United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-91-013
December 1992
Air
Enabling Document
for Regulations Governing
Compliance Extensions for
Early Reductions of
Hazardous Air Pollutants
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TABLE OF CONTENTS
1.0 Introduction and Overview ...... ...... 1-1
2.0 The Regulations 2-1
ง63.70 Applicability . . . 2-1
ง63.71 Definitions -..".- 2-1
ง63.72 General Provisions For Compliance Extensions 2-1
ง63.73 Source 2-4
ง63.74 Demonstration of Early Reductions 2-14
ง63.75 Enforceable Commitments 2-26
ง63.76 Review of Base Year Emissions 2-34
ง63.77 Application Procedures 2-40
ง63.78 Early Reductions Demonstration Evaluation 2-42
ง63.79 Approval of Applications 2-45
ง63.80 Enforcement .......... 2-49
ง63.81 Rule for Special Situations 2-50
3.0 Program Implementation 3-1
Enforceable Commitments 3-1
Steps in the System 3-3
Reviewer Checklists for Enforceable Commitments 3-7
Base Year Submittals -3-9
Permit Applications 3'10
4.0 Interface with the 33/50 (Industrial Toxics) Project 4-1
Description of the 33/50 Project 4-1
Interface Between 33/50 and The Early Reductions Program 4-3
APPENDIX A: Guidelines for Submitting Enforceable Commitments
Introduction v........... A-1
Organization of This Appendix A-2
Note on Confidential Business Information A-2
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TABLE OF CONTENTS
(concluded)
Contents of a Complete Enforceable Commitment Preferred Order
of Presentation ........................... .
Page
A-3
A. Cover Letter ............. . . . ". ................... A-4
Sample Cover Letter ............ ................... A-5
B. Table of Contents ................................. A-7
Sample Table of Contents ................ ........... A-8
C. Site Plan . . . ; ............ . ........... .... ....... A-9
Sample Site Plan .................... . ........... A-10
D. Source Identifying Information ....................... A-11
E. Emissions Data ....... ........... ............... A-15
F. Sample Enforceable Commitment ..... ............... A-17
APPENDIX B: Reviewer Checklists
Form A - Source Data Sheet
Form B - Completeness Review
Form C - Technical Review
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Table
1-1
2-1
2-2
2-3
2-4
2-5
LIST OF TABLES
Emissions Comparison Early Reductions vs.
Section 112(d) Standards .. - - 1-2
Information Requirements for Demonstration of Early Reduction ... 2-15
Weighting Factors for High-Risk Pollutants. 2-19
Standards Anticipated for Proposal Prior to 1994 .............. 2-27
EPA Regional Office Addresses 2-29
Components of an Enforceable Commitment 2-30
in
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LIST OF FIGURES
Pg.ure Page
1-1 Early Reductions Program: Duration of Overall Program 1-4
2-1 Overview of the Early Reductions Program 2-3
2-2 Chemical Plant Schematic Entire Facility 2-7
2-3 Chemical Plant Schematic Functional and Geographical 2-9
2-4 Chemical Plant Schematic Potentially Unacceptable Selective
Grouping 2-10
2-5 Metal Coating Operation 2-11
2-6 Chemical Plant Schematic Process Train 2-13
2-7 Early Reductions Program: Duration of Key Activities .. 2-35
2-8 Example Review Times 2-36
2-9 Early Reductions Program: Duration of Key Activities 2-43
3-1 Management System for Review of Enforceable Commitments 3-4
IV
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1.Q INTRODUCTION AND OVERVIEW
The purpose of this Enabling Document is to provide practical information on
implementation of the Early Reductions Program, including explanations of the
requirements and procedures for early reductions demonstration submittals and review
of the submittals. The primary goal is to enable the Regional Offices of the U. S.
Environmental Protection Agency (EPA) and States to better understand the Program
and their roles, and thereby, better implement the Program.
On November 15,1990, the Clean Air Act (CAA) was amended. Significant
changes were made to Section 112 of the CAA establishing national emission
standards for hazardous air pollutants (HAP's). One of the new features of the CAA is
an incentive program by which an owner or operator can obtain a six-year extension
of compliance with an applicable Section 112(d) standard for achieving early
reductions in hazardous air pollutant emissions.
The purpose of the program is to encourage early reductions in HAP emissions.
Source owners and operators that participate in the Program will gain the benefit of
more time to develop strategies for compliance with Section 112(d) standards. Ideally,
this will give them an opportunity to develop more cost-effective emission reduction
approaches. In addition, participating companies can enjoy the benefit of improved
community relations when they become publicly recognized for taking positive steps to
improve the environment.
At the same time, the public benefits because HAP emissions are significantly
reduced earlier than they would be if sources delayed control until they were subject
to Section 112(d) standards. Moreover, the Early Reductions Program has the
potential to not only lower annual emissions early, but also lower overall long-term
emissions from the source. The long-term environmental benefit is illustrated by
example in Table 1-1. Consider a source emitting HAP's at a rate of 100 tons per
year. Assume that this source achieves a 90-percent reduction in HAP emissions, to a
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TABLE 1-1. EMISSIONS COMPARISON
EARLY REDUCTIONS Vง. SECTION 112(d) STANDARD
TIME
(YEARS)
1 (year between proposal
and promulgation)
2
3
4 (third year after
promulgation)
5
6
7
8
g
10 (last year of
compliance extension)
TOTALS
CONTROL
ง11 2(d) STANDARD
100
100
100
100
2
2
2
2
2
2
412
SCENARIO
EARLY REDUCTIONS
10
10
10
10
10
10
10
10
10
10
100
Assumptions: 100 ton/yr source (uncontrolled); Section 112(d) standard achieves
98-percent control; Section 112(d) standard compliance date is 3 years after
promulgation; 9 years after Section 112(d) standard promulgation, Section 112(d)
standard applies to source which received a compliance extension.
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rate of 10 tons per year, just prior to proposal of an applicable Section 112(d)
standard, and receives a six-year compliance extension. In comparison, consider
an identical 100 ton per year source which does not achieve early reductions, but
complies with the Section 112(d) standard three years after the standard is
promulgated. Assuming the Section 112(d) standard requires 98 percent
reduction, the source participating in the Early Reductions Program would emit only
100 tons of HAP's over a ten-year period in comparison to 412 tons from the
source that waits and complies with the Section 112{d) regulation. After that
time, both sources would be subject to the Section 112(d) standard and HAP
emissions can be assumed to be equal.
The Early Reductions Program has long-term implications on the State and
Regional EPA permitting authorities that will administer the Program. As illustrated
in Figure 1-1, the duration of the overall program will be about 18 years, from
1991 until November 2009. Figure 1-1 illustrates that some submittals for the
Program (enforceable commitments) were received beginning in 1991. The last
compliance extension for the last Section 112(d) standard promulgated under Title
III of the Act will expire by November of 2009 (if all standards are promulgated by
the year 2000), thus formally ending the effects of the Early Reductions Program.
Initially, the Program will be administered by the EPA Regional Offices. Then, as
the individual permitting programs of the States are approved under Title V, the
respective States will take over administration of the Program.
On December 29, 1992, the EPA promulgated regulations governing
compliance extensions for early reductions of HAP's under subpart D of 40 CFR 63
(57 FR 61970). The rule establishes requirements and procedures for source
owners and operators to follow in order to obtain compliance extensions, and for
reviewing agencies to follow in evaluating requests for extensions.
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The regulations are organized according to the following sections:
Section 63.70
Section 63.71
Section 63.72
Section 63.73
Section 63.74
Section 63.75
Section 63.76
Section 63.77
Section 63.78
Section 63.79
Section 63.80
Section 63.81
Applicability.
Definitions.
General provisions for compliance extensions.
Source.
Demonstration of early reduction.
Enforceable commitments.
Review of base year emissions.
Application procedures.
Early reduction demonstration evaluation.
Approval of applications.
Enforcement.
Rule for special situations.
1-5
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2.0 THE REGULATIONS
This chapter provides a discussion of the individual sections of the proposed
regulation. Where appropriate, the underlying rationale for specific parts of the
regulation are discussed and guidance on implementation of the regulations is
provided. In addition, the EPA has published a separate document that addresses
questions regarding the rule. This document is entitled "Questions and Answers about
the Early Reductions Program" (EPA-450/3-92-005, January 1992) and is available
from the EPA library.
SECTION 63.70 - APPLICABILITY
The rules of the Early Reductions Program only apply to owners or operators of
sources who voluntarily apply for a compliance extension from Section 112(d)
standards.' The provisions of the rule also apply to State or local agencies who are
given authority by the EPA to operate a permit program under Trtle V of the CAA.
SECTION 63.71 - DEFINITIONS
This section identifies any terms that require special interpretations. All terms
that are not found in this section are given the same meaning as in the CAA or in
General Provisions of Part 63 of the Code of Federal Regulations.
SECTION 63.72 - GENERAL PROVISIONS FOR COMPLIANCE EXTENSIONS
This section of the regulation basically restates the main provisions outlined
under Section 112(5)(5) of the Clean Air Act (CAA). Under these provisions, the
Administrator or a State acting pursuant to a permitting program approved under
Title V shall by permit allow an existing source to meet an alternative emission
limitation in lieu of an emission limitation promulgated under Section 112(d) standard,
for a period of 6 years from the compliance date of the applicable standard, providing
the source owner or operator:
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(1) demonstrates that the source has achieved (i) 90 percent overall
(95 percent for paniculate emissions) reduction in base year HAP
emissions and (ii) a 90 (95) percent reduction in base year HAP
emissions adjusted for high-risk pollutant weighting fastors; and
(2) that such reduction is achieved before proposal of an applicable
Section 112(d) standard, or before January 1, 1994, provided that an
enforceable commitment was made prior to proposal of the earliest
applicable standard to that source.
As illustrated in Figure 2-1, this creates two paths for participation in the Early
Reductions Program. For sources that achieve reductions prior to proposal of an
applicable Section 112(d) standard, the owner or operator can submit a permit
application along with a demonstration of early reductions. For sources that cannot
achieve the early reductions before proposal, but can achieve such reductions before
January 1,1994, the owner or operator can submit an enforceable commitment to
reduce base year emissions by 90 (95) percent, achieve the reduction before
January 1, 1994, and submit a permit application prior to December 1, 1993
demonstrating the early reduction. The difference between the two paths is the timing
of the reductions with respect to proposal of an applicable Section 112(d) standard,
and the ability to submit an enforceable commitment in the case off the initial
Section 112(d) standards. In either case, the end result of a successful early
reductions demonstration is an alternate emission limitation issued by permit which
grants the owner or operator a six-year extension from compliance with an applicable
Section 112(d) standard.
In addition to reducing aggregate HAP emissions by 90 (95) percent, the
general provisions require a separate 90 (95) percent reduction demonstration taking
Into account high-risk pollutant weighting factors. The owner or operator must multiply
the base year and post-reduction emissions of each individual HAP by the weighting
factor associated with the HAP and show that HAP emissions adjusted for high-risk
pollutants also have been reduced by 90 (95) percent. Additional discussion of this
demonstration is provided in later sections.
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TWO PATHS TO
PARTICIPATION IN
THE EARLY REDUCTIONS
PROGRAM
SOURCE ANALYSIS
WILL QUALIFYING
REDUCTIONS BE
ACHIEVED BEFORE
PROPOSAL OF AN
APPLICABLE 112(d)
STANDARD?
No
Yes
SUBMIT ENFORCEABLE
COMMITTMENT
(COMMIT TO ACHIEVE
REDUCTIONS BEFORE
JANUARY 1,1994)
i "* 1
I SUBMIT BASE YEAR 1
| ESTIMATE FOR REVIEW |
SUBMIT PERMIT
APPLICATION WHICH
CONTAINS EARLY
REDUCTIONS
DEMONSTRATION
PERMITTING AUTHORITY ISSUES
A PERMIT ESTABLISHING
ALTERNATIVE EMISSION
LIMITATION(S) FOR SOURCE
Figure 2-1. Overview of the Early Reductions Program.
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The CM specifically gives States the right to require more than 90 (95) percent
aggregate or individual pollutant reduction when the States are issuing permits under
this program. In addition, other procedures or requirements may apply to the source
at the State level. For example, a source may be required to obtain State
preconstruction and operating permits for any action it undertakes under the Early
Reductions Program, or the source may have to meet separate control requirements
imposed by existing State regulations for toxic air pollutants.
SECTION 63.73 - SOURCE
For purposes of the Early Reductions Program, source is defined as follows:
Sf
(1) A building, structure, facility or installation identified as a source by
the EPA in Appendix B (of the rule);
(2) All portions of an entire contiguous plant site under common ownership
or control that emit hazardous air pollutants;
(3) Any portion of an entire contiguous plant site under common ownership
or control that emit HAP's and can be identified as a facility, building,
structure, or installation for purposes of establishing (standards under
Section 112(d) of the CAA; or
(4) Any individual emission point or combination of emission points within a
contiguous plant site under common ownership or control, provided that
emission reduction from such point or aggregation of points constitutes a
significant reduction of hazardous air pollutant emissions of the entire
contiguous plant site;
For purposes of paragraph (4) of this section, emissions reductions are
considered significant if they are made from base year HAP emissions of not less than
(1) a total of 10 tons per year where the total emissions of hazardous air pollutants in
the base year from the entire contiguous plant site is greater than 25 tons; or (2) a
total of 5 tons per year of hazardous air pollutants where the total emissions of
hazardous air pollutants In the base year from the entire contiguous plant site is less
than 25 tons per year.
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Depending on a particular Section 112(d) standard, a source may be defined
broadly or narrowly, from a discrete emission point up to and including an entire plant.
This definition of source is consistent with the broad flexibility encompassed under
Section 111(a)(3) of the CAA and is designed to enhance the attractiveness of the
Early Reductions Program.
The scope of the definition is best illustrated by examining each paragraph of
the definition. Under paragraph (1), the EPA has, to date, identified only one group of
emission points as a source for purposes of establishing Section 112(d) standards.
These are equipment leak emission points from synthetic organic chemical facilities
and other related facilities identified in the Hazardous Organic NESHAP (National
Emission Standard for Hazardous Air Pollutants), or HON. Fugitive emissions from
equipment leaks have been identified as a source for purposes of establishing
standards under Section 112(d) with sufficient certainty to consider them separately.
The EPA has engaged in an extensive regulatory negotiation to establish proposed
Section 112(d) standards for equipment leaks from HON plants. [See the March 6, -
1991 issue of the Federal Register (56 FR 9315).] The draft regulation defines source
as the collection of applicable equipment (valves, pumps, connectors, etc.) within a
process unit that uses as a reactant or makes one of the organics listed as hazardous
in Section 112(b) of the CAA Amendments. In addition, the HON covers certain HAP's
in other selected industries, such as pharmaceutical manufacturing and pesticide
production. For the purposes of the negotiated rule, the process unit comprises all
equipment from the feedstock storage tanks through end product disposition and
wastewater treatment.
The negotiated regulation for equipment leaks will require that certain equipment
in HAP service within a process unit to which the standards are applicable must be
viewed as a whole. This is the case for valves, pumps, or connectors within a process
unit, which must be considered together, as the regulation is written in terms of
percent leaking components across a process unit. That is, valves, pumps, or
connectors cannot be split up such that some of the valves in a process unit have an
early reduction alternative emission limitation and the rest meet the Section 112(d)
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standard. For example, it must be that either all valves within a process unit are in the
Early Reductions Program or none are.
The logic for requiring inclusion of all the valves, pumps, or connectors from a
process unit, does not extend to the other equipment covered by the equipment leak
rule, such as pressure relief devices or product accumulator vessels, which will be
subject to individual standards applicable to each device or vessel, and not all devices
or vessels as a group. Equipment subject to such "piece-specific" standards could
individually be assigned alternative emission limits as part of an early reductions
source or meet the Section 112(d) standard, and are not constrained by the process
unit coverage.
Equipment leaks are treated as a separate class because they can occur
throughout the plant wherever process equipment handles fluids and are not
' . i! , .
associated with any particular type of discrete emission point, e.g., storage or process
vents. The negotiating committee recognized the need to treat equipment leaks
separately. Thus, for purposes of early reductions, the definition of source for these
types of emissions will be what is reflected in the regulatory language in the notice
" ' ' '
published on March 6, 1991. The EPA notes that tentatively identifying equipment
leaks as a source for early reductions is in no way meant to limit how "source" will be
defined for the purposes of any particular Section 112(d) standard, including the HON
equipment leak standard.
The second part of the definition (paragraph (2)) encompasses the entire
contiguous plant site. (See Figure 2-2.) Under paragraph (2) of the definition, if an
applicant designates the entire contiguous plant site as the source and demonstrates
that the total emissions of HAP's from the contiguous plant site have been reduced by
90 percent (or 95 percent for particulates), then the plant would receive a six-year
extension from any and all applicable Section 112(d) standards. The six-year
extension is added to the promulgated compliance date for each applicable standard.
A plantwide definition of source clearly falls within the definition of source under
Section 111(a)(3). Under this definition, a source owner or operator must also
2-6
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Tank farm
A ('
Process unit X
/'. too = ! ^.
K 1 s_ j A
Process unit Z
Transfer/loading
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm
i
rfTTh
DL
Transfer/loading
Contiguous plant boundary
"N
'Tank farm
B
Process unit Y
ฎ
V)
Tank
Process unit YY
Iฎ
ฎ
j Tank farm
'^N-, D
Figure 2-2. Chemical Plant Schematic
(Entire Facility)
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account for HAP emissions from new points or units in the post-reduction calculation,
unless the new point or unit can be considered a major source by itself.
A "source" may also be defined to encompass less than an entire plant.
However, only those points identified as part of the source would be eligible for the
six-year extension from Section 112(d) standards. Under paragraph (3) of the
definition, the applicant could identify groups of emission points, that have a functional
or geographical relationship to one another and that could be characterized as a
facility, building, structure or installation. (See Figure 2-3.) For example, the applicant
could identify a group of functionally similar points (Tank Farm B) as a source and
achieve a 90-percent reduction across that source. Alternatively, the applicant could
identify all tanks in one of the other areas (A, C, or D) as a separate source because
each of these areas could be defined as a tank farm installation or facility. Moreover,
the applicant could take one or more of the tanks out of service and credit that
reduction towards the 90 percent, provided the shutdown was permanent (or at least
would last until the end of the compliance extension period). Under paragraph (3),
however, the applicant could not identify a tank farm as the source and then subdivide
the tank farm to exclude a portion of the tanks because they were already partially
controlled. (See Figure 2-4.) This configuration of a source may, however, be
acceptable if the designated tanks meet the requirements of paragraph (4).
