Imation
Draft Permit to Operate
Page 1 of 20 DRAFT PERMIT
March 26, 1996
Ventura County Air Pollution Control District
669 County Square Drive
Ventura, CA 93003
(805) 645-1401DRAFT PERMIT TO OPERATE
Number 0029 Valid January 1, 1996 to December 31, 1996
This Permit Has Been Issued To The Following:
Company Name / Address: Facility Name / Address 3M Company 3M Data Storage Tape Technical Division P.O. Box 33331 Bldg. #41-01-05 350 S. Lewis Rd. St. Paul, MN 55133 Camarillo, CA 93012
Permission Is Hereby Granted to Operate The Following:
Coating Dispersion Application/Drying Equipment Used for Magnetic Tape Production, And Consisting Of:
4 - Enclosed Magnetic Tape Coating/Curing Lines (Designated as 41, 42, 43, and 44, with 41 being the easternmost line). Each magnetic tape coating/curing line enclosure consists of a coater room and a drying/curing oven which exhaust to the ROC Control/Recovery System.
Coater Line 41 is equipped with a continuous airflow monitoring system to ensure that the line continues to meet total enclosure requirements. Airflow at Coater Line 41 is monitored at the coater enclosure air supply duct, the oven air supply duct, and the oven exhaust duct.
Coating Dispersion Compounding Equipment, Located in The Compounding Room, And Consisting Of The Following Types Of Equipment:
Ball Mills, Sand Mills, Shaker Mills, Mixing Kettles, Resin Kettles, Homogenizers, and Associated Pumps.
Each mixing kettle is equipped with a conservation vent (pressure/vacuum release valve) and lip exhausts which are routed to the ROC Control/Recovery System.
The compounding room is equipped with room vents (EF-13 and EF-14) which are routed to the coater oven supply duct, which in turn leads to the ROC Control/Recovery System.
Coating Dispersion Final Preparation, Located In The Tunnel Room, And Including The Following Equipment Which Is Exhausted To The ROC Control/Recovery System:
1 - Solvent Drum Hook-Up Vent System (F-19)
1 - Cold Solvent Wash Tank, with overhead exhaust (F-18)
1 - Tunnel Room Vent System (T-1, F-15, EF-22)
1 - Tunnel Room Vent System (T-2, T-3)
Coating Dispersion Storage Room, Consisting Of:
1 - Or More Coating Dispersion Storage Tanks, of less than 5,000 gallon capacity
Each storage tank is equipped with a conservation vent (pressure/vacuum relief valve) which exhausts to the ROC Control/Recovery System.
The coating dispersion storage room is equipped with room vent (PRE-12) which exhausts to the atmosphere.
Contaminated Soil Vapor Extraction System, Consisting Of:
1 - Or More Vapor Extraction Wells
1 - Blower, MD Pneumatics Model 5511, 25 HP, 400 cfm capacity
Exhaust from the vapor extraction wells is routed to the solvent laden air duct which leads to the ROC Control/Recovery system.
ROC (Reactive Organic Compound) Control/Recovery System, Consisting Of:
1 - Rekusorb Carbon Adsorption/Nitrogen Desorption/Solvent Recovery System, with a nominal flow rate of 60,000 CFM, and four carbon adsorption vessels identified as A1, A2, B1, and B2, operated as parallel pairs A (1 or 2) / B (1 or 2), or singly, with one common exhaust stack
1 - Solvent Recovery Storage Tank Farm, each with a capacity of less than 5,000 gallons, and each tank exhausting to the ROC Control/Recovery System
1 - Or More Distillation Columns, which exhaust to the ROC Control/Recovery System
A continuous emissions monitoring system (CEMS) is used to monitor the efficiency of the carbon adsorption system by monitoring the concentration (in ppmv) of total hydrocarbons at the following locations:
a) The solvent laden air duct;
b) The exhaust stack for carbon adsorption vessels A1 and A2;
c) The exhaust stack for carbon adsorption vessels B1 and B2; and
d) The common exhaust stack for the four carbon adsorption vessels.
One total hydrocarbon analyzer monitors emissions at the solvent laden air duct while another monitors emissions at the carbon adsorption exhaust stacks.
Emissions which are routed to the ROC Control/Recovery system are routed from the applicable local exhaust system to either a 36" duct or a 60" duct. These two ducts combine to form the "solvent laden air duct" which leads to the ROC Control/Recovery system.
