United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 2771 1
EPA-453/R-95-007
September 1995
Air
Enabling Document for
Permits for Early
Reductions Sources
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EPA-453/R-95-007
Enabling Document for
Permits for Early
Reductions Sources
Emissions Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1995
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This document has been reviewed by the Emission Standards Division
of the Office of Air Quality Planning and Standards, EPA, and
approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or
recommendation for use. Copies of this report are available
through the Library Services Office (MD-15), US Environmental
Protection Agency, Research Triangle Park, NC 27711 (telephone:
(919) 541-2777), or from National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161.
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U. S. ENVIRONMENTAL PROTECTION AGENCY
Enabling Document for
Permits for Early Reductions Sources
Prepared by:
"6ruce C. Jordan
Director,/Emission Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
(Date)
1. The promulgated rule "Permits for Early Reductions Sources"
(November 21, 1994 issue of the Federal Register, pages
59921-59933) established an interim, federal operating
permit program for sources participating in the Early
Reductions Program. This document provides information
to better understand and implement the rule.
2. Copies of this document have been sent to the following
federal departments: Labor, Health and Human Services,
Defense, Transportation, Agriculture, Commerce, Interior,
and Energy: and to the National Science Foundation; State
and Territorial Air Pollution Program Administrators; the
EPA's Regional Administrators; Local Air Pollution
Control Officals; the Office of Management and Budget;
and other interested parties.
3. For additional information contact:
Mr. David Beck or Mr. Rick Colyer
U.S. Environmental Protection Agency
Emission Standards Division (MD-13)
Research Triangle Park, North Carolina 27711
Telephone: (919) 541-5421 or 541-5262
4. Copies of this document may be obtained from the organizations
listed on the previous page of this document.
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Table of Contents
Section
1.0 INTRODUCTION . 1-1
1.1 PURPOSE OF ENABLING DOCUMENT 1-1
1.2 BACKGROUND . 1-2
2.0 EXPLANATION OF RULE . . .2-1
2.1 PROGRAM OVERVIEW (§71.21) 2-1
2.2 DEFINITIONS (§71.22) 2-3
2.3 APPLICABILITY (§71.23) 2-4
2.4 PERMIT APPLICATIONS (§71.24) 2-4
2.4.1 Where to File Permit Applications 2-4
2.4.2 Deadlines for Filing Permit Applications . .2-5
2.4.3 Permit Application Content . . 2-6
2.5 PERMIT CONTENT (§71.25) 2-9
2.6 PERMIT ISSUANCE, REOPENINGS, AND REVISIONS
(§71.26) . „ . . 2-12
2.6.1 Permit Issuance 2-12
2.6.2 Permit Changes . 2-13
2.7 PUBLIC PARTICIPATION AND APPEAL (§71.27) . . . . 2-15
3.0 PERMIT APPLICATION GUIDANCE 3-1
3.1 COVER LETTER AND TABLE OF CONTENTS 3-1
' 3.1.1 Cover Letter 3-1
3.1.2 Table of Contents 3-2
3.2 COMPANY AND SOURCE IDENTIFICATION INFORMATION . . .3-2
3.2.1 Company Identification 3-2
3.2.2 Source Identification 3-2
3.3 EMISSIONS REDUCTION DEMONSTRATION PLAN 3-5
3.4 PROPOSED PERMIT TERMS AND CONDITIONS AND
RATIONALE 3-6
3.4.1 Alternative Emissions Limitations . . . . . 3-7
3.4.2 Emission Point-Specific Terms and
Conditions 3-9
3.4.3 Operational Flexibility Provisions .... 3-15
3.4.4 Reporting 3-15
4.0 EMISSIONS REDUCTION DEMONSTRATION 4-1
4.1 BASE-YEAR EMISSIONS DOCUMENTATION 4-1
4.2 POST-REDUCTION EMISSIONS DOCUMENTATION 4-2
4.2.1 Short-Term Test Results 4-3
4.2.2 Use of Different Test Methods to Establish
Base-Year and Post-Reduction Emissions .... 4-4
5.0 PERMIT DEVELOPMENT 5-1
5.1 PERMIT APPLICATION COMPLETENESS REVIEW .5-1
5.2 DRAFTING THE PERMIT 5-4
5.2.1 Synthesizing Permit Conditions 5-4
5.2.2 Effective Permit Writing . 5-18
5.3 REVISING THE INITIAL DRAFT OF THE PERMIT .... 5-19
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Table of Contents (Continued)
APPENDIX A:
APPENDIX B:
APPENDIX C:
APPENDIX D:
APPENDIX E
APPENDIX F:
APPENDIX G:
APPENDIX H:
Example Permit Application
List of Validated Test Methods
Sources of Information on Test Methods
Options for Estimating HAP Emissions Below the
Detection Limit of the Measurement Method
Emissions from Startups, Shutdowns, and
Malfunctions
Review Checklist for Permit Applications
•Example Permit
Example Emissions Reduction Demonstration
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List of Figures
Figure Page
3-1 Example Report Format . 3-16
15-1 Organization of an Early Reductions Specialty Permit . .5-6
VI
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1.0 INTRODUCTION
1.1 PURPOSE OF ENABLING DOCUMENT
The purpose of this enabling document is to provide
practical information and guidance to permit applicants and
permit writers implementing the early reductions specialty permit
program. This document is designed to help participating
facilities develop their early reductions specialty permit
applications, and to help permitting agencies review these
applications and develop permits for early reductions sources.
This document includes:
• An explanation of the early reductions permit rule
(section 2.0);
• Guidance on preparing an early reductions permit
application (section 3.0);
• Guidance on preparing an emissions reduction
demonstration (section 4.0); and
• Guidance on developing an early reductions specialty
permit (section 5.0).
Several examples and checklists are provided in the
appendices, including:
Permit application information (Appendices A-E);
A review checklist for permit applications
(Appendix F);
An example early reductions specialty permit
(Appendix G); and
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An example emissions reductions demonstration
(Appendix H).
1.2 BACKGROUND
In 1990, Congress passed amendments to the Clean Air Act
(CAA). The amendments rewrote section 112 of the CAA to require
initial technology-based regulation of sources of toxic air
pollutants, followed by health risk-based standards at a later
time. The amendments listed 189 hazardous air pollutants (HAPs)
that were to be regulated and directed the U.S. Environmental
Protection Agency (EPA) to develop standards for sources emitting
these HAPs. The standards must require installation of the
"maximum achievable control technology" or "MACT" (although for
some area sources the Administrator may impose "generally
achievable control technology" or "GACT"). The determination of
MACT must be based on the best-performing facilities within the
source category (e.g., oil refinery, chemical plant) in question.
In 1992, EPA published a list of all the major source categories
to be regulated under section 112 and a schedule for issuing
standards.
However, under section 112(i)(5) of the CAA, a source can
obtain a six-year extension to an otherwise applicable MACT
standard compliance date if it voluntarily reduces its HAP
emissions before proposal of such a standard. In order to obtain
this "early reductions" extension, a source must demonstrate
qualifying HAP emissions reductions--generally, a 90-percent-by-
mass reduction or a 95-percent reduction of a particulate HAP on
an annual basis. This provision was designed to encourage
sources to substantially reduce their emissions before the
required deadlines. At the end of the six-year extension, a
source must meet all applicable MACT standards.
To establish the technical and procedural requirements for
obtaining an early reductions compliance extension, EPA
promulgated "National Emission Standards for Hazardous Air
Pollutants; Compliance Extensions for Early Reductions" in
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December 1992 (Federal Register. December 29, 1992,
pp. 61970-62002). This rule includes the statutory requirement
that every successful early reductions source be issued a title V
permit containing federally enforceable emissions limitations to
ensure that early reductions are maintained throughout the
compliance extension period.
States eventually will issue title V permits to sources
successfully demonstrating achievement of early reductions.
However, State title V permitting programs would not have been
approved by EPA in time to process the initial early reductions
permit applications. Therefore, EPA acted to establish an
interim title V permitting mechanism. The early reductions
permit rule was promulgated in the Federal Register on
November 21, 1994 (pp. 59921-59933) as 40 CFR part 71, subpart B,
"Federal Operating Permit Programs, Permits for Early Reductions
Sources." This specialty permit rule provides a permitting
mechanism for early reductions sources until comprehensive
operating permit programs become effective pursuant to title V.
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2.0 EXPLANATION OF RULE
This chapter provides a discussion, by section, of the most
important elements of the early reductions specialty permit rule.
The sections of the rule are:
• Program overview;
• Definitions;
• Applicability;
• Permit applications;
• ' Permit content;
• Permit issuance, reopenings, and revisions; and
• Public participation and appeal.
Together, these elements set out the regulatory framework for the
permit application requirements and emissions reduction
demonstration given in sections 3 and 4 of this document.
Many of the sections of the title V rule promulgated under
40 CFR part 70, "State Operating Permit Programs," have been
incorporated into this specialty permit rule. Certain sections
were dropped or modified as appropriate for the narrower scope of
this rule (i.e., to apply only to HAP emissions from the early
reductions source within a facility).
2.1 PROGRAM OVERVIEW (§71.21)
The regulations under this subpart describe a specialty
permit program that is a Federal title V permit program tailored
to early reductions sources. This specialty permit program is an
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interim program that will be gradually replaced as States obtain
• approval of their comprehensive operating permit programs under
title V. Until that time, specialty permits will be issued to
early reductions sources by the EPA Administrator (in fact, the
duty will be delegated to the EPA Regional offices.)
As implied above, EPA will not necessarily stop issuing
specialty permits immediately upon approval of a State's
comprehensive title V permit program. EPA may issue a specialty
permit after such approval in the following cases:
• If the State obtains its program approval after a
facility has filed an early reductions permit
application but before the permit is actually issued;
or
• If the deadline for a facility's comprehensive title V
permit application under the approved State program is
later than the specialty permit application deadline
under §71.24(b).
EPA's primary consideration in deciding whether to issue a
specialty permit or defer to the State in the above cases will be
the length of delay that would occur by waiting for the State to
issue the permit.
Even if a source has obtained a specialty permit, the
facility containing the source still must apply for the
comprehensive title V permit required by the approved permit
program after the State title V program is approved. The State
will incorporate the specialty permit into the comprehensive
title V permit issued to the facility containing the early
reductions source.
The rule requires that specialty permits be issued for terms
not to exceed five years. EPA plans to issue specialty permits
with five-year terms. Although a source's compliance extension
will still be in effect beyond the five-year permit term,
specialty permits issued under this subpart will not be renewed.
Rather, renewal will be accomplished by incorporating the terms
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and conditions of the specialty permit into the comprehensive
permit issued to the facility. In the event that a specialty
permit's term expires before a comprehensive permit is issued,
the specialty permit will remain in effect until the
comprehensive permit is issued.
The EPA Administrator may delegate to a State the
responsibility for implementing the specialty permit program.
However, EPA would retain the right to issue specialty permits in
cases where the permit application was filed before delegation
was granted. To obtain delegation, a State will have to
demonstrate that it has the ability to administer and enforce the
specialty permit program.
2.2 DEFINITIONS (§71.22)
This section of the rule includes definitions taken directly
from the promulgated part 70 (State title V) rule, where
applicable to this subpart. A few definitions were also added
from the promulgated part 63 (early reductions compliance
extensions) rule. Terms already defined in the CAA were not
repeated. Key terms with specific meaning under this subpart are
discussed below.
One term that has a specific meaning under this subpart is
"enforceable commitment." An enforceable commitment provided an
alternate means of obtaining an early reductions compliance
extension, but only for sources subject to "early" section 112(d)
standards--those standards that were proposed prior to
January 1, 1994. Generally, early reductions must be achieved
before the proposal date of the applicable section 112(d)
standard. However, some sources affected by the "early"
section 112(d) standards may not have had enough time to achieve
the qualifying emissions reductions before proposal. The CAA
amendments alleviated this problem by allowing such sources to
make an enforceable commitment prior to the proposal of an early
section 112(d) standard. Those sources making an enforceable
commitment had until January 1, 1994 to achieve qualifying
emissions reductions. Because January 1, 1994 has passed, no new
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enforceable commitments can be made, and all sources
participating in the program from now on must achieve the
required reductions before proposal of the otherwise applicable
standard.
Another key term defined in this section is "post-reduction
year." The post-reduction year is a one-year period that usually
begins on the date the reductions are required to be achieved.
For most sources, that date would be the date of proposal of the
first section 112(d) standard that applied to the early
reductions source. For sources that made enforceable
commitments, that date would be January 1, 1994 (and the
post-reduction year would run from January 1 through
December 31, 1994). Sources, at their discretion, may define an
earlier post-reduction year provided they notify the permitting
authority.
An additional key term defined in this section is
"Section 112(d) standard." This term refers to an emissions
standard.issued under the authority of section 112(d) of the CAA,
as amended by the 1990 amendments. These standards are the
National Emission Standards for Hazardous Air Pollutants
(NESHAP), which, as explained previously, in most cases will be
based on the MACT.
2.3 APPLICABILITY (§71.23)
This section states that the rule applies to owners or
operators who are participating in the early reductions program
and who must file a permit application before the State
comprehensive title V program is approved. It also states that
all HAP emissions from the early reductions source mus,t be
included in its specialty permit application and its permit.
2.4 PERMIT APPLICATIONS (§71.24)
Filing details and content requirements for permit
applications are provided in §71.24.
2.4.1 Where to File Permit Applications
Responsibility for processing specialty permit applications
will be delegated by the EPA Administrator to the EPA Regional
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offices during the period before State title V permitting
programs are approved. Therefore, the owner or operator of a
source must submit the permit application to the appropriate EPA
Regional Office. Copies of the application must also be
submitted the appropriate State air pollution control agency and
to:
EPA Emission Standards Division
Mail Drop 13
Research Triangle Park, NC 27711
Attn: Early Reductions Officer
EPA Office of Enforcement and Compliance Assurance
EN-341-W
401 M Street, S.W.
Washington, D.C. 20460
Attn: Early Reductions Officer
2.4.2 Deadlines for Filing Permit Applications
Owners/operators of sources who made enforceable commitments
were required to file a permit application by April 30, 1994.
For sources that have not made enforceable commitments, the
permit application must be submitted by the later of:
• 120 days after proposal of the earliest section 112(d)
standard that the source is seeking a compliance
extension from; or
• 120 days after the part 71 early reductions permits
rule is promulgated (because the rule was promulgated
on November 21, 1994, this date is March 21, 1995).
The post-reduction emissions demonstration is part of the
permit application. However, in most cases it will not be
submitted with the application but rather will be filed later as
a supplement. This is because the post-reduction year on which
the post-reduction emissions demonstration is based normally will
end one year after proposal of the applicable section 112(d)
standard, and the specialty permits rule allows the source one
month after the end of the post-reduction year to submit the
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demonstration (well after the permit application deadline).
However, if the source establishes an earlier post-reduction year
with the permitting authority, as allowed under the rule, and
such a year ends at least one month before the permit application
deadline, then the post-reduction demonstration must accompany
the permit application.
One exception to the above is that any source sampling
results used by the source as part of the post-reduction
emissions demonstration must be submitted with the permit
application. This will require that sources perform the sampling
early in the post-reduction year, thus assuring the permitting
authority that reductions occurred, as required, before proposal
of the applicable standard.
2.4.3 Permit Application Content
The primary components of a complete permit application are:
• Identifying information for the facility.
• ' A description of the early reductions source (also
required and delineated in more detail in the Early
Reductions Rule, 40 CFR §63.74).
• Substantiated base-year and post-reduction emissions
for the source that show achievement of qualifying
early reductions (delineated in more detail in the
Early Reductions Rule, 40 CFR §63.74).
• Proposed emissions limitations:
The alternative emissions limitation (AEL) for the
early reductions source;
A second alternative emissions limitation for
"high-risk" HAP's if any are emitted from the
source; and
Additional emission limiting requirements to
promote or ensure practical enforceability of the
alternative emissions limitation, as appropriate.
• Alternative operating scenarios, if the owner so
chooses.
• Monitoring, recordkeeping, compliance certification,
and reporting requirements proposed for the source.
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Several of these permit application components are discussed
below. Additional information relevant to permit application
components appears in other sections of this document (i.e.,
sections 3 and 5 and appendices A trhough E, and F).
2.4.3.1 Alternative Emissions Limitation. The alternative
emissions limitation proposed in the permit application must be
an annual cap (calendar-year basis) on aggregate HAP emissions
from the early reductions source. This limitation must reflect a
HAP emissions reduction on a mass basis of at least 90 percent
(95 percent for particulate HAP) from the established base-year
emissions.
If the early reductions source emits any of the 45 high-risk
pollutants listed in the early reductions rule, then a second
alternative emissions limitation must be proposed in the permit
application. This second alternative emissions limitation will
be similar to the first except that it will require a reduction
in HAP's of at least 90 (or 95) percent considering the weighting
factors of any high-risk HAP'S emitted. The weighting factor for
each pollutant is provided in the list of high-risk pollutants
found in Table 1 of 40 CFR 63.74. The factors are based on the
relative risks of adverse public health effects that may be
associated with exposure.
The permit application may include proposed additional
limitations to aid practical enforcement of the alternative
emissions limitations, as provided in §71.24(e)(4). The proposed
additional limitations may include:
Limitations on raw material usage;
Limitations on throughput (such as barrels per year for
a storage tank);
Capacity restrictions (such as MMBtu/hr for a boiler);
Limitations on operation (such as hours per year); and
Work practice standards (such as periodic inspections
and specified repair practices).
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Any additional limitations included in the specialty permit
would assist in tracking a source's progress toward meeting the
alternative emissions limitation (which is an annual cap).
2.4.3.2 Alternative Operating Scenarios. Alternative
operating scenarios for the source may be proposed by the
owner/operator if emitting processes or operations are
anticipated to vary during the course of a year or during the
course of the permit. The permit application must identify
associated permit terms and conditions needed to ensure that the
source will meet the alternative emissions limitation under the
alternate operating scenarios.
For example, if a facility has a storage tank in which
either ethylbehzene or xylene will be stored during the year, the
permit could be written to accommodate both scenarios. The
emissions calculation provisions for that tank should be written
so that any HAP-specific properties input to the calculations,
such as vapor pressure and molecular weight, are referenced only
generically. Thus, the permit would cite "vapor pressure of the
HAP" stored in the tank, rather than "vapor pressure of xylene."
In addition, the recordkeeping section would require the
owner/operator to record for each HAP stored in the tank, what
HAP it is, when it was stored in the tank, and the properties of
that HAP. The example permit in Appendix G illustrates this.
2.4.3.3 Monitoring. Recordkeeping. Reporting, and
Compliance Certifications. Specifically, the permit application
must contain:
• A statement of how the applicant proposes to
demonstrate continuing compliance with the proposed
alternative emissions limitation and other permit
conditions; and
• A schedule of submissions of compliance certifications
during the permit term (at least annually).
Methods to demonstrate continuing compliance would include a
description of monitoring devices and/or activities (such as
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process or equipment parameter monitoring or performing equipment
inspections) for the emissions units in the source, test methods,
and recordkeeping and reporting. It would also include the
emissions calculation procedures for the periodic
(e.g., quarterly) demonstration of compliance.
If a radionuclide source is included in the early reductions
source's emissions pool, the permit application must contain a
certification that no increases in radionuclide emissions will
occur under any post-reduction scenario.
The example permit in Appendix G gives a practical
application of these monitoring, reporting, and recordkeeping
requirements.
2.5 PERMIT CONTENT (§71.25)
Several of the elements required in a specialty permit
issued by EPA under this subpart mirror those required in a
State's comprehensive title V permit. In general, a specialty
permit will contain:
• An alternative emissions limitation;
• A second alternative emissions limitation if the source
emits any of the high-risk HAP's listed in the early
reductions rule;
• Additional emissions-limiting requirements such as
operational limits or work practice standards as needed
to ensure enforceability;
• Monitoring, recordkeeping, and reporting requirements;
• Compliance requirements;
• Terms and conditions for the alternative operating
scenarios identified by the permittee in the
application (if any);
• If requested by the permittee, terms and conditions for
trading HAP emissions among emissions units within the
early reductions source;
• A permit shield that applies only to compliance with
part 63, subpart D; and
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• A number of "boilerplate" title V permit conditions,
including emergency provisions and a severability
clause that keeps the permit requirements valid if any
part of the permit is challenged. (See section C of
the example specialty permit in Appendix G).
A specialty permit must contain all the monitoring
requirements necessary to determine whether the source is
complying with the alternative emissions limitation(s). These
requirements include monitoring and analysis procedures and test
methods, as applicable. These procedures and methods must be
consistent with those used for the early reductions demonstration
required by the part 63 regulation. The permit must require
monitoring on a frequency sufficient to ensure compliance.
The permit must require records of samples or measurements,
along with analyses of such samples, to be kept on site. Records
on samples must include the date, place, and time of sampling or
measurement and the operating conditions at that time. Records
on sample analyses must include the date of analysis, the company
that performed the analysis, the analytical techniques used, and
the results. The permit must require all monitoring records and
supporting information to be kept for at least five years.
Specialty permits issued under this subpart, like those
issued under part 70, must require that the source owner/operator
submit reports of all monitoring to the EPA at least every
six months. EPA intends to require the submission of monitoring
results and emissions calculations on a semiannual basis.
However, shorter reporting intervals may have to be specified for
the life of the permit for certain emitting units. For example,
emissions from some emission points may fluctuate widely over
time, or may make up the bulk of emissions from the entire early
reductions source. Emissions from such points may need to be
tracked more frequently to make sure the alternative emissions
limitations are not exceeded.
Under part 70, reporting of deviations from permit
requirements, including those due to upset conditions, must be
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"prompt." EPA will define "prompt" in relation to the extent and
type of deviation likely to occur at the source for each
specialty permit issued under this subpart. To minimize the
number of reportable deviations, the permittee should suggest in
the permit application terms and conditions covering routine
variations in operations and maintenance.
Additional limitations that may be included in the permit
are discussed in section 2.4.3.1 of this enabling document. EPA
will issue a specialty permit to include additional limitations,
if necessary, to ensure enforceability of the alternative
emission limitation.
The specialty permit will contain terms and conditions for
alternative operating scenarios at the early reductions source,
if requested by the applicant. Alternative operating scenarios
are discussed in section 2.4.3.2 of this enabling document. EPA
will issue a specialty permit to include permit terms and
conditions sufficient to ensure enforceability of the alternative
emissions limitation under any alternative operating scenario
described in the permit. The permit shall also require the
owner/operator to record in a log the scenario under which the
source is operating and provide notice to the Administrator
(i.e., EPA Regional Office) that the change has occurred. The
notification requirement is waived if process monitoring
information is sufficient to identify that a change to a
particular operating scenario has occurred.
Specialty permits will contain a permit shield statement.
This statement essentially says that if the permittee complies
with all terms and conditions of the permit, the permittee will
be regarded as complying with the requirements of the early
reductions regulations (part 63, subpart D). This shields the
permittee from being found out of compliance with any part 63,
subpart D, requirements that are misinterpreted in, or mistakenly
omitted from, the early reductions permit. The Appendix G
example permit provides permit shield language.
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2.6 PERMIT ISSUANCE, REOPENINGS, AND REVISIONS (§71.26)
Procedures for permit issuance and changes are set out in
§71.26.
2.6.1 Permit Issuance
Within 45 days of receiving a permit application, EPA must
determine whether the application is complete or incomplete. If
the application is incomplete, EPA must notify the applicant and
request the additional information needed. If no notification is
sent within 45 days, the application is considered complete. If
a source submits a complete early reductions permit application
on time, the source is protected by the "application shield."