Generally, geographic grouping to form a source would only be allowed for
emission points of the same type within a logical physical area, as iin the examples
above. Under paragraph (3) it would not be acceptable to aggregate as a source
based on a geographical relationship several unrelated tanks, process vents,
wastewater units, etc, simply because they were all located on the same side of the
road. However, if a building or other enclosed structure houses a collection of
emission points, such a source definition would be consistent with Section 111(a)(3)'s
definition of source as "any building, structure, facility, or installation." For example, a
metal parts coating operation consisting of degreasers, painting lines, and paint
strippers within a single enclosed structure could collectively be considered a source.
(See Rgure 2-5).
2-8
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Tank farm
O
oo
Process unit X
(V)
Vent
OTJ-JJ.
(5iiHS5/-iUv%5HSฃ;P
Transfer/loading
Process unit Z
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm
Transfer/loading
Tank farm
B
Figure 2-3. Chemical Plant Schematic
(Functional and Geographical)
Process unit Y
Tank
Process unit YY
Tank farm
D
2-9
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Tank farm
O
oo
Process unit X
LT)
Transfer/loading
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm
Transfer/loading
Process unit Y
Tank
Process unit YY
O O Tankfarm
OOO D
Figure 2-4. Chemical Plant Schematic
(Potentially Unacceptable Selective Grouping)
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Degreasing
Painting
line
Coated
parts
Degreasing
Painting
line
Off
Specification
Paint
Stripping
Enclosed building
Figure 2-5. Metal Coating Operation
2-11
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Under paragraph (3), the applicant could also identify a process or production
unit as a source, such as all equipment associated with the production of chemical X.
An applicant, therefore, could identify as one "source" the outlined areas in Figure 2-6
which constitute a process unit and include all tanks in Area A, the vents on
Production Unit X, and the tanks in Area C. All points that are substantially dedicated
to a particular process must be included in the process unit source). In many
instances, however, some components of the plant will be shared by multiple process
units, e.g., a wastewater treatment system. For common or shared facilities which
serve or are linked with multiple process units, the applicant could consider the
common facility as part of a single process unit or treat it as a separate source. The
applicant has fairly broad flexibility to identify logical points that constitute a process
unit or production train. A 90-percent reduction in HAP emissions from each
component would not be required, provided the aggregate overall reduction is 90
percent. However, the applicant must achieve a 90-percent reduction in HAP
emissions from the entire process unit.
Under paragraph (4), a "source" may be defined as any group of emission
points provided that the aggregation of emission points represents a significant
amount of emissions. For the purposes of the Early Reductions Program, the EPA
has determined that a significant amount of emissions of HAP's from a source must
be: a) at least 10 tons per year where the total emissions of. HAP's in the base year
-I . i '..'( "
from the entire contiguous plant site is greater than 25 tons per year; or b) a
90 (95) percent reduction from base year emissions of at least 5 tons for plants that
emitted 25 tons or less of HAP's during the base year.
These source definition examples are meant to be illustrative of the types of
groupings that may reasonably fall within the definition of source for purposes of the
Early Reductions Program. The definition provides the maximum benefit to an
applicant who Is capable of making reductions in various parts of its plant, and is
trying to make reductions without actual knowledge as to how the EPA will define
various components of the plant as "sources" for purposes of particular Section 112(d)
standards. Each identified source would receive extensions from applicable
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Tank farm
Process unit X
O
oo
Process unit Z
po
Transfer/loading
Wastewater
Treatment
Wastewater
Treatment
Tank farm C
Transfer/loading
Tank
Figure 2-6. Chemical Plant Schematic
(Process Train)
Tank farm
B
Process unit Y
Tank
Process unit YY
Tank farm
D
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Section 112(d) standards. If a plant owner or operator chose to reduce plantwide
emissions by 90 percent, the entire plant would receive an extension from all
applicable Section 112(d) standards.
SECTION 63.74 - DEMONSTRATION OF EARLY REDUCTION
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This section of the regulation establishes the criteria for demonstrating early
reductions in HAP emissions. Demonstration of early reductions is the responsibility of
the owner or operator of the facility. In summary, the owner or operator must provide
four sets of information in order to demonstrate early reduction. These are:
Source identifying information,
Base year emissions,
Ppst-reduction emissions, and
Calculations to show that a 90 (95) percent reduction in HAP emissions
has been achieved.
!!|1 . ป , ,
The specific information requirements for demonstration of early reductions are
itemized in Table 2-1. Most of the information requirements are straightforward and
require no further discussion. Rather than discuss each requirement, the following
discussion focuses on several key requirements.
One of the key requirements is evidence that the source conforms to one of the
allowable source definition options under Section 63.73. Considerable discussion is
provided in the previous section on allowable groupings of emission sources. The key
here is for the owner or operator to identify the source definition option selected under
Section 63.73 [e.g., paragraph (3)] and provide adequate information to justify the
selection.
Another requirement is to specify the base year selected. The regulation
requires that the base year must be 1987 or later, with one exception. If the owner or
operator can provide evidence that data for the defined source were submitted to the
Administrator prior to November 15, 1990 for the year 1985 or 1986 and pursuant to a
Section 114 request, that data may also be used to establish a 1985 or 1986 base
year emissions. In this case, a copy of the Section 114 request and a copy of the
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TABLE 2-1. INFORMATION REQUIREMENTS FOR DEMONSTRATION
OF EARLY REDUCTIONS
Source Identifying Information:
(1) A description of the source including a site plan of the entire contiguous plant
site under common control which contains the source, and markings on the
site plan locating the parts of the site that constitute the source;
(2) The activity at the source which causes HAP's;
(3) A complete list of all emission points of HAP's in the source, including
identification numbers and short descriptive titles; and
(4) A statement showing that the source conforms to one of the allowable
definition options from Section 63.73. If the source conforms to the option in
Section 63.73(a)(4), the total base year emissions from the source, as
determined pursuant to this section, shall be at least:
(i) 5 tons per year, for cases in which total HAP emissions from the
entire contiguous plant site under common control is less than or
equal to 25 tons per year, or
(ii) 10 tons per year in all other cases.
Base Year Emissions:
(1) The base year chosen, where the base year shall be 1987 or later, except
that the base year may be 1985 or 1986 if the owner or operator of the
source can demonstrate that emission data for the source for 1985 or 1986
were submitted to the Administrator pursuant to an information request
issued under Section 114 of the CAA and were received by the Administrator
prior to November 15,1990;
(2) The best available data on an annual basis of actual emissions during the
chosen base year for each HAP emitted from each emission point or group
of emission points listed in the source;
(3) The total base year emissions of all HAP's from the source calculated by
summing the data from individual emission points;
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TABLE 2-1. INFORMATION REQUIREMENTS FOR DEMONSTRATION
OF EARLY REDUCTION (continued)
(4) The total base year emissions from the source adjusted for high-risk
pollutants calculated by multiplying the base year emissions of each HAP by
the appropriate weighting factor from Table 2-2 and summing the result;
(5) The supporting basis for each emission number for each emission point(s),
including:
(i) For test results submitted as the supporting basis, a description of
the test protocol followed, any problems encountered during the
testing, and a discussion of the validity of the method for measuring
the subject emissions;
00 For calculations based on emission factors, material balance, or
engineering principles and submitted as the supporting basis, a step-
by-step description of the calculations, including assumptions used,
and a brief rationale for the validity of the calculation method used;
and
(6) Evidence that the emissions from individual sources are not artificially or
substantially greater than emissions in other years prior to implementation of
emission reduction measures.
(7) A statement that the base year emissions are within allowable emission levels
specified in any applicable law, regulation, or permit condition.
Post-Reduction Emissions:
(1) For each emission point or defined group of emission points listed in the
source, a description of all reduction and/or control measures employed to
achieve the required emission reduction;
(2) The best available data on an annual basis of actual emissions of all HAP
from each emission point(s) in the source following employment of reduction
measures;
(3) The total post-reduction emissions of all HAP's from the source calculated by
summing the individual emission data;
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TABLE 2-1. INFORMATION REQUIREMENTS FOR DEMONSTRATION
OF EARLY REDUCTION (concluded)
(4) The total post-reduction emissions adjusted for high-risk pollutants calculated
by multiplying the post-reduction emissions for each pollutant by the
appropriate weighting factor and summing the results;
(5) The supporting basis for each emission number, including;
0) For test results submitted as the supporting basis, a description of
the test protocol followed, any problems encountered during the
testing, and a discussion of the validity of the method for measuring
the subject emissions; and
(ii) For calculations based on emission factors, material balance, or
engineering principles and submitted as the supporting basis, a step-
by-step description of the calculations, including assumptions used,
and a brief rationale for the validity of the calculation method used;
(6) Evidence that all emission reductions were achieved prior to proposal of an
applicable standard issued under Section 112(d) of the CAA; or prior to
January 1,1994 for sources subject to enforceable commitments;
(7) An accounting of all emissions increases within the plant site that are a result
of emission reductions within the early reductions source (increase hours of
operation, replacement equipment, etc.); and
(8) Evidence that there was no increase in radionuclide emissions from the
source. .
2-17
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information provided in response to the request would be sufficient evidence.
The owner or operator must also provide evidence that base year emissions
were not artificially or substantially higher than years prior to reduction measures.
Here, the owner or operator of the source needs to compile and present information
that clearly indicates the base year chosen is not unusual with respect to emissions.
This generally entails determining emissions from the source for several years. In
cases where annual emissions from the source are shown to be proportional to
production rate, production rates for three or four years preceding implementation of
emission reduction measures should be provided. In addition, the owner or operator
should include a written rationale explaining why emissions from the early reductions
source are proportional to production. In other situations, emissions may be more
dependent on the hours of operation or the quantity of a particular material processed.
It is the responsibility of the source owner or operator to take the initiative in identifying
a reasonable parameter for demonstrating that emissions in the base year were not
artificially or substantially high.
In addition to reducing total HAP emissions by 90 (95) percent, there are some
restrictions regarding high-risk pollutants. A total of forty-seven (47) high-risk
pollutants are identified in the early reduction regulations. The EPA has devised a
weighting procedure to limit the use of offsetting reductions where emissions of any
high-risk pollutant(s) are not reduced by 90 (95) percent. The list of' high-risk
pollutants and their respective weighting factors are presented in Table 2-2.
The weighting factors for the carcinogens on this list are based on estimated
carcinogenic potency of the substances. Noncarcinogens on this list were subjectively
assigned a value of 10. There is no quantitative means of comparing carcinogenic
and noncarcinogenic health effects at this time. The list and the respective weighting
factors are subject to change as new information becomes available. Any changes will
be published in the Federal Register. As noted in Table 2-2, all HAP's not included in
the high-risk list are assigned a weighting factor of one.
When high-risk pollutants are emitted from the source, the owner or operator
must make a second 90 (95) percent reduction demonstration, one in which HAP
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TABLE 2-2. WEIGHTING FACTORS FOR HIGH-RISK POLLUTANTS
Pollutant
Carcinogens
2-Acetylaminofluorine
Acrolein
Acrylamide
Acrylic Acid
Acrylonitrile
Arsenic Compounds
Asbestos
Benzene
Benzidene
Beryllium Compounds
Bis (chloromethly) ether
1,3- Butadiene
Cadmium Compounds
Chlordane
2-Chloroacetophenone
Chromium Compounds
Chloromethyl methyl ether
Coke oven emissions
Diazomethane
Dibenzofuran
1 ,2-Dibromo-3-chloropropane
Dichloroethyl ether
Dimethylcarbamoyl chloride
1 ,2-Diphenylhydrazine
Ethylene dibromide
Ethylenimine (aziridine)
Ethylene oxide
Heptachlor
Hexachlorobenzene
CAS Number
53963
107028
79061
79107
107131
0
1332214
71432
92875
0
542881
106990
0
57749
532274
0
107302
0
334883
132649
96128
111444
79447
122667
106934
151564
75218
76448
118741
Weighting Factor*
100
100
10
10
10
100
100
10
1000
10
.1000
10
10
100
100
100
10
10
10
10
10
10
100
10
10
100
1ฐ
100
100
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TABLE 2-2. WEIGHTING FACTORS FOR HIGH-RISK POLLUTANTS
(concluded)
Pollutant
CAS Number
Weighting Factor
Hexachlorocyclopentadiene
Hydrazine
Manganese compounds
Mercury Compounds
Methylene diphenly diiosocyanate
Methyl hydrazine
Methyl isocyanate
Nickel compounds
N-N'rtrosodimethylamine
N-Nitroso-N-methylurea
Parathfon
Phosgene
Phosphine
Phosphorus
1,2-PropyIenimine
2,3,7,8-Tetrachlorodibenzo-p-dioxin
Toxaphene
Vinyl chloride
75445
7803512
7723140
75558
1746016
8001352
75014
10
100
10.
100
10
10
10
10
100
1000
10
10
10
10
100
100,000
100
10
*HAP not on the high risk list have a weighting factor of 1
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emissions are adjusted for high-risk pollutants. The applicant must use the applicable
weighting factors according to the following equation to make this second
demonstration:
Percent Reduction =
jFj - ฃ
X100
Where:
Mj =
MCj
Fi
mass of base year emissions of pollutant i
mass of post-reduction emissions of pollutant i
weighting factor for pollutant i
This weighting procedure is a direct response to the mandate in
Section 112(i)(5)(E) of the CAA that specifies that the Administrator shall limit the use
of offsetting reductions in emissions of other HAP's to compensate for lesser
reductions for high-risk pollutants. Originally, the EPA considered requiring 90 (95)
percent reduction of each individual high-risk pollutant. Many of the high-risk ,
pollutants, however, are emitted in very small, trace amounts. Reduction of these
emissions by 90 (95) percent can be extremely difficult or even technically infeasible.
Strict adherence to this requirement would prevent participation for many potential
applicants. The EPA determined that this was not consistent with encouraging
participation in the Early Reductions Program and devised the weighting procedure,
which does not force reduction of any specific high-risk pollutants. However, because
the weighting factors magnify the importance of high-risk pollutant emissions,
significant (non-trace) emissions must be reduced in order to achieve "weighted"
90 (95) percent reduction.
Although sources emitting both gaseous and paniculate HAP's generally would
have to demonstrate separately 90 and 95 percent reductions to qualify, there is one
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exception. Some sources may have individual emission points thsit emit both gaseous
and particulate HAP's. For these emission points, a weighted-average-percent
reduction between 90 and 95 percent may be demonstrated. The required reduction
in such a case is determined by the relative amounts of gases and particulates emitted
by the point. For example, if an emission point emits equal amounts of gaseous and
particulate HAP's, then the weighted-percent reduction is halfway between 90 and 95,
or 92.5 percent. The percent reduction required for total HAP's shall be calculated
as follows:
%W= 0.9 (ฃ Mcrt + 0.95 (ฃ MD) v|m
ฃ Mg + ฃ Mp
Where: % W = the required percent-reduction
Mg = the base year mass rate (e.g. kg/yr) of each
gaseous HAP
Mp = ' the base year mass rate (e.g. kg/yr) of each
particulate HAP
The same percent reduction calculated above for an emission point that emits both
gases and particulates also must be applied in the weighted post-reduction
demonstration.
In general, source testing is required as the supporting basis for base year and
post-reduction emissions. In order of preference, the source testing options are: an
EPA Reference Method (40 CFR 60 Appendix A and 40 CFR 61 Appendix B), an EPA
conditional method, or a test method validated by Method 301. Method 30.1, "The
Reid Validation of Emission Concentrations from Stationary Sources", is included in
Appendix A to 40 CFR Part 63. A list of validated methods may be obtained from the
Emission Measurement Technical Information Center (MD-19), U. S. Environmental
Protection Agency, Research Triangle Park, North Carolina 27711.
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Calculations based on engineering principles, emission factors, or material
balance may be acceptable if the applicant demonstrates to the satisfaction of the
permitting authority that:
(1) no source test method exists;
(2) it is not technologically or economically feasible to perform source tests;
(3) it can be demonstrated that the accuracy of a calculated estimate is
comparable to source testing;
(4) the base year conditions no longer exists, and emission data cannot be
produced by performing source tests under current conditions and
converting test results to reflect base year conditions more accurately
than a calculation procedure; or
(5) emissions from one or a set of points are insignificantly small
compared to total source emissions.
The first situation should be straightforward; either there is, or there is not, a
source test method. It is possible that an owner or operator would be unaware of an
existing method. Application reviewers would need to have a reference listing of
available methods. In other instances, even if a test method exists, testing may not
be the most appropriate method for determining the emissions from an emission point.
For example, if process emissions vary considerably, limited testing may not
accurately reflect the true annual emissions. The situations outlined in statements (2)
through (5) above are not straightforward and may be considered in combination with
one another. For example, the significance of an emission point may contribute to the
determination of what is technologically or economically feasible or whether the
calculated value is comparable to testing. To apply these reasons to a particular
source, the owner or operator and reviewer need to use a common sense approach
along with knowledge of the emission point to determine if a calculation procedure is
appropriate for establishing emissions.
In general, the owner or operator or reviewer should consider how much
uncertainty would be introduced through the calculation procedure versus source
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testing. In some cases, the reviewer may be able to quantify the relative uncertainty.
In other situations it may only be possible to make a qualitative judgement of the
accuracy. If the uncertainty in emissions is insignificant when compared to the total
emissions from the facility or when compared to the uncertainty from source tests,
then a calculation procedure is acceptable. For example, a source has defined three
emission points. Total emissions from two of the three emission points are established
by source testing to be 100 ton/year. The third emission point by reasonable
calculation emits about 0.5 ton/year. Testing for this emission point is not necessary.
Even if the calculations underestimated the emissions, the resulting emissions would
not significantly affect the total emissions.