Emissions are routed to the 36" duct from the following sources:
a) The solvent drum hook-up vent (F-19), overhead cold solvent wash tank vent (F-18), and T-1, F-15, F-18, and EF-22 tunnel room exhaust;
b) All conservation vents at the dispersion holding tanks in the dispersion storage room;
c) All conservation vents from compounding room mixture kettles; and
d) The solvent recovery storage tank farm and distillation column vents associated with the solvent recovery system.
Emissions are routed directly to the 60" duct from the following sources:
The four coating/curing line enclosure exhausts
Emissions are indirectly routed to the 60" duct from the following sources:
a) The T-2 and T-3 tunnel room exhausts via duct E-14 which then joins duct EF-13; and
b) All compounding room mixing kettle lip exhausts (EF-13).
Exhaust from these sources is routed to the four coating line oven air supply ducts and then exits the four oven exhaust ducts to the common 60" duct.
Emissions are routed directly to the solvent laden air duct from the following sources:
Vapor extraction wells
Wet Scrap Drying System, Consisting Of:
1 - Wet Scrap Dryer, Solidaire SJS 24-14
Boilers, Consisting Of:
1 - Nebraska Boiler, Model NS-C-44, identified as boiler No. 3, 39.3 MMBTU/Hr capacity, equipped with a Faber low NOx burner, Model WB-1-20FGR, and flue gas recirculation, fired on natural gas or standby No. 2 fuel oil
1 - Murray Boiler, Model M64-C-13, identified as boiler No. 1 and standby unit for boiler No. 3, 28.6 MMBTU/Hr capacity, equipped with a Faber low NOx burner and flue gas recirculation, fired on natural gas or standby No. 2 fuel oil
Printing Operations, Consisting Of:
1 - Or More Videojet Inkjet Printers, Model Excel 100, utilizing air drying method, with no ROC control equipment
1 - Or More Letterpress Printers, using only inks and cleanup materials that do not contain any ROCs or exempt organic compounds
This Permit Has Been Issued Subject to the Following Conditions:
1. Permitted Emissions:
Tons/Year Pounds/Hour Reactive Organic Compounds
Nitrogen Oxides
Particular Matter
Sulfur Oxides
Carbon Monoxide256.88
8.34
0.51
0.96
5.73331.31
5.57
0.56
20.07
1.39
2. Applicability of NSPS Subpart A and Subpart SSS
3. Emissions Limits for The Four Magnetic Tape Coater Lines
The Rekusorb carbon adsorption system, magnetic tape Coater Line 41, and all coating dispersion mix preparation equipment are subject to the New Source Performance Standard (NSPS) in Title 40 of the Code of Federal Regulations, Part 60, Subpart A, "General Provisions," and Subpart SSS "Standards of Performance for Magnetic Tape Coating Facilities." This NSPS is incorporated by reference in District Rule 72. All references to 40 CFR 60 in this Permit to Operate are references to this NSPS. (See 40 CFR 60.712.b.2.ii and 40 CFR 60.712.d.)
4. Emissions Limit for Coater Line 41
Total ROC (Reactive Organic Compound) emissions from Coater Lines 41, 42, 43, and 44 shall not exceed 240.37 tons per year.
In order to demonstrate compliance with this condition, the 3M Company shall provide data and records of monthly emissions from each coater, as specified in Condition Nos. 21 and 22(c). The monthly emissions shall be summed for the previous twelve months. Totals for any of these twelve month periods in excess of the specified limit shall be considered a violation of this Permit to Operate.
5. Compound Room And Tunnel Room Emission Limits
Total ROC emissions from Coater Line 41 shall not exceed 67.4 tons per year. (See 0029-140 dated 06/13/90, 0029-232 dated 10/30/91, and 0029-221 dated XX/XX/95.)
In order to demonstrate compliance with this condition, the 3M Company shall provide data and records, as specified in Condition Nos. 21 and 22(c). The monthly emissions shall be summed for the previous twelve months. Totals for any of these twelve month periods in excess of the specified limit shall be considered a violation of this Permit to Operate.
6. Requirement for Proper Operation Of The Rekusorb Control System
Total ROC emissions from equipment and/or operations performed in the compounding room, prior to reduction by the ROC control system, shall not exceed 18.93 pounds per hour. Total ROC emissions from equipment and/or operations performed in the tunnel room, prior to reduction by the ROC control system, shall not exceed 18.50 pounds per hour. (See 0029-23 dated 09/20/85, 0029-150 dated 04/17/90, and 0029-221 dated XX/XX/95.)
