Model Permit Specific Conditions And Instructions For Use CFR 40, Part 61 Subpart N National Emission Standards for Inorganic Arsenic Emissions from Glass Manufacturing Plants Submitted To: Warren R. Johnson, Jr. Project Manager OAQPS/ESD/SDB By: Vi'GYAN Inc. April 30, 1992 ------- ------- Permit MODEL PERMIT SPECIFIC CONDITIONS CFR 40, Part 61, Subpart N National Emission Standards for Inorganic Arsenic Emissions from Glass Manufacturing A. EMISSION LIMITS (1) The permittee shall not exceed the emission limits established in Table 1 for glass melting furnaces. Table 1 Furnace ID# Uncontrolled Emissions Control Device (if applicable) ID# Control Efficiency (%) Emission Limit1 (2) The permittee may, after [Agency] approval, bypass the arsenic emissions control device for a limited period of time for purposes such as maintenance of the control device. The permittee shall follow reporting requirements as outlined in Section C(8) of this permit. To obtain approval to bypass a control device the permittee of a source shall make a written application to the [Agency]. (3) The permittee shall at all times operate and maintain the furnace and associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions of inorganic arsenic to the atmosphere to the maximum extent practicable. B. EMISSION MONITORING (1) [For glass melting furnaces with emission control devices] The permittee shall: 1 [The emission limits for total arsenic specified in 40 CFR 61.162 are as follows: uncontrolled emissions from existing and new glass melting furnaces are to be less than 2.5 Mg/year and 0.4 Mg/year respectively, if total arsenic emissions are conveyed to a control device, there must be a reduction of arsenic by at least 85 percent.] Page 1 of 9 ------- Permit (a) Install, calibrate, maintain, and operate a continuous monitoring system for the measurement of the opacity of emissions discharged into the atmosphere from the control device. The system shall be located as specified in paragraph (g), below. (b) Install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the temperature of the gas entering the control device. The system shall be located as specified in paragraph (g), below. (c) Reduce all opacity data to 6-minute averages. 6-minute averages shall be calculated from 24 or more data points equally spaced within each 6-minute period. Data recorded during periods when the monitoring system breaks down, or is undergoing repairs, calibration checks, or zero and span adjustments, shall not be included in the data averages calculated under this paragraph. (d) Calculate 15-minute averages of the temperature of the gas entering the control device for each 15-minute operating period. (e) Check, for all continuous emission monitoring systems installed in accordance with the provisions of this permit, the zero (or low-level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily in accordance with a written procedure. The zero and span shall be adjusted whenever the 24-hour span drift exceeds 2 times the limits of the applicable performance specifications in 40 CFR 60, Appendix B. The system must allow the amount of excess zero and span drift measured at the 24-hour interval checks to be recorded and quantified, whenever specified. For continuous monitoring systems measuring opacity of emissions, the optical surfaces exposed to the effluent gases shall be cleaned prior to performing the zero and span drift adjustments except that for systems using automatic zero compensation exceeds 4 percent opacity. (f) Unless otherwise approved by the [Agency], adopt the following procedures for continuous monitoring systems measuring opacity of emissions. Minimum procedures shall include a method for producing a simulated zero opacity condition and an upscale (span) opacity condition using a certified neutral density filter or other related technique to produce a known obscuration of the light beam. Such procedures shall provide a system check of the analyzer internal optical surfaces and all electronic circuitry including the lamp and photo- detector assembly. (g) Ensure that all continuous monitoring systems or monitoring devices be installed such that representative measurements of emissions or Page 2 of 9 ------- Permit process parameters from the affected facility are obtained. Additional procedures for location of continuous monitoring systems contained in the applicable Performance Specifications of 40 CFR 60, Appendix B shall be used. (h) Ensure that all continuous monitoring systems are in continuous operation and meet minimum frequency of operation requirements as follows: (i) For systems measuring opacity of emissions, the permittee shall complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording for each successive 6-minute period. (ii) For systems measuring emissions, except opacity, the permittee shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording for each