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A.4 Fiberglass Operations The following are Minnesota Standards of Performance for Industrial Process Equipment A.4.1 Minn. R. for Fiberglass Operations – placed in operation before July 9, 1969 What to do Why to do it Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0710, subp. 1(A); Opacity: less than or equal to 20% opacity except for one-six-minute period per hour of not more than 60% opacity. Minn. R. 7011.0710, subp. 1(B) A.4.2 Minn. R. for Fiberglass Operations – placed in operation on or after July 9, 1969 What to do Why to do it Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A); Opacity: less than or equal to 20% opacity. Minn. R. 7011.0715, subp. 1(B) aq-12-01o 4/30/15 Page 143

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A.4 Fiberglass Operations

The following are Minnesota Standards of Performance for Industrial Process Equipment

A.4.1 Minn. R. for Fiberglass Operations – placed in operation before July 9, 1969

What to do Why to do it

Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0710, subp. 1(A);

Opacity: less than or equal to 20% opacity except for one-six-minute period per hour of not more than 60% opacity.

Minn. R. 7011.0710, subp. 1(B)

A.4.2 Minn. R. for Fiberglass Operations – placed in operation on or after July 9, 1969

What to do Why to do it

Total Particulate Matter: less than or equal to 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A);

Opacity: less than or equal to 20% opacity. Minn. R. 7011.0715, subp. 1(B)

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A.4.3 NESHAP subp. WWWW The following are National Emission Standards for Hazardous Air Pollutants for Reinforced Plastic Composites Production (40 CFR pt. 63, subp. WWWW)

Fiberglass Operations (spraying/coating, molding, casting, lamination, mixing and cleaning) – Subject to NESHAP subp. WWWW

Affected Source for NESHAP subp. WWWW: All parts of the facility engaged in the following reinforced plastic composites production operations: Open molding, closed molding, centrifugal casting, continuous lamination, continuous casting, polymer casting, pultrusion, sheet molding compound (SMC) manufacturing, bulk molding compound (BMC) manufacturing, mixing, cleaning of equipment used in reinforced plastic composites manufacture, HAP-containing materials storage, and repair operations on parts manufactured by the facility.

New Source: commenced construction after August 2, 2001Existing Source: commenced construction on or before August 2, 2001(Also see 40 CFR section 63.5795)

Compliance dates: All compliance dates have passed for this standard. For existing affected sources, the compliance date was April 21, 2006. For new affected sources, the compliance date was April 21, 2003, or the date of initial startup of the affected source, whichever was later.

The Permittee is subject to the requirements below if the Permittee owns or operates an affected source and the reinforced plastic composites operations at the facility use 1.2 tons per year or more of thermoset resins and gel coats that contain styrene combined. (Also see 40 CFR section 63.5785)

Definitions: (Also see 40 CFR section 63.5935)CR/HS: Corrosion-resistant and/or high strength

This rule does not cover the following, which are applicable to this permit: Non-gel coat surface coatings that meet the requirements of subparts MMMM or PPPP

What to do Why to do it

GENERAL COMPLIANCE REQUIREMENTS hdr

Unless otherwise noted, all equations and emission factors for 40 CFR pt. 63, subp. WWWW referenced in the requirements for NESHAP subp. WWWW in this general permit can be found in Appendix F of this permit.

Minn. R. 7007.0800, subp. 4 and 5

General Provisions Appendix: This permit contains an appendix which lists the requirements of the general provisions in 40 CFR Sections 63.1 through 63.15, and shows which parts of the general provisions apply to sources subject to 40 CFR pt. 63, subp. WWWW.

The Permittee shall comply with all applicable requirements contained in the General Provisions Appendix (Appendix B).

40 CFR Section 63.5925, Table 15 in 40 CFR pt. 63, subp. WWWW; Minn. R. 7011.7800; Minn. R. 7007.0800, subp. 2

Military exemption: Production resins that must meet military specifications are allowed to meet the organic HAP limit contained in that specification.

40 CFR Section 63.5790(d); Minn. R. 7011.7800

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In order for this exemption to be used, the Permittee shall supply to the permitting authority the specifications certified as accurate by the military procurement officer, and those specifications must state a requirement for a specific resin, or a specific resin HAP content.

Production resins for which this exemption is used must be applied with nonatomizing resin application equipment unless the Permittee can demonstrate this is infeasible.

The Permittee shall keep a record of the resins for which this exemption is used.

HAP EMISSION LIMITS – NEW AND EXISTING CENTRIFUGAL CASTING AND CONTINUOUS CASTING/LAMINATION

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HAPs-Organic: less than or equal to 25 lb/ton resin for centrifugal casting – CR/HS operations that use resin application with the mold closed or open, and the mold is vented during spinning and cure, based on a 12-month rolling average.

For compliance purposes, the Permittee shall calculate the emission factor using only the appropriate centrifugal casting equation in item 2 of Table W1 in Appendix F to this permit.

40 CFR pt. 63, subp. WWWW: Section 63.5805(a) and Table 3; Minn. R. 7011.7800

HAPs-Organic: for centrifugal casting – CR/HS operations that use resin application with the mold open, and the mold is not vented during spinning and cure, the Permittee shall use the appropriate open molding emission limit.

The Permittee shall calculate the emission factor using the appropriate open molding covered cure emission factor in item 1 of Table W1 in Appendix F to this permit.

40 CFR pt. 63, subp. WWWW: Section 63.5805(a) and Table 3; Minn. R. 7011.7800

HAPs-Organic: less than or equal to 20 lb/ton resin for centrifugal casting – non CR/HS operations that use resin application with the mold closed or open, and the mold is vented during spinning and cure, based on a 12-month rolling average.

For compliance purposes, the Permittee shall calculate the emission factor using only the appropriate centrifugal casting equation in item 2 of Table W1 in Appendix F to this permit.

40 CFR pt. 63, subp. WWWW: Section 63.5805(a) and Table 3; Minn. R. 7011.7800

HAPs-Organic: for centrifugal casting – non CR/HS operations that use resin application with the mold open, and the mold is not vented during spinning and cure, the Permittee shall use the appropriate open molding emission limit.

The Permittee shall calculate the emission factor using the appropriate open molding covered cure emission factor in item 1 of Table W1 in Appendix F to this permit.

40 CFR pt. 63, subp. WWWW: Section 63.5805(a) and Table 3; Minn. R. 7011.7800

HAPs-Organic: less than or equal to 15.7 lb/ton neat resin plus and neat gel coat plus for continuous lamination/casting operations, based on a 12-month rolling average.

Alternative: as an alternative to the lb/ton limit, the Permittee may instead elect to reduce total organic HAP emissions by at least 58.5 weight percent for continuous lamination/casting operations.

