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Imation

Pre-Draft Title V Permit - Section IV

VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT
Section IV Alternative Operating Scenarios, Applicable Requirements, and Implementation Procedures

During the term of this permit, Imation anticipates modifying existing coating lines or constructing and operating one or more of the processes described below. This section authorizes Imation to undertake modifications/reconstructions, constructions, or other activities as are specified in Section IV.A and according to procedures in Section IV.F. Imation may operate the modified/reconstructed or constructed processes or the other activities provided they (1) meet the applicable requirements of this Section and Sections II, III, and V of this permit, and (2) follow the procedures for implementing alternative operating scenarios in Section IV.F. Modification of this title V operating permit according to VCAPCD rules is required for any modifications/reconstructions, constructions, and/or other activities not addressed in Section IV.

A. Pre-Approved Alternative Operating Scenarios

The following constructions, modifications/reconstructions, and other specified activities are pre-approved by this permit but must result in installation of no more than a total of six (6) new process lines during the term of this permit. A process line means:


- a single coating line that includes any number or combination of adhesive, release, or precoat coating applicators, flashoff areas, and ovens which coat a continuous web, located between a web unwind station and a web rewind station (for pressure sensitive tape and labels coating scenarios described in IV.A.1(a) below);
- a single prime coat operation, a single finish coat operation, or a single combined prime/finish coat operation, where any such single operation is comprised of coating application station(s), a curing oven, and a quench station used to apply, and dry or cure the coating(s) on the surface of a metal coil (for metal coil surface coating scenarios described in IV.A.1(b) below;
- a single coating operation that includes any coater(s), flashoff area(s), and drying oven(s) located between a base substrate unwind station and a base substrate rewind station that coats a continuous base substrate (for polymeric coating and magnetic tape coating scenarios described in IV.A.1 (c) and (d) below);
- a single paper coating operation, a single fabric coating operation, or a single film coating operation (for paper, fabric, and film coating scenarios described in IV.A.1(e) below.

1. Scenarios Utilizing the Existing Solvent Recovery Unit (SRU): Any of the changes in (a) through (f) below are pre-approved and may be implemented and operated according to Section IV.F. The pre-approved changes specified below consist of modification of existing process equipment, construction of new process equipment, and subsequent modification of such new equipment, wherein all such equipment which emit VOCs and/or HAPs are hard-ducted directly to the existing SRU or are located within any combination of the following total enclosures with all such total enclosures being controlled by the existing SRU:
- one or more existing total enclosures;
- one or more existing total enclosures which have been enlarged or otherwise modified, or
- no more than one new total enclosure.

a) Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR 60 Subpart RR) and Ancillary Process Equipment

Description A pressure sensitive tape and labels coating process operation would consist of continuous web coating accomplished by one or more adhesive, release, or pre-coat coating applicators, combined with one or more ovens and possibly accompanying flash-off areas. Not directly part of the process operation, but included under this pre-approval, would be ancillary equipment which would likely include kettles, pumps, and related equipment for handling, mixing, and otherwise preparing the coating solutions for use from raw materials. The web (or substrate) receiving the coatings would likely be polyethylene or some similar material. Final products of a pressure sensitive tape and labels coating process operation might include pressure sensitive labels to be attached by consumers to data storage tape cartridges.

Process sources and types of regulated air pollutants: Regulated air pollutants would consist only of VOC and HAP substances which are currently used by the plant, or substances which have been subsequently approved for use pursuant to Section IV.F. The VOC and HAP substances are present in the process mainly as solvents which function as the carrier of the coating solids. The type of solvent(s) and solvent content of the coating are determined in part by the physical and chemical properties of the coating solution, especially as this is determined by the eventual properties to be accorded to the final product. Most of the VOC and HAP emissions would occur at the exhausts of the coater oven(s), with fewer emissions occurring at the coating applicator(s), flash-off area(s), and ancillary equipment.

Fuels: This coating operation would involve no sources of combustion and thus there would be no direct usage of fuel. All heat for the ovens would be supplied by electrical heating elements or by steam from the existing boilers.
Control of air pollutants: Under 40 CFR 60 Subpart RR a new, modified, or reconstructed pressure sensitive tape and labels coating process operation would normally require 90% control of VOC emissions, with no control required for VOC emissions from any auxiliary equipment or particulate HAP emissions from particulate HAP transfer operations. Under this permit, however, all emissions of both VOC and HAP substances from any new or subsequently modified or reconstructed pressure sensitive tape and labels coating operation(s) would be controlled according to the most stringent requirements identified under the streamlining analysis described in Section II, which consists effectively of the HAP control requirements under the MACT standard for magnetic tape coating (40 CFR 63 Subpart EE) plus 95% control of VOC emissions. All VOC and volatile organic HAP emissions from operations addressed under this pre-approval, that is, including emissions from any auxiliary equipment, would therefore be captured by a total enclosure and/or by direct ducting and would be routed to a 95% efficient air pollution control device. Particulate HAP from materials transfer operations would be controlled by the baghouse described in Section II, or a baghouse or fabric filter installed pursuant to Section IV.A.2.d.

b) Metal Coil Surface Coating (40 CFR 60 Subpart TT) and Ancillary Process Equipment

Description A metal coil surface coating operation would consist of continuous coating of a metal strip or web having a thickness of at least 0.15 millimeters (mm) (0.006 in.) and which is packaged into a roll or coil. The overall metal coil surface coating operation would consist of a finish coat operation, possibly preceded by one or more prime coat operations. In some cases a prime coat operation and finish coat operation may be accomplished by the same equipment. Each of the prime coat and finish coat operation(s) would include a coating application station(s) where the coating is applied onto the metal web, a curing or drying oven(s), and possibly a flash-off area consisting of any reach of web between the coating application station and its oven. Also part of each prime coat and finish coat operation may be a quench station where the web is cooled after exiting the oven.
Not directly part of the metal coil surface coating operation, but included under this pre-approval, would be ancillary equipment which would likely include kettles, pumps, and related equipment for handling, mixing, and otherwise preparing the coating solutions for use from raw materials.

Final products of a metal coil surface coating operation might include lithographic plates which are used in the printing an publishing industry.
Process sources and types of regulated air pollutants: Regulated air pollutants would consist only of VOC and HAP substances which are currently used by the plant , or substances which have been subsequently approved for use pursuant to Section IV.F. The VOC and HAP substances are present in the process mainly as solvents which function as the carrier of the coating solids. The type of solvent(s) and amount (per unit of coating solids) are determined in part by the physical and chemical properties of the coating solution, especially as this is determined by the eventual properties to be accorded to the final product. Most of the VOC and HAP emissions would occur at the exhausts of the curing or drying ovens of the prime and/or finish coat operations, with fewer emissions occurring at the coating application station(s), any flash-off area(s), and ancillary equipment.
Fuels: Any metal coil surface coating operation constructed or subsequently modified or reconstructed at this facility would involve no sources of combustion and would thus involve no direct usage of fuel. All heat for the curing or drying ovens would be supplied by electrical heating elements or by steam from the existing boilers.
Control of air pollutants: Under 40 CFR 60 Subpart TT a new, modified, or reconstructed metal coil surface coating operation would normally require 90% control of VOC emissions, with no control required for VOC emissions from any auxiliary equipment or for particulate HAP emissions from particulate HAP transfer operations. Under this permit, however, all emissions of both VOC and HAP substances from any new or subsequently modified or reconstructed metal coil surface coating operation(s) would be controlled according to the most stringent requirements identified under the streamlining analysis described in Section II, consisting effectively of the HAP control requirements under the MACT standard for magnetic tape coating (40 CFR 63 Subpart EE) plus 95% control of VOC emissions. All VOC and volatile organic HAP emissions from metal coil surface coating operation(s) addressed under this preapproval, that is, including emissions from auxiliary equipment, would therefore be captured by a total enclosure and/or by direct ducting and would be routed to a 95% efficient air pollution control device. Particulate HAP from materials transfer operations would be controlled by the baghouse described in Section II, or a baghouse or fabric filter installed pursuant to Section IV.A.2.d.