In order to demonstrate compliance with this condition, testing and reporting shall be conducted every twenty four months, as specified in Condition No. 14. Sampling shall occur at the following locations:
Tunnel Rooma) Duct EF-22 at a point downstream of merging with duct F-15;
During these tests, ducts T-2 and T-3 (from the tunnel room to the compounding room) shall not be blocked off.
b) Duct F-19;
c) Duct F-18;
Tunnel Room
d) Duct EF-13 at a point downstream of merging with duct EF-14; and
e) The duct which vents emissions from compounding room and dispersion tank conservation vents.
An hourly emissions total in excess of the corresponding limit shall be considered a violation of this Permit to Operate.
7. ROC Control Efficiency Requirement - Based on NSPS
A magnetic tape coating line shall only be operated when it is exclusively vented to the Rekusorb control system. Additionally, ROC-emitting operations in the tunnel room or in the compounding room shall only be conducted when the emissions are exclusively vented to the Rekusorb control system.
The control system and all ductwork, hoods, dampers, and fans shall be maintained in proper operating condition whenever one or more coating lines are in use, and whenever emissions are venting from the compounding room, the tunnel room, or from the coating lines.
8. ROC Control Efficiency Requirement - Based on Rule 74.3
Pursuant to 40 CFR 60.712.b.2.ii, whenever at least one coater is operating, the ROC control system shall reduce emissions of ROC, as measured in the solvent laden air duct, by at least 95% per carbon bed, before release to the atmosphere. This includes emissions resulting from coating line startups and shutdowns (40 CFR 60.713.c).
The 3M Company shall maintain continuous in-stack emissions monitors to ensure that a 95% control efficiency is continuously met, as required by 40 CFR 60.714.c.2 and summarized in Condition Nos. 12 and 13. Pursuant to 40 CFR 60.717.d.4.ii.B, if the control efficiency of any bed of the carbon adsorption system is measured or calculated to be less than 95% during any consecutive 72-hour (3-day) rolling period of coating operation, then the operation of the coating activity is in violation of 40 CFR 60, APCD Rule 72, and this Permit to Operate.
In order to demonstrate compliance with this condition, the 3M Company shall provide data and records, as specified in Condition Nos. 13 and 21, respectively.
9. Web Handling Limit For The Coating Lines
Whenever at least one coater is operating, the control system shall reduce emissions of ROC, as measured in the solvent laden air duct, by a combined capture and destruction efficiency of no less than 90%, averaged over each consecutive 24-hour rolling period, before release to the atmosphere. (See Rule 74.3.B.1.c.)
If any coating applied contains more than 1200 grams of ROC per liter, less water and less exempt organic compounds, then in addition to the 90% efficiency requirement, emissions shall be limited to 120 grams of ROC per liter of coating, less water and less exempt organic compounds, using a rolling 24 hour average. (See Rule 74.3.B.1.c.)
Prior to using any coating containing more than 120 grams of ROC per liter, less water and less exempt organic compounds, the permitted shall submit an application for, and receive, a permit modification.
The 3M Company shall maintain a continuous in-stack emissions monitor, as specified in Condition Nos. 12 and 13, to ensure on a continuous basis that a 90% control efficiency is met.
If during any single consecutive rolling 24-hour period of coating operation, the control efficiency of the carbon adsorption system is measured or calculated to be less than 90%, then the operation is in violation of APCD Rule 74.3.
In order to demonstrate compliance within this condition, the 3M Company shall provide data and records, as specified in Condition Nos. 13 and 21, respectively.
10. Coater Line 41 Total Enclosure Requirements
The cumulative web handling rate for all four coater lines shall not exceed 2,950 feet per minute. (See 0029-130 dated 08/08/89 and 0029-140 dated 06/13/90.)
In order to comply with this condition, the 3M Company shall provide data and records, as specified in Condition Nos. 13 and 21, respectively.
NSPS Requirements For Coating Mix Preparation Equipment
Whenever Coater Line 41 is in operation, the line shall be maintained in a "Total Enclosure." The following is a summary of criteria which shall be met, pursuant to 40 CFR 60.713.b.5.i:
a) The total area of all natural draft openings shall not exceed five percent of the total surface area of the walls, floor, and ceiling of the total enclosure; and
b) All sources of emissions within the enclosure shall be a minimum of four equivalent diameters away from each natural draft opening. The District shall be notified if any physical modifications are made to the total enclosure.
In addition, pursuant to 40 CFR 60.717.d.8, continuous monitoring of Coater Line 41 shall be conducted to ensure that the average inward flow across the natural draft openings continues to meet total enclosure requirements.
Monitoring shall be conducted at least once every 15 minutes in which Coater Line 41 is in operation. The average value shall be computed for each cumulative one hour period in which Coater Line 41 is in operation. Additionally, the average value shall be computed for each consecutive 3-hour rolling period in which Coater Line 41 is in operation.
