United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-91-013
JULY 1991
Air
Enabling Document
for Regulations Governing
Compliance Extensions for
Early Reductions of
Hazardous Air Pollutants
DRAFT
-------
ENABLING DOCUMENT FOR
REGULATIONS GOVERNING
COMPLIANCE EXTENSIONS FOR
EARLY REDUCTIONS OF F
AIR POLLUTANTS
Prepared By
Emission 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
July 1991
-------
TABLE OF CONTENTS
Page
1.0 INTRODUCTION AND OVERVIEW 1-1
2.0 THE REGULATIONS 2-1
§63.72 GENERAL PROVISIONS FOR COMPLIANCE
EXTENSIONS 2-1
§63.73 SOURCE 2-5
§63.74 DEMONSTRATION OF EARLY REDUCTION 2-16
§63.75 ENFORCEABLE COMMITMENTS 2-32
§63.76 REVIEW OF BASE YEAR EMISSIONS 2-39
§63.77 APPLICATION PROCEDURES 2-46
§63.78 EARLY REDUCTION DEMONSTRATION EVALUATION 2-49
§63.79 APPROVAL OF APPLICATIONS 2-51
§63.80 ENFORCEMENT 2.53
§63.81 RULE FOR SPECIAL SITUATIONS 2-55
3.0 PROGRAM IMPLEMENTATION 3_.|
ENFORCEABLE COMMITMENTS 3_-|
STEPS IN THE SYSTEM 3.3
REVIEW CHECKLISTS 3.6
BASELINE SUBMITTALS 3.7
REVIEWER CHECKLISTS FOR BASELINE SUBMITTALS 3-8
PERMIT APPLICATIONS 3_g
' 07/29/91
-------
TABLE OF CONTENTS (Continued)
Page
4.0 INTERFACE WITH THE INDUSTRIAL TOXICS PROJECT 4-1
DESCRIPTION OF THE 33/50 PROJECT 4-1
INTERFACE BETWEEN ITP AND THE EARLY REDUCTION PROGRAM 4-2
APPENDIX A: EXAMPLE ENFORCEABLE COMMITMENT
APPENDIX B: REVIEWER CHECKLISTS
APPENDIX C: REVIEWER CHECKLISTS FOR BASELINE APPROVAL
07/29/91
-------
LIST OF TABLES
Table Page
1-1 EMISSIONS COMPARISON EARLY REDUCTIONS VS. SECTION 112(d)
STANDARD ^3
2-1 INFORMATION REQUIREMENTS FOR DEMONSTRATION OF EARLY
REDUCTION 2-17
2-2 WEIGHTING FACTORS FOR HIGH-RISK POLLUTANTS 2-22
2-3 ANTICIPATED PROPOSAL DATES FOR EARLY STANDARDS 2-33
2-4 EPA REGIONAL OFFICE ADDRESSES 2-35
2-5 COMPONENTS OF AN ENFORCEABLE COMMITMENT 2-36
07/29/91
-------
LIST OF FIGURES
Figure Page
1-1 Early Reduction Program Duration of Overall Program 1-4
2-1 Overview of the Early Reduction Program 2-2
2-2 Chemical Plant Schematic Entire Facility 2-7
2-3 Chemical Plant Schematic Functional and Geographical .- 2-9
2-4 Chemical Plant Schematic Potentially Unacceptable Selective Grouping 2-10
2-5 Metal Coating Operation 2-12
2-6 Chemical Plant Schematic Process Train 2-13
2-7 Early Reduction Program Duration of Key Activities 2-40
2-8 Enforceable Commitment (or Baseline) Review 2-41
2-9 Early Reduction Program Duration of Key Activities 2-48
3-1 Management System for Review of Enforceable Commitments 3-4
07/29/91
-------
1.0 INTRODUCTION AND OVERVIEW
The purpose of this Enabling Document is to provide practical information on
implementation of the early reduction program, including explanations of the
requirements and procedures for early reduction demonstration submittals and review
of the submittals. The primary goal is to enable the EPA Regional Offices and States
to better understand the program and their roles, and thereby, better implement the
program.
This is EPA's first draft of the enabling document and EPA plans to make this a
living document. As EPA gains experience with the program, this document will be
revised and appended as appropriate to better aid the Regional EPA Offices and
states implement the regulations.
On November 15, 1990, the Clean Air Act was amended, and significant
changes were made to Section 112 of the Act establishing national emission standards
for hazardous air pollutants. One of the new features of the Act is an incentive
program by which an owner or operator can obtain a six-year extension of compliance
with an applicable 112(d) standard for early reductions in hazardous air pollutant
emissions.
The purpose of the program is to encourage early reductions in HAP emissions.
Source owners and operators that participate in the program will gain the benefit of
more time to develop strategies for compliance with 112(d) standards. Ideally, this will
give them an opportunity to develop more cost-effective emission reduction
approaches. In addition, participating companies can enjoy the benefit of improved
community relations when they become recognized as good corporate citizens that
are concerned about improving the environment.
At the same time, the public benefits because HAP emissions are significantly
reduced earlier than they would be, if sources delayed control until they were subject
to 112(d) standards. Moreover, this early reduction program has the potential to not
only lower annual emissions early, but also lower overall long-term emissions from the
1-1 07/29/91
-------
source. This long-term environmental benefit is illustrated by example in Table 1-1.
Consider a source emitting HAP at a rate of 100 tons per year. Assume that this
source achieves a 90 percent reduction in HAP emissions, to a rate of 10 tons per
year, just prior to proposal of an applicable 112(d) standard, and receives a six-year
compliance extension. In comparison, consider an identical 100 ton per year source
which does not achieve early reductions, but complies with the 112(d) standard three
years after the standard is promulgated. Assuming that 112(d) standard is 98 percent
reduction, the source participating in the early reduction program would emit only 100
tons of HAP over a ten-year period in comparison to 412 tons from the source that
waits and complies with the 112(d) regulation. After that time, both sources would be
subject to 112(d) standard and HAP emissions can be assumed to be equal.
The early reduction program has long term implications on the State and
Regional EPA permitting authorities that will administer the program. As illustrated in
Figure 1-1, the duration of the overall program will be about 18 years, from 1991 until
November 2009. Figure 1-1 illustrates that some submittals for the program
(enforceable commitments) will be received beginning in 1991. The last compliance
extension for the last 112(d) standard promulgated under Title III of the Act will expire
by November of 2009, thus formally ending the effects of the early reduction program.
Initially, the program will be administered by the EPA Regional Offices. Then, as
the individual permitting programs of the States are approved under Title V, the
respective States will take over administration of the program.
On June 13, 1991, the U.S. Environmental Agency (EPA) proposed regulations
governing compliance extensions for early reductions of hazardous air pollutants
under subpart D of 40 CFR 63. The proposed rule establishes requirements and
procedures for source owners and operators to follow in order to obtain compliance
extensions, and for reviewing agencies to follow in evaluating requests for extensions.
1'2 07/29/91
-------
TABLE 1-1. EMISSIONS COMPARISON EARLY REDUCTIONS VS.
SECTION 112(d) STANDARD
TIME
(YEARS)
1 (year between proposal
and promulgation)
2
3
4 (third year after
promulgation)
5
6
7
8
9
10 (last year of
compliance extension)
TOTALS
SECTION 112(d)
100
100
100
100
2
2
2
2
2
2
412
CONTROL SCENARIO
STANDARD EARLY REDUCTION
10
10
10
10
10
10
10
10
10
10
100
SECTION 112 (d) STANDARD = 98%
Assumptions: 100 ton/yr source (uncontrolled); Section 112(d) standard achieves 98%
control; Section 1l2(d) standard is effective 3 years after promulgation; 9 years after
Section 112(d) standard promulgation Section 112(d) standard applies to source which
received a compliance extension.
1-3 07/29/91
-------
EPA Administers Program Transition
States Administer Program
77777/77777777777,
Duration of Overall Program
0
1991
1992
1993
1994
1995
1996
1997
1998
•-
1999
2000
(.
Mid 1991
Industry
Consultations
Earliest E£
EC: Enforceable Commitment
Nov. 1999
Proposal of
Last112(d)
Standard
2009
Nov. 2009
Last
Compliance
Extension
Jres
Figure 1-1. Early Reduction Program: Duration of Overall Program
-------
The regulations are organized according to the following sections:
63.70 Applicability.
63.71 Definitions.
63.72 General provisions for compliance extensions.
63.73 Source.
63.74 Demonstration of early reduction.
63.75 Enforceable Commitments
63.76 Review of base year emissions.
63.77 Application procedures.
63.78 Early reduction demonstration evaluation.
63.79 Approval of applications.
63.80 Enforcement.
63.81 Rule for special situations.
1-5 07/29/91
-------
2.0 THE REGULATIONS
This chapter provides a discussion of the individual sections of the proposed
regulation. Where appropriate, the underlying rationale for specific parts of the
regulation are discussed and guidance on implementation of the regulations is
provided. In addition, implications of the standard and answers to anticipated
questions are provided at the end of each subsection.
§63.72 GENERAL PROVISIONS FOR COMPLIANCE EXTENSIONS
This section of the regulation basically restates the main provisions outlined
under 112(i)(5) of the Clean Air Act. Under these provisions, the Administrator or a
State acting pursuant to a permitting program approved under Title V shall by permit
allow an existing source to meet an alternative emission limitation in lieu of an emission
limitation promulgated under 112(d) standard, for a period of 6 years from the
compliance date of the applicable standard, providing the source owner or operator:
(1) demonstrates that the source has achieved (i) 90 percent overall (95
percent for paniculate emissions) reduction in base year HAP emissions
and (ii) a 90 (95) percent reduction in base year HAP emissions adjusted
for high-risk pollutant weighting factors; and
(2) that such reduction is achieved before proposal of an applicable 112(d)
standard, or before January 1, 1994, provided that an enforceable
commitment was made prior to proposal of the earliest applicable
standard.
As illustrated in Figure 2-1, this creates two paths for participation in the early
reduction program. For sources that achieve reductions prior to proposal of an
applicable 112(d) standard, the owner or operator can submit a permit application
along with a demonstration of early reduction. For sources that cannot achieve the
early reduction before proposal, but can achieve such reduction before
2-1 07/29/91
-------
TWO PATHS TO
PARTICIPATION IN THE
EARLY REDUCTION
PROGRAM
SOURCE ANALYSIS
WILL QUALIFYING
REDUCTIONS BE
ACHIEVED BEFORE
PROPOSAL OF AN
APPLICABLE 112(d)
STANDARD?
No
Yes
SUBMIT ENFORCEABLE
COMMITTMENT
(COMMIT TO ACHIEVE
REDUCTION BEFORE
JANUARY 1,1994)
I SUBMIT BASELINE I
I ESTIMATE FOR REVIEW I
SUBMIT PERMIT
APPLICATION WHICH
CONTAINS EARLY
REDUCTION
DEMONSTRATION
PERMITTING AUTHORITY ISSUES
A PERMIT ESTABLISHING
ALTERNATIVE EMISSION
LIMITATION(S) FOR SOURCE
Figure 2-1. Overview of the early reduction program.
2-2
07/29/91
-------
January 1, 1994, the owner or operator can submit an enforceable commitment to
reduce base year emissions by 90 (95) percent, achieve the reduction before
January 1, 1994, and submit a permit application prior to December 1, 1993
demonstrating the early reduction. The difference between the two paths is the timing
of the reduction with respect to proposal of an applicable 112(d) standard, and the
ability to submit an enforceable commitment in the case of the initial 112(d) standards.
In either case, the end result of a successful early reduction demonstration is an
alternate emission limitation issued by permit which grants the owner or operator a six-
year extension from compliance with an applicable 112(d) standard.
In addition to reducing aggregate HAP emissions by 90 (95) percent, the
general provisions require a separate 90 (95) percent reduction demonstration taking
into account high-risk pollutant weighting factors. The owner or operator must multiply
the base year and post-reduction emissions of each individual HAP by the weighting
factor associated with the HAP and show that HAP emissions adjusted for high-risk
pollutants have been reduced by 90 (95) percent. Additional discussion of this
demonstration is provided in later sections.
The Act specifically gives States the right to require more than 90 (95) percent
aggregate or individual pollutant reduction when the States are issuing permits under
this program. In addition, other procedures or requirements may apply to the source
at the State level. For example, a source may be required to obtain State
preconstruction and operating permits for any action it undertakes under the early
reduction program, or the source may have to meet separate control requirements
imposed by existing State regulations for toxic air pollutants.
Question and Answer
What happens if the source is granted an alternative emission limitation in
a permit issued by the EPA Regional Office and the State later attempts
to require greater than 90 (95) percent reduction, when it receives
permitting approval under Title V?
2-3 07/29/91
-------
Once an alternative emission limitation is granted by the
EPA or a State Agency under the Early Reduction Program,
it remains in effect for the entire six-year period. Under this
program, neither the State nor EPA can revoke the permit or
require an alternative emission limitation more stringent than
that already approved by the permitting agency, until the
end of the six-year period. However, the six year extension
_ applies only to 112(d) standards and does not universally
exempt a source from compliance with all other regulations.
What happens if the source makes an acceptable enforceable commitment to
the U.S. EPA and the State later requires greater than 90 (95) percent
reduction, when it receives permitting approval under Title V?
Nothing precludes a State from requiring greater than 90
(95) percent reduction under the early reduction program.
In concept, a source owner or operator could make a
commitment to reduce HAP emissions by 90 (95) percent
and later have the state require a greater than 90
(95) percent reduction. However, this situation should not
occur. The EPA's implementation program (see Chapter 3)
focuses on close communication and coordination between
the states, EPA Regional Offices, and EPA Headquarters.
The state will receive a copy of the enforceable commitment
at the same time as the EPA Region and will review the
enforceable commitment concurrent with EPA review. The
EPA Regional Office will discuss the commitment with the
state early in the review process and state comments on the
enforceable commitment will be solicited by the EPA
Region.
Can States grant extensions for less than six years?
No. The provision in Section 112(i)(5)(A) states that,
"Nothing in this paragraph shall preclude a State from
requiring reductions in excess of those specified in this
subparagraph as a condition of granting the extension...".
The provision allows for States to require greater reduction
(e.g., greater than 90 or 95 percent) of HAP emissions, but
does not allow the State to restrict the extension to less than
six years.
2-4 07/29/91
-------
§63.73 SOURCE
For purposes of the early reduction program, source is defined as follows:
(1) A building, structure, facility or installation identified as a source by
the EPA in Appendix B;
(2) All portions of an entire contiguous facility under common ownership or
control that emit hazardous air pollutants;
(3) Any portion of an entire contiguous facility under common ownership or
control that emit HAP and can be identified as a facility, building,
structure, or installation for purposes of establishing standards under
section 112(d) of the Act:
(4) Any combination of sources defined in (3) above, provided that emission
reduction from the aggregation of sources constitutes significant
reduction of hazardous air pollutant emissions of the entire contiguous
facility under common ownership or control; or
(5) Any individual emission point or combination of emission points within a
contiguous facility under common ownership or control, provided that
emission reduction from such point or aggregation of points constitutes a
significant reduction of hazardous air pollutant emissions of the entire
contiguous facility;
For purposes of paragraphs (4) and (5) of this section, emissions reductions
are considered significant if they are made from base year HAP emissions of not less
than (1) a total of 10 tons per year where the total emissions of hazardous air
pollutants in the base year from the entire contiguous facility is greater than 25 tons;
or (2) a total of 5 tons per year of hazardous air pollutants where the total emissions
of hazardous air pollutants in the base year from the entire contiguous facility is less
than 25 tons per year.
Depending on a particular 1l2(d) standard, a source may be defined broadly or
narrowly, from a discrete emission point up to and including an entire plant. This
definition of source is consistent with the broad flexibility encompassed under section
111(a)(3) of the Act and is designed to further the underlying purposes of the early
2-5 07/29/91
-------
reduction program. The final definition of source in the regulation may change as a
result of the notice and comment process.
The scope of the definition is best illustrated by examining each paragraph of
the definition. Under paragraph (1), EPA has, to date, identified only one group of
sources as likely sources for purposes of establishing 112(d) standards. These are
fugitive emissions sources from hazardous organic chemical facilities.
Fugitive emissions from equipment leaks covered in the Hazardous Organic
NESHAP, or HON, proposed in 1991 have been identified as a source for purposes of
establishing standards under 1l2(d) standards with sufficient certainty to consider
them separately. EPA has engaged in an extensive regulatory negotiation to establish
proposed 112(d) standards for equipment leaks from HON plants. See the March 16,
1991 issue of the Federal Register (56 FR 9315). The proposed regulation defines
source as the collection of applicable equipment (valves, pumps, connectors, etc.)
within a process unit that uses as a reactant or makes one of-the organics listed in
112(b) standard of the Clean Air Act Amendments as hazardous. For the purposes of
the negotiated proposed rule, the process unit comprises all equipment from the
feedstock storage tanks through end product disposition and wastewater treatment.
Fugitive equipment leaks are treated as a separate class because they can occur
throughout the plant wherever process equipment handles fluids and are not
associated with any particular type of discrete emission point, e.g., storage or process
vents. The negotiating committee recognized the need to treat equipment leaks
separately. EPA recognizes that this proposed definition of source is for proposal
purposes only. It may change as a result of the notice and comment process.
Nevertheless, for purposes of early reductions, the definition of source for these types
of emissions will be what is reflected in the regulatory language in the March 6 notice.
EPA notes that tentatively identifying equipment leaks as a source for early reductions
is in no way meant to limit how "source" will be defined for the purposes of any
particular 1l2(d) standard, including the HON equipment leak standard.
The second part of the definition (paragraph (2)) encompasses the entire
contiguous facility. (See Figure 2-2) Under paragraph (2) of the definition, if an
2-6 07/29/91
-------
Tank farm
A O
oo
Process unit X
Transfer/loading
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm C
Tank farm
B
Process unit Y
Tank
Process unit YY
Transfer/loading
O O Tank farm
OOO D
Contiguous plant boundary
Figure 2-2. Chemical Plant Schematic
Entire Facility
2-7
07/29/91
-------
applicant designates the entire contiguous facility as the source and demonstrates that
the total emissions of hazardous air pollutants from the contiguous facility have been
reduced by 90 percent (or 95 percent for particulates), then the facility would receive a
six year extension from any and all 112(d) standards applicable to the facility. The six
year extension is added to the promulgated compliance date for each applicable
standard. A plantwide definition of source clearly falls within the definition of source
under section 111(a)(3).
A "source" may also be defined to encompass less than an entire plant;
however, only those points identified as part of the source would be eligible for the six
year 112(d) standard extension. Under paragraph (3) of the definition, the applicant
could identify groups of emission points, that have a functional or geographical
relationship to one another and characterize the collection of points as a facility (see
Figure 2-3). For example, the applicant could identify a group of functionally similar
points (Tank Farm B) as a source and achieve a 90% reduction across that source.
Alternatively, the applicant could identify all tanks in one of the other areas (A, C, or D)
as a separate source because each of these areas could be defined as a tank farm
installation or facility. Moreover, the applicant could take one or more of the tanks out
of service and credit that reduction towards the 90%, provided the shutdown was
permanent. Under paragraph (3), however, the applicant could not identify a tank
farm as the source and then subdivide the tank farm to exclude a portion of the tanks
because they were already partially controlled. (Figure 2-4). This configuration of a
source may, however, be acceptable if the designated tanks meet the requirements of
paragraph (4) or (5).
Generally, geographic grouping to form a source would only be allowed for
emission points of the same type within a logical physical area, as in the examples
above. Under paragraph (3) it would not be acceptable to aggregate as a source
based on a geographical relationship several unrelated tanks, process vents,
wastewater units, etc, simply because they were all located on the same side of the
road. However, if a building or other enclosed structure houses a collection of
emission points, such a source definition would be consistent with section 111(a)(3)'s
2-8 07/29/91
-------
Tank farm
A O
oo
Process unit X
Transfer/loading
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm C
farm
Process unit Y
Tank
Process unit YY
Transfer/loading
O O O Tank farm
OOO D
Figure 2-3. Chemical Plant Schematic
Functional and Geographical
2-9
07/29/91
-------
Tank farm
A O
oo
Process unit X
Transfer/loading
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm C
Process unit Y
Tank
Process unit YY
Transfer/loading
O O O Tank farm
OOO D
Figure 2-4. Chemical Plant Schematic
Potentially Unacceptable Selective Grouping
2-10 07/29/91
-------
definition of source as "any building, structure, facility, or installation." For example, a
metal parts coating operation consisting of degreasers, painting lines, and paint
strippers within a single enclosed structure could collectively be considered a source.
(See Figure 2-5).
Under paragraph (3), the applicant could also identify a process or production
unit as a source, such as all equipment-associated with the production of chemical X.
An applicant, therefore, could identify as one "source" the outlined areas in Figure 2-6
which constitute a process unit and include all tanks in Area A, the vents on
Production Unit X, and the tanks in Area C. All points that are substantially dedicated
to a particular process must be included in the process unit source. In many
instances, however, some components of the plant will be shared by multiple process
units, e.g., a wastewater treatment system. For common or shared facilities which
serve or are linked with multiple process units, the applicant could consider the
common facility as part of a single process unit or treat it as a separate source. The
applicant has fairly broad flexibility to identify those logical points that constitute a
process unit or production train. However, the applicant must achieve a 90%
reduction in HAP emissions from the entire process unit. However, a 90% reduction of
each component would not be required provided the aggregate overall reductions
achieves 90%.