Facilities for Polymeric Coating of Supporting Substrates (40CFR 60 Subpart VVV) and Ancillary Process Equipment
Description A facility for polymeric coating of supporting substrates would consist of a continuous web coating operation that applies elastomers, polymers, or prepolymers to a web other than paper, plastic film, metallic foil, or metal coil, along with any associated coating mix preparation vessels in which solvent and other materials are blended to prepare the polymeric coatings. The coating operation would include any combination of coating applicator(s), flashoff area(s) (which is any reach of the web between the coating applicator and the drying oven where VOC begins to evaporate from the coated substrate) and drying oven(s) which are located between a substrate unwind station and a rewind station. No more than six (6) new coating mix preparation vessels would likely be installed under this preapproval during the term of the permit. This estimate of no more than six newly installed coating mix preparation vessels is not an enforceable permit limit. Rather, six is an upper-bound estimate of the number of vessels that are reasonably anticipated under this scenario. It is also likely that coating solutions for a coating line for polymeric coating of supporting substrates would share at least some of the mixing vessels which are presently at the plant for other purposes.
Ancillary equipment in addition to coating mix preparation vessels are included under this pre-approval, such as mills (except mills that do not emit VOC because they are closed, sealed, and operated under pressure), and equipment for handling raw materials.
Process sources and types of regulated air pollutants: Regulated air pollutants would consist only of VOC and HAP substances which are currently used by the plant , or substances which have been subsequently approved for use pursuant to Section IV.F. The VOC and HAP substances are present in the process mainly as solvents which function as the carrier of the coating solids. The type of solvent(s) and amount (per unit of coating solids) are determined in part by the physical and chemical properties of the coating solution, especially as this is determined by the eventual properties to be accorded to the final product. Most of the VOC and HAP emissions would occur at the exhausts of the drying oven(s) of the continuous web coating operation, with fewer emissions occurring at the coating application station(s), any flash-off area(s), mixing vessels, and other ancillary equipment.
Fuels: Any operation for polymeric coating of supporting substrates constructed or subsequently modified or reconstructed at this facility would involve no sources of combustion and would thus involve no direct usage of fuel. All heat for the curing or drying ovens would be supplied by electrical heating elements or by steam from the existing boilers.
Control of air pollutants: Under 40 CFR 60 Subpart VVV a new, modified, or reconstructed facility for polymeric coating of supporting substrates would normally require 90% overall control of VOC emissions or installation of a total enclosure around the coating operation with all captured VOC emissions vented to a control device that is at least 95% efficient. VOC emissions from mixing vessels would require a cover, or in the event that a new air pollution control device were constructed concurrently with the coating operation, VOC emissions from the mixing vessels would require covers and the venting of VOC emissions from the covered vessels to a 95% efficient control device. No control of VOC emissions from ancillary equipment apart from mixing vessels (such as mills, filters, etc.) would be required under 40 CFR 60 Subpart VVV.
Under this permit all emissions of both VOC and HAP substances from any new or subsequently modified or reconstructed facility for polymeric coating of supporting substrates would be controlled according to the most stringent requirements identified under the streamlining analysis described in Section II, consisting effectively of the HAP control requirements under the MACT standard for magnetic tape coating (40 CFR 63 Subpart EE) plus 95% control of VOC emissions. All VOC and volatile organic HAP emissions from operations addressed under this pre-approval, that is, including emissions from auxiliary equipment, would therefore be captured by a total enclosure and/or by direct ducting and would be routed to a 95% efficient air pollution control device. Particulate HAP from materials transfer operations would be controlled by the baghouse described in Section II, or a baghouse or fabric filter installed pursuant to Section IV.A.2.d.
Facilities for Magnetic Tape Manufacturing Operations (40CFR 60 Subpart SSS and 40CFR 63 Subpart EE) and Ancillary Process Equipment (VCAPCD Rule 74.6.1)
Description A facility for magnetic tape manufacturing already exists at the Imation Camarillo plant. Reconstruction according to 40 CFR 63.5 (that is, reconstruction of a major affected facility as defined at 40 CFR 63.2) is not allowed under this permit. Any modification of the facility (which includes the construction of new equipment), may include any combination of the following: continuous web coating operations (consisting of various combinations of coater(s), flashoff area(s), and drying oven(s) that are located between one or more base substrate unwind and rewind stations), solvent storage tanks, mix preparation equipment, waste handling devices, HAP particulate transfer operations, wash sinks for cleaning removable parts, certain types of wastewater treatment systems, and any condenser vents associated with distillation and stripping columns in the solvent recovery area. All of the vessels used to prepare the coating solutions for use are considered part of the magnetic tape manufacturing facility, including mixers, holding tanks, polishing tanks, and mills (with exception of mills that do not emit VOC or HAP because they are closed, sealed, and operated under pressure). In the course of any modification(s) of this facility, with the exception of the actual coating lines and any required air pollution control devices, no more than the following number of equipment items would likely be installed: fifteen (15) mix vessels, ten (10) solvent storage tanks, six (6) mills, two (2) waste handling devices, two (2) stations for HAP particulate transfer, two (2) wash sinks, one (1) wastewater treatment system, and three (3) condenser vents associated with distillation and stripping columns in the solvent recovery area. These estimates of the number of newly installed equipment items are not enforceable permit limits. Rather, the numbers provided are upper-bound estimates of the number of individual equipment items that are reasonably anticipated under this scenario.
The web substrate used in a facility for magnetic tape manufacturing is typically polyester. Final products might include magnetic tapes that are used for backup and other storage of data from computer systems.
Process sources and types of regulated air pollutants: Regulated air pollutants would consist only of VOC and HAP substances which are currently used by the plant , or substances which have been subsequently approved for use pursuant to Section IV.F. The VOC and HAP substances are present in the process mainly as solvents which function as the carrier of the coating solids. The type of solvent(s) and amount (per unit of coating solids) are determined in part by the physical and chemical properties of the coating solution, especially as this is determined by the eventual properties to be accorded to the final product. Most of the VOC and HAP emissions would occur at the exhausts of the drying ovens, with fewer emissions occurring at the coating application station(s), any flash-off area(s), and ancillary equipment.
Fuels: Any modification of the magnetic tape manufacturing facility at this plant would involve no sources of combustion and thus would involve no direct usage of fuel. All heat for the curing or drying ovens would be supplied by electrical heating elements or by steam from the existing boilers.
Control of air pollutants: Under 40 CFR 63 Subpart EE a modified facility for magnetic tape manufacturing requires 95% overall control of HAP emissions associated with all of the named equipment components. Under 40 CFR 60 Subpart SSS, VOC emissions from the coating lines and mix preparation vessels only would require at most 95% control. VCAPCD Rule 74.6.1 contains various requirements for cold solvent cleaning operations (such as the wash sinks described in this scenario), although there is no control efficiency requirement greater than 85%. Under this permit, however, all emissions of both VOC and HAP substances from any modification of the magnetic tape manufacturing facility would be controlled according to the most stringent requirements identified under the streamlining analysis described in Section II, consisting effectively of the HAP control requirements under the MACT standard for magnetic tape coating (40 CFR 63 Subpart EE) plus 95% control of VOC emissions.
Paper, Fabric and Film Coating Operations (VCAPCD Rule 74.3) and Ancillary Process Equipment
Description A paper, fabric, and film coating operation consists of any portion of a paper, fabric or film coating operation where surface coatings are applied and/or cured, including the coating applicator and heating ovens. The coating lines of each of the operations identified under Section IV.A.1.a through d above would qualify as a paper, fabric, and film coating operation, with the same typically resulting products. Not directly part of the coating operation, but included under this pre-approval, would be ancillary equipment which would likely include kettles, pumps, and related equipment for handling, mixing, and otherwise preparing the coating solutions for use from raw materials.
Process sources and types of regulated air pollutants: Regulated air pollutants would consist only of VOC and HAP substances which are currently used by the plant , or substances which have been subsequently approved for use pursuant to Section IV.F. The VOC and HAP substances are present in the process mainly as solvents which function as the carrier of the coating solids. The type of solvent(s) and amount (per unit of coating solids) are determined in part by the physical and chemical properties of the coating solution, especially as this is determined by the eventual properties to be accorded to the final product. Most of the VOC and HAP emissions would occur at the exhausts of the curing or drying ovens of the prime and/or finish coat operations, with fewer emissions occurring at the coating application station(s), any flash-off area(s), and ancillary equipment.
Fuels: Any paper, fabric, and film coating operation constructed or subsequently modified or reconstructed at this facility would involve no sources of combustion and thus would involve no direct usage of fuel. All heat for the curing or drying ovens would be supplied by electrical heating elements or by steam from the existing boilers.
Control of air pollutants: Under VCAPCD Rule 74 any paper, fabric, and film coating operation would normally require 90% overall control of VOC emissions or coatings having low VOC content, with no control required for VOC emissions from any auxiliary equipment or particulate HAP emissions from particulate HAP transfer operations. Under this permit, however, all emissions of both VOC and HAP substances from any new or subsequently modified or reconstructed paper, fabric, and film coating operation(s) would be controlled according to requirements for sources subject to the MACT standard for magnetic tape coating (40 CFR 63 Subpart EE). All VOC and volatile organic HAP emissions from a paper, fabric, and film coating operation(s), that is, including emissions from auxiliary equipment, would therefore be captured by a total enclosure and/or by direct ducting and routed to a 95% efficient air pollution control device. Particulate HAP from materials transfer operations would be controlled by the baghouse described in Section II, or a baghouse or fabric filter installed pursuant to Section IV.A.2.d.
Volatile Organic Liquid Storage Vessels (40 CFR 60 Subpart Kb and VCAPCD Rule 71.2)
Description This preapproval applies to each storage vessel that has a storage capacity greater than 5,000 gallons (for applicability of District Rule 71.2) and each vessel that is at least 40 cubic meters (10,568 gallons; subject to Subpart Kb) and is used to store organic liquids.
Process sources and types of regulated air pollutants: Regulated air pollutants would consist only of VOC and HAP substances which are currently used by the plant , or substances which have been subsequently approved for use pursuant to Section IV.F. The VOC and HAP substances are present in the vents of the storage vessels as a result of evaporation of the stored liquid into the tank's headspace.
Control of air pollutants: Various requirements exist under District Rule 71.2 and 40 CFR 60 Subpart Kb for control only of VOC emissions from volatile organic liquid storage vessels, ranging from simple documentation to control at 95% efficiency. Under this permit, however, all emissions of both VOC and HAP substances from any new or subsequently modified or reconstructed volatile organic storage vessel which is installed under this pre-approved scenario would be controlled according to requirements for sources subject to the MACT standard for magnetic tape coating (40 CFR 63 Subpart EE). All VOC and volatile organic HAP emissions from volatile organic liquid storage vessels would therefore be directly ducted or captured in a total enclosure and routed to a 95% efficient air pollution control device.

