacate NE No 1.0 1.0000 0.0000 1.0000 1.0000 0.0000 0.0000 0.0000 0.0000 1.0000 1.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.0000136-52-7 Hexanoic acid NE No 1.0 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.3000 0.3000 1.0000 1.0000 0.0000 1.0000 1.0000 0.0000 0.5000 0.5000 0.0000 0.0000 0.0000 0.0000 0.3000 0.3000 0.3000 0.3000 0.3000 0.3000 1.00003164-85-0 potassium 2-ethylhexanoate NE No 1.0 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.3000 0.3000 0.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.00001317-61-9 Iron Oxide Black NE No 0.0000 0.0000 5.0000 5.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5.000015625-89-5 Acrylic Polymer NE No 0.0000 0.0000 0.0000 0.0000 8.0000 8.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 8.0000112945-52-5 Silicon Dioxide NE No 0.0000 0.0000 0.0000 0.0000 7.0000 7.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.0000N/A Unsaturated Polyester Resin NE No 0.0000 0.0000 0.0000 0.0000 52.0000 52.0000 0.0000 0.0000 0.0000 0.0000 0.0000 29.0000 29.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 52.000025013-15-4 Vinyltoluene NE No 0.0000 0.0000 0.0000 0.0000 0.0000 3.0000 3.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 3.000085204-10-0 2-Butenedioic Acid NE No 0.0000 0.0000 0.0000 0.0000 0.0000 1.0000 1.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.000082919-37-7 Decanedioic Acid NE No 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.0000 1.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.000078-93-3 Methyl Ethyl Ketone V Yes 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 13.0000 13.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5.0000 13.000067-56-1 Methanol V Yes 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.5000 0.5000 0.0000 0.0000 0.0000 0.4000 0.4000 0.0000 0.0000 0.4000 0.4000 0.500098-83-9 2-Phenylpropene NE No 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.4000 1.4000 1.3000 1.3000 0.0000 1.4000 1.4000 0.0000 0.0000 0.0000 1.4000972-50-4 N-methyl-2-pyrrolidone NE No 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.3000 0.3000 0.0000 0.0000 0.3000 0.3000 0.30001338-23-4 Methyl Ethyl Ketone peroxide NE No 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 50.0000 0.00007722-84-1 Hydrogen Peroxide Solution NE No 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5.0000 0.0000

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.00000.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Totalsa N/A N/A N/A 93.00 0.00 93.00 107.00 0.00 107.00 108.00 0.00 0.00 108.00 92.00 0.00 92.00 109.00 0.00 109.00 43.50 0.00 43.50 41.00 0.00 41.00 83.00 0.00 83.00 72.00 0.00 72.00 111.00 0.00 111.00 100.00 0.00 100.00 35.40 0.00 35.40 35.30 0.00 35.30 38.90 0.00 38.90 35.60 0.00 35.60 42.00 0.00 42.00 34.20 0.00 34.20 35.00 0.00 35.00 60.00 0.00 0.00 N/A

Table 2Coatings Speciation - Paint

a The liquid materials used to manufacture fiberglass boats include catalyzed polyester resins (gelcoat) and catalyzed thermosetting liquid resin (resin)at the facility are not coatings. The vendor provided information did not include the level of detail in an air quality data sheet that contains the entire chemical makeup. The safety data sheets (SDS) were used to quantify the amount of pertinent chemicals, which is the reason the percentages do not equal 100%.

This table identifies all species in the coatings and classifies the species as volatiles (V), particulates (P) or as not emitted (NE). CAS numbers must be included, if available.

After the weight percentages (weight fractions) of the species are entered the table sums them to determine if complete speciation has been represented. The sum of the weight percentages needs to equal 100% or greater. The use of normalization to achieve 100% speciation is not acceptable. Coating vendors may need to be contacted to achieve this level of detail since many SDS do not include full speciation. However, many vendors have Air Quality Data Sheets (AQDS) that will provide complete information.