The applicant and the reviewer should not lose sight of the overall goal of the
reductions demonstration which is to determine whether or not the source has made
the necessary 90 (95) percent reduction in emissions of HAP's. The major emission
points within th.e source are the critical data points. The most accurate means of
establishing emissions should be used for these emissions. The most accurate means
may or may not be testing. Smaller, insignificant emissions should be established
using the best procedures considering that source testing may not be required., Test
methods that are unusually expensive or that require equipment to be dismantled or
production halted should not be imposed on emission points that contribute
insignificantly to the overall emissions.
The applicant is responsible for providing sufficient data to the reviewer to
determine if calculations are acceptable in lieu of testing. If the reviewer needs
additional technical assistance, support is available through the Office of Air Quality
Planning and Standards early reductions team.
If the source owner or operator uses calculation techniques; other than those
prescribed in one of the EPA documents, the burden is on the owner or operator to
convince the permitting authority that the techniques used are sound and the best
available means for establishing emissions.
The early reductions rule allows the use of EPA average emission factors for
estimating base year equipment leak emissions (such as from pumps, valves, etc.)
2-24
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only if no reductions in equipment leak emissions are claimed as part of the reduction
demonstration. Use of these factors may produce significant overestimates of base
year emissions in many cases. However, source owners or operators could establish
base year estimates for equipment leaks specific to their sources consistent with other
equipment leak emission estimating protocols already established by the EPA in the
document entitled "Protocols for Generating Unit-Specific Emission Estimates for
Equipment Leaks of VOC and VHAP,"EPA-450/3-88-010, October, 1988. These
protocols allow the use of "leak/no leak" factors or "stratified" emission factors, which
better approximate an individual source's actual emissions, as well as actual bagging
data to establish source-specific emission factors. The specific protocol selected
should be used for both base year and post-reduction emissions, so that apparent
reductions are not construed as simply a change in the methodology. The source
should have screening data on most components proposed to be covered within the
source definition, to which the appropriate emission factors are applied to determine
total equipment leak emissions. Also, a source owner or operator may propose an
alternative estimating method to account for equipment leak emissions from the
source. Such methods would be reviewed and approved or denied on a case-by-case
basis. ' '
Emissions reported for base year and post-reduction conditions may not
exceed allowable emission levels specified in any applicable law, regulation, or permit
condition. Sources with base year emissions that exceeded allowable emission levels
may still participate in the Early Reductions Program, but the base year emissions
used to demonstrate 90 (95) percent reduction will be the allowable level and not the
actual emission level.
To demonstrate a 90-percent (95 percent for paniculate emissions) HAP
emission reduction, source owners and operators may take credit for emission
reductions achieved for any reason. The early reduction provisions in the CAA and in
the rule do not distinguish between reductions achieved voluntarily and those that
result from other regulatory requirements, including emission standards promulgated
under Section 112 prior to the CAA Amendments of 1990. Therefore, HAP emission
2-25
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reductions required by State, local, and even Federal regulations qualify toward the
early reduction goal, if the reduction was achieved after the base year. This includes
reductions under the recent benzene NESHAP. To the .extent justified, air emission
reductions achieved under the 33/50 Program can also be credited toward the Early
Reductions Program. The overlap between this program and the Early Reductions
Program is discussed fully in Section 4.0 of this document. Emission reductions
resulting from shutdown or curtailment of production can also be included, provided
that they are "permanent", i.e., for the duration of the 6-year
Section 112(d) standard extension period. A unit that starts up during the
Section 112(d) standard extension period to replace production lost through shutdown
or curtailment (where the emission reduction was used in the early reduction
demonstration) must be included in the post-reduction emissions. For example, if the .
owner or operator of a source that includes a butadiene unit, shuts the unit down but
builds a new one on the other side of the plant three years into the Section 112(d)
standard extension period, the new unit must be included in the post-reduction
emissions determination, because ft has replaced the production of the old unit.
SECTION 63.75 - ENFORCEABLE COMMITMENTS
This section of the rule contains special provisions for sources that will be
affected by Section 112(d) standards proposed prior to 1994. Anticipated standards
for specific source categories are presented in Table 2-3. Since standards may be
proposed for some sources in the near future, facilities affected by these standards
may not have enough time to achieve reductions before proposal. If the source can
achieve the reductions prior to proposal of a Section 112(d) standard, it may do so
and submit a permit application when Part 71 Federal regulations have been
promulgated or the Title V program for their State is in place, whichever occurs first. If
it can not achieve reductions prior to proposal, this section establishes a set of
procedures by which these sources can participate in the Early Reductions Program.
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TABLE 2-3. STANDARDS ANTICIPATED FOR PROPOSAL
PRIOR TO 1994
Source
Synthetic Organic Chemical Manufacturing
Industry
Dry Cleaners Using Perchloroethylene
(proposed 12/9/91)
Commercial Sterilizers
Chromium Electroplating and Chromic
Acid Anodizing
Industrial Cooling Towers
Halogenated Solvent Cleaners
Gasoline Marketing
2-27
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The sources may participate by:
(1) entering into an enforceable commitment before proposal of an
applicable Section 112(d) standard; and
(2) achieving the reduction prior to January 1, 1994.
The applicant submits the enforceable commitment to the appropriate EPA
Regional Office and sends a copy each to the State; The EPA's Stationary Source
Compliance Division (SSCD), Mail Code EN-341-W, 401 M. Street, S.W., Washington,
DC 20460, and the EPA Emissions Standards Division (ESD) (MD-13), Research
Triangle Park, North Carolina 27711. AH correspondence should be addressed to the
attention of the Early Reductions Officer. Addresses for the Regional Offices are
provided in Table 2-4. This will ensure that all involved parties are siware of the
applicant's plans for early reductions and will facilitate review of the submittal.
The information required in the enforceable commitment is similar to that
required for a permit application. In summary, the enforceable commitment consists
of four components:
A properly signed statement of commitment,
Source identifying information,
Base year emissions, and
General plan for achieving the required reductions.
A list of the specific requirements for enforceable commitments is provided in
Table 2-5. The source identifying information and base year emission requirements
are identical to the requirements for demonstration of early reductions. An example
enforceable commitment is provided in Appendix A to provide guidance to owners and
operators planning to enter the Program.
The plan for achieving reductions may be general (i.e., not specify the type
control on each emission point), but should demonstrate that the source has seriously
considered the types of control that may be required to control the source by
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TABLE 2-4. EPA REGIONAL OFFICE ADDRESSES
Enforceable commftments must be submitted to the.appropriate EPA Regional Office
at the following addresses, attention of the Early Reductions Officer:
Director, Air, Pesticides, and Toxics Management Division, EPA Region I (AAA),
John F. Kennedy Federal Building, Boston, MA 02203
Director, Air and Waste Management Division, EPA Region II, Jacob K. Javits
Federal Plaza, New York, NY 10278
Director, Air Toxics and Radiation Management Division, EPA Region 111,
841 Chestnut Street, Philadelphia, PA 19107
Director, Air, Pesticides, and Toxics Management Division, EPA Region IV,
345 Courtland Street, N.E., Atlanta, GA 30365
Director, Air and Radiation Division, EPA Region V, 230 South Dearborn Street,
Chicago, IL 60604
Director, Air, Pesticides and Toxics Division, EPA Region VI, 1445 Ross Avenue,
12th Floor, Suite 1200, Dallas, TX 75202
Director, Air, and Toxics Division, EPA Region VII, 726 Minnesota Avenue,
Kansas City, KS 66101
Director, Air and Toxics Division, EPA Region VIII, 999 18th Street, Suite 500,
Denver, CO 80202-2405
Director, Air and Toxics Division, EPA Region IX, 1235 Mission Street,
San Francisco, CA 94103
Director, Air and Toxics Division, EPA Region X, 1200 Sixth Avenue,
Seattle, WA 98101
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TABLE 2-5. COMPONENTS OF AN ENFORCEABLE COMMITMENT
Source Identifying Information:
(1) A description of the source including a site plan of the entire contiguous plant
site under common control which contains the source, and markings on the
site plan locating the emission points that constitute the source;
(2) The activity at the source which causes HAP's;
(3) A complete list of all emission points of HAP's in the source, including
identification numbers and short descriptive titles; and
(4) A statement showing that the source conforms to one of the allowable
definition options from Section 63.73. If the source conforms to the option in
Section 63.73(a)(4), the total base year emissions from the source, as
determined pursuant to this sectipn, shall be at least:
(i) 5 tons per year, for cases in which total HAP emissions from the entire
contiguous plant site under common control are less than or equal to 25
tons per year, or
05) 10 tons per year in all other cases.
Base Year Emissions:
(1) The base year chosen, where the base year shall be 1987 or later except that
the base year may be 1985 or 1986 if the owner or operator of the source can
demonstrate that emission data for the source for 1985 or 1986 were submitted
to the Administrator pursuant to an information request issued under
Section 114 of the CAA and were received by the Administrator prior to
November 15,1990;
(2) The best available data on an annual basis of actual emissions during the
chosen base year for each HAP emitted from each emission point or group of
emission points listed in the source;
(3) The total base year emissions of all HAP's from the source calculated by
summing the data from individual emission points;
(4) The total base year emissions from the source adjusted for high-risk pollutants
calculated by multiplying the base year emissions of each HAP by the
appropriate weighting factor from Table 2-2 and summing the result;
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TABLE 2-5. COMPONENTS OF AN ENFORCEABLE COMMITMENT
(continued)
(5) The supporting basis for each emission number for each emission point(s),
including:
0) For test results submitted as the supporting basis, a description of the test
protocol followed, any problems encountered during the testing, and a
discussion of the validity of the method for measuring the subject
emissions; and
V
00 For calculations based on emission factors, material balance, or
engineering principles and submitted as the supporting basis, a step-by-
step description of the calculations, including assumptions used and their
bases, and a brief rationale for the validity of the calculation method used;
and
(6) Evidence that the emissions from individual sources are not artificially or
substantially greater than emissions in other years prior to implementation of
emission reduction measures.
General Control Plan:
(1) The general plan, for achieving the required hazardous air pollutant emissions
reductions at the source including descriptions of emission control equipment
to be employed, process changes or modifications to be made, and any other
emission reduction measures to be used; and
Statement of Commitment:
(1) A statement of commitment, signed by a responsible official of the source,
containing the following:
0) A statement providing the post-reduction emission level for total HAP
emissions and total HAP emissions adjusted for high-risk pollutants, as
applicable, from the source on an annual basis which reflects a 90-percent
(95-percent for paniculate pollutants) reduction from base year emissions;
(ii) A statement certifying that the base year emission data submitted as part
of the enforceable commitment constitute the best available data for base
year emissions from the source and are correct to the best of the
responsible official's knowledge;
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TABLE 2-5. COMPONENTS OF AN ENFORCEABLE COMMITMENT
(concluded)
(iii) A statement that it is understood by the source owner or operator that
submission of base year emissions constitutes a response to an EPA
request under the authority of Section 114 of the CAA and that the
commitment is subject to enforcement according to ง63,,80;
(iv) A statement committing the source owner or operator to achieving the
required emission levels before January 1,1994; and
(v) A statement that the base year emissions are within allowable emission
levels specified in any applicable law, regulation, or permit condition.
2-32
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90 (95) percent. In order to make an enforceable commitment, a company would
need to have determined with at least some degree of accuracy that the planned
emission reduction is achievable.
The commitment must be signed by the owner, operator or responsible party at
the source. The wording of the statement should follow closely the statement
presented in the regulation under Section 63.75 which reads:
"I certify to the best of my knowledge that the base year emissions given above
are correct and constitute the best available data for base year emissions from
the source, and acknowledge that these estimates are being submitted in
response to an EPA request under Section 114 of the Clean Air Act. I further
certify that the base year emissions provided for all emission points in the
source do not exceed allowable emission levels specified in any applicable law,
regulation, or permit condition. I commit to achieve before January 1,1994 the
stated post-reduction emission level(s) at the source, which will provide the 90
(95) percent reduction required to qualify for the compliance extension, and
acknowledge that this commitment is enforceable as specified in Title 40 Part 63
Subpart D of the Code of Ferteral Regulations"
The owner or operator of a source may rescind its commitment at any time
prior to December 1,1993, without penalty. Any source that rescinds its commitment
must comply with the applicable standard issued under Section 112 (d) of the CAA by
the compliance date specified in such a standard.
Sources found submitting false information in their commitment for early
reductions shall be subject to enforcement action under Section 113 of the CAA or
other Federal statutes. This is an important consideration for a company to weigh
when preparing the commitment. All data and information submitted should be
carefully reviewed to verify its accuracy and veracity. The EPA may exercise its
authority to ensure the integrity of information contained in the commitments by
conducting audits'of any or all submittals. The purpose of this activity is to encourage
sources to make only serious commitments that can be supported with acceptable
emission data.
Enforceable commitments for several different sources within a contiguous
facility may be aggregated into one submitted, provided that base year emissions and
post-reduction emission levels committed to are identified separately for each source.
2-33 , .
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A single enforceable commitment submittal may not involve sources; from more than
one contiguous facility.
Appendix A of this document provides guidance for submitting enforceable
commitments. The appendix details the types of information needed for a complete
submittal. Appendix A also includes an example enforceable commiitment that can be
referred to by companies preparing submittal packages.
SECTION 63.76 - REVIEW OF BASE YEAR EMISSIONS
The rule specifies review of base year emissions data for all enforceable
commitments. Review of base year emissions prior to submittal of a permit application
is also specified if a source requests such a review. The overall schedule for review of
base year emissions submitted as part of an enforceable commitment or as a request
for base year review is presented in Figure 2-7. In addition, the schedule for review of
base year emissions relative to the submittal date is presented in Figure 2-8. This
schedule varies depending on the completeness and approvability of the submittal.
The top line of the figure represents the case in which the initial submittal was
complete and approvable without any changes. The bottom line represents the
situation in which the submittal was not complete, the revised submittal was not
approvable, public comments were received during an extended public comment
period and the applicant resubmitted the emissions within 90 days. It does not
represent worst case because each event only required one revision. For review
requests sent to the State, a copy of the request shall also be submitted to the
Region. Prior to approval of the State permit program, review requests should be sent
to the appropriate Regional Office and copies should be sent to the applicable State
agency, and the early reductions officers in SSCD and ESD. (See addresses in
Section 63.75)
Within 30 days of receipt of an enforceable commitment or a request for review
of base year emissions, the EPA Regional Office will notify the applicant whether the
submittal is complete or incomplete. At this point in the review process, the
determination is whether all information required in the enforceable commitment has
2-34 .
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been supplied, not necessarily whether the information is adequate for the purposes of
the Early Reductions Program. However, the EPA will identify any obvious technical
deficiencies in the submittal at this time in order to facilitate the review process and
allow the source to make necessary changes prior to technical review.
The EPA Headquarters will publish a monthly list of all complete submittals
nationally. If the EPA determines that the enforceable commitment is incomplete, the
deficiencies in the submittal will be provided to the owner or operator of the source,
who must correct the deficiencies and resubmit the base year emissions data before
further review can proceed.
Within 60 days of a completeness determination, the EPA will judge the
adequacy of the enforceable commitment or emissions data submission and give
notice of that determination. If the EPA determines that the base year emissions are
approvable, a notice providing the aggregate base year emissions will be published by
advertisement in the area affected. The advertisement will explain that the emissions
submitted for base year review or as part of an enforceable commitment are being
proposed for approval and note the availability of additional nonconfidential information
contained in the enforceable commitment for public inspection in at least one location
in the community in which the source is located. A 30-day public comment period will
be provided, with an opportunity to extend it to 60 days and/or hold a public hearing
upon request by an interested party.
In some instances, companies participating in the Program may declare certain
information in their submittals to be confidential and, therefore, not available for review
by the public. The amount of confidential information in a submittal should be
relatively small and should not significantly affect the public's ability to review and
evaluate submittals. To help ensure this, the EPA recently published a FEDERAL
REGISTER notice (56 FR 7042; February 24, 1991) specifying categories of data that
qualify as "emissions data" and thus can not be regarded as confidential has been
published under the CAA. Such data include but is not limited to: identification of the
facility and emission points, emission types (type of release point and specific
pollutants), emission rates/release heights, descriptions of terrain and surrounding
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structures, stack or vent diameters at point of emission, release velocities, release
temperatures, frequencies of releases, durations of releases, concentrations, densities
of emission streams or average molecular weights, boiler or process design
capacities, emission estimation methods, percent space heat, and hourly maximum
design rates. When parts of a submittal are claimed confidential by the source, efforts
should be made by the submitting company to create a complete and coherent
nonconfidential submittal to accompany the confidential version. Additional guidance
regarding confidential information is given in Appendix A.
If the EPA determines that the base year emissions are not approvable because
the supporting data or calculations are incorrect or deficient in some manner, the
applicant will'be notified of the decision and the reasons for the decision. The
applicant must make the necessary corrections and resubmit the base year emissions
data to remain in the Program. There is no time limit for resubmittal of the base year
emissions data that were submitted for early review; however, it is assumed that
applicant would resubmit as quickly as possible to allow adequate time after approval
to implement the emission reduction plans. Revisions to base year data included in an
enforceable commitment, however, must be resubmitted within 90 days, or the
company must notify the EPA that revised data will eventually be submitted.
Otherwise, the enforceable commitment could be considered withdrawn. The
permitting agency would send a notice to this effect to the applicant. The source must
then comply on the same schedule as other sources subject to any applicable
Section 112(d) standard. If the applicant chooses to resubmit corrected emissions
data, the EPA will review the revised estimate within 30 days and, if approvable, will
notify tine company and publish a notice to that effect.
If, during the public comment period, no adverse public comments are received
by the reviewing agency on the proposed base year emissions for a source, the data
submission shall be considered approved at the close of the public comment period.
The reviewing agency will send notice of approval to the applicant and publish a
similar notice by advertisement in the area affected.
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In the event that adverse comments are received, the reviewing agency has the
authority to determine which, if any, public comments need to be addressed for the
base year emissions to be approved. If the reviewing agency agrees that corrections
are needed, it will notify the applicant of the disapproval and the reasons for the
disapproval. An applicant may then correct disapproved base year emissions data
and submit the revised base year emissions data or revised enforceable commitment.