successive 15-minute period). The requirements of (i) and (ii), above, do not apply during system breakdowns, repairs, calibration checks, and zero and span adjustments required under paragraphs (e) and (f), above. C. REPORTING AND RECORDKEEPING REQUIREMENTS (1) The permittee shall maintain at the source for a period of at least [2] years and make available to the [Agency] upon request a file of the following records: (a) All measurements, including continuous monitoring for measurement of opacity, and temperature of gas entering a control device. (b) Records of emission test data and all calculations used to produce the required reports of emission estimates to demonstrate compliance with the emission limits prescribed in Section 1 of this permit. (c) All continuous monitoring system performance evaluations, including calibration checks and adjustments. (d) The occurrence and duration of all startups, shutdowns, and malfunctions of the furnace. (e) All malfunctions of the air pollution control system. (f) All periods during which any continuous monitoring system or monitoring device is inoperative. Page 3 of 9 ------- Permit (g) All records of maintenance and repairs for each air pollution control system, continuous monitoring system, or monitoring device. (2) [For existing glass melting furnaces with uncontrolled total arsenic emissions, where less than 8.0 Mg per year of elemental arsenic is added to the furnace, or for new or modified uncontrolled glass melting furnaces where less than 1.0 Mg per year of elemental arsenic is added to the furnace.] The permittee shall determine and record at the end of every 6 months the uncontrolled arsenic emission rate for the preceding and forthcoming 12-month periods, using the procedures shown in paragraphs (a), (b), and (c) below: (a) Derive a theoretical uncontrolled arsenic emission factor (T), in grams of elemental arsenic per kilogram of glass produced, based on material balance calculations for each arsenic-containing glass type (i) produced during the 12-month period, using the following equation: Ti = (Aw * Wbi) + (Arf * Wd) - Where: Tj = the theoretical uncontrolled arsenic emission factor (g/kg) for each glass type (i). Ay = fraction by weight of elemental arsenic in the fresh batch for each glass type (i). Ww = weight (g) of fresh bath melted per kg of glass produced for each glass type (i). AQ = fraction by weight of elemental arsenic in cullet for each glass type (0- Wd = weight (g) of cullet melted per kg of glass produced for each glass type (i). (b) Estimate theoretical uncontrolled arsenic emissions for the 12-month period for each arsenic-containing glass type as follows: Yj = (Tj * Gi)/106 Where: Y. = the theoretical uncontrolled arsenic emission estimate for the 12-month period for each glass type (Mg/year). T. = the theoretical uncontrolled arsenic emission factor for each type of glass (i) produced during the 12-month period as calculated in paragraph (1) of this section (g/kg). Page 4 of 9 ------- Permit G; = the quantity (kg) of each arsenic-containing glass type (i) produced during the 12-month period. (c) Estimate the total theoretical uncontrolled arsenic emissions for the 12-month period by finding the sum of the values calculated for Y; in paragraph (b) of this section. (3) [For existing glass melting furnaces with uncontrolled total arsenic emissions, where 8.0 Mg per year or more of elemental arsenic is added to the furnace, or for new or modified uncontrolled glass melting furnaces where 1.0 Mg per year or more of elemental arsenic is added to the furnace.] The permittee shall determine and record at the end of every 6 months the uncontrolled arsenic emission rate for the preceding and forthcoming 12-month periods, using the procedures shown in paragraphs 2(a) and 2(b), above. In addition, the permittee shall conduct emissions testing and calculations as described in Section D of this permit (Emissions Testing Requirements). (4) While making emissions determinations under paragraphs (2) and (3), above, the permitee shall take into account changes in production rates, types of glass produced, and other factors that would affect the uncontrolled arsenic emission rate. (5) Whenever the permittee conducts an emissions test as outlined in Section D of this permit (Emissions Testing Requirement), the permittee shall: (a) submit a written report of the results of the emission test and associated calculations required, within [60] days after conducting the test. (b) Submit to the [Agency] a written report of the uncontrolled arsenic emission rates determined in accordance with paragraph C(2) and (3) of this section, if: (i) The uncontrolled glass melting furnace emission rate for the preceding 12-month period (or preceding 6-month period for the first 6-month determination) exceeded the applicable limits established in Section A (Emission Limits), Table 1, of this permit. (ii) The