Prior to the issuance of the specialty permit, this shield keeps
an early reductions source from being in violation of the
requirement to have an early reductions permit. The protection
ends when EPA either makes a final decision to issue or deny the
permit or requests additional information by a certain deadline
and the source fails to provide it.
The Administrator must make all draft permits and draft
permit modifications available for public review. Public
participation in the permit issuance process, which includes
notice, opportunity for comment, and a hearing if requested, is
discussed in section 2.7 of this enabling document.
EPA must take final action on each permit application within
12 months of receiving a complete application.unless additional
information is requested and the applicant does not provide it in
a timely manner.
As stated previously specialty permits issued under this
subpart will not be formally renewed, despite the fact that the
compliance extension granted the source will extend beyond the
5-year term of the specialty permit. Rather, EPA intends that
the terms and conditions of the specialty permit be renewed
through comprehensive title V permitting programs. When the
State title V program for issuing comprehensive title V permits
is approved, the State will incorporate the specialty permit
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terms and conditions into the facility's comprehensive title V
permit. If a specialty permit reaches the end of its term before
a comprehensive permit can be issued, it will remain in effect
until the comprehensive permit is issued. If the State's title V
program is never approved (or it appears that approval will not
be timely), the specialty permit will be incorporated into a
comprehensive permit issued by EPA under part 71.
2.6.2 Permit Changes
This subpart contains procedures for permit revisions due
to:
• Administrative amendments;
• Permit revisions; and
• Reopening for cause.
2.6.2.1 Administrative Amendments. An administrative
amendment is a permit revision that:
• Corrects typographical errors;
• Identifies minor administrative changes at the source
(such as a change in the name, address, or telephone
number of a person identified in the permit);
• Requires more frequent monitoring or reporting by the
permittee;
• Allows for certain changes in ownership or operational
control of the source; or
• Incorporates any other minor changes similar to those
above.
This last item allows EPA to process quickly other
insignificant changes not listed in the regulation without having
to go through the lengthy permit modification process.
To obtain an administrative permit amendment, a source
owner/operator must submit to EPA a proposed addendum to the
permit. The addendum must identify which of the existing permit
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conditions will be amended and what the amended conditions will
•be.
Although Administrative Amendments formally become effective
60 days after receipt of application by EPA unless EPA objects
within that time period, the early reductions source may
implement the changes in the request immediately. The EPA must
take final action on the administrative amendment within 60 days
from receipt of the request. Administrative amendment of a
permit is not subject to draft permit or public notice
requirements. If EPA denies the amendment, the source shall
comply (upon receiving such notice of denial) with the original
terms and conditions of the permit.
2.6.2.2 Permit Revisions. A permit revision is a change to
a specialty permit that does not qualify as an administrative
amendment. Unlike a part 70 permit program, this specialty
permit program does not make a distinction between minor and
significant permit revisions. The requirements for permit
revisions are the same as those for permit issuance, including
application submittal, public participation, and review by
affected States. The Administrator must take final action on a
request for permit modification within nine months of receiving a
complete application.
2.6.2.3 Permit Reopenings. A specialty permit may be
reopened and revised under certain conditions, which must be
specified in the permit itself. A permit may.be reopened and
revised if the Administrator determines that:
• The permit contains a mistake;
• Inaccurate statements were made in establishing the
alternative emissions limitation or other terms or
conditions of the permit; or
• The permit must be revised to ensure compliance with
the alternative emissions limitation.
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The Administrator will provide the source owner/operator
advance notice of at least 30 days before reopening a permit.
2.7 PUBLIC PARTICIPATION AND APPEAL (§71.27)
This section of the rule establishes specific procedures for
public participation related to preparation of draft permits,
initial permit issuance, and permit revisions. This section also
delineates administrative appeals procedures for final permit
decisions. Because this section contains much procedural detail
not germane to the primary focus of this document, it will not be
summarized comprehensively. Instead, the following generally
describes public participation in the permit issuance process.
The reader is referred to the rule for additional detail.
When a complete permit application is received, EPA must
decide whether to prepare a draft permit or issue a notice of
intent to deny the application. Along with the draft permit or
notice of intent to deny, EPA must prepare a statement of basis.
This would either describe the reasons for denying the
application or describe how and why the permit terms were
developed.
After the permit has been drafted or tentatively denied, EPA
must issue a public notice about its actions. Notice of draft
permits must provide at least 30 days for public comment, and the
Administrator will issue notice of a hearing at least 30 days
before the hearing is to be held. Public notice includes
notification of affected States. The definition of "affected
States" is taken directly from the part 70 rule, where affected
States are those whose air quality may be affected and are
contiguous to the source's State or located within 50 miles of
the source.
After the public comment period on a draft permit (or
denial) closes, EPA must issue a final permit decision and
response to comments.
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3.0 PERMIT APPLICATION GUIDANCE
This section provides a detailed discussion of each item
needed in the permit application. The items needed are based on
the regulatory requirements summarized in Section 2.4 and the
information needed by the permit writer to draft the permit (this
will be covered in section 5.0). For the applicant's ease of
understanding, specific examples are given wherever possible.
Supplementary information on applications is given in
appendices A through E.
3.1 COVER LETTER AND TABLE OF CONTENTS
3.1.1 Cover Letter
A complete cover letter for a specialty permit application
should include the items listed below so- that the application
reviewers will be able to quickly visualize the type of source
and the magnitude of emissions. The citations in brackets are
the associated requirements in the proposed specialty permit rule
(part 71 numbers) or the promulgated early reductions rule
(part 63 numbers).
A general description of the source or sources
[§71.24(e) (2)] ;
A statement explaining which definition of source is
appropriate for the early reductions source(s) [§63.73]
and a statement of the EPA approval status of the base
year emissions;
A table summarizing the base year emissions and the
requested alternative emission limitations for the
source, including both the total HAP emissions and the
total weighted HAP emissions adjusted for high-risk
pollutants, if appropriate [§63.74 (e).] ;
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• A statement certifying that the information provided
with this specialty permit application constitutes the
best available data for emissions from the source and,
based on information and belief formed after reasonable
inquiry, the statements and information in the document
are true, accurate, and complete [§71.24(f)];
• The name and phone number of the plant contact who
would be able to answer any technical questions
regarding the submittal [§71.24(e) (1)]; and
• The signature of a responsible official representing
the company that controls the contiguous area under
common control containing the source [§71.24(e)(2) and
§63.74].
A sample cover letter is provided in the example permit
application in appendix A.
3.1.2 Table of Contents
Including a table of contents in the specialty permit
application will help reviewers see the overall organization of
the application. The table of contents should identify each
major section of the submittal and give a corresponding page
number. Page numbering is critical for the reviewing agencies.
The application 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 any
deficiencies in the application and makes it easier for industry
to address agency comments.
3.2 COMPANY AND SOURCE IDENTIFICATION INFORMATION
3.2.1 Company Identification
The application should contain the company's name, address,
and the name and phone number of the plant contact.
3.2.2 Source Identification
Source identification information should include:
• A general source description;
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• Identification of emission points in the source,
including any changes from the base year to the post-
reduction year; and
• A site plan.
For applicants who submitted a base year emission demonstration
to EPA for review and approval prior to permit application
submittal, much of this information will already have been
submitted and is not required to be resubmitted. However, EPA
prefers that applicants copy and resubmit with the application
package applicable source identification information previously
submitted.
3.2.2.1 General Source Description. The applicant should
provide a narrative description of the source that includes
equipment and/or processes, the type(s) of manufacturing or
processing employed, and the HAP emissions generated by the
source. Examples of satisfactory general source descriptions
follow.
EXAMPLE 1: The proposed early reductions source is located
within a synthetic organic chemical manufacturing facility that
primarily produces aromatic derivative chemicals. The early
reductions 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. It also
includes the loading and unloading of xylene and styrene.
Hazardous air pollutants are emitted from the tanks during
filling and emptying of tanks and storage of the above chemicals.
Emissions also occur during the transfer of product chemicals to
tank cars. The source conforms to the definition found in
section 63.73(a)(4) of the early reductions regulation. The HAP
emissions from the set of emission points defined as the source
total more than 10 tons per year (tpy).
EXAMPLE 2: The proposed early reductions source is within a
resins manufacturing complex and is defined as all emission
points located in the epoxy resins manufacturing department.
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This includes tanks storing raw materials and intermediates,
•process vents, and the transfer equipment for loading and
unloading raw materials and finished goods. Hazardous air
pollutant emissions are generated during filling and emptying of
storage tanks, from "breathing" in the vapor space of storage
tanks, from the venting of noncondensable gases in distillation
columns, and during the filling and emptying of tank cars and
trucks. The source conforms to the definition found in
section 63.73(a)(3) of the early reductions regulation. This
source can be defined as a facility, structure, or installation
for the purpose of establishing standards under section 112(d) of
the Clean Air Act (CAA) .
3.2.2.2 Identification of Emission Points. The applicant
should include a list of all the emission points that includes a
brief descriptive title and a facility-assigned identification
code, the HAP's emitted and their corresponding CAS numbers, HAP
weighting factors, and State or local permit identification
numbers. • This information can be presented in a table format.
An example of such a table is given in appendix A. High-risk
HAP's and their weighting factors are listed in section 63.74 of
the early reductions regulation. The applicant should show any
changes to the emission points from the base year to the post-
reduction year (for example, some base-year emission points may
have been recycled or shut down and some emission points may have
been added because of equipment or process changes.
3.2.2.3 Site Plan. The site plan should show the boundary
of the contiguous facility and clearly identify the locations of
all emission points included in each source. The level of detail
for the site plan will depend 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.
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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).
3.3 EMISSIONS REDUCTION DEMONSTRATION PLAN
The specialty permit application's demonstration plan should
include a description of each control measure being used to
achieve post-reduction emissions levels. All control equipment
employed must be described, as well as any air pollution
minimization techniques such as process changes, raw materials
changes, or recycling, and work practices such as maintenance and
repair for equipment leaks.
The suggested format for submitting emissions reduction
information in the demonstration plan is a simple table
accompanied by summary text, which will give the reviewer an
overall picture of the applicant's planned emissions reduction
approach. (See example table 2-1 and text in appendix A.) The
table should show: (1) emission point description, (2) emission
point identification number, (3) emissions reduction measure
employed, and (4) expected emissions reduction efficiency. The
table should be accompanied by a brief text for each emission
point (or group of points) that describes the.emissions reduction
method employed (if any) and the method for demonstrating actual
post-reduction emissions. The emissions demonstration method
description should include source tests conducted (if any), post-
reduction year parameter monitoring being done, and calculations
to be performed to arrive at actual annual emissions.
All of the emission points presented should correspond to
the emission points listed in the earlier Source Identification
section of the application (see section 2.2.2.2). If there are
many emission points, applicants may choose to decrease the size
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of the table by grouping emission points either by type or by
common control device.
As a guide in tracking the emissions reduction measure for
each emission point, the applicant should assign an
identification number to each emissions reduction device unit.
That is, if several baghouses of similar design are used, each
baghouse should be identified separately. Preferably, the
identification number should be consistent with the
identification number assigned in any existing State or local air
permits.
The applicant should not confuse this information with the
actual emissions reduction demonstration. Guidance on the actual
demonstration is given in section 4.0 of this enabling document.
Inclusion of the information discussed above is recommended to
help reviewers picture the emissions reduction approach.
3.4 PROPOSED PERMIT TERMS AND CONDITIONS AND RATIONALE
The pool of early reductions permit applicants is expected
to include a variety of industry types. Further, different
applicants from the same industry are likely to delineate
different source configurations for inclusion in early reductions
permits. Thus, early reductions permit terms and conditions are
likely to vary widely from source to source.
The first step toward establishing permit terms and
conditions for a particular early reductions source is to have
the applicant propose them in the permit application. The terms
and conditions to be developed include (see §71.24(e) (6) (i)):
* An AEL for the whole source (and any other emission
limiting requirements, such as work practices,
necessary to assure compliance with the AEL);
• Emission point-specific terms and conditions, such as:
monitoring requirements,
recordkeeping requirements, and
emissions calculation procedures;
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• Operational flexibility provisions, if any; and
• Reporting requirements.
The following text presents guidance on applicants'
proposals for these types of conditions. Applicants are not
expected to propose precise wording for their permit terms and
conditions because the permitting authority will prepare the
final permit terms and conditions.
3.4.1 Alternative Emissions Limitations
Numerical Limit. Program participants must propose an AEL
as part of their permit application [§71.24(e) (3)]. The AEL is
the overall annual (calendar year) emissions cap the source must
meet to maintain the 90-percent (95-percent) reduction. The AEL
is always a mass-based standard and may be expressed in tons per
year (tpy) or pounds per year (Ib/yr) or their metric
equivalents. The AEL generally is calculated by multiplying
total base-year emissions by 10 percent (5 percent for
particulate HAP's).
A second AEL is required if the early reductions source
emits any high-risk pollutants. It is calculated by multiplying
the base-year emissions adjusted for high-risk pollutants by
either 10 percent or 5 percent, as appropriate [§63.74{e)(1)].
If both gaseous and particulate HAP's are emitted from the early
reductions source, then separate AEL's must be proposed for each
type [§63.74(e) (1) (v) ] .
In some cases, HAP emissions at the early reductions source
may have been reduced by more than 90 (95) percent, and the
owner/operator may wish to preserve the incremental reductions
above the required 90 (95) percent, perhaps for future offset
credits under title I of the CAA. In this case, the AEL could be
established at less than 10 (5) percent of base year emissions to
preserve the credits. Or, a source may already have a State
permit at a lower level and may want to accept the lower number
in their early reduction permit for consistency. (Note: A
general discussion of how reductions beyond the required 90 or
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95 percent may be used in offsets or netting transactions under
title I is contained in the preamble to the early reductions rule
(Federal Register. December 29, 1992, p. 61987).
Participants who have not had base-year emissions approved
prior to submitting their application should be aware that their
proposed AEL could be changed as a result of the EPA's technical
evaluation of the base-year emissions. For example, assume a
participant estimates (gaseous) base-year emissions to be 100 tpy
in the permit application. If, after EPA review, the approved
base-year emission level is 96 tpy, the AEL would be changed from
10 tpy to 9.6 tpy.
Frequency and Method of Calculation. The AEL is a yearly
(calendar year) limit on the early reductions source's HAP
emissions and, therefore, the source's actual HAP emissions must
be determined after the end of each year to determine compliance.
However, the permit will likely require HAP emissions to be
determined semiannually and reported, so that the permitting
authority will be able to track a source's progress toward
meeting the calendar-year limit. The applicant must propose HAP
emissions calculation methods for the purpose of determining AEL
compliance. These calculation procedures will become part of the
final permit terms. More detail on emissions calculations is
presented in the section describing emission point-specific terms
and conditions (section 3.4.3).
For applicants who have not made enforceable commitments,
the post-reduction year and post-reduction year emissions may not
be based on a calendar year [because the post-reduction year
begins on the proposal date of the applicable section 112(d)
standard, unless the source establishes an earlier post-reduction
year based on a calendar year]. In these instances, the final
permit will establish subsequent annual compliance checks of HAP
emissions based on the calendar year. The source owner/operator
would then be required to submit the first annual HAP emissions
data for the calendar year in which the post-reduction year
ended. As an example, the owner operator of a participating
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source subject to a section 112(d) standard proposed by EPA on
August 6, 1995 would have to provide to the permitting authority
documentation of HAP emissions from August 6, 1995 to August 5,
1996 (the post-reduction year) and, if a compliance extension is
granted, would be required in the permit to submit annual
compliance emission data for calendar year 1996 and subsequent
years until the extension expires. [Note: In the previous
example, the source owner/operator also would have the option to
establish the post-reduction year as July 1, 1995 to June 30,
1996 (which would show that the source achieved the 90/95 percent
reductions earlier than required by the Early Reductions
Program), thereby making the post-reduction year coincide with
calendar half-years and perhaps making emissions reporting
easier.]
Permits will not be issued until several months after the
post-reduction demonstration has been submitted. Nonetheless,
applicants should continue to monitor HAP emissions after the end
of the post-reduction year and before the permit is issued so
that a continuous record of emissions is available for semiannual
and annual reporting.
3.4.2 Emission Point-Specific Terms and Conditions
3.4.2.1 Monitoring. Generally, each emission point in the
early reductions source should be adequately and appropriately
monitored so that actual emissions can be determined on an
ongoing basis. For the more significant emitting units in the
early reductions source, monitoring may take the form of
continuous measurement of emissions or some process parameter(s)
directly related to emissions. For small emission points, the
monitoring may be less sophisticated; monitoring may be less
frequent and/or employ less costly monitoring devices or methods.
Precisely what constitutes a "small" emission point and what is
meant by "less sophisticated" monitoring cannot be explicitly
decided in this guidance, but will depend on the nature of the
early reductions source and its emissions and on the types of
available methods for tracking emissions performance. Final
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permit monitoring terms will reflect the joint input from the
•early reductions source, the permitting authority, and affected
States.
The permit application, therefore, must contain complete
descriptions of each proposed monitoring activity. Monitoring
methods may include:
• Testing at regular intervals;
• Direct emissions monitoring;
• Monitoring some process parameter directly related to
emissions;
• Recording specific work practices or maintenance
procedures that were performed; or
• Inspecting equipment.
Development of monitoring requirements. Information useful
for developing monitoring requirements for early reductions
sources may be found in EPA's proposed Enhanced Monitoring Rule
(Federal Register. October 22, 1993, p. 54648) or in the
provisions of other EPA standards already proposed or
promulgated, such as New Source Performance Standards (NSPS) or
National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the same or a similar industry. A complete description of
monitoring for emission points would include:
• A brief description of the type of monitoring proposed
(such as temperature measurement, pressure drop
measurement, direct emissions monitoring, etc.) and the
monitoring devices (e.g., thermocouple with digital
readout), test methods, or activities that will be used
to accomplish the monitoring. For monitoring other
than direct emissions monitoring, the description
should include the rationale for each monitoring
selection (e.g., if temperature measurement is selected
to monitor a specific piece of emitting equipment, how
does temperature relate to emissions?).
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The proposed frequency of monitoring for emitting units
in the early reductions source. This frequency should
be selected to support the periodic demonstration of
compliance with the AEL, and be conducted often enough
to provide a timely and accurate emission, estimate.
If different from the manufacturer's directions.
proposed requirements for the installation, use, and
maintenance of any monitoring equipment employed
(otherwise, the permit will require that the
manufacturer's directions be implemented).
Identification of appropriate parameters to be monitored
will be the responsibility of the applicant. In the case of
wastewater sources, identification of parameters is expected to
be particularly challenging because emissions from wastewater are
affected by the design and operation of plant-specific equipment
as well as by the HAP loading in the wastewater. Applicants need
to identify the parameters that most significantly affect
emissions and that can be easily monitored. It is also
particularly important for the applicant to provide supporting
rationale for why the selected parameter is a reasonable
indicator of actual emissions.
Monitoring strategy using source testing. In addition to
using source tests for post-reduction emissions demonstrations
(see section 3 for a more complete discussion of the post-
reduction demonstration), applicants may also use source tests in
their overall strategy to demonstrate compliance with the AEL.
For example, if one of the emissions reduction measures used in
early reductions is thermal incineration, a specialty permit
would probably require continuous monitoring of incinerator
firebox temperature. If performance of the incinerator was
demonstrated at only one temperature through a source test, that
temperature would be specified as the minimum operating
temperature in the permit or would be the lowest temperature at
which the demonstrated performance level could be assumed. It is
obvious that dropping below the designated temperature would not
necessarily result in uncontrolled emissions; however, emissions
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below the designated temperature could not be quantified
accurately. As a result, any periods in which the firebox
temperature falls below the level specified in the permit either
would violate a permit condition and/or cause emissions for that
period to be estimated at some default level that would be
considerably higher than that indicated by the source test data
at the designated temperature.
Conversely, the scope of the demonstration source test could
be expanded to develop a relationship between emissions and the
incineration temperature. Compliance provisions in the permit
could then be written in a way that allowed for emissions
determination at any incineration temperature. This flexibility
can be especially important where the emission point is only one
of multiple emission points that make up the defined source.
Higher emissions during periods of lower incineration
temperatures could be offset by greater reductions from other
emission points, or vice versa.
Compliance with enhanced monitoring requirements. The final
rule to implement the enhanced monitoring provision of the CAA
likely will not contain provisions specific to early reductions
sources. Monitoring requirements adequate and appropriate for
determining compliance with the AEL will be worked out during the
issuance process for each specialty permit. At the end of the
six-year extension period, early reductions sources must comply
with explicit enhanced monitoring requirements included in the
applicable MACT standards that become effective for those
sources.
Quality assurance/quality control (OA/OC) for monitoring
devices and procedures. Early reductions permits will contain
certain specifications related to QA/QC of monitoring
information, such as minimum monitor "on-line" time (minimum data
availability), measurement accuracy, etc. Specific requirements
will be worked out for each early reductions source individually
so that the characteristics of each source can be taken into
account.
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3.4.2.2 Recordkeeping. Along with a description of
monitoring methods, the application should include proposed
recordkeeping requirements. Records must be kept of the
monitoring performed on the emitting units; these records will
document the source's compliance status. Recordkeeping
requirements proposed for the early reductions source should
include:
Records of required monitoring performed to demonstrate
compliance with the AEL (the date, place, and time of
monitoring);
The results of the monitoring;
The occurrence and duration of monitor downtime (for
calibration, maintenance, or due to a malfunction);
A log of calibrations and maintenance performed on
monitoring systems;
The occurrence and duration of any other process or
control equipment malfunctions; and
If source testing was performed, the date, time, and
place of the test, as well as the dates analyses were
performed, the company performing the analyses, the
test results, the process operating conditions at the
time of the test, and any problems encountered during
the test.
Under §71.25(a)(4)(ii), records of all monitoring data and
supporting information must be retained for a period of at least
five years (this length of time is consistent with the rule
promulgated under part 70 for State title V permitting programs).
Supporting information includes all calibration and maintenance
records, all original strip-chart recordings for continuous
monitoring instrumentation, and copies of all reports required by
the permit.
Early reductions permits will require the first semiannual
emissions report submitted to include actual HAP emissions data
for the interval from the end of the post-reduction year to the
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end of the first semiannual reporting period. This will ensure
continuity of emissions reporting; without this requirement no
emissions information would have to be submitted for the period
beginning at the close of the post-reduction year and ending with
permit issuance.
3.4.2.3 Emissions Calculation Procedures. The source
owner/operator will be required to demonstrate compliance with
the yearly AEL and will also have to determine emissions
semiannually to keep track of progress toward meeting the AEL.
The owner/operator will therefore need to translate the
information recorded from the periodic monitoring or other
records related to emissions into a quantification of actual HAP
emissions. The applicant must describe the calculation procedure
to be used to determine actual emissions for each emission unit.
Of course, if emissions for a unit are directly monitored, no
calculations or procedures are needed. However, for all other
cases, the procedure or calculations to arrive at actual
emissions must be described, and the technical basis for the
procedure or calculation explained. Appendix A contains examples
of calculation procedures for determining actual emissions.
