Technical Support Document for the Amendment of

10 CSR 10-6.400, Restriction of Emission of Particulate Matter fromIndustrial Processes Background This rule restricts emissions of particulate matter from an operation, process, or activity
. The adopted rule amendment eliminates outdated information and clarifies the intent of the regulation by : 1) properly referencing the recently moved construction permit exemptions in 10 CSR 10- 6 .061 ; and 2) adds new

exemptions to the rule for : a. coating operations, b
. units subject to a more stringent standard, and c . units that have an uncontrolled potential to emit less than the allowable emissions
. The rule amendment is the result of input fromair pollution control staff fromthe Department of Natural Resources and St
. Louis city and county . Staff requested that exemptions be added for facilities for which the rule was not originally intended, such as spray booths
. As a result of the comments, the Missouri Air Program Advisory Forum

formed a workgroup to address changes to the rule
. The, workgroup was organized and composed of individuals and organizations familiar with the process weight rule
. The workgroup, which included department staff and members of the regulated community, developed the draft rule language
. The proposed rule amendment was filed with the Joint committee on Administrative Rules and the Secretary of State on September 9, 2008
. The proposed amendment was published in the Missouri Register on October 15, 2008
. Subsequently, a public hearing was held on the proposed amendment before the Missouri Air Conservation Commission on December 4, 2008
. The proposed rule amendment was adopted by the Commission on February 3, 2009
. Demonstration The U .S
. Environmental Protection Agency (EPA) Region VII Office commented in a letter dated December 11, 2008, that they would like the department to provide a demonstration that the proposed exemption for coating operations will not adversely affect ambient air
. Members of the workgroup requested the coating operation exemption to eliminate the need for facilities with coating operations to perform engineering calculations that always result in showing that it would be physically impossible for their units to exceed the limits contained in the rule
. The rule specifies that the exempted coating operations would have to control at least 95 percent of the particulate overspray. It is in a facility's best financial interest to recover as much of the material as possible in coating operations, which inherently results in the added benefit of decreased particulate matter (PM) emissions
. Even with the rule exemption forcoating operations, the PM levels at many .applicable facilities are very minimal, especially as a result of the controls in place that also minimize volatile organic compound and hazardous air pollutant emissions
. The attached tables are from a permit for the TG Missouri Corporation, which is one of the larger spray coating operators in the state. The tables are provided as examples of the calculations required in permits that justify how it is physically impossible to exceed the limits in the rule
. Table 2 shows that the controlled emission rate of the coating operations at the TG Missouri facility are well below

the calculated process weight limit
. Table 3 shows that the same coating operations are also well below the 0 .30 grain per standard cubic foot emission rate of the rule
. Conclusion Table 2 contains PM

data about the coating operations found at TG Missouri
. The controlled emission rate for each coating emission point is well below the emission rate limitation calculated using the process weight rule
. For example, the injection paint booths (Emission Points 60 and 61), have a controlled emission rate of 0 .01 lb/hr
. Using the formula provided in the rule, the emission rate limit is 0 .071b/hr
. The coating operation exemption to the rule will not be a relaxation of emissions control because the TG Missouri Corporation and other coating operations will not be doing anything differently
. Since facilities attempt to recover as much of the material as possible in coating operations, they will still control their emissions with this exemption, but will no longer have to calculate the emission rate limit using the calculation provided in the rule
. Therefore, the addition of an exemption for coating operations has a negligible impact on air quality
.From

: Part 70 Permit to Operate (OP2008-022) for TG Missouri Corporation Attachment E 10 CSR 10-6 .400 Restriction ofEmission ofParticulate Matter FromIndustrial Processes
Emission Unit Description MHDR- (lblhr) - ~

Emission Factor Uncontrolled , , ~ontrolled PM (E)_ Process WeightLimit , lb (1b/hr) 1bs/hr AluminumDie Cast EU00 Melting Furnaces (x3) 0 .1605 tph 3 lbs PM,o/ton 0.963 --- 1,2 EP-83 EU00 Fluidized Bed Parts

Cleaner EP-167 0.457 t h 2 .25 lb PMIO /ton 2.06 10.41 2.43 `Unit is equipped with bag filtration providing control efficiency of 80%
. , ZE = 4.10(P)o .b' Where : E = rate of emission in lb/hr P = process wei g ht rate in tons/hr
Table 2 MHDR PM Emission . Uncontrolled '
. Controlled ; L (E) Unit Description Solvent Factor,, Transfer 'Emission . ; Emiission , .` Emission PWR (Emission Point No.)', Usage (lb/ton efficiency ,rate ; Control' rate =limit tons/hr ( ) .,Coatin ~(lb/lir) = , (lb/hr)