40 CFR pt. 63, subp. WWWW: Section 63.5805(a) and Table 3; Minn. R. 7011.7800

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HAP EMISSION LIMITS – NEW AND EXISTING OPEN MOLDING hdr

HAPs-Organic: less than or equal to 113 lb/ton resin for open molding – CR/HS operations that use mechanical resin application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 171 lb/ton for open molding – CR/HS operations that use filament application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 123 lb/ton resin for open molding – CR/HS operations that use manual resin application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 88 lb/ton resin for open molding – non CR/HS operations that use mechanical resin application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 188 lb/ton for open molding – non CR/HS operations that use filament application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 87 lb/ton resin for open molding – non CR/HS operations that use manual resin application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 254 lb/ton resin for open molding – tooling operations that use mechanical resin application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 157 lb/ton resin for open molding – tooling operations that use manual resin application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 497 lb/ton resin for open molding – low-flame spread/low-smoke products operations that use mechanical resin application, based

40 CFR Sections 63.5805(b) and (c);

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on a 12-month rolling average. 40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 270 lb/ton for open molding – low-flame spread/low-smoke products operations that use filament application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 238 lb/ton resin for open molding – low-flame spread/low-smoke products operations that use manual resin application, based on a 12-month rolling average.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 354 lb/ton resin for open molding – shrinkage controlled resins operations that use mechanical resin application, based on a 12-month rolling average.

This emission limit applies regardless of whether the shrinkage controlled resin is used as a production resin or a tooling resin.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 215 lb/ton for open molding – shrinkage controlled resins operations that use filament application, based on a 12-month rolling average.

This emission limit applies regardless of whether the shrinkage controlled resin is used as a production resin or a tooling resin.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 180 lb/ton resin for open molding – shrinkage controlled resins operations that use manual resin application, based on a 12-month rolling average.

This emission limit applies regardless of whether the shrinkage controlled resin is used as a production resin or a tooling resin.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 440 lb/ton gel coat for open molding – gel coat operations that use tooling gel coating, based on a 12-month rolling average.

If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors (EF).

If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an EF for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate EFs.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 267 lb/ton gel coat for open molding – gel coat operations that use white/off white pigmented gel coating, based on a 12-month

40 CFR Sections 63.5805(b) and (c);

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rolling average.

If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors.

If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors.

40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 377 lb/ton gel coat for open molding – gel coat operations that use all other pigmented gel coating, based on a 12-month rolling average.

If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors.

If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 605lb/ton gel coat for open molding – gel coat operations that use CR/HS or high performance gel coating, based on a 12-month rolling average.

If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors.

If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAPs-Organic: less than or equal to 854lb/ton gel coat for open molding – gel coat operations that use fire retardant gel coating, based on a 12-month rolling average.

If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors.

If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

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application equation to calculate emission factors.

HAPs-Organic: less than or equal to 522lb/ton gel coat for open molding – gel coat operations that use clear production gel coating, based on a 12-month rolling average.

If the facility only applies gel coat with manual application, for compliance purposes the Permittee shall treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors.

If the facility uses multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the Permittee may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise the Permittee shall use the atomized spray gel coat application equation to calculate emission factors.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

HAP EMISSION LIMITS – NEW AND EXISTING PULTRUSION MACHINES hdr

HAPs-Organic: greater than or equal to 60 weight percent reduction of total organic HAP emissions for pultrusion machines, except:

Pultrusion machines that produce parts that meet the following criteria: 1,000 or more reinforcements or the glass equivalent of 1,000 ends of 113 yield roving or more; and have a cross sectional area of 60 square inches or more are not subject to this organic HAP emission limit.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 3;Minn. R. 7011.7800

WORK PRACTICE STANDARDS hdr

For new or existing closed molding operations using compression/injection molding, the Permittee shall uncover, unwrap or expose only one charge per mold cycle per compression/injection molding machine.

- For machines with multiple molds, one charge means sufficient material to fill all molds for one cycle

- For machines with robotic loaders, no more than one charge may be exposed prior to the loader.

- For machines fed by hoppers, sufficient material may be uncovered to fill the hopper. Hoppers shall be closed when not adding materials.

- Materials may be uncovered to feed to slitting machines. Materials shall be recovered after slitting.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 4;Minn. R. 7011.7800

For new or existing cleaning operations, the Permittee shall not use cleaning solvents that contain HAP, except that styrene may be used as a cleaner in closed systems, and organic HAP containing cleaners may be used to clean cured resin from application equipment. Application equipment includes any equipment that directly contacts resin.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 4;Minn. R. 7011.7800

For new or existing materials HAP-containing materials storage operations, the Permittee shall keep containers that store HAP-containing materials closed or

40 CFR Sections 63.5805(b) and (c);

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covered except during the addition or removal of materials. Bulk HAP-containing materials storage tanks may be vented as necessary for safety.

40 CFR pt. 63, subp. WWWW Table 4;Minn. R. 7011.7800

For existing or new SMC manufacturing operations, the Permittee shall:- Close or cover the resin delivery system to the doctor box on each SMC

manufacturing machine. The doctor box itself may be open; and- Use a nylon containing film to enclose SMC.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 4;Minn. R. 7011.7800

For all mixing or BMC manufacturing operations, the Permittee shall:- Use mixer covers with no visible gaps present in the mixer covers, except that

gaps of up to 1 inch are permissible around mixer shafts and any required instrumentation;

- Close any mixer vents when actual mixing is occurring, except that venting is allowed during addition of materials, or as necessary prior to adding materials or opening the cover for safety; and

- Keep the mixer covers closed while actual mixing is occurring except when adding materials or changing covers to the mixing vessels.

Exceptions: Containers of 5 gallons or less may be open when active mixing is taking place, or during periods when they are in process (i.e., they are actively being used to apply resin). For polymer casting mixing operations, containers with a surface area of 500 square inches or less may be open while active mixing is taking place.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 4;Minn. R. 7011.7800

For new or existing pultrusion operation manufacturing parts that meet the following criteria: 1,000 or more reinforcements or the glass equivalent of 1,000 ends of 113 yield roving or more; and have a cross sectional area of 60 square inches or more: the Permittee shall:

- Not allow vents from the building ventilation system, or local or portable fans to blow directly on or across the wet-out area(s);

- Not permit point suction of ambient air in the wet-out area(s);- Use devices such as deflectors, baffles, and curtains when practical to reduce

air flow velocity across the wet-out area(s);- Direct any compressed air exhausts away from resin and wet-out area(s);- Convey resin collected from drip-off pans or other devices to reservoirs,

tanks, or sumps via covered troughs, pipes or other covered conveyance that shields the resin from the ambient air;

- Cover all reservoirs, tanks, sumps, or HAP-containing materials storage vessels except when they are being charged or filled; and

- Cover or shield from ambient air resin delivery systems to the wet-out area(s) from reservoirs, tanks, or sumps where practical.