2. Scenarios Utilizing a New Air Pollution Control System: As specified below, you may install and operate one or more new control systems to control HAP/VOC emissions from the existing emissions units subject to Section II of this permit or from new or modified emissions units implemented under Section IV.A.1. The new control system(s) may replace the existing SRU or be used in conjunction with it.

(a) Subject to the conditions in Sections IV.B, C, D, E, and F, you are preapproved to install and operate a new thermal oxidizer.

(b) Subject to the conditions in Sections IV.B, C, D, E, and F, you are preapproved to install and operate a new catalytic oxidizer.

(c) Subject to the conditions in Sections IV.B, C, D, E, and F, you are preapproved to install and operate a new SRU (including restarting the existing stand-by SRU, commonly referred to as the "THF system").

(d) Subject to the conditions in Sections IV.B, C, D, E, and F and in conjunction with installation of a new SRU which utilizes steam desorption, you are preapproved to install and operate a new steam stripper or distillation column for the removal of HAPs from the wastewater generated by steam desorption.

(e) Subject to the conditions in Sections IV.B, C, D, E, and F, you are preapproved to install and operate a new baghouse, fabric filter, or enclosed transfer device for control of HAP particulate emissions.

3. Scenarios Utilizing a Control System Installed Previously under Section IV.A.2: If a new control device has been installed under a previously implemented Section IV.A.2 scenario, then any of the changes in IV.A.1.a through IV.A.1.f may be implemented with VOC and HAP emissions controlled by any such newly installed control system .

4. Other Pre-Approved Changes

Raw Material Changes: You must follow the requirements of Section IV.F.2 to implement a scenario involving a change in the use of raw materials, if such a change will result in the emission of a new HAP substance(s) and/or result in increased emission of an existing HAP substance(s) above the level addressed in the most recently approved health risk assessment .
New Equipment for Handling Dry Raw Materials: New or modified equipment for dispensing, weighing, handling, mixing, or otherwise processing dry raw materials are pre-approved for construction and initial operation. Any such equipment would typically be subject to VCAPCD Rules 52 and 53 for control of particulate matter emissions, however, equipment installed pursuant to this scenario will be subject to the more stringent requirements for HAP-particulate emitting sources as described in Section IV.B.12.
New Distillation Columns: In addition to any distillation columns installed under the scenario in Section IV.A.2.d, you are pre-approved to construct and operate one or more separator distillation columns for the existing or a newly installed solvent recovery unit (SRU) . Such operation must be in accordance with the requirements of Section IV.B.11.


B. Standards and Other Requirements

This section describes the standards and other requirements that apply to the alternative operating scenarios specified in Section IV.A. For scenarios that involve modifications to existing lines, or construction of new lines whose emissions are captured by an existing enclosure and routed to the existing SRU, the standards and requirements that apply are essentially the same as those described in Section II. Where such is the case, this section refers back to those requirements and notes that you must comply with the referenced part of Section II.

This section also contains several alternate compliance options that are available in the EE MACT, and that may be implemented as alternative operating scenarios. As with the alternative operating scenarios specified above, you must document in an on-site log the compliance option being implemented and this documentation must occur contemporaneously with any change in compliance option. [40 CFR 70.6(a)(9)(i)]

The federal new source performance standards and hazardous air pollutant standard and the Ventura County requirements that currently apply to existing operations, or will apply to new or modified coating facilities emitting VOC or HAP at the Camarillo site have been streamlined into a single set of requirements that assures compliance with all. The streamlining exercise showed that current applicable requirements (40 CFR Part 60 Subpart SSS and Ventura County APCD Rules 52, 53, 74.3, and 74.6.1) and future or potential applicable requirements (40 CFR Part 63 Subpart EE, 40 CFR part 60, subparts Kb, RR, TT, and VVV, and District Rule 71.2) can be met by the distilled requirements in Section II with the addition of the requirements in this section for equipment that is not currently part of the Camarillo site. The requirements essentially reduce to the pertinent parts of 40 CFR part 63 subpart EE, with some modification (for example, to account for the fact that subpart EE does not address VOC emissions), and a few selected additions from subsumed standards. Additional specific applicable requirements in this section, not stemming from the streamlining exercise, proceed from the terms of the Project XL Final Project Agreement .

1. For any of the changes identified in Section IV.A you must continue to meet the emission limits of Section II.A.

2. Except as otherwise stated in this section (IV.B), you must meet the requirements of Section II.B.1 (Streamlined Applicable Requirements for Coating Operations) for any of the changes identified in Section IV.A.

3. If the outcome of the BACT/TBACT analysis performed according to Section IV.F.3 is that greater than 95% control of VOCs and/or volatile organic HAPs is required, or that an alternative control device is required, such higher level of control and/or alternative control device must replace the corresponding requirements of Section II.B.1(b)(i).

4. If VOC and/or volatile organic HAP emissions are controlled by a thermal oxidizer implemented under Section IV.A.2.a, the thermal oxidizer must provide a combustion temperature, upon initial use, of 1500 degrees F and a minimum average residence time of 0.5 seconds. Upon completion of the initial performance test required by Section IV.D.3, the operating conditions of the thermal oxidizer may be revised, as necessary, to establish the operating conditions demonstrated by the performance testing to be required to meet the minimum efficiency of 95% (as required under Section II.B(1)(b)(i)). Alternatively, you must establish the operating conditions demonstrated by the performance testing to meet a higher efficiency if such higher efficiency is determined to be required by the results of the BACT/TBACT analysis . If the initial operating conditions contained in this permit for the thermal oxidizer (1500 degrees F and 0.5 seconds residence time) are demonstrated to achieve the required destruction efficiency, then you do not need to revise the operating conditions. If more stringent operating conditions (i.e., higher temperature and/or longer residence time) are required to achieve the necessary destruction efficiency, then you must revise the operating conditions accordingly using minor permit modification procedures. If less stringent operating conditions than those currently in the permit are demonstrated to achieve the necessary destruction efficiency, then you may revise the operating conditions accordingly or maintain the more stringent operating conditions already in the permit.