Because the AEL is an annual limit on actual emissions,
there should be no periods of unquantified emissions. Therefore,
the calculation procedures should include an approach for
determining (or estimating) emissions when a monitoring device is
inoperable or a monitored parameter exceeds the range of values
that has been directly correlated with HAP emissions. For
example, suppose an applicant has demonstrated through source
testing that an incinerator will have a HAP destruction
efficiency of 99 percent for incinerator firebox temperatures of
at least 1600°F; however, no efficiencies were established below
1600°F. In the event that the incinerator firebox temperature
falls somewhat below 1600°F, a way of estimating emissions for
that period must be established. Although the efficiency
certainly would not be zero, a default conservative efficiency
would need to be assumed to provide an emissions estimate. The
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manufacturer of the unit may have information that could be used
to estimate efficiency under these conditions. If no information
is available on which to base an estimate, a source test could be
performed at the lower temperature.
3.4.3 Operational Flexibility Provisions
The permit application should identify any alternative
operating scenarios expected to occur during the life of the
permit that would affect emissions. Alternative scenarios can
involve the use of different solvents or raw materials, or
production of different products altogether. Along with the
description of the alternative scenarios, the applicant should
describe how HAP emissions will be affected under each scenario
and how the AEL will still be met. The monitoring, recordkeeping
and reporting provisions of the permit will apply when the source
is operating under the alternative scenario unless separate terms
are proposed and issued specifically for operation under the
alternative scenario. The purpose of defining alternative
scenarios is to avoid the permit modification process for every
process variation, especially if the alternative scenario is
anticipated and permit conditions can be set ahead of time.
3.4.4 Reporting
Under §7l.24(e)(6)(i), an applicant also must propose
reporting requirements. The reporting section of a specialty
permit application should include:
• A statement indicating the frequency of reporting,
along with the date that the reports will be submitted
to the permitting authority; and
• Statements describing information that will be
contained in each report.
The EPA may issue guidance on a suggested report format in
the future, with the objective of setting up easy-to-follow
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semiannual emissions data reporting. An advance example format
•for emissions reporting is provided in figure 3-1.
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EARLY REDUCTIONS
SEMIANNUAL EMISSIONS REPORT FOR
XYZ CHEMICAL, RALEIGH, NC
Date:
Semiannual Period:
Total Emissions For This Period:
SEMIANNUAL
PERIOD
TOTAL
HAP
EMISSIONS
(tons)
WEIGHTED HAP
EMISSIONS
(tons)
Alternative Emissions Limitations:
Detailed Description of Emissions for this Semiannual Period
Emission Point
IDs
TOTAL
HAP Emissions
(tons)
Weighted HAP
Emissions
(tons)
Figure 3-1. Example Report Format
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4.0 EMISSIONS REDUCTION DEMONSTRATION
The emissions reduction demonstration, when complete, will
document actual base-year emissions and actual post-reduction
emissions (also weighted base-year and post-reduction emissions
if any high-risk pollutants are emitted from the early reductions
source). As discussed in section 3, the permit applicant must
include documentation of base-year emissions with the initial
specialty permit application (unless the base-year emissions were
submitted to the permitting authority earlier). In most cases,
the applicant will provide documentation of actual post-reduction
emissions as a separate submittal after the end of the post-
reduction year. (In instances where an "earlier" post-reduction
year has been established, the applicant may have to file the
post-reduction emission with the permit application. See
section 2.4.2 for additional detail). However, if any source
tests were performed to support emissions reduction, the
applicant must provide test results by the permit application
deadline (the results normally would be submitted in the same
package with the permit application).
This section provides specific guidance for documenting
base-year and post-reduction emissions. The example permit
application in appendix A provides example base-year emissions
documentation and appendix H presents an example emissions
reduction demonstration.
4.1 BASE-YEAR EMISSIONS DOCUMENTATION
Applicants are expected to submit documentation of base-year
emissions prior to or with the specialty permit application. For
an enforceable commitment example and guidance on documenting
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base-year emissions, applicants should refer to the early
reductions rule and/or the Enabling Document for Regulations
Governing Compliance Extensions for Early Reductions of Hazardous
Air Pollutants (EPA-450/3-91-013).
Applicants who submitted the base-year emissions
documentation separately do not have to submit the documentation
again. Instead, those applicants need only provide a summary of
base-year emissions with the specialty permit application. The
summary will facilitate review of the application without the
original base-year emissions submittal. Applicants are reminded
that the permit application may be reviewed by organizations
other than the permitting authority e.g., a public reviewer.
The suggested summary format is a table that summarizes the
names of the emitted HAP's and the base-year HAP emissions (total
and weighted) for each emission point (see example table 1-1 in
Appendix A) .
4.2 POST-REDUCTION EMISSIONS DOCUMENTATION
The-rules for documenting post-reduction emissions are the
same as those for documenting base-year emissions. Section 63.74
of the early reductions rule contains the documentation
requirements, and they are explained in more detail in the
enabling document. Briefly, the applicant must demonstrate post-
reduction emissions using the best available data accounting for
actual emissions. The best available data are presumed to
consist of documented results from source tests, unless one of
the following applies:
• No source test method exists for the emission point(s);
• It is not technically or economically feasible to
perform source tests;
• Another method of deriving emissions will produce
emissions estimates with accuracy comparable to source
tests; or
• Emissions from a point or set of points is so small
that estimating emissions by means other than source
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tests will not significantly affect the accuracy of
total emissions established for the source.
Because actual HAP emissions for the entire post-reduction
year are to be demonstrated, the results from source tests or
other measures of short-term emissions must be combined with
monitoring data or other emissions-related inputs for the post-
reduction year to produce an estimate of actual, post-reduction,
annual HAP emissions. Thus, short-term tests by themselves are
not sufficient to demonstrate actual emissions over the post-
reduction year. This combining of short-term test results or
other short-term emissions indicators with post-reduction year
monitoring data or other emissions-related inputs is what
constitutes the post-reduction emissions demonstration (due after
the end of the post-reduction year).
4.2.1 Short-Term Test Results
If any source tests have been performed to support post-
reduction emissions, the results should accompany the specialty
permit application (or must be sent by the permit application
deadline). The test results summary should provide the following
information for each emissions unit tested [§63.74(d)(3)(i)]:
• Identification number and descriptive title;
• Test method or protocol used;
• Results summary; and
• Discussion of any problems encountered during testing
and a statement on the validity of method for the type
of emissions tested.
Selection of acceptable test methods. Acceptable test
methods must be used where source tests are used to demonstrate
post-emissions reductions. An acceptable method would be any one
of the following:
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• An EPA method (i.e., a method with an EPA number)
already validated for the applicant's source type and
pollutant(s). EPA reference or test methods typically
include a scope that defines the source types or
pollutants to which the method applies.
• An EPA method validated by the applicant for the
applicant's source type and pollutant(s), according to
the requirements specified in EPA Method 301, Field
Validation of Pollutant Measurement Methods from
Various Waste Media.
• Any other method validated for the source type and
pollutant using EPA Method 301.
Section 12.1.1 of EPA Method 301 states that if a test
method has been validated previously at a "similar source," the
procedures in Method 301 can be waived as long as it can be
adequately demonstrated that the sources are "similar." To
receive a waiver, the source owner/operator must provide
supportive documentation to the EPA Emissions, Monitoring and
Analysis Division, including a description of the source test
method, a discussion of why the requestor believes that the
source is similar to the source for which the method was
validated, and a statement of accuracy and precision of the
method. A list of validated methods is presented in appendix B.
Information on the selection of acceptable test methods and
the integration of performance test methods into the proposed
compliance plan was given in section 3.4.3.1. Additional
information on test methods is given in appendices B, C, and D.
4.2.2 Use of Different Test Methods to Establish Base-Year and
Post-Reduction Emissions
In some cases, applicants may use a different test method to
measure post-emissions reductions than was used to measure base-
year emissions because a better method has become available in
the interim. The applicant may feel that because the method used
for base-year emissions measurement is not as accurate, the base-
year results should be adjusted.
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Adjustment can be made by performing the base-year method
simultaneously with the post-emissions reduction method when
post-emissions reductions are measured. The applicant should
then develop a correlation between the results yielded by the two
methods and apply this correlation to adjust the base-year
emissions estimate(s).
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5.0 PERMIT DEVELOPMENT
The purpose of this section is to provide guidance for the
EPA, State, or local agency permit writer on:
• Reviewing a permit application for completeness;
• Synthesizing a draft permit from the information in the
application;
• Identifying issues that need discussion with the
applicant; and
• Revising the draft permit based on comments from the
. permittee, other permitting authority reviewers, and
affected States.
These topics are discussed in the following sections. Where
possible, examples from actual permit applications reviewed and
permits developed by EPA are provided to illustrate the points
discussed.
Permit applicants may also find it valuable to read this
section for additional insight into developing a complete
application.
5.1 PERMIT APPLICATION COMPLETENESS REVIEW
Within 45 days of receiving a permit application, the
permitting authority must determine whether an application is
complete or incomplete. If the application is incomplete, the
permitting authority must notify the applicant and request the
additional information needed. If permitting authority does not
notify the applicant within 45 days, the application is
considered complete by default. This section provides guidance
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on reviewing an application for completeness and notifying an
applicant of any deficiencies.
The purpose of a permit application review is to:
• Assess whether the regulatory requirements for a
complete permit application have been met; and
• Identify any other deficiencies in the application that
prevent the permit writer from proceeding with permit
development.
Because the completeness review is a preliminary review, it is
likely that not all deficiencies will be identified at this
stage. As the permit writer begins to check the application in a
detailed manner and develops the applicant's proposed permit
conditions into an actual permit format, the need for additional
information may become apparent.
An application should be considered complete as long as it
is "substantially" complete; that is, the application constitutes
a good-faith effort to provide all of the information needed.
Because permit writers can request additional information at any
time, an application should not be considered incomplete unless
it is missing important information. Such omissions can occur in
an applicant's effort to submit an application by a certain
deadline.
If the application is considered complete, the permit writer
should send the applicant a letter to that effect. The letter
should also make it clear that the determination of completeness
does not mean that no additional information will be requested as
permit development proceeds.
If the application is not complete, the permit writer must
send the applicant a letter saying so, and itemizing the
information needed in as much detail as possible. It is also
recommended that the permit writer call the source's technical
contact to discuss the items needed, if they are very extensive
or complex.
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When an application has been declared complete, the
permitting authority begins drafting the permit. If additional
information is requested by the permitting authority during
processing, the applicant must provide the additional information
by the date specified in the request. The date specified can be
negotiated between the permitting authority and the applicant;
however, the permitting authority must agree to this date. If
the applicant does not provide the requested information by the
specified date, the permit might not be issued by the normal
deadline. Where all necessary information is received in a
timely manner, the permitting authority must take final action on
the specialty permit application within 12 months of receiving
the complete application.
During either the preliminary or the more detailed
subsequent permit application review, three types of deficiencies
may be spotted:
• • Items that are required but are not provided;
• Erroneous or inconsistent information; and
• Lack of detail for items that are provided.
Where such deficiencies exist, the applicant will have to provide
information to supplement the original application before permit
drafting can advance to the public review stage.
Items clearly needed for a complete application are listed
in the permit reviewer's checklist in appendix F. The items in
the checklist are based either on regulatory requirements, such
as those given in 40 CFR 71.24 and 40 CFR 63.74, or on types of
information needed by the permitting agency to begin developing
permit conditions. Without these items, the permit writer cannot
draft at least some of the relevant permit conditions and the
application does not fulfill the requirements of 40 CFR 71.24{e).
Erroneous or inconsistent information could result, for
example, when an applicant uses improper or conflicting
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assumptions in calculating base-year and post-reduction
•emissions. In one case, an applicant calculated base-year
emissions for a "constant-level" storage tank by assuming that
the level of change in the tank was five percent of the total
yearly throughput. Yet for calculating post-reduction emissions,
the applicant proposed using two percent of the total yearly
throughput as the level of change in the tank. No rationale was
provided for the inconsistency.
An example of lack of detail would be an application that
does not provide enough supporting information. One applicant
achieved some early reductions by routing a process vent to a
thermal oxidizer. The applicant proposed to monitor achievement
of the early reductions claimed by monitoring the firebox
temperature of the thermal oxidizer with a thermocouple.
However, the applicant did not specify the type, accuracy, and
operating range of the thermocouple. The permit writer was
unable to verify whether the thermocouple proposed was adequate.
5.2 DRAFTING THE PERMIT
5.2.1 Synthesizing Permit Conditions
The permit writer should begin synthesizing the permit
conditions based on the permit conditions proposed by the
applicant and information provided in the application. Where the
information provided in the application is questionable,
inadequate, or inappropriate, the permit writer should make
comments to that effect in the draft permit. .The permit writer
may also note what he or she believes would be adequate or
appropriate. The initial draft of the permit containing edits,
comments, and questions on the terms and conditions proposed in
the permit application would then be sent to the permittee and
other reviewers (e.g., State and EPA staff). After discussion
with the permittee and reviewers, a second draft of the permit
would be prepared. The process would be repeated until a formal
draft, ready for public comment, had been developed.
Appendix G shows an example early reductions specialty
permit. The format of this example permit has been carefully
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developed and reviewed, and is being used for the first group of
permits to be issued by EPA to early reductions sources. Its
format is similar to other model title V permits and it is
recommended that permit writers use this format.
The permit is organized into three major parts, as shown in
Figure 5-1. This section discusses a procedure for taking the
information in the permit application and drafting each of the
three parts.
5.2.1.1 Section A; Source Identification. First, the
permit writer should inventory all the emission units and
determine the post-reduction fate of each unit, e.g.:
• Routed to a control device;
• Routed to another vent;
• Dismantled;
• Eliminated through a process change; or
• ' Same as base year.
In Section A, "Source Identification," the permit writer should
include a table showing all emission units (including dismantled
units) in the early reductions source and their identification
numbers.
The primary purpose of this section is to define the early
reductions source in detail sufficient to allow an inspector to
identify early reductions emission units during a site
inspection. To do this, the inspector must be able to locate all
emission units and control devices. Usually, the description and
identification number of an emission unit coupled with its
location on a plot plan of the source would be sufficient. If
not, the permit might require the source owner/operator to
provide positive identification on the emission units with, for
example, tags, labels, or other markings.
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SECTION A: SOURCE IDENTIFICATION
SECTION B: SPECIFIC CONDITIONS
1. Alternative Emissions Limitations
2 . Other Specific Conditions
3. Monitoring Requirements
4. Recordkeeping Requirements
5. Reporting Requirements
6. Emissions Calculation Procedures
7. Compliance Certification
8 . Alternative Operating Scenarios
9. Permit Shield
SECTION C: GENERAL CONDITIONS
1. Annual Fee Payment
2. Permit Renewal and Expiration
3. Transfer of Ownership of Operation
4. • Property Rights
5. Operation and Maintenance Requirements
6. General Provisions Requirements
7 Submissions
8. Inspection and Entry
9. Compliance
10. Duty to Provide Information
11. Excess Emissions Due to an Emergency
12. Reopening for Cause
13. Severability Clause
14. Emissions Reductions From Equipment Shutdown or
Reduced Operation
15. Permit Deviations
16. Permit Revisions
Figure 5 -1.
Organization of an Early Reductions
Specialty Permit
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The permit should state that it is based on the information
contained in the original permit application and any additional
information received. The permit should state, for example, that
it is "based on information contained in the application dated
April 29, 1994, as amended on June 5, 1994 and July 14, 1994."
The date that a complete application was received from the
applicant should be referenced on the permit's cover page.
The permit writer should attach to the draft permit a copy
of the source diagram (plot plan) supplied in the application
that shows all of the emission units in the early reductions
source.
5.2.1.2 Section B; Specific Conditions.
1. Alternative Emission Limitations -- The permit writer
should check the AEL's for total and weighted HAP's to make sure
they represent 90 percent gaseous and 95 percent particulate HAP
reductions from base-year emissions. If correct, these AEL
values should be written into the permit.
Next, the permit writer should determine the AEL expiration
date, which is exactly six years after the compliance date of the
MACT standard that would otherwise be applicable to the early
reductions source. The AEL expiration date, the name of the
applicable MACT standard, and the compliance date of the
applicable MACT standard should all be cited in section B.I. If
this date is not yet known, the permit should state that the AEL
shall expire six years after the compliance date of the last
applicable MACT standard.
When more than one MACT standard applies to an early
reductions source, the AEL will not expire until six years after
the compliance date for the last applicable MACT standard. For
example, assume an early reductions source has emissions units 1,
2, and 3 that will be subject to MACT standard X, which has a
compliance date of June 20, 1996. The source also has emission
units 4 and 5 that will be affected by MACT standard Y, which has
a compliance date of January 1, 1999. The AEL would expire on
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January 1, 2005 (six years after MACT standard Y's compliance
•date).
However, after June 20, 2002 (six years after MACT
standard X's compliance date), emission units 1, 2, and 3 will
become subject to MACT standard X. Thus, between June 20, 2002
and January 1, 2005, the source must comply with MACT standard X
for emission units 1, 2, and 3 yet still include HAP emissions
from units 1, 2, and 3 in determining compliance with the AEL.
Footnote 1 in the example permit in appendix G contains wording
to this effect.
The permit should state that compliance with the AEL's shall
be determined on a calendar-year basis. The permit should
require that HAP emissions from the early reductions source be
computed semiannually, and should reference the calculation
procedures section.
2. Other Specific Conditions -- This section provides a
place to put conditions on the post-reduction status of the
emission-units. This section should specify which emission units
shall have identification tags, which are to be routed to control
devices, and which have been shut down, dismantled, or eliminated
through process changes. Note: shut down units must remain so
(except that restarting is permitted provided that emissions from
restarted units are included in post-reduction emissions
calculations for the early reductions source).
The emission units and any control devices should be listed
by identification number. The permit in appendix G provides an
example of this for several vent streams and a wastewater stream
that are routed to control devices. The purpose of these
conditions is to make sure that the devices used by the source to
achieve the early reductions continue to be used. If a source
owner/operator wants the flexibility to use other devices, this
can be addressed under section B.7 of the permit, "Alternative
Operating Scenarios."
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For those emission units that are dismantled or shut down as
part of the early reductions, this section should include wording
to the following effect:
Emission units . , and shall be dismantled (or
shut down) and shall not be in HAP service. If the
dismantled (shut down) process equipment is restarted or
replaced anywhere within the plant site, any HAP emissions
from the restarted or replacement equipment shall be counted
in the post-reduction emissions from the source.
This prohibits sources from achieving early reductions by
shutting down units within the early reductions source, moving
them outside the early reductions source to another location
within the plant site or building similar new HAP units at the
site, and operating them.
Any other specific conditions that do not belong elsewhere
in the permit also can be stated here.
3. Monitoring -- The primary objective of monitoring for
the early reductions programs is to periodically gather the
information needed to estimate HAP emissions within that period.
To this end, the permit writer must link the emissions
calculation procedures to the monitoring and recordkeeping
requirements by making sure that all inputs to the emissions
calculations are specified in the monitoring and recordkeeping
provisions. Many of these inputs will come from monitored and
recorded parameters; others, such as physical properties of
compounds, need only be recorded.
To make sure the monitoring data is accurate, the permit
writer should include permit conditions to the effect that all
monitoring equipment must be installed, calibrated and maintained
according to manufacturer's specifications. To make sure the
data is representative, the permit should specify that monitoring
equipment be installed to provide a representative measure of the
monitoring parameter.
To develop monitoring conditions for individual units, the
permit writer should first group similar emission units with
identical monitoring and recordkeeping requirements. For
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example, the applicant may have proposed that all tanks (or at
least some tanks) be monitored using the same parameter (e.g.,
throughput) in the same manner and at the same frequency. There
is no need to repetitively list the same requirements
individually in such cases.
The next step is to draft a table of monitoring and
recordkeeping requirements for the groups of emission units. For
each emission unit, or group of emission units, the table should
show the:
• Identification number(s);
• Monitoring requirements in terms of the following
items, as appropriate:
parameters monitored (e.g. number of barges
loaded, combustion chamber temperature, HAP
concentration),
device or instrument for monitoring each
parameter, or source of information if not a
device (e.g., shipping records, thermocouple),
location of device or instrument (e.g. thermowell
mounted in the combustion chamber wall below main
gas burner),
EPA method or other method used (e.g., EPA
Method 624),
frequency (e.g., continuous, daily, during
material shipment); and
• Recordkeeping requirements that ensure that records of
all parameters monitored and all inputs to the
emissions calculations are kept.
As mentioned above, the primary purpose of monitoring for
early reductions is to adequately track actual annual emissions.
This is in contrast to monitoring requirements for some MACT and
NSPS regulations, which are meant to warn when a short term
emission limit is violated. Therefore, adequate monitoring
provisions for early reductions can be different from MACT or
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NSPS monitoring provisions. These standards can, however,
provide a frame of reference for monitoring of similar sources
and control devices. Because less significant emission sources
make up a proportionally smaller part of the AEL, these sources
warrant less rigorous monitoring requirements than do the
significant sources.
An inspector performing an on-site review must be able to
conclusively identify each monitoring device listed in the
permit. To facilitate this, the permit should include, wherever
appropriate, the monitoring device type, special features, and
location. For example, one source achieved some of its early
reductions by installing a scrubber. The applicant proposed that
emissions from the scrubber be calculated based on scrubbant
water pressure as an indication of whether the scrubber was
achieving the targeted level of control. The application stated
that the pressure would be monitored by field inspection.
However, the applicant did not provide any information on the
type of monitoring device. Unless the permit writer pursued this
issue with the applicant and obtained device specifications, an
inspector at the site would not be able to verify that the
correct monitoring device was being used.
Where the source owner/operator proposes periodic sampling
of emission units, the permit writer should check the proposed
test methods to see if they are EPA methods. If they are not,
does the source .plan to validate the method through EPA
Method 301 validation procedures? For minor units, other non-EPA
methods may be sufficient (even if not validated). The permit
writer should obtain expert input on whether the proposed methods
are adequate.
To make sure HAP emissions are calculated as adequately as;
possible, calculation procedures must factor in different
parameters that affect emissions. Further, monitoring
requirements must be designed to ascertain the current status of
the different parameters and record the data for subsequent
emission calculations.
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For example, for storage tanks, the primary monitoring
parameter for estimating emissions from internal floating-roof
storage tanks may be tank throughput. The integrity of the tank
seals also affects emissions, however. Therefore, periodic
inspections of tank seal for gaps should also be required by the
permit.
The permit should also specify how discovery of a seal gap
shall affect the emissions calculations. In the case of an
internal floating-roof tank, the permit writer might specify
that:
• The internal floating roof and secondary rim seal be
inspected annually;
• The primary rim seal, gaskets, and slotted membranes be
inspected whenever the tank is emptied for cleaning,
but at least once during the term of this permit;
• If gaps are found, specific values that reflect this be
used for the rim seal loss factor in the emissions
calculation procedure for that quarter; and
• This calculation procedure shall be used for all
subsequent quarters until the gap is fixed.
The Appendix G permit provides example language for this
situation.
To ensure that enough monitoring data is gathered to
adequately track annual emissions, the permit.should specify that
valid monitoring data covering at least 75 percent of the total
operating time of the emissions units must be gathered. Also,
all periods of equipment of malfunction must be monitored so that
emissions during such periods can be included in the annual
emissions total.
4. Recordkeeping and Reporting Requirements -- For
recordkeeping, this section should specify that copies of all
reports must be kept at least five years. The most recent two
years must be kept onsite or must be accessible by computer; the
remaining three years of records may be kept offsite.