40 CFR Sections 63.5805(b) and (c);40 CFR pt. 63, subp. WWWW Table 4;Minn. R. 7011.7800

COMPLIANCE OPTIONS – NEW AND EXISTING OPEN MOLDING AND CENTRIFUGAL CASTING OPERATIONS

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The Permittee shall use one of the following methods to meet the standards for open 40 CFR Section

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molding or centrifugal casting operations listed above in the HAP Emission Limits and Work Practice Standards sections.

(a) Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit.

(b) Demonstrate that, on average, each combination of operation type and resin application method or gel coat type meets the applicable HAP Emission Limits.

(c) Demonstrate compliance with a weighted average emission limit.(d) Meet the HAP Emission Limit for one application method and use the same

resin(s) for all application methods of that resin type.

The Permittee may use any control method that reduces organic HAP emissions, including reducing resin and gel coat organic HAP content, changing to nonatomized mechanical application, and using uncovered curing techniques.

The Permittee may use different compliance options for the different operations listed above in the HAP Emission Limits and Work Practice Standards sections. The Permittee may switch between the compliance options above in paragraphs (a) through (d).

When the Permittee changes to an option based on a 12-month rolling average, the Permittee shall base the average on the previous 12 months of data calculated using the compliance option they are changing to, unless the Permittee was previously using an option that did not require maintaining records of resin and gel coat use. In this case, the Permittee shall immediately begin collecting resin and gel coat use data and demonstrate compliance 12 months after changing options.

63.5810; Minn. R. 7011.7800

Definition of Process Stream:- A process stream is each individual combination of resin or gel coat, application

technique, and control technique.- Process streams within operation types are considered different from each

other if any of the following four characteristics varyo the neat resin plus or neat gel coat plus organic HAP content,o the gel coat type,o the application technique, oro the control type.

40 CFR Section 63.5810(a); Minn. R. 7011.7800

Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit.

The Permittee shall perform the following calculations prior to beginning the use of a new individual resin or gel coat, or within 30 days of permit issuance, whichever is later.

(1) The Permittee shall calculate the actual organic HAP emissions factor for each different process stream within each operation type, using the appropriate equations in Table W1 of Appendix F to this permit for open molding and for centrifugal casting.

40 CFR Section 63.5810(a); Minn. R. 7011.7800

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- If the Permittee uses vapor suppressants to reduce HAP emissions, the Permittee shall determine the vapor suppressant effectiveness (VSE) by conducting testing according to the procedures specified in Appendix A to 40 CFR pt. 63, subp. WWWW.

- The emission factor calculation should include any and all emission reduction techniques used.

(2) If the calculated emission factor is less than or equal to the appropriate HAP Emission Limit, the Permittee has demonstrated that this process stream complies with the HAP Emission Limit in the NESHAP subp. WWWW section of this permit.

It is not necessary that all process streams at the facility, considered individually, demonstrate compliance to use this option for some process streams. However, for any individual resin or gel coat used, if any of the process streams that include that resin or gel coat are to be used in any averaging calculations described in options (b) through (d) below, then the Permittee shall include all process streams using that individual resin or gel coat in the averaging calculations.

Demonstrate that, on average, each combination of operation type and resin application method or gel coat type meets the applicable HAP Emission Limits.Within 30 days following the end of each month, the Permittee shall demonstrate that, on average, each unique combination of operation type and resin application method or gel coat 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 resin application method or gel coat type listed in the HAP Emission Limit section above and then calculate a weighted average emission factor based on the amounts of each individual resin or gel coat used for the last 12 months, using Equation W1 in Appendix F to this permit.(ii) The Permittee may, but is not required to, include process streams where they have demonstrated compliance as described above in the “Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit” requirement.(2) The Permittee shall compare each organic HAP emissions factor calculated in paragraph (1) in this requirement with its corresponding HAP Emissions Limit. If all emission factors are equal to or less than their corresponding emission limits then the source is in compliance.

40 CFR Section 63.5810(b); Minn. R. 7011.7800

Demonstrate compliance with a weighted average emission limit.Each month the Permittee shall demonstrate that the facility meets each weighted average of applicable HAP emission limits in the NESHAP subp. WWWW section of this permit. When using this option, the Permittee shall demonstrate compliance with the weighted average organic HAP emissions limit for all open molding operations at the facility, and then separately demonstrate compliance with the weighted average organic HAP emissions limit for all centrifugal casting operations at the facility. The Permittee shall not average open molding operations and centrifugal

40 CFR Section 63.5810(c); Minn. R. 7011.7800

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casting operations together.(1) Within 30 days following the end of 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 in Appendix F to this permit.

(2) Within 30 days following the end of each month, the Permittee shall calculate the weighted average organic HAP emissions factor for open molding and centrifugal casting, using Equation W3 in Appendix F to this permit.

(3) Within 30 days following the end of each month, the Permittee shall compare the values calculated in paragraphs (1) and (2) of this requirement. If each 12-month rolling average organic HAP emissions factor is less than or equal to the corresponding 12-month rolling average organic HAP emissions limit, then the source is in compliance.

Meet the HAP Emission Limit for one application method and use the same resin(s) for all application methods of that resin type.

The Permittee shall perform the compliance demonstration for this option within 30 days following the end of each month. This option is limited to resins of the same type. The resin types for which this option may be used are noncorrosion-resistant, corrosion-resistant and/or high strength, and tooling.

(1) For any combination of manual resin application, mechanical resin application, filament application, or centrifugal casting, the Permittee may elect to meet the organic HAP emissions limit for any one of these application methods and use the same resin in all of the resin application methods listed in this paragraph. The possible combinations based on a facility selecting the application process that results in the highest allowable organic HAP content resin are presented in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section below. If the resin organic HAP content is below the applicable value shown in the next section of the NESHAP subp. WWWW section of this permit, the resin is in compliance.

(2) The Permittee may also use a weighted average organic HAP content for each application method described in paragraph (1) of this requirement. To do so, the Permittee shall calculate the weighted average organic HAP content monthly using the following procedures:

- Use Equation W1 in Appendix F to this permit, except substitute organic HAP content for organic HAP emissions factor.

The Permittee is in compliance if the weighted average organic HAP content based on the last 12 months of resin use is less than or equal to the applicable organic HAP contents in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section below.

40 CFR Section 63.5810(d); Minn. R. 7011.7800

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(3) The Permittee may simultaneously use the averaging provisions in options (b) or (c) above to demonstrate compliance for any operations and/or resins not included in the compliance demonstration in paragraphs (1) and (2) of this requirement. However, any resins for which the Permittee claims compliance under the option in paragraphs (1) and (2) of this requirement may not be included in any of the averaging calculations described in options (b) or (c) above.

(4) The Permittee is not required to keep records of resin use for any of the individual resins where compliance is demonstrated under the option in paragraph (1) of this requirement unless the Permittee elects to include that resin in the averaging calculations described in paragraph (2) of this requirement.