5. If VOC and volatile organic HAP emissions are controlled by a catalytic oxidizer implemented under Section IV.A.2(b), construction and initial operation of the catalytic oxidizer is subject to review according to Section IV.F.

6. If VOC and volatile organic HAP emissions are controlled by a new SRU implemented under Section IV.A.2(c), construction and initial operation of the SRU is subject to review according to Section IV.F.

7. New or Modified Total Enclosures: Existing total enclosures may be modified or enlarged according to Section IV.A. No more than one (1) new total enclosure is authorized to be created/constructed under Section IV.A during the term of this permit. Subsequent modification(s) or enlargement(s) of a new total enclosure are authorized under Section IV.A. Any enlargement or other modification of an existing total enclosure, or any newly installed total enclosure, must meet the requirements of 40 CFR 63.705(c)(4)(i)(A) through (c)(4)(i)(D) which are described in Section II.B.1(d).

8. HAP Particulate Transfer: As an alternative to directing HAP particulate emissions through a baghouse as described in Section II.B.1.b.ii, HAP emissions from particulate transfer operations may be controlled by using an enclosed transfer method [40 CFR 63.703(d)(1)]

9. Flushing Fixed Lines: As an alternative to meeting the emission limitation requirements in Section II.B.1.b.i for VOC and volatile organic HAP emissions from flushing fixed lines, such emissions may be controlled by using a closed system for flushing the fixed lines. [40 CFR §63.703(f)(1)(ii)].

10. Wastewater Treatment Systems: For any HAP- and/or VOC-containing wastewater generated when the carbon bed in the carbon adsorber is desorbed by steam, you must

a) treat the wastewater discharge to remove each HAP and/or VOC by at least the fraction removed specified in Table 9 of 40 CFR Part 63, Subpart G, [40 CFR 63.703(g)(1)(i)].

b) As an alternative to the requirement of IV.B.10.a, you must treat (other than by dilution) the HAP and/or VOC that are present in the wastewater discharge such that the exit concentration is less than 50 parts per million by weight of total volatile organic HAP and VOC. [40 CFR 63.703(g)(1)(ii)].
The treatment method employed must not transfer emissions from the water to the atmosphere in an uncontrolled manner. [40 CFR 63.703(g)(2)]

11. Separator Distillation Columns: For any separator distillation columns for the existing SRU or a newly installed SRU that are implemented pursuant to Section IV.A.2.d or IV.A.4.c, you must ensure that emissions from the condenser vents on the columns are controlled at a 95 percent efficiency, and that during non-coating periods they are vented to a control device as described in Section II.B.1.b. All other requirements specified in Section II for existing condenser vents in solvent recovery must also be met.

12. Equipment for Handling Dry Raw Materials: The requirements that apply to installation or modification of equipment for handling of dry raw materials, according to Section IV.A.4.b, are subsumed under the streamlined requirements of this permit. You must apply a baghouse or fabric filter to any equipment implemented under a scenario in Section IV.A.4.b. in accordance with 40 CFR 63.703(d)(2). Alternatively, you must utilize an enclosed transfer method in accordance with 40 CFR 63.703(d)(1).

13. During the term of this permit, no more than six (6) new process lines are authorized under Section IV.A.1 or A.2.

C. Emissions Monitoring and Recordkeeping

You must comply with all monitoring and recordkeeping provisions as identified in the streamlining analysis described in Section II.B of this permit . Table IV.C.1 below describes specific, federally enforceable monitoring and recordkeeping requirements for the pre-approved alternative operating scenarios listed in Section IV.A Specific additional monitoring and recordkeeping requirements are contained below in Sections IV.C.2 through IV.C.8 .

VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT

Table IV.C.1 Applicable Monitoring and Recordkeeping Requirements
Control Device or Other Monitored Equipment	Associated Emission Unit(s)	Parameter(s) Monitored and Monitoring Device	Monitored Parameter Compliance Indicator(s)	Recordkeeping Requirements	Installation, O&M, and Quality Control Requirements for Monitors
(a) Thermal Oxidizer (future control device)	Exhausts from Total Enclosures 1, 2, 3, and/or 4 and/or a new total enclosure and/or direct ducting of equipment installed under a preapproval under Section IV.A	For monitoring control device efficiency Parameter: Combustion temperature (continuous) CMS: Thermocouple Parameter: residence time of gases in combustion chamber CMS: flow meter (or system designed to provide 0.5 second residence time at maximum flow to incinerator) [40 CFR 63.704(b)(3)]	For thermocouple: Minimum combustion temperature of 1500 F, based on a 3-hour rolling average of combustion temperatures [40 CFR 63.704(c)(3)(iv)] For flow meter: you must not exceed the flow rate maximum that ensures a minimum of 0.5 second residence time of gases in the combustion chamber	You must keep records of: · hourly averages of combustion temperature · three hour rolling averages of combustion temperature (rolling period 1 hour) [40 CFR 63.704(b)(3), 40 CFR 63.704(b)(8), 40 CFR 63.704(c)(3)(iv)] · hourly averages of flow rate to the incinerator (unless maximum design flow to the incinerator guarantees adequate residence time) · You must comply with the recordkeeping requirements of Section II.C.2.e for the CMS	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 thermal oxidizer [40 CFR 63.8(c)(4)] · See additional CMS requirements at Sections IV.C.3 and IV.C.6.

Table IV.C.1 Applicable Monitoring and Recordkeeping Requirements
Control Device or Other Monitored Equipment	Associated Emission Unit(s)	Parameter(s) Monitored and Monitoring Device	Monitored Parameter Compliance Indicator(s)	Recordkeeping Requirements	Installation, O&M, and Quality Control Requirements for Monitors
(a) Thermal Oxidizer (future control device)	Exhausts from Total Enclosures 1, 2, 3, and/or 4 and/or a new total enclosure and/or direct ducting of equipment installed under a preapproval under Section IV.A	For monitoring site emission caps: Parameters: · Concentration: total VOC (ppm or equivalent) · Concentration: individual HAPs (ppm or equivalent) CMS: · Fourier Transform Infra-red Spectrophotometer (FTIR-CEMS) CMS location: · Thermal oxidizer exhaust Parameter: · thermal oxidizer exhaust flow (scfm or equivalent) CMS: · air flow meter CMS Location: · thermal oxidizer 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 12-month period and emissions of any one HAP must be less than 10 tons per 12-month period (rolled monthly and determined according to Section 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 of each individual HAP emitted during the previous 12-month period	· 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 thermal oxidizer [40 CFR 63.8(c)(4), 63.704(c)(7)] The FTIR and air flow meter must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period. [40 CFR 63.8(c)(4)(ii)] · See additional CMS requirements at Section IV.C.6 and IV.D.4.

Table IV.C.1 Applicable Monitoring and Recordkeeping Requirements
Control Device or Other Monitored Equipment	Associated Emission Unit(s)	Parameter(s) Monitored and Monitoring Device	Monitored Parameter Compliance Indicator(s)	Recordkeeping Requirements	Installation, O&M, and Quality Control Requirements for Monitors
(b) Catalytic Oxidizer (future control device)	Exhausts from Total Enclosures 1, 2, 3, and/or 4 and/or a new total enclosure and/or direct ducting of equipment installed under a preapproval under Section IV.A	For monitoring control device efficiency Parameters: continuously monitor temperature at inlet and outlet of the catalyst bed CMS: Thermocouple [40 CFR §63.704(b)(4) and (c)(6)] CMS Locations: inlet and outlet of the catalyst bed	Minimum gas stream temperature at inlet to catalyst bed (for any rolling three hour period) Minimum temperature rise across catalyst bed (for any rolling three hour period) [40 CFR §63.704(c)(6)] [Note: compliance indicators to be established during performance test of new catalytic oxidizer ]	Rolling three hour averages of: · gas stream temperature at the inlet to catalyst bed and · temperature rise across the catalyst bed (outlet temp minus inlet temp)	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 catalytic oxidizer [40 CFR 63.8(c)(4)] · See additional CMS requirements at Sections IV.C.3 and IV.C.6.