The same time limitations for resubmittal of base year emissions data apply as
described in the above paragraph.
If the reviewing agency is satisfied that the revised submission accounts for the
adverse comments, it will send notice of approval to the applicant and publish the
approval by advertisement in the area affected. The revised submission will not
undergo another public comment period. If the applicant does not address all the
comments, the agency shall return the submission with a list of reasons for
disapproval. The same time limitations for resubmittal apply as described in the above
paragraph. "
The reviewing agency may determine that the adverse comments do not
warrant changes to the submrttat. If this is the case, the reviewing agency will send
notice of approval to the applicant and publish the approval and the reasons for not
accepting the adverse comments by advertisement in the area affected.
Once base year emissions have been approved, the EPA will honor the data
and will not change criteria for approval arbitrarily. However, review of base year
emissions does not provide an absolute shield against changes. Discovery of
incorrect or fraudulent information in the emissions data or supporting materials even
after its initial approval could potentially invalidate the base year data and require
revision to it. In the case of fraudulent information, the EPA may bring an enforcement
action against the source owner or operator under Section 113 of the CAA. Such
discrepancies could be discovered at any stage of the process, including during
review of the permit application. Base year data should be carefully reviewed and
approved by knowledgeable company officials before submittal.
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SECTION 63.77 - APPLICATION PROCEDURES
The request for a compliance extension and alternative emission limitation will
be in the form of a permit application. The application should contain the information
necessary to demonstrate achievement of the early emission reductions by the
appropriate deadline, as well as any additional information required for a complete
permit application (as specified in regulations under Part 70 or 71,1 which implement
permit programs required under Title V of the CAA as amended). In most instances,
the application must be received by the appropriate permitting authority before
proposal of an applicable Section 112(d) standard. However, there are two
exceptions. The first exception is for sources that previously made an enforceable
commitment, where the permit application must be received no later1 than
December 1,1993 (which may be after proposal of an applicable standard). The
second exception is for sources which have achieved qualifying reductions prior to
proposal of an applicable Section 112(d) standard but which are unable to submit a
permit application before proposal because a Federal permit program has not been
established (i.e., Part 71 Federal permitting regulations have not been promulgated)
and the State does not have a permit program approved pursuant to Title V of the
CAA. These permitting programs will be necessary to define the information needed
for a complete permit application. This situation may arise within the next year or so,
before Part 71 Federal permitting regulations are promulgated and any State permitting
programs are approved. Therefore, to take this situation into account, the rule
specifies that the deadline for submitting permit applications under the Early
Reductions Program is the later of the following dates:
(1) the date of proposal of an applicable Section 112(d) standard; or
1 NOTE: Federal Part 71 permitting regulations have not been proposed or
promulgated, the final Early Reductions rule, therefore, cannot: refer to unissued
regulations: When Part 71 regulations are issued for Early Reductions sources, the Early
Reductions rule may be amended.
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(2) 120 days after promulgation of Part 71 regulations or 120 days
after approval of a State permit program under Title V of the CAA,
whichever occurs first. - ;
It is recommended that owners or operators in this situation notify the
appropriate EPA Regional Office of their intent to submit a permit application
containing an early reductions demonstration. The EPA Regional Office, in turn, will
notify the potential applicant when the Part 71 regulations have been promulgated or
the appropriate State has received approval for a Title V permit program, whichever
occurs earlier. This will give the applicant timely notice of an approaching permit
application submittal deadline.
The permit application for sources with an enforceable commitment should
demonstrate that a qualifying early reduction has been achieved or, where applicable,
will be achieved by January 1, 1994 (as required in Section 63.74 of the proposal rule).
Test data to support the post-reduction emissions data may be submitted up to 120
days after the deadline for submittal of the permit application. This submittal allows
the source flexibility to provide required post-reduction emission data from tests
conducted after final controls or reduction strategies are in place. The permit
application should specify appropriate emission limitations for the source and the test
method or equivalent means used to determine the emission limitation, as well as
appropriate monitoring, reporting, and recordkeeping requirements. Under the
Part 70 permitting regulations published July 21, 1992 (57 FR 32250), current EPA
plans would require that the permit be issued within nine months after receipt of the
complete permit application. Until that time, the enforceable commitment would
remain the enforceable instrument for the source. Section 112(i)(5)(B) of the CAA
provides that the commitment "shall be enforceable to the same extent as a regulation
under this section."
If the relevant State or local agency has an approved Title V permit program, it
will be responsible for processing the application according to provisions in 40 CFR
Part 70. For sources in States without approved Title V permit programs, applications
should be submitted to the EPA pursuant to 40 CFR Part 71. A fee will be required by
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States to offset the costs of reviewing Title V permit applications. (If the EPA is the
permitting authority, a fee as specified in 40 CFR 71 would be required.)
The overall schedule for review of permit applications submitted as part of the
Early Reductions Program is presented in Figure 2-9. In order to meet schedules in
the CAA, the last Section 112(d) proposal date would be proposed about November
1999. If permit applications must be submitted prior to proposal, and review of the
application must be accomplished within 9 months of receipt of a complete application,
all early reduction permits will be reviewed by the end of the year 2000. According to
this schedule, this is the last year an extension would be granted.
SECTION 63.78 - EARLY REDUCTION DEMONSTRATION EVALUATION
The permitting authority evaluates all available information in determining
whether to approve or deny a permit application. This includes information supplied
by the source owner or operator in the early reduction demonstration and information
received from public comments on the application. Specific to the demonstration of
early reductions, the permitting authority would decide whether the information and
data required have been provided and whether data were valid considering the
following:
1. Did the facility provide the necessary plant identifying information to
adequately describe the source and the emission points within the
source?
2. Does the source meet one of the definitions described in Section 63.73?
3. Were emission tests conducted in accordance with the procedures
and requirements of the early reductions rule?
4. Were justifications acceptable for using something other than testing to
establish post-reduction emission data?
5. Are engineering calculations correct and the assumptions underlying the
calculations valid?
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6. Have emission factors been appropriately applied and can their use be
reasonably expected to represent the emissions from the source
accurately?
7. Are material balance data adequately documented by records and
sufficiently accurate to give credible emission estimates?
8. Have .all HAP emissions from each source for which a compliance
extension is requested been documented and included in the
calculations?
9. Are base year emissions within allowable limits?
10. Were high-risk weighting factors appropriately applied to all
high-risk HAP's?
After evaluating a permit application containing an early reduction
demonstration, the permitting authority will make a determination to either approve or
deny it. Specific reasons for denial include but are not limited to:
1. The information provided by the owner or operator is incomplete.
2. The source is not correctly identified.
3. The required 90 (95) percent reduction has not been demonstrated or it
has not continued to be achieved after demonstration.
4. The base year or post-reduction emission data are incorrect or not
sufficiently reliable or well-documented to determine with reasonable
certainty that required reductions have been achieved. (Sources which
submit base year emission data for review early, including sources which
submit an enforceable commitment, should not be subject to a second
base year review at the permit application stage. Note?, however, that
base year emission data could change at this stage if they are found to
be based on incorrect or fraudulent information.
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5. The emission of HAP's or the performance of emission control measures
are sufficiently unreliable as to preclude determination that the required
reductions have been or will continue to be achieved.
If the permit is denied, the permitting authority will notify the applicant of the
denial and state the reasons for that denial.
SECTION 63.79 - APPROVAL OF APPLICATIONS
If the application is approved, the reviewing agency will establish an enforceable
emission limitation for the source by issuing a permit under Title V of the CAA. The
enforceable emission limitation will reflect'the level of control which qualified the source
for the compliance extension. The permit will also include operating conditions and
compliance monitoring, reporting, and recordkeeping requirements necessary to
ensure continuing compliance.
Although the 90 (95) percent reduction is expressed as an annual emission
limitation, the permit itself may contain specific conditions for specific types of emission
points. For example, a storage tank may require certain types of equipment, a
process may be limited to a certain number of operating hours per year, or an
equipment leak program may specify work practices. Other points or control devices
may require frequent or continuous monitoring. Alternatively, an owner or operator
may be able to receive the overall limitation as the permit condition, if they are able to
demonstrate to the permitting authority's satisfaction on a periodic basis that the
alternative emission limitation is being achieved, and that control equipment is properly
operated and maintained.
The alternative emission limitation would be effective and enforceable
immediately upon issuance of the permit for the source and would remain in effect
until six years after the compliance date for the applicable Section 112(d) standard. At
that time, the source would be required to comply with the standard. Since permits
will be issued for periods not to exceed five years, there will be at least two permits in
effect over the six-year compliance extension. The second and subsequent permit,
2-45
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which will be issued when the first one expires, will contain the alternative emission
limitation for the remainder of the six-year extension, and as appropriate, the limitations
to comply with the Section 112(d) standard.
A source in a nonattainment area (an area where a national ambient air quality
standard is exceeded) may need to obtain offsets for new construction or modification
activities. Emission reductions of HAP's required for the purpose of obtaining an
alternative emission limitation under Section 112(i)(5) of the CAA are not creditable for
the purpose of meeting an offset requirement under Section 173(a)(1). The HAP
reductions are not allowed as offsets in this instance because
Section 173(c)(2) of the CAA states: "Emission reductions otherwise) required by this
Act shall not be creditable as emission reductions for purposes of ainy such offset
requirement11 A source successfully participating in the Early Reductions Program will
be granted an alternative emission limitation (for the duration of the compliance
extension period) in lieu of a Section 112(d) emission standard. Therefore, the
reduction of HAP emissions under the Early Reductions Program is a substitute for the
reduction of HAP emissions as "required" under a Section 112(d) standard.
However, a source owner or operator may use as offsets any reductions in
HAP emissions in excess of those required to qualify for an extension under the Early
Reductions Program or reductions in non-HAP emissions which are coincidentally
obtained through use of the HAP emission reduction measures, if such reductions are
not required by any other provision of the CAA and meet the other requirements for
offsets under New Source Review (NSR) rules. These reductions are allowed as
offsets pursuant to Section 173(c)(2) of the CAA which further states: "Incidental
emission reductions which are not otherwise required by this Act shall be creditable as
emission reductions for such purposes..." As a simple example, consider a source
emitting ethylene (a non-HAP) and ethylene oxide (a HAP) that is controlled for
purposes of qualifying for a compliance extension under the Early Reductions
Program. Assume that the control measures used reduced ethylene oxide emissions
by 92 percent or 46 tons per year and also reduced ethylene emissions by 20 tons
per year, although there is not a requirement to reduce the ethylene emissions.
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Further, assume that the permit issued to the source requires a continuing 92-percent
reduction. In this instance, the 20 ton-per-year reduction- in ethylene emissions may
be used, if needed, to offset an increase in volatile organic compound emissions from
new construction or a modification of an existing source. Additionally, since the
source achieved a 2-percent HAP reduction beyond that required to obtain an
extension, the extra 2-percent reduction, or 1 ton per year in this example, may also
be used as an offset.
Emission reductions of HAP's achieved under the Early Reductions Program
may be used for netting purposes under the NSR rules with some limitations. In
general, an owner or operator considering a physical or operational change at a major
stationary source (as defined in the NSR rules) will be subject to (1) the requirements
of Section 173(a) [e.g., offsets, application.of LAER] in nonattainment areas or ozone
transport regions or (2) the requirements for Prevention of Significant Deterioration
(PSD) [e.g., application of BACT] in attainment or unciassifiable areas, unless the
changes will not cause a "significant net emissions increase" in pollutants subject to
NSR. To determine the net emissions increase for NSR purposes, the owner or
operator is allowed to sum the emissions increase from the proposed change with any
creditable increases and decreases elsewhere at the plant.
The NSR rules and the EPA's "Emissions Trading Policy Statement (ETPS)"
(51 FR 43823, December 4, 1986) limit the credibility of some decreases in
emissions for this "netting" procedure. For example, the NSR rules for nonattainment
areas state that a decrease in emissions is creditable only to the extent that "...the
reviewing authority has not relied on it in issuing any permit under regulations
approved pursuant to 40 CFR Part 51 Subpart I or the State has not relied on it in
demonstrating attainment or reasonable further progress;..." [40 CFR
51.165(a)(1)(vi)(E)]. The PSD rules contain similar language. Essentially what this
restriction does is prevent sources from obtaining two credits for one reduction, where
the credits are related to the same air quality objective (which in this case is the
attainment/maintenance of national ambient air quality standards). Thus, as an
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example, a source cannot use an emissions reduction to meet reasonable further
progress requirements and as a reduction credit in netting calculations.
However, under the ETPS, HAP decreases credited under the Early Reductions
Program also may be credited for purposes of determining the net emissions increase
for a plant change proposed at a later time, provided of course that the reduced
HAP's also are pollutants subject to the NSR rules and that the decreases meet all
other requirements for netting. In such situations, the HAP decreases produce
benefits for two different air quality objectives and one credit can be given toward
each; the HAP credit is associated with the air toxics reduction objectives of
Section 112 of the CAA and the NSR credit is associated with the
attainment/maintenance of national ambient air quality standards and PSD. The
amount of the HAP reduction creditable in these situations will be limited if the netting
calculations involve HAP emissions increases. Specifically, the creditable HAP
reductions from the Early Reductions Program will be reduced by the amount of any
increase in HAP emissions involved in the netting calculations. If no HAP increases
are involved, the entire HAP reduction is creditable.
The principle behind this policy limitation is similar to that behind the netting
restriction in the NSR rule mentioned above, namely that a reduction should not
receive two benefits or credits (double counting) for the same air pollution control
objective. The objective of the Early Reductions Program under Section 112 of the
CAA is to achieve significant reductions of HAP's at existing facilities. Sources that
achieve such HAP reductions in accordance with the rules promulgated today receive
credit for the reductions in the form of a six-year compliance extension for applicable
Section 112(d) standards. If the reductions also were allowed to be used as netting
reduction credits for physical or operational changes involving increases in HAP's,
then the reductions in effect would be promoting HAP increases elsewhere at the plant
sfte by helping such facilities net out of NSR control requirements. Under such a
Scenario, an owner or operator could receive a six-year compliance extension to
Section 112(d) standards for some portion of the plant, net out of NSR control
2-48
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requirements, and have overall HAP emissions equal to preexisting levels. Clearly this
is not a result consistent with the objectives of the, CAA.
To illustrate the effect of this policy, consider a plant site in which a portion of
the facility (e.g., a process unit) participates in the Early Reductions Program and
achieves a 50 tons per year reduction of HAP's, which also are particulate matter.
Later, the owner or operator proposes a physical or operational change at another
section of the plant which would increase particulate emissions by 75 tons per year,
and none of the emissions increase would be HAP's. In this case, the owner or
operator can use all of the HAP reductions from the Early Reductions Program to net
against the particulate emissions Increase because no HAP increases are involved.
However, if 30 tons per year of the proposed 75 ton increase are HAP's, then only 20
tons per year of the HAP reductions under the Early Reductions Program could be
used as reduction credits in any netting calculations (20 tons per year is the amount
by which the HAP reduction exceeds the proposed HAP increase). Finally, if 50 or
more tons per year of the proposed 75 ton increase would be HAP emissions, then
none of the HAP reductions from the Early Reductions Program could be used to net
against the particulate emissions increase (because the HAP increase from the
proposed modification is equal to or greater than the HAP reductions from the Early
Reductions Program).
It should be noted that this netting policy for HAP reductions is applicable only
for NSR programs. Under Section 112(g) of the CAA, the EPA must promulgate
separate requirements for modification of HAP sources. The provisions to implement
Section 112(g) are under development but will not become effective in a State until the
State has obtained approval of a Title V permitting program.
SECTION 63.80 - ENFORCEMENT
All base year and post-reduction emissions information submitted as part of a
permit application or an enforceable commitment are considered to have been
requested by the Administrator under the authority of Section 114 of the CAA.
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Therefore, any fraudulent statements contained in the such submittals will be
considered violations of Section 114 and are actionable under Section 113 of the CAA.
In appropriate situations, fraudulent statements in these submittals will be considered
violations of 18 U.S.C. 1001, the general false swearing provision of the United States
Code.
if an early reductions demonstration in a permit application is; disapproved,
whether or not the source is subject to an enforceable commitment, the owner or
operator must comply with any applicable Section 112(d) standards. Failure to comply
with the applicable Section 112(d) standards is actionable under Section 113 of the
CAA. Similarly, failure to comply with an alternative emission limitation is actionable
under Section 113 of the CAA.
SECTION 63.81 - RULE FOR SPECIAL SITUATIONS
*
When a source is subject to multiple Section 112(d) standards, the proposal
date of the first applicable standard is the proposal date which governs the deadline
for the Early Reductions Program. In other words, a permit application or enforceable
commitment must be submitted prior to proposal of the earliest Section 112(d)
standard that applies to any emission point in the source definition. The extension for
compliance, however, begins on the compliance date of the Section 112(d) standard
applicable to the emission point. This will lead to different compliance extension
expiration dates for different emission points in a source subject to more than one
Section 112(d) standard.
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3.0 PROGRAM IMPLEMENTATION
The EPA is committed to making the Early Reductions Program a success and
will play an active role in implementation of the early reductions regulations. The EPA
recognizes the burden this Program could put on the EPA Regional Offices and State
agencies. In an effort to assist the Regional Offices and the states, the EPA has
developed a management system for review of enforceable commitments and is also
committing a pool of its staff to implementation of the Program. Depending on the
needs of the Program, the EPA may develop similar management systems for the
review of permit applications under the Early Reductions Program.
The objective of this chapter is to prepare the Regional EPA and State reviewers
for implementation of the Program. With this in mind, the intent of this chapter is to
define the roles of the EPA Headquarters staff, the Regional Offices, and the States in
implementing the program. In addition, the appendices provide checklists, tracking
forms, and examples of the types of materials reviewing agencies will need to
generate.
ENFORCEABLE COMMITMENTS
Initial activity on the Early Reductions Program will be the submrttal of
enforceable commitments. In fact, enforceable commitments and base year reviews
are the only submrttals the EPA Regions and States will be able to process at the
outset. Neither the EPA Regions nor the States will be able to process a permit
application until late 1.993.