EMISSION FACTORS – OPEN MOLDING AND CENTRIFUGAL CASTING OPERATIONS hdr

Calculating Organic HAP Emission Factors for Open Molding and Centrifugal Casting: The Permittee shall use the equations in Table W1 of Appendix F to this permit to calculate the emission factors. Equations are available for each open molding operation and centrifugal casting operation and have units of pounds of organic HAP emitted per ton (lb/ton) of resin or gel coat applied.

Emission factors are used to determine compliance with certain organic HAP emission limits in the HAP Emission Limits section above. These equations are intended to provide a compliance demonstration method without the need to conduct HAP emission testing.

The Permittee may also use the organic HAP emissions factors calculated using the equations in Table W1, combined with resin and gel coat use data, to calculate the organic HAP emissions from fiberglass operations at the facility.

40 CFR Section 63.5796; Minn. R. 7011.7800

Determining organic HAP content of resins and gel coats: To determine the organic HAP content of resins and gel coats, the Permittee may rely on information provided by the material manufacturer, such as manufacturer’s formulation data and safety data sheets (SDS), using the following procedures:

(a) Include in the organic HAP total each organic HAP that is present at 0.1 percent by mass or more for Occupational Safety and Health Administration-defined carcinogens, as specified in 29 CFR 1910.1200(d)(4) and at 1.0 percent by mass or more for other organic HAP compounds.

(b) If the organic HAP content is provided by the material supplier or manufacturer as a range, the Permittee shall use the upper limit of the range for determining compliance. If a separate measurement of the total organic HAP content, such as an analysis of the material by EPA Method 311 of appendix A to 40 CFR part 63, exceeds the upper limit of the range of the total organic HAP content provided by the material supplier or manufacturer, then the Permittee shall use the measured organic HAP content to determine compliance.

40 CFR Section 63.5797; Minn. R. 7011.7800

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(c) If the organic HAP content is provided as a single value, the Permittee may use that value to determine compliance. If a separate measurement of the total organic HAP content is made and is less than 2 percentage points higher than the value for total organic HAP content provided by the material supplier or manufacturer, then the Permittee still may use the provided value to demonstrate compliance. If the measured total organic HAP content exceeds the provided value by 2 percentage points or more, then the Permittee shall use the measured organic HAP content to determine compliance.

Calculating organic HAP emissions for applicability determination: The Permittee shall use the following procedures to calculate the facility’s organic HAP emissions in tpy for purposes of determining which paragraphs of 40 CFR section 63.5805 apply to the source.

(a) For new facilities prior to startup, calculate a weighted average organic HAP emissions factor for the operations specified in 40 CFR sections 63.5805(c) and (d) on a lbs/ton of resin and gel coat basis. Base the weighted average on the projected operation for the 12 months subsequent to facility startup. Multiply the weighted average organic HAP emissions factor by projected resin use over the same period. The Permittee may calculate the organic HAP emissions factor based on the factors in Table W1 of Appendix F to this permit, or the Permittee may use any HAP emissions factor approved by the MPCA, such as factors from the “Compilation of Air Pollutant Emissions Factors, Volume I: Stationary Point and Area Sources (AP-42),” or organic HAP emissions test data from similar facilities.

(b) For existing facilities and new facilities after startup, the Permittee may use the procedures in either paragraph (b)(1) or (2) below. If the emission factors for an existing facility have changed over the period of time prior to their initial compliance date due to incorporation of pollution-prevention control techniques, existing facilities may base the average emission factor on their operations as they exist on the compliance date. If an existing facility has accepted an enforceable permit limit that would result in less than 100 tpy of HAP measured prior to any add-on controls, and can demonstrate that they will operate at that level subsequent to the compliance date, they can be deemed to be below the 100 tpy threshold.

(1) Use a calculated emission factor. Calculate a weighted average organic HAP emissions factor on a lbs/ton of resin and gel coat basis. Base the weighted average on the prior 12 months of operation. Multiply the weighted average organic HAP emissions factor by resin and gel coat use over the same period. The Permittee may calculate this organic HAP emissions factor based on the equations in Table W1 of Appendix F to this permit, or the Permittee may use any organic HAP emissions factor approved by the MPCA, such as factors from AP-42, or site-specific organic HAP emissions factors if they are supported by HAP emissions

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test data.

(2) Conduct performance testing. Conduct performance testing using the test procedures in 40 CFR section 63.5850 to determine a site-specific organic HAP emissions factor in units of lbs/ton of resin and gel coat used. Conduct the test under conditions expected to result in the highest possible organic HAP emissions. Multiply this factor by annual resin and gel coat use to determine annual organic HAP emissions. This calculation must be repeated and reported to MPCA and EPA annually by February 2 for the previous year.

(c) The Permittees of existing facilities shall initially perform this calculation based on their 12 months of operation prior to April 21, 2003, and include this information with their initial notification report. The Permittees of existing facilities shall repeat the calculation based on their resin and gel coat use in the 12 months prior to their initial compliance date, and submit this information with their initial compliance report. After their initial compliance date, existing and new facilities shall recalculate organic HAP emissions over the 12-month period ending June 30 or December 31, whichever date is the first date following their compliance date specified in 40 CFR section 63.5800. Subsequent calculations should cover the periods in the semiannual compliance reports.

The Permittee is not required to calculate or report emissions under this requirement if the source is an existing facility that does not have centrifugal casting or continuous lamination/casting operations, or a new facility that does not have any of the following operations: Open molding, centrifugal casting, continuous lamination/casting, pultrusion, SMC and BMC manufacturing, and mixing. Emissions calculation and emission reporting procedures in other sections of 40 CFR pt. 63, subp. WWWW still apply.

For centrifugal casting operations at existing facilities, the Permittee shall not include any organic HAP emissions where resin or gel coat is applied to an open centrifugal mold using open application techniques. Table W1 and the Table W1 footnotes in Appendix F to this permit present more information on calculating centrifugal casting organic HAP emissions.

ORGANIC HAP CONTENT FOR USE OF THE SAME RESIN ACROSS DIFFERENT OPERATIONS OF THE SAME RESIN TYPE

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If the Permittee elects to use the same resin(s) for multiple resin applications, the Permittee shall use any resin(s) with an organic HAP content less than or equal to the values in the following requirements, or any combination of resins whose weighted average organic HAP content based on a 12-month rolling average is less than or equal to the values in the following requirements.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

For centrifugal casting CR/HS resins, resin weight must be less than or equal to:

48.0 percent organic HAP content, or weighted average weight percent

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table

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organic HAP content, for CR/HS mechanical. Nonatomized mechanical application must be used.

48.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS filament application.

48.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual.

The Permittee shall not blow heated air through the molds for these centrifugal casting operations.

If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option.

7; Minn. R. 7011.7800

For nonatomized mechanical CR/HS resins, resin weight must be less than or equal to:

46.4 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS filament application.