Under paragraph (4) and (5), a "source" may defined as any group of sources
identified under paragraph (3) of the source definition or any group of emission points
provided that the aggregation of sources or emission points represents a significant
reduction of the plant total emissions. In other words, a source may be defined in any
manner as long as the reductions meet the significance criterion. EPA has determined
that for the purposes of the Early Reductions program a significant reduction in
emissions of hazardous air pollutants is a 90% reduction from base year emissions per
year of at least 10 tons or a 90% reduction from base year emissions of at least 5 tons
for plants that emitted 25 tons or less of hazardous air pollutants during the base year.
These examples of the definition of source are meant to be illustrative of the types of
groupings that may reasonably fall within the proposed definition of source for
2-11 07/29/91
-------
Degreasing
Degreasing
Painting
line
Coated
parts
Painting
line
Off
Specification
Paint
Stripping
Enclosed building
Figure 2-5. Metal Coating Operation
2-12
07/29/91
-------
Tank farm
Process unit X
O
oo
Transfer/loading
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm C
Transfer/loading
Process unit Y
Tank
Process unit YY
©
Tank farm
OOO D
Figure 2-6. Chemical Plant Schematic
Process Train
2-13
07/29/91
-------
purposes of the early reductions program. Obviously, each individual plant will be
configured differently and it is impossible to contemplate all the combinations that may
be unique to a particular contiguous facility. However, because EPA has not yet
defined "source" for purposes of establishing 112(d) standards, the test for the
definition of source under the early reductions program must be whether the
application includes identifiable "sources" as that term is defined under the Clean Air
Act.
The proposed definition provides the maximum benefit to an applicant who is
capable of making reductions in various parts of its plant, and is trying to make
reductions without actual knowledge as to how EPA will define various components of
the plant as "sources" for purposes of particular 112(d) standards. Each source
identified would receive extensions from the 112(d) standards applicable to it. If a
plant owner or operator chose to reduce plantwide emissions by 90 percent, the plant
would receive an extension on all 112(d) standards applicable to it.
Question and Answer
If an owner or operator has defined a source (e.g., including all the
emission points from production of chemical X), can any of the same
emission points be included in another demonstration of early reduction
from some other defined source within the facility?
No. If a facility has shutdown a portion of its operation or
recently applied good control (i.e., greater than 90 percent)
on an emission point, that emission point can not be
repeatedly averaged in with other groups of emission points
to demonstrate early reduction.
•
Can sources include emission points that have been eliminated due to
shutdown of a certain unit or portions of a contiguous facility?
Yes. If the emission point was operating in the base year
chosen and will continue to remain unoperational
throughout the six-year extension period, the reduction may
be included in the demonstration of early reduction. This
requirement will be included as an operating condition in
2-14 07/29/91
-------
the issued permit. In addition, reduced operating hours
can be a valid means of reducing emissions, if made a
permit condition. However, if the shutdown unit is replaced
by equipment elsewhere in the contiguous facility or
production hours are increased elsewhere at the facility to
compensate for the reduced operating hours of the defined
source, the HAP emissions from these emission points are
considered part of the source and must be included in the
demonstration. Additionally, if the owner or operator wishes
to restart the shutdown portion of the facility or increase
operating hours during the extension period, the owner or
operator must maintain the 90 (95) percent reduction of
HAPs at the source and would have to make compensating
reductions in HAP emissions to offset any HAP emissions
from the restarted unit or increased operation. This may
require that the source definition be expanded.
Can a source be defined so that it contains a building, structure, facility or
installation identified as a source by EPA in Appendix B along with other
emission points?
/es. For example, the owner or operator of a chemical
manufacturing facility could define his source as the entire
facility, including equipment leak emissions which are
identified as a source in Appendix B. Similarly, the
equipment leak emissions for a single process unit could be
included in a source defined as the process unit. If any
equipment leak emission point (i.e., pumps, valves, etc.) is
included in the source definition, then all equipment leak
emission points, as identified by EPA in Appendix B, must
be included in the source definition. When the source is
defined as all emissions points within a process unit, the
owner/operator has the option of including or excluding
equipment leak emissions in the source definition.
If a contiguous facility leases a portion of the facility to another operator, can
the host facility take credit for emission reductions which occur in the leased
portion of the facility?
A/o. 777e host facility is not responsible for emissions from
the leased portion and may not take credit for any emission
reduction achieved by the leased portion. The leased
portion is not included as part of the contiguous facility
because it is not under "common control." The operator of
2-15 07/29/91
-------
the leased portion must apply separately for an extension
under the early reduction program.
If a portion of a contiguous facility is owned jointly between the owner/operator
of the entire facility and another entity (i.e., a joint venture), can the host facility
take credit for HAP reductions in the jointly owned portion of the facility?
Only if the host facility has control of emissions. If the host
facility does not have complete control over emissions, then
the portion of the facility under joint ownership must apply
separately for an extension.
When is a single emission point a source for purposes of the Early Reduction
Program?
A single emission point is a source if it is a building,
structure, facility, or installation; or if it emits more than
10 TPY of HAP (5 TPY of HAP at a facility than emits less
than 25 TPY of HAP.
§63.74 DEMONSTRATION OF EARLY REDUCTION
This section of the regulation establishes the criteria for demonstrating early
reductions in HAP emissions. Demonstration of early reduction is the responsibility of
the owner or operator of the facility. In summary, the owner or operator must provide
four sets of information in order to demonstrate early reduction. These are:
• Source identifying information,
• Base year emissions,
• Post-reduction emissions, and
• Calculations to show that a 90 (95) percent reduction in HAP emissions
has been achieved.
The specific information requirements for demonstration of early reduction are itemized
in Table 2-1. Most of the information requirements are straightforward and require no
further discussion. Rather than discuss each requirement, the following discussion
focuses on several key requirements.
2-16 07/29/91
-------
TABLE 2-1. INFORMATION REQUIREMENTS FOR DEMONSTRATION
OF EARLY REDUCTION
Source Identifying Information:
(1) A description of the source including a site plan of the entire contiguous
facility under common control which contains the source, and markings
on the site plan locating the parts of the site that constitute the source;
(2) The activity at the source which causes hazardous air pollutant
emissions;
(3) A complete list of all emission points of hazardous air pollutants in the
source, including identification numbers and short descriptive titles; and
(4) A statement showing that the source conforms to one of the allowable
definition options from §63.73. If the source conforms to the option in
§63.73(d), the total base year emissions from the source, as determined
pursuant to this section, shall be at least:
(i) 5 tons per year, for cases in which total hazardous air
pollutant emissions from the entire contiguous facility under
common control are 25 tons per year or less as calculated
under paragraph (1) of this section, or
(ii) 10 tons per year in all other cases.
Base Year Emissions:
(1) The base year chosen, where the base year shall be 1987 or later,
except that the base year may be 1985 or 1986 if the owner or operator
of the source can demonstrate that emission data for the source for 1985
or 1986 was submitted to the Administrator pursuant to an information
request issued under section 114 of the Act and was received by the
Administrator prior to November 15, 1990;
(2) The best available data on an annual basis of actual emissions during the
chosen base year for each hazardous air pollutant emitted from each
emission point or group of emission points listed in the source;
(3) The total base year emissions from the source of all hazardous air
pollutants calculated by summing the data from individual emission
points;
(4) The total base year emissions from the source adjusted for high-risk
pollutants calculated by multiplying the base year emissions of each
chemical by the appropriate weighting factor from Table 2-2 and
summing the result;
(5) The supporting basis for each emission number for each emission
point(s), including;
2-17 07/29/91
-------
TABLE 2-1. INFORMATION REQUIREMENTS FOR DEMONSTRATION
OF EARLY REDUCTION(cont'd)
(i) For test results submitted as the supporting basis, a
description of the test protocol followed, any problems
encountered during the. testing, and a discussion of the
validity of the method for measuring the subject emissions;
and
(ii) For calculations based on emission factors, material
balance, or engineering principles and submitted as the
supporting basis, a step-by-step description of the
calculations, including assumptions used, and a brief
rationale for the validity of the calculation method used;
(6) Evidence that the emissions from individual sources are not artificially or
substantially greater than emissions in other years prior to
implementation of emission reduction measures;
Post-Reduction Emissions:
(1) For each emission point or defined group of emission points listed in the
source, a description of all control measures employed to achieve the
required emission reduction;
(2) The best available data on an annual basis of actual emissions and
following employment of reduction measures of all hazardous air
pollutants and each emission point(s) in the source;
(3) The total post-reduction emissions of all hazardous air pollutants from the
source calculated by summing the individual emission data;
(4) The total post-control emissions adjusted for high-risk pollutants
calculated by multiplying the post-reduction emissions for each pollutant
by the appropriate weighting factor and summing the results;
(5) The supporting basis for each emission number, including;
(i) For test results submitted as the supporting basis, a
description of the test protocol followed, any problems
encountered during the testing, and a discussion of the
validity of the method for measuring the subject emissions;
and
2-18 07/29/91
-------
TABLE 2-1. INFORMATION REQUIREMENTS FOR DEMONSTRATION
OF EARLY REDUCTION (concluded)
(ii) For calculations based on emission factors, material
balance, or engineering principles and. submitted as the
supporting basis, a step-by-step description of the
calculations, including assumptions used, and a brief
rationale for the validity of the calculation method used;
(6) Evidence that all emission reduction was achieved prior to proposal of an
applicable standard issued under section 112(d) of the Act; or prior to
January 1, 1994 for sources subject to enforceable commitments;
(7) Evidence that none of the emission reduction achieved was due to lower
production rates or fewer hours of operation compared to the base year,
unless such lower rates or hours are shown to be permanent and no
compensating increases in rates or hours occur at other facilities within
the contiguous area under common control which contains the source
or, if they occur, do not result in emissions of hazardous air pollutants;
and
(8) Evidence that emission reductions achieved due to the shutdown of
equipment within the source are permanent. If shutdown equipment is
replaced by new equipment, or will be replaced by new equipment prior
to the expiration of any compliance extension granted to the source, the
HAP emissions from the new equipment or as applicable, the projected
HAP emissions shall be counted in the post-control emissions for the
source.
2-19 07/29/91
-------
One of the key requirements is evidence that the source conforms to one of the
allowable source definition options under §63.73. Considerable discussion is provided
in the previous section on allowable groupings of emission sources. The key here is
for the owner or operator to identify the source definition option selected under §63.73
(e.g., paragraph (3)) and provide adequate information to justify the selection.
Another requirement is specification of the base year selected. The regulation
requires that the base year must be 1987 or later, with one exception. If the owner or
operator can provide evidence that data for the source as defined were submitted to
the Administrator for 1985 or 1986 prior to November 15, 1990 pursuant to a section
114 request, that data also may be used to determine base year emissions. In this
case, a copy of the section 114 request and a copy of the information provided in
response to the request would be sufficient evidence.
The owner or operator must also provide evidence that the base year emissions
were not unusually high. Here, the owner or operator of the source needs to compile
and present information that clearly indicates the base year chosen is not unusual with
respect to emissions. In cases where annual emissions are primarily a function of
production rate, production rates for the year preceding the base year and following
the base year could provide an adequate demonstration that the base year is
representative (not unusually high). In other situations, emissions may be more
dependent on the hours of operation or the quantity of a particular material processed.
The source owner or operator must take the initiative in identifying a reasonable
parameter for demonstrating that emissions in the base year were not unusually high.
In addition to reducing total HAP emissions by 90 (95) percent, there are some
restrictions regarding high-risk pollutants. A total of thirty-five (35) high-risk pollutants
are identified in the early reduction regulations and EPA has devised a weighting
procedure to limit the use of offsetting reductions where emissions of any high-risk
2-20 07/29/91
-------
pollutant(s) are not reduced by 90 (95) percent. The list of high-risk pollutants and
their respective weighting factors are presented in Table 2-2. The list currently
includes 35 pollutants, 26 of which are carcinogens or potential carcinogens and 9 of
which are not carcinogens but cause other toxic effects. The weighting factors for the
carcinogens on this list were based on estimated carcinogenic potency of the
substances. Noncarcinogens on this Hst were subjectively assigned a value of 10.
There is no quantitative means of comparing carcinogenic and noncarcinogenic health
affects at this time. The list and the respective weighting factors are subject to change
as new information becomes available. Any changes will be published in the Federal
Register. As noted in Table 2-2, all HAP not included in the list are assigned a
weighting factor of one.
When high-risk pollutants are emitted from the source, the owner or operator
must demonstrate a 90 (95) percent reduction in base year emissions adjusted for
high-risk pollutants. The applicant may use the weighting factors according to the
following equation to make this demonstration:
MCjFj
0/ 0 ,
% Reduction = — - X 100
I MjFj
where:
MJ = mass of base year emissions of pollutant i
MCj = mass of post-reduction emissions of pollutant i
Fj = weighting factor for pollutant i
This weighting procedure is a direct response to the mandate in section
112(i)(5)(E) of the Act which specifies that the Administrator shall limit the use of
offsetting reductions in emissions for high-risk pollutants. Originally, EPA considered
requiring 90 (95) percent reduction of each individual high-risk pollutant. Many of the
high-risk pollutants, however, are emitted in very small, trace amounts. Reduction of
these emissions by 90 (95) percent can be extremely difficult or even technically
infeasible. Strict adherence to this requirement would prevent participation for many
2-21 07/29/91
-------
TABLE 2-2. WEIGHTING FACTORS FOR HIGH-RISK POLLUTANTS
Pollutant
CAS Number
Weighting Factor*
Carcinogens
2,3,7,8-Tetrachlorodibenzo-p-dioxin
Benzidene
Bis(chloromethyl)ether
Asbestos
Chromium Compounds
Hydrazine
Arsenic Compounds (inorganic including
arsine)
Chloromethyl Methyl Ether
Cadmium Compounds
Heptachlor
Beryllium Compounds
Acrylamide
Coke Oven Emissions
Hexachlorobenzene
Chlordane
Dichloroethyl ether (Bis(2-chloroethyl)
ether)
1 ,3-Butadiene
Benzotrichloride
Ethylene Dibromide (Dibromoethane)
Ethylene oxide
Vinyl chloride
Acrylonitrile
1 ,1 ,2,2-Tetrachloroethane
Vinylidene chloride (1,1-Dichloroethylene)
Benzene
1 ,2-Propylenimme (2-Methyl aziridine)
1746016
1332214
302012
76448
79061
57749
111444
106990
98077
106934
75014
107131
79345
75354
71432
75558
100,000
1,000
1,000
100
100
100
100
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
2-22
07/29/91
-------
TABLE 2-2. WEIGHTING FACTORS FOR HIGH-RISK POLLUTANTS (Continued)
Pollutant CAS Number Weighting Factor
Noncarcinogens
2,4-Toluene diisocyanate 584849 10
Acrolein 107028 10
Acrylic acid 79107 10
Chloroprene 126998 10
Dibenzofurans 132649 10
Mercury Compounds 10
Methyl isocyanate 624839 10
Methylene diphenyl diisocyanate (MDI) 101688 10
Phosgene 75445 10
*HAP not on the high risk list have a weighting factor of 1
2-23 07/29/91
-------
potential applicants. EPA determined that this was not consistent with encouraging
participation in the early reduction program and devised the weighting procedure,
which does not force reduction of any specific high-risk pollutants. Yet, because the
weighting factors magnify the importance of high-risk pollutant emissions, significant
(non-trace) emissions must be reduced in order to achieve "weighted" 90 (95) percent
reduction.
If a source emits only gaseous or only paniculate pollutants, the calculation of
reductions achieved is straightforward. However, a source emitting a combination of
gases and particulates has the option of separately demonstrating 90 and 95 percent
reductions, respectively, or applying a weighted average percent reduction between 90
and 95. For example, if a source emits equal amounts of gaseous and particulate
HAPs, then the weighted percent reduction is halfway between 90 and 95, or 92.5
percent. If the owner or operator chooses to apply a weighted average percent
reduction, the percent reduction required for total HAP shall be calculated as follows:
% W = 0.9 f£ Ma) + 0.95 r£ Mo) x 100
£ Mg + X Mp
where: % W = the required percent reduction
Mg = the base year mass rate (e.g. kg/yr) of each
gaseous HAP
Mp = the base year mass rate (e.g. kg/yr) of each
particulate HAP
A weighted average percent reduction may also be applied to the reduction
demonstration required for high-risk pollutants. If the applicant chooses to use the
weighted percent method for gases and particulates, the percent emissions reduction
required for HAP emissions adjusted for high-risk pollutants shall be calculated by the
following equation:
0-9 (I Mg.Fj) + 0.95 (I MpjFj)
%W = - X 100
MpiFi
2-24 07/29/91
-------
where %W = the required weighted percent reduction
Mg. = the base year mass rate (e.g., kg/yr) of each gaseous HAP
Mp. = the base year mass rate of each particulate HAP
FJ = weighting factor for each HAP
The demonstrations of total HAP reduction and HAP reduction adjusted for
high-risk pollutants must be calculated separately. In the case where the owner or
operator chooses to use a weighted percent reduction for gases and particulates, the
total HAP reduction may have a different percent reduction requirement than the HAP
reduction adjusted for high-risk pollutants. If the high-risk pollutants are gaseous, the
percent reduction adjusted for high-risk pollutants will be lower than the total HAP
percent reduction requirement. If the high-risk pollutants are particulates, the greater
weight will be given to the particulate or 95 percent requirement and, therefore, the
required percent reduction adjusted for high-risk pollutants will be higher than the total
HAP reduction requirement.
In general source testing is required as the supporting basis for base year and
post-reduction emissions. In order of preference, the source testing options are: an
EPA Reference Method (40 CFR 60 Appendix A and 40 CFR 61 Appendix B), an EPA
conditional method, or a test method validated by Method 301. Method 301, "The
Field Validation of Emission Concentrations from Stationary Sources", is included in
Appendix A to 40 CFR Part 63. A list of validated methods may be obtained from the
Emission Measurement Technical Information Center (MD-19), U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina 27711.
Calculations based on engineering principles, emission factors, or material
•
balance may be acceptable if the applicant demonstrates to the satisfaction of the
permitting authority that:
(1) no source test method exists;
(2) it is not technologically or economically feasible to perform source tests;
(3) it can be demonstrated that the accuracy of a calculated estimate is
comparable to source testing;
2-25 07/29/91
-------
(4) the base year conditions no longer exists, and emission data cannot be
produced by performing source tests under current conditions and
converting test results to reflect base year conditions more accurately
than a calculation procedure; or
(5) emissions from one or a set of points are insignificantly small
compared to total source emissions.
The first situation should be straightforward; either there is, or there is not, a
source test method. It is possible that an owner or operator would be unaware of an
existing method. Application reviewers would need to have a reference listing of
available methods. In other instances, even if a test method exists, testing may not
be the most appropriate method for determining the emissions from an emission point.
For example, if process emissions vary considerably, limited testing may not
accurately reflect the true annual emissions. The situations outlined in statements (2)
through (5) above are not straightforward and may be considered in combination with
one another. For example, the significance of an emission point may contribute to the
determination of what is technologically or economically feasible or whether the
calculated value is comparable to testing. To apply these reasons to a particular
source, the owner or operator and reviewer need to use a common sense approach
along with a knowledge of the emission point to determine if a calculation procedure is
appropriate for establishing emissions.
In general, the owner or operator or reviewer should consider how much
uncertainty would be introduced through the calculation procedure versus source
testing. In some cases, the reviewer may be able to quantify the relative uncertainty.
In other situations it may only be possible to make a qualitative judgement of the
accuracy. If the uncertainty in emissions is insignificant when compared to the total
emissions from the facility or when compared to the uncertainty from source tests,
then a calculation procedure is acceptable. For example, a source has defined three
emission points. Total emissions from two of the three emission points are established
by source testing to be 100 ton/year. The third emission point by reasonable
calculation emits about 1/2 ton/year. Testing for this emission point is not necessary.
2-26 07/29/91
-------
Even if the calculations significantly underestimated the emissions, the resulting
emissions would not significantly affect the total emissions.
The applicant and the reviewer should not lose site of the overall goal of the
reductions demonstration which is to determine whether or not the source has made
the necessary 90 (95) percent reduction in emissions of HAP. The major emission
points within the source are the critical data points. The most accurate means of
establishing emissions should be used for these emissions. The most accurate means
may or may not be testing. Smaller, insignificant emissions should be established
using reasonable but not necessarily the most accurate procedures. Test methods
that are unusually expensive or that require equipment to be dismantled or production
halted should not be imposed on emission points that contribute insignificantly to the
overall emissions.
The applicant is responsible for providing sufficient data to the reviewer to
determine if calculations are acceptable in lieu of testing. If the reviewer needs
additional technical assistance, support is available through the Office of Air Quality
Planning and Standards early reductions team. To assist owners and operators in
establishing emissions for their source, EPA will publish procedures for establishing
emissions that would be considered acceptable for the source categories subject to
112(d) standards. The documents will indicate the appropriate EPA reference method
or conditional method that should be used for source testing emission points from the
subject source, but the primary focus of these documents is accepted techniques for
establishing emissions when source testing is not performed. These documents do
not preclude a source owner or operator from establishing emissions using other
techniques that are appropriately documented, but source owners and operators are
encouraged to use the techniques prescribed in these documents. A notice
announcing the availability of a procedures document for the first group of source
categories (those for which standards will be proposed in the 1991-1993 time frame)
will be published in the Federal Register soon after proposal of the regulations
governing compliance extensions. A copy may be obtained from the EPA Library
(MD-35), Research Triangle Park, NC, 27711, Telephone (919)541-2777. Refer to
2-27 07/29/91
-------
"Procedures for Establishing Emissions for Early Reduction Compliance Extensions"
(EPA-450/3-91-012a).