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The permit should also require the following to be kept:
• Records of monitoring parameters specified in the
permit;
• Supporting calculations used to determine HAP
emissions;
• Records of each startup, shutdown and malfunction in
the early reductions source;
• Records of each malfunction of an air pollution control
device or a continuous monitoring system;
• Records showing that the procedures in the startup,
shutdown, and malfunction plan were followed, and
documentation of any deviations from the plan, for all
startup, shutdown, and malfunction incidents; and
• For continuous monitoring systems, records showing that
the manufacturer's instructions were followed for
installation, calibration, and maintenance.
Permit recordkeeping provisions must also require the
following source tests records be kept for at least five years:
• Date, place, and time of sampling or measurement;
• Date any analyses were performed;
• Analytical techniques/methods used;
• Operating conditions at the time of sampling or
measurement; and
• Results.
For reporting, this section should specify the frequency of
reporting and provide the format for reporting. The frequency of
reporting should be semiannually unless otherwise necessary. The
reporting format provided in the permit should follow the example
given in Appendix D.
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This section should specify that:
• Semiannual reports shall be submitted by the last day
of the month following the end of the calendar half-
year (i.e., January 31 or July 31, as appropriate);
• The first report submitted after permit issuance should
cover the calendar half-year in which the permit is
issued and should cover emissions since the end of the
post-reduction year; and
• The first report should include supporting calculations
for all reported emissions, using the calculation
procedures in the permit (subsequent reports need not
include all supporting calculations, unless requested
by the permitting authority).
Because of the year-long post-reduction demonstration
period, the source will have achieved its early reductions more
than a year prior to permit issuance. In addition, the source
will have been monitoring the parameters needed for input to the
emission calculations more than a year prior to permit issuance
(because the applicant proposes the emissions calculation
methodology and monitoring parameters).
Thus, the source will have all of the information needed to
provide emissions data for the year to date at the time the first
semiannual report is required to be submitted by the permit.
Emissions calculations need to be included with the first
semiannual report so the permit agency can make sure the
permittee is following the permit's calculation procedures
properly. The permit should state that the calculations are not
required to be submitted with subsequent semiannual reports.
5. Emissions Calculation Procedures -- First, the permit
writer should check the emissions calculation procedures proposed
by the applicant to make sure that:
They are consistent with base-year emissions
calculations (where parameters such as vapor pressure
or the control status of the emission unit are
unchanged from the base year);
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• They are consistent with any EPA-accepted calculation
procedures used, or appropriate documentation is
provided for methods that are not EPA-approved;
• They are consistent with the proposed monitoring;
• They are correct; and
• All calculation procedures can be replicated.
Examples of EPA-accepted procedures for selected emissions
types can be found in the document "Procedures for Estimating
Emissions From Early Reductions Compliance Extensions"
(EA-450/3-91-012a, February 1992). If a non-EPA procedure is
used by the applicant, the permit writer should verify that all
necessary supporting documentation was provided, including how
the procedure was derived and rationales for any assumptions
made.
Next, the permit writer should verify that all inputs to the
calculations, other than assumptions or constants, are included
in the monitoring and recordkeeping requirements.
Finally, the permit writer should draft the calculation
procedures, including those for total HAP emissions, total
weighted HAP emissions, and each individual emission unit.
The relevant HAP weighting factors should be listed in the
permit, along with the reference from which they were obtained
(i.e., 40 CFR 63.74). As with emission sources with the same
monitoring requirements, sources with the same calculation
procedures should be grouped together. (Because monitoring and
calculation procedures are closely linked, these groupings will
often be the same.)
Every step in the calculation procedures should be clearly
specified so there is no ambiguity about which values are to be
input. Steps for calculating averages, summing individual items
to obtain a total, and otlier items that seem obvious should be
included.
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The permit should include calculation procedures for every
•unit that emits to the atmosphere. For emission units that are
routed to a control device, the permit should list those emission
units and state that they shall be routed to that specific
control device. Then the procedure for calculating emissions
from the control device should be specified.
6. Compliance Certification -- The permit must require the
permittee to submit an annual compliance certification signed by
a responsible official, as defined in 40 CFR 71.22. The permit
must specify that the following items be included in the
certification:
Identification of each permit term or condition that is
the basis of the certification; and
The compliance status for the 12 month period,
including whether compliance was continuous or
intermittent.
7. 'Alternative Operating Scenarios --If the applicant
proposes alternative operating scenarios, the permit writer
should verify that these can be accommodated under the proposed
monitoring, recordkeeping, and emissions calculation provisions.
If not, additional monitoring, recordkeeping, and emissions
calculation provisions necessary to provide emissions estimates
under the alternative scenario(s) must be generated. The permit
also must require the source to contemporaneously record in a log
the scenario under which it is operating.
Alternative operating scenario suggestions are important for
facilities handling a wide array of chemicals. If no alternative
operating scenarios are identified in the permit application,
frequent revisions to the permit could be required to incorporate
changes at the source.
It may also be beneficial to review, via a conference call,
some possible scenarios that may be of interest to the applicant.
For example, the permittee may want the flexibility to change the
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material stored in a given tank, the color of a storage tank, or
the type of loading from truck loading to rail car loading
without requesting a permit change. The applicant may not
realize that the detailed monitoring, recordkeeping, and
emissions calculations procedures proposed for the permit (i.e.,
tank color may be an input to the storage tank emissions
calculation procedure) will preclude this flexibility unless
alternative operating scenarios are anticipated and included in
the permit.
8. Permit Shield -- This section is fairly standard. The
language in appendix G can be used as a template. The permit
shield may extend to all terms and conditions under the
alternative operating scenarios (if any).
5.2.1.3 Section C; General Conditions. The general
conditions stem from the early reductions permit rule, and are
the same for all sources. The language in the appendix G example
permit should be used for all specialty permits. The
requirements of 40 CFR part 63, subpart A, "General Provisions",
are incorporated into the example permit by reference in
section C(6), and in the recordkeeping and reporting requirements
of section B.
The General Conditions section contains:
• Standard language on annual fee payment;
• Permit renewal and expiration;
• Transfer of ownership or operation;
• Property rights;
• Operation and maintenance requirements;
• General provisions requirements;
• Submissions of reports and notifications;
• Inspection and entry;
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• Compliance;
• Duty to provide information;
• Excess emissions due to an emergency;
• Reopening for cause;
• Severability;
• Emissions reductions from equipment shutdown or reduced
operation;
• Permit deviations; and
• Permit revisions.
5.2.2 Effective Permit Writing
Many concepts of effective permit writing are covered in the
previous section on synthesizing permit conditions. Several
general tips are discussed here.
Permit language should always be simple, clear, objective,
and specific. The permit should be a stand-alone document in
that all items needed to verify compliance should be listed in
the permit. An inspector visiting the early reductions source
should not need the permit application to find out how to
calculate emissions for an emission unit, or to find out which
emission units are routed to a certain control device.
Permit writers should avoid vague, negative, and imprecise
language. The following table shows a comparison of language to
be used versus language to be avoided:
Avoid this:
"should," "would"
"...as soon as possible..."
11... shall be used as
appropriate..."
"This requirement shall not
apply to X."
11.. .periodically.. . "
Use this:
"shall," "will"
"...within 10 days of..."
"... shall be used in the
following -conditions..."
"This requirement applies to
A, B, and C."
"...weekly..."
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5.3 REVISING THE INITIAL DRAFT OF THE PERMIT
Comments on the first version of the draft permit should be
solicited from:
• EPA Regional Office staff (e.g., the early reductions
contact);
• Early reductions staff at OAQPS;
• Other EPA staff, as appropriate;
• Affected States and Indian tribes;
• The applicant; and
• Other experts, particularly where expert knowledge is
needed (for example, on control devices, EPA methods).
Affected States are those within 50 miles of the source or those
whose air quality may be affected and that are contiguous to the
State in which the source is located. The permit writer should
provide these reviewers a copy of the statement of basis for the
permit.
As mentioned earlier, the initial draft permit may contain
the permit writer's comments and questions and/or the
inadequacies or inappropriate permit conditions proposed by the
applicant. After discussing these issues or receiving written
responses on them from the reviewers, the permit writer should
revise the permit. The comment and revision cycle should be
repeated until all issues have been resolved and a formal draft
permit is ready for public comment.
At this point, a notice that the draft permit is available
for public comment must be published in a newspaper local to the
source. The public comment period must be at least 30 days. If
a hearing on the permit is requested during the public comment
period, the permitting agency must publish a notice (in a local
newspaper) of the hearing at least 30 days in advance. After the
public comment period (including any hearing requested), the
permitting agency must respond to any comments and decide whether
5-19
-------
the permit should be issued as proposed, revised, or denied.
the permit is revised significantly, it should be re-noticed
before it is issued so that the public again has a chance to
comment.
If
5-20
-------
APPENDIX A
EXAMPLE TITLE V SPECIALTY PERMIT
APPLICATION FOR AN
EARLY REDUCTIONS SOURCE
-------
-------
April 1, 1994
Director
Air, Pesticides, and Toxics Management Division
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Re: Title V Specialty Permit Application for Source A
at the XYZ Chemical Company, Raleigh, NC
Dear Sir/Madam:
In accordance with Title 40 Part 71 of the Code of Federal
Regulations, the XYZ Chemical Company is applying for a Title V
Specialty Permit under the Early Reductions Program and
requesting a 6-year compliance extension for otherwise applicable
standards issued under Section 112(d) of the Clean Air Act. The
enclosed permit application and compliance extension request is
for a group of individual emission points located within XYZ's
synthetic organic chemical manufacturing facility in Raleigh,
North Carolina. This group of emission points conforms to the
definition of "source" per 40 CFR 63.73(a)(4) and is identified
as "Source A." Source A consists of the emission points listed
in Table'1-1 of this permit application.
An Enforceable Commitment for Source A was submitted originally
to EPA Region IV on April 1, 1992, prior to the proposal of the
Hazardous Organic NESHAP. Base-year (1987) HAP emissions from
Source A were approved by EPA in revised form on August 17, 1993.
The base-year total HAP and weighted HAP emissions from
Source A are shown below:
Total HAP
Emissions
Weighted HAP
Emissions
Source A
225.2 Mg/yr 722.8 Mg/yr
With this Title V Specialty Permit application, the XYZ Chemical
Company is requesting alternative emissions limitations (AEL's)
for Source A as shown below:
Total HAP
Emissions
Weighted HAP
Emissions
AEL for Source A 22.52 Mg/yr 72.28 Mg/yr
These AEL's represent 90-percent reductions of base-year HAP
emissions from Source A.
I hereby certify the following statements:
A-l
-------
Director
EPA Region IV
April 1, 1993
Page 2
Information provided in this permit application
represents the best available emissions data for
Source A;
Emissions data are based on information gathered and
the belief formed after a reasonable inquiry; and
Statements and information in this permit application
are true, accurate, and complete.
If you have any technical questions regarding the content of this
submittal, please contact Mr. Joe Smith (Environmental Affairs
Manager) at (919) 555-0000.
Sincerely,
George S. Jones
Plant Manager
Enclosure
cc: (appropriate) State Regulatory Agency
U.S. EPA Emission Standards Division
U.S. EPA Office of Enforcement
A-2
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TABLE OF CONTENTS
Page
1.0 COMPANY AND SOURCE IDENTIFYING INFORMATION A-5
1.1 Company Information A-5
1.2 General Description of Source A A-5
1.3 Identification of Source A Emission Points ... A-5
1.4 Site Plan A-7
2.0 EMISSIONS REDUCTION DEMONSTRATION PLAN A-9
3.0 PROPOSED PERMIT TERMS AND CONDITIONS A-12
3.1 Alternative Emissions Limitations (AELs) . . . A-12
3.2 Proposed Reporting Requirements A-12
3.3 Emission Point-Specific Terms and Conditions . A-13
Emission Point ID: PV-1 ............. A-14
Emission Point ID: PV-2 A-18
Emission Point ID: L-l A-20
Emission Point ID: S-l . A-23
Emission Point ID: WW-1 A-27
4.0 EMISSIONS REDUCTION DEMONSTRATION A-33
4.1 Base-Year Emissions Documentation A-33
4.2 Short-Term Post-Reduction Test Results .... A-33
Emission Point ID: PV-1 A-34
Emission Point ID: L-l A-35
Emission Point ID: WW-1 . A-36
4.3 Post-Reduction Year Actual Emissions A-37
A-3
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-------
LIST OF TABLES
Page
1-1 Identification of Emission Points contained in Source A at
the XYZ Chemical Company A- 6
2-1 Emissions Reduction Measures for Source A A-10
4-1 Summary of Performance Test Results for TO-1 A-34
4-2 Summary of Performance Test Results for C-l A-35
4-3 Summary of Performance Test Results for STST-1 .... A-36
LIST OF FIGURES
1-1 Site Plan Identification of Early Reductions Emission
Points Included in Source A
A-8
A-4
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1.0 COMPANY AND SOURCE IDENTIFYING INFORMATION
1.1 COMPANY INFORMATION
The XYZ Chemical Company is a synthetic organic chemical
manufacturing facility located at 8910 Industrial Park Drive in
Raleigh, North Carolina. The XYZ Chemical Company is submitting
this Title V Specialty Permit application under the Early
Reductions Program. The authorized representative of this source
is the Plant Manager, Mr. George S. Jones. The contact for
technical issues regarding this permit application is the
Environmental Affairs Manager, Mr. Joe Smith. These persons can
be reached by telephone at (919) 555-0000.
1.2 GENERAL DESCRIPTION OF SOURCE A
Source A is defined as a miscellaneous group of emission
points located within the contiguous boundaries of the facility
at the above address. Source A consists of two process vents
(PV-l and PV-2), a rail car loading rack (L-l), a product storage
tank (S-l), and a process wastewater stream (WW-1). The
hazardous air pollutant (HAP) emissions from these emission
points are the result of raw material and product losses during
normal production operations. Source A conforms to the Early
Reductions definition of source under 40 CFR 63.73(a)(4).
1.3 IDENTIFICATION OF SOURCE A EMISSION POINTS
Table 1-1 lists all of the emission points included in
Source A. This table provides the following information for each
emission point: a brief description, identification code
assigned by the facility, applicable State permit number, name
and CAS number of HAP emitted, HAP weighting factor, base-year
HAP emissions, and base-year weighted HAP emissions.
Each emission point is physically labeled with an
identification code that corresponds to the codes listed in
Table 1-1. This system of physically labeling emission points
A-5
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allows quick and confident identification of Source A emission
points within the facility.
1.4 SITE PLAN
Figure 1-1 shows the contiguous boundary of the XYZ Chemical
Company's facility located in Raleigh, North Carolina, and
identifies the location of each emission point included in
Source A.
A-7
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Defined as Source A
A-8
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2.0 EMISSIONS REDUCTION DEMONSTRATION PLAN
Table 2-1 lists the measures implemented to achieve the
necessary emissions reductions. This table includes emission
point descriptions, emission point identification codes assigned
by the facility, description of the emissions reduction measures,
emissions reduction measure identification codes assigned by the
facility, and the expected efficiency of the emissions reduction
measure.
The XYZ Chemical Company plans to demonstrate a 90-percent
reduction from base-year HAP emissions by following the
monitoring, recordkeeping, and calculation procedures proposed in
Section 3.0. The demonstration will be performed by computing
the 1994 calendar year emissions from each emission point and
summing these emissions to determine the total emissions from
Source A. This demonstration will require a point-by-point
computation as summarized below. More details on the computation
of emissions from each emission point are provided in
Section 3.3.,
Air Oxidation Unit 1 - (PV-1). The emission stream from
this process vent is now routed to a regenerative thermal
oxidizer (TO-1), As proposed in Section 3.0, the firebox
temperature of TO-1 will be monitored and recorded
continuously. The firebox temperatures have been correlated
with performance test results to estimate post-reduction HAP
emissions for each day in 1994. The daily emissions
estimates will be summed to determine the calendar year 1994
emissions.
EO-1 Carbon Dioxide Vent - (PV-2). The HAP emissions stream
from this process vent are uncontrolled and are exhausted
directly to the atmosphere. The quantity of HAP emissions
are directly proportional to the production rate of the
Ethylene Oxide Process Unit. Calendar year 1994 HAP
emissions will be determined using a HAP emission rate
(kg/hr) corresponding to the maximum expected production
A-9
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rate of ethylene oxide over the next year. This
conservative emission rate will be multiplied by the
recorded hours of process operation.
PX Loading/Paraxylene Rail Car Loading (L-l). Emissions
from this loading rack are now controlled by a refrigerated
condenser (C-l). As proposed in Section 3.3, an interlock
process control system will prevent rail car loading
operations when the condenser exit temperature exceeds
32 °F. This condenser exit temperature has been correlated
with performance test results and unit mass loading rates to
estimate post-reduction HAP emissions for each day in 1994.
The daily emissions estimates will be summed to determine
the calendar year 1994 emissions.
Xylene/Ethylbenzene Storage Tank (S-l). This storage tank
has been retrofitted with an internal floating roof
consisting of primary and secondary seals. The 1994 tank
throughput will be determined from daily recordkeeping of
throughput along with physical properties of the stored
material. These inputs will be used to compute 1994
emissions following the calculation procedures included in
"Procedures for Establishing Emissions for Early Reduction
Compliance Extensions Volume 1 -- Synthetic Organic
Chemical Manufacturing, Ethylene Oxide Sterilization, and
Chromium Electroplating" (EPA-450/3-91-012a or EPA AP-42).
Waste Acid from the Methyl Chloride Drying Tower -
Wastewater Effluent. This wastewater stream is now routed
to a steam stripper (STST-1) for HAP removal. As proposed
in Section 3.0, the steam-to-feed ratio of STST-1 will be
monitored continuously and hourly averages will be recorded.
To estimate 1994 calendar year emissions, the steam-to-feed
ratio has been correlated with short-term effluent sampling
results and fraction-emitted to fraction-measured ratios
presented in the EPA document No. EPA-450/3-91-012a.
A--11
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3.0 PROPOSED PERMIT TERMS AND CONDITIONS
3.1 ALTERNATIVE EMISSIONS LIMITATIONS (AEL)
The XYZ Chemical Company is requesting the following AEL's
for the defined Source A:
Total HAP
Emissions
Weighted HAP
Emissions
AEL for Source A 22.52 Mg/yr 72.28 Mg/yr
The XYZ Chemical Company will calculate total and weighted HAP
emissions semiannually.
3.2 PROPOSED REPORTING REQUIREMENTS
The .HAP emissions from Source A will be reported
semiannually. The semiannual reports will be submitted to the
EPA regional office on or before the last day of each month
following the end of a calendar half-year period (January 31 or
July 31, as appropriate). The first semiannual report will be
submitted after the end of the calendar half-year in which the
permit is issued.
Each report will contain the semiannual HAP emissions for
Source A and the report covering the second half of a calendar
year will contain aggregate HAP emissions for the entire year.
The HAP emissions will be calculated using the calculation
procedures in Section 3.3 of this document. The semiannual HAP
emissions from emission points, PV-1, PV-2, L-l, S-l, and WW-1,
will be summed to obtain the total semiannual HAP emissions from
Source A. Aggregate HAP emissions will be calculated by adding
the total HAP emissions for each calendar half-year.
A-12
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3.3 EMISSION POINT-SPECIFIC TERMS AND CONDITIONS
For each emission point, the proposed terms and conditions
for monitoring, recordkeeping, and emissions calculation
procedures are presented individually on the following forms.
A-13
-------
EMISSION POINT ID:
PV-1
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES
Emission Point Description:
Emission Reduction Measure ID:
Emission Reduction Measure Description:
Air Oxidation Unit 1
TO-1
Thermal Oxidizer
A. Proposed monitoring:
The XYZ Chemical Company proposes to monitor the firebox
temperature of the Thermal Oxidizer (TO-1) and gas flow from
PV-1 to TO-1. Selection of these monitoring parameters is
consistent with requirements of the HON. The XYZ Chemical
Company proposes to install, maintain, calibrate, and
operate all monitoring equipment according to the
manufacturer's recommended specifications.
The firebox temperature of the thermal oxidizer (TO-1) is
monitored with a Type K thermocouple (TIC-PV-1) located on
the firebox wall opposite the gas burners. This location
was selected because it is the closest location to the
combustion zone that provides a reliable indication of
combustion zone temperature. The thermocouple indicator is
equipped with a continuous wheel chart recorder (TIR-PV-1).
Both the thermocouple indicator and wheel chart recorder are
located in the Process A Control Room. The firebox
temperature will be correlated with performance test data
and used as a surrogate indicator of HAP emissions. The
firebox temperature of TO-1 will be monitored to determine
the number of hours TO-1 is operated in various temperature
ranges listed below in Section C.
A pitot tube is installed in the exhaust duct of PV-1 to
indicate process vent gas flow to TO-1. The gas flow
A-14
-------
EMISSION POINT ID: PV-1
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
indicator (FIR-PV-1) is equipped with a continuous recorder
located in the Process A Control Room. The flow indicator
will be used to determine the number of hours that gases are
routed from PV-1 to TO-1.
B. Proposed recordkeeping:
Daily firebox temperature charts for TO-1 will be maintained
in a file located in the Process A Control Room. In
addition, the process operator will record the following
information in a log book at the end of each work day:
a) Date
b) Number of hours the firebox temperature of TO-1
was maintained in each of the four temperature
ranges listed in Section C
c) Number of hours that process gas flowed from PV-1
to TO-1
d) Number of hours that process gas flowed to an
uncontrolled vent
Proposed calculation procedure for determining emissions:
Daily HAP emissions from PV-1 will be determined using the
number of hours TO-1 was operated within each of four
firebox temperature ranges along with temperature-dependent
emission factors developed from the results of the initial
performance test on TO-1.
This performance test was conducted during the period of
November 15-17, 1993 to document post-reduction HAP
emissions from PV-1. A volatile organic sampling train
A-15
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EMISSION POINT ID: PV-1
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
(VOST), Method SW 846 0030, was used to quantify residual
benzene concentrations from PV-1 after passing through TO-1.
Method SW 846 0030 was selected rather than EPA Methods 18
or 25A because Method SW 846 0030 is more sensitive in
measuring minute concentrations of the volatile organic
compounds that are expected in combustion exhaust gas. EPA
Method 2 was used to quantify gas flow rates during the
performance test. The results of the performance test
established the following emission factors for the maximum
gas flow rate from PV-1 into TO-1:
Firebox Temperature
Range (°F)
Temp >. 1600
1600 > Temp > 1400
1400 > Temp >. 1200
1200 > Temp
Emission Factor
(kg/hr)
0.126
0.314
0.440
7.177
Daily HAP emissions from PV-1 will be calculated by
multiplying the number of hours that TO-1 was operated
within the appropriate temperature range by the
corresponding emission factor. The daily emissions value
will be recorded into a log maintained by the process
operator. At the end of each calendar half-year, these
daily emission values will be summed to determine the
semiannual HAP emissions from PV-1.
The Thermal Oxidizer is considered to be in an uncontrolled
condition when the average hourly firebox temperature is
lower than 1200 °F.
A-16
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EMISSION POINT ID:
PV-2
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES
Emission Point Description: EO-1 Carbon Dioxide Vent
Emission Reduction Measure ID: None
Emission Reduction Measure Description: None
Proposed monitoring:
The XYZ Chemical Company proposes to monitor the operating
hours of the Ethylene Oxide Process Unit. The XYZ Chemical
Company proposes to install, maintain, calibrate, and
operate all monitoring equipment according tp the
manufacturer's recommended specifications. Based on
engineering calculations documented in the Enforceable
Commitment, the XYZ Chemical Company has demonstrated that
HAP emissions from PV-2 are directly proportional to the
process production rate. The vent gas flow rate is equal to
the by-product production rate of carbon dioxide in the
ethylene oxide reactor. The annual production rate of this
process has been relatively constant over the past few
years.