Table IV.C.1 Applicable Monitoring and Recordkeeping Requirements
Control Device or Other Monitored Equipment	Associated Emission Unit(s)	Parameter(s) Monitored and Monitoring Device	Monitored Parameter Compliance Indicator(s)	Recordkeeping Requirements	Installation, O&M, and Quality Control Requirements for Monitors
(b) Catalytic Oxidizer (future control device)	Exhausts from Total Enclosures 1, 2, 3, and/or 4 and/or a new total enclosure and/or direct ducting of equipment installed under a preapproval under Section IV.A	For monitoring site emission caps: Parameters: · Concentration: total VOC (ppm or equivalent) · Concentration: individual HAPs (ppm or equivalent) CMS: · Fourier Transform Infra-red Spectrophotometer (FTIR-CEMS) CMS location: · catalytic oxidizer exhaust Parameter: · Catalytic oxidizer exhaust flow (scfm or equivalent) CMS: ·Air flow meter CMS Location: · catalytic oxidizer 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 12-month period and emissions of any one HAP must be less than 10 tons per 12-month period (rolled monthly and determined according to Section 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 of each individual HAP emitted during the previous 12-month period	· 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 catalytic oxidizer [40 CFR 63.8(c)(4), 63.704(c)(7)] The FTIR and air flow meter must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period. [40 CFR 63.8(c)(4)(ii)] · See additional CMS requirements at Section IV.C.6 and IV.D.4.

Table IV.C.1 Applicable Monitoring and Recordkeeping Requirements
Control Device or Other Monitored Equipment	Associated Emission Unit(s)	Parameter(s) Monitored and Monitoring Device	Monitored Parameter Compliance Indicator(s)	Recordkeeping Requirements	Installation, O&M, and Quality Control Requirements for Monitors
(c) Steam Stripper (air emissions from future wastewater control device)	Wastewater from the steam desorption section of a new solvent recovery unit	Parameter: Steam-to-feed ratio established according to 40 CFR 63.704(b)(10)(i) (continuous) Alternate Parameter: outlet total VOHAP concentration of the wastewater discharge established according to 40 CFR 63.704(b)(10)(ii) (once per month)	During periods when HAP-containing wastewater is being fed to the steam stripper, the continuously measured steam-to-feed ratio must be no less than the ratio established in accordance with 704(b)(10)(i) for any 3-hour period. [40 CFR 63.704(d)(1)] If the outlet total VOHAP concentration of the wastewater discharge is established (according to 40 CFR 63.704(b)(10)(ii)) as the site-specific operating parameter, then you must not operate the steam stripper at an outlet VOHAP concentration greater than the established value for any month.	· steam-to-feed ratio for all rolling 3-hour periods when HAP-containing wastewater is being fed to the steam stripper · record once per month the outlet total VOHAP concentration of the wastewater discharge	The CMS must be in continuous operation except during the following periods: · CMS breakdown · CMS repair or maintenance · No VOC or HAP-containing wastewater is being sent to the steam stripper [40 CFR 63.8(c)(4)] · See additional CMS requirements at Section IV.C.6.

VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT

2. Scenarios utilizing the existing VOC and HAP control system: For Section IV.A scenarios that are located within one or more of the existing total enclosures and controlled by the existing SRU, you must meet the compliance monitoring and recordkeeping requirements specified in Table II.C.1 for total enclosures and the solvent recovery unit.


3. Scenarios utilizing a new VOC and/or HAP control system: Compliance monitoring and recordkeeping for pre-approved scenarios specified in Section IV.A.2, must be performed according to Table IV.C.1 as applicable plus Condition 3(a) or 3(b), as applicable.

a) VOC/HAP control by thermal oxidizer:

i) A CMS consisting of a thermocouple must be installed in the combustion chamber of the thermal oxidizer to measure and record the combustion temperature whenever HAP or VOC from manufacturing operations are vented to the control device. All temperature measurements must be made within an accuracy of ±2.5 degrees C. [40 CFR 63.704(b)(3), (b)(8), (c)(3)(iv), and (c)(5), 40 CFR 60.445(e)]

ii) The CMS thermocouple must be installed, calibrated, maintained, and operated according to the manufacturer's specifications. The thermocouple calibration must be verified or replaced every 3 months, as specified by the manufacturer of the thermocouple, or as recommended by the National Institute of Standards and Technology (NIST, formerly National Bureau of Standards), NBS Monograph 125, National Bureau of Standards, Washington, D.C. 1979. [40 CFR 63.704(c)(2)(ii), 40 CFR 63.8(c)(1)(iii), 40 CFR 63.705(j)]

b) VOC/HAP control by catalytic oxidizer:

i) A CMS consisting of a thermocouple must be installed to measure and record the gas temperatures both upstream and downstream of the catalyst bed and the temperature difference measured across the catalyst bed to within an accuracy of ±2.5 degrees C. [40 CFR 60.584(c), 63.704(b)(4), and 40 CFR 60.445(e)]

ii) The CMS thermocouple must be installed, calibrated, maintained, and operated according to the manufacturer's specifications. The thermocouple calibration must be verified or replaced every 3 months, as specified by the manufacturer of the thermocouple, or as recommended by the National Institute of Standards and Technology (NIST, formerly National Bureau of Standards), NBS Monograph 125, National Bureau of Standards, Washington, D.C. 1979. [40 CFR 63.704(c)(2)(ii), 704(c)(6), 705(j) and 63.8(c)(1)(iii)]

VOC/HAP control by a new SRU: For a new SRU installed according to Section IV.A.2, you must meet the monitoring and recordkeeping requirements for the control device efficiency, the alternate outlet concentration limit(s), and the site emission caps in Table II.C.1.f

4. Particulate HAP control by fabric filter or baghouse:

For a baghouse or fabric filter installed under Section IV.A.2.e which is exhausted to any of the following:

i) the existing SRU;
ii) a new SRU;
iii) a thermal oxidizer, or
iv) a catalytic oxidizer

provided for the purpose of controlling volatile organic HAP or VOC emissions, the requirements under Sections II.C.1.d and II.C.2.a (Monitoring of Particulate HAP transfer) must be met. The requirements of Section IV.C.4.b must otherwise be met.

Except as required under Section IV.C.4.a, visible emission testing of the exhaust of each baghouse or fabric filter installed under Section IV.A.2.e must be performed according to 40 CFR 63.704(e) each day that particulate HAP transfer occurs. Compliance with opacity emission limits will be determined according to 40 CFR 63.6(h) (as modified by Table 1 of 40 CFR 63 Subpart EE). [40 CFR 63.704(e), 40 CFR 63.6(h)]

In addition, for a baghouse or fabric filter installed under Section IV.A.2.e which is not exhausted to one of the devices in IV.C.4.a, you must meet the requirements of 40 CFR 63.704(b)(7). Alternatively, you must meet the requirements of Section II.C.1.d of this permit.

5. New or modified total enclosures:

The requirements of Table II.C.1.a and Section II.C.2.b must be met for any total enclosure which has been installed or modified under Section IV.A and which has no natural draft openings (NDO).

Within 180 days of startup of any total enclosure which has been installed or modified under Section IV.A and which has natural draft openings (NDO), you must comply with the requirements of 40 CFR 63.704(b)(6) for establishing the operating parameter value, monitoring the parameter, and submitting information to the District.