46.4 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

For filament application CR/HS resins, resin weight must be less than or equal to:

42.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

For filament application non-CR/HS resins, resin weight must be less than or equal to:

45.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual.

45.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS mechanical. Nonatomized mechanical application must be used.

48.0 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS centrifugal casting.

The Permittee shall not blow heated air through the molds for these centrifugal casting operations.

If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

For nonatomized mechanical non-CR/HS resins, resin weight must be less than or equal to:

38.5 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS centrifugal casting.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

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38.5 percent organic HAP content, or weighted average weight percent organic HAP content, for CR/HS manual.

The Permittee shall not blow heated air through the molds for these centrifugal casting operations.

If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option.

For centrifugal casting non-CR/HS resins, resin weight must be less than or equal to:

37.5 percent organic HAP content, or weighted average weight percent organic HAP content, for non-CR/HS manual.

The Permittee shall not blow heated air through the molds for these centrifugal casting operations.

If the centrifugal casting molds are not vented, the Permittee may treat the centrifugal casting operations as if they were vented if the Permittee elects to use this compliance option.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

For nonatomized mechanical tooling resins, resin weight must be less than or equal to:

91.4 percent organic HAP content, or weighted average weight percent organic HAP content, for tooling manual.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

For manual tooling resins, resin weight must be less than or equal to:

45.9 percent organic HAP content, or weighted average weight percent organic HAP content, for tooling atomized mechanical.

40 CFR pt. 63, subp. WWWW: Section 63.5810(d) and Table 7; Minn. R. 7011.7800

COMPLIANCE OPTIONS – NEW AND EXISTING CONTINUOUS LAMINATION/CASTING OPERATIONS

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The Permittee shall use one or more of the following options to meet the standards for continuous lamination/casting operations listed above in the HAP Emission Limits and Work Practice Standards sections:

(a) Compliant line option: The Permittee shall demonstrate that each continuous lamination line and each continuous casting line complies with the applicable standard.

(b) Averaging option: The Permittee shall demonstrate that all continuous lamination and continuous casting lines combined, comply with the applicable standard.

(c) Combination option: The Permittee shall use any combination of options in paragraphs (a) and (b) of this requirement to demonstrate compliance.

40 CFR Section 63.5820; Minn. R. 7011.7800

COMPLIANCE OPTIONS – PULTRUSION OPERATIONS hdr

The Permittee shall use one or more of the following options to meet the standards 40 CFR Section

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for pultrusion operations subject to the 60 weight percent organic HAP emission reductions requirement listed above in the HAP Emission Limits and Work Practice Standards sections:

(a) Use direct die injection pultrusion machines with resin drip collection systems that meet all the following criteria:

- All the resin that is applied to the reinforcement is delivered directly to the die;

- No exposed resin is present, except at the face of the die; and- Resin drip is captured in a closed system and recycled back to the

process.

(b) Use a preform injection system that meets the following definition:- A form of pultrusion where liquid resin is injected to saturate

reinforcements in an enclosed system containing one or more chambers with openings only large enough to admit reinforcements. Resin, which drips out of the chamber(s) during the process, is collected in closed piping or covered troughs and then into a covered reservoir for recycle. Resin storage vessels, reservoirs, transfer systems, and collection systems are covered or shielded from the ambient air. Preform injection differs from direct die injection in that the injection chambers are not directly attached to the die.

(c) Use any combination of options in paragraphs (a) or (b) of this requirement in which different pultrusion lines comply with different options described in paragraphs (a) or (b) of this requirement, and:

- Each individual pultrusion machine meets the 60 percent reduction requirement; or

- The weighted average reduction based on resin throughput of all machines combined is 60 percent. For purposes of the average percent reduction calculation, wet area enclosures reduce organic HAP emissions by 60 percent, and direct die injection and preform injection reduce organic HAP emissions by 90 percent.

63.5830; Minn. R. 7011.7800

TESTING AND INITIAL COMPLIANCE DEMONSTRATION REQUIREMENTS hdr

Initial Performance Testing: The Permittee shall conduct performance tests, performance evaluations, design evaluations, and other initial compliance demonstrations by the compliance date specified in Table 2 to 40 CFR pt. 63, subp. WWWW.

Exceptions: For open molding and centrifugal casting operations that elect to meet an organic HAP emissions limit on a 12-month rolling average, the Permittee shall initiate collection of the required data on the compliance date, and demonstrate compliance 1 year after the compliance date.

40 CFR Section 63.5840; Minn. R. 7011.7800

Initial Compliance: The Permittee shall demonstrate initial compliance with each 40 CFR Section

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organic HAP emissions standard 40 CFR Section 63.5805 that applies to the fiberglass operations at the facility by using the procedures in the requirements below.

63.5860; Minn. R. 7011.7800

Initial Compliance: For open molding and centrifugal casting operations that must meet an organic HAP emissions limit in the HAP Emissions Limit section above, or an organic HAP content limit in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, the Permittee has demonstrated initial compliance if:

(i) The Permittee has met the appropriate organic HAP emissions limits for these operations as calculated using the procedures in the Compliance Options – New and Existing Open Molding and Centrifugal Casting Operations section above on a 12-month rolling average 1 year after the appropriate compliance date; and/or

(ii) The Permittee demonstrates that any individual resins or gel coats not included in (i) above, as applied, meet their applicable emission limits; or

(iii) The Permittee demonstrates using the appropriate values in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above that the weighted average of all resins and gel coats for each resin type and application method meet the appropriate organic HAP contents.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 8; Minn. R. 7011.7800

Initial Compliance: For continuous lamination/casting operations that must:

(a) reduce total organic HAP emissions by at least 58.5 weight percent, the Permittee has demonstrated initial compliance if total organic HAP emissions, based on the calculation procedures specified in 40 CFR sections 63.5865 through 63.5890, are reduced by at least 58.5 percent by weight.

(b) not exceed an organic HAP emissions limit of 15.7 lbs of organic HAP per ton of neat resin plus and neat gel coat plus, the Permittee has demonstrated initial compliance if total organic HAP emissions, based on the calculation procedures specified in 40 CFR sections 63.5865 through 63.5890, do not exceed 15.7 lbs of organic HAP per ton of neat resin plus and neat gel coat plus.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 8; Minn. R. 7011.7800

Initial Compliance: For pultrusion operations that must reduce total organic HAP emissions by at least 60 percent by weight, the Permittee has demonstrated initial compliance if, as part of the notification of initial compliance status, the Permittee submits a certified statement that all pultrusion lines for which an emission reduction is being claimed are using direct die injection and/or wet-area enclosures that meet the criteria listed in the Compliance Options – Pultrusion Operations section above.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 8; Minn. R. 7011.7800

Initial Compliance: For new or existing closed molding operations using compression/injection molding that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that only one charge is uncovered, unwrapped, or exposed per mold cycle per compression/injection molding machine, or prior to the loader, hoppers are closed

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 9; Minn. R. 7011.7800

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except when adding materials, and materials are recovered after slitting.