Proposed recordkeeping:
At the end of each work day, the process operator will
record in a log book the date and the number of hours the
process unit was operated.
Proposed calculation procedure for determining emissions:
Daily HAP emissions from PV-2 will be calculated by
multiplying the number of hours that the Ethylene Oxide
Process Unit was operated by the emission rate (kg/hr)
corresponding to the maximum expected production rate of the
A-17
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EMISSION POINT ID:
PV-2
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (Continued)
ethylene oxide process unit over the next year, as shown
below:
0.0265 kg of HAP per hour of process operation.
The daily emissions value will be recorded into a log
maintained by the process operator. At the end of each
calendar half-year, these daily emission values will be
summed to determine the semiannual HAP emissions from PV-2,
A-18
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EMISSION POINT ID: L-l
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES
Emission Point Description:
PX Loading/p-xylene
Rail Car Loading
Emission Reduction Measure ID:
Emission Reduction Measure Description:
C-l
Refrigerated
Condenser
A. Proposed monitoring:
The XYZ Chemical Company has installed an interlock process
control system on L-l to prevent rail car loading operations
when the exit stream temperature of condenser (C-l) exceeds
a temperature of 32°F. When this temperature limit is
exceeded, the loading pumps are automatically stopped and an
audible alarm sounds to alert the process operator to the
situation. Loading operations can resume only when the exit
stream of C-l has a temperature of 32°F or less. The XYZ
Chemical Company proposes to install, maintain, calibrate,
and operate the interlock process control system according
to the manufacturer's recommended specifications.
B. Proposed Recordkeeping:
On days when rail cars are loaded with p-xylene, the loading
operator will record the following information in a log book
at the end of each loading day:
a) Date of rail car loading
b) Total quantity of p-xylene (kg) loaded
A-19
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EMISSION POINT ID: L-l
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
C. Proposed calculation procedure for determining emissions:
At the end of each day when rail cars are loaded with
p-xylene, daily HAP emissions from L-l will be determined
using the quantity of p-xylene (kg) loaded that day and
loading emission factors developed from the results of the
initial performance test on C-l.
This performance test was conducted during the period
November 22-23, 1993 to document post-reduction HAP
emissions from L-l. The procedures of EPA Method 18 were
followed to gather three samples of gas exiting C-l in
Tedlar bags. The samples were analyzed for p-xylene using
gas chromatography and a flame ionization detector. The HAP
emission factor reported below is based on the average
p-xylene concentration measured in the three samples. The
samples were gathered under maximum loading rates (7,000
gallons per hour) and at a maximum C-l gas exit temperature
of 32 °F. These conditions represent a worst-case scenario.
The gas flow rate from L-l to C-l was measured using EPA
Method 2. The results of the performance test established
the following controlled emission factor for the maximum
flow rate from L-l to C-l:
0.0043 kg of HAP emissions per 1000 kg of p-xylene loaded
Daily HAP emissions from L-l will be calculated by
multiplying the quantity of p-xylene (kg) loaded that day by
the above emission factor. The daily emissions value will
be recorded into a log maintained by the loading operator.
At the end of each calendar half-year, these daily emission
A-20
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EMISSION POINT ID: L-l
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
values will be summed to determine the semiannual HAP
emissions from L-l.
A-21
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EMISSION POINT ID: S-l
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES
Emission Point Description:
Emission Reduction Measure ID:
Xylene/Ethylbenzene
Storage Tank
None
Emission Reduction Measure Description:
Internal floating roof with primary & secondary seals
A. Proposed monitoring:
The XYZ Chemical Company proposes to monitor the quantity of
material transferred to S-l and the integrity of rim seals
on the internal floating roof with periodic visual
inspections. Selection of these monitoring parameters is
consistent with the requirements of the HON. The XYZ
Chemical Company proposes to install, maintain, calibrate,
and operate all monitoring equipment according to the
manufacturer's recommended specifications.
The flow of xylene/ethylbenzene to S-l is monitored by a
Hercules 2100 flow meter equipped with a cumulative flow
gauge (FIC-S-1). The flow meter is installed on the pipe
conveying xylene/ethylbenzene to storage tank S-l at a
location 4 feet prior to entering S-l. This equipment will
determine the volume of xylene/etliylbenzene transferred to
tank S-l from various process units.
Inspections and maintenance of the internal floating roof
and secondary rim seal will be conducted annually to ensure
proper operation of the equipment. Inspections and
maintenance of the primary rim seal will be conducted once
every 5 years or when the tank is emptied for periodic
cleaning of the tank, which ever occurs first.
A-22
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EMISSION POINT ID: S-l
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
This inspection and repair program will minimize fugitive
HAP emissions resulting from weathered cracks or gaps in the
floating roof and rim seals.
B. Proposed recordkeeping:
At the end of each day, the process operator will record in
a log book the date and current gauge reading from the flow
accumulator. The log book is kept in the Xylenes Process
Control Room. In addition, the process operator will record
in the log book the date when inspections of the internal
floating roof and rim seals was conducted and any findings
observed during the inspection.
C. Proposed calculation procedure for determining emissions:
Semiannual HAP emissions from S-l will be determined using
the semiannual throughput (gallons) for S-l and the internal
floating-roof tank emissions calculations given in the EPA
document "Procedures for Establishing Emissions for Early
Reduction Compliance Extensions" (No. EPA-450/3-91-012a) or
"Compilation of Air Pollution Emission Factors" (EPA AP-42).
The semiannual throughput for tank S-l will be determined by
subtracting the accumulator gauge reading at the beginning
of the 6-month period from the reading at the end of the
period. The resulting value will be the number of gallons
of xylene/ethylbenzene transferred to S-l during the 6-month
period.
A-23
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EMISSION POINT ID: S-l
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
The tank emissions calculations also require the following
tank design information and stored material physical
properties:
Tank Design Parameters
Tank height:
Tank diameter:
Tank capacity:
Roof and shell color:
Diurnal temperature change:
Deck fittings:
Number of deck support columns:
Bolted or welded floating deck:
Internal floating roof seal factor
for liquid-mounted primary seal
with secondary rim seal:
Stored Material Properties
Molecular weight of stored material:
Vapor pressure of stored material:
Density of stored material:
48 ft
100 ft
2,820,000
gallons
Medium gray
9.5 °F
Uncontrolled
7
Bolted
1.6
106 Ib/lb mole
0.164 psia
7 Ib/gal
The above information is used to determine emissions from
S-l when the internal floating roof and rim seals are in
good working order. When an annual visual inspection of the
secondary rim seal reveals gaps between the rim seal and the
tank wall, emissions from S-l are determined by assuming the
internal floating roof is equipped with only a primary,
liquid-mounted rim seal. The corresponding internal
floating roof seal factor will be 3.0.
When a 5-year visual inspection of the primary rim seal
reveals gaps between the rim seal and the tank wall,
A-24
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EMISSION POINT ID: S-l
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
emissions from S-l are determined by assuming the internal
floating roof is equipped with only a primary, vapor-mounted
rim seal. The corresponding internal floating roof seal
factor will be 6.7.
The semiannual emissions value will be recorded into a log
maintained by the process operator.
A-25
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EMISSION POINT ID: WW-1
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES
Emission Point Description: Waste acid from the methyl
chloride drying tower
Emission Reduction Measure ID: STST-1
Emission Reduction Measure Description: Steam Stripper
A. Proposed monitoring:
The XYZ Chemical Company proposes to monitor the steam flow
rate into STST-1, wastewater mass flow rate into STST-1,
wastewater feed temperature, and the outlet temperature of
the overheads condenser. The organic HAP loading in the
wastewater entering the steam stripper is considered
constant. This assumption is based on two points: first,
the wastewater enters a steam stripper feed tank that is
well mixed and has a residence time of 8-hours and, second,
three separate analyses of wastewater from this feed tank
over the last 18 months indicated less than 10 percent
variation from the average of the organic-HAP
concentrations. The XYZ Chemical Company proposes to
install, maintain, calibrate, and operate all monitoring
equipment according to the manufacturer's recommended
specifications.
The wastewater feed mass flow rate will be determined using
a Spiro XTR rotameter (FIC-WW-1) and the density of
wastewater (8.34 Ib/gal). This rotameter will be located on
the influent pipe, 4 feet prior to entering STST-1. The
steam mass flow rate will be determined using an orifice
pressure gauge (FIC-WW-2) and steam charts. This pressure
gauge will be located on the steam influent pipe, 22 feet
prior to entering STST-1. The respective flow indicators
(FIR-WW-1 and FIR-WW-2) are connected to a Honeywell Data
A-26
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EMISSION POINT ID: WW-1
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
Acquisition System (DAS), which collects data from each
monitoring parameter once every 2 seconds. The flow rate
indicators and the DAS are located in the MC Process Control
Room.
The "steam-to-feed ratio" is the ratio of steam mass flow
rate to wastewater feed mass flow rate. The steam-to-feed
ratio of STST-1 can be correlated with performance test data
and used as an indicator for the HAP removal efficiency of
STST-1. The steam-to-feed ratio of STST-1 will be monitored
to determine the number of hours STST-1 is operated in
various steam-to-feed ratio ranges listed below in
Section C.
The temperature of the wastewater feed and overheads
condenser outlet will be measured using Type J
thermocouples. The wastewater feed thermocouple (TIC-WW-1)
is located on the influent pipe, 6 feet prior to entering
STST-1. The overheads condenser thermocouple (TIC-WW-2) is
located in the condensing chamber prior to the overheads
discharge. The respective thermocouple indicators (TIR-WW-1
and TIR-WW-2) are connected also to the DAS, which collects
data from each monitoring parameter once every 2 seconds.
The thermocouple indicators and the DAS are located in the
MC Process Control Room.
B. Proposed recordkeeping:
At the end of each day, the process operator will obtain
from the DAS hourly-average values for the following
parameters:
a) Date
A-27
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EMISSION POINT ID: WW-1
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
b) Steam-to-feed ratio
c) Number of hours the steam-to-feed ratio was maintained
within each of the three steam-to-feed ratio ranges
listed below in Section C
d) Wastewater feed temperature
e) Temperature of the overheads condenser outlet
These values will be recorded in a log book by the process
operator.
C. Proposed calculation procedure for determining emissions:
Daily HAP emissions from WW-1 will be determined using the
number of hours STST-1 was operated within each of three
steam-to-feed ratio ranges along with steam-to-feed ratio-
dependent emission factors that were developed from the
results of the initial performance test on STST-1.
This performance test was conducted during the period
November 1-4, 1993 to document post-reduction HAP emissions
from WW-1. Using the methodology prescribed in Method 305,
the HAP concentrations in the wastewater feed and bottoms
streams were determined. Concentration measurements were
conducted at a minimum wastewater feed temperature of 35 °C
and steam-to-feed ratios of 0.09 and 0.12. Also, the
condenser outlet vapor temperature was maintained below 50
°C. The results of the performance test established the
following speciated emission factors:
Steam-to-Feed Ratio (kg/kg)
steam-to-feed ratio > 0.12
Methanol
Emission Factor
1.24 kg/hr
A-28
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EMISSION POINT ID: WW-1
PROPOSED MONITORING, RECORDKEEPING, AND
EMISSION CALCULATION PROCEDURES (continued)
0.12 > steam-to-feed ratio .> 0.09
0.09 > steam-to-feed ratio
Steam-to-Feed Ratio (kg/kg)
steam-to-feed ratio .> 0.12
0.12 > steam-to-feed ratio .> 0.09
0.09-> steam-to-feed ratio
1.36 kg/hr
12.4 kg/hr
Methyl Chloride
Emission Factor
0.03 kg/hr
0.04 kg/hr
4.5 kg/hr
Daily HAP emissions from WW-1 will be calculated by
multiplying the number of hours that STST-1 was operated
within the appropriate steam-to-feed ratio range by the
corresponding emission factor. The daily emissions value
will be recorded into a log maintained by the process
operator. At the end of each calendar half-year, these
daily emission values will be summed to determine the
semiannual HAP emissions from WW-1.
The steam stripper is considered to be in an uncontrolled
condition when the average hourly steam-to-feed ratio is
lower than 0.09 kg/kg, or the average daily wastewater feed
temperature is lower than 35 °C, or the average daily
temperature of the overheads condenser outlet is higher than
50 °C.
A-29
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4.0 EMISSIONS REDUCTION DEMONSTRATION
Emissions reductions from a source are demonstrated by
documenting emissions for a given base year, conducting short-
term emissions tests to verify the performance of installed
emissions reduction measures, and documenting annual post-
reduction emissions. This section provides documentation of
base-year emissions and short-term performance tests on emissions
reduction measures, only. Documentation of annual post-reduction
emissions will be submitted after the end of the post-reduction
year as specified in the Permits for Early Reductions Source
Rule.
4.1 BASE-YEAR EMISSIONS DOCUMENTATION
Base year (1987) HAP emissions from Source A are presented
in Table 1-1 (section 1.3). Documentation for the base-year
emissions can be found in the Enforceable Commitment for
Source A, which was submitted to EPA Region IV on April 1, 1992,
and approved by EPA on August 17, 1993.
4.2 SHORT-TERM POST-REDUCTION TEST RESULTS
Short-term performance testing has been performed for PV-1,
L-l, and WW-1. A summary of the post-reduction emissions testing
for these emission points is presented below. Performance
testing was not necessary to document post-reduction emissions
from PV-2 and S-l. Emissions reduction measures were not applied
to emission point PV-2; "post-reduction" emissions from this vent
are determined using the approach for uncontrolled emissions in
Section 3.3. Post-reduction emissions from emission point S-l
can be documented by using the emissions equations for storage
tanks with internal floating roofs provided in the either of
these EPA documents: EPA-450/3-91-012a or AP-42.
A-30
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Emission Point ID; PV-1
Summary of Test Results -- During the period of
November 15-17, 1993, a performance test was conducted on thermal
oxidizer TO-1 to document post-reduction emissions from PV-1. A
volatile organic sampling train (VOST), Method SW 846 0030 was
used to quantify the residual benzene concentration in PV-1 after
passing through TO-1. EPA Method 2 was used to quantify gas flow
rates during the performance test. Three test runs were
conducted under each of four different operating conditions
(varying TO-1 firebox temperatures). The emissions data
collected under each operating condition were averaged to yield
emission rates for maximum gas flow from PV-1 to TO-1. The
individual test run emission rates and average test emission
rates are presented below:
TABLE 4-1. SUMMARY OF PERFORMANCE TEST RESULTS FOR TO-1
Average
Firebox
Temperature
(°P)
1600
1400
1200
Uncontrolled
condition
Emission Rates (kg/hr)
Run 1
0.125
0.325
0.396
Run 2
0.120
0.317
0.432
Run 3
0.133
0.300
0.492
Average
0.126
0.314
0.440
7.177
Applicability of Selected Test Method -- Method SW 846 0030
was used because it is an EPA test method that has been validated
for quantifying benzene in combustion gases from an incinerator
(thermal oxidizer).
EPA Method 2 was used because it is an EPA test method that
is the industry standard for quantifying gas flow rates in
exhaust stacks.
A-31
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Discussion of Test Result Anomalies or Problems -- No
problems were encountered during the short-term performance tests
that could have influenced the results.
Emission Point ID: L-l
Summary of Test Results -- During the period November 19-20,
1993, a performance test was conducted on condenser C-l to
document post-reduction emissions from L-l. Following the
procedures under EPA Method 18, a total of three samples of the
product exit gas from the condenser were gathered in Tedlar bags.
These three samples were gathered under a single operating
condition where the rail car loading rate was 7,000 gallons per
hour (maximum) and the product exit gas temperature was
maintained at 32 °F (maximum) . The samples were analyzed for
p-xylene using gas chromatography and a flame ionization
detector. The gas flow rate from L-l to C-l was measured using
EPA Method 2.
The emission rates determined from each gas sample were
averaged to yield an overall emission rate. This overall
emission rate is used in the emissions estimating procedure for
L-l as described in Section 3.3. The individual test run
emission rates and average test emission rates are presented
below:
TABLE 4-2. SUMMARY OF PERFORMANCE TEST RESULTS FOR C-l
Average Condenser
Exit Temperature
(°F)
32
Emission Rates (kg emissions/kg loaded)
Run 1
0.0040
Run 2
0.0044
Run 3
0.0045
Average
0.0043
Applicability of Selected Test Method - - Method 18 was used
because it is an EPA test method that has been validated for
quantifying xylene in gaseous exhaust streams.
A-32
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EPA Method 2 was used because it is an EPA test method that
is the industry standard for quantifying gas flow rates in
exhaust streams.
Discussion of Test Result Anomalies or Problems --No
problems were encountered during the short-term performance tests
that could have influenced the results.
Emission Point ID; WW-1
Summary of Test Results -- During the period November 1-4,
1993, a performance test was conducted on STST-1 to document
post-reduction'emissions from WW-1. Using the methodology
prescribed in EPA Method 305, the HAP concentrations in the.
wastewater feed and bottoms streams were determined as an average
of three samples. Concentration measurements were conducted at a
minimum wastewater feed temperature of 35 °C and steam-to-feed
ratio of-0.09 and 0.12. Also, the condenser outlet vapor
temperature was maintained below 50 °C. The results of the
performance tests established the following speciated emission
rates:
TABLE 4-3. SUMMARY OF PERFORMANCE TEST RESULTS FOR STST-1
Average Steam- to -Feed
Ratio
0.09
0.12
Uncontrolled condition
Average Steam- to -Feed
Ratio
0.09
0.12
Uncontrolled condition
Methanol Emission Rates (kg/hr)
Run 1
1.34
1.28
Run 2
1.35
1.22
Run 3
1.39
1.22
Average
1.36
1.24
12.4
Methyl Chloride Emission Rates
(kg/hr)
Run 1
0.04
0.02
Run 2
0.03
0.03
Run 3
0.04
0.03
Average
0.04
0.03
4.5
A-33
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Applicability of Selected Test Method -- Method 305 is
recommended by the HON as the prescribed test method for
quantifying HAP's in industrial wastewater streams.
Discussion of Test Result Anomalies or Problems --No
problems were encountered during the short-term performance tests
that could have influenced the results.
4.3 POST-REDUCTION YEAR ACTUAL EMISSIONS
(To be supplied after the end of the post-reduction year.)
A-34
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APPENDIX B
List of Validated Test Methods
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EMISSION MEASUREMENT TECHNICAL INFORMATION CENTER
GUIDELINE DOCUMENT
List of Validated Test Methods
Introduction
On December 29, 1992 the Administrator promulgated 40 CFR
Part 63, "National Emission Standards for Hazardous Air
Pollutants for Source Categories: Regulations Governing
Compliance Extensions for Early Reductions of Hazardous Air
Pollutants." The regulations require that the emission
reductions called for be determined by comparing the post-
reduction emissions from a source with emissions in a base year.
To demonstrate the post-reduction emission reduction, the source
owner or operator must present verifiable and actual emission
data for both the pre- and post-reduction operations.
These verifiable and actual data will in many cases consist
of source test results using validated methods. A validated
method is defined as a measurement methodology with a
demonstrated precision and bias over the measured concentration
of the source's emission. A validated method may be an EPA Test
Method, a validated conditional test method, or a test method
validated according to the protocol in Method 301 (promulgated
with the above regulations). The regulation states that a list
of validated methods may be obtained from the Emission
Measurement Technical Information Center (EMTIC).
Validated Methods
The Atmospheric Research Exposure and Assessment Lab (AREAL)
and Emissions, Monitoring, and Analysis Division have developed
an initial list of validated methods and source applicability.
The following table is EMTIC's preliminary listing of validated
methods; EMTIC is preparing a more complete and more detailed
list of methods with validation and applicability status in a
computer disk format. The purpose of this methods list is to
provide direction for developing or applying validated air toxic
emission test methods and provide a means for checking the
applicability of proposed methods. This dynamic list is
scheduled to be available initially in October 1991 and will be
updated as additional methods are validated. The list also will
be updated as validated methods are reported to EMTIC by various
permitting authorities.
Prepared by Tony Wayne, Emission Measurement Branch EMTIC G-015
Technical Support Division, OAQPS, EPA June 27, 1991
B-l
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EMTIC G-015
EMTIC GUIDELINE DOCUMENT
EPA Reference, or Test Methods published in the FEDERAL
REGISTER. Citations include:
40 CFR Part 51, Appendix M
40 CFR Part 52, §52.12 (pertaining to approved
SIP's)
60, Appendix A*
61, Appendix B
40 CFR Part
40 CFR Part
40 CFR Part 63, Appendix A
40 CFR Part 763, Subpt.E, Appendix A
40 CFR Part 763, Subpt.F, Appendix A
* Test Method 18 is considered a self validating method.
Properly conducted, the method may have broad
applicability.
EPA conditional test methods as published through EMTIC.
Citations include:
• CTM-001 Determination of Butadiene Emissions. Sampling
and Analysis of Butadiene at a Synthetic Rubber Plant. EPA
Method 18 procedure was validated for measurement of
butadiene in the presence of styrene.
Contact: Dr. J.C. Pau
(919) 541-3680
• CTM-002 Determination of Particulate Matter (Screening
Procedure). The screening procedure was evaluated at
ammonium nitrate facilities.
Contact: Mr. J. Brown
(919) 541-0200
• CTM-003 Hi-Vol Method for PM. A particulate emission
test method was validated for positive pressure bag-house
controls. Method is applicable to low concentration, low
humidity situations.
Contact: Ms. C. Sorrell
(919) 541-1064
• CTM-004 Determination of Hydrogen Chloride Emissions.
Methodology has been validated at Municipal and Hazardous
Waste Incinerators.
Contact:
Mr. J.H.
(919)
Margeson
541-2848
• CTM-005 Condensible Particulate Matter (Revised). The
method was validated at wood waste and coal fired boilers.
Contact: Ms. C. Sorrell
(919) 541-1064
B-2
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EMTIC G-015
EMTIC GUIDELINE DOCUMENT
• CTM-006 Determination of Chromiinn Emissions from
Chromium Electroplaters. This method has been validated for
the subject source category.
Contact: Mr. F. Clay
(919) 541-5236
• CTM-008 Determination of Acrylonitrile from Stationary
Sources. Determination of Acrylonitrile in Stationary
Source Emissions by Impinger Sampling and Gas Chromatography
with Nitrogen-Phosphorus Detection. The procedure was
validated at a acrylic fiber plant where AN was used as raw
material and a AN manufacturing plant.
Contact: Dr. J.C. Pau
(919) 541-3680
• CTM-009 Emission Rates of VOC through Cover Materials.
The method was validated for cover membranes at hazardous
waste storage, treatment, and disposal facilities.
Contact: Ms. R. Dishakjian
(919) 541-0443
• CTM-010 Determination of Perchloroethylene Content of
Wet Waste Materials from filters and Still Bottoms. Method
was 'validated at several perc dry cleaning facilities.
Contact: Mr. A. Wayne
(919) 541-3576
• CTM-011 Determination of Halogenated Organics from
stationary sources. The method was validated for
halogenated compounds in nonparticulate laden sources.
Contact: Mr. F. Curtis
(919) 541-1063
3. The following test procedures also have been validated for
the cited applications:
• Volatile Organic Sampling Train (VOST) Protocol. The
VOST has been validated at a hazardous waste incinerator
with five specific POHCs.