In addition, for new or modified total enclosures which have NDOs, you must install, calibrate, operate, and maintain the instrumentation necessary to continuously measure the operating parameter established whenever VOC and/or HAP are vented through the enclosure. Operation of the enclosure at an average value greater than or less than (as appropriate) the operating parameter value established for any 3-hour period constitutes a violation. [40 CFR 63.704(c)(7)]

6. Additional CMS Operation, Maintenance, and Other Requirements: All CMS must be installed, operational, and the data verified as specified in the relevant standard either prior to or in conjunction with conducting performance tests under 40 CFR 63.7. Verification of operational status must, at a minimum, include completion of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system. [40 CFR 63.8(c)(3)]

(a) CMS for any new total enclosure, baghouse, fabric filter, or by-pass valve, installed pursuant to a pre-approved scenario under Section IV of this permit, must comply with the CMS requirements in Section II.C.2.c (i) and (ii).

(b) CMS for any new steam stripper, installed pursuant to a pre-approved scenario under Section IV of this permit, and the FTIR, thermocouples, and air flow meter contained in Table IV.C.1 all must comply with the CMS requirements in Section II.C.2.c (i), (ii), (iii), and (iv).

(c) Out-of-Control CMS. The thermocouples and air flow meter contained in Table IV.C.1 must comply with the requirements of Section II.C.2.d for out-of-control CMS.

(d) Record of CMS Operation. The thermocouples and air flow meter contained in Table IV.C.1 must comply with the requirements of Section II.C.2.e for recording operation of the CMS.

(e) Reduction of CMS data. CMS for any new total enclosure, baghouse, fabric filter, or steam stripper, and the FTIR, thermocouples, and air flow meter contained in Table IV.C.1 must comply with the requirements of Section II.C.2.f for reduction of CMS data.

(f) Additional requirements for the FTIR-CEMS. The following additional requirements apply to the FTIR-CEMS contained in Table IV.C.1.

(i) Zero (low-level) and high level calibration drifts for the FTIR-CEMS must be checked at least daily and adjusted according to 40 CFR 63.8(c)(6).

(ii) The FTIR-CEMS must be operated according to the U.S. EPA Draft FTIR Protocol of 1995, U.S. EPA Draft Method 320, and U.S. EPA Draft Performance Specification 15, according to the Certification Testing performed by Rho Squared on the FTIR at the Camarillo plant on January 19 through 22, 1998.

7. Determination of Compliance with Facility-Wide Emissions Caps: Subsequent to implementing any of the pre-approved scenarios under Section IV.A, you must continue to determine facility-wide emissions of VOC and HAP using the procedures of Section II.C.3. These calculations must include emissions from all sources at the facility (existing and new sources implemented under a pre-approved scenario), as well as the fugitive and other sources specified in Section II.C.3.

8. Log of changes made: You must maintain on-site a log contemporaneously identifying under which operating scenario(s) the plant is operating. [40 CFR 70.6(a)(9)(i)]

For the multiple compliance options described in this permit as alternative operating scenarios, the log must identify the compliance option being met.


D. Compliance and Source Testing Procedures

1. Scenarios utilizing the existing Solvent Recovery Unit

For any pre-approved scenarios which include newly constructed, modified, reconstructed or otherwise changed equipment implemented under Section IV.A.1(a), (b), (c), or (d), and for which there is an emission of a new VOC or volatile organic HAP substance, a performance test must be conducted within 180 days of startup according to Section II.D, as applicable. For any change implemented under Section IV.A.4(a) (change in the usage of raw materials) which occurs subsequent to implementation of a scenario under Section IV.A.1(a), (b), (c), or (d), a performance test must likewise be conducted within 180 days of startup. Testing performed under this Section must consist of measuring the efficiency of the solvent recovery unit (SRU) while it is connected only to the newly constructed, modified, reconstructed or otherwise changed equipment of Section IV.A.1(a), (b), (c), or (d) and while it is utilizing coatings that are representative of the operation. Test results must be submitted within 60 days of test completion according to 40 CFR 63.9(h). [40 CFR 63.7(2)]

b) For any pre-approved scenarios which include newly constructed, modified, reconstructed or otherwise changed equipment implemented under Section IV.A.1(a), (b), (c), or (d), and for which there is not emission of a new VOC or volatile organic HAP substance, a performance test is not required.

2. New or modified total enclosure:

Except as noted in (b), a compliance demonstration against the criteria of 63.705(c)(4)(i) must be performed within 180 days of startup of any total enclosure which has been modified or newly installed according to Section IV.A.1 [40 CFR 63.7(a)(2)]

For any total enclosure which has been modified or newly installed according to Section IV.A.1 and which contains no natural draft openings (NDOs), the initial compliance test must be performed according to Section II.D.1.a.iii. [40 CFR 63.7(a)(2)]

3. Scenarios utilizing a new VOC and/or HAP control system: Compliance and performance testing procedures for any pre-approved scenario which includes new construction, reconstruction, or modification or other changes specified in Section IV.A.2 must be performed according to the following, as applicable:

For the initial implementation of a scenario in Section IV.A.2(a), (b), or (c) (i.e. a project which includes the actual construction of a new VOC and HAP control system)

i) For control of VOC and HAP emissions by a newly installed thermal oxidizer: A performance test must be conducted, according to 40 CFR 63.704(c)(4), to demonstrate initial compliance with the 95% destruction of VOCs, or higher efficiency if such is indicated by the BACT/TBACT analysis, and to determine the minimum combustion temperature required to meet the required efficiency. [40 CFR 63.704(b)(3), 63.703(c)(2), and FPA]

ii) For control of VOC and HAP emissions by a newly installed catalytic oxidizer: A performance test must be conducted, according to 40 CFR 63.704(c)(4), to demonstrate initial compliance with a VOC destruction efficiency of at least 95%, or higher efficiency if such is indicated by the BACT/TBACT analysis, and to determine the minimum gas temperature at the inlet to the catalytic oxidizer and temperature differential across the catalyst bed required to meet the required efficiency . [40 CFR 63.704(b)(4), 63.703(c)(2), and FPA]

iii) For control of VOC and HAP emissions by a newly installed solvent recovery unit: A performance test must be conducted according to 40 CFR 63.704(c)(4) to demonstrate a VOC recovery efficiency of 95%, or higher level of control if such is required by the BACT/TBACT analysis . [40 CFR 63.704(b)(1) and FPA]

To implement a scenario under Section IV.A.3 (i.e., changes for which emissions are controlled by a VOC and/or HAP control system which was constructed under a previously implemented scenario at Section IV.A.2(a), (b), or (c)), you must conduct a performance test only when the newly installed equipment is of the type specified in IV.A.1 (a), (b), (c), or (d), and there is emission of a new VOC or volatile organic HAP substance. Such performance test must be conducted according to Section IV.D.1.a.

Compliance testing required by this Section must be performed within 180 days of startup of the activity that triggered the performance testing requirement. Compliance tests must be performed according to Section II.D.2 (Compliance and Performance Testing Procedures). [40 CFR 63.7(a)(2)]

4. The following requirements relate to the operation of the FTIR-CEMS used for monitoring VOC and HAP emissions:


You must continue to comply with PS 15 for continuous monitoring applications with the FTIR-CEMS.

b) In the case of process modifications which result in the emission of a new VOC or HAP substance, you must comply with the requirements of "Method 320 - Measurement of Vapor Phase Organic and Inorganic Emissions by Extractive Fourier Transform Infrared (FTIR) Spectrometry" for identification of all the target pollutants (VOCs and HAPs) to be speciated by the FTIR-CEMS, and before resuming use of the FTIR-CEMS for continuous monitoring. To do this, you must:

i) conduct an engineering analysis that considers both the VOC and HAP inputs to the process (use of formulation data would be appropriate) as well as the potential for creation of VOC or HAP cure volatiles or reaction products;

ii) conduct a screening study using the EPA FTIR spectral library available on the Internet (www.epa.gov/oar/oaqps/emc) per the procedures in section 8.0 and the definition of screening in section 3.27 of Method 320. The QA/QC procedures in sections 8.6.2, 9.2, and 13.0 of Method 320 must be used to validate the accurate measurement of the target pollutants identified;

iii) follow USEPA's FTIR Protocol to estimate the quality of future spectrometry results for the new compound(s) in the presence of the known exhaust constituents and in the presence of any spectroscopically similar exhaust constituents (that is, determine maximum analytical uncertainty (MAU) and lower detection limit (LDL));

iv) using an "FTIR Method," which includes the new VOC/HAP(s), reanalyze an existing data set which does not have as exhaust constituents the new VOC/HAP(s) and determine if the "FTIR Method" provides fractional uncertainty results for the existing data set that are consistent with previous results.

c) The validation described in IV.D.4.b above is not required for:

i) the compounds addressed in the report, "Pre-Compliance Test Fourier Transform Infrared Spectrometry Measurement of Tetrahydrofuran, Toluene, 2-Butanone, and Cyclohexanone, 3M Data Storage Tape Technology, Rekusorb Carbon Adsorption and Nitrogen Recovery System, Camarillo, California Facility, August 29, 1995;" and

ii) the compound (MIBK) addressed in the letter report, "Screening test methods, results, and recommendations regarding extractive FTIR spectrometric measurements of regulated organic compounds and hazardous air pollutants at the outlet of the Camarillo plant solvent recovery unit, December 23, 1997."

