Jump to main content.


Project XL Logo

Imation

Pre-Draft Title V Permit - Section II
Table II.C. 1 Applicable Monitoring and Recordkeeping Requirements
Control Device or
Other Monitored
Equipment
Associated
Emission Unit(s)
Parameter(s) Moni-
tored and Monitoring
Device
Monitored Parameter Compliance Indicator(s)
Recordkeeping
Requirements
Operation, Maint.,
and Quality Control
Req'ts for Monitors
(a) Total Enclosure #1 - Coating





---------------------------------
(b) Total Enclosure #2 - Charging Floor and Total Enclosure #3 - Milling Floor









---------------------------------
(c) Total Enclosure #4 - Tunnel
Coating Operations (including associated ovens)
· Coater 41
· Coater 42
· Coater 43
· Coater 44
---------------------------------
Mix preparation equipment
Includes:
· mixing kettles
· resin kettles
· homogenizers
· associated pumps

Other equipment
Includes:
· ball mills
· sand mills
· shaker mills
---------------------------------
Wash Sinks
· Cold solvent wash tank
· Drums
· Associated pumps and piping
Parameter:
· Operational status of automatic closing mechanism and alarm on all access doors in enclosures (alarms on a personnel access door must sound when the door is open more than 30 seconds; for other access doors the alarm must sound when the door is open more than 5 minutes)
· Integrity of enclosure

Device: No device required. Monthly inspection of enclosure integrity, access door closing mechanism, and alarm to confirm proper operation [40 CFR 63.704(b)(1) and (b)(6)]
It is a violation of this monitoring provision when a second consecutive monthly inspection shows that the automatic closing mechanism or alarm failed to work properly on an access door, or a crack or other breach of the enclosure has not been repaired.








From the results of the monthly inspection, record the operational status (working, not working) of the automatic door-closing mechanism and alarm for each access door and the condition of each total enclosure with respect to cracks or other openings. · The automatic door-closing mechanism and door alarm must be in continuous operation except during the following periods: breakdown, repair or maintenance, no VOC or HAP substances being ventilated through the total enclosure [40 CFR 63.8(c)(4) and 63.704(c)(7)]
(d) Baghouses Particulate HAP transfer operations from Milling Floor and Charging Floor Parameter: Pressure drop across baghouse (continuous)
CMS: Differential pressure gauge

CMS Location: Inlet and outlet duct of baghouse

[40 CFR 63.704(b)(7), (e)]
Minimum pressure drop across the baghouse, based on the average over any 3-hour period

Exhaust from the baghouse routed to the SRU accord-ing to Section II.C.2.a

(Note: minimum pressure drop compliance indicator to be established according to Section II.D.1.b)
·3-hour average of the pressure drop across the baghouse See Section II.C.2 for CMS requirements.

The CMS must be in continuous operation except during the following periods:
· CMS breakdown
· CMS repair or maintenance
· Calibration checks
· No particulate HAP ventilation to the baghouse [40 CFR 63.8(c)(4)]

(e) Valves on bypass lines Vents on bypass lines Parameter: Valve position(s)

CMS: Valve position indicator

CMS location: At each bypass valve

The monitoring system must be inspected at least once every month to ensure that it is functioning properly.

[40 CFR 63.704(c)(10)(iii)]
Bypass vent valves in closed position
[40 CFR 63.704(c)(10)(iii)]
For each bypass line:
· times and durations of all periods when the valve position on any bypass line changed to the open position
· results of monthly inspections of valve position monitors
[ 40 CFR 63.706(c)(2)(iii)]
See Section II.C.2 for CMS requirements.

The CMS must be in continuous operation except during the following periods:
· CMS breakdown
· CMS repair or maintenance
· No VOC or HAP substances being ventilated to the SRU [40 CFR 63.8(c)(4)]
(f) Solvent Recovery Unit · Exhausts from Total Enclosures 1,2,3, and 4,
· Solvent storage tank vents
· condenser exhaust of wet scrap dryer
· condenser exhaust of sparge bin
· condenser exhaust from solvent distillation columns
· Exhaust from baghouses
For monitoring control device efficiency

Parameter: total VOC concentration (ppm or equivalent)

CMS:
·Flame ionization detector (FID)

CMS sampling locations:
· Common SRU inlet
· SRU exhaust of Plant A
· SRU exhaust of Plant B

[40 CFR 63.704(b)(1)(ii), (c)(2)(iii), (c)(3), and (c)(3)(i)(A)]



You must meet the following separately for each individual carbon adsorber bed:

During periods of coater operation, the exhaust VOC concentration must be at least 95% less than inlet concentration, based on a rolling 72-hour average of 1-hour averages.
[40 CFR 40 CFR 63.704 (b)(1)(ii), (c)(3)(iii)]





For each FID-CEMS you must record:
· 10-minute averages of VOC concentration
· hourly averages of VOC concentration

For each individual carbon adsorber bed, you must record:
· hourly averages of VOC % reduction
· rolling 72-hour averages of VOC percent reduction (rolling period one hour )


