Technical Support Document for the Amendment of 

10 CSR 10-6.400, Restriction of Emission of Particulate Matter from Industrial 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The adopted rule amendment eliminates outdated information and clarifies the intent of the 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 from air pollution control staff from the 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 for 
coating 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 of Emission of Particulate Matter From Industrial Processes 

Emission 

Unit Description MHDR- 

(lblhr) - 

~ Emission Factor 

Uncontrolled , , ~ontrolled PM (E)_ 

, Process WeightLimit 

lb (1b/hr ) 1bs/hr 

Aluminum Die 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 weight 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 System Robotic 

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 of Particulate 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 from pounds/hour to grains/standard cubic feet, the following equation is used: 

Emission Rate(gr / dscf ) = Emission Rate I 

lb x 7000 grains _ Stack Flow Rate (SCFM) 1 

hr ) ( lb ) 60 min/ hr i 

Stack flow rates 'are derived from the reported actual stack flow rate (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 

Aluminum Die Cast Melting Furnaces (x3) 

EP-83 83 500 533 .1 1974 1097.43 0.96 f 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