If the source owner or operator uses calculation techniques other than those
prescribed in one of the EPA documents, the burden is on the owner or operator to
convince the permitting authority that the techniques used are sound and the best
available means for establishing emissions.
The early reduction regulation prohibits the use of EPA average emission
factors for estimating base year equipment leak emissions. Use of these factors may
produce significant overestimates of base year emissions in many cases. However,
source owners or operators could establish base year estimates for equipment leaks
specific to their sources consistent with other equipment leak emission estimating
protocols already established by EPA in the document entitled "Protocols for
Generating Unit-Specific Emission Estimates for Equipment Leaks of VOC and
VHAP,"EPA-450/3-88-010, October, 1988. These protocols allow the use of "leak/no
leak" factors or "stratified" emission factors, which better approximate an individual
source's actual emissions, as well as actual bagging data to establish source-specific
emission factors. The source must have screening data on each component
proposed to be covered within the source definition, with the exception of flanges and
other connectors (a special formula is used to determine the appropriate number of
these), to which the appropriate emission factors are applied to determine total
equipment leak emissions. Also, a source owner or operator may propose an
alternative estimating method to account for equipment leak emissions from the
source. Such methods would be reviewed and approved or denied on a case-by-case
basis.
Emissions reported for base year and post-reduction conditions may not
exceed allowable emission levels specified in any applicable law, regulation, or permit
condition. Sources with base year emissions that exceeded allowable emission levels
may still participate in the early reduction program, but the base year emissions used
to demonstrate 90 (95) percent reduction must be within the allowable level and not
based on the actual emission level.
2-28 07/29/91
-------
To demonstrate a 90 percent (95 percent for participate emissions) HAP
emission reduction, source owners and operators may take credit for emission
reductions achieved for any reason. The early reduction provisions in the Act and in
the proposed rule do not distinguish between reductions achieved voluntarily and
those that result from other regulatory requirements, including emission standards
promulgated under section 112 prior to the Clean Air Act Amendments of 1990.
Therefore, HAP emission reductions required by State, local, and even Federal
regulations qualify toward the early reduction goal, if the reduction was achieved after
the base year. This includes reductions under the recent Benzene NESHAP. To the
extent justified, air emission reductions achieved under the 33/50 Program (Industrial
Toxics Project) should also be credited toward the early reduction program. The
overlap between this program and the early reduction program is discussed fully in
section 4 of this document. Emission reductions resulting from shutdown or
curtailment of production can also be included, provided that they are "permanent",
i.e., for the duration of the 6-year 112(d) standard exemption period. A unit that starts
up during the 112(d) standard exemption period to replace production lost through
shutdown or curtailment (where the emission reduction was used in the early reduction
demonstration) must be included in the post-reduction emissions. For example, if the
owner or operator of a source that includes a butadiene unit, shuts the unit down but
builds a new one on the other side of the plant three years into the 112(d) standard
exemption period, the new unit must be included in the post-reduction emissions
determination, because it has replaced the production of the old unit.
Question and Answer
If a facility has an approved permit under the early reduction program and,
because of new information, one of the pollutants emitted by the facility is now
listed as a high-risk pollutant such that the facility would no longer qualify for the
early reduction program, what happens to the existing permit?
As previously mentioned, permits approved under the early
reduction program are valid for a six-year period. Neither
2-29 07/29/91
-------
the EPA Region nor the State will revoke an approved
permit on this basis. However, the source is responsible for
meeting other State or Federal regulations that may affect
emissions from the source.
What is baseline if the source is constructed and begins operation just prior to
proposal of a 112(d) standard?
The early reduction program was not intended for sources
that are built just prior to proposal of an applicable 112(d)
standard and in most cases it will not be possible for such
sources to participate. First, the regulations require that
actual and verifiable base year emissions be established.
This means that a representative operating history is
required prior to proposal of 112(d) standard. Additionally,
most states require a reasonably high level of control for
HAP emissions from new sources as part new source
permitting. Although possible, it will be difficult to achieve
90 (95) percent reduction above the level of control
required.
Are emission reductions due to enforcement actions creditable?
Yes, if base year emissions for the defined source are in
compliance with all State, Local and Federal Regulations.
For example, air emissions from a facility may be in
compliance with all regulations. However, if the wastewater
treatment unit is in violation of the Clean Water Act, an
enforcement action may require reduction of wastewater
concentrations of a pollutant as well as reduction of air
emissions of that pollutant. These reductions in air
emissions would be creditable for the early reduction
program.
Can HAP emission reductions resulting from criteria pollutant (i.e., VOC, PM)
offsets be credited toward early reductions in HAP?
Xes. As long as the reduction in HAP emissions occurred
after the base year chosen and the base year emissions are
within all regulatory requirements in the base year.
Can reductions in HAP emissions resulting from participation in the 33/50
Industrial Toxics Program be credited toward early reductions in HAP?
2-30 07/29/91
-------
Ves. The reductions in HAP emissions are creditable under
the Earlier Reduction Program. However, the Early
Reduction Program requires different supporting data for
base year and post-reduction emissions data. In the 33/50
program, the owner or operator must establish base year
emissions and post-reduction emissions in accordance with
the early reduction regulations.
Must the same base year be used for all emission points within a source?
Xes, but test data can be used for differing years. If test
data for various emission points within the source are
available from different years, the applicant must show that
they also are appropriate for the base year, or make
adjustments to the data (such as for production rate
differences between the test year and the base year) so that
it represents base year conditions.
Are Toxic Release Inventory (TRI) submissions acceptable as base year
emissions?
In general, TRI data alone are not sufficient to support base
year emissions. The early reduction regulation requires
more rigorous support for emissions data than is required
by TRIS. If the data submitted to TRIS has supporting data
that meets all the requirements of the early reduction
program, then it is acceptable. TRIS data will not be
accepted for the early reduction program simply because it
was reported to TRIS.
Do all emissions within permit levels qualify as not artificially or substantially
higher emissions?
No. The source owner/operator must provide actual data
demonstrating that the base year emissions were not
artificially high.
Should accidental releases be included in base year and post-reduction
emission or only routine emissions?
The intent of the early reduction program is to reduce
routine HAP emissions from sources. The definition of
actual emissions states that it "does not include excess
emissions from a malfunction". Base year and post-
2-31 07/29/91
-------
reduction emissions which include "abnormally high
emissions such as could be caused by equipment
malfunctions, accidents,..." are considered artificially or
substantially greater emissions and are not acceptable for
the early reduction program. There are some situations
where standards have been written for what may be
considered accidental releases. If malfunctions are
preventable, it may be possible to consider them not
accidental. The State and EPA will work with facilities on a
case-by-case basis if there is some question as to whether
a particular emission is considered accidental or routine.
The facility must keep in mind that if an emission is
considered routine it must be in compliance with all
applicable regulations to be acceptable as a base year
emission.
§63.75 ENFORCEABLE COMMITMENTS
This section of the regulation contains special provisions for sources that will be
affected by early 112(d) standards. Anticipated proposal dates for these early
standards are presented in Table 2-3. Since standards may be proposed for some
sources in the fall of 1991, facilities affected by these standards may not have enough
time to achieve reductions before proposal. If the source can achieve the reductions
prior to proposal of a 112(d) standard, it may do so and submit a permit application
when part 71 Federal regulations have been promulgated or the Title V program for
their State is in place, whichever occurs first. If it can not achieve reductions prior to
proposal, this section establishes a set-of procedures by which these sources can
participate in the early reduction program. The sources may participate by:
(1) entering into an enforceable commitment before proposal of an
applicable 112(d) standard; and
(2) achieving the reduction prior to January 1, 1994.
2-32 07/29/91
-------
TABLE 2-3. ANTICIPATED PROPOSAL DATES FOR EARLY STANDARDS
Source
Anticipated
Proposal Date
Synthetic Organic Chemical Manufacturing
Industry
Dry Cleaners Using Perchloroethylene
and 1,1,1 -trichloroethane
Commercial Sterilizers
Chromium Electroplating and Chromic
Acid Anodizing
Industrial Cooling Towers
Halogenated Solvent Cleaners
Gasoline Marketing
November 1991
November 1991
March 1992
February 1992
June 1992
September 1992
April 1993
2-33
07/29/91
-------
If the State has an approved permitting program under title V, the applicant
submits the enforceable commitment to the State and sends a copy to the EPA
Regional Office; The Office of General Counsel (OGC) (LE-132A), 401 M. Street, S.W.,
Washington, DC 20460, and the EPA Emissions Standards Division (ESD) (MD-13),
RTP, NC 27711; attention The Early Reductions Officer. Addresses for the Regional
Offices are provided in Table 2-4. If the State does not have an approved program,
the applicant submits the enforceable commitment to the EPA Regional Office and
sends a copy to the State, OGC and ESD. This will ensure that all involved parties are
aware of plans companies have for early reductions and will facilitate review of base
year emissions in enforceable commitments.
The information that is required in the enforceable commitment is similar to that
required for a permit application. In summary, the enforceable commitment consists
of four components:
• Source identifying information,
• Base year emissions,
• General plan for achieving the required reductions, and
• A statement of commitment.
A list of the specific requirements for enforceable commitments is provided in
Table 2-5. The source identifying information and base year emission requirements
are identical to the requirements for demonstration of early reduction.
The plan for achieving reductions may be general (i.e., not specify the type control
on each emission point), but should demonstrate that the source has seriously
considered the types of control that may be required to control the source by
90 (95) percent. In order to make an enforceable commitment, a company would
need to have determined with at least some degree of accuracy that the planned
emission reduction is achievable.
The commitment must be signed by the owner, operator or responsible party at
the source. The wording of the statement should follow closely the statement
presented in the regulation under §63.75 which reads:
2-34 07/29/91
-------
TABLE 2-4. EPA REGIONAL OFFICE ADDRESSES
Enforceable commitments must be submitted to the appropriate EPA Regional
Office at the following address:
Director, Air, Pesticides, and Toxics Management Division, EPA Region I (AAA),
John F. Kennedy Federal Building, Boston, MA 02203
Director, Air and Waste Management Division, EPA Region II, Jacob K. Javits
Federal Plaza, New York, NY 10278
Director, Air Toxics and Radiation Management Division, EPA Region III, 841
Chestnut Street, Philadelphia, PA 19107
Director, Air Management Division, EPA Region 4, 345 Courtland Street N E
Atlanta, GA 30365 ' "
Director, Air and Radiation Division, EPA Region 5, 230 South Dearborn Street
Chicago, IL 60604
Director, Air, Pesticides and Toxics Division, EPA Region 6, 1445 Ross Avenue
12th Floor, Suite 1200, Dallas, TX 75202
Director, Air; and Toxics Division, EPA Region ;7, 726 Minnesota Avenue
Kansas City, Ks 66101
Director, Air ;and Toxics Division, EPA Region 8, 999 18th Street, Suite 500
Denver, CO 80202-2405
Director, Air and Toxics Division, EPA Region 9, 1235 Mission Street San
Francisco, CA 94103
Director, Air and Toxics Division, EPA Region 10, 1200 Sixth Avenue, Seattle
WA 98101
2-35 07/29/91
-------
TABLE 2-5. COMPONENTS OF AN ENFORCEABLE COMMITMENT
Source Identifying Information:
(1) The name and address of the source.
(2) The name and telephone number of the source owner or operator or
other responsible official who can be contacted concerning the
commitment;
(3) An alternative mailing address if correspondence is to be directed to a
location other than that given in item (1);
Base Year Emissions:
(1) The base year chosen, where the base year shall be 1987 or later except
that the base year may be 1985 or 1986 if the owner or operator of the
source can demonstrate that emission data for the source for 1985 or
1986 was submitted to the Administrator pursuant to an information
request issued under section 114 of the Act and was received by the
Administrator prior to November 15, 1990;
(2) The best available data on an annual basis of actual emissions during the
chosen base year for each hazardous air pollutant emitted from each
emission point or group of emission points listed in the source;
(3) The total base year emissions from the source of all hazardous air
pollutants calculated by summing the data from individual emission
points;
(4) The total base year emissions from the source adjusted for high-risk
pollutants calculated by multiplying the base year emissions of each
chemical by the appropriate weighting factor from Table 2-2 and
summing the result;
(5) The supporting basis for each emission number for each emission
point(s), including;
(i) For test results submitted as the supporting basis, a description of
the test protocol followed, any problems encountered during the
testing, and a discussion of the validity of the method for
measuring the subject emissions; and
(ii) For calculations based on emission factors, material balance, or
engineering principles and submitted as the supporting basis', a
step-by-step description of the calculations, including assumptions
used, and a brief rationale for the validity of the calculation method
used;
(7) Evidence that the emissions from individual sources are not artificially or
substantially greater than emissions in other years prior to
implementation of emission reduction measures;
2-36 07/29/91
-------
TABLE 2-5. COMPONENTS OF AN ENFORCEABLE COMMITMENT(confd)
General Control Plan:
(1) The general plan, for achieving the required hazardous air pollutant
emissions reductions at the source including descriptions of emission
control equipment to be employed, process changes or modifications to
be made, and any other emission reduction measures to be used; and
Statement of Commitment:
(1) A statement of commitment, signed by a responsible official of the
source, containing the following:
(i) A statement providing the post-reduction emission level for
total hazardous air pollutant emissions, total hazardous air
pollutant emissions, adjusted for high-risk pollutants, as
applicable, from the source on an annual basis which
reflects a 90 percent (95 percent for paniculate pollutants)
reduction from base year emissions;
(ii) A statement certifying that the base year emission data
submitted as part of the enforceable commitment constitute
the best available data for base year emissions from the
source and are correct to the best of the responsible
official's knowledge;
(iii) A statement that it is understood by the source owner or
operator that submission of base year emissions constitutes
a response to an EPA request under the authority of
section 114 of the Act and that the commitment is subject
to enforcement according to §63.80; and
(iv) A statement committing the source owner or operator to
achieving the required emission levels before January 1
1994.
2-37 07/29/91
-------
"I certify to the best of my knowledge that the base year emissions given above
are accurate and acknowledge that these emission numbers are being
submitted in response to an EPA request under section 114 of the Act.
Furthermore, I commit to achieve before January 1, 1994 the stated post-
reduction emission level(s) at the source, which will provide the 90 (95) percent
reduction required to qualify for the compliance extension, and acknowledge
that this commitment is enforceable as specified in Title 40 Part 63 Subpart D of
the Code of Federal Regulations"
The owner or operator of a source may rescind its commitment at any time
prior to December 1, 1993 without penalty. Any source that rescinds its commitment
must comply with the applicable standard issued under section 112 (d) of the Act by
the compliance date specified in such a standard.
Sources found submitting false information in their commitment for early
reduction shall be subject to enforcement action under Section 113 of the Act or other
Federal statutes. This is an important consideration for a company to weigh when
preparing the commitment. All data and information submitted should be carefully
reviewed to verify its accuracy and veracity. The EPA may exercise its authority to
ensure the integrity of information contained in the commitments by conducting audits
of any or all submittals. The purpose of this activity is to encourage sources to make
only serious commitments that can be backed up with acceptable emission data.
Enforceable commitments for several different sources within a contiguous
facility may be aggregated into one submittal, provided that base year emissions and
post-reduction emission levels committed to are identified separately for each source.
A single enforceable commitment submittal may not involve sources from more than
one contiguous facility.
Question and Answer
Is submittal of unacceptable base year emission data the only basis for
denying an enforceable commitment?
No. But, the base year emission data are the primary basis
for denial or acceptance. In addition to acceptable base
year data, the enforceable commitment must satisfy all of
the requirements listed under §63.75 of the regulation. This
2-38 07/29/91
-------
includes a signed commitment that satisfies the
requirements and also a general control plan. The base
year emissions are the most critical data provided. Hence,
most denials will be based on some deficiency in
establishing base year emissions.
Under what circumstances will States handle enforceable commitments?
If a State program is approved prior to December 1, 1993,
the State would be the permitting authority and would
handle any enforceable commitments.
If 112(d) standard turns out to be less than 90 percent control, can the source
rescind its enforceable commitment?
A source may rescind any enforceable commitment prior to
December 1, 1993 for any reason without penalty. After this
date, the facility must comply with its commitment.
§63.76 REVIEW OF BASE YEAR EMISSIONS
The proposed rule specifies review of base year emissions data for all
enforceable commitments and in the event a source requests review of its base year
emissions prior to submittal of a permit application. The overall schedule for review of
base year emissions submitted as part of an enforceable commitment or as a request
for base year review is presented in Figure 2-7. In addition, the schedule for review of
base year emissions relative to the submittal date is presented in Figure 2-8. This
schedule varies greatly depending on the completeness and approvability of the
submittal. The top line of the figure represents the case in which the initial submittal
was complete and approvable without any changes. The bottom line represents the
situation in which the submittal was not complete, the revised submittal was not
approvable, public comments were received during an extended public comment
period and the applicant resubmitted the emissions within 90 days. It does not
represent worst case because each event only required one revision but could
2-39 07/29/91
-------
EPA Administers Program Transition
States Administer Program
IVJ
o
-Nl
CO
EC (or ba..im.) R.v|.w.d
Additional Baseline Reviews
EC (.r ba..im.) sub.ni.ui> Additional Baselines Submitted
Duration of Overall Program " _
1991 If
Mid 1991
Industry
Consultations
Earliest E*C
J^
J92 199JJ\ 1994
1995 1996 1997 1998
12/1/93 1/1/94
Permit Reductions
Applications Achieved
Due (for EC (for EC sources)
Sources)
-~L— •""" :
• --c» *- *
1999 2000 2009
"
Nov. 1999 Nov. 2009
Proposal of Last
Las* 1 1 2(d) Compliance
Standard Extension
Expires
EC: Enforceable Commitment
Figure 2-7. Early Reduction Program: Duration of Key Activities
-------
UNCONTESTED REVIEW
Completeness
Review
1
Emission Estimate Review
•
n
E<
Subm
: SOD
lied
ays 60 D
ays 90 D
lys 1201
>ays ISO I
lays 1801
lays 2101
lays 240
Daya
ro
EC
Submitted
30 Day*
10
(O
(O
REVIEW WITH ADVERSE COMMENT
Icomplsiensss 1
Review Corr *
1 Emission Estimate Adequacy
Initial Review Corr. *
; i
Subsequent
Review
"--»,
Public
Comment
Period
-—
BO Day*
90 Day*
120 Days
ISO Day*
1 BO Days
2^0 Days 240 Day*
Corrections period after comment* are received
Figure 2-8. Example Review Times for Enforceable Commitment (or Baseline) Review
-------
represent reasonable worst case. For review requests sent to the State, a copy of the
request shall also be submitted to the Region. Prior to approval of the State permit
program, review requests should be sent to the appropriate Regional Office and
copies should be sent to the applicable State agency, and the early reductions officers
in OGC and ESD. (See addresses §63.75)
Within 30 days of receipt of an enforceable commitment or a request for review
of base year emissions, the EPA Regional Office must notify the applicant whether the
base year emissions data contained in the submittal are complete or incomplete. At
this point in the review process, the determination is whether all information required
for the base year emission submission has been supplied, not necessarily whether the
information is adequate for the purposes of the early reduction program. If the
Regional Office accepts the submittal as complete, the information is entered into the
Early Reduction Program Tracking System (ERPTRAX). Based on the data entered
into ERPTRAX, EPA Headquarters will publish a monthly list of all submittals nationally.
If EPA determines the base year emissions data are incomplete, the deficiencies in the
estimate will be provided to the owner or operator of the source, who must correct the
deficiencies and resubmit the base year emissions data before further review can
proceed.
Within 60 days of a completeness determination, EPA must judge the adequacy
of the enforceable commitment or emissions data submission and give notice of that
determination. If EPA determines that the base year emissions are approvable, a
notice providing the aggregate base year emissions will be published by advertisement
in the area affected. The advertisement will explain that the emissions submitted for
base year review or as part of an enforceable commitment are being proposed for
approval and note the availability of additional nonconfidential information contained in
the enforceable commitment for public inspection in at least one location in the
community in which the source is located, and in the appropriate EPA Regional Office.
A 30 day public comment period will be provided, with an opportunity to extend it to
60 days and/or hold a public hearing upon request by an interested party.
2-42 07/29/91
-------
A recent FEDERAL REGISTER notice regarding categories of data that qualify
as "emissions data" and thus are not regarded as confidential has been published
(56 FR 7042, February 21, 1991). Such data includes but is not limited to:
identification of the facility and emission points, emission types (type of release point
and specific pollutants), emission rates, release heights, descriptions of terrain and
surrounding structures, stack or vent diameters at point of emission, release velocities,
release temperatures, frequencies of releases, durations of releases, concentrations,
densities of emission streams or average molecular weights, boiler or process design
capacities, emission estimation methods, percent space heat, and hourly maximum
design rates. Additional data may be provided to the reviewing agency that is
considered confidential and will not be available for public comment and review.
If EPA determines that the base year emissions are not approvable because the
supporting data or calculations are incorrect or deficient in some manner, the applicant
will be notified of the decision and the reasons for the decision. The applicant must
make the necessary corrections and resubmit the base year emissions data. There is
no time limit for resubmittal of the base year emissions data that were submitted for
early review; however, it is assumed that applicant would resubmit as quickly as
possible to allow adequate time after approval to implement the emission reduction
plans. Revised base year data as part of an enforceable commitment, however, must
be resubmitted within 90 days or the enforceable commitment will be considered
withdrawn. The permitting agency will send a notice to this effect to the applicant.