The table also identifies the maximum weight % of each species. The data should be entered as the percentage value from the data sheet. If the data sheet value is 15%, 15 should be entered. Using 0.15 is not correct. Do not change the cell format to %. Leave it as a number. This value is used throughout the remainder of the calculations since it represents the worst-case weight % that can be found in any coating. The resulting list of species and maximum weight fractions produces a “super paint”. This approach is significantly less labor intensive than trying to estimate emissions paint by paint and selecting the highest species emission rate at the end.

Chemical Abstract

Service No. (CAS No.) Chemical Species

Volatile, Particulate, or Not Emitted

(V, P, NE)

Thinner

Weight %

Thinner

Weight %

Thinner

Weight %

Thinner

Weight %

Thinner

Weight %

Solvent

Weight %

Solvent

Weight %

Solvent

Weight %

Solvent

Weight %Maximum Weight %

67-64-1 Acetone V 100.000 100.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.0000.000

N/A N/A Total 0.00 0.00 0.00 0.00 0.00 100.00 0.00 0.00 0.00 N/A

Press TAB to move through input areas. Press UP or DOWN arrow in column A to read through the document.

Table 3Coatings Speciation - Thinner

This table identifies all species in the solvents and classifies the species as volatiles (V), particulates (P) or as not emitted (NE). CAS numbers must be included, if available.

After the weight percentages (weight fractions) of the species are entered the table sums them to determine if complete speciation has been represented. The sum of the weight percentages needs to equal 100% or greater. The use of normalization to achieve 100% speciation is not acceptable. Solvent vendors may need to be contacted to achieve this level of detail since many SDS do not include full speciation. However, many vendors have Air Quality Data Sheets (AQDS) that will provide complete information.

The table also identifies the maximum weight % of each species. If the data sheet value is 15%, 15 should be entered. Using 0.15 is not correct. Do not change the cell format to %. Leave it as a number. This value is used throughout the remainder of the calculations since it represents the worst-case weight % that can be found in any solvent. The resulting list of species and maximum weight fractions produces a “super thinner”. This approach is significantly less labor intensive than trying to estimate emissions solvent by solvent and selecting the highest species emission rate at the end.

of 9

EPN/Source Grouping Worst-Case Modeled Unit Impact (µg/m3/lb/hr)SPRAYBOOTH 9.72SP1 9.73SP2 15.65 PROD1 9.71PROD2 9.71

CAS NO. Species Name INGREDIENTTYPE SPRAYBOOTH EPN BOOTH

EPN SPECIAL SP1 EPN RTO-1EPN RTO-1 SP2 EPN PRIME

EPN MTL PRIME PROD1 EPN TOPCOATEPN MTL TOP PROD2b EPN OVEN

EPN OVEN NA NA NA

CAS No. Species Name Volatile, Particulate, or Not Emitted (V, P, NE)

Emission Ratea

(LB/HR)GLCs

(ug/m³)Emission Rate

(LB/HR)GLCs


(LB/HR)GLCs


(LB/HR)GLCs


(LB/HR)GLCs

(ug/m³)

20181-Hour

ESL(ug/m³)

Hourly Off-SiteGLCs

(ug/m³)