Total enclosure monitoring shall be conducted according to Condition No. 22(d). This permit condition specifies that the parameter to be measured as an indicator of ROC capture system performance is the net average inward volumetric flowrate across all natural draft openings, as shown in Equation 6 of 40 CFR 60.713.b.5.i.C.
The airflows, "Q," which shall be monitored are at the coater enclosure inlet, the oven inlet, and the oven exhaust. In a total enclosure demonstration test performed on November 14, 1991, the average inward volumetric flowrate, "(;Qout - ;Qin)" determined in the most recent total enclosure demonstration test is significant for Coater Line 41 total enclosure reporting requirements. (See Condition No. 21(n)(ii)).
Calibration of the airflow monitoring system shall be conducted according to manufacturer's specifications.
In order to demonstrate compliance with this condition, the 3M Company shall provide data and records, as specified in Condition Nos. 13 and 21, respectively. Failure to comply with this condition shall be considered a violation of 40 CFR 60, APCD Rule 72, and this Permit to Operate.
12. CEM Operating Requirements - ROC Control System
The 3M Company shall control emissions at each piece of coating mix preparation equipment by venting the equipment to a control device which achieves at least 95% control of ROC emissions and by installing and using a cover on each piece of equipment that meets the following specifications (See 40 CFR 60.712.d.1):
a) The cover shall be closed at all times except when adding ingredients, withdrawing samples, transferring the contents, or making visual inspection when such activities cannot be carried out with cover in place. Such activities shall be carried out through ports of the minimum practical size; andb) The cover shall extend at least 2 cm beyond the outer rim of the opening or shall be attached to the rim; and
c) The cover shall be of such design and construction that contact is maintained between cover and rim along the entire perimeter; and
d) Any breach in the cover (such as an opening for insertion of a mixer shaft or port of addition of ingredients) shall be covered consistent with b and c of this section when not actively in use; and
e) A polyethylene or nonpermanent cover may be used provided it meets the requirements of b, c, and d of this section. Such a cover shall not be reused after once being removed.
Coating mix preparation equipment includes all: mills, mixers, holding tanks, polishing tanks, and other equipment used in the preparation of a magnetic tape formulation. This does not include those mills that do not emit ROC because they are closed, sealed, and operated under pressure (40 CFR 60.711.a.4). This definition includes the dispersion tanks.
Failure to meet any of these requirements shall be considered a violation of 40 CFR 60, APCD Rule 72, and this Permit to Operate.
13. Data Requirements For Monitoring Associated With Magnetic Tape Production
In accordance with 40 CFR 60.714.c.2, the 3M Company shall install, calibrate, maintain, and operate, in accordance with manufacturer's specifications, a continuous emissions monitoring system (CEMS). The CEMS shall continuously measure and record the concentration level of organic compounds in the solvent laden air duct (combination of 36" to 60" ducts), the common exhaust stack, and the outlet concentration from each in-service carbon adsorption bed. Continuous measurement is defined as measuring each required monitoring point at least once every 15 minutes.
Quality assurance procedures for the CEMS shall be performed as specified in Condition No. 22(b). Procedures for daily calibration, start-up, and operation of the CEMS shall be performed as specified in Condition No. 22(a).
Every twenty four months a source test shall be conducted to determine and to demonstrate the continuing acceptable operation of the CEMS. Testing shall be performed as specified in Condition No. 14.
Any significant modification or replacement of either of the two Ratfish Model RS 55CA Oven Heated Total Hydrocarbon Analyzer Systems shall trigger an immediate testing requirement. Whether a modification is considered significant will be determined by the District on a case by case basis. The District shall be notified prior to such a change.
14. Requirement For Periodic Source Testing Of ROC Emissions From Magnetic Tape Production Operations
The CEMS and compliance monitoring system shall be designed and operated to provide the following data or information immediately upon demand for the most current data and in a permanent electronic record with a hard copy printout upon request:
a) The ROC concentrations in ppmv at the following locations: the solvent laden air duct; the common exhaust duct to the atmosphere from the carbon adsorption system; and the exhaust from each operating carbon bed; andb) The most recently calculated value for adsorption efficiency at each carbon bed; and
c) The most recent average carbon adsorption efficiency for each carbon bed, as calculated over a consecutive 72-hour (3-day) rolling period of coating operation (40 CFR 60.717.d.4.ii.B); and
d) The most recent average carbon adsorption system efficiency, as calculated over a consecutive 24-hour rolling period of coating operation (APCD Rule 74.3); and
e) The current airflow at each of the two supply airflows and one exhaust airflow of the Coater Line 41 total enclosure, as well as the current average airflow at each of these points, as calculated over the most recent consecutive 3-hour rolling period (40 CFR 60.717.d.8); and
f) The current average value calculated for the net average inward volumetric flowrate, "(;Qout - ;Qin)", using the airflow data from "e)" above (40 CFR 60.717.d.8); and
g) The compliance status for the most recently calculated value of "(;Qout - ;Qin)" that drops five percent or more from the average value determined during the most recent performance test that demonstrated compliance for total enclosure shall be considered a violation (40 CFR 60.717.d.8).
