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Imation

Pre-Draft Title V Permit - Section IV
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.


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