Cumulative Fraction of Hourly ESL

100-42-5 Styrene V 3.7600 36.5434 0.6912 6.7272 0.6912 10.8169 2.7647 26.8536 2.7647 26.8536 110 107.795 0.980013463-67-7 Titanium Dioxide NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 50 0.000 0.000014807-96-6 Talc NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 20 0.000 0.000080-62-6 Methyl Methacrylate V 0.5400 5.2483 0.0425 0.4139 0.0425 0.6655 0.0170 0.1652 0.0170 0.0000 860 6.493 0.00751317-65-3 Limestone NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Must Meet NAAQS 0.000 See NAAQS Analysis7631-86-9 Silicon Dioxide Amorph NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 27 0.000 0.000041556-26-7 bis(1,2,2,6,6-pentamethyl-4-piperidyl) sebacate NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 100 0.000 0.0000136-52-7 Hexanoic acid NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.21 0.000 0.00003164-85-0 potassium 2-ethylhexanoate NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Must Meet NAAQS 0.000 See NAAQS Analysis1317-61-9 Iron Oxide Black NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Must Meet NAAQS 0.000 See NAAQS Analysis15625-89-5 Acrylic Polymer NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 10 0.000 0.0000112945-52-5 Silicon Dioxide NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 27 0.000 0.0000N/A Unsaturated Polyester Resin NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2 0.000 0.000025013-15-4 Vinyltoluene NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2420 0.000 0.000085204-10-0 2-Butenedioic Acid NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2 0.000 0.000082919-37-7 Decanedioic Acid NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 100 0.000 0.000078-93-3 Methyl Ethyl Ketone V 0.0150 0.1458 0.0060 0.0584 0.0060 0.0939 0.0240 0.2331 0.0240 0.0000 18000 0.531 0.000067-56-1 Methanol V 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 3900 0.000 0.000098-83-9 2-Phenylpropene NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 250 0.000 0.0000972-50-4 N-methyl-2-pyrrolidone NE 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2 0.000 0.00001338-23-4 Methyl ethyl ketone peroxide NE 1.0000 9.7190 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 15 9.719 0.64797722-84-1 hydrogen peroxide NE 2.0000 19.4380 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 14 19.438 1.3884

2 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.00002 0.0000

0.0000 0.0000 2 0.00000.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.000

a The emissions were calculated using emission factors developed by the American National Standards Institute (ANSI) specifically for open molding fiberglass manufacturing. For a more detailed explanation of calculations, the full guidance is included in the New Source Review (NSR) application submitted through the State of Texas Electronic Emissions Reporting System (STEERS).b Majek Boats manufacturing site contains one other EPN not included in this spreadsheet. The finishing operations consist of sanding the boats and using a dust collection system to remove particulate matter. These emissions calculations for the finishing operations are included in the NSR application packaged submitted via STEERS.

Table 15Maximum Speciated VOC and PM Off-Site Cumulative GLCs (ug/m3)

This table brings together the species emission rates from each source, the dispersion modeling results, and the effects screening levels (ESLs) from the TAMIS database to provide the off-property concentrations used in the impacts analysis.

Impacts are determined by multiplying the species emission rate (lb/hr) for a source by the Unit Impact Multiplier (µg/m3 per lb/hr) (UIM) to obtain a maximum off-property concentration. The impacts for all of the sources for a species are then summed and compared to the ESL.

ESL values and the basis for an ESL are extracted from the TAMIS Database retrieval using the VLOOKUP function. It should be noted that not all species have a numerical ESL. Species of limited concern have an ESL of “Must Meet NAAQS”. This means that no species-specific analysis is to be conducted as long as the project increase is below the Significant Impact Level (SIL) for PM10 and PM2.5 or the site wide impacts plus an

If a species does not have an ESL, no impacts analysis is required. See the Modeling and Effects Review Applicability guidnce document, Step 0.

Please remember that ESLs are guidelines and not standards. If an ESL is exceeded it means that further review is required by the TCEQ Toxicology Division.

Once all the data is entered in the cells identified as beige cells, the emission rates and GLCs are updated. Since the formulas reference the data cells identified as beige cells, no changes need to be made to the remainder of the spreadsheet.

CRA Coatings Workbook 3-6-2020; Species Impacts Page 74 of 95 Updated 4/7/2020

of 9

NA NA NA NA NA NA NA

Less than Hourly ESL?

(Y/N)

2018 Hourly ESL Basis(Health or Odor)

2018 Annual ESL

(ug/m³)

Annual Off-Site GLCs

(ug/m³)

Cumulative Fraction of Annual ESL

Less than Annual ESL?

