And you use.. With. Use the organic HAP Emission Factor (EF) Equation for materials with less that 33 percent organic HAP (19% organic HAP for

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Norman Cain
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1 Permit Appendix F: 40 CFR pt. 63, subp. WWWW supplementary information Table W1 Table W1 of Subpart WWWW: Equations to Calculate Organic HAP Emissions Factors for Specific Open Molding and Centrifugal Casting Process Streams 1 The Permittee shall use the equations in the following table to calculate organic HAP emissions factors for specific open molding and centrifugal casting process streams: If your operation type is new or existing.. And you use.. With. Use the organic HAP Emission Factor (EF) Equation for materials with less that 33 percent organic HAP (19% organic HAP for nonatomized ) Use the organic HAP Emission Factor (EF) Equation for materials with 33 percent or more organic HAP (19% organic HAP for nonatomized ) 2,3,4 1. Open molding operation a. Manual b. atomized mechanical c. nonatomized mechanical i. nonvaporsuppressed ii. vapor-suppressed iii. vacuum curing with roll-out iv. vacuum curing without rollout i. nonvaporsuppressed ii. vapor-suppressed iii. vacuum curing with roll-out iv. vacuum curing without rollout i. nonvaporsuppressed ii. vapor-suppressed EF = x % HAP x. EF = x % HAP x x (1-(0.5 x VSE factor)) EF = x % HAP x x 0.8. EF = x % HAP x x 0.5. x (1-(0.45 x VSE factor)) x x 0.55 EF = x % HAP x. EF = ((0.286 x %HAP) ) x EF = ((0.286 x %HAP) ) x x (1-(0.5 x VSE factor)) EF = ((0.286 x %HAP) ) x x 0.8 EF = ((0.286 x %HAP) ) x x 0.5 EF = ((0.714 x %HAP)-0.18) x EF = ((0.714 x %HAP)-0.18) x x (1-(0.45 x VSE factor)) EF = ((0.714 x %HAP)-0.18) x x 0.85 EF = ((0.714 x %HAP)-0.18) x x 0.55 EF = ((0.157 x %HAP) ) x EF = ((0.157 x %HAP)- aq-12-01f 4/30/15 Page 374

2 If your operation type is new or existing.. And you use.. With. Use the organic HAP Emission Factor (EF) Equation for materials with less that 33 percent organic HAP (19% organic HAP for nonatomized ) Use the organic HAP Emission Factor (EF) Equation for materials with 33 percent or more organic HAP (19% organic HAP for nonatomized ) 2,3,4 d. atomized mechanical with robotic or automated spray control 5 e. filament 6 iii. vacuum curing with roll-out iv. vacuum curing without rollout i. nonvaporsuppressed ii. vapor-suppressed EF = x % HAP x x (1-(0.45 x VSE factor)) EF = x % HAP x x EF = x % HAP x x 0.55 x 0.77 EF = x % HAP x. EF = 0.12 x % HAP x ) x x (1-(0.45 x VSE factor)) EF = ((0.157 x %HAP) ) x x 0.85 EF = ((0.157 x %HAP) ) x x 0.55 EF = 0.77 x ((0.714 x %HAP)-0.18) x EF = (( x %HAP) ) x EF = (( x %HAP) ) x x Centrifugal casting operations 7,8 f. atomized spray g. nonatomized spray h. atomized spray using robotic or automated spray a. heated air blown through molds b. vented molds, but air vented through the molds is not heated. EF = x % HAP x EF = x % HAP x EF = x % HAP x x 0.73 EF = x % HAP x EF = x % HAP x EF = (( x %HAP) ) x EF = (( x %HAP) ) x EF = (( x %HAP) ) x x 0.73 EF = x % HAP x EF = x % HAP x aq-12-01f 4/30/15 Page 375