h) ROC emissions, as calculated over the most recent consecutive twelve month rolling period of coater operations for each coater and for all coaters combined; and
i) Identification of all coater lines currently in operation; and
j) Solvent loading rate for each coater line in operation; and
k) Current line speed at each coater and cumulative line speed (cumulative web handling speed for all coater lines); and
l) An audible, visual, or electronic alarm system that automatically alerts the operator and makes a permanent record should either of the following occur:
The carbon adsorption control efficiency at any carbon bed falls below the 95% requirement of 40 CFR 60.712.b.2.ii (40 CFR 60.717.d.r.ii.B); or
The average calculated value of "(;Qout - ;Qin)", as determined over a consecutive 3-hour rolling period, drops by 5% or more from the average value of "(;Qout - ;Qin)", as determined during the most recent performance test which demonstrated compliance (40 CFR 60.717.d.8); or
The carbon adsorption control system efficiency falls below the 90% requirement, based on a consecutive 24-hour rolling average (APCD Rule 74.3).
15. Solvent Restrictions For Magnetic Tape Coating
The 3M Company shall demonstrate compliance of the ROC control and continuous emissions monitoring system every twenty four (24) months via a source testing procedure mutually acceptable to the 3M Company and the APCD, subject to APCD approval. The following, at a minimum, shall be determined from source testing:
a) The control efficiency at the Rekusorb carbon adsorption system. For at least one carbon bed, the control efficiency determination shall coincide with a complete adsorption cycle; andb) The ROC emissions from the ROC control system as determined from measured ROC concentrations and measured volumetric flowrates at the carbon adsorption system outlet; and
c) Whether there is continuing acceptable operation of the CEMS and the performance of a relative accuracy demonstration for the CEMS. If discrepancies between the CEMS and the reference method appear to be significant, the District may require further measures; and
d) A comparison between ROC control system emissions determined from the source test and emissions determined from the COP during the source test interval; and
e) Worst case hourly emissions from coating dispersion compounding operations and coating dispersion final preparation operations located in the compounding room and tunnel room, respectively.
Source testing of the Rekusorb carbon adsorption system shall be conducted in accordance with Section 1.1, "Applicability and Principle," of CFR Part 60, Appendix A, Method 25, "Determination Of Total Gaseous Nonmethane Organic Emissions As Carbon." This includes the requirement that direct measurement with an FID analyzer (as allowed by Method 25A) may only be used for testing when the relative percentages of compounds in the gas streams are either known or determined and when the FID responses to the compounds (response factors) are either known or determined.
In addition to the requirement that the above tests be performed every twenty four months, the requirement for a test on a system may be triggered earlier if any significant change is made to the system. Please contact the District Engineering Section to receive feedback on whether a particular change is deemed significant. In addition, some changes may also trigger the requirement for a permit modification.
Prior to performing any testing, the 3M Company shall submit test protocols to the District Engineering Section and receive approval for the protocols. The 3M Company shall also arrange for a mutually acceptable test schedule so that District staff may be allowed to observe the tests.
This condition is applied to ensure that proper operation of the ROC collection, control, and monitoring system continues.
16. Minimizing Emissions From Drums In The Tunnel Room
The 3M Company shall only use the following solvents in magnetic tape coating formulations: methyl ethyl ketone, tetrahydrofuran, cyclohexanone, toluene, and methyl isobutyl ketone. This condition does not prohibit the use of solvents or additives which, as summed, comprise less than five percent, by weight, of the volatile fraction in each dispersion coating formulation.
This condition is applied to ensure compliance with APCD Rule 51, "Nuisance," and APCD Rule 26, "New Source Review."
Prior to using any solvent prohibited by this condition, the permittee shall submit an application for, and receive, a permit modification. A permit modification evaluation may include, but is not limited to, consideration of the following: the permittee's CEM response factor for the proposed solvent; carbon breakthrough characteristics of the solvent; and the acute and chronic risk factors for the proposed solvent.