The reviewing agency (the EPA Regions or later the State) is encouraged to
hold preapplication meetings with potential early reductions source representatives, if
there is an opportunity to do so. In many cases, the first knowledge that a company
wishes to participate in the Program will be when an application is received. However,
in situations where the applicant gives advance notice that an application is being
prepared, the Regional Office should take advantage of the opportunity to hold a
3-1
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preapplication meeting. This can be particularly useful in cases such as chemical
manufacturing complexes where there are many emission points and the potential
exists for numerous source definitions.
As mentioned above, the EPA has developed a management system for review
of enforceable commitments. This draft management system is intended to ensure
that necessary support is provided to Regional Office reviewers during the early
implementation phase of the Early Reductions Program (i.e. post-proposal) and that
consistent review and decision-making occurs. The EPA Headquarters will be learning
about-the scope and complexity of the implementation task, and can minimize
problems through regular communication and consultation. This is a highly visible
rulemaking, and several constituent groups will follow its progress with a keen interest.
The EPA will likely be asked for progress reports and information on how the Program
is working. Thus, the internal tracking of important milestones using a computerized
reporting system is being emphasized. The Headquarters team will prepare periodic
summary reports as necessary.
The Early Reductions Program Tracking System (ERPTRAX) is a computer
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based system for internal EPA use that provides up-to-date tracking information on
Early Reductions activity in each Region. It allows significant milestones in the review
process to be scheduled and tracked, such as receipt by the Regional Office, and the
status of completeness and technical reviews and resubmittals. These tracking needs
are mirrored in the early reductions regulations, and the extension is a natural one.
Moreover, the system is user friendly, enabling direct input and access by the
Regional Office and Headquarters staff.
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STEPS IN THE SYSTEM
A schematic of this system is presented in Figure 3-1 and the individual steps
are described below.
1. The applicant prepares four copies of the enforceable commitment submittal,
sending one to the Regional Office, one to the State, one to SSCD, and one to
OAQPS.
2. The Regional Office logs in and advises the applicant of receipt; the date of
receipt is entered into ERPTRAX. -
3. Within 3 weeks of receipt of application, the Regional Office initiates a
conference call with the Headquarters team (and as appropriate, the State) to
discuss preliminary assessment, identify issues (including schedule) and get
Headquarters commitment for their opinion on completeness.
4. Within 30 days after receipt of the application, the Regional Office, after
consultation with Headquarters, makes a completeness determination. (In the
early phase of the Early Reductions Program, the Headquarters team will have
responsibility for final decisions if there is a dispute.)
5. The OAQPS/DC will prepare and submit for publication a FR notice listing all
"complete" enforceable commitment applications received in the previous
month.
6. If the application is incomplete, the Regional Office advises the applicant that
additional information is needed. This may involve asking for submittal of
additional material, or returning the application for substantive revision. The
applicant may comply or decide to rescind the application. If a response is not
received within 90 days, the application may be considered withdrawn.
7. If the application is deemed complete, the Regional Office enters the
completeness date in the computer tracking system and initiates the 60-day
application technical review.
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Rgure3-1. Management System for
Review of Enforceable Commitments
3-4
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8. If the application cannot be reviewed for approvability in 60 days, the Regional
Office should discuss the problem with the Headquarters team. Review periods
longer than 60 days should be exceptions, not the rule, and should directly
stem from the complexity and scope of a submittal. If it is determined that a
longer review time is needed, a new schedule should be established and the
applicant so advised. (NOTE: If there has been a pre-application conference,
the possibility of extended review should be discussed at that time.) The
Regional Office will enter any revised schedules into the computer tracking
system.
9. Throughout the application review process, the Regional Office, Headquarters
team (and State, as appropriate) should consult via conference call to discuss
issues. Within the review period, the Headquarters team (and State) will provide
their assessment of the approvability of the application to the Regional Office.
10. Within 60 days (or otherwise agreed upon schedule), the Regional Office will
decide on approvability of the application after consultation with the
Headquarters team (and the State).
11. If there is a dispute regarding the approvability of the application, it will be the
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Headquarters team's responsibility to promptly elevate the issue to get a
decision. No action is to be taken until a decision is made.
12. If the application is not approvable, the Regional Office will advise the applicant
of the deficiencies and the necessary corrective action. (NOTE: The applicant
should be advised of significant deficiencies as soon as they are identified.)
13. The applicant may correct deficiencies and submit a revised enforceable
commitment to the Regional Office, or rescind the application. Responsibility
lies with the applicant for resubmitting the revised commitment in a timely
manner. If a response is not received within 90 days, the application may be
considered withdrawn.
14. The Regional Office reviews new information for approvability, consulting with
the Headquarters team and the State as necessary. If the revised submittal is
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not approvable, steps 13 and 14 are repeated with the applicant. If the
submittal is approvable, the review process proceeds to step 16.
15. If approvable, the Regional Office will publish a local notice of intent to approve
and request public comment (30-day comment period). The Region enters the
notice date into the computer tracking system.
16. The thirty-day comment period can be extended to 60 days upon request of an
interested party. Local notifications of extension are published by the Regional
Office, and the Regional Office also informs the applicant about the extension.
17. If so requested by an interested party, a public hearing on the application may
be conducted in the local area.
18. The Regional Office provides comments to the applicant, Headquarters team
and State.
19. If adverse comments are received, the Regional Office consults with the
Headquarters team (and State) concerning disposition.
20. If comments are not accepted, the Regional Office prepares an approval notice
explaining reasons for not accepting comments.
21. If comments are accepted, the Regional Office assesses necessary corrective
action and advises the applicant.
22. The applicant may correct any deficiencies and submit them to the Regional
Office, or rescind the application. If a response is not received within 90 days,
the application may be considered withdrawn.
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23. If revisions are acceptable, the Regional Office prepares an approval notice
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explaining adverse comments and corrective action taken. I'F revisions are not
acceptable, steps 21 and 22 are repeated.
24. The Regional Office publishes a local notice of approval, and enters the date
into the computer tracking system.
25. Headquarters includes approval information in the monthly FR notice on
complete applications received.
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REVIEWER CHECKLISTS FOR ENFORCEABLE COMMITMENTS
Three standard forms are provided in Appendix C to assist reviewers in
processing Early Reductions submittals. The forms are designed to be used for either
an enforceable commitment or for base year review. Proper use of the forms will
require a basic understanding of the Early Reductions Program. For example, a
reviewer should be familiar with the flexible source definition. An explanation of how to
use each form is given below.
Form A - Source Data Sheet
The source data sheet is used to track a source through the entire review
process. A source data sheet should be completed for each specific source. If a
company submits an enforceable commitment for three sources in one facility, three
source data sheets should be completed.
The source data sheet includes space for general source identification
information such as company, location, plant contact, source, and base year. Space
is also provided to identify contacts within the EPA Regional Offices and appropriate
local agencies. A "submittal diary" is included on the sheet enabling the reviewer to
track key dates in the review process such as the dates of approval for completeness
and technical review.
Finally, the source data sheet includes space for making notations on the status
of the submittal. For example, rf the submittal was considered incomplete during the
first completeness review, the date the submittal was returned to the applicant for
revision can be noted.
Form B - Completeness Review
Form B is to be used for completeness reviews for both enforceable
commitments and base year reviews. Page 1 of this form is a summary sheet that
includes general identification information and space to summarize deficiencies in the
review. Space is also provided to note any obvious technical deficiencies noted during
completeness review. Although the purpose of the completeness review is only .to
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assure that all necessary information is included in the submittal, any technical
deficiencies noted during the review should be identified. This will enable the applicant
to make any appropriate changes in their submittal prior to technical review, therefore
facilitating the review process.
Pages 2 and 3 are a checklist of items that must be present in the submittal.
For an enforceable commitment, Sections A through C must be completed. Only
Sections B and C must be completed for base year reviews. Every item should be
checked "Yes" or "N/A" for a submittal to be complete.
Page 4 of Form B provides a format for conducting completeness checks for
each emission point in the source. Space is provided for 15 emission points. If a
source includes more than 15 emission points, this page can be copied as necessary.
Each emission point can be listed on the form using an emission point
Identification number or description provided by the source. The reviewer can
systematically check for completeness using either the blocks under "testing" or
"calculations," depending upon the method used to estimate base year emissions.
Symbols such as checkmarks or dashes can be used to complete all applicable boxes
on the form, or letters such as "Y," "N," and "N/A" corresponding to "Yes," "No," and
"Not Applicable." For example, if an EPA approved test method is used for the
emission estimate, a checkmark would be placed in the box for "EPA Methods" and
dashes would be placed in all other boxes indicating "Not Applicable." Similarly, if a
material balance was used and complete information was provided describing the
material balance procedures, "N/A" would be placed in all boxes corresponding to
testing and AP-42, and "Y" would be placed in the boxes for "Rationale for not
Testing," "Material Balance," "Discussion of Method," and "Detailed Calculations."
Because of the complexity of some submittals and the numerous alternatives for
presenting emissions data, many completeness determinations will be more subjective
than others. The table provided in Form B lends to an objective review for
completeness. In some cases, yes or no answers may not be adequate. Some
space has been provided on the form for making notes and additional pages may be
needed by the reviewer. The final column on the form is for making the completeness
3-8
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determination by judging the emission estimates for each emission point as either
complete or deficient. When an emission point is marked deficient, some explanation
of the deficiency will be needed to assist applicants in making necessary changes to
their submittal.
Form C - Technical Review
Form C includes 2 pages. Page 1 is a table for tracking the technical review of
each emission point. Page 2 includes a list of statements designed to initiate the
thought process needed to determine if the emissions data are valid and accurate. It
is not necessary for the reviewer to complete page 2 for each specific emission point.
Rather, the reviewer can use these statements to ensure thorough review of the
emissions data.
A detailed review of the estimation methodology and calculations will need to be
performed on many, if not all, emission points. It will be left to the discretion of the
reviewer to pick individual emission points for detailed reviews. Obviously, all of the
larger emission points should be checked thoroughly while other emission points can
be checked randomly. It may be possible to check every emission point in smaller
sources while selecting only major emission points in sources containing a large
number of emission points.
BASE YEAR SUBMITTALS
The other activity that Regional Offices and States will immediately become
involved with is review of base year submtttals. One provision of the early reductions
rule is that a facility owner or operator considering participation in the Program can
request a review of base year emissions. This allows the source owner or operator to
establish the base year emission level for the source prior to submitting a permit
application.
The review of base year submittals is nearly identical to the review of
enforceable commitment submittals. The only difference is that base year submittals
will not include a commitment to reduce HAP emissions or a general control plan.
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. "Ill
Base year submittals will also be entered into the EPA's early reductions
tracking system. The steps for review of base year submittals will be identical to those
presented in Rgure 3-1 for the review of enforceable commitments.
PERMIT APPLICATIONS
As indicated earlier, the EPA may develop a management system for permit
applications containing early reductions sources similar to the system presented in this
chapter for enforceable commitments and base year submittals. Such a system will
not be introduced until after the permitting program is in place.
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4.0 INTERFACE WITH THE 33/50 PROGRAM
The 33/50 Program is part of the EPA's overall pollution prevention strategy
and the first of its new pollution prevention initiatives. Like the Early Reductions
Program, participation in this program is fully voluntary. Many of the companies that
are currently participating in the 33/50 Program may also participate in the Early
Reductions Program. The two programs are complementary, and the intent of this
chapter is to minimize confusion over the differing requirements and encourage
participation in both programs.
DESCRIPTION OF THE 33/50 PROGRAM
The 33/50 Program was announced in February 1991 and is one of the major
components of the EPA's pollution prevention strategy. This program is designed to
encourage voluntary reduction of toxic releases and off-site transfers of 17 chemicals.
The 17 targeted chemicals are:
Benzene
Cadmium and Cadmium Compounds
Carbon Tetrachloride
Chloroform (Trichloromethane) .^
Chromium and Chromium Compounds
Cyanide Compounds and Hydrogen Cyanide
Lead and Lead Compounds
Mercury and Mercury Compounds
Methylene Chloride (Dichloromethane)
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Nickel and Nickel Compounds
Tetrachloroethylene (perchloroethylene)
Toluene
1,1,1 -Trichloroethane (methyl chloroform)
Trichloroethylene
Xylene (all isomers)
This list of chemicals is drawn from the Toxics Release Inventory (TRI) and
based on recommendations from the EPA program offices. The following factors were
considered in developing the list: high production; high releases and off-site transfers
4-1
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relative to total production as indicated by TRI reports; potential for pollution
prevention activities; and potential for a wide range of health and environmental
effects.
. The 33/50 Program establishes a national goal to reduce releases and off-site
transfers of these 17 chemicals by one-third by the end of 1992 and one-half by the
end of 1995 with emphasis on the use of pollution prevention techniques. The
baseline for these reduction goals is the 1988 TRI. Based on the TRI, aggregate
releases and off-site transfers of the targeted chemicals were 1.4 billion pounds in
1988.
Thus far, the Administrator has asked thousands of U. S. companies to
participate in this program. Each company has been asked to examine its processes
to identify and implement cost-effective pollution prevention practices related to the
33/50 Program chemicals. Companies have also been asked to develop written
commitments to publicly state their reduction goals and how they plan to achieve
them. The following are general guidelines and milestones for what the EPA has
asked companies to do.
May 15,1991 - receipt of company-wide numerical commitments.
July 30, 1991 - receipt of facility specific and chemical specific numerical
commitments including discussion of pollution prevention activities, as
appropriate.
November 30,1991 - receipt of updated information, as needed, on
company and facility specific commitments as a result of activities with
other regulatory planning or toxic use reduction programs, or the Early
Reductions Program for Section 112(d) standards under the Clean Air
Act
Progress in achieving the 33/50 Program goals will be monitored through the
use of information reported to the TRI.
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INTERFACE BETWEEN THE 33/50 PROGRAM AND THE EARLY REDUCTIONS
PROGRAM
The EPA intends to implement the 33/50 Program and the Early Reductions
Program in a coordinated manner to minimize confusion over their differing require-
ments and to encourage participation. The Early Reductions Program is being
implemented by a rule defining procedures and requirements that must be followed to
obtain a compliance extension.
Any HAP emission reductions documented under the Early Reductions Program
can also can be submitted and credited under the 33/50 Program and vice versa.
Reduction credits are not "used up" when applied to one of these programs.
However, reductions achieved under the 33/50 Program will not necessarily qualify a
source for a compliance extension under the Early Reductions Program. In general,
the Early Reductions Program documentation requirements are more stringent. Also,
sufficient control must be employed to achieve at least 90 (95) percent reduction in
base year HAP emissions from the source.
Although the 90 (95) percent reduction requirement for the Early Reductions
Program may seem much higher than the reductions goals of the 33/50 Program, it is
important to note the differences in the emission sources. Under the Early Reductions
Program, an owner or operator may choose to define the source as a subset of the
emission points within the plant site. In the 33/50 Program, the source is always the
entire plant site. Therefore, by voluntarily reducing air emissions from a single source
or group of sources by 90 (95) percent, a source owner or operator may or may not
achieve the 33/50 Program goal of reduction from all media. Additionally, it is
important to note the differences in base years. The base year for the Early
Reductions Program is generally 1987 or later, whereas the base year for the 33/50
Program is 1988. It should also be noted that properly documented reductions under
the 33/50 Program may qualify for credit under the Early Reductions Program
because of the flexibility afforded an applicant in defining a source as a subpart of an
entire facility.
As with the 33/50 Program, the EPA encourages participation in the Early
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Reductions Program through the adoption of pollution prevention measures. The EPA
defines pollution prevention as the use of materials, processes, practices, or products
that avoid, reduce or eliminate wastes or toxic releases, through activities such as
toxic use reduction, source reduction and closed-loop recycling.
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APPENDIX A
Guidelines for Submitting Enforceable Commitments
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GUIDELINES FOR SUBMITTING
ENFORCEABLE COMMITMENTS
Introduction
The purpose of this appendix is to provide updated guidelines for submitting
enforceable commitments. To date, EPA has received over 70 submittals from companies
wishing to participate in the Early Reductions Program. Most of these companies are part
of the Synthetic Organic Chemicals Manufacturing Industry (SOCMI).
In reviewing these submittals, EPA has gained experience in determining an
acceptable format for facilitating review and acceptance of the information provided. This
appendix presents a suggested format for organizing a submtttal and provides an
example of a complete and technically acceptable enforceable cofnmitment.
It is intended that this information will be used by both regulatory agencies and
industry to improve the organization and presentation of enforceable commitments. Some
of the suggested information is not required by the Early Reductions rule. However,
inclusion of this information will help facilitate review of the submtttal and will also provide
a more thorough document for public review.
A-1
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Organization of This Appendix
" i", , " - " , , " ,:,| 'MI "; Hi
This appendix is organized into six sections. Sections A-E present components
of an enforceable commitment. Rationale for including specific information is provided in
this part of the report.
Section F is a sample enforceable commitment containing all of the required
information for a complete submittal. For the most part, the information included in
Section F has been taken from actual enforceable commitments received by EPA.
Note on Confidential Business Information
When parts of a submittal are claimed confidential by the source, efforts should be
made to create a complete and coherent nonconfidential submittal to accompany the
confidential version. The EPA is sensitive to confidential" business information and does
not want source owners and operators to reveal information that may jeopardize the
company's competitive position. However, the applicant must also realize that there is
great public interest in the Early Reductions Program and the nonconfidential information
needs to be complete and self-standing. Simply blacking out confidential portions of the
submittal or referring to confidential portions provided under a separate cover will not be
accepted. The non-confidential version should be devoid of all confidential markings.
The burden of providing a complete nonconfidential submittal will be placed on the
applicant Information considered confidential will need to be described in a way so that
someone reviewing the nonconfidential version is able to follow aind understand how
emissions were computed. If confidential information is used in the computation, the type
of information and the methodology used to compute emissions should be described in
narrative form. If necessary, calculation inputs can be combined and presented as
lumped parameters to protect confidential information, yet provide calculation details.
H confidential information is submitted, it should clearly be stated in the cover letter.
The letter should describe tire nature and location of the confidential business information
in the submittal.