uncontrolled glass melting furnace emission rate for the forthcoming 12-month period will exceed the applicable limits established in Section A (Emission Limits), Table 1, above. In this case, the permittee shall also notify the [Agency] of the anticipated date of the emission test to demonstrate compliance with the applicable limit in Table 1, above. Page 5 of 9 ------- Permit (iii) The permittee shall ensure that any report(s) required in (i) or (ii), above, are postmarked by the [tenth] day following the end of the 6-month reporting period. (6) The permittee [when required to operate a continuous opacity monitoring system] shall follow reporting procedures listed below: (a) The permittee shall submit a written report to the [Agency] of the results of the continuous monitoring system evaluation, as required under Section B (Emission Monitoring) of this permit, within [60] days after conducting the evaluation. (b) The permittee shall submit a written report to the [Agency] every [6] months if excess opacity occurred during the preceding [6] month period. For purposes of this paragraph, an occurrence of excess opacity is any 6-minute period during which the average opacity, as measured by the continuous monitoring system, exceeds the opacity value corresponding to the 97.5 percent upper confidence level of a normal or lognormal (whichever the permittee determines is more representative) distribution of the average opacity values. The permittee may redetermine the opacity value corresponding to the 97.5 percent upper confidence level during any emission test that demonstrates compliance with the emission limits established in Table 1, above. (7) The permittee shall ensure that any required semiannual report of excess opacity is postmarked by the [thirtieth] day following the end of the [6] month period and includes the following information: (a) The magnitude of excess opacity, any conversion factor(s) used, and the date and time of commencement and completion of each occurrence of excess opacity. (b) Specific identification of each occurrence of excess opacity that occurs during startups, shutdowns, and malfunctions of the source. (c) The date and time identifying each period during which the continuous monitoring system was inoperative, except for zero and span checks, and the nature of the system repairs or adjustments. (8) The permittee [with approval to bypass a control device under A(2) of this permit] shall maintain at the source, for a period of [at least 2 years], and make available to the [Agency] upon request, a file of the following records: (a) the dates the control device was bypassed; and Page 6 of 9 ------- Permit (b) steps taken to minimize arsenic emissions during the period the control device was bypassed. D. TEST METHODS AND PROCEDURES (1) To meet the requirements of Section C of this permit (Reporting & Recordkeeping Requirements), paragraph (3), the permittee must conduct emission tests, reduce test data, and follow the procedures specified in this section, unless the [Agency]: (a) Specifies or approves, in specific cases, the use of a reference method with minor changes in methodology; (b) Approves the use of an equivalent method; (c) Approves the use of an alternative method the results of which have been determined to be adequate for indicating whether a specific source is in compliance; or (d) Waives the requirement for emission tests as provided under 40 CFR 61.13. (2) The permittee shall estimate the theoretical uncontrolled arsenic emissions for each glass type for the 12-month period by performing the calculations described in Section C, paragraphs 2(a) and 2(b), of this permit. (3) The permittee shall conduct emission testing to determine the actual uncontrolled arsenic emission rate during production of the arsenic-containing glass type with the highest theoretical uncontrolled arsenic emissions (as calculated under paragraph (2) of this section). The permittee shall use the following test methods and procedures: (a) Use Method 108 in Appendix B of the NESHAP for detennining the arsenic emission rate (g/h). The emission rate shall equal the arithmetic mean of the results of 3 60-minute test runs. (b) Use the following methods in Appendix A to 40 CFR Part 60: (i) Method 1 for sample and velocity traverse. (ii) Method 2 for velocity and volumetric flowrate. (iii) Method 3 for gas analysis. (iv) For sources equipped with positive pressure fabric filters, use Section 4 of Method 5D to determine a suitable sampling location and procedure. (4) The permittee shall determine the actual uncontrolled arsenic emission factor (Ra) in grams of elemental arsenic per kilogram of glass produced, as follows: Ra = Ea/P Page 7 of 9 ------- Permit Where: R, = the actual uncontrolled arsenic emission factor (g/kg). E, = the actual uncontrolled arsenic emission rate (g/h) from paragraph (d)(2) of this section. P = the rate of glass production (kg/h), determined by dividing the weight (kg) of glass pulled from the furnace during the emission test by the number of hours (h) taken to perform the test under paragraph (d)(2) of this section. (5) The permittee shall calculate a correction factor to relate the theoretical and the actual uncontrolled arsenic emission factors as follows: Where: F = the correction factor. R, = the actual uncontrolled arsenic emission factor (g/kg) determined in paragraph (d)(3) of this section. TJ = the theoretical uncontrolled arsenic emission factor (g/kg) determined in paragraph (c)(l) of this section for the same glass type for which R, was determined. (6) The permittee shall determine the uncontrolled arsenic emission rate for the 12-month period, as follows: 106 Where: Tj = the uncontrolled arsenic emission rate for the 12-month period (Mg/year). TJ = the theoretical uncontrolled arsenic emission factor for each arsenic-containing glass type (i) produced during the 12-month period, as calculated in paragraph (c)(l) of this section. F = the correction factor calculated in paragraph (d)(4) of this section. Gj = the quantity (kg) of each arsenic-containing glass type (i) produced during the 12-month period. Page 8 of 9 ------- Permit n = the number of arsenic-containing glass types produced during the 12-month period. (7) The permittee shall provide the [Agency] [2Q] days prior notice of any emission test required of the permittee, to afford the [Agency] the opportunity to have an observer present. Page 9 of 9 ------- ------- Instructions INSTRUCTIONS FOR USE MODEL PERMIT SPECIFIC CONDITIONS CFR 40, Part 61, Subpart N National Emission Standards for Inorganic Arsenic Emissions from Glass Manufacturing I. PREFACE TO INSTRUCTIONS The model permit specific conditions document has been prepared to reflect the provisions of Section 502(c) of Title V in the Clean Air Act Amendments of 1990, which states that a single permit may be issued for a facility with multiple sources. Accordingly, this permit assumes that the facility being permitted: • has one or more pieces of equipment covered by the NESHAPs; • may have more than one piece of the same type of equipment; and • each piece of equipment may have several exhaust gas streams. When preparing an actual permit, the permitting agency should only use those sections of the model permit specific conditions document that are relevant. A. THE USE OF TABLES & BLANK SPACES FOR EMISSION LIMITS Although the NESHAPs prescribe definite emission limits, the model permit specific conditions document uses blank tables and blank spaces, in which the permitting agency can enter appropriate emission limits. The reason for using blank tables and spaces is twofold: First, some state or local regulations may have emission limits that are more stringent than those in the NESHAPs. In such instances, the permitting agency may choose to use the more stringent limit. Second, even if state or local regulations do not prescribe more stringent emission limits (or do not have emission limits at all), the permitting agency may choose to use actual emission amounts (or concentrations as appropriate) submitted by the facility in its application for a permit provided that the amounts (or concentrations) are within the limits established by the NESHAPs, and any applicable state and local regulations. In both the cases outlined in the previous paragraph, however, any emission limits that differ from those presented in the NESHAPs may not be federally enforceable. This is an issue that has not been resolved during the preparation of these model permits. To simplify matters, we have inserted limits or other values that are federally enforceable in the blanks. Agencies, at their own discretion, may choose to use these or other appropriate values. Many of the emission limits in the document may be presented via tables; this is done for the sake of comprehensiveness and to avoid repetitive use of legal terminology. Page 1 of 8 ------- Instructions However, such a form of presentation is not a requirement under the NESHAPs, and the permitting agency may choose to present emission limits individually in a text format. In other instances blank spaces have been left in the text, in which the permitting agency may insert the appropriate limit. (Federally enforceable limits are inserted in square brackets.) The choice of whether to use tables or blank spaces in the document was made as follows: Whenever the NESHAPs prescribed an emission limit that could apply to several exhaust gas streams or several pieces of equipment, a table was chosen. Blank spaces were chosen whenever the NESHAPs prescribed a single emission limit. Permitting agencies can insert appropriate limits in the tables and blank spaces. Once again, limits other than those in the NESHAPs may not be federaUy enforceable. B. USING & MODIFYING TABLES The tables presented in the document are meant to