Initial Compliance: For new or existing closed molding operations using compression/injection molding that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that only one charge is uncovered, unwrapped, or exposed per mold cycle per compression/injection molding machine, or prior to the loader, hoppers are closed except when adding materials, and materials are recovered after slitting.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 9; Minn. R. 7011.7800

Initial Compliance: For new or existing cleaning operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that all cleaning materials, except styrene contained in closed systems, or materials used to clean cured resin from application equipment, contain no HAP.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 9; Minn. R. 7011.7800

Initial Compliance: For new or existing materials HAP-containing materials storage operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that all HAP-containing storage containers are kept closed or covered except when adding or removing materials, and that any bulk storage tanks are vented only as necessary for safety.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 9; Minn. R. 7011.7800

Initial Compliance: For existing or new SMC manufacturing operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that the resin system is closed or covered and that a nylon-containing film is used to enclose SMC.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 9; Minn. R. 7011.7800

Initial Compliance: For existing or new mixing or BMC manufacturing operations that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits certified statements in the notice of compliance status that:

- mixer covers are closed during mixing except when adding materials to the mixers, and that gaps around mixer shafts and required instrumentation are less than 1 inch;

- mixers are not actively vented to the atmosphere when the agitator is turning except when adding materials or as necessary for safety; and

- mixers are closed except when adding materials to the mixing vessels.

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 9; Minn. R. 7011.7800

Initial Compliance: For new or existing pultrusion operation manufacturing parts that meet the following criteria: 1,000 or more reinforcements or the glass equivalent of 1,000 ends of 113 yield roving or more; and have a cross sectional area of 60 square inches or more; and that must meet the requirements in the Work Practice Standards section above, the Permittee has demonstrated initial compliance if the Permittee submits a certified statement in the notice of compliance status that they have

40 CFR pt. 63, subp. WWWW: section 63.5860(a) and Table 9; Minn. R. 7011.7800

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complied with all the requirements listed in 40 CFR pt. 63, subp. WWWW Table 9, items 9.i through 9.vii.

CONTINUOUS COMPLIANCE REQUIREMENTS hdr

Facilities meeting an organic HAP emissions standard based on a 12-month rolling average shall begin collecting data on the compliance date in order to demonstrate compliance.

40 CFR section 63.5800; Minn. R. 7011.7800

The Permittee shall demonstrate continuous compliance with each standard in the HAP Emission Limits and Work Practice Standards sections above according to the following methods:

- Compliance with organic HAP emissions limits is demonstrated by maintaining an organic HAP emissions factor value less than or equal to the appropriate organic HAP emission limit listed in the HAP Emission Limits section above, on a 12-month rolling average, and/or by including in each compliance report a statement that individual resins and gel coats, as applied, meet the appropriate organic HAP emission limits, as discussed below in the Recordkeeping section.

- Compliance with organic HAP content limits in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above is demonstrated by maintaining an average organic HAP content value less than or equal to the appropriate organic HAP contents listed in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, on a 12-month rolling average, and/or by including in each compliance report a statement that resins and gel coats individually meet the appropriate organic HAP content limits in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, as discussed below in the Recordkeeping section.

- Compliance with the Work Practice Standards section above is demonstrated by performing the work practice required for the operation.

The Permittee shall meet the organic HAP limits and work practice standards that apply to operations at the facility during periods of startup, shutdown, or malfunction.

40 CFR Section 63.5900 (a) and (e); Minn. R. 7011.7800

The Permittee shall report each deviation from each applicable standard in the HAP Emission Limits and Work Practice Standards sections above. The deviations shall be reported according to the requirements below.

40 CFR Section 63.5900 (b); Minn. R. 7011.7800

COMPLIANCE DEMONSTRATIONS – CONTINUOUS LAMINATION CASTING OPERATIONS

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Calculations for wet-out areas and ovens: To calculate the annual uncontrolled organic HAP emissions from the wet-out areas and ovens at the facility, the Permittee shall:

- develop uncontrolled wet-out area and uncontrolled oven organic HAP

40 CFR Section 63.5870; Minn. R. 7011.7800

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emissions estimation equations or factors to apply to each formula applied on the line,

- determine how much of each formula for each end product is applied each year on each line, and

- assign uncontrolled wet-out area and uncontrolled oven organic HAP emissions estimation equations or factors to each formula.

Uncontrolled organic HAP emissions estimation equations and factors: To develop uncontrolled organic HAP emissions estimations and factors, the Permittee shall, at a minimum, do the following:

(1) Identify each end product and the thickness of each end product produced on the line. Separate end products into the following end product groupings, as applicable: corrosion-resistant gel coated end products, noncorrosion-resistant gel coated end products, corrosion-resistant nongel coated end products, and noncorrosion-resistant nongel coated end products. This step creates end product/thickness combinations.

(2) Identify each formula used on the line to produce each end product/thickness combination. Identify the amount of each such formula applied per year. Rank each formula used to produce each end product/thickness combination according to usage within each end product/thickness combination.

(3) For each end product/thickness combination being produced, select the formula with the highest usage rate for testing.

(4) If not already selected, also select the worst-case formula (likely to be associated with the formula with the highest organic HAP content, type of HAP, application of gel coat, thin product, low line speed, higher resin table temperature) amongst all formulae. (The Permittee may use the results of the worst-case formula test for all formulae if desired to limit the amount of testing required.)

(5) For each formula selected for testing, conduct at least one test (consisting of three runs). During the test, track information on organic HAP content and type of HAP, end product thickness, line speed, and resin temperature on the wet-out area table.

(6) Using the test results, develop uncontrolled and controlled organic HAP emissions estimation equations (or factors) or series of equations (or factors) that best fit the results for estimating uncontrolled and controlled organic HAP emissions, taking into account the organic HAP content and type of HAP, end product thickness, line speed, and resin temperature on the wet-out area table.

In lieu of using the method specified above in this requirement for developing uncontrolled organic HAP emissions estimation equations and factors, the Permittee

40 CFR Sections 63.5870(a) and (b); Minn. R. 7011.7800

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may elect to use the following method:- For uncontrolled organic HAP emissions estimates, the Permittee may use

previously established, facility-specific organic HAP emissions equations or factors, provided they allow estimation of both wet-out area and oven organic HAP emissions, where necessary, and have been approved by the MPCA.

- If a previously established equation or factor is specific to the wet-out area only, or to the oven only, then the Permittee shall develop the corresponding uncontrolled or controlled equation or factor for the other organic HAP emissions source.

Determine how much of each formula for each end product is applied each year on each line: The Permittee shall assign to each formula an uncontrolled organic HAP emissions estimation equation or factor based on the end product/thickness combination for which that formula is used.