Contact: Mr. T.J. Logan
(919) 541-2580
• Determination of Selected Nitrogen-Containing Hazardous
Pollutants in Complex Matrices by Gas Chromatography with a
Nitrogen-Phosphorous Detector. The procedure was validated
for outlet streams of a scrubber unit at a chemical for the
compounds plantaniline, nitrobenzene, and toluene.
Contact: Dr. J.E. Knoll
(919) 541-2952
B-3
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EMTIC G-015
Eiyrric GUIDELINE DOCUMENT
• Chrome Analysis at a Ferrochrome Smelter, a Chemical
Plant and a Refractory Brick Plant. Various techniques were
validated for the determination of Cr6+.
Contact: Dr. J.E. Knoll
(919) 541-2952
• Determination of Chromium Speciation -- Ferrochrome
Smelter Dust.
Contact: Dr. J.E. Knoll
(919) 541-2952
• Validation of a Test Method for Formaldehyde Emissions.
Three methods: peroxide impinger/ion chromatography (1C),
dinitrophenylhydrazine-coated (NPH) cartridge/high
performance liquid chromatography (HPLC), and NPH
impinger/HPLC. Procedures validated at two formaldehyde
manufacturing plants.
Contact: Dr. J.C. Pau
(919) 541-3680
• Method for Determination of Methylene Chloride Emissions
at Stationary Sources.
Contact: Dr. J.E. Knoll
(919) 541-2952
• Analytical Method Evaluation for Measuring Ethylene Oxide
Emissions from Commercial Dilute-Acid Hydrolytic Control
Units.
Contact: Mr. J.H. Margeson
(919) 541-2848
• Semi-Volatile Organic Sampling Train Method (Semi-VOST)
for measuring concentrations of principal organic hazardous
constituents (POHCs) with boiling points greater than 100°C
that are emitted from hazardous waste incinerators. The
method was validated on 5 deuterated organic compounds
(ds-pyridine, d8-toluene, ds-chlorobenzene, d10-o-xylene, and
d2-tetrachloroethane) .
Contact: Mr. J.H. Margeson
(919) 541-2848
• Modified Method Five (MM5) .Test Method for PCs and PCFs.
The method has been validated at a municipal waste combustor
(MWC) .
Contact: Dr. J.C. Pau
(919) 541-3680
• Methodology for Measuring Emissions of Chlorinated
Solvents From Stationary Sources. An EPA Method 18
procedure was validated at several sources.
Contact: Dr. J.C. Pau
(919) 541-3680
B-4
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EMTIC G-015
EMTIC GUIDELINE DOCUMENT
• Thin Layer X-Ray Powder Diffraction (XR) Methods for
Semiquantitative Analysis of Asbestos Cement Pipe Industry
Emissions: Analysis of Emission Samples by XR and Electron
Microscopy.
Contact: Mr. T.J. Logan
(919) 541-2580
• Method for Determining Asbestos Mass Emission Rate From
Stationary Sources.
Contact: Mr. T.J. Logan
(919) 541-2580
• Methods for Determining the Polychlorinated Biphenyl
Emissions from Incineration and Capacitor and Transformer
Filling Plants.
Contact: Dr. J.C. Pau
(919) 541-3680
• An application of EPA Method 111 for the determination of
Benzene From Stationary Sources.
Contact: Dr. J.E. Knoll
(919) 541-2842
• Procedures for Measuring Hexavalent Chromium Emissions
from Hazardous Waste Incinerators.
Contact: Dr. J.E. Knoll
(919) 541-2842
B-5
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APPENDIX C
Sources of Information on Test Methods
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Sources of Information on Test Methods
The purpose of this appendix is to suggest several sources
of information about test methods for HAP's. A complete
reference for each document is listed here, as well as how it can
be obtained. Discussions of why the methods or databases of
methods were developed and how they are applicable to EPA and
permit applicants are also presented.
Stationary Source Sampling and Analysis Directory
The Stationary Source Sampling and Analysis Directory
(SSADAIR), Version 2.1, is a menu-driven program for personal
computers developed at Radian Corporation for the U.S. EPA
Atmospheric Research and Exposure Assessment Laboratory (AREAL).
For further information on how to obtain a copy of this
directory, contact Mr. Merrill Jackson at AREAL, (919) 541-2559.
The SSADAIR includes a database of physical properties and
sampling 'and analytical considerations for chemical compounds
that are potential air pollutants. The SSADAIR was created
primarily to help regulators decide whether proposed sampling and
analytical methods are appropriate for a particular chemical.
The SSADAIR can also be very useful to facilities that must
perform source testing in order to obtain or comply with a
permit. This database may help plant officials and contractors
avoid performing costly sampling and analyses that may not yield
acceptable data.
The SSADAIR (originally called the "Problem POHC Database")
was developed at Southern Research Institute under contract to
the EPA. The list of chemical compounds included in the database
is a composite of those given in the Appendix VIII list and its
revision, Appendix IX of the Resource Conservation and Recovery
Act, and the 1990 Clean Air Act list of toxic air pollutants.
All information for pertinent physical properties and best
available sampling and analytical methodology was compiled. Much
of this information was obtained from laboratory and field
studies and analytical judgement. Examples of this information
C-l
-------
include considerations such as whether or not a compound can be
separated and detected by a gas chromatographic method or if a
compound decomposes during sampling or analysis. The validation
status for sampling and analytical methods is provided where
possible. For a small number of analytes, a validation protocol
that involves dynamic spiking of analytes in the field was
followed. Where this information is available, a source for the
information, usually an EPA report, is cited. In other cases, a
complete sampling and analytical method has not been validated,
but some laboratory experiments or validation of an analytical
procedure has been performed, and this information is cited by
report number.
Also included in this report are University of Dayton
Research Institute (URI) Thermal Stability Classes and Thermal
Stability Rankings, which provide an indication of the ease of
incineration of a compound. Database records containing
information about compounds can be accessed by the compound's
name or CAS registry number, by physical property, or by problem
areas. Physical properties include URI Thermal Stability,
molecular weight, boiling or melting point, combustion rank, or a
combination of any two properties. Problem areas include
analysis, sampling, or compound hazards.
s Clean Air Act Air Toxics Database
This database was developed by Lawrence H. Keith of Radian
Corporation and Mary M. Walker of Mary M. Walker and Associates
and was published by Lewis Publishers /CRC Press, Inc., Boca
Raton, Florida in 1992. The database was edited and adapted for
electronic publication from EPA's Report No. EPA-450/4-91-021,
"Screening Methods for the Development of Air Toxics Emission
Factors . " The database addresses the questions of how to sample
and analyze the 189 hazardous air pollutants (HAP's) on the Clean
Air Act list. Some of the methods referenced in this database
are not yet validated for the air toxics, may not have been used
with some of the air toxics, and must be modified and then
verified before they can be used with confidence. However, all
the methods in this database represent the best estimate at this
C-2
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time for methods that can be used for sampling and analysis of
the air toxics. For some of the HAP's, existing sampling and
analytical methodologies are directly pertinent to the analyte of
interest in stationary sources, and the performance parameters
for the compounds have been completely defined. For some of the
189 HAP's, data were available to substantiate part or all of the
performance of analytical methodology, but no information was
available to establish whether the compound could be sampled
quantitatively. For a significant percentage of the HAP's,
assignment to a sampling and analytical methodology could be made
tentatively only on the basis of chemical or physical
correspondence to other compounds that have been sampled and
analyzed with the methodology. The purpose of this database is
to identify methods with the broadest applicability to the HAP's.
Environmental Monitoring Methods Index
The Environmental Monitoring Methods Index (EMMI) is an
information retrieval tool consisting of software programs and
on-line manuals. It was developed by EPA's Engineering and
Analysis Division (EA) within EPA's Office of Water. EMMI is an
automated inventory of information on environmentally significant
analytes monitored by EPA and methods for their analysis. The
database includes information on more than 2600 analytes from
over 80 regulatory and non-regulatory lists and lists more than
900 analytical methods. EMMI includes analytes from the Clean
Air Act as well as from the Clean Water Act, the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA),
Superfund Amendments and Reauthorization Act (SARA), and the Safe
Drinking Water Act (SDWA).
The database provides a comprehensive cross-reference
between analytes and analytical methods and contains information
on related laws and organizations and additional databases for
further information. Hardware requirements for using EMMI are an
IBM PC or compatible with a hard drive having 8 megabytes of
available space and 20OK RAM at the OS prompt, a monochrome or
color monitor, a keyboard or mouse, and a printer able to print
165 columns of compressed text. Software requirements are PC-OS
C-3
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or MS-OS Version 2.0 or later and EMMI System Software Version
1.0 or later. Software support is provided by the EPA EA Sample
'Control Center at (703) 557-5040.
A list of validated test methods is available through the
Emission Measurement Technical Information Bulletin Board (EMTIC
BBS), which is part of the EPA's Technology Transfer Network
(TTN) . To access the EMTIC BBS, the user needs a computer, a
modem, and a communication package capable of communication at.
either 1200, 2400 or 9600 baud, 8 data bits, 1 stop bit, and no
parity (8-N-l). The BBS telephone number is (919) 541-5742. To
retrieve the document from the EMTIC BBS, reference the menu
"File Transfers" and choose option EMTIC Documents. Then
choose EMTIC Guideline Documents, where you will find the
list of validated test methods. The WordPerfect file is called
G-015.WPF. The file should be downloaded to your computer's hard
drive or to a particular disk, wherever you, as a user, wish to
place your file. See Appendix B for the materials that can be
obtained through the EMTIC BBS.
C-4
-------
APPENDIX D
Options for Estimating HAP Emissions Below
the Detection Limit of the Measurement Method
-------
-------
Options for Estimating HAP Emissions Below the Detection Limit
of the Measurement Method
Should a HAP known to be emitted be emitted at levels below
the test method detection limit, the applicant has several
options for quantifying those emissions. These options are
explained below.
• Base-Year Emissions Below the Detection Limit
The applicant may use another estimation method,
such as engineering calculations or material
balance data, to document an "actual" emission
level.
The applicant may use the detection limit of the
method to establish emissions. This should only
'be used if no emissions reduction will be claimed
for the emission point, and emissions from the
base year to the post-reduction year have not
increased (i.e., the post-reduction emissions
value must be the same as the base-year emissions
value).
The applicant may use the post-reduction emissions
value for the base-year emissions estimate. This
should be used only if post-reduction emissions of
the HAP have been detected and measured by a
method more sensitive than the method used for
base-year emissions, and if post-reduction
emission levels can be shown to be the same or
less than base year levels.
• Post-Reduction Emissions Below the Detection Limit
The applicant may assume an emissions level equal
to the detection limit of the method for the HAP
in question.
Where emission controls have been applied, it may
be possible to deduce post-reduction emissions for
a nondetectable HAP by using the same percent
reduction as was achieved on another similar
compound that was detected in the emission stream
(the applicant must show the control would be
expected to achieve the same reduction on both the
detectable and nondetectable HAP).
The applicant may use another emissions estimation
method to quantify "actual" emissions of the HAP.
The alternate method must be documented as a
valid, accurate means of estimating the HAP
emissions.
D-l
-------
Both Base-Year and Post-Reduction Emissions Below the
Detection Limit
The applicant may use another emissions estimation
method to quantify "actual" emissions of the HAP.
The alternate method must be documented as a
valid, accurate means of estimating the HAP
emissions.
The applicant may use the detection limit of the
test method to establish emissions, provided the
base-year and post-reduction estimate is the same.
Where a more sensitive test method (i.e., lower
HAP detection limit) is used for post-reduction
emissions compared to the method used to measure
base-year emissions, the applicant cannot use the
detection limits of the respective methods to
establish emissions. This would produce an
emissions reduction solely due to the differing
'detection limits of the methods. In such cases,
the applicant may use the detection limit of
either test method to establish both base-year and
post-reduction emissions. The applicant should
provide evidence that emissions have not increased
from the base year to the post-reduction year.
D-2
-------
APPENDIX E
Emissions from Startups, Shutdowns, and Malfunctions
-------
-------
Emissions from Startups, Shutdowns, and Malfunctions
The purpose of this appendix is to discuss how startup,
shutdown, and malfunction emissions from an early reductions
source may be handled in the Specialty Permit.
The definition of "actual emissions" in the Early Reductions
Rule does not include excess emissions from a malfunction or
startup and shutdown associated with a malfunction [§63.71].
Only emissions from "routine" startups and shutdowns, such as
those due to plant turn-around or routine maintenance, can be
considered part of the emissions from an early reductions source
and, therefore, eligible for a compliance extension. Malfunction
emissions of HAPs would be subject to the requirements of the
general provisions under title 40, part 63 of the Code of Federal
Regulations.
The Specialty Permit applicant has two choices for handling
emissions from routine startups and shutdowns: either consider
such emissions to be part of the early reductions source, or
exclude them from the source. If the applicant considers such
emissions to be part of the source, these emissions need to be
quantified and included in the base-year emissions, demonstration
of post-reduction emissions, and periodic calculation of
emissions for compliance and reporting purposes. The applicant
should make clear in the submission of base-year emissions that
startup and shutdown emissions have been included. The applicant
should also make clear in the permit application how such
emissions will be quantified and calculated into the periodic
computation of total source emissions.
Regardless of whether an applicant considers routine startup
and shutdown emissions to be part of the early reductions source,
the applicant will be required to prepare a Startup, Shutdown,
and Malfunction Plan within a year of issuance of the specialty
permit. This plan would include procedures for operating and
maintaining the source during periods of startup, shutdown, and
malfunction, and a program of corrective action for
malfunctioning process and air pollution equipment. If an
applicant includes routine startup and shutdown emissions in the
E-l
-------
early reductions source, then the Startup, Shutdown, and
Malfunction Plan need only address malfunction emissions and any
startup and shutdown emissions associated with a malfunction (if
any) . The requirement for this plan is part of the NESHAP
General Provisions [§63.6(e)(3)] and applies to all sources
subject to a section 112 standard. Such a startup/shutdown/
malfunction plan would not be part of a Specialty Permit.
As EPA reviews base-year submittals and permit applications,
a determination will be made on which approach the applicant
selected for handling startup and shutdown conditions. Specialty
Permit terms and conditions will therefore reflect this
determination. If the applicant did consider these emissions
part of the source, the permit will specify, based on the
proposed terms in the application, how such emissions should be
quantified and summed into the periodic calculation of total
emissions. If an applicant did not consider such emissions to be
part of the source, emissions from routine startups and shutdowns
will not be counted against the AEL.
E-2
-------
APPENDIX F
Review Checklist for Permit Applications
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APPENDIX G
EXAMPLE DRAFT SPECIALITY PERMIT
-------
-------
DRAFT
TITLE V SPECIALTY PERMIT
Company Name:
Mailing Address:
Company Representative(s):
Phone Number:
SIC Number:
Facility Type:
Facility Location:
Permit No.:
Type of Permit:
Application Date:
Permit Effective Date:
(Date of Issuance)
Expiration Date:
Permitting Authority:
Regional Office Contact:
The XYZ Chemical Company
8910 Industrial Park Drive,
Raleigh, NC
Mr. Joe Smith, Technical Contact
Mr. George Jones, Plant Manager
(919) 555-0000
0286
X Permanent
..Temporary
8901 Industrial Park Drive,
Raleigh, NC
Early Reductions Specialty Permit
April 1, 1994
Environmental Protection Agency
Region IV
Director, Air, Pesticides, and
Toxics Management Division
G-I
-------
-------
CONTENTS
SECTION A: SOURCE IDENTIFICATION G-l
SECTION B: SPECIFIC CONDITIONS . . . G-3
1. Alternative Emission Limitations (AEL's) G-3
2. Other Specific Conditions G-4
3. Monitoring Requirements G-4
4. Recordkeeping Requirements . . G-5
5. Reporting Requirements . . G-6
6. Emission Calculation Procedures G-14
7. Compliance Certification . G-19
8. Alternative Operating Scenarios G-20
9. Permit Shield G-20
SECTION C: GENERAL CONDITIONS G-21
1. Annual Fee Payment G-21
2. Permit Renewal and Expiration G-21
3. Transfer of Ownership or Operation . G-21
4. Property Rights G-22
5. Operation and Maintenance Requirements . . . . .G-22
6. General Provisions Requirements G-26
7. Submissions G-26
8. Inspection and Entry G-27
9. Compliance G-27
10. ' Duty to Provide Information G-28
11. Duty to Supplement or Correct G-28
12. Excess Emissions Due to an Emergency G-28
13. Reopening for Cause G-29
14. Severability Clause G-29
15. Emission Reductions from Equipment Shutdown or
Reduced Operation ... G-30
16. Permit Deviations G-30
17. Permit Revisions G-30
SITE PLAN ............... G-32
G-II
-------
-------
DRAFT
TITLE V SPECIALTY PERMIT
AIR PERMIT NO.
Permit Effective Date:
(Date of Issuance)
Expiration Date:
SECTION A: SOURCE IDENTIFICATION
In accordance with section 112(i)(5) of the Clean Air Act, as
amended; title 40, part 63, subpart D of the Code of Federal
Regulations; and title 40, part 71, subpart B of the Code of
Federal Regulations, the permittee
THE XYZ CHEMICAL COMPANY, RALEIGH, NC
is hereby authorized to operate air emission units and control
equipment comprising the Early Reductions Source, which includes
the emission units and associated equipment listed in Table A-l,
in accordance with the specific and general conditions of this
permit.
Table A-l. Emission Unit Identification
Emission Unit
Thermal Oxidizer - The following vent
is routed to TO-1: Air Oxidation Unit
I
EO-1 Carbon Dioxide Vent - Process Vent
Condenser - The following unit is
routed to C-l: Px Loading/ Paraxylene
Rail Car Loading
Xylene/Ethylbenzene - Storage Tank
Condenser - The following unit is
routed to C-2: Steam Stripper;
Wastewater effluent is hard piped to
the steam stripper
ID #
TO-1
PV-2
C-l
S-l
C-2
This permit is based on information contained in the application
dated April 29, 1994 received from The XYZ Chemical Company, on
any plans, specifications, previous applications, data referenced
by that application, and other information submitted in support
G-l
-------
of that application, all of which are filed with the EPA
Region IV Office in Atlanta, Georgia (the Permitting Authority)
The emission units comprising the Early Reductions Source
described are also identified in the diagram attached to this
permit.
G-2
-------
SECTION B: SPECIFIC CONDITIONS
In accordance with section 112(i)(5) of the Clean Air Act and
title 40, part 63, subpart D of the Code of Federal Regulations
(Early Reductions Rule), this permit grants each emission unit in
the Early Reductions Source a six-year extension from the
compliance date of the otherwise applicable standard(s)
promulgated under section 112(d) of the Clean Air Act. In lieu
of complying with applicable section 112(d) standard(s), The XYZ
Chemical Company accepts the following Alternative Emission
Limitations (AEL's), monitoring, recordkeeping, emission
calculation, and reporting requirements for the Early Reductions
Source. In addition to implementing a compliance extension
granted under title 40, part 63, subpart D of the Code of Federal
Regulations, this permit also implements the General Provisions
requirements of title 40, part 63, subpart A of the Code of
Federal Regulations for each emission unit in the Early
Reductions Source.
1. Alternative Emission Limitations (AEL's)
The AEL's for the Early Reductions Source described in Section A
are:
22.52 Mg/calendar year of Total Gaseous Hazardous Air Pollutants
72.28 Mg/calendar year of Weighted Gaseous Hazardous Air
Pollutants
The AEL's shall be effective until six years after the compliance
date for the last standard promulgated under section 112(d) of
the Clean Air Act that is applicable to any emission unit in the
Early Reductions Source.1 The AEL's shall expire on
April 22, 2003, (six years after April 22, 1997, the applicable
compliance date for emission units in the Early Reductions
Source, which are subject to the National Emission Standards for
Organic Hazardous Air Pollutants from the Organic Hazardous Air
Pollutants from the Synthetic Organic Chemical Manufacturing
Industry).
1. Note that the compliance extension for each emission unit
included in the Early Reductions Source expires six years
after the compliance date of an applicable
section 112(d) standard. However, the AEL's do not expire
until six years after the compliance date for the last
section 112(d) standard that applies to the Early
Reductions Source. Therefore, periods of time may occur
when emissions from certain units are: (a) subject to an
applicable section 112(d) standard; and (b) included in
determining compliance with the AEL's.
G-3
-------
The AEL's will be effective beyond the term of this permit and
therefore, the AEL's shall be renewed when this permit is
'incorporated into the facility's comprehensive title V permit.
Compliance with the AEL's shall be determined on a calendar year
basis by summing hazardous air pollutant (HAP) emissions from
each emission unit included in the Early Reductions Source for
each semiannual period during the calendar year. Semiannual
emissions shall be determined in accordance with section B.6 of
this permit.
2. Other Specific Conditions
Each emission unit in the Early Reductions Source shall be
uniquely identified such as through a tag, label, or other
marking on the equipment or shall be uniquely identifiable from a
plot plan or other drawings available at the Early Reductions
Source.
The XYZ Company shall meet the following other specific
conditions:
a. Emission unit PV-1, the air oxidation unit 1 vent, is
routed to a thermal oxidizer (TO-1)
b. Emission unit L-l, the paraxylene loading operation
• vent, is routed to a condenser (C-l). When the exit
stream temperature of condenser (C-l) exceeds a
temperature of 32°F, the loading pumps will
automatically stop and an audible alarm will be sounded
to alert the process operator.
c. Emission unit WW-1, the wastewater effluent, is hard-
piped to a steam stripper (STST-1). The steam stripper
vent is routed to a condenser (C-2).
3. Monitoring Requirements
For emission units included in the Early Reductions Source, the
permittee shall monitor and keep records of the parameters
indicated in Table B-l below. To ensure that the monitoring
equipment meets the accuracy requirements specified in Table B-l
below, all monitoring equipment shall be installed, calibrated,
and maintained.
a. According to the manufacturer's specifications, or
other written procedures that provide adequate
assurance that the equipment would reasonably be
expected to monitor accurately;
G-4
-------
b. In a manner consistent with good air pollution control
practices during all periods while emissions are
generated.
Monitoring equipment shall be maintained to provide valid
monitoring data for at least 75 percent of the total operating
time of each significant emission unit, consisting of units TO-1,
C-l, S-l, and C-2. Data obtained from properly functioning
monitoring equipment that meets applicable accuracy requirements
shall be considered valid.
4. Recordkeeping Requirements
The permittee shall keep copies of all applicable reports and
records required under this permit for at least 5 years. All
applicable records shall be maintained in such a manner that they
can be readily accessed. The most recent 2 years of records
shall be maintained on site, at the Early Reductions Source, or
shall be accessible from a central location by computer. The
remaining 3 years of records may be retained offsite. Records
may be maintained in hard copy or computer-readable form
including, but not limited to, paper, microfilm, computer, floppy
disk, magnetic tape, or microfiche. The permittee shall keep the
following records relating to emission units included in the
Early Reductions Source:
a. Records of the monitoring parameters indicated in Table
B-l;
b. Records of the supporting calculations used to
determine semiannual HAP and weighted HAP emissions;
c. Records of the occurrence and duration of each startup,
shutdown, and malfunction of operation of an emission
unit within the Early Reductions Source;
d. Records of the occurrence, duration/ and cause (if
known) of each malfunction of air pollution equipment
or monitoring equipment used to comply with the AEL's
or monitoring provisions of this permit;
e. After the effective date of the permittee's startup,
shutdown, and malfunction plan (see section C.B.b) and
for each startup, shutdown or malfunction that occurs
after that date, records indicating that the procedures
in the permittee's startup, shutdown, and malfunction
plan were followed, and documentation of actions taken
that are not consistent with the plan; and
f. For monitoring equipment used to comply with the
monitoring requirements of this permit, records
G-5
-------
do alimenting the completion of installation, calibration
checks, and maintenance.