A-2
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Contents of a Complete Enforceable Commitment
Preferred Order of Presentation
A. Cover Letter
B. Table of Contents
a) Identification of Major Headings
b) Page Numbers
c) List of Tables and Figures
d) Appendices
C. Site Plan
a) Plan of Contiguous Facility
b) Detailed Identification of the Source and Emission Points
D. Source Identifying Information
a) General Source Description
b) Activity Causing HAP Emissions
c) List of Emission Points
1) Identification of emission points using plant ID
2) List of HAP's for each emission point
3) Total emissions for each emission point
4) Total weighted emissions for each emission point
5) Permit ID numbers for each emission point
d) General Plan for Achieving Reduction
e) Evidence that Base Year Emissions are not Artificially or Substantially High
E. Emissions Data
a) Presentation of emissions data
A-3
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A Cover Letter
A complete cover letter for an enforceable commitment should include the following:
1) A general descriptive identification of the source or sources.
2) An identification of the source definition that applies to the source(s).
3) Identification of the base year.
4) A table summarizing the base year emissions from each source, including
both the total HAP emissions and the total HAP emissions adjusted for high
risk pollutants, if appropriate.
5) A statement certifying that the base year emission estimates represent the
best available emission estimates.
6) A statement including an understanding that the base year emission
estimates constitute a response to an EPA request under authority of
section 114 of the Clean Air Act.
7) A statement specifying that the base year emissions are within allowable
limits specified in any applicable law, regulation, or permit condition.
8) A statement committing the source owner or operator to achieving the
required post-reduction emissions by January 1, 1994.
9) A table showing the post-reduction emission level to be achieved, including
both the total HAP emissions and the total HAP's adjusted for high risk
pollutants.
10) Identification of confidential business information in the submittal.
'. ' \
11) The name of the plant contact who would be able to sinswer any technical
questions regarding the submittal.
12) The signature of a responsible official representing the company that
controls the contiguous area under common control containing the source.
A sample cover letter is provided on the next page. Each of the items listed above
are identified by number and with bold typeface.
A-4
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SAMPLE COVER LETTER
April 1, 1992
Director
Air, Pesticides, and Toxic Management Division
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Re: Enforceable Commitment for XYZ Chemical
Dear Sir/Madam:
In accordance with Title 40 Part 63 of the Code of Federal Regulations, we wish to
participate in the Early Reductions Program for one source located within our Raleigh,
North Carolina, facility. This source is identified as a group of emission points
located within the contiguous plant site. These emission points are listed in Table
1 on page of this submittal.
Attached is a site plan of the contiguous facility identifying the Early Reductions source.
Also included is a detailed site plan of the source that identifies each emission point using
plant identification numbers.
The source conforms to source definition a(4) under section 63.73. A
demonstration that the source conforms to this definition is included along with evidence
that the base year emissions were not unusually high. As provided in the attachment, the
base year (1987) HAP emissions from this source were as follows:
(1)
Total
HAP
Emissions
Weighted
HAP
Emissions
(2)
(3)
(4)
Source A
150 tons/yr 235 tons/yr
A-5
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I certify to the best of my knowledge that the base year emissions given above (5) (6)
are correct and constitute the best available data for base year emissions from the
source and acknowledge that these estimates are being submitted in response to
an EPA request under Section 114 of the Act. I further certify that the base year (7)
emissions provided for all emission points in the source do noit exceed allowable
emission levels specified In any applicable law, regulation, or permit condition., I
commit to achieve before January 1,1994 the stated post-reduction level(s) at the
source, which will provide the 90 (95) percent reduction required to qualify for the
compliance extension, and acknowledge that this commitment is enforceable as
specified in Title 40 Part 63 Subpart D of the Code of Federal Regulations.
We commit to achieve, before January 1,1994, the following post-reduction
emission levels:
Total
HAP
Emissions
Weighted
HAP
Emissions
(8)
(9)
Source A
15 tons/yr 23.5 tons/yr
These post-reduction emission levels will provide the 90 percent reduction required to qualify for
a compliance extension. I acknowledge that this commitment is enforceable as specified in Title
40, Part 63, Subpart D of the Code of Federal Regulations.
Please note that process information regarding temperature, pressure, and rates (10)
of reaction contained in the calculation sheets for the process vents on pages
6-8 of Appendix A are considered confidential.
if you have any questions concerning the content of this submittal, please contact (11)
Joe Smith at 919-555-0000.
Sincerely,
George S. Jones
Plant Manager
(12)
A-6
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S. Table of Contents
Including a Table of Contents in the enforceable commitment will help facilitate the
review process. The table should identify each major section of the submittal and give
a corresponding page number. Page numbering is critical for the reviewing agencies.
The submittal is reviewed concurrently by as many as three regulatory offices. By having
page numbers, the respective agencies can discuss various components of the submittal.
In addition, page numbering helps the regulatory agency pinpoint deficiencies,
subsequently making it easier for industry to address any comments as a result of
completeness or technical review.
A sample Table of Contents is given on the following page.
A-7
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SAMPLE TABLE OF CONTENTS
Table of Contents
Page
List of Tables i
List of Figures ii
Site Plan
Plan of Contiguous Facility 1
Detailed Identification of the Source
and Emission Points 2
"Source Identifying Information
General Source Description 3
Activity Causing HAP Emissions 3
List of Emission Points 4
General Plan for Achieving Reduction 5
Evidence that Base Year Emissions
Are Not Artificially or Substantially Greater 6
Emissions Data 7
Process Vent A 8
Process Vent B 11
Storage Tank A 14
Process Wastewater 17
A-8
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C. Site Plan
The site plan should identify the locations of all emission points within each source
identified for the Early Reductions Program. The level of detail for the site plan will be
dependent on the complexity of the source and the source definition. For example, if the
source definition includes all storage tanks in tank farm A, it should be easy to identify the
location of these tanks on a site plan. However, if the source definition is a collection of
emission points from various locations at a facility, the site plan must clearly indicate
which emission points are included in the source.
In some cases, it may be necessary to include two site plans to identify a source.
The first site plan would show the entire contiguous facility and highlight the location of
processes or specific emission points that make up the source (a "macro" site plan). The
second site plan would magnify the individual processes and identify each specific
emission point (a "micro" site plan).
An example of an acceptable site plan is presented on the following page. This site
plan shows the boundary of the contiguous facility and also clearly marks each emission
point included in the source.
A-9
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N
AIR EMISSIONS POINT SOURCES
AND
TOTAL SOURCE BOUNDARY
FROM
MAIN
GATE
to
WAREHOUSE
BU. 245
CHANGE
HOUSE
MRO STORES
BL. 219
GRANULATION
UNIT
BL. 170
CENTRAL
MAINTENANCE
SHOP
CHEMICAL
UNIT *1
SOLVENT HANDLING '/
UNIT '/
FIELD TANK
FARM
. RAW MATERIAL
STORAGE /
WAREHOUSE
Bi..
PUMP
HOUSE
BL. 119
CHEMICAL
JNIT ป2
POINT SOURCES
VAPOR RECOMPRESSiCN
STACK
=RODUCT BLOWOVES
SAG HOUSE
OACXOUT BAGHOUSE
NEGATIVE AJR
BAG HOUSE
VAPOR RECOMPRESSiON
TORIT 3AGHOUSE
STACK
QUALITY
, CONTROL
/ LABORATORY
WASTE TREATMENT
JNIT
SCALE: O
A-10
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D. Source Identifying Information
The source identifying information includes the following items:
a) General Source Description
b) Activity Causing HAP Emissions
c) List of Emission Points
d) General Plan for Achieving Reduction
e) Evidence that Base Year Emissions are Not Artificially or Substantially
High
Each of these will be discussed in detail below. .
a) General Source Description
The general source description is a narrative description of the source or sources
defined for the Early Reductions Program. Examples of satisfactory general source
descriptions follow:
Example 1
The source is defined as the set of emission points associated with the
Dock Tank Farm. This includes three xylene fixed-roof tanks and one styrene fixed-
roof tank and the unloading and loading of xylene and styrene.
The source, as defined for purposes of the Early Reductions Program,
conforms to section 63.73 (a) (4). The HAP emissions from the set of emission
points defined as the source total more than 10 tons per year.
Example 2
The source is defined as all emission points located in the resins
manufacturing department. This includes the storage of raw materials and
intermediates, process vents, process storage losses, and the transfer and
unloading of raw materials and finished goods.
A-11
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The source conforms to 'definition (a)(3) in section 63.73 of the Early
Reductions regulation. It can be defined as a facility, structure, or installation for the
purposes of establishing standards under Section 112(d) of the Clean Air Act.
b) Activity Causing HAP Emissions
This is also a general narrative statement describing the activity causing the
emission of hazardous air pollutants. Examples of satisfactory statements include:
Examole 1
HAP's are emitted from the source as a result of raw material and product
losses during normal production operations. HAPs are also emitted from the plant
laboratory, utility operations, and the pilot plant.
Example 2
mt " , , , , .1
HAP's are emitted as a result of volatilization from large exposed surface
areas of the treatment units. Wastewater is hard-piped to the treatment processes,
and this is the first point of atmospheric exposure.
c) List of Emission Points
Thorough and accurate completion of this section of the enforceable commitment
will greatly aid the review for completeness. Careful attention should be given to logically
arranging the information. The use of tables is encouraged.
Each emission point must be listed. A logical arrangement sequence would be by
source, process, and then individual emission point. A table should include the following
columns: ...,...!..
- i1"1!
1) Emission point, using plant identification code
2) Permit ID number of emission point, if applicable
3) Description of the emission point
4) Each HAP emitted by the emission point
5) CAS number for each HAP.
A-12
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6) Emissions of each HAP (Ibs/yr or Mg/yr)
7) Weighting factor for the HAP
8) Weighted HAP emissions
Table 1 in Section F is an example of a complete list of emission points including
each of these suggested items.
d) General Plan for Achieving Reductions
The general plan for achieving emission reductions ajso could be presented in
tabular form. This is especially helpful if there are a large number of emission points in
the source. The table should include each emission point identified by plant ID number,
the description of the emission point, and the reduction plan. In addition, it would be
helpful to show the year that each reduction measure was implemented, or is anticipated
to be implemented. An example-of a complete table is Table 2 in Section F.
e) Evidence that Base Year Emissions are not Artificially or Substantially High
It is critical that the facility demonstrate that the base year emissions are not
artificially or substantially greater than emissions in other years prior to implementation of
emission reduction measures. In cases where the reduction measures are implemented
in the year following the base year, evidence should be provided for the two years prior
to the base year. In cases where the reduction measures are implemented several years
after the base year, evidence should be provided for all years between the base year and
the year in which reduction measures are implemented.
The applicant should provide HAP emissions from the proposed source for at least
3 or 4 years prior to implementation of control measures. To the extent possible, the
methodology used to determine emissions should be consistent from year to year, and
should be the applicant's best determination. What the EPA considers to be "substantially
or artificially high" will be necessarily subjective, taking into consideration the nature of the
source, growth, and other factors affecting emissions.
Where HAP emission determinations from the source for other years cannot be
readily quantified, a surrogate parameter can be proposed such as production rate for
other years in comparison to the base year. However, it is important that the applicant
provide an appropriate rationale for why HAP emissions are believed to be related to the
A-13
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surrogate parameter and to the source as defined. Simply stating that emissions are
believed to be related to production is not sufficient, anci supporting rationale must be
provided. For example, the applicant might state that:
"We .believe that emissions are directly related to process production rates. Two
process vents account for 95 percent of the base year emissions. Emissions from
these two vents are the result of impurities in raw materials. The level of impurities
In raw materials is relatively constant. Therefore, the parameter most directly
affecting the generation of vent gas is the feed rate of raw materials. The feed
rates of raw materials are a direct function, of process production rate."
Additional examples are provided in the attached example enforceable commitment.
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E. Emissions Data
a) Presentation of Emissions Data
Documentation of base year emissions is the most important component of an
enforceable commitment. The facility must show that the base year emission estimates
are accurate and based on substantiated information.
For the purposes of facilitating review, it is helpful to present a table listing each
emission point and the method used to calculate the emissions from each point.
Table 3 in Section F is an example of such a table. The submittal must also include
information justifying why emissions testing was not conducted for applicable emission
points. The example table shows one way to summarize the rationale for not testing.
This is helpful for review purposes, but a more complete rationale should be provided
when presenting data for specific points.
A procedures document has been prepared to assist owners and operators in
estimating emissions ("Procedures for Establishing Emissions for Early Reduction
Compliance Extensions," EPA-450/3-91-Q12a). It is recommended that the forms
presented in this document be used when submitting emissions data. Note that these
forms are not a substitute for the underlying documentation, which must also be
submitted, but are used to summarize data from emissions points from the source.
In general, base year and post-reduction emissions must consist of documented
results from source tests using an EPA Reference Method, EPA Conditional Method, or
the source owner's or operator's source test method that has been validated using
Method 301. However, section 63.74 (f) of the Early Reductions regulation lists five
conditions under which an owner or operator may submit calculations based on
engineering principles, emission factors, or material balance data in lieu of results from
source tests. It is important that the applicant identify one of the reasons listed under
section 63.74 (f) and provide supporting rationale.
When the base year emissions are based on an EPA Reference Method, EPA
Conditional Method, or the owner or operator's own method validated using Method 301,
at least a short summary of the test and test results should be provided. The dates of
the test, the sampling method, number of samples collected, and the basis for the value
A-15
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used in establishing emissions should be provided. In the case of a non-EPA method
validated using Method 301, the supporting validation data should also be provided.
A-16
r. 'i! i
, 'iff ii/ii!
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SECTION _F
SAMPLE ENFORCEABLE COMMITMENT
XYZ CHEMICAL COMPANY
A-17
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IF
April 1, 1992
Director
Air, Pesticides, and Toxic Management Division
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
foe: Enforceable Commitment for XYZ Chemical
Dear Sir/Madam:
jn accordance with Title 40 Part 63 of the Code of Federal Regulations, we wish to
participate in tne Early Reductions Program for one source located within our Raleigh,
North Carolina facility. This source is identified as Source A and contains those
emission points listed in Table 1 on page A-9 of this submittal.
Attached is a site plan of the contiguous facility identifying each emission point in Early
Reductions source. The source conforms to source definition a(4) under ง 63.73. The
basis for the source conforming to this definition is included in the) attachment, along
with "evidence that the base year emissions were not unusually high. As provided in
the attachment, the base year (1987) HAP emissions from this source were as follows:
Total
HAP
Emissions
Weighted
HAP
Emissions
Source A
225.2 Mg 739.6 Mg
I certify to the best of my knowledge that the base year emissions given above
constitute the best available data for base year emissions from the source and are correct to
the best of my knowledge, and I acknowledge that these estimates are being submitted in
response to an EPA request under Section 114 of the Act. I further certify that the base year
emissions provided for all emission points in the source do not exceed allowable emission
levels specified in any applicable law, regulation, or permit condition.
A-18
-------
We commit to achieve, before January 1, 1994, the following post-reduction
emission levels:
Source A
Total
HAP
Emissions
22.5 Mg
Weighted
HAP
Emissions
74.0 Mg
These post-reduction emission levels will provide the 90 percent reduction required to qualify
for a compliance extension. I acknowledge that this commitment is .enforceable as specified
in Title 40, Part 63, Subpart D of the Code of Federal Regulations.
If you have any questions concerning the content of this submtttal, please contact Joe
Smith at 919-555-0000.
Sincerely, '
George S. Jones
Plant Manager
A-19
-------
XYZ Chemical - Enforceable Commitment
Table of Contents
List of Tables A-21
Site Plan
Site Plan Identifying the Source
and Emission Points A-22
Source Identifying Information
General Source Description A-23
Activity Causing HAP Emissions / A-23
U'sJ of Emission Points A-23
General Plan for Achieving Reduction A-23
Evidence that Base Year Emissions
Are 'tyot Artificially or Substantially High A-24
|r ' i , " .
ilil ' , !
Emissions Data A-25
PV-1 A-29
PV-2 A-31
L-1 '. A-38
S-1 A-40
WW-1 A-47
A-20
-------
List of Tables
1 XYZ Chemical Company Base Year Emissions A-26
2 General Plan for Achieving Reduction A-27
3 . Basis for Base Year Emission Estimates A-28
A-21
-------
Site Plan
Identification of Eariy Reductions Emission Points Included in Source A
A-22
-------
a) General Source Description
The source is defined as a collection of emission points located within the
contiguous facility. Included in the source are two process vents, one product storage
tank, rail car loading for paraxylene, and one process wastewater stream.
The source, as defined for purposes of the Early Reductions Program, conforms
to section 63.73 (a) (4). The HAP emissions from the set of emission points defined as
the source total more than 10 tons per year..
b) Activity Causing HAP Emissions
HAP's are emitted from the emission points in the source as a result of raw material
and product losses during normal production operations. Two process vents are
included in the source. One is the vent on an air oxidation reactor in the benzoic acid
process unit. HAP emissions result from the venting of excess air fed to the air oxidation
reactor. Some benzene is present in this vent stream. HAP emissions from the other
process vent included in the defined source are caused by the venting of byproduct
carbon dioxide formed in a chemical reaction. Ethylene oxide, which is a product of the
reaction, is carried from the reactor in the byproduct carbon dioxide. Also included in the
defined source is a paraxylene loading operation and a xylenes/ethylbenzene fixed roof
storage tank. Emissions from the loading operation result from the displacement of vapor
from rail cars as the material is loaded. HAP emissions from the fixed roof storage tank
result from storage tank breathing and working losses. One wastewater stream is also
included in the defined source. HAP's present in this wastewater stream volatilize to the
atmosphere during collection and treatment of the wastewater stream.
c) Ust of Emission Points
Table 1 lists all of the HAP's emitted from the defined source. This table identifies
each emission point by plant identification code and also provides the State permit
number for each emission point, where appropriate. Weighting factors for each HAP are
provided, along with the total HAP emissions for the base year (1987) and also the
weighted HAP emissions.
d) General Plan for Achieving Reductions
The general plan for achieving emissions reductions is presented in Table 2.
A-23
-------
e) Evidence that Base Year Emissions are not Artificially or Substantially
High
The HAP emissions from the source are not substantially or artificially higher
than in other years prior to implementation of control measures. Emissions
determined for other years are included below:
1987 foase veart
225.2
1988 1989 1990
228.4 218.6 215.3
These emissions were based on a combination of using test results PV-1, WW-1),
engineering calculations (PV-2), and AP-42 emission factors (L-1, S-1). Emissions were
determined from the points in the source for the years listed by prorating (in the case of
test results) or using the operating conditions (e.g., throughput) for that year.