The source must then comply on the same schedule as other sources to any
applicable MACT standard. If the applicant chooses to resubmit corrected emissions
data EPA will review the revised estimate within 30 days and, if approvable, will publish
a notice to that effect.
If no adverse public comments are received by the reviewing agency on the
proposed base year emissions for a source, the data submission shall be considered
approved at the close of the public comment period. The reviewing agency will send
notice of approval to the applicant and publish a similar notice by advertisement in the
area affected.
2-43 07/29/91
-------
In the event that adverse comments are received, the reviewing agency has the
authority determine which, if any, public comments need to be addressed for the base
year emissions to be approved. If the reviewing agency agrees that corrections are
needed, it will notify the applicant of the disapproval and the reasons for the
disapproval. An applicant may then correct disapproved base year emission data and
submit the revised base year emission data or revised enforceable commitment. The
same time limitations for resubmittal of base year emissions data apply as described in
the above paragraph.
If the reviewing agency is satisfied that the revised submission accounts for the
adverse comments, it will send notice of approval to the applicant and publish the
approval by advertisement in the area affected. The revised submission will not be
open to public comment. If the applicant does not address all the comments, the
agency shall return the submission with a list of reasons for disapproval. The same
time limitations for resubmittal apply as described in the above paragraph.
The reviewing agency may determine that the adverse comments do not
warrant changes. If this is the case, the reviewing agency will send notice of approval
to the applicant and publish the approval and the reasons for not accepting the
adverse comments by advertisement in the area affected.
Once base year emissions have been approved, EPA will honor the data and
will not change criteria or approval arbitrarily. However, review of base year emissions
does not provide an absolute shield against changes. Discovery of incorrect or
fraudulent information in the emission data or supporting materials even after its initial
approval could potentially invalidate the base year data and require revision to it. In
the case of fraudulent information, EPA may bring an enforcement action against the
source owner or operator under section 113 of the Clean Air Act. Such discrepancies
could be discovered at any stage of the process, including during review of the permit
application. Base year data should be carefully reviewed and approved by
knowledgeable company officials before submittal.
2-44 07/29/91
-------
Question and Answer
How do facilities appeal decisions made under this program?
Since decisions under the early reduction program are not
judicially reviewable, there is not formal appeals process for
decisions regarding base year emissions data. Appeals
concerning demonstration of early reduction will be
handled according to procedures outlined in the permitting
regulations (Part 70 or Part 71, whichever is applicable).
Although there is no appeals process for baseline emissions
data, the review process for base year emissions is
designed to reach agreement. The State, Region, EPA
Headquarters review team and public will review the base
year emissions and allow the facility an opportunity to revise
and resubmit the emission data, if adverse comments result
from the review. EPA, however, will not accept poor quality
base year emissions data. In the case of disagreements
regarding base year emissions, the decision of the
reviewing authority will be final.
Who pays for the local advertisement and the announcement in the Federal
Register?
EPA headquarters will pay for the announcements in the
Federal Register. The reviewing agency will pay for the
notification in local publications.
What action needs to be taken if the base year emissions data conflict with data
previously submitted to TRIS?
The early reduction program requires more rigorous support
for base year emissions than is required by TRIS. It is
possible that the process of determining emission data
more rigorously will result in emissions data different from
what was reported to TRIS. In most instances, it will not be
possible for the reviewing agency to compare these data
because TRIS data is reported for the entire facility,
whereas the early reduction application will likely include
only a portion of the facility. If the facility realizes that
emissions are different than those reported under TRIS, the
facility should submit a modification to the TRIS data.
2-45 07/29/91
-------
§63.77 APPLICATION PROCEDURES
The request for a compliance extension and alternative emission limitation will
be in the form of a permit application. The application should contain the information
necessary to demonstrate achievement of the early emission reduction by the
appropriate deadline, as well as any additional information required for a complete
permit application (as specified in regulations under Part 70 or 71, which implement
permit programs required under Title V of the Act as amended). In most instances,
the application must be received by the appropriate permitting authority before
proposal of an applicable 112(d) standard. However, there are two exceptions. The
first exception is for sources that previously made an enforceable commitment, where
the permit application must be received no later than December 1, 1993 (which may
be after proposal of an applicable standard). The second exception is for sources
which have achieved qualifying reductions prior to proposal of an applicable MACT
standard but which are unable to submit a permit application before proposal,
because the Federal permit program has not been initiated (i.e., Part 71 Federal
permitting regulations have not been promulgated) and the State does not have a
permit program approved pursuant to Title V of the Act. These programs will be
necessary to define the information needed for a complete permit application. This
situation may arise within the next year or so, before Part 71 regulations are
promulgated and any State permitting programs are approved. Therefore, to take this
situation into account, the proposed rule specifies that the deadline for submitting
permit applications under the early reduction program is the later of the following
dates:
(1) the date of proposal of an applicable 112(d) standard; or
(2) 120 days after promulgation of Part 71 regulations or 120 days after
approval of a State permit program under Title V of the Act, whichever
occurs first.
It is recommended that owners or operators in this situation notify the appropriate EPA
Regional Office of their intent to send in a permit application for the early reduction
program. The EPA Regional Office, in turn, will notify the potential applicant when the
2-46 07/29/91
-------
Part 71 regulations have been promulgated or the appropriate State has received
approval for a Title V permit program, whichever occurs earlier. This will give the
applicant timely notice of an approaching permit application submittal deadline.
The permit application for sources with an enforceable commitment should
demonstrate that a qualifying early reduction has been achieved or, where applicable,
will be achieved by January 1, 1994 (as required in §63.74 of the proposal rule). Test
data to support the post-reduction emissions data may be submitted up to 90 days
after the deadline for submittal of the permit application. This submittal allows the
source flexibility to provide required post-reduction emission data from tests conducted
after final controls or reduction strategies are in place. The permit application should
specify appropriate emission limitations for the source and the test method or
equivalent means used to determine the emission limitation. Current EPA plans, under
proposed permitting regulations published May 10, 1991 (56 FR 21712), would require
that the permit be issued within nine months after receipt of the complete permit
application. Until that time, the enforceable commitment would remain the enforceable
instrument for the source (section 112(i)(5)(B) of the Act provides that the commitment
"shall be enforceable to the same extent as a regulation under this section.").
If the relevant State has an approved Title V permit program, it will be
responsible for processing the application according'to provisions in 40 CFR Part 70
(scheduled for promulgation in November 1991). For sources in States without
approved Title V permit programs, applications should be submitted to EPA pursuant
to 40 CFR Part 71. (These regulations are scheduled for proposal in November 1991
and promulgation in May 1992.) A fee may be required by States to offset the costs
of reviewing applications. (If EPA is the permitting authority, a fee as specified in
40 CFR 71 would be required.)
The overall schedule for review of permit applications submitted as part of the
early reduction program is presented in Figure 2-9. The last 112(d) proposal date is
November 1999. If permit applications must be submitted prior to proposal and review
of the application must be accomplished with 9 months of receipt of a complete
2-47 07/29/91
-------
EARLY REDUCTION PROGRAM
DURATION OF KEY ACTIVITIES
EPA Administers Program Transition
o>
States Administer Program
Permit Applications Reviewed
Permit Applications Submitted
EC (or bai.iin.) H.vi.w. Additional Baseline Reviews
EC(orba».nn.)submi».dJ> Additional Baselines Submitted
Duration of Overall Program
•
1991
1992
tl
199$ ]\1994
1995
1996
1997
1998
1999
2000
HC*
Mid 1991
Q Industry
12/1/93 1/1/94
Permit Reductions
^ Consultations Applications Achieved
Earliest EC Due (for EC sources) (for EC sources)
5
Nov. 1999
Proposal of
Last 112(d)
Standard
»
EC: Enforceable Commitment
Figure 2-9. Early Reduction Program Duration of Key Activities
•
2009
Nov. 2009
Last
Compliance
Extension
Expires
-------
application, all early reduction permits will be reviewed by the end of the year 2000.
This is the last year an extension may be granted.
Question and Answer
Do base year emissions submitted for early approval need to be
resubmitted during application?
No. The applicant simply needs to include a statement that
the data have not changed since the submittal of the base
year emissions. However, the rule does not provide an
absolute shield against rejection of the base year emission
data. Discovery of incorrect or fraudulent information in the
emission data or supporting materials even after its initial
approval, could potentially invalidate the base year data and
require revision.
§63.78 EARLY REDUCTION DEMONSTRATION EVALUATION
In determining whether to approve or deny a permit application, the permitting
authority evaluates all available information, including that supplied by the source
owner or operator in the early reduction demonstration and information received from
public comments on the application. Specific to the demonstration of early reductions,
the permitting authority would decide whether the information and data required had
been provided and whether data were valid considering the following:
1. Did the facility provide the necessary plant identifying information
to adequately describe the source and the emission points within
the source?
2. Does the source meet one of the definitions described in
§63.73?
3. Were emission tests conducted in accordance with the
procedures and requirements of the proposed rule?
4. Were justifications acceptable for using something other than testing to
establish post-reduction emission data?
2-49 07/29/91
-------
5. Are engineering calculations correct and the assumptions underlying the
calculations valid?
6. Have emission factors been appropriately applied and can their use be
reasonably expected to represent the emissions from the source
accurately?
7. Are material balance data adequately documented by records and
sufficiently accurate to give credible emission estimates?
8. Have all HAP emissions from each source for which a compliance
extension is requested been documented and included in the
calculations?
9. Were high-risk weighting factors appropriately applied to all
high-risk HAP?
After evaluating a permit application containing an early reduction
demonstration, the permitting authority will make a determination to either approve or
deny it. Specific reasons for denial include but are not limited to:
1. The information provided by the owner or operator is incomplete.
2. The source is not correctly identified.
3. The required 90 (95) percent reduction has not been demonstrated or it
has not continued to be achieved after demonstration.
4. The base year or post-reduction emission data are incorrect or not
sufficiently reliable or well-documented to determine with reasonable
certainty that required reductions have been achieved. (Sources which
submit base year emission data for review early, including sources which
submit an enforceable commitment, should not be subject to a second
base year review at the permit application stage. Note, however, that
base year emission data could change at this stage if they are found to
be based on incorrect or fraudulent information.
2-50 07/29/91
-------
5. The emission of HAPs or the performance of emission control measures
are sufficiently variable or unreliable as to preclude determination that the
required reductions have been or will continue to be achieved.
If the permit is denied, the permitting authority will notify the applicant of the
denial and state the reasons for that denial.
§63.79 APPROVAL OF APPLICATIONS
If the application is approved, the reviewing agency establishes by permit
issued under Title V of the Act enforceable emissions limitations for the source
reflecting the control which qualified the source for the compliance extension. The
permit would also include operating conditions and compliance monitoring, reporting,
and recordkeeping requirements necessary to ensure continuing compliance.
Although the demonstration of 90 (95) percent reduction of HAP emissions
must be expressed in terms of actual annual emissions, the emission limitation may be
expressed in a number of different ways. A numerical emission limitation in the same
format as applicable source category standards would be preferable. However, this
may not be possible if, for example, the early reduction is being achieved with
emission control technology that is different from that on which the standard is based.
A different format may be necessary in such a case, or a different time period for
averaging emissions (e.g., 24 hours vs. 1 month) may be appropriate. The main
objective in selecting the format and units of the emission limitation, and
complementary monitoring, recordkeeping, and reporting requirements is to ensure
continuing achievement of the 90 (95) percent reduction of emissions. Although a
numerical emission limitation is the preferred format, if a numerical limitation is not
feasible for technological or economic reasons, some other requirements could be
established instead as long as it reflects the reduction which qualified the source for a
compliance extension.
The emission limitation would be effective and enforceable immediately upon
issuance of the permit for the source and would remain in effect until six years after
2-51 07/29/91
-------
the compliance date for the applicable section 112(d) standard, at which time the
source would be required to comply with the standard. Since permits will be issued
for periods not to exceed five years, there will be at least two permits in effect over the
six-year compliance extension. The second and subsequent permit, which will be
issued when the first one expires, will contain the alternative emission limitation for the
remainder of the six-year extension, and as appropriate, the limitations to comply with
the 112(d) standard.
Emission reductions of HAP for the purpose of obtaining an alternative
emissions limitation under section 112(i)(5) of the Act are not creditable for the
purpose of meeting an offset requirement under section 173(a)(1) of the Act. A
source in a nonattainment area (an area where a national ambient air quality standard
is exceeded) may need to obtain offsets for new construction or modification activities.
The HAP reductions are not allowed as offsets in this instance because
section 173(c)(2) of the Act states: "Emission reductions otherwise required by this Act
shall not be creditable as emission reductions for purposes of any such offset
requirement." A source emitting HAPs either will have to comply with a standard
issued under section 112(d) of the Act or an alternative emissions limitation which is
granted to the source in lieu of such a standard. Therefore, the reduction of HAP
emissions under the early reduction program is a substitute for the reduction of HAP
emissions as "required" under a 112(d) standard.
However, a source owner or operator may use as offsets any reductions in
HAP emissions in excess of those required to qualify for an exemption under the early
reduction program or reductions in non-HAP emissions which are obtained through
use of the HAP emission reduction measures, if such reductions are not required by
any other provision of the Act and meet the other requirements for offsets under Title I
of the Act. These reductions are allowed as offsets pursuant to I73(c)(2) of the Act
which further states: "Incidental emission reductions which are not otherwise required
by this Act shall be creditable as emission reductions for such purposes..." As a
simple example, consider a source emitting ethylene (a non-HAP) and ethylene oxide
(a HAP) which is controlled for purposes of qualifying for a compliance extension
2-52 07/29/91
-------
under the early reduction program. Assume that the control measured used reduced
ethylene oxide emissions by 92 percent or 46 tons per year and also reduce ethylene
emissions by 20 tons per year, although there is not a requirement to reduce the
ethylene emissions. Further, assume that the permit issued to the source requires a
continuing 92 percent reduction. In this instance, the 20 ton per year reduction in
ethylene emissions may be used, if needed, to offset an increase in volatile organic
compound emissions from new construction or a modification of an existing source.
Additionally, since the source achieved a 2 percent HAP reduction beyond that
required to obtain an extension, the extra 2 percent reduction, or 1 ton per year in this
example, may be used as an offset.
Question and Answer
May sources whose application for an extension under the Early
Reduction Program is denied apply for a compliance extension under
Section 112(i)(3)(B)?
/es. The regulation does state that facilities not meeting
requirements of the early reduction program must comply
with the 112(d) by its compliance date. The intent is not
that these facilities cannot apply for an extension but that
the same compliance date(s) now apply to the facility as if
the facility had never applied for the Early Reduction
program.
§63.80 ENFORCEMENT
All base year and post-reduction emissions information submitted as part of a
permit application or an enforceable commitment are considered to have been
requested by the Administrator under the authority of Section 114 of the Act.
Therefore, any fraudulent statements contained in the such submittals will be
considered violations of section 114 and are actionable under section 113 of the Act.
In appropriate situations, fraudulent statements in these submittals will be considered
2-53 07/29/91
-------
violations of 18 U.S.C. 1001, the general false swearing provision of the United States
Code.
If an early reduction demonstration in a permit application is disapproved,
whether or not the source is subject to an enforceable commitment, the owner or
operator must comply with any applicable 112(d) standards. Failure to comply with
the applicable 112(d) standards is actionable under section 113 of the Act. Similarly,
failure to comply with an alternative emission limitation is actionable under section 113
of the Act.
Question and Answers
At the end of the six year compliance extension, does the source have to
continue to comply with the alternative emission limitation for emission points
not covered by the 112(d) standard?
Nothing in the Early Reduction program requires continued
compliance with the alternative emission limitation after the
six-year compliance extension. States, however, may have
the authority to continue this requirement when issuing the
renewal permit.
If a source violates the alternative emission limitation, is the compliance
extension revoked?
No. The source is simply in violation of its permit condition
and will be treated in the same manner as any other
violation.
If a source fails to meet an enforceable commitment, how long is it subject to
penalties?'
The source is subject to penalties until 112(d) standard is
promulgated and the source is in compliance. If the source
has made a good faith effort to achieve the enforceable
commitment and/or the emission reduction meets what has
been proposed as 112(d) standard, such actions will be
taken into consideration in establishing penalties.
2-54 07/29/91
-------
§63.81 RULE FOR SPECIAL SITUATIONS
When a source is subject to multiple 112(d) standards, the proposal date of the
first applicable standard is the proposal date which governs the deadline for early
reduction program. In other words, a permit application or enforceable commitment
must be submitted prior to proposal of the earliest 112(d) standard that applies to any
emission point in the source definition. The extension for compliance, however,
begins on the compliance date of the 112(d) standard applicable to the emission point.
This will lead to different compliance extension expiration dates for different emission
points in a source subject to more than one 112(d) standard.
2-55 07/29/91
-------
3.0 PROGRAM IMPLEMENTATION
The EPA is committed to making the early reduction program a success and
will play an active roll in implementation of the early reduction regulations. The EPA
recognizes the burden this program could put on EPA Regional Offices and state
agencies. In an effort to assist the Regional Offices and the states, EPA has
developed a management system for review of enforceable-commitments and is also
committing a pool of its staff to implementation of the program. Depending on the
needs of the program, EPA may develop similar management systems for the review
of permit applications under the early reduction program.
The objective of this chapter is to better prepare the Regional EPA and State
reviewers for implementation of the program. With this in mind, the intent of this
chapter is to clearly define the roles of EPA Headquarters staff, the Regional Offices,
and the states in implementing the program. Additionally, this chapter provides
checklists, tracking forms, and examples of the types of materials reviewing agencies
will need to generate.
ENFORCEABLE COMMITMENTS
Initial activity on the early reduction program is expected to be the submittal of
enforceable commitments. In fact, enforceable commitments and baseline reviews are
the only submittals EPA Regions and states will be able to process at the outset. In all
likelihood, neither the EPA Regions nor the States will be able to process a permit
application until mid-1992. The reason for this is that federal regulations governing air
permit applications under Title V will not be promulgated until mid-1992 and the
approval process for State programs will not get started until the fall of 1991.
The reviewing agency (EPA Regions or later the State) is encouraged to hold
preapplication meetings with facility representatives, if there is an opportunity to do so.
In many cases, the first knowledge that a company wishes to participate in the
program will be when an application is received. However, in situations where the
3-1 07/29/91
-------
applicant gives advance notice that an application is being prepared, the Regional
Office should take advantage of the opportunity to hold a preapplication meeting. This
can be particularly useful in cases such as chemical manufacturing complexes where
there are many emission points and the potential exists for numerous source
definitions.
As mentioned above, EPA has developed a management system for review of
enforceable commitments. This draft management system is intended to ensure that
necessary support is provided to Regional Office reviewers during the early
implementation phase of the early reduction provision (i.e. post proposal) and that
consistent review and decision-making occurs. EPA Headquarters will be learning
about the scope and complexity of the implementation task, and can minimize
problems through regular communication and consultation. This is a highly visible
rulemaking, and several constituent groups will follow its progress with a keen interest.
The EPA will likely be asked for progress reports and information on how the provision
is working. Thus, the tracking of important milestones, using a system such as
SIPTRAX is being emphasized. The Headquarters team will prepare periodic summary
reports as necessary.
The SIPTRAX system is a computer based system which provides up-to-date
information on SIP activity in each Region, identified by State and nonattainment area,
pollutants involved and other pertinent information. It allows significant milestones in
the review process to be scheduled and tracked, such as receipt by the Regional
Office, date of completeness determination, dates for Federal Register actions, and the
like. These data handling needs are mirrored in the early reduction regulations, and
the extension is a natural one. Moreover, the system is user friendly, enabling direct
input and access by the Regional Office and Headquarters staff.
The early reduction management system is not intended to usurp the role of the
Regional Offices (and later the States) as primary reviewer/decision makers. Rather, it
is designed to get the program off on the right foot. A conference of the Regions,
interested States, and Headquarters should occur within 90-120 days of proposal to
take stock and discuss improvements, changes in roles, etc.
3-2 07/29/91
-------
Steps in the System
A schematic of this system is presented in Figure 3-1 and the individual steps
are described below.
1. Applicant prepares four copies of the enforceable commitment submittal,
sending one to the Regional Office, one to the State, one to OGC, and one to
OAQPS.
2. Regional Office logs in and advises applicant of receipt; enters date of receipt
into the computer tracking system.
3. Within 2 weeks of receipt of application, Regional Office initiates conference call
with Headquarters team (and as appropriate, the State) to discuss preliminary
assessment, identify issues (including schedule) and get Headquarters
commitment for opinion on completeness.
4. Within 30 days, Regional Office, after consultation with Headquarters, makes
completeness determination. (In the early phase of the Early Reduction
Program, Headquarters team will have responsibility for final decision if there is
a dispute.)
5. The OAQPS/DC will prepare and submit for publication an FR notice listing all
Enforceable Commitment applications received in the previous month.
6. If application is not deemed complete, Regional Office advises applicant of
additional information needed. This may involve asking for submittal of
additional material, or returning the application for substantive revision.
Applicant may comply or decide to withdraw the application. If a response is
not received within 90 days, the application will be considered withdrawn.
7. If the application is deemed complete, the Regional Office enters the
completeness date in the computer tracking system and initiates the 60-day
application review.