5. Any baghouse or fabric filter for control of particulate HAP which has been installed or modified under a pre-approved scenario in this Section must meet the requirements of Section II.D.1.b except as noted herein. Any such baghouse or fabric filter which does not have its exhaust routed to the existing SRU, a new SRU, a thermal oxidizer, or a catalytic oxidizer provided for VOC control, must conduct an initial visible emissions demonstration according to 40 CFR 63.7.

Alternatively, if you implement the alternate compliance option of IV.B.8 by installing an enclosed transfer device for conveying particulate HAP, you must use the device following manufacturer's specifications or other written procedures developed for the device. [40 CFR 63.705(g)(1)]

6. Any wash sink or equipment for flushing of fixed lines that are installed or modified under a preapproved scenario in this Section must meet the requirements of Section II.D.1.c.

7. Within 180 days of start-up of a solvent recovery unit which has been installed under a pre-approved scenario in this Section, you must collect CEM data and submit alternate outlet concentration limit(s) for non-coating periods according to Section II.D.1.d.

8. Within 180 days of start-up of any equipment which has been installed under a pre-approved scenario in this Section, and which is hard ducted to the air pollution control device (including equipment such as a sparge bin) you must perform a compliance demonstration according to Section II.D.1.e.

In addition, within 180 days of initial start-up of any mix preparation equipment installed under a pre-approved scenario, you must perform a compliance demonstration (for work practice requirements) as described in Section II.D.1.e [40 CFR 63.705(d)(2)].

9. Within 180 days of start-up of a steam stripper which has been installed under a pre-approved scenario in this Section, you must perform a compliance demonstration in accordance with 40 CFR 63.705(h), utilizing the test methods described in 40 CFR 63.705(b)(9).

10. CMS Performance Evaluations. Within 180 days of initial use of any CMS used to monitor a control device installed under a pre-approved scenario in Section IV.A.2, you must conduct a performance evaluation of the CMS, in accordance with 40 CFR 63.8(e). [40 CFR 63.8(e)(1), (e)(4) and 40 CFR 63.10(e)(1) and (2)]

11. Unless otherwise noted, all compliance demonstrations must be performed according to Section II.D.2 (Compliance and Performance Testing Procedures).


E. Reporting

1. The monthly report, as described in Section II.E must include information pertaining to anticipated, in-progress, and/or recently completed constructions, modifications, reconstructions, or other changes implemented as alternative operating scenarios at the facility. The report must also identify for each such scenario implemented which sections of the permit are being implemented and how the specific requirements which apply to each implemented scenario will be met.

2. Unless otherwise noted, the reporting requirements described in Section II.E also apply to the changes implemented under this Section and will be met through provision of the monthly report.

3. No later than 60 days after completion of any performance testing under Section IV.D of this permit, you must provide VCAPCD with an initial notification of compliance status in accordance with 40 CFR 63.9(h). Such notification will be met through provision of the monthly report.

4. All notification, reporting, and other submittal requirements under Section II.E.2 apply to any corresponding activity under Section IV.

5. For any steam stripper installed pursuant to Section IV.A.2.d, you must submit to VCAPCD with the notification of compliance status the design specifications demonstrating that the steam stripper is meeting the required efficiency. These specifications shall include at a minimum: feed rate, steam rate, number of theoretical trays, number of actual trays, feed composition, bottoms composition, overheads composition, and inlet feed temperature. [40 CFR 63.707(f)]


F. Procedures for Implementing an Alternative Operating Scenario

This section addresses procedures for implementing any of the pre-approved operating scenarios identified in Section IV.A. New constructions, modifications, reconstructions, or other changes authorized under a pre-approved scenario in Section IV.A of this permit may be implemented by the permittee using the following procedures:

1. You must provide advance notification of any new constructions, modifications, reconstructions, or other changes authorized under a pre-approved scenario in Section IV.A of this permit through the monthly report described more fully in Section II.E.1. Advance notification must be provided no later than 30 days prior to commencement of the pre-approved construction, modification, reconstruction, or other change.


2. For any new constructions, modifications, reconstructions, or other changes authorized under a pre-approved scenario in Section IV.A of this permit which involve the emission of a new HAP, an increase in actual emissions of a HAP above levels identified in the most recently approved tiered health risk assessment, or any increase in actual HAP emissions occurring prior to the initial tiered health risk assessment conducted under this Subsection, you must conduct a tiered health risk assessment according to the following procedures:

- The tiered health risk assessment must be performed by Imation using the methodology agreed to by VCAPCD (detailed procedures are described in the EMS for this facility), based on the guidelines for California's Air Toxics "Hot Spots" Information and Assessment laws under Sections 44300-44394 of the Health and Safety Code (AB2588).

- The assessment must be performed on actual levels of emissions from existing operations together with anticipated average and maximum future emissions resulting from implementation of a pre-approved change according to Section IV, Subsection A, or otherwise from emission of a new substance.

If the results of the tiered health risk assessment indicate a carcinogenic risk equal to or greater than 1 x 10-5 (10 in one million) or an acute or chronic hazard index of 1.0 or greater, then the new construction, modification, reconstruction, or other change may not be implemented under a pre-approved scenario.

If the results of the tiered health risk assessment indicate a carcinogenic risk of less than 1 x 10-5 (10 in one million) but greater than 1 x 10-6 (1 in one million), or an acute or chronic index between 0.5 and 1.0, then you may proceed according to the following process:

i) You must submit the results of the tiered health risk assessment and any necessary supporting documentation to the VCAPCD for approval, and you may commence construction, modification, or reconstruction (assuming all other requirements for implementing the scenario are met) while the VCAPCD reviews the assessment. In the case of implementing a scenario under Section IV.A.4.a (changed usage of an existing raw material or usage of a new raw material), you must not implement the scenario until approval is granted under Section IV.F.2.b.iii of this permit.

ii) VCAPCD shall review and approve or disapprove the assessment within 45 days of receipt from the permittee. It is expected that the permittee and VCAPCD will cooperate fully during this 45 day review period and will each provide any necessary and requested information in a timely fashion.

iii) Upon approval of the assessment by VCAPCD, you are authorized to commence operation of the pre-approved newly constructed, modified, reconstructed, or otherwise changed equipment (assuming all other requirements for implementing the scenario are met), or in the case of a change under Section IV.A.4.a, commence usage of a new raw material or changed usage of an existing raw material.

iv) If VCAPCD does not approve the results of the assessment, you must immediately cease any new construction, modification, reconstruction, or other change.

If the results of the tiered health risk assessment indicate a carcinogenic risk of 1 x 10-6 (1 in one million) or less, and acute and chronic indices of 0.5 or less, then you may proceed according to the following process:

i) You must submit the results of the tiered health risk assessment and any necessary supporting documentation to the VCAPCD for approval.

ii) VCAPCD must review and approve or disapprove the assessment within 45 days of receipt from the permittee. It is expected that the permittee and VCAPCD will cooperate fully during this 45 day review period and will each provide any necessary and requested information in a timely fashion.

iii) Once you have submitted the results of the tiered health risk assessment and any necessary supporting documentation to VCAPCD, you are authorized to immediately implement the proposed activity that triggered the requirement to conduct the assessment (assuming all other requirements for implementing the scenario are met).

iv) VCAPCD will notify you upon approval of the submitted assessment.

v) If VCAPCD does not approve the results of the assessment, you must immediately cease any new operation begun under the proposed scenario.

vi) If VCAPCD determines the results of the assessment indicate a carcinogenic risk equal to or greater than 1 x 10-5 (10 in one million), or an acute or chronic index equal to or greater than 1.0, then you will be considered in violation of this permit and subject to penalties and injunctive relief.