(NOTE: Where emission determinations cannot be made from the source for other years,
the following description of the emissions/production (throughput) relationship would be
acceptable as a surrogate.)
Emissions from the process vents and the wastewater stream included in the
defined source are believed to be directly related to the production rates of the respective
production units. The vent gas rate for the air oxidation reactor is directly related to the
production rate and the benzene concentration of the stream is believed to be constant.
Similarly, the vent gas rate from the ethylene oxide reactor is directly related to the
production rate of ethylene oxide and the ethylene oxide concentration is believed to be
constant. The flow rate, of the wastewater stream included in the source is directly related
to the production of cnloromethanes. The methylene chloride and methanol
concentration are believed to be constant. The production rates for the three respective
process units are presented below:
PRODUCTION (10*)
Product
Benzole Acid
Ethylene Oxide
Chloromethanes
1987
46.6
75.4
390.4
1988
54.6
68.0
407.9
1989
58.2
68.0
385.9
1990
53.6
69.8
385.9
Emissions from the paraxylene loading operation are most directly related to the volume
of paraxylene loaded. Annual volumes of paraxylene loaded are presented below:
A-24
-------
PARAXYLENE LOADED (10* GALLONS)
1987
18.2
1988
18.4
17.8
1990
18.1
Emissions from the xyiene/ethylbenzene storage tank are most directly related to the
annual throughput. The composition of the stored material is constant. Annual
throughputs for this tank are presented below:
ANNUAL THROUGHPUT (10' GALLONS)
1987
87.96
1988
88.24
1989
88.78
1990
90.23
f) Emission Data .
Table 3 presents the basis for establishing base year emissions from each
emission point. The table provides rationale for not conducting emission estimates where
appropriate. The emission calculations and supporting documentation for the estimates
are also provided on the following pages.
A-25
-------
XJI1 ' nil: " '."in is'''"
<
CD
C/3
03
3 (O
O
-------
TABLE 2. General Plan for Achieving Reductions
Description
Air Oxidation
Unit 1
COa Vent
Rail Car
Loading
Storage Tank
Wastewater
ID#
PV-1
PV-2
L-1
S-1
WW-1
Control
Thermal Oxidizer
None
Vapor Control
Unit
Internal Roating
Roof
Steam Stripper
Date
12/93
1990
1992
12/93
A-27
-------
to
5
cc
V
(A
UJ
ง
o
ป
5
If 8ซ,
m s
CD *"^
D)O
g CO
C Q.
C ฃ
Is
HI
C. O C.
.2 c c>
"So"
0J* t. "C3
*I
o ^ ฃ2-
^0 c:
?
CO
!s (O
CD C
^'S
.9 = &
Q.O 13
a. CD -5
ซj r: o
o o 15 co ฃ
Z Z O CQ UJ
II II !,l II II
T- CM CO ซt W
A-28
-------
Source: Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS
HAP; Benzene
Year: 1987
Process Vent Identification; PV-1
Description; Air Oxidation Unit 1
Date s 1-29-92
Calculator s RHH
Process Conditions/Sampling
Date of flow measurement
Method of flow measurement
Date of concentration measurement
Method of concentration measurement
(if not an EPA Method give a brief
description and attach protocol)
Describe any problems encountered
during testing^ None
9-16-81
EPA Method 2
9-19-81
Method 18
Production rate during flow determination (Ibs/hr).
Production rate during sampling (Ibs/hr)
Average production rate for the year (Ibs/hr)
3800
3800
3800
Stream Characteristics
Annual average vent stream flow rate
(ft3/min)
Annual average HAP concentration (ppmv)
Annual hours of operation (hrs)
Vent stream discharge temperature (ฐF)
HAP molecular weight (Ib/lb-mole)
Pressure at point of discharge (psia)
HAP high-risk weighting factor
2070
630
7676
69.9
78.11
14.7
10
Q
c
h
T
MW
P
FHR
Control
Control device
HAP control efficiency (%)
Calculationsa
Uncontrolled Emissions (E{j)
Uncontrolled Emissions (Ey)
None
eff
2.54E-09 Q C h MW P
T + 460
2.54B-09f2070H630H76761 (78.111(14.71
(69.9) +460
55.09
Mg/yr
A-29
-------
Source: Source A
I1 ' , ' ,:j
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS (CONCLUDED)
HAP Emissions
HAP Emissions
(1 - eff/100)
55.09H1 - _ Q _ /100)
55.09
Mg/yr
'HAP FHR
Weighted HAP Emissions
Weighted HAP Emissions
If the conditions during testing are not representative of base
year qf operation, make the appropriate extrapolation below and
explain:
(55.09) (10)
Mg/yr
If the flow or concentration were not measured using an EPA
reference method, EPA conditional method or validated using
Method 301, provide justification and supporting calculations:
Expression provided in "Procedures for Establishing Emissions
for Early Reduction Compliance Extensions" to convert flow and
concentration into an annual mass rate; -the 2.54E-09 constant .is
based on the ideal gas law.
Hotซป on PV-1 Calculations: Following EPA Method 18 procedures,
three vent gas samples were obtained in Tedlar bags and analyzed
using gas chromatagraphy and a flame ionization detector. The
value reported represents the average of three samples. The
samples were obtained during a period representative of base year
operation. The flow was measured using EPA Method 2.
A-30
-------
Source; Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS
HAP: Ethvlene Oxide
Year: 1987
Date: 1-29-92
Calculator: RHH
Process Vent Identification; PV-2
Description; EO-1 Carbon Dioxide Vent
Process Conditions/Sampling
Date of flow measurement
Method of flow measurement
Date of concentration measurement
Method of concentration measurement
(if not an EPA Method give a brief
description and attach protocol)
Describe any problems encountered
during testing. None
1988 Annual
Calculation
05/18/89 - 06/02/89
SCG 632-81
3.602
Production rate during flow determination (Ibs/hr).
Production rate during sampling (Ibs/hr) .
Average production rate for the year (Ibs/hr) 3.602
3,500
Stream Characteristics
Annual average vent stream flow rate
Annual average HAP concentration (ppmv)
Annual hours of operation (hrs)
Vent stream discharge temperature (ฐF)
HAP molecular weight (Ib/lb-mole)
Pressure at point of discharge (psia)
HAP high-risk weighting factor
39.5
7552
44
14.7
10
Control
Control device _
HAP control efficiency (%)
Calculations
SEE ATTACHED CALCULATIONS
None
Q
C
h
T
MW
P
FHR
eff
A-31
-------
Source; Sources A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS (CONCLUDED)
HAP Emissions
HAP Emissions
(1 - eff/100)
0.201 (1 - 0 /100)
Mg/yr
EHAP .FHR
( 0.20) (10)
Mg/yr
Weighted HAP Emissions
Weighted HAP Emissions
If the conditions during testing are not representative of base
year of operation, make the appropriate extrapolation below and
explain:
If the flow or concentration were not measured using an EPA
reference method, EPA conditional method or validated using
Method 301,provide justification and supporting calculations:
' " ; . , / ' : ' ' .' ' " ' T
A total of five samples of the carbon dioxide vent gas stream
Were collected between 05/18/89 and 06/02/89. They were obtained
in one liter sample cylinders through the sample port located on
the carbon dioxide vent. The samples were obtained during normal
process operation. These samples were analyzed using Analytical
Method SCO632-81 (see attached). Three analyses were performed
for each sample and then averaged to obtain the EO composition
for that sample. The results for each of the five samples (42.1,
38.5, 38.2, 39.6, and 39.1) were averaged to obtain the 39.5 ppm
used in our computation of base year emissions.
Expression provided in "Procedures for Establishing Emissions
for Early Reduction Compliance Extensions" to convert flow and
concentration into an annual mass rate; the 2.54E-09 constant
is based on the ideal gas law.
A-32
-------
As noted, the sampling was actually performed in 1989 and the
base year selected is 1987. No data exists for 1987, and we
believe that the 1989 results are representative of the base year
as well as 1989.
We are not aware of any validated EPA Method for measuring EO
concentration and have used SCG 632-81 which is a gas
chromatographic procedure using a Poropak QS column and a thermal
detector. SCG 632-81 is an industry standard for determining EO.
concentration and has been used at this facility for more than
ten years to evaluate process operations. A copy of the method
is .attached. Considering the annual quantity of HAP emissions
from this source, we feel that the expense of validating this
method with Method 301 is not justified.
Detailed Calculations
Assumptions/Knowns;
1. The vent gas rate is roughly equal to the rate of by-
product C02 production. By-product C02 formed in the EO
reactors is separated from the product stream and exhausted
to the atmosphere. The Ib-moles of C02 in the vent gas is
assumed to equal the Ib-moles of CO2 produced in the
reactors. Additionally, the Ib-moles of ethylene oxide
(EO), acetaldehyde (ACH), methane (CH4) and heavy
hydrocarbons (C2 - C4) are believed to be negligible
compared to the total Ib-moles of C02 in the vent stream.
Therefore, total Ib-moles of vent gas is assumed equal to
total Ib-moles CO2 produced.
2. Ethylene consumed in reactors = 20,816,172 Ibs in 1987.
3. Average reactor selectivity = 83.0% in 1987
Where: % selectivity -MOLES EO FORMED x 100
MOLES C2H4 REACTED
This is based on GC analyses of the reactor product stream.
A total of five samples were analyzed in May of 1987. EO
and C02 concentrations were measured. All reacted C2H4 was
assumed to form either EO or CO2ป Attached Method SCG-632-
81 was used to determine EO concentration.
4. Remainder of C2H4 (17.0%) is assumed to form
5. Vent gas analysis is on dry basis.
A-33
-------
6. Stoichiometric equation for C02 production:
C2H4 + 302 * 2C02 + 2H20
C02 Production
1. Convert C2H4 feed rate from Ibs/yr to Ib-moles/yr:
Feed
,f
2.08E07 Ibs x Ib-mole
yr 28 Ibs C2H4
7.43EO5 Ib-mole
yr
2.
Determine Ib-moles of C02 (vent gas) produced from C2H4'feed.
Based on 17% of C2H4 being reacted to C02:
7.43E05 Ib-moles
yr
0.17'Ib-moles to C02 x 2 Ib-moles
Ib-mole CH feed Ib-mole
2.52EO5 Ib-moles C02 Produced
Assuming the vent gas rate is equal to the rate of C02
production , compute EO emissions:
"i III! '' ' '.i , ' ' ' .
2.52ECJ5 Ib-moles Vent Gas x 39.5 Ib-mole EO x 44 Ibs EO
yr EO6 Ib-mole Vent Gas Ib-mole EO
Min H1 ** , .......... ., . " ,
3 438 Ibs EO/yr
" ..... ",;!:: ' ..... ..... . "'.:.". i : . ..";' : ...'.. ..... ..( . .
Uncontrolled Emissions
(Eu) ป 4.54E-04(438)
HAP Emissions
HAP Emissions
Mg/yr
= Eu (1 - eff/100)
0.20 (1 - 0 71001
EHAP FHR
(0.20) (10)
Mg/yr
Weighted HAP Emissions
Weighted HAP Emissions
Testing conditions were representative of base year.
No EPA method available. The method used, SCG 632-81, is a gas
chromatographic procedure using a Poropak QS column and a thermal
detector. A copy of the method is provided in Exhibit 1.
A-34
-------
EXHIBIT 1
XYZ CHEMICAL COMPANY
RALEIGH PLANT
Analytical Method SCG-632-81
Analysis of
. EO.UNIT GAS STREAMS
Gas Chromatographic Procedure
SCOPE
1. This is a gas chromatographic (GC) procedure for determining
the composition of EO Unit gas streams. Among the samples
that can be analyzed by this method are the reactor feed and
product, treated and untreated natural gas, and residual gas.
METHOD SUMMARY
2. The sample is injected by a sample valve and fractionated with
Poropak QS. As the components emerge they are detected by
thermal conductivity detection and recorded as peaks. The
peak areas are adjusted by applying response factors and
concentrations in mole percent are calculated by normalizing
the corrected peak areas.
UNUSUAL HAZARDS
3. Some of the components of these gases are highly flammable.
Store the sample cylinders containing them in the fume hood
until time for analysis. Permit only the small amount needed
for analysis to escape into the general laboratory atmosphere.
Due to the low concentrations and small amount of sample used
to purge the sample loop, no special handling is required for
samples containing EO.
APPARATUS
4. a.
1)
2)
3)
4)
Gas chromatograph, Hp 5710 A, TC, set up as follows:
Column: 6' x 1/8", S.S., 0.012" wall, packed with
Poropak QS, 80-100 mesh.
Gas sample injection valve, 0.5 cc.
Injector at 250-C, detector at 300*, sensitivity at 5.
Carrier gas (helium) at 30 ml/min.
A-35
-------
ANALYTICAL METHOD SCG-732-81
36
5) Temperature programmer to hold at 40-C for 2 minutes,
then rise to 250* at 8ซC/min.
b. Strip chart recorder.
CALIBRATION
5.
Purchase a 1500 psi gas mixture of about the following
Composition, analyzed by the supplier to show actual
concentrations to the nearest 0.01% mole.
1) Nitrogen
2) Argon
3 j Methane
4) Carbon Dioxide
5) Ethylene
6) Ethane
7) Cyclopropane
8) Propane
9) Ethylene Oxide
2%
2%
12%
60%
20%
1%
1%
0.1%
0.5%
Inject 0.5 cc of the standard and -analyze by the
technique described in step 6 below. Measure the area
for each component and then determine the "observed %" by
area normalization without applying response factors.
Calculate the mole response
component as follows:
Actual % mole
Observed % Area
factor (M.R.F.) for each
M.R.F.
PROCEDURE
6.
a.
b.
Prepare the GC for analysis by setting the conditions
listed in step 4 (a).
Inject 0.5 cc sample, simultaneously starting the
temperature program, the computer and the recorder. Make
note of the attenuations used. See figure 1 for an
example of the chromatogram obtained.
"| " , , , . ' ;'; ' ;: '" '" , . , ' ',
Measure the area of each peak.
A-36
-------
ANALYTICAL METHOD SCG-732-81
37
CALCULATIONS
7. a. Determine the corrected area (CA) for each peak:
CA = (A) (attenuation) (M.R.F.)
A ป peak area (Area units must be consistent
throughout)
M.R.F. = mole response factor for the peak.
b. Normalize the corrected areas to give composition in
units of % mole.
c. Report results to the nearest 0.1%M for routine analysis.
DISCUSSION
8. Some confusion may arise because % mole is used here rather
than % weight. This is done to conform to the convention of
giving results for gas analyses in % mole. It is advisable to
always include the units when reporting results, because most
analyses are reported in % weight.
EVALUATION OF THE METHOD .
. *
9. This procedure gives results accurate and repeatable to + 10%
for the amount present based on the analysis of known
concentrations in a standard.
REFERENCE
10. a.
Analytical Method SCG-632-76, "Analysis of EO Unit Gas
Streams by Gas Chromatograph," and
b. Analytical Method SCG-1051-77,
Distribution of Olefin Gas Mixtures."
'Carbon
Number
JRR/pac
Raleigh Plant
August 11, 1981
Approved:
A-37
-------
Source; Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS
HAP; Paraxvlene
Date: 4/1/92
Calculator: SAS
Year: 1987
; ' ;r , . , |i;. . , , . , , , .. . . . i
Loading Operation: Ll - PX Loading/Paraxvlene Raiil Car Loading
Loading Parameters
.J; ..... I
, , " ""I i1 * .1. , , ,
Cargo carrier (tank truck, rail car/ etc.)
Mode of operation (choose from Table 2-16)
Annual volume of liquid loaded (gallons)
Temperature of liquid loaded (ฐF)
Weight percent HAP in the loaded material
True vapor pressure of the HAP loaded (psia)
[Note: For mixtures, use the HAP partial
pressure]
Molecular weight of the HAP (Ib/lb-mole)
Saturation factor (see Table 2-16)
HAP high-risk weighting factor
Control
Control device
HAP control efficiency (%)
Calculation3
,,'.
Rail Car
Submerged Loading
18.150.000 = G
85 = T
100
0.21
106
0.5
None
N/A
= M
- S
FHR
eff
Uncontrolled Loading Loss Eu - 5.65E-06 S P M G
T + 460
Uncontrolled Loading Loss EU^5.65E-06 (0.5HO.21U 106U 18.150.000)
(85) + 460
HAP Emissions
Mg/yr
- Eu (1 - eff/ 100)
- 0_/100)
Mg/yr
A-38
-------
Source:
Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS (CONCLUDED)
Calculation (continued)
Weighted HAP Emissions
Mg/yr
aCalculation worksheet and procedure from "Procedures for
Establishing Base Year and Post-reduction HAP Emissions.
This procedure is consistent with AP-42.