40 CFR Section 63.5870(c); Minn. R. 7011.7800

Calculate annual uncontrolled organic HAP emissions:

(1) To calculate the annual uncontrolled organic HAP emissions from wet-out areas that do not have any capture and control and from wet-out areas that are captured by an enclosure but are vented to the atmosphere and not to a control device, multiply each formula’s annual usage by its appropriate uncontrolled organic HAP emissions estimation equation or factor and sum the individual results.

(2) To calculate the annual uncontrolled oven organic HAP emissions, multiply each formula’s annual usage by its appropriate uncontrolled organic HAP emissions estimation equation or factor and sum the individual results.

40 CFR Section 63.5870(d); Minn. R. 7011.7800

Calculations for application of neat resin plus and neat gel coat plus: The Permittee shall use the following procedures to determine how much neat resin plus and neat gel coat plus is applied to each line for continuous lamination/casting operations each year:

(a) Track formula usage by end product/thickness combinations;(b) Use in-house records to show usage. This may be either from automated

systems or manual records;(c) Record daily the usage of each formula/end product combination on each

line. This is to be recorded at the end of each run (i.e., when a changeover in formula or product is made) and at the end of each shift; and

(d) Sum the amounts from the daily records to calculate annual usage of each formula/end product combination by line.

40 CFR Section 63.5880; Minn. R. 7011.7800

Calculating organic HAP emissions factors: The Permittee shall use one of the following options to calculate an organic HAP emissions factor to demonstrate compliance for continuous lamination/casting operations:

(a) Compliant line option: use Equation W4 of Appendix F to this permit to

40 CFR Section 63.5890; Minn. R. 7011.7800

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calculate an organic HAP emission factor in lbs/ton.(b) Averaging option: use Equation W5 of Appendix F to this permit to

demonstrate compliance.(c) Combination option: use Equations W4 and W5 of Appendix F to this permit,

as applicable, to demonstrate compliance.

RECORDKEEPING hdr

Calculations for new and existing open molding and casting operations: Within 30 days following the end of each month, the Permittee shall complete the necessary calculations to demonstrate compliance with the standards for new and existing open molding and casting operations.

These calculations are described above in the Compliance Options - New and Existing Open Molding and Casting Operations Section.

40 CFR Section 63.5810; Minn. R. 7011.7800

Monitor and Collect Data to Demonstrate Continuous Compliance if not Using an Add-On Control Device: The Permittee shall monitor and collect data as specified below:

(1) Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the Permittee shall conduct all monitoring in continuous operation (or collect data at all required intervals) at all times that the affected source is operating.

(2) The Permittee shall not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities for purposes to this subpart, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The Permittee shall use all the data collected during all other periods in assessing the operation of the control device and associated control system.

(3) At all times, the Permittee shall maintain necessary parts for routine repairs of the monitoring equipment.

(4) A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring equipment to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions.

40 CFR Section 63.5895 (b); Minn. R. 7011.7800

Recording and Recordkeeping to meet organic HAP emissions: The Permittee shall collect and keep records of resin and gel coat use, organic HAP content, and operation where the resin is used if the Permittee is meeting any organic HAP emissions limits based on an organic HAP emissions limit in the HAP Emission Limit section above.

The Permittee shall collect and keep records of resin and gel coat use, organic HAP content, and operation where the resin is used if the Permittee is meeting any organic HAP content limits listed in the Organic HAP Content For Use of the Same Resin Across Different Applications of the Same Resin Type section above, if you are

40 CFR Section 63.5895 (c);Minn. R. 7011.7800

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averaging organic HAP contents.

Resin use records may be based on purchase records if the Permittee can reasonably estimate how the resin is applied. The organic HAP content records may be based on information provided by the material manufacturer, such as manufacturer’s formulation data and safety data sheets (SDS), or on resin specifications supplied by the resin supplier.

Recording and Recordkeeping for all resins and gel coats: For the individual resins and gel coats for which the Permittee demonstrates, as applied, meet their applicable emission limit as defined in the “Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit” requirement in the Compliance Options – New and Existing Open Molding and Centrifugal Casting Operations section above, resin and gel coat use records are not required.

- However, the Permittee shall retain the records of resin and gel coat organic HAP content, and shall include the list of these resins and gel coats and identify their application methods in the semiannual compliance reports.

- If, after the Permittee has initially demonstrated that a specific combination of an individual resin or gel coat, application method, and controls meets its applicable emission limit, the resin or gel coat changes or the organic HAP content increases, or the Permittee changes the application method or controls; then the Permittee again shall demonstrate that the individual resin or gel coat meets its emission limit as specified in the HAP Emission Limits section above.

o If any of these changes results in a situation where an individual resin or gel coat now exceeds its applicable emission limit as specified in the “Demonstrate that an individual resin or gel coat, as applied, meets the applicable HAP Emission Limit” requirement in the Compliance Options – New and Existing Open Molding and Centrifugal Casting Operations section above, the Permittee shall begin collecting resin and gel coat use records and calculate compliance using one of the averaging options on a 12-month rolling average.

40 CFR Section 63.5895 (d); Minn. R. 7011.7800

Recording and Recordkeeping for pultrusion machines: For each pultrusion machine at the facility, the Permittee shall record all times that the wet area enclosures doors or covers are open and there is resin present in the resin bath.

40 CFR Section 63.5895 (d); Minn. R. 7011.7800

Recording and Recordkeeping for continuous lamination/casting operations: For continuous lamination/casting affected sources complying with a percent reduction requirement or a lbs/ton limit, the Permittee shall generate the following data:

- For each wet-out area, the Permittee shall determine the annual uncontrolled wet-out area organic HAP emissions.

- For each oven, the Permittee shall determine the annual uncontrolled oven organic HAP emissions.

- For each line, the Permittee shall determine the amount of neat resin plus

40 CFR pt. 63, subp. WWWW: sections 63.5865 (a) and (b), Tables 11 and 12; Minn. R. 7011.7800

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applied, and the amount of neat gel coat plus applied.

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Records: The Permittee shall keep the records of the following:

1) A copy of each notification and report the Permittee submits to comply with 40 CFR pt. 63, subp. WWWW, including all documentation supporting any Initial Notification or Notification of Compliance Status the Permittee submit, according to the requirements in 40 CFR Section 63.10(b)(2)(xiv).

2) The records in 40 CFR Section 63.6(e)(3)(iii) through (v) related to startup, shutdown, and malfunction.

3) Records of performance tests, design, and performance evaluations as required in 40 CFR Section 63.10(b)(2).

c) The Permittee shall keep all data, assumptions, and calculations used to determine organic HAP emissions factors or average organic HAP contents for operations listed in the HAP Emission Limits and Work Practice Standards sections above.

d) The Permittee shall keep a certified statement that the Permittee is in compliance with the requirements in the Work Practice Standards section above, as applicable.

e) For a new or existing continuous lamination/ casting operation, the Permittee shall keep the records listed in paragraphs (e)(1) through (4) of this section, when complying with the percent reduction and/or lbs/ton requirements specified in paragraphs (a) and (c) through (d) of 40 CFR Section 63.5805.