(Y/N)

2018 Annual ESL Basis(Health or Odor)

Yes Odor 140 8.624 0.062 Yes HealthYes Health 5 0.000 0.000 Yes HealthYes Health 2 0.000 0.000 Yes HealthYes Odor 210 0.519 0.002 Yes HealthYes Health Must Meet NAAQ 0.000 See NAAQS Analysis Yes HealthYes Health 2 0.000 0.000 Yes HealthYes Health 10 0.000 0.000 Yes HealthYes Health 0.0017 0.000 0.000 Yes HealthYes Health Must Meet NAAQ 0.000 See NAAQS Analysis Yes HealthYes Health Must Meet NAAQ 0.000 See NAAQS Analysis Yes HealthYes Health 1 0.000 0.000 Yes HealthYes Health 2 0.000 0.000 Yes HealthYes NA 0.02 0.000 0.000 Yes NAYes Health 242 0.000 0.000 Yes HealthYes NA 0.02 0.000 0.000 Yes NAYes Health 10 0.000 0.000 Yes HealthYes Health 2600 0.042 0.000 Yes HealthYes Health 2100 0.000 0.000 Yes HealthYes Odor 48 0.000 0.000 Yes HealthYes NA 0.02 0.000 0.000 Yes NAYes Health 1.5 0.778 0.518 Yes HealthNo Health 1.4 1.555 1.111 No HealthNo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo NA 0.02 No NANo 0.000 No

n appropriate monitored background concentration are less than the PM10 and PM2.5 24-hour standards and the PM2.5 annual standard.

CRA Coatings Workbook 3-6-2020; Species Impacts Page 74 of 95 Updated 4/7/2020

Sourcea Source EPN Source Type Zone X Coordinate

(UTM meters)Y Coordinate (UTM meters)

Emission Rate

(lbs/hr)

Stack/ Release Height 3

(ft)

Stack Inside Diameter 1

(ft)

Stack Flow Rate (cfm)

Stack Flow Rate

(acfm)

Stack Exit Velocity 2

(ft/s)

Stack Exit

Temperature(°F)

Dispersion Coefficient

Urban/Rural Option

Building Height

(ft)

Building Width

(ft)

Building Length

(ft)

L (ft)

Region of Building Influence

(5L) (ft)

Area or Volume Length

(ft)

Area or Volume Width

(ft)Area Axis(Degrees)

Minimum Distance

from Property Line

(ft)

Building Cavity Zone

(3L)(ft)

Property Line Within Cavity

Zone? (Yes/No)

Cavity Calculation Required? (Yes/No)

Spray Booth SPRAYBOOTH Point 14 660529.6 3059301.8 1.000 35 3.5 69.3 70 0.12 76.7 Rural 18.0 150.7 70.8 18.01181 90.1 N/A N/A N/A 60.69 54.03543 NO NO

Small Parts 1 SP1 Point 14 660543.33 3059285.86 1.000 35.0 3.5 69.3 70 0.12 76.7 Rural 18.0 150.7 70.8 18.01181 90.1 N/A N/A N/A 61 54.03543 NO NO

Production Area 1 PROD1 Point 14 660562.8 3059292 1.000 35.0 3.5 69.3 70 0.12 76.7 Rural 18.0 49.2 104.3 18.01181 90.1 N/A N/A N/A 87 54.03543 NO NO

Small Parts 2 SP2 Point 14 660558.31 3059286.86 1.000 39.4 2.5 34.0 34 0.12 76.7 Rural 18.0 49.2 104.3 18.01181 90.1 N/A N/A N/A 87 54.03543 NO NO

Production Area 2 PROD2 Point 14 660586.15 3059292.51 1.000 35.0 3.5 69.3 70 0.12 76.7 Rural 18.0 49.2 104.3 18.01181 90.1 N/A N/A N/A 87 54.03543 NO NO

3.28084 336.9288996 21.115 69.2749366336.9288996 21.115 69.2749366

336.9288996 21.123 69.30118332

193.2575265 10.35 33.956694336.9288996 21.115 69.2749366

#REF! 6.988 22.92650992

Area Sources3 Stack height for area sources is set to either one half of the over head door height or the structure. Please contact TCEQ for additional guidance for other situations.