17. Minimizing Emissions At The Cold Solvent Wash Tank
All drums which are connected to supply coating to a coater line shall be connected to the drum vent system even if the coater line is not immediately using drum material. All other drums of coating shall be covered except when adding or removing material pursuant to APCD Rule 74.3.B.2. (This condition is imposed as part of the emission reduction credit granted pursuant to 0029-23 issued 09/20/85.)
18. Minimizing Emissions From Containers And Mixing Equipment
The damper in the exhaust duct of the cold solvent wash tank shall be maintained in proper working order, including proper sealing of the damper. The wash tank cover shall be opened only when necessary to process work. (This condition is imposed as part of the emission reduction credit granted pursuant to 0029-25 issued 09/20/85.)
19. Magnetic Tape Production Clean-Up Activities
Containers and mixing equipment containing reactive organic compounds shall be free from leaks and shall be covered except when necessary to add or remove materials, or during cleaning operations. Charging and solvent flushing shall only take place in an area when the ventilation system for the area, and the carbon adsorption system controlling the emissions from the ventilation system, are operating. (See Rule 74.3.B.2.)
20. ROC Control System In A Single Carbon Bed Mode
Clean-up activities using solvent containing reactive organic compounds of 200 grams per liter or more shall be done within the total enclosure with the appropriate carbon adsorption system in operation or in an area when the ventilation system for the area, and the carbon adsorption systems controlling the emissions from the ventilation system, are in operation. (See Rule 74.3.B.3.)
21. Monitoring, Recordkeeping, And Reporting Requirements
The ROC Control/Recovery System shall be allowed to operate in a single carbon bed mode provided that the control efficiency for the ROC Control System is monitored (comparison of the ROC concentration in the solvent laden air to the common exhaust duct) as well as the efficiency for the single carbon bed (comparison of the ROC concentration in the solvent laden air duct to the exhaust for the active carbon bed).
Pursuant to 40 CFR 60.712.b.2.ii, APCD Rule 72, and this Permit to Operate, a 95% control efficiency shall be met, as measured in the solvent laden air duct and the active carbon bed exhaust duct, and as determined over each consecutive 72-hour rolling period of coating operation.
Pursuant to APCD Rule 74.3, and this Permit to Operate, a 90% control efficiency shall be met, as measured in the solvent laden air duct and the common exhaust duct, and as determined over each consecutive 24-hour rolling period of coater operation.
22. COP Procedures For ROC Emissions From Magnetic Tape Production
The 3M Company shall comply with the following monitoring, recordkeeping and reporting requirements:
a) Monthly records of the total ROC emissions from each of the four coater lines and their summation, as determined using CEMS data, and as generated from procedures followed in Condition No. 22(c). Records shall also be kept for monthly emissions summed over the pervious twelve months.b) Daily compilations of the maximum cumulative web handling speed for the four coater lines, recorded each hour, as specified in Condition No. 22(c).
c) Daily compilations of the continuous readings for total hydrocarbon concentration monitoring, in ppmv, at the following locations: the solvent laden air duct, the common exhaust stack, and the outlet concentration from each in-service carbon adsorption bed. The reported values for each monitoring location may be averaged over a maximum period of 15 minutes. The 3M Company shall also identify, for each carbon adsorption bed, the periods the device is not in-service.
d) Rolling 24-hour records of the control efficiencies for the total carbon adsorption system, and rolling 72-hour records of the control efficiencies for each carbon absorber bed, as determined by the procedures of Condition No. 22(c).
e) For each of the coating dispersion formulations, data on the solids content (percent by weight), the density, the ROC content in grams per liter, and the ROC content in grams per liter, as determined less water and less exempt organic compounds. Additionally, monthly records shall be maintained of the quantity of each coating dispersion formulation applied at each coating line.
f) Daily compilations of the continuous readings for Coater Line 41 total enclosure monitoring, in cubic feet per minute, of the average airflow, as calculated over each consecutive 3-hour rolling period, at each of the two supply airflows and one exhaust airflow of the total enclosure (40 CFR 60.714.h).
g) Daily compilations of the average calculated values of "(;Qout - ;Qin)" for the Coater Line 41 total enclosure, as determined over each consecutive 3-hour rolling period. For each of the calculated values of "(;Qout - ;Qin)", daily records shall be kept of the compliance status. Values of "(;Qout - ;Qin)" that drop five percent or more below the average value determined during the most recent performance test that demonstrated compliance for total enclosure shall constitute a violation. "(;Qout - ;Qin)" was calculated as 1402 CFM on November 14, 1991 (40 CFR 60.714.h and 40 CFR 60.717.d.8).