(1) The Permittee shall keep all data, assumptions, and calculations used to determine percent reduction and/or lbs/ton as applicable;

(2) The Permittee shall keep a brief description of the rationale for the assignment of an equation or factor to each formula;

(3) When using facility-specific organic HAP emissions estimation equations or factors, the Permittee shall keep all data, assumptions, and calculations used to derive the organic HAP emissions estimation equations and factors and identification and rationale for the worst-case formula; and

(4) For all organic HAP emissions estimation equations and organic HAP emissions factors, the Permittee shall keep documentation that the appropriate permitting authority has approved them.

40 CFR Sections 63.5915(a) and (c)-(e); Minn. R. 7011.7800

Records Retention: The Permittee shall maintain all applicable records in such a manner that they can be readily accessed and are suitable for inspection according to 40 CFR Section 63.10(b)(1).

As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

The Permittee shall keep each record onsite for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to Section63.10(b)(1). The Permittee may keep the records offsite for the remaining 3 years.

The Permittee may keep records in hard copy or computer readable form including, paper, microfilm, computer floppy disk, magnetic tape, or microfiche.

40 CFR Section 63.5920; Minn. R. 7011.7800

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REPORTING, NOTIFICATIONS, AND SUBMITTALS hdr

Notification of threshold exceedance: If the facility emits greater than or equal to 100 tpy of HAP in any calendar year, the Permittee shall notify the MCPA in the compliance report.

Note: exceeding the 40 CFR pt. 63, subp. WWWW threshold of 100tpy of HAP also exceeds the 12.5 tpy permit cap on total HAP emissions and is a violation of the permit terms. This notification of exceeding the 40 CFR pt. 63, subp WWWW 100tpy threshold is in addition to any other actions required as a result of violating the permit terms.

40 CFR Section 63.5805(e); Minn. R. 7011.7800

Initial Notification for an existing source: The Permittee shall submit an initial notification with the information specified in 40 CFR Section 63.9(b), no later than 120 calendar days after April 21, 2004, (or within 120 calendar days after the source becomes subject to Subpart WWWW). Use Form 4W-01.

40 CFR Section 63.9(b)(c); 40 CFR Section 63.5905(a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R. 7011.7800

Initial Notification for a new source: The Permittee shall submit an initial notification with the information specified in 40 CFR Section 63.9(b)(4) and (5), delivered or postmarked within 15 calendar days after the actual date of startup of the source. Use Form 4W-01

40 CFR Section 63.9(b)(4) and (5); 40 CFR Section 63.5905(a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R. 7011.7800

Notice of Compliance Status, existing sources: The Permittee of an existing affected source shall submit a notification of compliance status as specified in 40 CFR Section 63.9 if the Permittee is complying with organic HAP emission limit averaging provisions by May 21, 2007.

40 CFR Section 63.9(h); 40 CFR Section 63.5905(a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R. 7011.7800.

Notice of Compliance Status, existing sources: The Permittee of an existing affected source shall submit a notification of compliance status as specified in 40 CFR Section 63.9 if the Permittee is complying with organic HAP contents limits, application equipment requirements or organic HAP emissions limit other than organic HAP emission limit averaging by May 21, 2007.

40 CFR Section 63.9(h); 40 CFR Section 63.5905(a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R. 7011.7800.

Notice of Compliance Status, new sources: The Permittee of a new affected source shall submit a notification of compliance status as specified in 40 CFR Section 63.9 if the Permittee is complying with organic HAP emission limit averaging provisions by May 21, 2004, or no later than one year and 30 days after the date of initial startup of the affected source, whichever is later.

40 CFR Section 63.9(h); 40 CFR Section 63.5905(a) and Table 13 to 40 CFR pt. 63, subp. WWWW; Minn. R. 7011.7800.

Notice of Compliance Status, new sources: The Permittee of a new affected source shall submit a notification of compliance status as specified in 40 CFR Section 63.9 if the Permittee is complying with organic HAP contents limits, application equipment requirements or organic HAP emissions limit other than organic HAP emission limit

40 CFR Section 63.9(h); 40 CFR Section 63.5905(a) and Table 13 to 40 CFR pt. 63,

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averaging by May 21, 2004, or no later than one year and 30 days after the date of initial startup of the affected source, whichever is later.

subp. WWWW; Minn. R. 7011.7800.

Notification of Changes to Previous Notifications: The Permittee must submit the changes in writing to the Administrator within 15 calendar days after the change, if the Permittee changed any information submitted in any previous notification.

40 CFR Section 63.5905(b); Minn. R. 7011.7800

Semiannual Compliance Report: due 31 days after the end of each calendar half-year starting on the compliance date for each affected source. The report shall contain the information specified below:

(1) Company name and address;(2) Statement by a responsible official with that official’s name, title, and

signature, certifying the truth, accuracy, and completeness of the content of the report;

(3) Date of the report and beginning and ending dates of the reporting period;(4) If there was a startup, shutdown, or malfunction during the reporting period

and the Permittee took actions consistent with the startup, shutdown, and malfunction plan, the compliance report shall include the information in 40 CFR Section 63.10(d)(5)(i);

(5) If there are no deviations from any applicable organic Hap emissions limitations (emissions limit and operating limit), and there are no deviations from the requirements in the Work Practice Standards section above, a statement that there were no deviations from the organic HAP emissions limitations or work practice standards during the reporting period;

(6) For each deviation from an organic HAP emissions limitation and each deviation from the requirements for work practice standards that occurs at an affected source, the total operating time of each affected source during the reporting period and information on the number, duration, and cause of deviations (including unknown cause, if applicable) as applicable, and the corrective action taken;

(7) If organic HAP emissions in the fiberglass operations at the facility have exceeded the 100 tpy emission threshold; and

(8) Where multiple compliance options are available, a statement if the Permittee has changed compliance options since the last compliance report.

40 CFR Sections 63.5910(a)-(d) and (f)-(i); Minn. R. 7011.7800

Immediate Startup, Shutdown, and Malfunction Report: The Permittee shall submit to the MPCA actions taken for the event by fax or telephone within 2 working days after starting actions inconsistent with the plan.

40 CFR pt. 63, subp. WWWW: section 63.5910(h) and Table 14; Minn. R. 7011.7800

Immediate Startup, Shutdown, and Malfunction Report: The Permittee shall submit the information in 40 CFR 63.10(d)(5)(ii) by letter within 7 working days after the end of the event unless the Permittee has made alternative arrangements with the MPCA.

40 CFR pt. 63, subp. WWWW: section 63.5910(h) and Table 14; 40 CFR Section 63.10(d)(5)(ii); Minn. R. 7011.7800

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