Pseudo Point Sources1 Stack inside diameter revised to 0.001 meters per TCEQ guidance memo for Modeling Fugitive Emissions as Pseudo-Point Sources dated July 25, 1997.2 Stack exit velocity revised to 0.001 meters/sec per TCEQ guidance memo for Modeling Fugitive Emissions as Pseudo-Point Sources dated July 25, 1997.3 Stack height for pseudo point sources may either be 1.0 meters or the actual release height for horizontal discharges and stacks with rain hats or gooseneck exhaust. Please contact TCEQ for additional guidance for other situations. TCEQ memo on pseudo-point sources: https://www.tceq.texas.gov/assets/public/permitting/air/memos/pseudopt.pdf

Table 17Modeling Input Parameters

Short-Term Impacts Analysis and NAAQS Screening Analysis

The input data for SCREEN3 or other models is entered here. The data in this table provides the stack parameters to be entered for each model run, information on source characterization (point, pseudo point, area and volume), building dimensions for downwash and dispersion coefficient. It also aids in the determination of the dominant downwash structure for each stack as well as determine if a cavity calculation is required.

a The information above was entered from the electronic modeling evaluation workbook provided with the NSR application package

Volume SourcesVolume source length and width are based on the EPA SCREEN3 Users Guide - EPA - 454/B-95-004, Table 1SCREEN3 user guide: https://www3.epa.gov/scram001/userg/screen/screen3d.pdf

For volume sources, the base of the volume must be square.For a building 150 ft x 100 ft the dimensions of a square with an equal area is (L2 + W2)*0.5 = 122.47 ft σy0 = 122.47 ft ÷ 4.30 = 28.48 ftσz0 = 27 ft ÷ 2.15 = 12.55 ft

Description of image: Summary of Suggested Procedures for Estimating Initial Lateral Dimensions Sigma y naught and initial vertical dimensions sigma z naught for volume and line sources.

Initial lateral dimensions sigma y naught: For single volume source, sigma y naught equals the length of side divided by 4.3. For a line source represented by adjacent volume sources, sigma y naught equals the length of the side, divided by 2.15. For line sources represented by separated colume

Updated 4/7/2020

https://www.tceq.texas.gov/assets/public/permitting/air/memos/pseudopt.pdf













https://www3.epa.gov/scram001/userg/screen/screen3d.pdf

















SPRAYBOOTHModeled Concentration 9.719 µg/m3 NA NA NA NAFugitive Reduction2 1.00 NA NA NA NA NALow Wind Speed Reduction3 1.00 NA NA NA NA NAShroud Factor4 1.00 NA NA NA NA NA

EPN SPECIAL Averaging Period

Averaging Period

Conversion Factor1

Unit Impact Multiplier

((µg/m3)/(lb/hr))Fugitive

Reduction2

Low Wind Speed

Reduction3 Shroud Factor

Reduction4

Adjusted Impact For Use in Analysis

((µg/m3)/(lb/hr))1-hr 1.00 9.719 1.00 1.00 1.00 9.7193-hr 0.90 8.747 1.00 1.00 1.00 8.7478-hr 0.70 6.803 1.00 1.00 1.00 6.80324-hr 0.40 3.888 1.00 1.00 1.00 3.888Annual 0.08 0.778 1.00 1.00 1.00 0.778

SP1Modeled Concentration 9.733 µg/m3 NA NA NA NAFugitive Reduction2 1.00 NA NA NA NA NALow Wind Speed Reduction3 1.00 NA NA NA NA NAShroud Factor4 1.00 NA NA NA NA NA

EPN RTO-1 Averaging Period

Averaging Period

Conversion Factor1



Reduction2

Low Wind Speed


Reduction4



SP2Modeled Concentration 15.650 µg/m3 NA NA NA NAFugitive Reduction2 1.00 NA NA NA NA NALow Wind Speed Reduction3 1.00 NA NA NA NA NAShroud Factor4 1.00 NA NA NA NA NA