3. For any pre-approved scenario implemented under Section IV.A. Condition 1, 2, or 3 you must conduct an internal BACT/TBACT analysis, using the VCAPCD Rule _____ definitions of BACT and TBACT ). Details of the procedures for conducting the BACT/TBACT analysis are described in the EMS for this facility.

If the results of the BACT/TBACT analysis indicate that the existing solvent recovery unit (SRU) represents BACT/TBACT, or that a control device installed previously in accordance with Section IV.A.2 (a), (b), or (c) represents BACT/TBACT, then you may proceed according to the following process:

i) You must submit the results of the BACT/TBACT analysis and any necessary supporting documentation to the VCAPCD for approval, and you may commence construction, modification, reconstruction, or other change (assuming all other requirements for implementing the scenario are met) while the VCAPCD reviews the analysis.

ii) VCAPCD shall review and approve or disapprove the BACT/TBACT analysis within 45 days of receipt from the permittee. It is expected that the permittee and VCAPCD will cooperate fully during this 45 day review period and will each provide any necessary and requested information in a timely fashion.

iii) Upon approval of the BACT/TBACT analysis by VCAPCD, you are authorized to commence operation of the pre-approved newly constructed, modified, reconstructed, or otherwise changed equipment (assuming all other requirements for implementing the scenario are met). [Note: if VCAPCD finds that the SRU, or other existing control device installed previously in accordance with Section IV.A.2 (a), (b), or (c), does not represent BACT/TBACT for the proposed new construction, modification, reconstruction, or other change, then you must immediately cease any such activity and proceed according to the appropriate steps described in 3.b below.]

iv) If a performance test is required (see testing requirements at Section IV.D), then within 180 days of startup of the pre-approved newly constructed, modified, reconstructed, or otherwise changed equipment performed under Section IV.A.1 of this permit, you must conduct a compliance test according to 40 CFR 63.7 and 40 CFR 63.705 whereby the efficiency of the control device is measured when only the newly constructed, modified, reconstructed, or otherwise changed equipment is connected to the control device. Results of the compliance test must be submitted within 60 days of test completion, as part of the initial compliance demonstration, according to 40 CFR 63.9(h) and 63.705.

If the results of the BACT/TBACT analysis indicate that the existing SRU, or other existing control device installed previously in accordance with Section IV.A.2 (a), (b), or (c), does not represent BACT/TBACT and that a new or additional control system is necessary, or if the results confirm that a new control system represents BACT/TBACT (as is specified under the scenarios in Section IV.A.2 of this permit), then you may proceed according to the following process:

i) You must submit the results of the BACT/TBACT analysis and any necessary supporting documentation to the VCAPCD for approval.

ii) VCAPCD shall review and approve or disapprove the BACT/TBACT analysis within 45 days of receipt from the permittee. It is expected that the permittee and VCAPCD will cooperate fully during this 45 day review period and will each provide any necessary and requested information in a timely fashion.

(A) If VCAPCD approves the analysis demonstrating that a new thermal oxidizer is BACT/TBACT, then you are authorized to commence construction, modification, reconstruction, or other change and operation of the newly constructed, modified, reconstructed, or otherwise changed equipment (assuming all other requirements for implementing the scenario are met, including compliance with the initial parameters for a thermal oxidizer described in Section IV.B.4, acquisition prior to operation of offsets for any collateral emissions associated with the thermal oxidizer, and notification of VCAPCD, pursuant to California Health and Safety Code 40709.5.e and VCAPCD Rule 26.4 relating to offset notification).

(B) If VCAPCD approves the analysis demonstrating that a new catalytic oxidizer is BACT/TBACT, then you are authorized to commence construction, modification, reconstruction, or other change (assuming all other requirements for implementing the scenario are met). No later than 30 days prior to commencement of operation you must submit to VCAPCD the following information and a proposal with supporting engineering analysis for the initial operating conditions of the control device as follows: the minimum gas stream temperature at the inlet of the catalyst bed and the minimum temperature rise across the catalyst bed to ensure VOC and HAP destruction efficiency at the level determined to be BACT/TBACT. Prior to operation of the new catalytic oxidizer, you must secure offsets for any collateral emissions associated with the new device, and provide notification to VCAPCD, pursuant to California Health and Safety Code 40709.5.e and VCAPCD Rule 26.4 relating to offset notification.

(C) If VCAPCD approves the analysis demonstrating that a new solvent recovery unit (this includes the THF system currently located at the facility) is BACT/TBACT, then you are authorized to commence construction, modification, reconstruction, or other change (assuming all other requirements for implementing the scenario are met). No later than 30 days prior to commencement of operation you must submit to VCAPCD information and a proposal with supporting engineering analysis for the initial operating conditions of the control device that will ensure VOC and HAP control efficiency at the level determined to be BACT/TBACT.

iii) Within 180 days of startup of the new pollution control device, a compliance test must be performed according to 40 CFR 63.7 and 40 CFR 63.705 whereby the efficiency of the control device is measured when only the newly constructed, modified, reconstructed, or otherwise changed equipment is connected to the control device. Results of the compliance test must be submitted within 60 days of test completion, as part of the initial compliance demonstration, according to 40 CFR 63.9(h) and 63.705.

iv) Upon completion of the performance testing described in Section IV.F.3.b.iii, you must submit an application for a minor permit modification to the VCAPCD, unless otherwise noted below.

(A) For a new thermal oxidizer, the purpose of the minor permit modification would be to establish the operating conditions for the control device that were demonstrated through performance testing to provide the necessary level of VOC/HAP destruction efficiency (95% or higher). As noted in Section IV.B.4 of this permit, if the initial operating condition requirements contained in this permit for the thermal oxidizer (1500 degrees F and 0.5 seconds residence time) are demonstrated to achieve the required destruction efficiency, then you do not need to revise the operating conditions (and no permit modification is required). If more stringent operating conditions (i.e., higher temperature and/or longer residence time) are required to achieve the necessary destruction efficiency, then you must revise the operating conditions accordingly with a minor permit modification. If less stringent operating conditions than those currently in the permit are demonstrated to achieve the necessary destruction efficiency, then you may revise the operating conditions accordingly through a minor permit modification or maintain the more stringent operating conditions already in the permit.

(B) For a new catalytic oxidizer a minor permit modification is necessary once performance testing of the new device is complete. The purpose of the minor permit modification is to establish the operating conditions for the catalytic oxidizer that were demonstrated through performance testing to provide the necessary level of VOC/HAP destruction efficiency (95% or higher).

(C) For a new carbon adsorption system a minor permit modification is necessary once performance testing of the new device is complete. The purpose of the minor permit modification is to establish the operating conditions for the carbon adsorption system that were demonstrated through performance testing to provide the necessary level of VOC/HAP control efficiency (95% or higher).

(D) If a permit modification is made under (A), (B), or (C) above, then such modification will also provide an opportunity to document on the permit the scenario that was implemented (i.e., indicate on the face of the permit the fact that equipment initially specified only in a Section IV.A pre-approved AOS is now present at the facility). Any such permit modification would not in any way change the requirement in Section IV.F.5 to maintain a contemporaneous log indicating the scenario under which you are operating.

4. To implement any of the pre-approved operating scenarios specified in Section IV.A.4, you are not required to conduct a BACT/TBACT analysis, however you must proceed according to Sections IV.A.1 and IV.A.2 (as appropriate) above.

5. For any pre-approved scenarios involving new constructions, modifications, reconstructions, or other changes authorized by Section IV.A and implemented according to the procedures of this subsection (IV.F), you must maintain a log at the facility recording the implementation of such activity and describing the scenario under which the facility is operating. This log must be created and maintained contemporaneously with any change in the facility's operating scenario. This log must also be made available for public review.

 

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