3-3 07/29/91
-------
DRAFT: 07/29/91
Figure 3-1. Management System for
Review of Enforceable Commitments
3-4
07/29/91
-------
8. If the application cannot be reviewed for approvability in 60 days, Regional
Office should discuss the problem with the Headquarters team. Review periods
longer than 60 days should be exceptions, not the rule, and should directly
stem from the complexity and scope of a submittal. If it agreed with
Headquarters that a longer review time is needed, a new schedule should be
established and the applicant so advised. (NOTE: If there has been a pre-
application conference, the possibility of extended review should be discussed
at that time.) Regional Office will enter any revised scheduled into the computer
tracking system.
9. Throughout the application review process, the Regional Office, Headquarters
team (and State, as appropriate) should consult via conference call to discuss
issues. Within the review period, Headquarters team (and State) will provide
Regional Office with their assessment of the approvability of the application.
10. Within 60 days (or otherwise agreed upon schedule), the Regional Office, after
consultation with the Headquarters team (and the State), will decide on
approvability of the application.
11. If there is a dispute regarding the approvability of the application, it will be the
Headquarters team's responsibility to promptly elevate the issue to get a
decision. No action is to be taken until a decision is made.
12. If the application is not approvable, the Regional Office will advise the applicant
of the deficiencies and the necessary corrective action. (NOTE: Applicant
should be advised of significant deficiencies as soon as they are identified.)
13. Applicant may correct deficiencies and submit to the Regional Office, or
withdraw the application. Responsibility lies with the applicant and required
action is on his clock. If a response is not received within 90 days, the
application will be considered withdrawn.
14. Regional Office reviews new information for approvability, consulting with the
Headquarters team and the State as necessary. If not approvable, repeat steps
13 and 14 with the applicant. If approvable, go to step 16.
3-5 07/29/91
-------
15. If approvable, the Regional Office will publish local notice of intent to approve,
requesting public comment (30-day comment period). Region enters notice
date into computer tracking system.
16. Thirty-day comment period can be extended to 60 days upon request of an
interested party. Regional Office publishes local notification of extension and
advises applicant.
17. Regional Office provides comments to applicant, Headquarters team and State.
18. If adverse comments are received, Regional Office will consult with
Headquarters team (and State) concerning disposition.
19. If comments are not accepted, Regional Office prepares an approval notice
explaining reasons comments were not accepted.
20. If comments are accepted, Regional Office assesses necessary corrective
action and advises the applicant.
21. Applicant may correct deficiencies and submit to Regional Office, or withdraw
the application. If a response is not received within 90 days, the application will
be considered withdrawn.
22. If revisions are acceptable, Regional Office prepares approval notice explaining
adverse comments and corrective action taken. If revisions are not acceptable,
repeat steps 21 and 22.
23. Regional Office publishes local notice of approval, and enters date into the
computer tracking system.
24. Headquarters includes approval information in the monthly FR notice on
applications received.
Reviewer Checklists for Enforceable Commitments
A set of four checklists are provided in Appendix B to assist the reviewers in
processing enforceable commitments. The first checklist is an overall checklist for
enforceable commitments. This checklist is designed to help keep track of key dates
and to insure that all actions required under the regulations are performed. When all
the boxes in the checklist are checked "yes1 then the review is considered complete
3-6 07/29/91
-------
and the enforceable commitment is approved.
The second checklist provided in Appendix B is for the completeness review.
This checklist is designed so that the reviewer simply checks the appropriate box
("Yes" or "No"). If all of the checks are "Yes", then the application is considered
complete. Conversely, if one or more boxes are checked "No", then the application
should be considered incomplete.
The third checklist provided in Appendix B is a source definition checklist. The
purpose of this checklist is to ensure that the source as defined by the owner or
operator meets the requirements of §63.73. This checklist is designed so that the
reviewer simply checks the requirement meet by the owner or operators source
definition. If any one box on the checklist is checked "Yes", then the definition of
source is acceptable.
The forth checklist provided in Appendix B is a checklist for review of emission
levels submitted for the base year. This should be the area of emphasis in the review
of an enforceable commitment. A separate checklist should be completed by the
reviewer for each emission point or set of grouped emission points. The form is
designed to provoke the judgements that need to be made on emissions data
provided for each emission point or set of grouped emission points. Unlike the other
two checklist, this one does require a considerable amount of judgement on the part
of the reviewer. As discussed in the previous chapter, it is the responsibility of the
reviewer to insure the accuracy of the base year and post-control emissions. This
requires that the reviewer keep a broad perspective in reviewing the individual
emissions data provided and continuously evaluate potential inaccuracies with respect
to the total source emissions.
BASELINE SUBMITTALS
The other activity that Regional Offices and states will become involved in
immediately is review of baseline submittals. One provision of the early reduction
regulations is that a facility owner or operator considering participation in the program
can request a review of year emissions. This allows the source owner or operator to
3'7 07/29/91
-------
establish the base year emission level for the source prior to submitting a permit
application.
The review of baseline submittals is nearly identical to the review of enforceable
commitment submittals. The only difference is that baseline submittals will not include
a commitment to reduce HAP emission or a general control plan.
Baseline submittals will also be entered into EPA's early reduction tracking
system. In fact the steps for review of baseline submittals will be identical to those
presented in Figure 3-1 for the review of enforceable commitments.
Reviewer Checklists for Baseline Submittals
A set of four checklists are provided in Appendix C to assist reviewers in
processing requests for baseline review. The first checklist is an overall checklist for
review of baseline submittals. This checklist is designed to help keep track of key
dates and to insure that all actions required under the regulations are performed.
When all the boxes in the checklist are checked "yes1 then the review is considered
complete and the base year emissions are considered approved.
The second checklist provided in Appendix C is for the completeness review.
This checklist is designed so that the reviewer simply checks the appropriate box
("Yes" or "No"). If all of the checks are "Yes" then the application is considered
complete. Conversely, if one or more boxes are checked "No", then the application
should be considered incomplete.
The third checklist provided in Appendix C is a source definition checklist. The
purpose of this checklist is to ensure that the source as defined by the owner or
operator meets the requirements of §63.73. If any one box on the checklist is
checked "Yes", then the definition of source is acceptable.
The forth checklist provided in Appendix C is a checklist for review of emission
levels submitted for the base year. This should be the area of emphasis in the review
of an baseline submittals. A separate checklist should be completed by the reviewer
for each emission point or set of grouped emission points. This checklists is identical
to the one provided in Appendix B for enforceable commitments.
3-8 07/29/91
-------
PERMIT APPLICATIONS
As indicated earlier, EPA may develop a management system similar to the
system presented in this chapter for enforceable commitments and baseline
submittals. Such a system will not be introduced until after the permitting regulations
have been proposed.
3-9 07/29/91
-------
4.0 INTERFACE WITH THE 33/50 (INDUSTRIAL TOXICS) PROJECT
The 33/50 Project is part of the Agency's overall Pollution Prevention Strategy
and the first of its new pollution prevention initiatives. Like the early reduction
program, participation in this project is fully voluntary. Many of the companies that are
currently participating in the 33/50 Project may also participate in the early reduction
program. The two programs are complementary, and the intent of this chapter is to
minimize confusion over the differing requirements and encourage participation in both
programs.
DESCRIPTION OF THE 33/50 PROJECT
The 33/50 Project was announced in February 1991 and is one of the major
components of the Agency's pollution prevention strategy. This program is designed
to encourage voluntary reduction of toxic releases and off-site transfers of 17
chemicals. The 17 targeted chemicals are:
Benzene
Cadmium and Cadmium Compounds
Carbon Tetrachloride
Chloroform (Trichloromethane)
Chromium and Chromium Compounds
Cyanide Compounds and Hydrogen Cyanide
Lead and Lead Compounds
Mercury and Mercury Compounds
Methylene Chloride (Dichloromethane)
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Nickel and Nickel Compounds
Tetrachloroethylene (perchloroethylene)
Toluene
1,1,1 -Trichloroethane (methyl chloroform)
Trichloroethylene
Xylenes (all xylenes)
This list of chemicals is drawn from the Toxics Release Inventory (TRI), based on
recommendations from EPA program offices and considering the following: high
production; high releases and off-site transfers relative to total production as indicated
4'1 07/29/91
-------
from TRI reports; potential for pollution prevention activities; and potential for a wide
range of health and environmental effects.
The 33/50 Project establishes a national goal to reduce releases and off-site
transfers of these 17 chemicals by one-third by 1992 and one-half by 1995 with
emphasis on the use of pollution prevention techniques. The baseline for these
reduction goals is the 1988' TRI. Based on the TRI, aggregate releases and off-site
transfers of the targeted chemicals was 1.4 billion pounds in 1988.
The Administrator to date has asked over 600 U.S. companies to participate in
this program. Each company has been asked to examine its processes to identify and
implement cost-effective pollution prevention practices related to the 33/50 Project
chemicals. Companies have also been asked to develop written commitments to
publicly state their reduction goals and how they plan to achieve them. The following
are general guidelines and milestones for what EPA has asked companies to do.
• May 15, 1991 - receipt of company wide numerical commitments.
• July 30, 1991 - receipt of facility specific and chemical specific numerical
commitments including discussion of pollution prevention activities, as
appropriate.
• November 30, 1991 - receipt of updated information, as needed, on
company and facility specific commitments as a result of activities with
other regulatory planning or toxic use reduction programs, or the Early
Reductions Program for 112(d) standards under the Clean Air Act.
Progress in achieving the 33/50 Project goals will be monitored through the use
of information reported to the TRI.
INTERFACE BETWEEN THE 33/50 PROJECT AND THE EARLY REDUCTION
PROGRAM
The Agency intends to implement the 33/50 Project and the early reduction
program in a coordinated manner to minimize confusion over their differing require-
ments and encourage participation. The early reduction program is being implement-
ed by a rule defining procedures and requirements that must be followed to obtain a
4-2 07/29/91
-------
compliance extension.
Any HAP emission reductions documented under the early reduction program
also can be submitted and credited under the 33/50 Project and vice versa. Reduc-
tion credits are not "used up" when applied to one of these programs. However, it is
not-necessarily the case that HAP reductions achieved under the 33/50 Project will
qualify a source for a compliance extension under the early reduction program. In
general, the early reduction program documentation requirements are more stringent.
Also, sufficient control must be employed to achieve at least 90 (95) percent reduction
in base year HAP emissions from the source.
Although the reduction requirement for the early reduction program, 90 (95)
percent, may seem much higher than the 33/50 Project reduction goals, it is important
to note the differences in the emission source. Under the early reduction program, an
owner or operator may choose to define the source as a subset of the emission points
within the facility; whereas, in the 33/50 Project, the source is always the entire
facility. Therefore, by voluntarily reducing emissions from a single source or group of
sources by 90 (95) percent, a source owner or operator may or may not achieve the
33/50 Project goal. Additionally, it is important to note the differences in base years.
The base year for the early reduction program is generally 1987 or later, whereas the
base year for the 33/50 Project is 1988. It is important to note that properly
documented reductions under the 33/50 Project may qualify for credit under the Early
Reductions Program because of the flexibility afforded an applicant in defining a
source as a subpart of an entire facility.
As with the 33/50 Project, the Agency encourages participation in the early
reduction program through the adoption of pollution prevention measures. The
agency defines pollution prevention as the use of materials, processes, practices, or
products that avoid, reduce or eliminate wastes or toxic releases, through activities
such as toxic use reduction, source reduction and closed-loop recycling.
4-3 07/29/91
-------
APPENDIX A
EXAMPLE ENFORCEABLE COMMITMENT
07/29/91
-------
EXAMPLE ENFORCEABLE COMMITMENT
This appendix presents an example of a complete and well documented
enforceable commitment. It contains all of the requirements of the proposed regulations
gorverning compliance extensions under the early reduction program.
The example documentation of base year emissions includes completed
worksheets .for each emissions point. These worksheets are from a document entitled,
"Procedures for Establishing Emissions for Early Reduction Compliance Extensions - Vol
I" (EPA-450/3-91-Ol2a). This procedures document provides guideance on accepted
techniques for establishing HAP emissions for SOCMI and several other source types.
The worksheets obtained from the procedures document and used to document base
year emissions in the example contain numerous references to tables and figures. The
tables and figures referred to are in the procedures document.
A-1 07/29/91
-------
EXAMPLE ENFORCEABLE COMMITMENT
(Submittal Letter)
August 25, 1991
Director
Air Management Division
EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Enforceable Commitment for the Chloromethanes Process Train
and the South Tank Farm
Dear Sir/Madam:
In accordance with Title 40 Part 63 Subpart D of the Code of
Federal Regulationsf we wish to participate in the early
reduction program for two sources located within our Durham,
North Carolina facility. These are the Chloromethanes process
train and the South Tank Farm. Attached please find a site plan
of the contiguous facility containing these two sources, evidence
that each of these sources conforms to one of the allowable
source definitions under §63.73, our base year emissions along
with the supporting basis, and evidence that our base year
emissions were not unusually high.
As provided in the attached documentation, our total base
year (1987) HAP emissions from these two sources were as follows:
Total Weighted
HAP HAP
Emissions Emissions
Source (Ma/vrl (Ma/vr)
Chloromethanes Process Train 668.5 668 5
South Tank Farm 14.1 19!6
I certify to the best of my knowledge that the base year
emissions given above are accurate and acknowledge that these
emissions data are being submitted in response to an EPA request
under section 114 of the Act. I further certify that the base
year emissions provided for all emission points in the source do
not exceed allowable emission levels specified in any applicable
law, regulation, or permit condition.
A-2 07/29/91
-------
We commit to achieve, before January 1, 1994, the following post-
reduction emission levels:
Total Weighted
HAP HAP
Emissions Emissions
Source (Ma/vr) (Ma/vrl
Chloromethanes Process Train 66.85 66.85
South Tank Farm 1.41 "1.96,
These post-reduction emission levels will provide the
90 percent reduction required to qualify for a compliance
extension. I acknowledge that this commitment is enforceable as
specified in Title 40 Part 63 Subpart D of the Code of Federal
Regulations.
If you have any questions concerning the content of this
submittal, please contact me at (919)555-1000.
Sincerely,
Joe Chemical
President
A-3 07/29/91
-------
- 9°9*[g,uous f?!ant boundary
Tank farm A
«1TO» ) I ,ST09
Process unit
«"«• ) { MTU.
LJ)
Transfer/loading
Wastewater
Treatment
Tank
Wastewater
Treatment
Tank farm C
Tank farm
f XST10 J B
Process unit
OTank
Process unit
ooo
Transfer/loading (^) £) Q D
Figure 1. Site Plan
A-4
07/29/91
-------
SOURCE IDENTIFYING INFORMATION
Company Name:
Address:
City/State/Zip:
Responsible Official:
Telephone Number:
XY2 Company
100 XY2 Street
Joe chemical
(9191555-1000
Source:
General Source
Description:
Activity Which Causes
HAP Emissions:
Chloromethanea Process Train
The source is defined as the set of
emission points that are associated with
the production of Chloromethanes from
methanol. This includes storage of raw
materials and intermediates, process
vents, equipment leaks, product storage
losses, and secondary emissions from
wastewater collection and treatment.
The source, as defined for purposes of
the early reduction program, conforms to
§63.73(a)(3) and §63.73(a)(5). The
process unit is considered a structure
or installation. Additionally, HAP
emissions from the set of emission
points defined as the source total more
than 25 TPY.
HAP are emitted from the source as a
result of raw material and product
losses during the production of
Chloromethanes.
A-5
07/29/91
-------
Source:
Base Year:
Emission Points:
BASE YEAR EMISSIONS
Chloromethanea Process Train
1987
ID
Description
Base Year Emissions (Ma/yrl
Total HAP Weighted HAP
XPV01 Inert-gas purge vent 44.8
XPV02 Methylene chloride
condenser vent 0.059
XPV03 Chloroform condenser
vent 0.024
XST01 Methanol storage tank 18.3
XST02 Crude product storage
tank 14.4
XST03 Crude chloroform storage 11.2
XST04 Methylene chloride day
tank 29.2
XST05 Methylene chloride day
tank 29.2
XST06 Methylene chloride
product storage 160.7
XST07 Chloroform day tank 9.5
XST08 Chloroform day tank 9.5
XST09 Chloroform product 62.72
XST10 Crude carbon tetrachloride 4.81
XEL Equipment leaks 48.2
XL01 Rail Car Loading 50.9
XL02 Tank Truck Loading 46.7
XWW01 Wastewater Collection and
Treatment 128.3
44.8
0.059
0.024
18.3
9.01
6.80
25.3
25.3
140.1
8.1
8.1
54.4
3.7
48.1
47.7
46.7
128.3
TOTAL
668.5
617.5
A-6
07/29/91
-------
GENERAL PLAN FOR ACHIEVING THE REQUIRED REDUCTION
ID
Description
Control
XPV01 Inert-gas purge vent
XPV02 Methylene chloride
condenser vent
XPV03 Chloroform condenser
vent
XST01 Methanol storage tank
XST02 Crude product storage
tank
XST03 Crude chloroform storage
XST04 Methylene chloride day
tank
XST05 Methylene chloride day
tank
XST06 Methylene chloride
product storage
XST07 Chloroform day tank
XST08 Chloroform day tank
XST09 Chloroform product
XST10 Crude carbon tetrachloride
XEL Equipment leaks
XL01 Rail Car Loading
XL02 Tank Truck Loading
XWW01 Wastewater Collection and
Treatment
Incinerator
None
None
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Internal Floating
Roof
Leak Detection and
Repair Program
Refrigerated
Condenser
Refrigerated
Condenser
Steam Stripper
A-7
07/29/91
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS
HAP; Methvl Chloride Date; 08/20/91
Year: 1987 " . Calculator;
Process Vent Identification; XPVOi
Description: Inert Gas Purcre Vent
Process Conditions/Sampling
Date of flow measurement 10/05/87
Method of flow measurement EPA Method 2
Date of concentration measurement 10/05/87
Method of concentration measurement
(if not an EPA Method give a brief
description and attach protocol) EPA Method 18
Describe any problems encountered
during testing none encountered
Production rate during flow determination (Ibs/hr) 47.000
Production rate during sampling (Ibs/hr) 47.000
Average production rate during base year (Ibs/hr) 47.000
Stream Characteristics
Average vent stream flow rate (ft3/min) 6.57 = Q
HAP concentration (ppmv) 230.OOP = c
Annual hours of operation (hrs) 8500 = h
Vent stream discharge temperature (°F) no , T
HAP molecular weight (Ib/lb-mole) 50.5 _ j/^
HAP high-risk weighting factor 3. = F
~~^^~~^~^^^~~ HR
Control
Control device None
HAP control efficiency (%)N/& = eff
Calculations5
Uncontrolled Emissions (Ey) = 3.94E-08 0 c h MW
T + 460
Uncontrolled Emissions (EU) = 3.94E-Q8(6.571^230.0001 fasooi rso.s^
(_110_) + 460
44.8
Mg/yr
HAP Emissions (E^p) = EU (1 - eff/100)
A-8 07/29/91
-------
Source: Chloromethanes Production Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS (CONCLUDED)
HAP Emissions (Ej^p) = 44.8 fl - Q_/100)
Mg/yr
44.8
Weighted HAP Emissions = Ej^p FHR
Weighted HAP Emissions = (44.8) (1)
Mg/yr
If the conditions during testing are not representative of base
year operation, make the appropriate extrapolation below and
explain:
The process was operating at the base year production rate during
testing.
If the flow or concentration were not measured using an EPA
reference method, EPA conditional method or validated using
Method 301, provide justification and supporting calculations:
N/A
Expression provided in "Procedures for Establishing Base Year
and Post-Reduction HAP Emissions" to convert flow and
concentration into an annual mass rate; the 3.94E-08 constant is
based on the ideal gas law.
A-9 07/29/91
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS
HAP; Methvlene chloride
Year: 1987
Date; 08/20/91
Calculator :
RHH
Process Vent Identification; XPV02
Vent ID/Description; Methvlene Chloride Condenser Vent
Process Conditions/Sampling
Date of flow measurement
Method of flow measurement
Date of concentration measurement
Method of concentration measurement
(if not an EPA Method give a brief
description and attach protocol)
Describe any problems encountered
during testing
10/05/87
EPA Method 2
N/A
Production rate during flow determination (Ibs/hr)
Production rate during sampling (Ibs/hr)
Average production rate during base year (Ibs/hr)
Stream Characteristics
Average vent stream flow rate (ft3/min)
HAP concentration (ppmv)
Annual hours of operation (hrs)
Vent stream discharge temperature (°F)
HAP molecular weight (Ib/lb-mole)
HAP high-risk weighting factor
None (see est. below)
N/A
47,000
N/A
47.000
0.042
28.600
8500
120
85
Q
c
h
T
MW
F
Control
Control device
HAP control efficiency (%)
Calculations
None
N/A
HR
= eff
Uncontrolled Emissions
Uncontrolled Emissions
HAP Emissions
3.94E-08 O C h MW
T + 460
= 3.94E-08 (0.042)^28.6001fSSOOl(BS\
(_12£_) + 460
Mg/yr
0.059
(l - eff/100)
A-10
07/29/91
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS (Concluded)
HAP Emissions (EHAp) = 0.059(1 - _0__/100)
0.059
Mg/yr
Weighted HAP Emissions = EHar> FHTj
nntr nx\
Weighted HAP Emissions = (0.059) (1)
Mg/yr
If the conditions during testing are not representative of base
year operation, make the appropriate extrapolation below and
explain:
The process was operating at the average base year rate during
flow measurement.