EPN METAL PRIME Averaging Period

Averaging Period

Conversion Factor1



Reduction2

Low Wind Speed


Reduction4



PROD1Modeled Concentration 9.713 µg/m3 NA NA NA NAFugitive Reduction2 1.00 NA NA NA NA NALow Wind Speed Reduction3 1.00 NA NA NA NA NAShroud Factor4 1.00 NA NA NA NA NA

EPN METAL TOP Averaging Period

Averaging Period

Conversion Factor1



Reduction2

Low Wind Speed


Reduction4



PROD2Modeled Concentration 9.713 µg/m3 NA NA NA NAFugitive Reduction2 1.00 NA NA NA NA NALow Wind Speed Reduction3 1.00 NA NA NA NA NAShroud Factor4 1.00 NA NA NA NA NA

EPN OVEN DRY Averaging Period

Averaging Period

Conversion Factor1



Reduction2

Low Wind Speed


Reduction4



If an adjustment is not applicable, enter 1.00.https://www.tceq.texas.gov/assets/public/permitting/air/memos/shroudcredit.pdf


Concentration Adjustment


1 Conversion factors are from EPA Screening Procedures for Estimating the Air Quality Impact of Stationary Sources - Revised, EPA 454/R-92-019, page 4-162 TCEQ 0.6 low release height adjustment - See March 6, 2002 Memo which is located at:

3 TCEQ 0.67 factor to adjust for low wind speed of 1.0 m/sec - SCREEN3 only.4 Shroud factor is based on the shroud guidance memo which is located at:

Table 18Unit Impact Multipliers Using SCREEN3




This table should be structured such that there is a unit impact multiplier (UIM) table for each EPN in the impacts analysis. The individual EPN tables are structured to provide a UIM (µg/m3 per lb/hr) for each averaging period for the National Ambient Air Quality Standards (NAAQS) and species impacts analysis and are based on EPA conversion factors.

Additionaly, correction factors may be applied to the model results, as noted in the footnotes, which are dependent on the type of model used.

Once all the data is entered in the cells identified as beige cells, the impacts are updated below. Since the formulas reference the data cells identified as beige cells, no changes need to be made to the remainder of the spreadsheet.









https://www.tceq.texas.gov/assets/public/permitting/air/memos/shroudcredit.pdf










Criteria Pollutant

Current Allowable

Emission Rate (lb/hr)

Proposed Allowable


Difference in Allowable


Emission Rate Increase or Decrease?

Averaging Period Unit Impact Multiplier

(µg/m3/lb/hr)

Change in Impact (µg/m3)

Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


PM10 0.000 0.000 No Change 24-hr 3.888 0.000 NOx 0.000 0.000 No Change Hourly 9.719 0.000PM2.5 0.000 0.000 No Change 24-hr 3.888 0.000 NOx 0.000 0.000 No Change Annual 0.778 0.000PM2.5 0.000 0.000 No Change Annual 0.778 0.000

Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)



Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)



Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)



Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


PM10 0.000 0.000 No Change 24-hr 3.885 0.000 NOx No Change Hourly 9.713PM2.5 0.000 0.000 No Change 24-hr 3.885 0.000 NOx No Change Annual 0.777PM2.5 0.000 0.000 No Change Annual 0.777 0.000

Criteria Pollutant Project Impact

(µg/m3)

Significant Impact Level

(µg/m3)

Less than Significant

Impact Level? (Y/N)

Further Analysis Required?

Site-Wide Impact (µg/m3)1

Background Concentration

(µg/m3)

Total Concentration

(µg/m3)NAAQS (µg/m3)

Less than Standard? (Y/N) Criteria Pollutant

Project Impact (µg/m3)


(µg/m3)


Impact Level? (Y/N)




(µg/m3)

Total Concentration


Less than Standard? (Y/N)

PM10 0.000 5.0 Yes Analysis Complete 0.000 0.000 0.000 150 Yes NOx 7.8 No Go to Full

Analysis 188 No

PM2.5 0.000 1.2 Yes Analysis Complete 0.000 35 No NOx 1.0 No Go to Full

Analysis 100 No

PM2.5 0.000 0.3 Yes Analysis Complete 0.000 12 No

EPN SPRAYBOOTHEPN SPRAYBOOTH

This table is structured to complete a NAAQS analysis for both the solids emissions (PM/PM10/PM2.5) from painting and the products of combustion from sources such as ovens, the RTOs, and air makeup units (AMUs).