be examples of tables that the permitting agency may choose to use. As such, each table is subject to modification by the permitting agency to fit its needs. Each table has 2 main features: (i) equipment and/or gas stream identifiers; and (ii) corresponding emission limits. Because a limit is being applied uniquely to either a piece of equipment or an exhaust gas stream, it is necessary to identify the equipment or gas stream. The tables have used generic terminology to denote identifiers. The permitting agency may choose to amend the terminology to suit its individual requirements, provided amended terminology uniquely identifies the equipment or gas stream, typically by cross-reference to a process flow diagram, etc. There is likely to be considerable variation in the number of pieces of equipment covered by different sections of a permit (both, within a single permit, as well as between one permit and another). Therefore, the permitting agency will need to modify each table to reflect the correct number of pieces of equipment. To complete the emission limit columns in the tables, the permitting agency may choose to simply use the limits prescribed by the NESHAPs (as shown in the square brackets). Alternatively, the agency may choose to insert other appropriate limits. C. OTHER CONSIDERATIONS In addition to blank spaces left for emission limits, blank spaces have been left for other reasons throughout the model permit specific conditions document, including: • spaces for the permitting agency to insert its name; and • spaces that allow the permitting agency to insert other information that may vary from state to state (such as the length of time that permittees must keep records). D. A NOTE ON EMISSIONS TESTING The NESHAPs require facility owners/operators to conduct emission testing as follows (unless they obtain a waiver of emission testing): Page 2 of 8 ------- Instructions • within 90 days of the effective data of the regulations in the case of existing sources or new sources with an initial startup date preceding the effective date; or • within 90 days of startup in the case of new sources that have an initial startup date after the effective date of the regulations. These provisions have been interpreted as one-time testing requirements; as such they are not on-going operational requirements. Furthermore, because they are required only at the time of startup, these provisions are judged to be more appropriate in a construction permit rather than an operating permit. For these reasons, these testing requirements are not included in this model permit document. II. INSTRUCTIONS In the sections that follow, information is presented on regulatory requirements under 40 CFR 61, Subpart N. Typically, these sections explain the basis for each of the conditions in the model permit specific conditions document, and provide references that the permitting agency may use for additional clarification or details. To facilitate using these instructions, each section and subsection below corresponds to the sections and subsections in the permit document. A. EMISSION LIMITS (1) This section establishes emission limits for existing glass melting furnaces with and without control devices. A table is used in this section to clearly show the permittee the emission limits that apply to each furnace. The permit writer should first determine whether the glass melting furnace does/does not use an emission control device. If the furnace does not use an emission control device, the furnace is considered uncontrolled. The emission limit that applies to existing uncontrolled furnaces according to §61.162 is 2.5 Mg per year] total arsenic emissions. For new or modified, uncontrolled glass melting furnaces the emission limit that applies, is 0.4 Mg per year total arsenic emissions. New or existing/modified glass melting furnaces whose emissions are directed to a control device are subject to different emission limits. Emission limits for these types of furnaces are calculated by reducing the total uncontrolled arsenic emissions from the furnace in proportion to the control efficiency of the device. §61.162 requires a control efficiency of at least 85 percent. This limit can be calculated by the formula: E, = Et * (1 - 6) where: Ej = emission limit E, = total uncontrolled arsenic emissions 6 = control efficiency of the control device. Page 3 of 8 ------- Instructions The footnote on Page 1 of the permit is for reference purposes of the permitting agency only, and is not meant to be included in an actual permit. Example Table 1 illustrates the calculation of emissions limits for different furnaces. Furnaces 1, 2, and 3 are existing furnaces, and furnaces 4, and 5 are new. Furnaces 1 and 2, being uncontrolled existing furnaces, are subject to a limit of 2.5 Mg/year under the NESHAPs. In this case, the permit writer has decided to use the current uncontrolled emission rates