3 Footnotes to Table W1 1 The equations are intended for use in calculating emission factors to demonstrate compliance wit the emission limits in Subpart WWWW. These equations may not be most appropriate method to calculate emission estimates for other purposes. However, this does not preclude a facility from using the equations to calculate emissions factors for purposes then rule compliance if these equations are the most accurate available. 2 To obtain the organic HAP emissions factor value for an operation with an add-on control device multiply the EF above by the add-on control factor calculated using Equation 1 of Sec The organic HAP emissions factors have units of lbs of organic HAP per ton of or applied. 3 Percent HAP means total weight percent of organic HAP (styrene, methyl methacrylate, and any other organic HAP) in the or prior to the addition of fillers, catalyst, and promoters. Input the percent HAP as a decimal, i.e. 33 percent HAP should be input as 0.33, not The VSE factor means the percent reduction in organic HAP emissions expressed as a decimal measured by the VSE test method of appendix A to 40 CFR pt. 63, subp. WWWW. 5 This equation is based on an organic HAP emissions factor equation developed for mechanical atomized controlled spray. It may only be used for automated or robotic spray systems with atomized spray. All spray operations using hand held spray guns must use the appropriate mechanical atomized or mechanical nonatomized organic HAP emissions factor equation. Automated or robotic spray systems using nonatomized spray should use the appropriate nonatomized mechanical equation. 6 Applies only to filament using an open bath. If is applied manually or with a spray gun, use the appropriate manual or mechanical organic HAP emissions factor equation. 7 These equations are for centrifugal casting operations where the mold is vented during spinning. Centrifugal casting operations where the mold is completely sealed after injection are considered to be closed molding operations. 8 If a centrifugal casting operation uses mechanical or manual techniques to apply to an open centrifugal casting mold, use the appropriate open molding equation with covered cure and no rollout to determine an emission factor for operations prior to the closing of the centrifugal casting mold. If the closed centrifugal casting mold is vented during spinning, use the appropriate centrifugal casting equation to calculate an emission factor for the portion of the process where spinning and cure occur. If a centrifugal casting operation uses mechanical or manual techniques to apply to an open centrifugal casting mold, and the mold is then closed and is not vented, treat the entire operation as open molding with covered cure and no rollout to determine emission factors. aq-12-01f 4/30/15 Page 376

4 W.1 Equation W1 (40 CFR Section (b)(1)) Demonstrate that, on average, each combination of operation type and method or gel coat type meets the applicable HAP Emission Limits. The Permittee shall demonstrate that, on average, each unique combination of operation type and method or type listed above in the HAP Emission Limits section meets the applicable HAP Emission Limits using the following procedures: (1) (i) Group the process streams by operation type and method or type listed in the HAP Emission Limit section above and then calculate a weighted average emission factor based on the amounts of each individual or used for the last 12 months, using Equation W1 below. To do this, sum the product of each individual organic HAP emissions factor calculated in paragraph (1) in the Demonstrate that an individual or, as applied, meets the applicable HAP Emission Limit requirement and the amount of neat plus and neat gel coat plus usage that corresponds to the individual factors and divide the numerator by the total amount of neat plus and neat plus used in that operation type: Equation W1: EF avg = n i=1 (EF act,i Material i ) n i=1 Material i Where: EF avg = average organic HAP emissions factor EF act,i = actual organic HAP emissions factor for process stream i, lbs/ton. This is the individual organic HAP emissions factor calculated in paragraph (1) in the Demonstrate that an individual or, as applied, meets the applicable HAP Emission Limit requirement (40 CFR section (a)(1)). Material i = neat plus or neat plus used during the last 12 calendar months for process stream i, tons n = number of process streams for which an organic HAP emissions factor is calculated W.2 Equation W2 (40 CFR Section (c)(1)) Demonstrate compliance with a weighted average emission limit. (1) Each month the Permittee shall calculate the weighted average organic HAP emissions limit for all open molding operations and the weighted average organic HAP emissions limit for all centrifugal casting operations at the facility for the last 12-month period to determine the organic HAP emissions limit that the Permittee shall meet, using Equation W2 below. To do this, the Permittee shall multiply the individual HAP Emission Limit for each open molding (centrifugal casting) operation type by the amount of neat plus or neat plus used in the last 12 months for each open molding (centrifugal casting) operation type, sum the aq-12-01f 4/30/15 Page 377

5 results, and then divide this sum by the total amount of neat plus and neat plus used in open molding (centrifugal casting) over the last 12 months : Equation W2: EL avg = n i=1 (EL i Material i ) n i=1 Material i Where: EL avg = weighted average emission limit EL i = organic HAP emissions factor for operation type i, lbs/ton. This is the individual organic HAP emissions limit from the HAP Emissions Limits section in the NESHAP subp. WWWW section of this permit. Material i = neat plus or neat plus used during the last 12 calendar months for operation type i, tons n = number of operations W.3 Equation W3 (40 CFR Section (c)(2)) (2) Each month the Permittee shall calculate the weighted average organic HAP emissions factor for open molding and centrifugal casting, using Equation W3 below. To do this, the Permittee shall multiply the actual open molding (centrifugal casting) operation organic HAP emission factors calculated in paragraph (1) of the Demonstrate that, on average, each combination of operation type and method or type meets the applicable HAP Emission Limits requirement and the amount of neat plus and neat plus used in each open molding (centrifugal casting) operation type, sum the results, and then divide this sum by the total amount of neat plus and neat plus used in open molding (centrifugal casting) operations: Equation W3: EF AWA = n i=1 (EF op,i Material i ) n i=1 Material i Where: EF AWA = actual weighted average organic HAP emissions factor EF op,i = actual organic HAP emissions factor for operation type i, lbs/ton. This is the organic HAP emissions factor calculated in paragraph (1) in the Demonstrate that, on average, each combination of operation type and method or type meets the applicable HAP Emission Limits requirement (40 CFR section (b)(1)). Material i = neat plus or neat plus used during the last 12 calendar months for operation type i, tons n = number of operations W.4 Equation W4 (40 CFR Section (a)) (a) Compliant line option: use Equation W4 below to calculate an organic HAP emission factor in lbs/ton. WAE+ O Equation W4: E = R+G aq-12-01f 4/30/15 Page 378