If the flow or concentration were not measured using an EPA
reference method, EPA conditional method or validated using
Method 301, provide justification and supporting calculations:
HAP concentration was not measured because the HAP emissions from
this emission point are small compared to total source HAP
emissions and errors in calculating emissions from this source do
not significantly affect the accuracy of total estimated HAP
emissions from the source. The HAP concentration is based on
saturation of the HAP at process conditions just prior to
discharge (29.4 psi and 110°F) and a methylene chloride pressure
of 8.4 psia at no°p. ideal gas behavior is assumed.
8.4 psia = 0.286 Ib-mole methvlene chloride
29.4 psia Ib-mole of vent gas
Expression provided in "Procedures for Establishing Emissions"
to convert flow and concentration into an annual mass rate; the
3.94E-08 constant is based on the ideal gas law.
A-11 07/29/91
-------
Source:Chloronethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS
HAP: Chloroform Date; 08/20/91
Year: 1987 Calculator: RHH
Process Vent Identification; XPV03
Vent ID/Description: Chloroform Condenser Vent _
Process Conditions/Sampling
Date of flow measurement 10/05/87
Method of flow measurement EPA Method 2
Date of concentration measurement N/A
Method of concentration measurement
(if not an EPA Method give a brief
description and attach protocol) None (see est. below)
Describe any problems encountered
during testing __ N/A
Production rate during flow determination (Ibs/hr) 47.000
Production rate during sampling (Ibs/hr) N/A
Average production rate during base year (Ibs/hr) 47.000
Stream Characteristics
Average vent stream flow rate (ft3/min) p. 015 = Q
HAP concentration (ppmv) 22.900 = c
Annual hours of operation (hrs) 8500 = h
Vent stream discharge temperature (°F) 120 = T
HAP molecular weight (Ib/lb-mole) 119.4 =
HAP high-risk weighting factor _ i = F
^~~^^^~~^~~^^~ HR
Control
Control device _ None
HAP control efficiency (%) N/A _ eff
Calculations
Uncontrolled Emissions (Ey) = 3.94E-08 0 C h MW
T + 460
Uncontrolled Emissions (Ey) = 3.94E-08ro.oisi (22900} (asoo\ (119.41
( 120 1 + 460
0.024
Mg/yr
HAP Emissions (E^p) = EU (l - eff/100)
A-12 07/29/91
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM PROCESS VENTS (Concluded)
Emissions
= 0.024(1 -
0.024
Weighted HAP Emissions =
Mg/yr
HR
Weighted HAP Emissions = (0.024) (l)
Mg/yr
If the conditions during testing are not representative of base
year operation, make the appropriate extrapolation below and
explain:
The process was operating at the average base year production
rate during flow measurement.
If the flow or concentration were not measured using an EPA
reference method, EPA conditional method or validated using
Method 301, provide justification and supporting calculations:
HAP concentration was not measured because the HAP emissions from
this emission point are small compared to total source HAP
emissions and errors in calculating emissions from this source do
not significantly affect the accuracy of estimated total HAP
emissions from the source. The HAP concentration is based on
saturation of the HAP at process conditions just prior to
discharge (17 psi and lio°P) and a chloroform vapor pressure of
3.9 psia at no°F. Ideal gas behavior is assumed.
3.9 psia
17 psia
= 0.229 Ib-mole chloroform
Ib-mole of vent gas
Expression provided in "Procedures for Establishing Emissions"
to convert flow and concentration into an annual mass rate; the
3.94E-08 constant is based on the ideal gas law.
A-13
07/29/91
-------
Source:Chloromethane Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS
HAP; Methanol Date; 08/20/91
Vear:_i987 Calculator :_Rra_
Tank designation; XST01
Product: Methanol Feed
Tank Characteristics
Inside diameter, (ft) 60 =D
Height, (ft) 48 ~ =HT
Capacity, (gal) = n S £ * 7.48 3*1 1,000.000 =v
4 ft3
if not known
Roof color White
Shell color White
Vapor space height, (ft)a 24 =H
Ambient Conditions
Average atmospheric pressure (psia) 14.7 =pa
(defaults 14.7 psia)
Average ambient diurnal temperature 20 =Am
(0F)-b T
Average annual ambient temperature TO =T*
(°F) A
Bulk Liquid Characteristics
Stored liquid temperature (°F)C 70 =T
Total throughput per year (gal) 24.OOP.OOP =AN
Number of turnovers per yeard 24 . =N
Molecular weight of vapor (Ib/lb mole) 32 =MV
Mole percent of HAP ipp v
Partial pressure of the HAP at liquid 1.9 =p
conditions (psia)
HAP high-risk weighting factor 1 =FUTS
^^~^^—~~~^^^—^^^— HR
Adjustment Factors
Paint factor (see Table 2-3) i.p -p
Small diameter tank factor6 i.p =CP
Turnover factorf It0 _K
Product factor^ ^Q _RN
A-14 07/29/91
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS (continued)
None
Control
Control device
HAP control efficiency (%)
Calculations*1
Breathing Loss (M9/yr) =
LB = 1.02E-05MV °-68
=eff
= 1.02E-05
2.40
Pa-P
Mg/yr
D1.73H0.51AT0.50FpCKc
(1)(l)(l)
Working Loss (Mg/yr) = LW = 1.09E-08 MVPVNKNKC
= 1.09E-08 (32)(1.9)(1,000,000)(24)(1)(1)
Mg/yr
15.90
Total Loss (Mg/yr) =
TL = LB + LW = (2.40) + (15.90) =
18.3
Mg/yr
If a control device is employed,
HAP Emissions (E^p) = Total Loss (l - eff/100)
= 18.3 (l - _0_/100)
Mg/yr
A-15
07/29/91
-------
Source;Chloromethane3 Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS (continued)
Weighted HAP Emissions = EHAP
= '(18.3) (1)
Mg/yr
If vapor space height is unknown or shell, assume H equals one
half tank height. If tank has a cone roof, adjust vapor space
height by adding 1/3 of height of cone.
If average ambient diurnal temperature change is unknown, assume
20°F.
cStored liquid temperature may be approximated from average
annual ambient temperature. See Table 2-2.
dN = AN
where N = number of turnovers per year
AN = total throughput per year (gal)
V = tank capacity (gal)
eFor D > 30ft, C=l; For 6 < D < 30ft, C=0. 0771D-0. 0013D2-0. 1334 .
fFor turnovers > 36, KN = (180 + N)/(6 * N)
where KN = turnover factor (dimensionless)
N = number of turnovers per year
For turnovers < 36, KN = l
= 1.0 for volatile organic liquids
Expression for computing HAP emissions are from "Procedures for
Establishing Emissions." The calculation procedure is
consistent with AP-42.
07/29/91
-------
SUMMARY OF CALCULATION INPUTS FOR ADDITIONAL FIXED-ROOF STORAGE
TANKS ASSOCIATED WITH THE CHLOROMETHANES PROCESS TRAIN
Tank
ID
XST02
XST02
XST02
XST03
XST03
XST04
XSTOS
XST06
XST07
XSTOS
XST09
XST10
Tank
Description
Crude Product
Crude Product
Crude Product
Crude Chloroform
Crude Chloroform
Methylene
Chloride Day Tank
Methylene
Chloride Product
Chloroform
Day Tank
Chloroform
Crude Carbon
Tetrachloride
HAP
MC
C
CT
C
CT
MC
MC
C
C
CT
D
Inside V
Mole Tank Diameter Capacity
Percent Color (ft.) (gal)
55.3 White
40.5 White
4.2 White
90.6 White
9.4 White
White
White
White
White
27
27
27
27
27
30
60
21
47
21
100.000
100,000
100,000
100,000
100,000
40,000
1.000.000
20.000
400,000
20,000
H
Vapor
Space
Height
(ft.)
12
12
12
12
12
4
24
4
16
4
Stored
N
Ljquid Number of
Temperature Turnovers
(°F) per Year
95
95
95
104
104
86
70
104
70
104
6
6
6
6
6
216
17
199
20
32
Mv
Molecular
Weight
(Ib/lbmole)
85
119.4
154
119.4
154
85
85
119.4
119.4
154
P
Partial
Pressure
(psia)
5.4
1-.7
0.11
4.0
0.24
8.8
7.4
4.3
4.3
2.6
Pa?nt
Factor
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
c
Small
Diameter
Factor
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.91
1.0
0.91
KN
Turnover
Factor
1.0
1.0
1.0
1.0
1.0
0.305
1.0
0.317
1.0
1.0
MC = Methylene Chloride; C = Chloroform; CT = Carbon Tetrachloride
CO
^O
-------
SUMMARY OF CALCULATED EMISSIONS FROM FIXED-ROOF STORAGE TANKS
ASSOCIATED WITH THE CHLOROMETHANES PROCESS TRAIN
>
00
o
>J
I
CD
Tank
ID
XST02
XST02
XST02
XST03
XST03
XST04/
XST05
XST06
XST07/
XST08
XST09
XST10
LB LW LT
Breathing Working Total
Tank Loss Loss Loss
Description HAP (Mg/yr) (Mg/yr) Mg/yr
Crude Product MC 6.21 3.00 9.21
Crude Product C 3.16 1.33 4.49
Crude Product CT 0.59 o.li 0.70
Crude Chloroform c 6.76 3.12 9.89
Crude Chloroform CT 1.05 0.24 1.29
Methylene Chloride
Day Tank MC 7.69 21.48 29.17
Methylene Chloride
Product MC 44.13 116.55 160.68
Chloroform Day Tank C 2.44 7.06 9.50
Chloroform Product C 17.95 44.77 62.72
Crude Carbon
Tetrachloride CT 2.01 2.79 4.81
. Control Baseline
Control Efficiency Emissions
Device (%) (Mg/yr)
None o
None o
None o
None 0
None o
None o
None o
None o
None o
None 0
9.21
4.49
0.70
9.89
1.29
29.17
160.68
9.50
62.72
4.81
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS3
HAP; Methvl Chloride
Year; 1987
Process: Chloromethanea Production
Date: 08/20/91
Calculator: RHH
Equipment Counts
Pump Seals (Light Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC
Pump Seals (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Valves (Gas/Vapor)
Average
Total HAP
Number Wt. Fract.
5
10
X
X
X
X
X
0.05
0.175 =
0.50
0.87
1.00
Subtotal
0.25
10
10.25
=PSLL
x
X
X
X
X
0.05
0.175 =
0.50
0.87
1.00
Subtotal
=PSHL
0 -10 Wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Valves (Light Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
4 x 0.05
X 0.175 -
x 0.50
X 0.87
6 x 1.00
Subtotal
10 X 0.05
X 0.175 -
X 0.50
X 0.87
16 X 1.00
Subtotal
0.20
6
6.20
0.50
16
16.50
=VGV
=VLL
A-19
07/29/91
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (cont.fd)
Valves (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC
Pressure Relief Valves (Gas/Vapor)
0 -10 wt% HAP of VOC 2
10-25 Wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC 2
Open-Ended Lines
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC 4
Compressor Seals
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Sampling Connections
0 -10 wt% HAP of VOC 4
10-25 Wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 Wt% HAP Of VOC
100 wt% HAP Of VOC 6
X 0.05
X 0.175 =
X 0.50
x 0.87
X 1.00
Subtotal
_ x 0.05 = 0.10
. X 0.175 •=
. X 0.50
. x 0.87
. X 1.00 = 2.0
Subtotal 2.10
. X 0.05
. X 0.175 =
X 0.50
X 0.87
. X 1.00 = 4.0
Subtotal 4 . 0
X 0.05 =
X 0.175 -
X 0.50
X 0.87
X 1.00
Subtotal
X 0.05 = 0.20
X 0.175 =
X 0.50
X 0.87
X 1.00 = 6.0
Subtotal 6.20
=VHL
=PRV
=OEL
=CS
=SC
A-20
07/29/91
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratifled)(cont.«d)
Flanges
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC
Annual hours process equipment
Screening Calculations
Number
Screened
Pump Seals
Light Liquid 26
Heavy Liquid
Valves
Gas/Vapor 10
Light Liquid 26
Heavy Liquid
Pressure Relief Valves
Gas /Vapor 4
Open-Ended Lines 4
Compressor Seals
Sampling Connections 10
Flanges 70
HAP Emission Calculation
PSLL X EpSTjL x H = 10.25
PSHL X EP]CHL X H =
VGV x EVGV X H = 6.2
VLL X EUTlTj X H = 16.5
VHL X E^/HJ x H -
PRV x Epov x H = 2.1
20 x 0.05 = 1.0
x 0.175 =
x 0.50
x 0.87
50 x 1.00 = 50.0
Subtotal 51.0
contains the HAP 8500
Number of Sources
Screenina fDomvl
0-1000 1000-10000 >10000
14 ~7 ~1
3 1
3 !
4 6
40 20 10
X 0.062 x 8500 = 5.401
X x 8500 =
X 0.0094 X 8500 = 495
X 0.019 x 8500 = 2,665
X X 8500 -
X 0.078 x 8500 - 1.392
=F
=H
Computed
Emissions*5
(per source)
ka/hr/ source
0.062 =ET>^T T
PSHL
0.0094 =ETT/-TT
0.019 =EVTT
"VljLi
^VHL
0 . 078 =EI-IT>TT
— ^PRV
0.0023 =EnFT
^CS
0.0053 =E
sc
0.0079 -E^
A-21
07/29/91
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratified)(cont.'d)
HAP Emission Calculation (continued^
OEL X EOEL X H = 4.0 X 0.0023 X 8500 = 78
CS X ECS X H = x x 8500 = .
SC x Esc X H = 6.2 X 0.0053 x 8500 = 279
F X Ep X H = 51.0 x 0.0079 x 8500
HAP Emissions
HAP high-risk weighting factor
Weighted HAP Emissions = EHao FHD
Hri.tr UK
= (13,700) (1)
Kg/yr
Calculation worksheet and methodology from "Procedures for Establishing
a?I )fvar an? Post-Reduction HAP Emissions." This procedure is consistent
with the methodology presented in "Protocols for Generating Unit-Specific
Emission Estimates for Equipment Leaks of VOC and VHAP" (EPA Publication
No. 450/3-88-010) .
bCompute using the stratified emission factors provided in Table 2-12-
whor.oE ^ C(£L1 *.SEF1> +
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS3
HAP: Methvlene Chloride
Year: 1987
Date: 08/20/91
Calculator: RHI
I
Process: Chloromethanes Production
•
Equipment Counts
Pump Seals (Light Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Pump Seals (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Valves (Gas/Vapor)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC
Valves (Light Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC
Average
Total HAP
Number Wt . Frac .
x 0.05
x 0.175 =
5 x 0.50 = 2.50
x 0.87
6 x 1.00 = 6.0
Subtotal 8.50
x 0.05
x 0-175 =
X 0.50
X 0.87
X 1.00
Subtotal
X 0.05 =
4 x 0.175 = 0.70
x 0.50
x 0.87
2 x 1.00 = 2.0
Subtotal 2.70
x 0.05
4 x 0-175 = 0.70
6 x 0.50 = 3.00
x 0.87
10 x 1.00 - 10.0
Subtotal 13.70
=PSLL
=PSHL
=VGV
=VLL
A-23
07/29/91
-------
Source:Chloromethanea Process Trai
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (cont.'d)
Valves (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Pressure Relief Valves (Gas/Vapor)
0 -10 wt% HAP of VOC 2
10-25 wt% HAP .of VOC
25-75 Wt% HAP Of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC 2
Open-Ended Lines
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 Wt% HAP Of VOC
75-99 wt% HAP Of VOC
100 wt% HAP of VOC 4
Compressor Seals
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC
25-75 Wt% HAP Of VOC
75-99 Wt% HAP of VOC
100 wt% HAP Of VOC
Sampling Connections
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC 4
25-75 Wt% HAP Of VOC
75-99 Wt% HAP Of VOC
100 Wt% HAP of VOC 6
X 0.05
X 0.175 -
X 0.50
X 0.87
X 1.00
Subtotal
X 0.05 = 0.10
_ X 0.175 =
X 0.50
_ X 0.87
_ X 1.00 = 2.0
Subtotal 2.10
. X 0.05
. X 0.175 =
. X 0.50
. X 0.87
. X 1.00 = 4.0
Subtotal 4.0
. x 0.05
X 0.175 -
X 0.50
X 0.87
X 1.00
Subtotal
X 0.05
X 0.175 = 0.70
X 0.50 =
X 0.87
X 1.00 = 6.0
Subtotal 6.70
=VHL
=PRV
=OEL
= CS
=SC
A-24
07/29/91
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratified)(cont.'d)
Flanges
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC-
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Annual hours process equipment
Screening Calculations
Number
Screened
Pump Seals
Light Liquid n
Heavy Liquid
Valves
Gas/Vapor 6
Light Liquid 20
Heavy Liquid
Pressure Relief Valves
Gas/Vapor 4
Open-Ended Lines 4
Compressor Seals
Sampling Connections 10
Flanges 60
Baseline Emission Calculation
PSLL X EPSLL x H = 8.50
PSHL x EpCHL x H =
VGV x EVGY x H = 2.70
VLL X EVTJi x H = 13.70
VHL x EVHT( x H =
PRV x Eppv x H = 2.10
10 X 0.05 = 0.50
10 x 0.175 - 1.75
x 0.50
x 0.87
40 X 1.00 = 40.0
Subtotal 42.25
contains the HAP 8500
Number of Sources
Screenincr foomv)
0-1000 1000-10000 >10000
63 2
5 i
12 6 2
3
12 1
4 6
30 20 10
X' 0.090 x 8500 - 6.502
X x 8500 -
X 0.0076 X 8500 = 174
X 0.012 x 8500 - 1.397
X x 8500 -
X 0.078 x 8500 - 1.392
=F
=H
Computed
Emissions*3
(per source)
kg/hr/ source
0.090 =EpoT T
PSHLi
0.0076 =ErrrTT
0.012 =EVTT
0.078 =EnnrT
fRV
0.0074 -E«T*T
— — OEL
=ECo
0.0053 -E
sc
0.0092 =EF
A-25
07/29/91
-------
Source:Chloromathanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratified)(cont.'d)
Baseline
OEL
CS
SC
F
Emi
X
X
X
X
ssion
EOEL
ECS .
ESC
EF
ca
X
X
X
X
lonl
H =
H =
H =
H =
at i
4
6
42
on (conti
.0 X
X
.70 x
.25 x
HAP
0.
0.
0.
nuedl
0074 X
X
0053 x
0092 X
Emissions
8500 -
8500 -
8500 -
8500 =
(EHAP) -
252
302
3,303
13,300
kg/yr
HAP high-risk weighting factor
Weighted HAP Emissions =
'HR
HR
= (13,300) (1)
kg/yr
Calculation worksheet and methodology from "Procedures for Establishing
Emissions." This procedure is consistent with the Methodology presented
in "Protocols for Generating Unit-Specific Emission Estimates for
Equipment Leaks of VOC and VHAP" (EPA Publication No. 450/3-88-010).
bCompute using the stratified emission factors provided in Table 2-12-
™v,™E * C(£L1 *.SEF1> +
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS3
HAP: Chloroform
Year: 1987
Date: 08/20/91
Calculator: RHH
Process: Chloromethanea Production
Equipment Counts
Pump Seals (Light Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Pump Seals (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Valves (Gas/Vapor)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Valves (Light Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Average
Total HAP
Number Wt . Frac .
x 0.05
X 0.175 =
5 x 0.50 = 2.50
X 0.87 =
6 x 1.00 = 6.0
Subtotal 8.50
x O.Q5
* 0.175 -
x 0.50
x 0.87
x 1.00
Subtotal
X 0.05
4 x 0.175 = 0.70
x 0.50
x 0.87
2 x 1.00 = 2.0
Subtotal 2.70.
x 0.05
4 x 0.175 = 0.70
6 x 0.50 - 3.00
X 0.87
10 X 1-00 = 10.0
Subtotal 13.70
=PSLL
=PSHL
=VGV
=VLL
A-27
07/29/91
-------
Source:Chloromethanes Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (cont.'d)
Valves (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 wt%- HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Pressure Relief Valves (Gas/Vapor)
0 -10 Wt% HAP Of VOC 2
10-25 wt% HAP of VOC
25-75 Wt% HAP Of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC 2
Open-Ended Lines
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC 4
Compressor Seals
0 -10 Wt% HAP of VOC
10-25 Wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC
Sampling Connections
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC 4
25-75 Wt% HAP of VOC
75-99 Wt% HAP of VOC
100 Wt% HAP of VOC 6
X 0.05
X 0.175 =
X 0.50
X 0.87
X 1.00
Subtotal
_ X 0.05 = 0.10
. X 0.175 =
. X 0.50
X 0.87
. X 1.00 = 2.0
Subtotal 2 . 10
. x 0.05
X 0.175 =
x 0.50
X 0.87
. X 1.00 = 4.0
Subtotal 4.0
X 0.05
. X 0.175 =
X 0.50
X 0.87
x 1.00
Subtotal
x 0.05
X 0.175 = 0.70
X 0.50
X 0.87
X 1.00 = 6.0
Subtotal s.70
=VHL
=PRV
=OEL
= CS
=SC
A-28
07/29/91
-------
Source:Chloromethane3 Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratified)(cont.«d)
Flanges
0 -10 wt% HAP of VOC
•10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP Of VOC
Annual hours process equipment
Screening Calculations
Number
Screened
Pump Seals .