of 2.4 Mg/year and 1.2 Mg/year as more stringent requirements for furnaces 1 and 2. Furnaces 3 and 4 have control devices and are subject to the limit of an 85 percent reduction in uncontrolled emissions. The permit writer has filled in the control device I.D. # and control efficiency. The emission limits for furnaces 3 and 4 were determined by using the formula above. Furnace 5 being a new, uncontrolled furnace is subject to an emission limit of 0.4 Mg/year under the NESHAPs. The permit writer has again chosen to use the uncontrolled emission rate of 0.3 Mg/year as the limit, which is more stringent than the NESHAP limit. EXAMPLE TABLE 1 Furnace ID# 1 (existing) 2 (existing) 3 (existing) 4 (new) 5 (new) Uncontrolled Emissions 2.4 Mg/yr 1.2 Mg/yr 10.0 Mg/yr 6.0 Mg/yr 0.3 Mg/yr Control Device (if applicable) ID# — — 00712-004 00661-002 — Control Efficiency (%) N/A N/A 90 90 N/A Emission Limit 2.4 Mg/yr 1.2 Mg/yr 1.0 Mg/yr 0.6 Mg/yr 0.3 Mg/yr According to the NESHAP, Subpart N, uncontrolled emissions may be conveyed to a control device and reduced by 85 percent. A statement to that effect may be placed into Section A of the permit. By taking an uncontrolled furnace and installing a control device, the permittee might be able to increase the uncontrolled emissions of the furnace as long as the emissions are reduced by 85 percent by the control device. This action would require that the permittee notify the [Agency] of the action taken and report any increase in emissions. The [Agency] may also require revision of the permit to incorporate the new emission limit. If a furnace has multiple emission points, each emission point for a single furnace should be listed on consecutive lines in Table 1 of Section A (Emission Limits) in the model permit specific conditions document. To calculate emission limits for multiple emission points from a single furnace, the permit writer should consider that the emission limit for Page 4 of 8 ------- Instructions a single emission point furnace would be the same as the sum of all the emissions from a multiple emission point furnace, because the limit is established for a furnace, not for individual emission points. To calculate the emission limits for a furnace with multiple sources, divide the total emissions by the number of emission sources (see Example 2). Example 2: Furnace 1 and Furnace 6 are existing, uncontrolled furnaces emitting 2.5 Mg per year each. Furnace 1 has a single emission point, and Furnace 6 has four emission points. According to the NESHAPs, Furnace 6 has the same total emission limit as Furnace 1. However, the permitting agency may choose to impose an emission limit for each emission point as follows: No. of Emission Points = 4 Emission Limit = (2.5 -=- 4) Mg per year = 0.63 Mg per year for each emission point. This calculation assumes that all emission points have equal flow. To determine emission Limits for points that do not have equal flow, use the percentage of total flow for each emission point. The percentage of flow for each emission point is multiplied by the emission amount for the entire furnace to get the emission limits for each emission point. Note: The sum of the emission limits from sources with multiple emission points must total the limit as if the source had only a single emission point. (2) This condition is based on §61.162(c). Application procedures are described in CFR 40 61.165(e). (3) This condition is based on §61.162(d). B. EMISSION MONITORING 1) This condition prescribes procedures for the permittee to follow if the permittee has a furnace that uses an emission control device. If the permittee has only uncontrolled furnaces, this section may be omitted. (a) Specific condition for opacity monitoring, as required by §61.163(a)(l). (b) Specific condition for temperature monitoring, as required by §61.163(a)(2). (c) This condition specifies data treatment for opacity data, as required by §61.163(g)(l). (d) This condition specifies data treatment for temperature data, as required by §61.163(g)(2). (e) This condition specifies zero and span adjustment for continuous emission monitoring systems, as required by §61.163(e) and 60.13(d)(l). Page 5 of 8 ------- Instructions (f) This condition specifies zero and span adjustment for continuous monitoring systems measuring opacity, as required by §61.163(e) and §60.13(d)(2). (g) This condition refers the permittee to the appropriate procedures for installing the continuous monitoring system, and is based on §61.163(e) and §60.13(f) requirements. 