h) Records of time periods of coating operations when an emission control device is not in use (40 CFR 60.714.I).
i) An up-to-date report that identifies the date and time of each compliance violation, as specified in Condition No. 13, item "1", of this permit.
j) Daily calibration records and quality assurance records for the CEMS, including records of the certified analyses for the zero and span gases.
k) Records of calibrations performed, according to manufacturer's specifications, for all coater line solvent loading flow meters.
l) Records of calibrations performed, according to manufacturer's specifications, on the pilot arrays at the oven inlet, coater enclosure inlet, and the oven exhaust of Coater Line 41.
m) Maintain test reports for all emission tests related to magnetic tape production operations.
n) Quarterly reports shall be submitted to the Ventura County APCD that document the following:
o) Report to the Ventura County APCD anytime the CEMS indicates that the 95% (based on the 72-hour (3 day) rolling averages of all the individual adsorption vessels) control efficiency requirement or the 90% (24-hour average) control efficiency requirement has not been achieved, by following the reporting requirements of the breakdown procedure discussed in District Rule 32, "Breakdown Conditions; Emergency Variances".
i) All 3-day rolling averages (during actual coating operation) when the control device efficiency for any of the carbon beds falls below 95 percent (40 CFR 60.717.d.4.ii.B); andii) All 3-hour periods (during actual coating operations) during which the average total enclosure monitoring device readings for Coating Line 41 drops by 5 percent or more from the average value measured during the most recent performance test that demonstrated compliance for total enclosure (40 CFR 60.717.d.8).
The reports may be submitted semiannually when no reportable periods have occurred (40 CFR 60.717.e). The reports shall be postmarked within 30 days of the end of the reporting period (40 CFR 60.717.h). In addition, all reports required under NSPS (40 CFR 60.7 and 40 CFR 60.717) shall be forwarded to the Ventura County APCD.p) Monthly records of cleanup solvent consumption, including solvent identification numbers and the amount used.
q) Daily records of the amount of standby fuel oil used in the boilers, and the duration of each occurrence (Rule 74.15.D.3), as well as monthly compilations of the amount of natural gas and standby fuel oil burned in the boilers, and the sulfur content of the fuel oil burned, on a percent by weight basis.
r) Maintain test reports for all emission tests performed on the boilers (Rule 74.15.D.2).
s) Monthly records specifying the amount of all ROC-containing inks, additives, and cleanup materials used. The records shall also identify the ROC content, as applied, of each material, and the type of printing operation associated with the material (e.g. letterpress, inkjet). Manufacturer's documentation shall also be provided to support the ROC data. Adequate supporting documentation shall also be provided for those materials which the permittee claims contain no ROCs. All records shall be maintained for a period of two years and shall be available to the District for inspection upon request.
The 3M Company shall utilize the following Camarillo Operating Procedures as approved by the District:
a) The procedures for daily calibration, start-up and operation of the total hydrocarbon analyzers used to monitor the solvent-laden air and purified air (5385-COP-17).b) The quality assurance procedures for the continuous monitoring instruments used to measure reactive organic compound emissions from the Rekusorb control system (5300-COP-165).
c) The procedures for monitoring compliance with the ROC emission limitations for the coater lines and carbon adsorption system, the coater line permitted emissions, and permitted emissions attributable to the compounding and tunnel rooms (5300-COP-184).
d) The procedures for monitoring compliance with the "Total Enclosure" requirement for Coater Line 31 (5300-COP-184).
e) The procedures for monitoring compliance with the permitted emissions attributable to the scrap dryer (5300-COP-102).
23. Applicability Of APCD Rule 74.15 To The Boilers
24. Prohibition On Simultaneous Operation Of The Two Boilers
The emissions of oxides of nitrogen and carbon monoxide, from both the Nebraska and the Murray Boiler, shall not exceed 40 ppmvd and 400 ppmvd, respectively, corrected to 3% excess oxygen. These emission limits do not apply when the boilers are operated on fuel oil in compliance with Condition No. 25. (See Rule 74.15.B.1).
In order to comply with this condition, the permittee shall have boiler emissions tested no less than once every 24 months and shall maintain the external flue gas recirculation system according to the parameters specified in Condition No. 27.
25. Fuel Consumption Limits On The Boilers
The Nebraska Boiler, identified as boiler No. 1, shall not be operated at the same time as the Murray Boiler, identified as boiler No. 3. (See 0029-200 dated 11/27/91)
26. Requirement for Periodic Source Testing Of The Boilers
Fuel consumption for the boilers is limited to 324.1 MMSCF per year of natural gas, 13,900 gallons per year of standby fuel oil for boiler No. 3, and 10,100 gallons per year of standby fuel oil for boiler No. 1. Total fuel use for both boilers shall not exceed 344 billion BTU per year, assuming the heat content of natural gas is 1050 BTU/scf and the heat content of the standby fuel oil is 141,000 BTU/gal.