Light Liquid n
Heavy Liquid
Valves
Gas/Vapor 6
Light Liquid 20
Heavy Liquid
Pressure Relief Valves
Gas /Vapor 4
Open-Ended Lines 4
Compressor Seals
Sampling Connections 10
Flanges 60
HAP Emission Calculation
PSLL X EPST.T. x H = 8.50
PSHL X Ep«5HTi x H =
VGV x Evnv x H = 2.70
VLL x EVT.T. x H = 13.70
VHL x EVHT x H -
PRV x Eppv x H = 2.10
10 x 0.05 = 0.50
10 . X 0.175 = 1.75
X 0.50
X 0.87
40 x 1.00 = 40.0
Subtotal 42.25
contains the HAP 8500
Number of Sources
Screen ina rppmv)
0-1000 1000-10000 >10000
5 i
12 6 2
3 1
-i- J- -^
4 6 _
30 20 10
X 0.090 x 8500 - 6.502
X x 8500 -
X 0.0076 x 8500 - 174
X 0.012 x 8500 - 1.397
X X 8500 -
X 0.078 X 85OO — 1.7O?
=F
=H
Computed
Emissions*3
(per source)
kg/hr/source
0.090 =Er~LL
EPSHL
0.0076 =ETTS*TT
0.012 — ETTT T
EVHL
0.078 =EpTjTT
0.0074 =EQrT
p
^CS
0.0053 =F
sc
0.0092 =EF
A-29
07/29/91
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratifled)(cont.»d)
HAP Emission Calculation (continued!
OEL X EOEL X H = 4.0 x 0.0074 x 8500 = 252
CS x Ecs X H = x x 8500 =
SC x Esc X H = 6.70 x O.OOS3 x 8500 = 302
F X Ep X H = 42.25 X 0.0092 x 8500 = 3.303
HAP Emissions (Ej^p) = 13,300 kg/yr
HAP high-risk weighting factor i = FUT5
fir\
Weighted HAP Emissions = EHaD FHt>
tine tlK
= (13,300) (1)
kg/yr
Calculation worksheet and methodology from "Procedures for Establishing
Base Year and Post-Reduction HAP Emissions." This procedure is consistent
with the Methodology presented in "Protocols for Generating Unit-Specific
Emission Estimates for Equipment Leaks of VOC and VHAP" (EPA Publication
No. 450/3-88-010).
bCompute using the stratified emission factors provided in Table 2-12-
w*-r. E ^ [(SL1 *.SEF1> +
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKSa
HAP: Carbon Tetrachloride
Year: 1987
Process: Chloromethanes Production
Equipment Counts
Total
Number
Pump Seals (Light Liquid)
0 -10 wt% HAP of VOC 2
10-25 wt% HAP of VOC
25-75 Wt% HAP of VOC 3
75-99 wt% HAP of VOC
100 wt% HAP of VOC 4
Pump Seals (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 Wt% HAP Of VOC
25-75 Wt% HAP of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Valves (Gas /Vapor)
0 -10 wt% HAP of VOC 2
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC 2
75-99 wt% HAP of VOC
100 wt% HAP of VOC 2
Valves (Light Liquid)
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC 2
25-75 Wt% HAP of VOC 2
75-99 wt% HAP of VOC
100 wt% HAP Of VOC 4
Date: 08/20/91
Calculator: RHH
Average
HAP
Wt . Frac .
X 0.05 = 0.10
X 0.175 =
X 0.50 = 1.50
X 0.87
X 1.00 = 4.0
Subtotal 5.60 =PSLL
X 0.05
X 0.175 =
X 0.50
X 0.87
X 1.00
Subtotal =PSHL
X 0.05 = 0.10
X 0.175 =
X 0.50 = 1.00
X 0.87
X 1.00 = 2.00
Subtotal 3.10 =VGV
x 0.05
X 0.175 = 0.35
X 0.50 = 1.00
X 0.87
X 1.00 = 4.00
Subtotal 5.35 =VLL
A-31
07/29/91
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (cont.«d)
Valves (Heavy Liquid)
0 -10 wt% HAP of VOC
10-25 wt% HAP Of VOC
25-75 Wt% HAP Of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC
Pressure Relief Valves (Gas/Vapor)
0 -10 wt% HAP of VOC 2
10-25 wt% HAP of VOC
25-75 wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC 2
Open-Ended Lines
0 -10 wt% HAP of VOC
10-25 Wt% HAP of VOC
25-75 Wt% HAP Of VOC
75-99 wt% HAP of VOC
100 wt% HAP of VOC 2
Compressor Seals
0 -10 wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 Wt% HAP Of VOC
100 Wt% HAP Of VOC
Sampling Connections
0 -10 wt% HAP of VOC 2
10-25 wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 Wt% HAP Of VOC
100 Wt% HAP of VOC
X 0.05
X 0.175 =
X 0.50
X 0.87
X 1.00
Subtotal
x 0.05 = 0.10
_ x 0.175 =
_ X 0.50
. X 0.87
X 1.00 - 2.00
Subtotal 2 . 10
. x 0.05
. X 0.175 -
. X 0.50
X 0.87
. X 1.00 = 2.00
Subtotal 2.00
. x 0.05
x 0.175 -
x 0.50
X 0.87
X 1.00
Subtotal
X 0.05 = 0.10
X 0.175 =
X 0.50
X 0.87
X 1.00
Subtotal 0.10
=VHL
=PRV
=OEL
= CS
=SC
A-32
07/29/91
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratified)(cont.«d)
Flanges
0 -10 Wt% HAP of VOC
10-25 wt% HAP of VOC
25-75 Wt% HAP of VOC
75-99 Wt% HAP of VOC
100 wt% HAP of VOC
Annual hours process equipment
Screening Calculations
Number
Screened i
Pump Seals
Light Liquid 9
Heavy Liquid
Valves
Gas/Vapor 6
Light Liquid 8
Heavy Liquid
Pressure Relief Valves
Gas/Vapor 4
Open-Ended Lines 2
Compressor Seals
Sampling Connections 2
Flanges 26
HAP Emission Calculation
PSLL X EDCT.T. X H = 5.60
PSHL X EDCUT X H -
••" •"• "BVIM^j »»• **
VGV x EVr=v X H = 3.10
VLL x EVT.T. X H = 5.35
VHL X ETTOT X H —
* '"-1 A "VHTj A. n
PRV x EpRV x H = 2.10
20 x 0.05 = l.'OO
X 0.175 =
X 0.50
x 0.87
6 x 1.00 = 6.00
Subtotal 7.00
contains the HAP 8500
Number of Sources
Screening fcomv)
0-1000 1000-10000 >10000
5 2 1
61 i
3 1
2
I i
14 7 5
X 0.106 x 8500 = 5,046
X 8500 —
X 0.0076 X 8500 = 900
X 0.012 X 8500 - *4«
X x 8500 =
X 0.078 x 8500 = 1.392
=F
=H
Computed
Emissions*3
(per source)
kg /hr/ source
0. 106 =Eiic>T T
PSLL
'•'PSHL
0.0076 =ETT/~TT
0.012 -ETTTT
— -f
^VHL
0.078 =EnnTT
PRV
0.00876 ='Em->T
^CS
0.019 =E
sc
0.010 -Ep
A-33
07/29/91
-------
Source:Chloromethanea Process Train
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM EQUIPMENT LEAKS (Stratified)(cont.«d)
HAP Emission Calculation ^continued)
OEL X EOEL X H = 2.00 x 0.00876 x 8500 = 149
CS X Ecs X H = x x 8500 = ^HH
SC X Esc X H = 0.10 X 0.019 x 8500 = 16
F X EF X H = 7.00 x 0.010 x 8500 = 595
HAP Emissions (Ej^p) = 7,944 kg/yr
HAP high-risk weighting factor
Weighted HAP Emissions = E^p FHR
= (7,944) (1)
kg/yr
acalculation worksheet and methodology from "Procedures for Establishing
X"5J2£; i T51S Procedure is consistent with the Methodology presented
in "Protocols for Generating Unit-Specific Emission Estimates for
Equipment Leaks of VOC and VHAP" (EPA Publication No. 450/3-88-010) .
bCompute using the stratified emission factors provided in Table 2-12-
«H™ * [(2L* *.SEF1> +
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS
HAP; Methvlene chloride Date; 08/20/91
Year: 1987 Calculator; RHH
Loading Operation: XLOl/Methylene Chloride/Chloroform Rail Car
Loading
Loading Parameters
Cargo carrier (tank truck, rail car, etc.) rail car
Mode of operation (choose from Table 2-16) submerged loading
Annual volume of liquid loaded (gallons) 6.970.000 = G
Temperature of liquid loaded (°F) 70 = T
Weight percent HAP in the loaded material 100
True vapor pressure of the HAP loaded (psia) 4.3 = P
[Note: For mixtures, use the HAP partial
pressure]
Molecular weight of the HAP (Ib/lb-mole) 119.4 = M
Saturation factor (see Table 2-16) 0.60 = s
HAP high-risk weighting factor i = PUD
~~^^^—^^^^— tlK
Control
Control device none
HAP control efficiency (%) N/A = eff
Calculation3
Uncontrolled Loading Loss Eu = 5.65E-06 s P M G
T + 460
Uncontrolled Loading Loss Eu = 5.65E-06 (0.601(7.4)(BS)(6.970.000^
(70) + 460
Mg/yr
HAP Emissions (E^p) = Eu (l - eff/100)
= 22.9 (1 - 0/100)
Mg/yr
A-35 07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS (CONCLUDED)
Calculation (continued)
Weighted HAP Emissions = Ejj^^p FHP
= (22.9) (l)
Mg/yr
Calculation worksheet and procedure from "Procedures for
Establishing Emissions." This procedure is consistent with AP-42
A-36 07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS
HAP: Chloroform
Year; 1987
Date: 08/20/91
Calculator:
Loading Operation: XLOl/Methylene Chloride/Chloroform Rail Car
Loading
Loading Parameters
Cargo carrier (tank truck, rail car, etc.)
Mode of operation (choose from Table 2-16)
Annual volume of liquid loaded (gallons)
Temperature of liquid loaded (°F)
Weight percent HAP in the loaded material
True vapor pressure of the HAP loaded (psia)
[Note: For mixtures, use the HAP partial
pressure]
Molecular weight of the HAP (Ib/lb-mole)
Saturation factor (see Table 2-13)
HAP high-risk weighting factor
Control
Control device
HAP control efficiency (%)
Calculation5•
tank truck
submerged loading
6,970.000 = G
70 = T
100
7.4
85
0.60
None
N/A
_ = M
_. C
= FHR
= ef f
Uncontrolled Loading Loss Eu =
Uncontrolled Loading Loss Eu =
5.65E-06 S P M G
T + 460
5.65E-06f0.601 (7.4)(BS)(6.970.000)
(70) + 460
Mg/yr
HAP Emissions (EHAP) = Eu (1 - eff/100)
= 28.0 (1 - 0/100)
Mg/yr
A-37
07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS (CONCLUDED)
Calculation (continued)
Weighted HAP Emissions
~ EHAP FHP
= (28.0) (1)
Mg/yr
Calculation worksheet and procedure from "Procedures for
Establishing Emissions." This procedure is consistent with
AP-42.
A-38
07/29/91
-------
CALCULATION WORKSHEET FOR ESTIMATING HAP EMISSIONS
FROM LOADING OPERATIONS
HAP;Methvlene Chloride
Year; 1987 —
Date; 08/20/91
Calculator; RHH
Loading Operation: XL02/Methylene Chloride/ Chloroform Tank Truck
Loading
Loading Parameters
Cargo carrier (tank truck, rail car, etc.)
Mode of operation (choose from Table 2-16)
dedicated normal service.
rail ear
_ _
Annual volume of liquid loaded (gallons)
Temperature of liquid loaded (°F)
Mole percent HAP in the loaded material
True vapor pressure of the HAP loaded (psia)
[Note: For mixtures, use the HAP partial
pressure]
Molecular weight of the HAP (Ib/lb-mole)
Saturation factor (see Table 2-16)
HAP high-risk weighting factor
Control
Control device
HAP control efficiency (%)
Calculation5
10. OOP. OOP
70
7.4
as
0.60
None
N/A
= T
= P
= s
u_
HR
_ eff
Uncontrolled Loading Loss =
Uncontrolled Loading Loss =
5.65E-06 S P M G
T + 460
HAP Emissions
5.65E-06 (0.60) f?.4i (851
(70) + 460
Mg/yr
= Eu (l - eff/ 100)
= 40.2 (1 - 0/100)
Mg/yr
A-39
07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS (CONCLUDED)
Calculation (continued^
Weighted HAP Emissions = E FHP
= (40.2) (1)
Mg/yr
Calculation worksheet and procedure from "Procedures for
Establishing Emissions." This procedure is consistent with
AP-42.
A-40 07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS
HAP ; Chloroform
Year: 1987
Date; 08/20/91
Calculator; RHH
Loading Operating:
XL02/Methylene Chloride/ Chloroform Tank Truck
Loading
Loading Parameters
Cargo carrier (tank truck, rail car, etc.)
Mode of operation (choose from Table 2-16)
dedicated normal service
tank truck
submerged loading;
1.990.000
70
100
4.3
119.4
0.60
None
N/A
G
T
= M
= S
Annual volume of liquid loaded (gallons)
Temperature of liquid loaded (°F)
Weight percent HAP in the loaded material
True vapor pressure of the HAP loaded (psia)
[Note: For mixtures, use the HAP partial
pressure]
Molecular weight of the HAP (Ib/lb-mole)
Saturation factor (see Table 2-16)
HAP high-risk weighting factor
Control
Control device
HAP control efficiency (%) N/A = eff
Calculation3
Uncontrolled Loading Loss = 5.65E-06 S P M G
T + 460
Uncontrolled'Loading Loss = 5.65E-06 fQ.60W4.awii9.4 wi.ago,
(70) + 460
HAP Emissions
Mg/yr
Eu (1 - eff/100)
6.5 (1 - 0/100)
Mg/yr
A-41
07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM LOADING OPERATIONS (CONCLUDED)
Calculation (continued^
Weighted HAP Emissions
Mg/yr
Calculation worksheet and procedure from "Procedures for
Establishing Emissions." This procedure is consistent with
AP-42.
A-42
07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM WASTEWATER SOURCES
HAPrMethanol Date; 05/20/91
Year: 1987 Calculator:
Wastewater Stream Identification; XWWOl
DeSCriPtion: Waate aeid fr°* th« m«thyl chloride
Process Condit ions / Samp T i ng
Date of flow measurement 04/24/91
Method of flow measurement __ __ -
Date of concentration measurement 04/24/91
Method of concentration measurement Method 25D/18 ~ -
Production rate during flow determination (Ibs/hr) 42.000
Production rate during sampling (Ibs/hr) 42 ooo
Average production rate during base year (Ibs/hr) 47.000
Stream Characteristics
Average flow rate during discharge (1pm) 100 = o
HAP concentration (mg/1) 3000 - = £
Annual hours of stream flow (hrs) i~500 - = „
HAP high-risk weighting factor 3. —
Control
~ FHR
Control device None
HAP control efficiency (%) N/A = eff
Calculations3
Wastewater Emissions Potential (WEU) = p.63 O c H
1.67E07.
Wastewater Emissions Potential (WEU) = 0.63 floowaooowasoo)
1.67E07
96.2 Mg/yr
A-43 07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM WASTEWATER SOURCES (CONCLUDED)
Potential HAP Emissions
= WEU (1 - eff/100)
= 96.2 (1 - 0/100)
Mg/yr
Weighted HAP Potential Emissions
HP
= (96.2) (1)
Mg/yr
Calculation worksheet and procedure from "Procedures for
Establishing Emissions".
A-44
07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM WASTEWATER SOURCES
HAP;Methvl Chloride
Year; 1987
Date; 08/20/91
Calculator :_RIffl
Wastewater Stream Identification; XWWOl
Wastewater Stream Description; Waste acid from the methvl chloride
drvina tower _ _
Process Conditions /Sampling
Date of flow measurement
Method of flow measurement
Date of concentration measurement
Method of concentration measurement
Production rate during flow determination (Ibs/hr)
Production rate during sampling (Ibs/hr)
Average production rate during base year (Ibs/hr)
Stream Characteristics
Method 2SD/18
1000
8SOO
Average flow rate during discharge (1pm)
HAP concentration (mg/1)
Annual hours of stream flow (hrs)
HAP high-risk weighting factor
Control
Control device
HAP control efficiency (%)
Calculations3
Wastewater Emissions Potential (WEU) = 0.63 O c H
1.67E07
100
None
N/A
04/24/91
04/24/91
42.000
42.000
47.000
= Q
H
HR
_ eff
Wastewater Emissions Potential (WEU) = 0.63
fioooi
32
.1
1.67E07
Mg/yr
A-45
07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM WASTEWATER SOURCES (CONCLUDED)
Calculations fcontinuedl
Potential HAP Emissions
= .WEU (1 - eff/100)
= 32.1 (1 - 0/100)
Mg/yr
Weighted Potential HAP Emissions
EHAP FHP
(32.1) (1)
Mg/yr
aCalculation worksheet and procedure from "Procedures for
Establishing Emissions."
A-46
07/29/91
-------
EVIDENCE THAT BASE YEAR EMISSIONS WERE
NOT USUALLY HIGH
Emissions are believed to be most directly related to production
rate. Production rate during the base year was 180,000 Mg of
chloromethanes. Production rates in other years are provided
below:
1986 170,000 Mg
1988 185,000 Mg
1989 175,000 Mg
1990 175,000 Mg
A-47 07/29/91
-------
SOURCE IDENTIFYING INFORMATION
Company Name:
Address:
City/State/Zip:
Responsible Official:
Telephone Number:
Source:
General Source Description:
XYZ Company
100 XYZ Street
Activity Which Causes
HAP Emissions:
North Carolina 27704
Joe Chemical _ . _
(919)555-1000 _
South Tank Farm _
The source is defined as the set of
emission points associated with the
South Tank Farm. This includes two
fixed-roof carbon tetrachloride
storage tanks and two floating roof
benzene storage tanks.
The source, as defined for purposes
of the early reduction program,
conforms to §63.73 (a) (3) , The
South Tank Farm is considered an
installation. All emission points
included in the source definition
are similar and are physically
related to one another.
HAP are emitted from the source as
a result of breathing, working, and
seal losses.
A-48
07/29/91
-------
BASE YEAR EMISSIONS
Source: South Tank Farm
Base Year: 1987
Emission. Points:
ID
STF01
STF02
STF03
STF04
Description
Carbon Tetrachloride
Storage Tank
Carbon Tetrachloride
Storage Tank
Benzene Storage Tank
Benzene Storage Tank
TOTAL
Base Year Emission (Mg/yr)
Total HAP Weighted HAP
6.72
6.72
0.31
0.31
14.1
6.72
6.72
3.1
3.1
19.6
A-49
07/29/91
-------
GENERAL PLAN FOR ACHIEVING THE REQUIRED REDUCTION
ID
STF01
STF02
STF03
STF04
Description
Carbon Tetrachloride
Storage Tank
Carbon Tetrachloride
storage Tank
Benzene Storage Tank
Benzene Storage Tank
Control
Internal Floating
Roof
Internal Floating
Roof
Route Vent To
Incinerator
Route Vent To
Incinerator
A-50
07/29/91
-------
Source:South Tank Farm
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS
HAP; Carbon Tetrachloride Date; 08/20/91
Year:_1987 Calculator; RHH
Tank designation; STF01/STF02
Product: Carbon Tetrachloride
Tank Characteristics
Inside diameter, (ft) 27 =D
24
..._ • i 100.oon
4 ft3
•^ • • *~ -^ **• *» «M ^ W»*l»*Mi W ^^ •Mm f \ Am \f I & i
Height, (ft) 24 =HT
Capacity, (gal) = n £ k * 7.48 3*1 / lOO.ooo =v
if not known
Roof color white
Shell color _ white _
Vapor space 'height, (ft)a 12 _ =H
Ambient Conditions
Average atmospheric pressure (psia) 14.7 =p
(defaults 14.7 psia) A
Average ambient diurnal temperature 20 =A™
(OF)TD - «T
Average annual ambient temperature 70 =T,
(°F) - A
Bulk Liquid Characteristics
Stored liquid temperature (°F)C 70 _ =f
Total throughput per year (gal) 1.200.000 =A
.
Number of turnovers per year" _ 12
N
M
_ _
Molecular weight of vapor (Ib/lb mole) 154 T
Mole percent of HAP 100
Partial pressure of the HAP at liquid 2.2 =p
conditions (psia)
Adjustment Factors
Paint factor (see Table 2-3)
Small diameter tank factor6
Turnover factorf
Product factor"?
1.0
1.0
1.0
1.0
=Fr
=C
=KN
=KC
A-51 07/29/91
-------
Source:South Tank Farm
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM FIXED ROOF STORAGE TANKS (continued)
Baseline Control
Control device None
HAP control efficiency (%)
Calculations
Breathing Loss
LB = 1.02E-05MV
N/A
=eff
Mg/yr
Working Loss (Mg/yr) = Ly = 1.09E-08 MVPVNKNKC
= 1.09E-08 (154) (2.2) (100,000) (12) (1) (1)
4.43
Mg/yr
Total Loss (Mg/yr) =
TL = LB + LW = (2.29) + (4.43) =
6.72
Mg/yr
If a control device is employed,
Base year emission (Mg/yr) = Total Loss (l - eff/100)
= 6.72 (1 - 0 7100)
Mg/yr
A-52
07/29/91
-------
Source:South Tank Farm
CALCULATION WORKSHEET FOR BASELINE EMISSIONS
FROM FIXED ROOF STORAGE TANKS (concluded)
Calculation (Continued!