6 Where: E = HAP emissions factor in lbs/ton of and WAE = uncontrolled wet-out area organic HAP emissions, lbs/year O = uncontrolled oven organic HAP emissions, lbs/year R = total usage of neat plus, tpy G = total usage of neat plus, tpy W.5 Equation W5 (40 CFR Section (b)) (b) Averaging option: use Equation W5 below to demonstrate compliance. m n i=1 + j=1 O Equation W5: E = WAE R+G Where: E = HAP emissions factor in lbs/ton of and WAE = uncontrolled wet-out area organic HAP emissions from wet-out area i, lbs/year O = uncontrolled oven organic HAP emissions from oven j, lbs/year m = number of wet-out areas n = number of ovens R = total usage of neat plus, tpy G = total usage of neat plus, tpy aq-12-01f 4/30/15 Page 379

7 Table W2: Emission Factors for Open Molding of Composites Table W2a: Emission Rate in Pounds of Styrene Emitted per Ton of Resin or Gelcoat Processed Application Process Manual Manual w/ Vapor Suppressed Resin VSR (3) Mechanical Atomized Mechanical Atomized with VSR (3) Mechanical Non- Atomized Mechanical Non-Atomized with VSR (3) Filament Styrene content in /gelcoat, % (1) <33 (2) >50 (2) x x x x ((0.286 x ) x Manual emission factor [listed above] x (1 - (0.50 x specific VSR reduction factor for each /suppressant formulation)) ((0.714 x 0.18) x Mechanical Atomized emission factor [listed above] x (1 - (0.45 x specific VSR reduction factor for each /suppressant formulation)) x x ((0.157 x ) x Mechanical Non-Atomized emission factor [listed above] x (1 - (0.45 x specific VSR reduction factor for each /suppressant formulation)) x x (( x ) x Filament x x aq-12-01f 4/30/15 Page 380

8 Application Process with VSR (4) Gelcoat Application Covered-Cure after Roll-Out Covered-Cure without Roll- Out Styrene content in /gelcoat, % (1) <33 (2) >50 (2) x x x (( x ) x (( x 0.195) x Non-VSR process emission factor [listed above] x ( 0.80 for Manual <or> 0.85 for Mechanical) Non-VSR process emission factor [listed above] x ( 0.50 for Manual <or> 0.55 for Mechanical) Table W2b: Emission Rate in Pounds of Methyl Methacrylate Emitted per Ton of Gelcoat Processed MMA content in gelcoat, % (5) Application >20 Process Gel coat (6) x %MMA x Footnotes to Table W2 1. Including styrene monomer content as supplied, plus any extra styrene monomer added by the molder, but before addition of other additives such as powders, fillers, glass,...etc. 2. Formulas for materials with styrene content < 33% are based on the emission rate at 33% (constant emission factor expressed as percent of available styrene), and for styrene content > 50% on the emission rate based on the extrapolated factor equations; these are not based on test data but are believed to be conservative estimates. The value for "% styrene" in the formulas should be input as a fraction. For example, use the input value 0.30 for a with 30% styrene content by weight. aq-12-01f 4/30/15 Page 381

9 3. The VSR reduction factor is determined by testing each /suppressant formulation according to the procedures detailed in the CFA Vapor Suppressant Effectiveness Test. 4. The effect of vapor suppressants on emissions from filament winding operations is based on the Dow Filament Winding Emissions Study. 5. Including MMA monomer content as supplied, plus any extra MMA monomer added by the molder, but before addition of other additives such as powders, fillers, glass,...etc. 6. Based on gelcoat data from NMMA Emission Study. This table is based on the CFA Unified Emissions Factors document, dated April 7, These factors shall be used or EPA-approved factor supersedes emission factors used herein. aq-12-01f 4/30/15 Page 382

Control of VOC emissions from reinforced plastic composites production operations.

ACTION: Original DATE: 11/29/2018 11:17 AM 3745-21-25 Control of VOC emissions from reinforced plastic composites production operations. [Comment: For dates and availability of non-regulatory government