5. Reporting Requirements
The XYZ Company shall submit to the permitting authority
semiannual reports of the performance of the Early Reductions
Source, one for each half of the calendar year. The semiannual
reports shall be submitted to the permitting authority within
thirty-one days after the end of the six-month period covered
(July 31 for the report covering January 1 through June 30 and
January 31 for the report covering July 1 through December 31).
The format of the semiannual emissions report is displayed on
page(s) following Table B-l below. The XYZ Company shall submit
to the permitting authority semiannual reports for the Early
Reductions Source as follows:
a. The first semiannual report for a calendar year,
covering January 1 through June 30, shall include:
(i)
(ii)
(iii)
A description of any deviations from permit
requirements that occurred during the
reporting period and that were not previously
reported, the probable cause of such
deviations, and corrective actions or
preventive measures taken;
A description of any malfunction of
processes, air pollution control equipment,
or monitoring equipment that occurred during
the reporting period, the date and duration
of the incidents, and the probable cause and
actions taken to remediate such incidents;
and
Either:
total HAP emissions for the Early
Reductions Source for the first half of
the calendar year, as determined by
using the calculation procedures
described in section B.6;
or
except for the first semiannual report
submitted under this permit, a
certification by a responsible official
that total HAP emissions from the Early
Reductions Source during the reporting
period would be 40 percent or less of
the AEL's (less than 9.01 Mg of gaseous
HAP's and 28.91 Mg of weighted gaseous
HAP's), based on the results of
monitoring for emission units TO-1, C-l,
G-6
-------
b.
S-l and C-2 and information related to
emissions for the other emission units
in the Early Reductions Source.
The second semiannual report for a calendar year,
covering July 1 through December 31 shall include:
(i) A description of any deviations from permit
requirements that occurred during the
reporting period and that were not previously
reported, the probable cause of such
deviations, and corrective actions or
preventive measures taken;
(ii) A description of any malfunction or
processes, air pollution control equipment or
monitoring equipment that occurred during the
six-month reporting period, the date and
duration of the incidents, and the probable
cause of the incidents, and actions taken to
remediate such incidents;
(iii) Total HAP emissions for the Early Reductions
Source for the second half of the calendar
year (or for the entire calendar year if
emissions were not reported for the first
six-months of the calendar year in the
previous semiannual report), as determined by
using the calculation procedures in
section B.6; and
(iv) A certification for the calendar year
reporting period of the Early Reductions
Source's compliance with respect to the AEL's
and all other terms and conditions of this
permit. The certification shall include
identification of each term or condition that
is the basis of the certification, the
compliance status, and whether compliance was
continuous or intermittent (except for the
AEL's).
The first semiannual report submitted under this permit must
contain HAP emissions for the calendar half year, or for the full
year (if it is the first report under this permit) and all
supporting calculations for HAP emissions. After the first
semiannual emissions report, a certification statement may be
substituted for the report covering the first six-month period of
a calendar year (see section B.5.a.(iii) above). If the
permitting authority determines that these calculations are
deficient or incomplete, the permittee shall correct the
deficiencies and resubmit the calculations. Supporting
G-7
-------
calculations for HAP emissions will be required in subsequent
reports only when an alternative method need be included. Any
violation of an AEL shall be reported (by phone call or facsimile
transmission) to the permitting authority within 24 hours of
detection. This initial notification shall be followed by
written notification within 30 days.
G-8
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-------
EARLY REDUCTIONS SEMIANNUAL EMISSIONS REPORT FOR
THE XYZ CHEMICAL COMPANY, RALEIGH, NC
AIR PERMIT NO.:
Date:
Semiannual Period:
Total Emissions For This Semiannual Period:
SEMIANNUAL
PERIOD
TOTAL
HAP EMISSIONS
(Mg)
WEIGHTED HAP
EMISSIONS (Mg)
AEL's:
22.52 Megaarams/calendar year of unweighted HAP's
72.28 Megagrams/calendar year of weighted HAP's
Detailed Description Of Emissions For This Semiannual
Period:
EMISSION UNIT
ID #
TO-1
PV-2
C-l
S-l
C-2
HAP EMISSIONS
(Mg)
WEIGHTED HAP
EMISSIONS (Mg)
G-13
-------
-------
6.
Emission Calculation Procedures
The calculation procedures described below shall be used to
quantify emissions from each emission unit. Total unweighted HAP
emissions shall be computed by calculating the emissions from
each emission unit as specified in this section and then summing
the emissions from each emission unit.
Total weighted emissions for each emission unit shall be
calculated by multiplying the calculated pollutant-specific
emissions by the appropriate weighting factor for the pollutant
and then summing all weighted emissions data. The following
equation shall be used to calculate total weighted emissions:
where,
WE
E;
F: =
total weighted emissions,
total unweighted emissions of pollutant i from all
emission units, and
weighting factor for pollutant i (obtained from
Table 1 in title 40, section 63.74 of the Code of
Federal Regulations).
Data recorded during an emergency or malfunction (either of the
process equipment, emission reduction equipment, or monitors)
shall not be used in determining actual emissions. Actual
emissions for such periods shall be calculated as if there were
no emergency or malfunction (i.e., assuming the equipment had
operated normally). However, periods of excess emissions, not
due to an emergency or malfunction, must be calculated and
reported as actual emissions.
The XYZ Company shall use the weighting factors listed in
Table B-2 to compute weighted emissions:
Table B-2. HAP Weighting Factors
HAP
Benzene
Ethylene Oxide
p-Xylene
Xylene
Ethylbenzene
CAS #
71432
75218
106423
95476
100414
M. W.
78
44
106
106
106
Weighting Factor
10
10
1
1
1
G-14
-------
Emission Calculation Procedures for TO-1
Semiannual HAP emissions from TO-1 shall be determined using the
number of hours TO-1 was operated within each of four firebox
temperature ranges listed below, along with temperature-dependent
emission factors. Hourly-average firebox temperature shall be
obtained from the Data Acquisition System interfaced to Type K
thermocouple.
The following emission factors shall be used for emission
calculations:
Firebox Temperature
Range (°F)
Emission
Factor
(kg/hr)
Temp >. 1600
1600 > Temp .> 1400
1400 > Temp >. 1200
1200 > Temp(uncontrolled
operation)
0.126
0.314
0.440
7.177
Semiannual HAP emissions from TO-1 shall be calculated by adding
semiannual controlled and semiannual uncontrolled emissions.
Semiannual controlled emissions shall be calculated by
multiplying the number of hours TO-1 was operated within a given
temperature range by the corresponding emission factor.
Semiannual uncontrolled emissions shall be computed by
multiplying the number of hours process gas was routed to an
uncontrolled vent by the emission factor for uncontrolled
operation.
Emission Calculation Procedures for PV-2
Semiannual HAP emissions from PV-2 shall be assumed to be
0.0575 Mg.
Emission Calculation Procedures for C-l
Semiannual HAP emissions from C-l shall be determined by
multiplying the quantity of p-xylene (kg) loaded during the
semiannual period by loading emission factor presented below:
0.0043 kg of p-xylene emissions per 1000 kg of p-xylene
loaded
G-15
-------
Emission Calculation Procedures for S-l
Semiannual HAP emissions from emission unit S-l shall be
determined using the emission calculation procedures shown below.
Individual transfers into tank S-l during a semiannual period
shall be summed to obtain the semiannual throughput. The
semiannual throughput shall be used to compute semiannual
emissions.
LT =
LD
where,
LT
Lw
total loss (Mg/semiannual period),
withdrawal loss (Mg/semiannual period),
0.943QCWL
2205D
LE = 0 . 5 KR D P*
2205 P
LF = 0.5 FF
2205 P
= 0.5 SD KDD2
2205 P
D
Q
C
N
rim seal loss (Mg/semiannual period),
fitting loss (Mg/semiannual period),
deck seam loss (Mg/semiannual period),
tank diameter (ft) ,
product average throughput (bbl/semiannual period),
product withdrawal shell clingage factor
(bbl/103 ft2) ,
density of the product (Ib/gal),
number of columns (dimensionless),
effective column diameter (ft),
rim seal loss factor (Ib mole/ft yr),
-------
p
Pi
the vapor pressure function (dimensionless)
s (P/PA) /((!+(!- P/PA) °'5)2), .
true vapor pressure of the material stored (psia),
« partial pressure of the specific HAP (psia),
= atmospheric pressure (psia),
- average molecular weight of the stored material
vapor (Ib/lb-mole),
= product factor =1.0 for volatile organic HAP's,
= deck seam length factor (ft/ft2) ,
- deck seam loss factor, and
« the total deck fitting loss factor (Ib mole/yr)
NFi KF1
where ,
NFi
n
» number of fittings of a particular type
(dimensionless),
- deck fitting loss factor for a particular type
fitting (Ib mole/yr), and
» number of different types of fittings
(dimensionless).
The equations presented above shall be used to establish
emissions from freely vented internal floating roof tanks in
conjunction with the following tank design information presented
in Table B-3 below, unless otherwise approved by the permitting
authority:
Table B-3. Tank Design Data
Tank Parameter
Tank Internal Diameter (D, ft)
Rim Seal Type
Number of Columns (Nc)
Effective column diameter (Fc,
ft)
Tank Capacity (gal)
Diurnal Temperature Change (°F)
Rim seal loss factor (KR, Ib
mole/ft yr)
Product Factor (KC)
S-l
100
Liquid mounted primary seal
plus secondary seal
7
1
2,820,000
9.5
1.61'2
1
G-17
-------
Table B-3. Tank Design Data (continued)
Tank Parameter
Shell Clingage Factor (C,
bbl/1000 ft)
Deck Fitting Loss Factor (FF)
Deck Seam Loss Factor (KD, Ib-
mole/ft yr)
Deck Seam Length Factor (FD)
S-l
0.0015
600
0.34
0.2
1 When annual visual inspections of the secondary rim seal
reveal gaps between the rim seal and the tank wall, it shall
be assumed that the internal floating roof is equipped with
only a primary, liquid-mounted rim seal. The rim seal loss
factor shall then be taken as 3.0. This factor shall be
used.to calculate emissions for the semiannual period in
which a defect in the secondary seal is detected and for
subsequent semiannual periods until the defect is fixed.
2 When visual inspections of the primary rim seal, gaskets,
and slotted membranes reveal gaps between the rim seal and
the tank wall or inability of gaskets to close off liquid
surface or greater than 10 percent open area in slotted
membranes, it shall be assumed that the internal floating
roof is equipped with only a primary, vapor-mounted rim
seal. The rim seal loss factor shall be taken as 6.7. This
factor shall be used to calculate emissions for the
semiannual period in which a defect in the primary seal or
gaskets or slotted membranes is detected and for subsequent
semiannual periods until the defect is fixed.
The vapor pressure, P, of the material stored in tank S-l shall
be obtained from recordkeeping requirement.
Emissions Calculation Procedures for C-2
Semiannual HAP emissions from C-2 shall be determined using the
number of hours STST-1 steam stripper was operated within each of
the three steam-to-feed ratio ranges shown below along with
steam-to-feed ratio dependent emission factors.
The following emission factors shall be used in emission
calculations:
-18
-------
Steam-to-Feed Ratio
(kg/kg)
Methanol Emission
Factor
steam-to-feed ratio
> 0.12
0.12 > steam-to-feed ratio
ii 0.09
0.09 > steam-to-feed ratio
(uncontrolled operation)
1.24 kg/hr
1.36 kg/hr
12.4 kg/hr
Steam-to-Feed Ratio
(kg/kg)
Methyl Chloride
Emission Factor
steam-to-feed ratio
> 0.12
0.12,> steam-to-feed ratio
> 0.09
0.09 > steam-to-feed ratio
(uncontrolled operation)
0.03 kg/hr
0.04 kg/hr
4.5 kg/hr
The hourly wastewater feed mass flow rate shall be determined by
dividing .the hourly volumetric flow data obtained from the
rotameter by the density of wastewater (8.34 Ib/gal). The hourly
steam mass flow rate shall be determined using hourly volumetric
flow rate obtained from the orifice pressure gauge, the hourly
steam temperature, and steam tables such as those found in the
Chemical Engineers' Handbook published by McGraw-Hill. The
hourly steam-to-feed ratio is the ratio of hourly steam mass flow
rate to hourly wastewater feed mass flow rate. Semiannual HAP
emissions from C-2 shall be calculated by multiplying the number
of hours STST-1 was operated within a given steam-to-feed ratio
range by the corresponding emission factor.
The steam stripper shall be considered to be at the uncontrolled
condition when the average hourly steam-to-feed ratio is lower
than 0.09 kg/kg, or the average daily wastewater feed temperature
is lower than 35°C, or the average daily temperature of the
overheads condenser outlet is higher than 50°C.
7. Compliance Certification
The permittee shall certify annually that the Early Reductions
Source has complied with the requirements of this permit. The
certification shall describe the following:
a. the permit terms or conditions that constitute the
basis of the certification; and
G-19
-------
b. the compliance status for the preceding calendar year,
including whether compliance was continuous or
intermittent (except for the AELs').
The compliance certification shall be signed by a responsible
official as defined by title 40, section 71.22 of the Code of
Federal Regulations. The compliance certification shall be
submitted to the permitting authority.
8. Alternative Operating Scenarios
Since The XYZ Company has not identified any alternative
operating scenarios, any changes to the methods of operation
identified in this permit will require a permit revision (see
section C.17).
9.
Permit Shield
Compliance with the terms and conditions of this permit shall be
deemed compliance with title 40, part 63, subpart D of the Code
of Federal Regulations, the Early Reductions Rule. In addition:
a. Nothing in this permit shall alter or affect: (i) the
liability of the Early Reductions Source for any
violation of applicable requirements, prior to or at
the time of permit issuance; (ii) applicable acid rain
requirements; (iii) the ability of the EPA to obtain
information under section 114; (iv) provisions of
sections 112(r) and 303 of the Clean Air Act (emergency
orders); or (v) provisions of title 40,
section 63.1(a)(3) of the Code of Federal Regulations.
b. Issuance of this permit does not relieve the Early
Reductions Source from an obligation to file a timely
and complete permit application for a comprehensive
title V permit as required under an approved title V
permit program. Such an application shall reference
this permit, and this permit subsequently will be
incorporated into a comprehensive title V permit issued
to The XYZ Company.
c. In accordance with title 40, section 71.25(d)(2) of the
Code of Federal Regulations, the permit shield is
extended to all permit terms and conditions for
alternate operating scenarios or those that allow
increases and decreases in hazardous air pollutant
emissions pursuant to emissions trading provisions.
G-20
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SECTION C: GENERAL CONDITIONS
1. Annual Fee Payment
The permittee is not required to pay a fee for this specialty
permit issued under the authority of title 40, part 71 of the
Code of Federal Regulations. However, a State may establish a
permit fee under title 40, part 70 of the Code of Federal
Regulations, once the State receives approval of their title V
permit program as authorized by the Clean Air Act Amendments of
1990.
2. Permit Renewal and Expiration
a. This permit is issued for a term of five years and
shall expire on (date: five years after permit
issuance), except as provided in paragraph "b" below.
However, the compliance extension and AEL's in this
permit have been granted to extend beyond this five-
year term, to April 22, 2003. Therefore, upon or
before expiration, the terms and conditions of this
permit shall be renewed through incorporation into a
comprehensive permit issued to the facility containing
the Early Reductions Source by a State/local program
approved under title V of the Clean Air Act or a
Federal program under title 40, part 71, subpart B of
the Code of Federal Regulations. Once this specialty
permit has been incorporated into the facility's
comprehensive title V permit, the appropriate
State/local agency will be designated as the permitting
authority.
b. In the event that a timely and complete application for
a comprehensive title V permit has been submitted but
the permitting authority has failed to issue or deny
the comprehensive permit prior to expiration of this
permit, this permit shall not expire until the
comprehensive permit for the facility containing the
Early Reductions Source has been issued or denied.
3. Transfer of Ownership or Operation
Title 40, section 71.26(c)(1)(iv) of the Code of Federal
Regulations specifies that a change in ownership or operational
control of this Early Reductions Source shall be treated as an
administrative permit amendment provided that no other change in
the permit is required and a written agreement has been submitted
to the permitting authority identifying the specific date for
transfer of permit responsibility, coverage, and liability
between the current and new permittee. If these stipulations are
G-21
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not met, the new owner or operator shall obtain a new permit from
the permitting authority.
4. Property Rights
This permit does not convey any property rights of any sort, or
any exclusive privilege.
5. Operation and Maintenance Requirements
a. General Requirements
(i)
(ii) '
(iii)
(iv)
(v)
The operation and maintenance requirements in
this section are enforceable, independent_
from the other terms and conditions of this
permit, including the alternative emissions
limitations.
At all times, including periods of startup,
shutdown, and malfunction, the permittee
shall operate and maintain the Early
Reductions Source, including associated_air
pollution control equipment and monitoring
equipment, in a manner consistent with good
air pollution control practices for
minimizing emissions.
After a startup, shutdown, and malfunction
plan is developed and implemented as
described in paragraph "b" below, the
permittee shall operate and maintain the
Early Reductions Source (including associated
air pollution control equipment and
monitoring equipment) during periods of
startup, shutdown, and malfunction in
accordance with the procedures specified in
such plan.
Before and after a plan is in place, the_
permittee shall ensure that any malfunction
that occurs is repaired as soon as
practicable after its occurrence. To ensure
immediate repair or parts replacement _ for
routine monitoring equipment malfunctions
identified by the plan, the permittee shall
keep the spare parts necessary for routine
repairs of the affected equipment readily
available at the Early Reductions Source.
The permitting authority will determine
whether the operation and maintenance
procedures being used by the Early Reductions
G-22
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c.
Source are acceptable based on information
available to the permitting authority. This
information may include, but is not limited
to, monitoring results, review of operation
and maintenance procedures (including
procedures specified in the startup,
shutdown, and malfunction plan), review of
operation and maintenance records, and
inspection of the Early Reductions Source.
Startup, Shutdown, ,and Malfunction Plan
The permittee shall develop and implement, no later
than one year after permit issuance, a written startup,
shutdown, and malfunction plan (plan) that describes in
detail procedures for operating and maintaining the
Early Reductions Source during periods of startup,
shutdown, and malfunction (an event), and a program of
action_for correcting the malfunctioning processes, air
•pollution control equipment and monitoring equipment
covered by this permit. The plan shall also identify
all routine or otherwise predictable malfunctions of
air pollution control equipment and monitoring
equipment required by this permit. For the identified
malfunctions, the plan shall specify procedures for
repairing control equipment malfunctions as soon as
possible and for repairing or replacing malfunctioning
monitoring equipment immediately.
In developing a startup, shutdown, and malfunction
plan, the permittee may use the Early Reduction
Source's standard operating procedures manual, or an
Occupational Safety and Health Administration or other
plan meeting all the requirements for a startup,
shutdown, and malfunction plan specified by this
permit. The permittee shall comply with the plan at
all times during Early Reductions Source operation.
Startup, Shutdown, and Malfunction Recordkeeping and
Report ing Requi rement s
(i)
Recordkeeping Requirements
When actions taken by the permittee during a
startup, shutdown, or malfunction (including
actions to correct a malfunction) are
consistent with the procedures specified in
the affected Early Reductions Source's
startup, shutdown, and malfunction plan, the
permittee shall keep records for that event
demonstrating that the procedures specified
in the plan were followed. These records may
G-23
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(ii)
take the form of a "checklist," or other
effective form of recordkeeping, which
confirms that the procedures and other
specifications of the startup, shutdown, and
malfunction plan were followed during that
event. In addition, the permittee shall keep
records of the occurrence and duration of
each startup, shutdown, or malfunction of
operation and each malfunction of air
pollution control equipment or monitoring
equipment.
If an action taken by the permittee during a
startup, shutdown, or malfunction (including
an action taken to correct a malfunction) _ is
not consistent with the procedures specified
in the Early Reduction Source's startup,
shutdown, and malfunction plan, the permittee
shall record the actions taken for that
event.
The permittee shall keep the written startup,
shutdown, and malfunction plan on record
after it is developed, to be made available
for inspection, upon request, by the
permitting authority for the life of the
Early Reductions Source or until the Early
Reductions Source is no longer subject to any
provisions of title 40, part 63 of the_Code
of Federal Regulations. In addition, if the
startup, shutdown, and malfunction plan is
revised, the permittee shall keep previous
(i.e. superseded) versions of the startup,
shutdown, and malfunction plan on record, to
be made available for inspection, upon
request by the permitting authority, for a
period of 5 years after each revision of the
plan.
Reporting Requirements
When the permittee takes actions during an
event that are consistent with the plan, the
permittee shall confirm in the next
semiannual emission report that actions taken
during the relevant reporting period during
periods of startup, shutdown, and
malfunction, were consistent with the Early
Reduction Source's startup, shutdown and
malfunction plan.
G-24
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When the permittee takes actions (or fails to
take actions) during an event, and such
actions (or inactions! affect a significant
emission unit, as identified in section B.3
of this permit, (or the control equipment or
monitoring equipment for such unit) and are
inconsistent with the terms of the plan, the
permittee shall report the actions taken for
that event by a telephone call (or facsimile
[FAX] transmission) made to the permitting
authority within 2 working days after
commencing actions inconsistent with the plan
followed by a letter within 30 days after the
end of the event. This report shall fully
describe the event and all remedial actions
taken during the event's duration.
Additionally, when malfunctioning monitoring
equipment is involved in an event, such
report shall either certify that the
malfunctioning monitoring equipment has been
repaired, or shall include a plan of action
for repairing such equipment as soon as
possible.
d. Revision of the Startup, Shutdown, and Malfunction Plan
The EPA may require reasonable revisions to a plan if
it finds that the plan:
(i)
(ii)
(iii)
Does not address a startup, shutdown, or
malfunction event that has occurred;
Fails to provide for the operation of the
Early Reductions Source (including associated
air_pollution control equipment and
monitoring equipment) during a startup,
shutdown, or malfunction event in a manner
consistent with good air pollution control
practices for minimizing emissions at least
to the levels required for compliance with
the AEL's and other terms of this permit; or
Does not provide adequate procedures for
correcting malfunctioning process and/or air
pollution control equipment as quickly as
practicable.
The permittee shall also revise the plan within 45 days
after the_occurrence of an event that meets the
characteristics of a malfunction but was not addressed
or was inadequately addressed in the startup, shutdown,
and malfunction plan at the time the plan was
G-25
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developed. The revisions made shall include detailed
procedures for operating and maintaining the Early
Reductions Source during similar malfunction events
and a program of corrective action for similar
malfunctions of process, air pollution control, or
monitoring equipment.
6. General Provisions Requirements
In addition to complying with the terms and conditions of this
permit, the Early Reductions Source shall also comply with tne
provisions of the General Provisions, title 40, part 63,
subpart A of the Code of Federal Regulations shown on Table C-i.
These sections shall apply to the Early Reductions Source as if
they were expressly stated in this permit. Other sections of the
General Provisions not listed in the table or not specifically
incorporated within this permit do not apply to the Early
Reductions Source.
Table C-l.