- . (lb/hr) Injection Paint Booths (B-1) EP-60, EP-61 ' 0 .0023 1080.40 50.00% 1 .24 99.00% 0 .01 0.07 Side Molding Automated Paint Booth P-1 (EP-69, EP-70) 0.0081 1362.80 50.00% 5 .52 99.00% 0.06 0 .16 Building 1 Paint Booth (P-0) (EP-81) 0.0080 1080 .40 50.00% 4.32 99.00% 0.04 0.16 Back Panel (Rear Garnish) Paint Booth (P-2 (EP-128) 0.0021 1828.00 50.00% 1 .92 99.00% 0.02 0.07 Mudguard Paint Booth (P-3) (EP-132, EP-133) 0.0025 1828.00 50.00% 2.29 99 .00% 0.02 0.07 Air Bag/Column Cover Paint Booth (P-4) (EP-137, EP-138) 0.0035 1744.60 50.00% 3 .05 99.00% 0.03 0.09 Air Bag Robotic Paint Booths (P-5, P-6) (EP-146, EP-147) 0.0084 1011 .20 50 .00% 4.25 99.00% 0 .04 0 .17 Air Bag Robotic Paint Booth (P-7) (EP-159) 0.0046 1148 .00 50.00% 2.64 99 .00% 0.03 0.11 Robotic Paint booths (P-9) (EP-176, 177, 179, 180) 0.0070 1775.00 50.00% 6.21 99.00% 0.06 0.15 Chain on Edge Spray SystemRobotic Paintbooth (P-8) (EP-184) 0.0105 660.00 65.00% 2.43 99.00% 0.02 0.19 Table 1

Since the calculated particulate matter emission rates are much less than the respective limits, it is highly unlikely that these units will exceed the limits of 10 CSR 10-6.400(3)(A)(1)
.Attachment E (Continued)

10 CSR 10-6.400 Restriction of Emission ofParticulate Matter From Industrial Processes To evaluate compliance with the emission limit of 0.30 gr/scf of 10 CSR 10-6.400(3)(A)(4), the calculated emission rate of each unit as listed in the previous tables must be converted into the proper units
. To convert the emission rate frompounds/hour to grains/standard cubic feet, the following equation is used : Emission Rate(gr / dscf) = Emission Rate I lb x 7000grains
_ Stack Flow Rate (SCFM) 1 

### hr ) ( lb ) 60 min/ hr i Stack flow

rates 'are derived fromthe reported actual stack flowrate (ACFM) after standardization to SCFM utilizing Ideal Gas Law
. Table 3

, U~iit~Description : Emission Temp Temp ' PM

(Emissioni Point No.) Points - °F ACFM SCFM (lb/hr) PM (gr/scf) Injection Paint Booths (B-1) EP-60, EP-6 1 60-61 350 449.8 5912 3895 .62 0.07 0.002 Side Molding Automated Paint Booth (P-1) EP-69, EP-70 69-70 75 297 .0 4700 4689 .89 0.06 0.001 Building 1 Paint Booth (P-0) (EP-81) 80-82 282 412.0 1100 791 .28 0 .02 0.004 AluminumDie Cast Melting Furnaces (x3) EP-83 83 500 533 .1 1974 1097 .43 0.96f 0.102 Back Panel (Rear Garnish) Paint Booth (P-2) (EP-128 ,126-131 73 295.9 2211 2214.53 0.02 0.001 Mudguard Paint Booth (P-3) EP-132, EP-133 132-136 73 295 .9 2503 2506.99 0.02 0.001 Air Bag/Column Cover Paint Booth (P-4 (EP-137, EP-138 137-143 73 295.9 10998 11015 .55 0.03 0.000 Air Bag Robotic Paint Booths (P-5, P-6) EP-146, EP-147 144-148 190 360.9 1330 1092 .22 0.04 0.005 Air Bag Robotic Paint Booth (P-7) EP-159) 155-162 200 366.5 1200 970.52 0.03 0.003 Fluidized Bed Parts Cleaner 167 75 297 .0 7000 6984.94 0.41 0.007 Robotic Paint Booths (P-9) EP-176, 177, 179, 180 171-183 70 294.3 24000 24174.45 0 .06 0 .000 Chain on Edge Spray System Robotic Paint Booth P-8) (EP-184) 184-187 70 294.3 46000 46334.36 0.02 0.000 j