The analysis is a two-step process. In the first step, the change in emission rates for the project are determined for each source and the change in impacts is determined using the UIMs developed on Table 18. These changes in concentration are summed and compared to the SIL. If the increase in impacts is less than the SIL, the analysis is complete. If not, you must proceed to the second step. In this step all sources at the site must be included in the analysis as well as an appropriate background concentration taken from an ambient monitor.

The table is structured to accommodate existing sites and new sites. For new sites and new sources at existing sites, the existing emission rate should be entered as a zero. For existing sources the current allowable emission rate should be entered. After this the proposed allowable emission rate should be entered for each EPN. The table is structured such that if there is an emission decrease the change in emission rates and off property concentrations will be a negative value. This is acceptable since this is part of first step of the review where the net change in concentration is being determined.

If the change in concentration for the project is above the SIL, then site wide modeling is required to determine the total concentration from all sources at the site. Once this value is determined, using additional modeling runs, if required, it is entered into the table along with an appropriate background concentration and compared to the NAAQS. If the impact is less than the NAAQS the analysis is complete. Exceedances of the NAAQS are not allowed and changes to the facility may be required such as reducing emission rates, adding pollution control equipment or improving dispersion such as raising stacks may be required to obtain an acceptable result.

EPN SP1 EPN SP1

1 If the project increase is greater than the SIL, enter total sitewide impacts based on site wide modeling here.If the project increase is equal to sitewide impacts, enter the project impact here.

EPN PROD2

EPN PROD1

EPN SP2

EPN PROD2

EPN SP2

EPN PROD1

Total Impacts Total Impacts

Table 20 - N/ANAAQS SIL Analysis and Impacts Analysis

CRA Coatings Workbook 3-6-2020; NAAQS Analysis Updated 4/7/2020

Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


CO 0.000 0.000 No Change Hourly 9.719 0.000 SO2 0.000 0.000 No Change 1-hr 9.719 0.000CO 0.000 0.000 No Change 8-hr 6.803 0.000 SO2 0.000 0.000 No Change 3-hr 8.747 0.000

SO2 0.000 0.000 No Change 24-hr 3.888 0.000SO2 0.000 0.000 No Change Annual 0.778 0.000

Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)




Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)




Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)




Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


Criteria Pollutant

Current Allowable


Proposed Allowable






(µg/m3/lb/hr)


CO No Change Hourly 9.713 SO2 No Change 1-hr 9.713CO No Change 8-hr 6.799 SO2 No Change 3-hr 8.742

SO2 No Change 24-hr 3.885SO2 No Change Annual 0.777

Criteria Pollutant Project Impact

(µg/m3)


(µg/m3)


Impact Level? (Y/N)




(µg/m3)

Total Concentration


Less than Standard? (Y/N) Criteria Pollutant

Project Impact (µg/m3)


(µg/m3)


Impact Level? (Y/N)




(µg/m3)

Total Concentration


Less than Standard? (Y/N)

CO 2000 No Go to Full Analysis 0.000 40000 No SO2 7.8 No Go to Full

Analysis 196 No

CO 500 No Go to Full Analysis 0.000 10000 No SO2 25.0 No Go to Full

Analysis 1300 No

SO2 5.0 No Go to Full Analysis 365 No

SO2 1.0 No Go to Full Analysis 80 No

EPN BOOTHEPN BOOTH

EPN TOPCOAT

Total Impacts

EPN RTO-1EPN RTO-1

EPN OVEN

EPN TOPCOAT

EPN PRIME

Total Impacts

EPN OVEN

EPN PRIME

CRA Coatings Workbook 3-6-2020; NAAQS Analysis Updated 4/7/2020

process description all4 quality professional (aqp) seal tceq … · 2020. 4. 14. · majek...

Documents