General Provisions Requirements Incorporated By
Reference
r. '" .1— - — — —
Title 40, part
63, subpart A
CFR Citation
63.2
63.3
63. 4 (b)
63.12
63.13
63.15
__===—=——=—=
Subject
Definitions
Units and Abbreviations
Circumvention
State authority and delegations
Addresses of State Air Pollution Control
Agencies and EPA Regional Offices to which
information submittals are required
Availability of information and
confidentiality
7. Submissions
a Reports, test data, monitoring data, notifications and
applications shall be submitted to the following
agency:
Early Reductions Officer
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
G-26
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b. Any document submitted shall be certified as being
true, accurate and complete by a responsible corporate
official as defined by title 40, section 71.22 of the
Code of Federal Regulations. The certification shall
state that, based on information and belief formed
after reasonable inquiry, the statements and
information in the document are true, accurate, and
complete.
8. Inspection and Entry
Upon presentation of credentials and other documents as may be
required by law, the permittee shall allow authorized
representatives of the permitting authority to perform the
following:
a. enter upon the permittee's premises where a regulated
facility or activity is located or conducted, or where
records must be kept under the conditions of the
•permit,
b. have access to and copy, at reasonable times, any
records that must be kept under conditions of the
permit,
c.
d.
inspect, at reasonable times, facilities, equipment
(including monitoring and control equipment),
practices, or operations regulated or required under
the permit, and
sample or monitor, at reasonable times, substances or
parameters for the purpose of determining compliance
with this permit.
9.
Compliance
The permittee must comply with all of the conditions of this
permit. A violation of an alternative emission limitation, as
well as any other requirement established in this permit, is
subject^to an enforcement order issued under section 113 of the
Clean Air Act. Any permit noncompliance constitutes a violation
of the Clean Air Act and is grounds for enforcement action or for
permit termination, revocation and reissuance, or revision.
It shall not be a defense for a permittee in an enforcement
action that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the
conditions of this permit.
G-27
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10. Duty to Provide Information
The permittee shall furnish to the permitting authority, within a
reasonable time, any information that the permitting Authority
may request in writing to determine whether cause exists for
revising, revoking and reissuing, or terminating the permit, or
to determine compliance with the permit. Upon request, the
permittee shall also furnish to the permitting authority copies
of records that the permittee is required to keep under the
permit, or for information claimed to be confidential, the_
permittee may furnish such records directly to the permitting
authority along with a claim of confidentiality.
11. Duty to Supplement or Correct
The permittee, upon becoming aware that any relevant facts were
omitted or incorrect information was submitted in the permit
application or other information submitted in support of tne
application, shall promptly submit such supplementary facts or
corrected information.
12. Excess Emissions Due to an Emergency
Until such time as the permittee's startup, shutdown, and_ _
malfunction Plan (required under section C.6 of this permit) _is
in effect, the permittee may seek to establish that noncompliance
with the'AEL's under this permit was due to an emergency. To do
so the permittee shall demonstrate the affirmative defense of
emergency through properly signed, contemporaneous operating
logs, or other relevant evidence that:
a. an emergency occurred and that the permittee can
identify the cause(s) of the emergency,
b. the permitted facility was being properly operated at
the time of emergency,
2 An "emergency" means any situation arising from sudden and
reasonably unforeseeable events beyond the control_of this
Early Reductions Source, including acts of God, which
situation requires immediate corrective action to restore
normal operation, and that causes this Early Reductions
Source to exceed an AEL under this permit, due to
unavoidable increases in emissions attributable to the
emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of
preventative maintenance, careless or improper operation, or
operator error.
6-28
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c. during the period of the emergency, the permittee took
all reasonable steps to minimize levels of emissions
that exceeded an AEL or could cause exceedance of an
AEL later in the calendar year, and
d. the permittee submitted notice of the emergency to the
permitting authority within 2 working days of the time
when AEL's were exceeded due to the emergency or within
30 days of the beginning of the emergency for cases
where emissions from the emergency do not immediately
violate the AEL's but would (or may) be responsible for
its violation later in the calendar year. This notice
must_contain a description of the emergency, any steps
to mitigate emissions, and corrective actions taken.
13. Reopening for Cause
The permitting authority will reopen and revise this permit as
necessary to remedy deficiencies in the following circumstances:
The permitting authority determines that this permit
contains a material mistake or inaccurate statements
were made in establishing the AEL's or other terms or
conditions of this permit.
a.
b.
The permitting authority determines that the permit
must be revised or revoked to assure compliance with
the applicable requirements.
Reopenings shall not be initiated before a notice of intent to
reopen is provided to the permittee by the permitting authority
at least 30 days in advance of the date that this permit is to be
reopened, except that the permitting authority may provide a
shorter time period in the case of an emergency.
Proceedings to reopen and modify or issue this permit shall
follow the same procedures that apply to initial permit issuance
and shall affect only those parts of this permit for which cause
to reopen exist. Such reopening shall be made as expeditiously
as practicable.
All permit conditions remain in effect until such time as the
permitting authority takes final action. The filing of a request
by the permittee for a permit revision, revocation and
reissuance, or termination, or of a notification of planned
changes or anticipated noncompliance does not stay any permit
condition. .
14. Severability Clause
The provisions of this permit are severable, and if any provision
of this permit, or the application of- any provision of this
G-29
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permit to any circumstance, is held invalid, the application of
such provision to other circumstances and the remainder of this
"permit, shall not be affected thereby.
15. Emission Reductions from Equipment Shutdown or Reduced
Operation
If emission reductions are achieved by shutting down process
equipment and the shutdown equipment is restarted or replaced
anywhere within the facility containing the Early Red^°*J
Source, any hazardous air pollutant emissions from the restarted
or replacement equipment shall be counted in the post-reduction
emissions from the Early Reductions Source.
If lower rates or hours are used to achieve all or part of the
emission reduction, any hazardous air pollutant emissions that
occur from a compensating increase in rates or hours from the
same activity elsewhere within the plant site which contains the
Early Reductions Source shall be counted in the post-reduction
emissions -from the Early Reductions Source.
16. Permit Deviations
All instances of deviation from permit requirements shall be
reported. Any instance of deviation involving a significant
emission unit, as identified in section B.3 of this_permit, shall
be reported within 30 days of each deviation. Any instance of
deviation involving all other emission units shall be reported
along with the applicable semiannual report. Deviation reports
shall include the probable cause of deviation and any corrective
actions or preventive measures taken.
17. Permit Revisions
After issuance of this permit, permit revision will not be
required for physical changes at the Early Reductions Source that
do not violate the AEL's and do not violate or alter the _
monitoring, recordkeeping, emission calculation, or reporting
requirements stated in section B of this permit. Any other
planned changes to emission units or associated equipment within
the Early Reductions Source that are not accommodated by the
terms and conditions of this permit or any planned changes to the
terms and conditions of this permit cannot be implemented until
the permittee complies with the permit revision/administrative
amendment procedures of the Permits for Early Reductions Sources
Rule, i.e., title 40, part 71, subpart B of the Code of Federal
Regulations (or after this specialty permit is incorporated into
a comprehensive title V permit for the facility containing the
Early Reductions Source, the applicable permit revision
procedures governing such a comprehensive title V permit).
Changes subject to this requirement include:
G-30
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a.
b.
process or operational changes to emission units or
associated air pollution control equipment or
monitoring equipment;
physical changes or additions to emission units or air
pollution control equipment or monitoring equipment;
and
c. changes to any permit term or condition.
G»31
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SITE PLAN
THE XYZ COMPANY
RALEIGH, NC
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I •••••«•••••• ^r
X..
L-l
XYZ Chemical Company Site Plan - Emission Points
Defined as Source A
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APPENDIX H
Example Emissions Reduction Demonstration
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February 1, 1995
Director
.Air, Pesticides, and Toxics Management Division
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Re: Post-Reduction Emissions Demonstration
XYZ Chemical Company
Dear Sir/Madam:
ac
-------
_
a
These post-reduction emissions represent greater than a L 90 '
reduction from base year emissions as requxred to qualify
compliance extension.
I hereby certify the following statements:
• information provided in this submittal represents the best
available emissions data for Source A;
• Emissions data are based on information gathered and the
belief formed after a reasonable inquiry; and
Statements and information in this _ post-reduction
documentation are true, accurate, and complete.
If you have any technical questions regarding the content of this
submittalT Please contact Mr. Joe Smith (Environmental Affairs
Manager) at (919) 555-0000.
Sincerely, ' . .
George S. Jones
Plant Manager
Enclosure
cc: (appropriate) State Regulatory Agency
U.S. EPA Emission Standards Division
U*. S. EPA Office of Enforcement
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4.3 POST-REDUCTION DEMONSTRATION
This section documents the actual emissions from Source A
during the 1994 calendar year. Since Source A made an enforceable
commitment, the post-reduction year is January 1, 1994 through
December 31, 1994. A brief description of the procedures used to
determine emissions from each emission unit is provided in this
section. The monitoring, recordkeeping, and emission calculation
procedures proposed in Section 3 of our permit application
(April 1, 1994) were used to determine emissions. The table
presented below provides a summary of the 1994 annual emissions for
each emission unit.
DESCRIPTION
Air Oxidation
Unit 1 -
process' vent
EO-1 Carbon
Dioxide Vent -
process vent
PX
Loading/ Paraxyl
ene Rail Car
Loading
Xylene/Ethylben
zene - storage
tank
Waste Acid from
the Methyl
Chloride Drying
Tower -
wastewater
effluent
EMISSION
UNIT
ID #
PV-1
PV-2
L-l
S-l
WW-1
TOTAL
AEL
HAP EMISSIONS
(Mg)
4.78
0.23
0.334
0.337
13.05
18.73
22.52
WEIGHTED HAP
EMISSIONS
(Mg)
47.8
2.3
0.334
0.337
13.05
63.82
72.28
H-3
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H-4
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EMISSION UNIT ID: PV-1
POST-REDUCTION EMISSION DEMONSTRATION
Emission Unit Description:
Emission Reduction Measure ID:
Emission Reduction Measure
Description:
Air Oxidation Unit 1
TO-1
Thermal Oxidizer
Emissions from PV-1 were established based on the short-term test
results and control device parameters monitored in 1994. A summary
of these results is presented in Section 4.2 of this permit
application. Test results were used to correlate the firebox
temperature of TO-1 with benzene emissions, which is the only HAP
emitted from PV-1. Emission factors were developed for four
firebox temperature ranges at maximum gas flow from PV-1 to TO-1.
The firebox temperature was monitored using a thermocouple
interfaced to a Honeywell Data Acquisition System. At the end of
each work day, the process operator recorded the date, hours TO-1
operated in each temperature range, hours gas flowed from PV-1 to
TO-1, and the hours of gas flow during periods when TO-1 was not in
operation. A copy of a daily log sheet for PV-1 is attached to
this post-reduction demonstration.
The first step in computing daily HAP emissions was to multiply the
number of hours gas flowed to TO-1 within each temperature range by
the corresponding emission factor. To determine the daily total,
the daily emissions corresponding to each temperature range were
summed. The annual emissions were calculated by multiplying the
number of total number of hours that gas flowed to TO-1 within each
temperature range by the emission factor for the corresponding
firebox temperature. The table below presents the annual emissions
calculations. A summary of the annual emissions is presented on
the following page. Note that the total operating hours is 'less
than 8,760. The difference is accounted for in scheduled and
unscheduled maintenance shut-downs and holidays.
Temperature
Temp :
1600 :
1400 :
1200 :
(°F)
> 1600
> Temp :
> Temp ;
> Temp
Emission
Factor
(kcr/hr-}
i 1400
= 1200
0
0
0
7
.126
.314
.440
.177
X
X
X
X
Hours
IhrsV
3
2
1
,872
,593
,170
412
Annual
Emissions
(Ma)
0
0
0
2
.488
.814
.515
.96
Total:
8,047
4.78
H-5
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PV-1 ANNUAL EMISSIONS
HAP Emissions
(Mg of benzene)
4.78
Weighted HAP Emissions
(Mg of benzene)
47.8
H-6
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EMISSION UNIT ID: PV-2
POST-REDUCTION EMISSION DEMONSTRATION
Emission Unit Description:
Emission Reduction Measure ID:
Emission Reduction Measure
Description:
EO-1 Carbon Dioxide Vent
None
None
Annual emissions from PV-2 are assumed to be 0.23 Mg. This value
represents the maximum emissions from this vent. The emission
factor (i.e. 0.0265 kg/hr) used for the base year estimate, was
multiplied by the maximum number of hours of operation (i.e. 8,760
hrs) . _The emission factor was developed based on the maximum
production rate and as demonstrated in the base year emission
estimate, emissions from PV-2 are directly proportional to the
production rate.
PV-2 ANNUAL EMISSIONS
HAP Emissions
(Mg of ethylene oxide)
0.23
Weighted HAP Emissions
(Mg of ethylene oxide)
2.3
H-7
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EMISSION UNIT ID: L-l
POST-REDUCTION EMISSION DEMONSTRATION
Emission Unit Description:
Emission Reduction Measure
Description:
PX Loading/p-xylene, Rail Car
Loading
Emission Reduction Measure ID: C-l
Refrigerated Condenser
Post-reduction emissions were determined based on short-term test
results. A summary of the test results is presented in Section 4.2
of this permit application. The test results were used to
correlate the condenser exit temperature to HAP emissions, which
yielded a controlled emission factor based on the quantity of
p-xylene loaded. The refrigerated condenser is equipped with an
interlock process control system that prevents rail car loading
when the condenser exit temperature exceeds 32°F. Therefore,
emissions are zero when the condenser exit temperature exceeds
32°F. As discussed in Section 3.3, the quantity of p-xylene loaded
and the condenser exit stream temperature were monitored, and
records were kept of the date of any loading operations and the
total quantity of p-xylene loaded on that day. A copy of a daily
log sheet for L-l is attached to this post-reduction demonstration.
Daily HAP emissions were determined by multiplying the quantity of
p-xylene loaded by the controlled emission factor. Calendar year
1994 HAP emissions were determined by summing the daily quantities
of p-xylene loaded and multiplying this sum by the emission factor.
The emission calculations for L-l is presented below and a summary
of the annual emissions is presented on the following page.
L-l Annual
HAP Emissions
L-l Annual
HAP Emissions
(Kilograms of p-xylene loaded in 1994) x
(emission factor)
(7.77 x 107 kg loaded)
emissions/1,000 kg loaded)
(0.0043 kg
H-8
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L-l ANNUAL EMISSIONS
HAP Emissions
(Mg of p-xylene)
0;334
Weighted HAP Emissions
(Mg of p-xylene)
0.334
H-9
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EMISSION UNIT ID: S-l
POST-REDUCTION EMISSION DEMONSTRATION
Emission Unit Description:
Emission Reduction Measure
Description:
Xylene/Ethylbenzene Storage
Tank
Emission Reduction Measure ID: None
Internal floating roof with
primary and secondary seals
Post-reduction emissions are based on the tank throughput and
procedures provided in AP-42, as modified for the Early Reductions
Program in "Procedures for Establishing Emissions for Early
Reduction. Compliance Extensions" (No. EPA-450/3-91-012a). The
volume transferred to the tank and the condition of the tank and
seals were monitored as discussed in Section 3.3 of this permit
application. After each transfer, the operator logged the date and
gauge reading from the flow accumulator. The date of tank and seal
inspections was recorded including any observed problems. A copy
of a daily log sheet for S-l is attached to this post-reduction
demonstration. Physical properties such as vapor pressure,
chemical composition, and liquid density used in emission
calculations are the same as those used in the base year
calculations. The calculation of xylene emissions from S-l is
shown on the following page. Ethylbenzene emissions, which were
the only other HAP emissions from S-l, were calculated using the
same procedures and inputs except for vapor pressures.
Ethylbenzene emissions and total annual emissions are provided
following the xylene calculations.
H-10
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DETAILED EMISSION CALCULATIONS
Procedures
Internal floating roof tank emission calculations given in
EPA-450/3-91-012a
Parameters
Throughput (Q):
Tank diameter (D):
Shell clingage factor (C):
Density of stored material (W,) :
Number of ' columns (Nc) :
Effective column diameter (F.) :
2,100,420 bbls
100 ft
0.0015
7.00 Ib/gal
7
1 ft
Molecular weight of component i (M^): 106 Ib/lb-mole xylene
106 Ib/lb-mole ethylbenzene
Molecular weight of material
106 Ib/lb-mole
Partial pressure of components i (Pi): 0.0330 psia, xylene
0.131 psia, ethylbenzene
Vapor pressure of material (P):
Vapor pressure function (P*):
Atmospheric pressure (Pa) :
Rim seal loss factor (Kr) :
Deck fitting loss factor (Ff) :
Deck seam loss factor (Kd) :
Deck seam length factor (Fd) :
Product factor (Kc) :
0.164 psia
0.00282
14.6 psia
1.6
819.5
0.34
0.2
1
H-ll
-------
Calculations (Xylene)
Lt
Lw
Lr + Lf
Q.943 O C W.
2205 D
D
=0.943(2.100.420) (0.0015) (7.00) [l+(7? (1)3 ((106) (0.033))
- 2205(100) (100) ((106) (0.164).)
= Q 0203 Mg
Lr = 0.25 K, D P* M.J Kc P}
2205 P
L = (0.25) '(1.6) (100) (0.00282) (106) (1)
Lr - 0.00437 Mg
(0.033)
2205(0.164)
Ff D P* M.J Kc
P:
2205 P
Lf =' (819.5) (100) (0.00282) (106) (1)
Lf « 0.0224 Mg
(Q.033)
2205(0.164)
Kd Fd D P* M,i Kc
P:
2205 P
Ld - (0.340) (0.2) (100) (0.00282) (106) (1)
La » 0.0186 Mg
1^ = (0.0203 + 0.00437 + 0.0224 + 0.0186) Mg
1^ - 0.0657 Mg of xvlene
(0.033)
2205(0.164)
H-12
-------
ETHYLBENZENE EMISSIONS
Lt = (0.0807 + 0.0174 + 0.0889 + 0.0737) Mg
L, = 0.261 Mq of ethvlbenzene
S-l ANNUAL EMISSIONS
HAP
Xylene
Ethylbenze
ne
Total
HAP
Emissions
(Mg)
0.0744
0.263
0.337
Weighted HAP Emissions
(Mg)
0.0744
0.263
0.337
H-13
-------
-------
EMISSION UNIT ID: WW-1
POST-REDUCTION EMISSION DEMONSTRATION
Emission Unit Description:
Waste acid from the methyl
chloride drying tower
Emission Reduction Measure ID: STST-1
Emission Reduction Measure
Description:
Steam Stripper
Post-reduction emissions were determined based on process
parameters and short-term performance testing, which are summarized
in Section 4.2 of this permit application. Results from testing
were used to correlate the steam-to-feed ratio to methanol and
methyl chloride emissions. Based on the tests, three emission
factors were developed for each HAP representing three ranges of
steam-to-feed ratio. Concentration measurements were conducted at
minimum wastewater temperatures and steam-to-feed ratios to avoid
underestimating emissions, and thereby address possible loading
variations throughout the year.
The wastewater flow rate, steam flow rate and temperature,
wastewater temperature at the inlet to STST-1, and the condenser
outlet temperature of STST-1 were monitored as proposed in
Section 3.3 of this permit application. The equipment monitoring
these parameters is interfaced with a data acquisition system
(DAS) . At the end of each work day, the process operator
determined and recorded hourly-averages of i) the steam-to-feed
ratio, ii) time of operation within each of the three
steam-to-feed ranges, iii) steam inlet temperature, iv) the
wastewater feed temperature, and v) the condenser outlet
temperature. Included in this post-reduction demonstration is a
copy of a daily log sheet for WW-1 showing the hourly-averages of
these parameters.
The hourly steam-to-feed ratio was determined by dividing the
hourly steam mass flow rate by the hourly wastewater feed mass flow
rate. The hourly steam mass flow rate was determined using the
hourly volumetric rate obtained from the orifice pressure gauge,
the hourly steam feed temperature, and steam tables available in
Reference 1. The hourly wastewater feed mass flow rate was
determined by dividing the hourly volumetric flow by the density of
wastewater (8.34 Ib/gal).
H-14
-------
Daily emissions were determined by determining the number of
hours STST-1 was operated during that day within each of the three
steam-to-feed ratio ranges and multiplying those hours by the
corresponding emission factors. Annual emissions for the 1994
calendar year are shown on the following page. These emissions
were determined using the same procedure for calculating daily
emissions, except the total number of hours of operation for 1994
was used instead of the hours of operation in one day.
H-15
-------
EMISSION UNIT ID: WW-1 (continued)
Metha.no! Emissions
Steam- to- feed
(ka/ka)
Ratio & 0 . 12
0.12 > Ratio a 0.
0.09 > Ratio
ratio
09
Emission
Factor
(ka/hr)
1.24
1.36
12.4
X
X
X
Annual
Hours
(hrs)
6,345
2,312
103
Emissions
(Ma)
7.87
3.14
1.28
Total:
8,760
Methyl Chloride Emissions
12.3
Steam- to feed ratio
(ka/ka)
Ratio & 0.12
0.12 > Ratio a 0.09
0.09 > Ratio
Emission
Factor
(kcr/hr)
0.03
0.04
4.50
X
X
X
Annual
Hours
(hrs)
6,345
2,312
103
Emissions
(Ma)
0.190
0.0925
0.464
Total:
8,760
0.747
HAP
Methanol
Methyl
Chloride
Total
WW-1 ANNUAL EMISSIONS
HAP Emissions
(Mg)
12.3
0.747
13.047
Weighted HAP Emissions
(Mg)
12.3
0.747
13.047
H-16
-------
-------
References
1. Chemical Engineers' Handbook, Fifth Edition. Perry, R.H. and
Chilton, C.H. McGraw-Hill Book Company. New York, New York.
H-17
-------
-------
LOG SHEETS
H-18
-------
-------
DAILY LOG FOR THERMAL OXIDIZER TO-1
EMISSION UNIT ID: PV-1
Date
Vfcfr
\lltffr-
i?l?fi
Total
this
page
Number of Hours
Temperature £ 1600
l*fr
13
I /«r-
t*-
Number of Hours
1600 > Temperature 2 1400
10
c,
*1
2,8
Number of Hours
1200 > Temperature
£S
2,
o
Z
Initials
G^£
£Z2>
f=*z. ^.
&3&
-------
PARAXYLENE LOADING LOG
EMISSION UNIT ID: L-1
-------
XYLENE/ETHYLBENZENE STORAGE TANK LOG
EMISSION UNIT ID: S-1
Date
Gauge
Reading
(bbl)
initials
Date
Gauge
Reading
(bbl)
Initials
Tes
HO
-------
ANNUAL TANK INSPECTION
FOR THE
XYLENE/ETHYLBENZENE STORAGE TANK
EMISSION UNIT ID: S-1
Condition of
deck fittings3
Condition of
seals3
1 = good
2 = fair
3 = poor
4 = bad
-------
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-------
1 /„, TECHNICAL REPORT DATA
• (f lease read instructions on the reverse before completing)
•EPA-453/R-95-007
•». TITLE AND SUBTITLE
HEnabling Document for Permits for Early Reductions
ISources
). PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director, Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
September, 1995
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68D10117
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
On November 21, 1994, EPA promulgated a rule establishing an interim federal permit
program for companies participating in the Early Reductions Program (59 FR 59921). This
document provides practical information on interpretation of the rule and its
implementation, and includes an example permit application and permit.
7. KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air Pollution
Hazardous Air Pollutants
Early Reductions
Operating Permits
18. DISTRIBUTION STATEMENT
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b.lDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
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c. COSATI Field/Group
13B
21. NO. OF PAGES
184
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-------
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