See Section II.C.2 for CMS requirements. CMS must be in continuous operation except for:
CMS breakdown, CMS repair or maintenance, CMS calibration checks, CMS zero (low-level) and high-level calibration drift adjustments, or when no VOC or HAP is ventilated to the SRU [40 CFR 63.8(c)(4), 63.704(c)(7)]
(f) Solvent Recovery Unit
(continued)
· Exhausts from Total Enclosures 1,2,3, and 4,
· Solvent storage tank vents
· condenser exhaust of wet scrap dryer
· condenser exhaust of sparge bin
· condenser exhaust from solvent distillation columns
· Exhaust from baghouses or fabric filters
For monitoring alternate outlet concentrations:

Parameter: total VOC concentration (ppm or
equivalent)

CMS:
· Flame ionization detector (FID-CEMS)

CMS sampling locations:

· SRU exhaust of Plant A
· SRU exhaust of Plant B
You must meet the following separately for each individual carbon adsorber bed:

During periods when no coaters are operating, the VOC concentration must be less than the alternative outlet concentration values established according to Section II.D.1.d, based on a 72-hour average of 1-hour VOC concentration averages
[40 CFR 63.704(c)(3)(iii)]


(Note: alternative outlet concentration values will be established according to Section II.D.1.d)
For each individual carbon adsorber bed, you must record:
· 10-minute averages of VOC outlet concentration
· hourly averages of VOC outlet concentration
· rolling 72-hour averages of VOC outlet concentration (rolling period one hour)

· You must keep a record of all periods when Coaters 41, 42, 43, and 44 are not operating
· You must comply with the requirements in Permit Section II.C.2.e
See Section II.C.2 for CMS requirements.

· CMS must be in contin-uous operation except for:
CMS breakdown, CMS repair or maintenance, CMS calibration checks, CMS zero (low-level) and high-level calibration drift adjustments, or when no VOC or HAP is ventilated to the SRU [40 CFR 63.8(c)(4), 63.704(c)(7)]
(f) Solvent Recovery Unit
(continued)
· Exhausts from Total Enclosures 1,2,3, and 4,
· Solvent storage tank vents
· condenser exhaust of wet scrap dryer
· condenser exhaust of sparge bin
· condenser exhaust from solvent distillation columns
· Exhaust from baghouses or fabric filters
For monitoring site emission caps:

Parameter:
· Concentration: total VOC (ppm or equivalent)
· Concentration: individual HAPs (ppm or equivalent)
· SRU exhaust flow (scfm or equivalent)

CMS:
· Fourier Transform Infra-red Spectrophotometer (FTIR-CEMS)
· Air flow meter

CMS location:
· FTIR-CEMS - common SRU exhaust
· Air flow meter - common SRU exhaust

[FPA - II.A.3.a]
Total VOC emissions must be no greater than 150 tons per rolling 12-month period (rolled monthly and determined according to Section II.C.3.a)

Total HAP emissions must be less than 25 tons per rolling 12-month period and emissions of any one HAP must be less than 10 tons per rolling 12-month period (rolled monthly and determined according to Section II.C.3.b)

[Note: the monitored parameter compliance indicators above for total VOC and HAP emissions must be calculated to include not just the emissions monitored by the FTIR-CEMS, but also the other VOC and HAP emission sources at the plant identified in Sections II.C.3.a and II.C.3.b]
For each substance measured by FTIR, the following must be recorded for each FTIR cycle (approximately every 4.5 minutes):
· air flow on a wet cfm basis (from flow meter)
· concentration on a wet ppm basis
· calculated average lb/hr emission rate
You must also keep a record of:
· calculated pounds emitted for each calendar month for each substance measured by the FTIR
· total pounds VOC emitted per calendar month
· total pounds HAP emitted per calendar month
· total pounds individual HAP emitted per calendar month
· total pounds VOC emitted during the previous 12-month period
· total pounds HAP emitted during the previous 12-month period
· total pounds individual HAP emitted during the previous 12-month period
[FPA Section II.A.3]
See Section II.C.2 for CMS requirements.

· CMS must be in contin-uous operation except for:
CMS breakdown, CMS repair or maintenance, CMS calibration checks, CMS zero (low-level) and high-level calibration drift adjustments, or when no VOC or HAP is ventilated to the SRU [40 CFR 63.8(c)(4), 63.704(c)(7)]
(g) Boiler No. 3 - Nebraska Boiler (Model NS-C-44)

(h) Boiler No. 1 - Murray Boiler (Model N64-C-13)
Boiler No. 3 - Nebraska Boiler (Model NS-C-44)


Boiler No. 1 - Murray Boiler (Model N64-C-13)
For compliance with emission caps:

Parameter: standby No. 2 fuel oil usage
Device: Level sensor
Parameter: natural gas usage
Device: Facility gas meter
Total emissions from the facility must not exceed any of the emission caps in Section II.A. Fuel consumption records must be used to calculate emissions from the boilers in accordance with the procedures in Section II.C. · daily records of the standby fuel oil used
· duration of each occur-rence of standby fuel oil use
· monthly and yearly compilations of the amount of standby fuel and natural gas burned in the boilers
· monthly compilation of the sulfur content of standby fuel oil burned
· test reports for all emission tests performed on the boiler (Ventura County Rule 74.15.D.2)
Ventura County APCD Rule 74.15


Local Navigation


Jump to main content.