A-39
-------
Source; Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS
HAPs Xvlene
Year: _1I87_
Date: 2-2-92
Calculator s MTW
Tank designation:_Sjil
Product: Xylene/Ethvlbenzene
Tank Characteristics
Inside diameter, (ft)
Height, (ft)
Capacity, (gal) - H/4*D2*h * 7.48 gal/ft3
if not known
Roof color medium gray _
100
48
Shell color medium gray
Vapor space height, (ft)a
Ambient Conditions
Average atmospheric pressure (psia)
(defaults 14.7 psia)
Average ambient diurnal temperature
2.820.000
24
14.7
Average annual ambient temperature
Bulk Liquid Characteristics
Stored liquid temperature (ฐF)C
Total throughput per year (gงl)
Number of turnovers per yeara
Molecular weight of HAP (Ib/lb mole)
Vapor pressure of stored material (psia)
Partial pressure of the HAP at liquid
conditions (psia)
HAP high-risk weighting factor
Adjustment Factors
Paint factor (see Table 2-3)
Small diameter tank factor6
Turnover f actorf
Product factor^
1.46
9.5
69.8
=Aip
=TA
73.3
87.956.200
31
=TS
=AN
106 =MTT
0.164
0.033
=P
=Pi
=FHR
-C
A-40
-------
Source; Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS (continued)
Control
Control device None
HAP control efficiency (%)
Calculations*1
Breathing Loss (M9/Yr) =
LB - 1.02E-05MV. ( - 2 - )
1 P~P
0
ฐ'68
=1.02E05(106) - 0.164 - ฐ-68 ( 100) 1.73 (24) 0 -51(9 ,
(14.7)-(0.164)
Mg/yr
0.50
ปeฃf
1}Io.0331
(0.164)
Working Loss (Mg/yr) - % - 1.09E-08 Mv.PiVNKNKc
- 1.09E-08 (106) (0.033) (2,820,000) (31) (1) (1)
Mg/yr
3.333
Total Loss (Mg/yr) =
TL = LB + LW ซ (0.677) +( 3.333)
4.010
Mg/yr
If a control device is employed,
HAP Emissions (Egj^p) = Total Loss (1 - eff/100)
- 4.010 (1 - _Q_/100)
Mg/yr
A-41
-------
Source; Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS (concluded)
Weighted HAP Emissions
alf vapor space height is unknown or shell, assume H equals one
half tank height. If tank has a cone roof, adjust vapor space
height by adding 1/3 of height of cone.
falf average ambient diurnal temperature change is unknown, assume
2oฐF. ; ' ' i ;.
cStored liquid temperature may be approximated from average
annual ambient temperature. See Table 2-2.
AN
V
where N - number of turnovers per year
AN - total throughput per year (gal)
V - tank capacity (gal)
eFor D > 30ftf C-l? For 6 < D < 30ft, C=0.0771D-C).0013D2-Q. 1334 .
' '' ' '" '
turnovers > 36, KN - (180 + N)/(6 * N)
where KN ป turnover factor (dimensionless)
N ป number of turnovers per year
For turnovers < 36, KN ป 1
9KC ป 1 . 0 for volatile organic liquids
hExpression for computing HAP emissions are from "Procedures for
Establishing Base Year and Post-Reduction HAP Emissions.' The
calculation procedure is consistent with AP-42.
A-42
-------
Source: Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS
HAP; Ethvlbenzene
Years 1987
Tank designation; S-l
Product t Xvlene/Ethvlbenzene
Date; 2-2-92
Calculator: MTW
Tank Characteristics
Inside diameter, (ft)
Height, (ft)
Capacity, (gal) - E 2& *
if not known
Roof color medium gray
100
48
7.48
4
ft3
2,820,000
Shell color medium arav
Vapor space height, (ft)a
Ambient Conditions
Average atmospheric pressure (psia)
(defaults 14.7 psia)
Average ambient diurnal temperature
Average annual ambient temperature
Bulk Liquid Characteristics
Stored liquid temperature (ฐF)C
Total throughput per year (gงl)
Number of turnovers per yeard
Molecular weight of HAP (Ib/lb mole)
Vapor pressure of stored material (psia)
Partial pressure of the HAP at liquid
conditions (psia)
. HAP high-risk weighting factor
Adjustment Factors
Paint factor (see Table 2-3)
Small diameter tank factorฎ
Turnover factor*
Product factor^
24
14.7
9.5
69.8
_=D
_=Hip
=V
=H
--PA
87
73.3
.956,200
31
=TS
^^ป1Cf
=N
106 =Mw;
0.164
0.131
1
=P
=pi
. =FHR
1.46
1
1
1
=FP
=C
=KN
=KC
A-43
-------
Source: Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS (continued)
Control
Control device None
HAP control efficiency (%)
Calculations.**
Breathing Loss (M9/Yr) ^
LB - 1
0.164
-68
(14.7)-(0.164)
Mg/yr
0-50 ( 1>46
(0.164)
"Working Loss (Mg/yr) - LW - 1.09E-08.
- 1.09E-08 (106) (0.131) (2^820, 000) (31) (!)(!)
13.23
Mg/yr
Total Loss (Mg/yr) -
TL ซ LB -ซ LW - (2.69) + ( 13.23)
15.92
Mg/yr
If a control device is employed,
HAP Emissions (Snap) - Total Loss (1 - eff/100)
' - 15.92 (1 - _2_/100)
Mg/yr
A-44
-------
Source; Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS (concluded)
Weighted HAP Emissions
(15.92) ( 1)
Mg/yr
alf vapor space height is unknown or shell, assume H equals one
half tank height. If tank has a cone roof, adjust vapor space
height by adding 1/3 of height of cone.
blf average ambient diurnal temperature change is unknown, assume
20ฐF.
GStored liquid temperature may be approximated from average
annual ambient temperature. See Table 2-2.
AN ,
where
V
N = number of turnovers per year
AN = total throughput per year (gal)
V = tank capacity (gal)
eFor D > 30ft, C-l; For 6 < D < 30ft, C=0.0771D-0.0013D2-0.1334.
fFor turnovers > 36, KN - (180 + N)/(6 * N)
where KN = turnover .factor (dimensionless)
N - number of turnovers per year
For turnovers < 36, KJJ = 1
gKc = i.o for volatile organic liquids
Expression for computing HAP emissions are from "Procedures for
Establishing Base Year and Post-Reduction HAP Emissions." The
calculation procedure is consistent with AP-42.
A-45
-------
SUPPORTING CALCULATIONS FOR VAPOR PRESSURE AND PARTIAL PRESSURE
Tank Designation: S-l
From Chemical Engineer ' s Handbook
Vapor pressure (3-xylene) ''- 0.148 psia
quality control (one per day)
.Vapor pressure of Ethyl-benzene
22. 9 C for product
0.169 psia @ 22.9- C
Based on liquid analysis by gas chromatograph (one per day), a
representative composition of the stored material is 22.5 mol. %
xylene and 77.5 mol. % ethylbenzene. The xylene concentration was
21.6 to 23.5 percent. The 22.5 percent used in this calculation is
not a computed average, but is believed to be representative.
1 'i. , ii
Using Raoult's Law, partial pressure of xylene =
. If i '|l , ' ,, i, , ,': '.I .,.'' , , W ',,!,' : ' , '"
(0.225) (0.148) = 0.033 psia
and the partial pressure of ethylbenzene =-
(0.775) (0.169) ซ 6.131 psia
Therefore, vapor pressure of the stored material
0.033 + 0.131 - 0.164 psia
A-46
-------
Source: Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM WASTEWATER SOURCES
HAP: Methanol
Year; 1987
Date;4/6792
Calculators.
RHH
Wastewater Stream Identification:_WWl
Wastewater Stream Description; Waste acid from the methyl
chloride drying tower .
Flow Meter
EPA Method 25D/18
Process Conditions/Sampling
Date of flow measurement
Method of flow measurement
Date of concentration measurement
Method of concentration measurement
Production rate during flow determination (Ibs/hr)
Production rate during sampling (Ibs/hr)
Average production rate during base year (Ibs/hr)
Stream Characteristics
Average annual flow rate during discharge
(1pm)
Average annual HAP concentration (mg/1)
Fraction of HAP that would be emitted
(see Table 2-18)a
Fraction of HAP that would be measured
by Method 25D/18 (see Table 2-18)*
HAP high-risk weighting factor
4/24/91
4/24/91
42,000
42.000
47.000
78.6 Q
3000
0.28 fe
0.32
Control
Control device
HAP control efficiency (%)
Calculations'8
Wastewater Emissions (WEU) = 5.26E-04 Q CVOHAP fej_
fnu
None
N/A
= fmj
FHR
= eff
A-47
-------
Source: Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM WASTEWATER SOURCES (CONCLUDED)
Wastewater Emissions (WEU)
HAP Emissions
5.26E-04(78.6)(3000)(0.281
(0.32)
108.5 Mg/yr
= WEU (1 - eff/100)
= 108.5 (1 - 0_/100)
Mg/yr
Weighted HAP Emissions =
FHP
= (108.5)( 1)
Mg/yr
aTable 2-14 in "Procedures for Establishing Emissions for Early
Reduction Compliance Extensions."
.'iP!J , ": ' " ' ' '
^Calculation worksheet and procedure from "Procedures for
Establishing Emissions for Early Reduction Compliance Extensions.
Notes on Sampling Method: The flow was measured with a flow meter
in a closed channel. Three samples of the wastewater were obtained
and analyzed. The protocol prescribed in Method 25D was followed
to obtain the samples. Method 18 was performed by splitting the
air purge stream and performing the Method 18 analysis (gas
chromatography) parallel to the Method 25D analysis.
. A-48
-------
,Source t Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM WASTEWATER SOURCES
HAP: Methvl Chloride
Year: 1987
Date:4/6/92
Calculator:
RHH
Wastewater Stream Identification:_WWl____
Wastewater Stream nggri-ription; Waste acid from the methyl
chloride drying tower :
Flow Meter
EPA Method 25D/18
Process Conditions/Sampling
Date of flow measurement
Method of flow measurement
Date of concentration measurement
Method of concentration measurement
Production rate during flow determination (Ibs/hr)
Production rate during sampling (Ibs/hr)
Average production rate during base year (Ibs/hr)
Stream Characteristics
Average annual flow rate during discharge
(1pm)
Average annual HAP concentration (mg/1)
Fraction of HAP that would be emitted
(see Table 2-18)a
Fraction of HAP that would be measured
by Method 25D/18 (see Table 2-18)a
HAP high-risk weighting factor
Control
Control device
HAP control efficiency (%)
4/24/91
4/24/91
42.000
42.000
47.000
100
1000
_= Q
-=GซIKP
0.75 =
1.00
FHR
None
N/A
= ef f
Calculations1*
Wastewater Emissions (WEU)
= 5.26E-04 Q CVOHAP
Table 2-14 in "Procedures for Establishing Emissions for Early
Reduction Compliance Extensions."
"Calculation worksheet and procedure from "Procedures for
Establishing Emissions for Early Reduction Compliance Extensions."
A-49
-------
Kj
isf: ,:
Sir';""
'if 5 '.!
, Source: Source A
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROMWASTEWATER SOURCES (CONCLUDED)
Wastewater Emissions Potential (WEU) = 5.26E-04 (100) (3000)1P_._751
'"' ' " , " ' ' ' ' ' ' ซ" " (1.00)
' ' ' ' '' '
39.4
HAP Emissions
WEU (1 - eff/100)
= 39.4 (1 - 0_/100)
Mg/yr
Weighted HAP Emissions
EHAP FHP
- (39.4)(
Mg/yr
Mg/yr
\ ' , fjj i1 ; , '' '"j'l'1 -I ,i , ", ; !. .'ซ
Notes on Sampling Mathod: The flow was measured with a flow meter
in a closed channel. Three samples of the wastewsiter were obtained
and analyzed. The protocol prescribed in Method 25D was followed
to obtain the samples.. Method 18 was performed by splitting the
air purge stream and performing the Method 18 analysis (gas
chromatography) parallel to the Method 25D analysis.
A-50
ill i!!!, '1'!; , '.<,
-------
APPENDIX B
Reviewer Checklists
Form A - Source Data Sheet
Form B - Completeness Review
Form C - Technical Review
-------
, I. ,.', " "I , " i< ...BnHII"!1:1'",,,' I "", , '' 'nliiUiLill'l1;.". <
-------
Early Reductions Program
Source Data Sheet
1
Company j
i
Location , ,; ' , \
, . {
Plant Contact (Phone #) \
i
EPA Region
State/Loca[jAgency_^_
EPA Regional Contact
State/Local Agency Contact
n Enforceable Commitment Q Base Year Review
Source i
i
Base Year i
'I
Bass Year Emlnton*
VMghtod Bnisalons
Post-Reduction Goaf i
.... t
Wซ!ghtซJGoal {
Submittal Diary Progress by Date
Subintllal
Received
Completeness ,
Approval
Technical
Approval
Public Comment
Period Begins
Permit Approval
Proposal of
Applicable
ง112(d) Standard
Notes on Status
Form A
-------
-------
Eariy Reductions Program
Completeness Review
Company/Location
Source
Enforceable Commitment (Complete Sections A D)
Base Year Review (Complete Sections B - D)
Summary of Deficiencies / Completeness Review
Technical Deficiencies Noted During Completeness Review
Form B
-------
A. Enforceable Commitments
For enforceable commitments only, is the following information provided:
Yes No N/A
d D D 1. A statement of commitment providing the post-reduction emission level to be achieved
by the source?
d q D 2. A statement of commitment providing the post-reduction emission level adjusted for
. high-risk pollutants?
O
3. A statement certifying that the base year emission estimates represent the best
available emission estimates?
d a
4. A statement including an understanding that the base year emission estimates
constitute a response to an EPA request under authority of ง 114 of the Clean Air Act?
D 5. A statement committing the source owner or operator to achieving the required post-
reduction emissions by January 1, 1994?
D D
,
6. A statement specifying that base year emissions are within allowable limits specified
in any applicable law, regulation, or permit condition.
d d n " 7. A statement of commitment signed by a responsible official representing the company
. that controls the contiguous area under common control containing the source?
D O a 8. A general plan describing how emission reductions will be achieved.
B. General Source Information .
Yes No
O O 1. Does the submittal include a site plan of the contiguous iarea under common control
that contains the source(s)?
D D
2. is the site plan marked to Indicate the location of the source(s)?
D D D 3. The source definition that describes the source.
D D D 4. The activity causing HAP emissions.
d O D 5. A list of all emission points In the source.
D O 6. A list of HAP emitted by the source.
dan 7. A list of high risk HAP emitted by the source.
Form B
-------
C, Base Year Emissions
Yes No N/A
d D n 1. If the base year chosen is 1985 or 1986, is evidence provided that emission data for
these years was provided to the Administrator before November 15, 1990?
O D D 2. Are the total base year emissions provided?
D d D 3. For each emission point, are base year emissions provided for each HAP?
n D D 4. For each high risk pollutant, are the total base year emissions adjusted using the high
risk weighting factors?
D D HI 5. Is there evidence provided, that the base year emissions are not artificially or
substantially greater than emissions in the years prior to implementation of reduction
measures?
Form B
-------
D. Substantiation of Base Year Emission
'" 1
J! 1'
, - . :< :rซ .
Emission Point ID # |
Testing
EPA Methods
I
1
1
I
p
Non-EPA Methods |
.
Description of Test
Protocol
i
m
o>
cc
ts
ฃ
Rationale for Non-EPA
Method or Method 301
Calculations
Rationale for Not
Testing
ซ
AP-42 / Documented
Procedure
Material Balance
i_
Discussion of Method
Detailed Calculations
Status
COMPLETE
DEFICIENT
!
Notes:
Form B
-------
Early Reductions Program
Technical Review
Company/Location ]
Source , ' ;" j
Total Base Year
Emissions ;
-
Emission Point ID
3 Year Emissions
M
(0
m
g
1
ฃ
ฃ
til
Methodology
ง
!i
s s
E <
CO
i?
ซ s
So
o S
a ฃ
00
I
o
<
1
%
a
Notes
Form C
-------
Emission Point ID
A. Testing
Yes No N/A
d" d D
d
d
n
D
d
n
P
a
n
n
a
d
n
n
n
n
a
n
d
n
n
n
d ' n
o
B. Calculations
Yes
n
q
ri
n
n
d
a
No
n
a
a
d
n
d
n
N/A
a
n
n
n
n
n
a
1. Was a validated EPA test method used to measure flow?'
1 >.'' i . .' " * . ..':' , ':"
2. Was a validated EPA test method used to measure concentration?
3. Is a description of the test protocol and any problems encountered during testing
Included?
4. Was the test method appropriate for the source and pollutants tested?
5. Are emissions reported as annual emission rates for each hazardous air pollutant?
6. Is the annual emission rate presented consistent with the test results?
7. If the test data was collected from a year different from 'the base year, was the data
appropriately scaled to the base year?
8. Are the pollutants emitted consistent with the described process?
"i, ' '! ,' , ' ..!!'!' i , "',,' i":"1!'"!1 ,i
9. Are the quantities emitted consistent with the quantities expected based on a rough
material balance or comparison with similar industries?
1. Is the rationale for not conducting tests acceptable?
' M: ,'.' ' :': ' ' : : . . i:;" " .'. ' ' . . *'!
2. Are all calculations described step-by-step and are all assumptions provided?
' . , ". ' ' ' ; , .;!;;'' ' ' r . iy .' ;.., ' |, ' . , , ,'
3. Is the calculation method one of the acceptable method!) for that source category as
presented In one of the EPA documents, or If not, iiป the method appropriately
documented and acceptable?
.i. ,,' i ' , . ,; , i " i ' n
4. Were all the calculations performed correctly?
5. If the emission source is equipment leaks, was some method other than EPA average
emission factors used?
6. Are the pollutants emitted consistent with the described process?
7. Are the quantities emitted consistent with the quantities expected based on a rough
material balance or comparison with similar industries?
Form C
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA 450/3-91-013
4. TITLE AND SUBTITLE
Enabling Document for Regulations Governi
Extensions for Early Reductions of Hazard
Pollutants
7. AUTHOR(S)
3. RECIPIENT'S ACCESSION NO.
S. REPORT DATE
QC rvWLian- December 1992 - . .
ฐ- ,.r 6. PERFORMING ORGANIZATION CODE
ous Air - . .
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS ' 1O. PROGRAM ELEMENT NO.
Office of Air Quality Planning and Standards
Environmental Protection Agency 11. CONTRACT/GRANT NO.
Research Triangle Park, North Carolina 27711 68D10117
12. SPONSORING AGENCY NAME AND ADDRESS
Director, Office of Air Quality Planning
Office of Air & Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 2
13. TYPE OF REPORT AND PERIOD COVERED
& Standards
14. SPONSORING AGENCY CODE
7711 EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Regulations governing compliance extensions for early reductions of hazardous
air pollutants are promulgated under the authority of section (612) (i) (5) of the
Clean Air Act (CAA) . These rules would apply to sources that seek compliance
extensions from standards promulgated under section (112) (d) of the CAA. This
document provides practical information on the implementation of the Early
Reductions Program.
_ *
17. " KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Hazardous Air Pollutants
National emission standards for
hazardous air pollutants
Early Reductions
18. DISTRIBUTION STATEMENT
Unlimited
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Pollution Control 13B
Unclassified
20. SECURITY CLASS (This page} 22. PRICE
Unclassified
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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