Weighted HAP Emissions = Ej^p FHP
= (6.72) (l)
Mr/yr
If vapor space height is unknown for shell, assume H equals one
half tank height. If tank has a cone roof, adjust vapor space
height by adding 1/3 of height of cone.
If average ambient diurnal temperature change is unknown, assume
20°F.
GStored liquid temperature may be approximated from average
annual ambient temperature. See Table 2-2.
dN = AN
where N = number of turnovers per year
AN = total throughput per year (gal)
V = tank capacity (gal)
eFor D > 30ft, C=l; For 6 < D < 30ft, C=0.0771D-0.0013D2-0.1334.
fFor turnovers > 36, KN = (180 + N)/(6 * N)
where KN = turnover factor (dimensionless)
N = number of turnovers per year
For turnovers < 36, KN = l
=1.0 for volatile organic liquids
A-53 07/29/91
-------
Source:South Tank Farm
CALCULATION WORKSHEET FOR BASELINE EMISSIONS
FROM INTERNAL FLOATING ROOF STORAGE TANKS
HAP:—Benzene Date; 08/20/91
Year; 1987 Calculator; RHH
Tank designation; STF03/STFQ4
Product: Benzene
Tank Characteristics
Inside diameter, (ft) 27 _ = D
Rim Seal type: _
Number of columns3 _ 1 _ = N
Effective column diameter (ft)b _ i.o = FP
Ambient Conditions
Average atmosphe
Average annual ambient temperature
Average atmospheric pressure (psia) 14.7 = p
I *) 70 = T
Bulk Liquid Characteristics
Stored liquid temperature (°F) 70 = T
Total throughput per year (bbl/yr)
[Note: 42 gal/bbl] 28.570 = Q
Molecular weight of HAP (Ib/lb -mole) 78 = MV
True vapor pressure at bulk liquid
conditions (psia) 1.9 _ p
HAP liquid density (Ib/gal) 7.0 = w
Factors
Rim seal loss factor (Ib mole/ft yr) ;
obtain from Table 2-4 2.5 = K
Product factor (dimensionless) i.o = KJ!
Shell clinage factor (bbl/1000 ft2) ;
obtain from Table 2-9 Q.QIS _ c
Deck fitting loss factor 92.4 = F
Deck seam loss factor 034 =K
(Ib-mole/ft yr)d D
Deck seam length factor; 0.20 =p
obtain from Table 2-7 D
A-54 07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM INTERNAL FLOATING ROOF STORAGE TANKS (CONTINUED)
None
Control
Control Device
Control HAP Efficiency (%) _
Calculations6
P* = 0.068 P/C (1 + (1 - 0.068 P)°-5)2)
= 0.068 (1.9)/((1 + (1 - 0.068 (1.9))°-5)2) =
N/A
eff
psia
= f 0.94 3^ OCWL [1 + (MCFC)]/2205
= (0.943) (28.7501 (0.01S) (^^ [^ + (j) m]/22Q5 =
(27)
(27)
LR = KR D P* MVKC/2205 = (2.5)(27)(0.035)(78)(1)/2205 =
LF = FF P* MVKC/2205 = (92.4) (0.035) (78) (1)/2205 =
LD = KDFD°2 p* MVKC/2205 = (0.34) (0.20) (27)2(0.035) (78) (1)/2205
Uncontrolled Emission Eu = LR + Lw + LF + LD
= (0.084)+(0.050)+(0.114) + (0.061)
Mg/yr
HAP Emission (EHAp) = Eu (1 - eff/100)
= 0.31 (1 - 0/100)
Mg/yr
A-55
07/29/91
-------
CALCULATION WORKSHEET FOR ESTABLISHING HAP EMISSIONS
FROM INTERNAL FLOATING ROOF STORAGE TANKS (CONCLUDED)
Weighted HAP Emissions = E^^p FHP
(0.31) (10)
Mg/yr
aFor self -supported fixed roof or external floating roof tank,
Nc = o. If Nc is unavailable, see Table 2-6.
blf Fc is unavailable;
Fc = 1.1 for 9 inch by 7 inch built-up columns;
0.7 for 8 inch diameter pipe column;
1.0 if column construction details are not known
CFF is determined using Table 2-10 and the following calculation
d
KD = 0.0 for welded deck and 0.34 for non-welded deck.
Calculation worksheet and procedures from "Procedures for
Emissions-" These procedures are consistent with
A-56 07/29/91
-------
EVIDENCE THAT BASE YEAR EMISSIONS
WERE NOT UNUSUALLY HIGH
The most significant variable affecting emissions from these
storage tanks is annual throughput. The combined throughputs were
2.4 million gallons for carbon tetrachloride and benzene,
respectively, in the base year. Throughputs in other years were
as follows:
Carbon
Tetrachloride Benzene
(106 gal) (106 gal)
1986 ~3 T~3
1988 2.5 2.4
1989 2.2 2.1
1990 2.4 2.2
A-57 07/29/91
-------
APPENDIX B
REVIEWER CHECKLISTS FOR
ENFORCEABLE COMMITMENTS
07/29/91
-------
ENFORCEABLE COMMITMENT
OVERALL CHECKLIST
Company Name
Source
A. KEY DATES
Date submittal received.
Deadline for completeness review (30 days from receipt of the
enforceable commitment).
Deadline for review of base year emissions (60 days from
completeness determination).
Closing date for the public comment period (30 days from
determination that the base year emission submittal is approvable
or may be extended to 60 days if requested by interested party)
Date of public hearing - if requested.
B. COMPLETENESS REVIEW
Yes No
D D
1. Did both the EPA Region and the State receive a copy of the
enforceable commitment?
n D 2.
D D 3.
D D 4.
Did the OGC and ESD Early Reduction Officers receive a copy of
the enforceable commitment?
Was the "Checklist for Completeness Review" completed and were
all responses "Yes"
Was the applicant notified that the enforceable commitment is
complete/incomplete. If the submittal is incomplete was the
applicant provided a list of deficiencies? [STOP HERE IF THE
SUBMITTAL IS INCOMPLETE]
B-1
07/29/91
-------
Yes No
ENFORCEABLE COMMITMENT
OVERALL CHECKLIST (cont.'d)
das. Was the data for the complete enforceable commitment entered
into the ERPTRAX.
D D 6. Was an announcement made in the Federal Register that- a
complete base year emission submittal was received from the
source? [Place a copy of the notice in the file.]
C. APPROVAL OF BASE YEAR EMISSIONS
1. Was the "Checklist for Baseline Approval of Emissions Data"
completed for each emission point and were all responses to
section B or C (as appropriate) "Yes".
2. Was the applicant notified that the base year emissions are judged
approvable/disapproved. If the submittal was disapproved, was
the applicant provided a list of deficiencies and errors? [STOP
HERE IF THE SUBMITTAL IS DISAPPROVED]
3. Was a public notice published in the local newspaper where.the
source is located, providing the aggregate base year emissions
proposed for approval? [Place a copy of the notice in the file and
record the closing date for the comment period above.]
4. In view of public comments received during the comment period,
was the applicant notified of approval/disapproval? If public
comments warrant revision of the base year emissions, were
errors and deficiencies identified in the notice.
D. ENFORCEABLE COMMITMENT
1. Does the statement of commitment include:
ED a. A Post control emission level for total hazardous air
pollutant emissions that represents a 90 (95) percent
reduction in base year emissions;
B-2 07/29/91
-------
Yes No
ENFORCEABLE COMMITMENT
OVERALL CHECKLIST (cont.'d)
b. A post control emission level for hazardous air pollutants
adjusted for high-risk pollutants that represents a 90 (95)
percent reduction in base year emissions that are also
adjusted for high-risk pollutants;
2. Based on a review of the general plan for achieving required
reductions in hazardous air pollutant emissions, is it conceivable
that the required post-control emission level can be achieved?
3. Was the applicant notified that the enforceable commitment is
accepted?
REVIEWING AGENCY
REVIEWER
DATE
B-3 07/29/91
-------
ENFORCEABLE COMMITMENT
CHECKLIST FOR COMPLETENESS REVIEW
Company Name
Source
A. PLANT IDENTIFYING INFORMATION
Yes NO
OO 1. Is adequate facility identifying information provided?
a. Name and address of the source.
b. Name and telephone number of the source owner or
operator or other responsible official.
n D 2. Is a complete description of the source provided, including:
Od a. A site plan of the contiguous area under common
control which contains the source.
On b. Markings on the site plan locating the building,
structure, facility, or installation that constitutes the
source.
n n c. A description of the activity at the source which
causes hazardous and pollutant emissions.
H d. A list of all emission points of hazardous air
pollutants in the source.
n e. Evidence that the source conforms to one of the
allowable source definitions. (See Source Checklist).
B. BASE YEAR EMISSIONS
n 1. Is the base year indicated? If 1985 or 1986, is evidence
provided that emission data for one of these years provided
to the Administrator before November 15, 1990.
B-4 07/29/91
-------
ENFORCEABLE COMMITMENT
CHECKLIST FOR COMPLETENESS REVIEW (Continued)
Yes No
D 2. Are base year emissions provided for each HAP from each
emission point?
O 3. Is a total base year emissions of hazardous air pollutant
emissions from the source provided?
D 4. Is a total base year emissions adjusted for high-risk
hazardous air pollutant emissions provided?
n 6. Is the supporting basis provided for each emission estimate
(each HAP from each emission point)?
a. For estimates based on test results:
n 1. A description of the test protocol followed and
any problems encountered during testing.
O 2. A discussion of the validity of the method used
for measuring the subject emissions.
n 3. A record of the test results.
b. For estimates based on calculations:
O 1. A rationale for not conducting a source test
and the validity of the calculation.
O 2. A step-by-step description of the calculations
including assumptions.
D 7. Are base year emissions within allowable emission levels
specified in any air pollution control laws or regulations
applicable to the base year?
n 8. Is evidence provided that the base year emissions are not
artificially or substantially greater than emissions in years
prior to the base year?
B-5 07/29/91
-------
Yes
D
D
D
n
ENFORCEABLE COMMITMENT
CHECKLIST FOR COMPLETENESS REVIEW (Continued)
No
D
D
C. ENFORCEABLE COMMITMENT
1. Is a general plan for achieving the required hazardous air
pollutant emission reductions at the source provided?
2. Is a statement of commitment signed by a responsible
official of the source provided, including:
a. The Post control emission level for total hazardous
air pollutant emissions.-
b. The post control emissions adjusted for high-risk
hazardous air pollutant emissions.
c. A statement certifying that the base year emission
- estimates submitted constitute the best available
estimates.
d. A statement of understanding that the base year
emission estimates constitute a response to an EPA
request under the authority of §114.
D
e. A statement committing the source owner or
operator to achieving the required post-control levels
by January 1, 1994.
Reviewing Agency
Reviewer
Date Reviewed
B-6
07/29/91
-------
ENFORCEABLE COMMITMENT
SOURCE DEFINITION CHECKLIST
COMPANY NAME
SOURCE
If the answer to any of the following questions is yes, you may stop filling
out the questionnaire. A yes answer to any of the following questions qualifies
the source as meeting the definition of source.
YES NO
D D
a n
n
1.
2.
3.
REVIEWING AGENCY
REVIEWER
DATE
Does the source emit greater than 10 tons/year of HAP?
Does the source emit greater than 5 tons/year of HAP at a
facility that emits less than 25 tons/year of HAP?
Is the source defined as the entire contiguous facility under
common ownership or control?
4. Is the source a facility, building, structure or installation and
a) Are the emission points functionally related (e.g., are
all emission points from a process unit or do all
emission points have similar purpose)?
b) are all the emission points geographically related?
5. Is the source defined as a source in Appendix B of the
regulation (e.g., equipment leaks from the HON)?
B-7
07/29/91
-------
ENFORCEABLE COMMITMENT
CHECKLIST FOR APPROVAL OF EMISSIONS DATA
THIS CHECKLIST IS TO BE COMPLETED FOR EACH EMISSION
POINT OR GROUP OF EMISSION POINTS FOR WHICH A SINGLE
EMISSION RATE IS REPORTED.
COMPANY NAME
SOURCE
EMISSION POINT
A. SUPPORTING DATA
YES NO
1 • Was a validated test method used to establish base year
emissions? [If "yes", move on to section B.]
2. Was some other method used due to: [If "yes" to any of the
following, skip section B and move to section C]
a) lack of a test method,
b) the economic or technical infeasibility of testing,
c) the demonstration that emission data based on
engineering principles, emission factors, or material
balances are as accurate as results gained through
testing,
d) the emissions from this emission point are
insignificant compared to total emissions from
source, or
e) the base year condition no longer exists?
B-8 07/29/91
-------
ENFORCEABLE COMMITMENT
CHECKLIST FOR APPROVAL OF EMISSIONS DATA (Continued)
B. TEST DATA
YES NO
1. Is a description of the test protocol and any problems
encountered during testing included?
On 2. Was the test method appropriate for the source and
pollutants tested?
OO 3. Are emissions reported as annual emission rates for each
hazardous air pollutant?
OO 4. Is the annual emission rate presented consistent with the
test results?
Od 5. If the test data was collected from a year different from the
base year was the data appropriately scaled to the base
year?
On 6. Are the pollutants emitted consistent with the described
process?
E Q ?• Are the quantities emitted consistent with the quantities
expected based on a rough material balance or comparison
with similar industries?
C. CALCULATION METHODS
OD 1 • Is the rationale for not conducting tests acceptable?
2. Are all calculations described step-by step and are all
assumptions provided?
B-9 07/29/91
-------
ENFORCEABLE COMMITMENT
CHECKLIST FOR APPROVAL OF EMISSIONS DATA (Continued)
YES NO
ED 3. Is the calculation method one of the acceptable methods
for that source category as presented in one of the EPA
documents, or if not, is the method appropriately
documented and acceptable?
^ E 4. Were all the calculations performed correctly?
^ E 5. If the emission source is equipment leaks, was some
method other than EPA average emission factors used?
ED 6. Are the pollutants emitted consistent with the described
process?
ED 7- Are the quantities emitted consistent with the quantities
expected based on a rough material balance or comparison
with similar industries?
REVIEWING AGENCY
REVIEWER
DATE
B-10 07/29/91
-------
APPENDIX C
REVIEWER CHECKLISTS FOR
BASELINE APPROVAL
07/29/91
-------
REQUEST FOR BASELINE REVIEW
OVERALL CHECKLIST
COMPANY
SOURCE
A. KEY DATES
Date base year emissions submitted for review.
Deadline for completeness review (30 days from
receipt of the base year review submittal)
Deadline for review of base year emissions (60 days from
completeness determination)
Closing date for the public comment period (30 days from
determination that the base year emission submittal is
approvable or 60 days if requested by interested party)
Date of Public Hearing - if requested.
B. APPROVAL OF BASE YEAR EMISSIONS
D D
1.
2.
3.
Was the "Checklist for Completeness Review" completed and
were all responses "yes".
Was the "Checklist for Approval of Emissions Data" completed
for each emission point and were all responses for sections
B or C "yes"?
Was the applicant notified that the base year emissions are
judged approvable/disapproved. If the submittal was
disapproved, was the applicant provided a list of deficiencies
and errors? [STOP HERE IF THE SUBMITTAL IS
DISAPPROVED]
C-1
07/29/91
-------
REQUEST FOR BASELINE REVIEW
OVERALL CHECKLIST (Continued)
4. Was a public notice published in the local newspaper where
the source is located, providing the aggregate base year
emissions proposed for approval? [Place a copy of the
notice in the file and record the closing date for the
comment period above.]
5. In view of public comments received during the comment
period, was the applicant notified of approval/disapproval?
If disapproved, were errors and deficiencies identified in the
notice to the applicant?
REVIEWING AGENCY
REVIEWER
DATE COMPLETED
C-2 07/29/91
-------
REQUEST FOR BASELINE REVIEW
CHECKLIST FOR COMPLETENESS REVIEW
COMPANY NAME
SOURCE
A. PLANT IDENTIFYING INFORMATION
YES NO
Od 1 . Is adequate facility identifying information provided?
a. Name and address of the source.
b. Name and telephone number of the source owner or
operator or other responsible official.
^ E 2. Is a complete description of the source provided, including:
a. A site plan of the contiguous area under common
control which contains the source.
b. Markings on the site plan locating the building,
structure, facility, or installation that constitutes the
source.
c. A description of the activity at the source which
causes hazardous and pollutant emissions.
d. A list of all emission points of hazardous air
pollutants in the source.
e. Evidence that the source conforms to one of the
allowable source definitions. (See source checklist).
B. BASE YEAR EMISSIONS [A "NO" RESPONSE TO ANY OF THE QUESTIONS
IN THIS SECTION INDICATES THAT THE BASE YEAR IS NOT COMPLETE AND
DOES NOT MEET THE REQUIREMENTS OF THE REGULATION.]
1- Base year is 1987 or later, OR base year is 1985 or 1986
and data was submitted to the Administrator prior to
November 15, 1990.
C-3 07/29/91
-------
REQUEST FOR BASELINE REVIEW
CHECKLIST FOR COMPLETENESS REVIEW (Continued)
YES NO
2. Is evidence provided that the base year emissions are not
artificially or substantially greater than emissions in years
prior to the base year?
3. Is evidence provided that the emission estimates are within
allowable emission levels specified in any air pollution
control laws or regulations applicable to the base year?
4. is the data presented as an annual emission rate (e.g.,
Mg/year)?
5. Are base year emissions provided for each HAP from each
emission point?
6. Are total emissions of hazardous air pollutants provided?
7- Are total emissions adjusted for high-risk hazardous air
pollutants provided?
8. Is the supporting basis provided for each emission point?
a. For emissions based on test results:
1 . A description of the test protocol followed and
any problems encountered during the test.
2. A discussion of the validity of the method used
for measuring the subject emissions.
3. A record of the test results.
b. For emissions based on calculations:
1 . A rationale for not conducting a source test
and the validity of the calculation.
C-4 07/29/91
-------
REQUEST FOR BASELINE REVIEW
CHECKLIST FOR COMPLETENESS REVIEW (Continued)
YES NO
2. A step-by-step description of the calculations
including assumptions.
REVIEWING AGENCY
REVIEWER
DATE REVIEWED
C-5 07/29/91
-------
REQUEST FOR BASELINE REVIEW
SOURCE DEFINTION CHECKLIST
COMPANY NAME
SOURCE
If the answer to any of the following questions is yes, you may stop filling
out the questionnaire. A yes answer to any of the following questions qualifies
the source as meeting the definition of source under the early reduction
regulation.
YES NO
E E 1. Does the source emit greater than 10 tons/year of HAP?
ED 2. Does the source emit greater than 5 tons/year of HAP at a
facility that emits less than 25 tons/year of HAP?
E n 3. Does the source include the entire contiguous facility under
common ownership or control?
ED 4. Is the source a facility, building, structure or installation and
a) Are the emission points functionally related (e.g., are
all emission points from a process unit or do all
emission points have similar purpose)?
b) are all the emission points geographically related?
n n 5. Is the source defined as a source in Appendix B of the
regulation (e.g., equipment leaks from the HON)?
REVIEWING AGENCY
REVIEWER
DATE
C-6 07/29/91
-------
REQUEST FOR BASELINE REVIEW
CHECKLIST FOR APPROVAL OF EMISSIONS DATA
THIS CHECKLIST IS TO BE COMPLETED FOR EACH EMISSION
POINT OR GROUP OF EMISSION POINTS FOR WHICH A SINGLE
EMISSION RATE IS REPORTED.
COMPANY
SOURCE
EMISSION POINT
A. SUPPORTING DATA
YES NO
1. Was a validated test method used to establish base year
emissions? [If "yes", move on to section B.]
2. Was some other method used due to: [If "yes" to any of the
following, skip section B and move to section C]
a) lack of a test method,
b) the economic or technical infeasibility of testing,
c) the demonstration that emission data based on
engineering principles, emission factors, or material
balances are as accurate as results gained through
testing,
d) the emissions from this emission point are
insignificant compared to total emissions from
source, or
e) the base year condition no longer exists?
C-7 07/29/91
-------
REQUEST FOR BASELINE REVIEW
CHECKLIST FOR APPROVAL OF EMISSIONS DATA (Continued)
B. TEST DATA
YES NO
1. Is a description of the test protocol and any problems
encountered during testing included?
a E 2. Was the test method appropriate for the source and
pollutants tested?
E d 3. Are emissions reported as annual emission rates for each
hazardous air pollutant?
ED 4. Is the annual emission rate presented consistent with the
test results?
n E 5. If the test data was collected from a year different from the
base year was the data appropriately scaled to the base
year?
^ E 6. Are the pollutants emitted consistent with the described
process?
ED 7- Are the quantities emitted consistent with the quantities
expected based on a rough material balance or comparison
with similar industries?
C. CALCULATION METHODS
^ ^ 1 . Is the rationale for not conducting tests acceptable?
2- Are all calculations described step-by step and are all
assumptions provided?
C-8 07/29/91
-------
REQUEST FOR BASELINE REVIEW
CHECKLIST FOR APPROVAL OF EMISSIONS DATA (Continued)
YES NO
3. Is the calculation method one of the acceptable methods
for that source category as presented in one of the EPA
documents, or if not, is the method appropriately
documented and acceptable?
4. Were all the calculations performed correctly?
5. If the emission source is equipment leaks, was some
method other than EPA average emission factors used?
6. Are the pollutants emitted consistent with the described
process?
7. Are the quantities emitted consistent with the quantities
expected based on a rough material balance or comparison
with similar industries?
REVIEWING AGENCY
REVIEWER
DATE
C-9 07/29/91
------- |