40 CFR 60, Appendix B is the reference for the procedures. (h) This condition specifies frequency of operation requirements for continuous monitoring systems, as required by §61.163(f) and 60.13(e). C. REPORTING AND RECORDKEEPING REQUIREMENTS (1) This section describes requirements and procedures used when the furnace has an emission control device and is subject to continuous monitoring. The permit writer may delete this section if none of the furnaces have emission control devices and are not subject to continuous monitoring requirements. §61.165(a) is the basis for this set of conditions. (2) This section lists the procedures for recording and reporting emission levels and methods for calculating required emissions information, as required by §61.165(c)(l). It only pertains to existing glass melting furnaces with uncontrolled total arsenic emissions, where less than 8.0 Mg per year of elemental arsenic is added to the furnace, and to new or modified uncontrolled glass melting furnaces where less than 1.0 Mg per year of elemental arsenic is added to the furnace. This information has been put in square brackets only to serve as a reference for the permitting agency, and must not appear in the actual permit. If the facility being permitted does not have uncontrolled total arsenic emissions, then Section C(2) does not apply, and must not be included in the permit. If a facility has some furnaces with controlled emissions but others with uncontrolled emissions, Section C(2) applies only to the furnaces with uncontrolled emissions, and this must be specified in the permit. §61.165(c) describes 3 steps that the facility must take: (i) derive a theoretical uncontrolled arsenic emission factor; (ii) estimate theoretical uncontrolled arsenic emissions for each arsenic- containing glass type; and (iii) estimate the total theoretical uncontrolled arsenic emissions for all glass types. These 3 steps are outlined in paragraphs 2(a) through 2(c) of the permit. (3) This section, which is also required by §61.165(c)(l), only pertains to existing glass melting furnaces with uncontrolled total arsenic emissions, where 8.0 Mg per year or more of elemental arsenic is added to the furnace, and to new or modified uncontrolled glass melting furnaces where 1.0 Mg per year or more of elemental arsenic is added to the furnace. This information has been put in square brackets only to serve as a reference for the permitting agency, and must not appear in the actual permit. Page 6 of 8 ------- Instructions Section C(3) does not apply if the permitted facility does not have uncontrolled total arsenic emissions, and must not be included in the permit. If a facility has some furnaces with controlled emissions but others with uncontrolled emissions, Section C(3) applies only to the furnaces with uncontrolled emissions, and this must be specified in the permit. §61.165(d), which is referenced in §61.165(c)(l), requires emissions testing. This requirement is reflected in paragraph (3) of the permit. (4) This is a requirement of §61.165(c)(2). (5) This section establishes notification deadlines for emission tests, as required by §61.165(d)(2), (4), and (5). (6) This condition applies to permittees who are required to operate a continuous opacity monitoring system. The condition reflects the requirements of §61.165(f)(l) and (2). If continuous opacity monitoring is not required of the permittee, this condition should be omitted from the permit. (7) This condition outlines additional information that the permittee must report, if required to operate a continuous opacity monitoring system. The condition reflects the requirements of §61.165(f)(3). If continuous opacity monitoring is not required of the permittee, this condition should be omitted from the permit. (8) This condition refects the requirements of §61.165(b), and only applies to permittees with agency approval to bypass a control device under Condition A(l) of the permit. This condition should be omitted if the permittee is not bypassing control devices. D. EMISSIONS TESTING REQUIREMENTS (1) This paragraph, based on §61.164(a), outlines circumstances when the permittee may deviate from emission testing and calculation procedures required by the permit. (2-6) These steps are part of the emissions testing procedures, described in §61.164(d). These conditions only apply to permittees with existing with uncontrolled total arsenic emissions, where 8.0 Mg per year or more of elemental arsenic is added to the furnace, and to permittees with new or modified uncontrolled furnaces where 1.0 Mg per year or more of elemental arsenic is added to the furnace; or when emissions testing is required for some other reason, as outlined in §61.164(b)(3) and (4). The steps, as outlined in paragraphs (2) through (6), that the facility must take are: (i) derive a theoretical uncontrolled arsenic emission factor and estimate theoretical uncontrolled arsenic emissions for each arsenic-containing glass type; (ii) conduct emissions testing; (iii) determine actual uncontrolled arsenic emission factor; Page 7 of 8 ------- Instructions (iv) calculate a correction factor for the theoretical emission factor; and (v) determine the uncontroled emission rate. (7) This condition is based on the requirements of §61.165(d)(l). Page 8 of 8 ------- |