The standby fuel oil may be used only during periods of natural gas curtailment to the boilers by the natural gas supplier. The standby fuel oil may also be used for up to 50 hours per year for each boiler as required to maintain the alternative fuel system.
In order to demonstrate compliance with this condition, the operator shall maintain daily records and monthly reports of fuel consumption as required by Condition No. 21. The monthly records shall be summed for the previous 12 months. Fuel consumption totals for the previous 12 months in excess of the above limits shall be considered to be a violation of this condition.
27. Flue Gas Recirculation Parameters
The 3M Company shall cause emissions source testing to be completed on the two boilers no less than once every 24 months. The test methods used for emissions determination shall be in accordance with APCD Rule 74.15. Prior to any stack testing, the 3M Company shall contact the APCD Enforcement Section to arrange a mutually acceptable testing schedule. The emissions test report and results shall be submitted to the APCD Enforcement Section within 45 days after the test.
28. Vapor Extraction System Requirements
The Murray and Nebraska boilers flue gas recirculation mechanical linkage settings shall comply with the following:
Murray Boiler Third pin setting from the end
Nebraska Boiler Connecting rod attached to the 4th hole from the end on the damper control arm and the 5th hole from the end on the cam indicator arm.
In order to comply with these requirements, the 3M Company shall be prepared to demonstrate to the APCD representative, on request, that the linkage is set as shown. If the settings are different, it shall be considered to be a violation of this condition unless the 3M Company can demonstrate compliance with the emission limits of APCD Rule 74.15 by emissions testing pursuant to APCD Rule 74.15.
29. Inkjet Printing And Associated Cleanup
The following requirements apply to the vapor extraction system:
a) The exhaust from the system shall be routed to the Rekusorb carbon adsorption system.b) Permitted emission estimates of ROC from this system are based on an uncontrolled emission rate of 2 lb/hr on an annual average basis and an annual average control efficiency of 93% by weight. If actual exhaust flow rate is not measured, it will be assumed that the exhaust flow rate is equal to the system rated capacity of 400 cfm.
c) The 3M Company shall maintain sample ports in the system piping to the existing solvent laden air (SLA) duct. Sample ports shall be located such that the combined concentration of ROC from all the extraction wells can be determined prior to entrance to the existing SLA duct. Sample ports shall be closed when not in use.
d) The 3M Company shall sample ROC from the system exhaust on a monthly basis, while operating. The frequency of sampling may be adjusted based on review of the required sampling records and determination that a steady state or steadily declining emission condition has been reached. Written approval from the APCD shall be obtained prior to modifying the sampling frequency. Sampling shall be performed using an HNU photoionization meter. The meter shall be calibrated against a benzene standard and shall be zeroed and spanned before each use.
e) The 3M Company shall maintain records of results of exhaust sampling and carbon adsorption system ROC reduction efficiency. ROC reduction efficiency shall be determined on an annual basis. Records shall also be maintained on the exhaust volumetric flow rate from the system if it is measured. Records shall be maintained for a period of two years and shall be made available to APCD personnel on request.
f) On or before October 2 of each year, the 3M Company shall submit to the District the records required by e), above. If actual annual emissions are greater than those assumed in issuing this permit, the District will adjust the permitted emissions, emission offsets, and annual permit renewal fees to reflect the actual emissions from the system.
The specified annual consumption limits and ROC content limits shall not be exceeded for the following materials:
Material Maximum VOC In Grams Per Liter (Lbs/Gal), As Applied Annual Limit
(Gallons)Inks
Cleanup815 (6.80)
815 (6.80)932
4530. Letterpress Printing And Associated Cleanup
In order to demonstrate compliance with this condition, monthly usage records for all inkjet inks, additives, and cleanup materials shall be maintained as required by Condition No. 21. The monthly records shall be summed for the previous 12 months.
Totals for any of these twelve month periods in excess of the specified limits shall be considered a violation of this condition.
The inkjet printing operations are not subject to APCD Rule 74.19, "Graphic Arts". (See Rule 74.19.G.10).
Within ten days after receipt of this permit, the applicant may petition the Hearing Board to review any new or modified condition on the permit (Rule 22).
No materials shall be used in association with letterpress printing or cleanup that contain any ROCs or exempt organic compounds. Based on a Material Safety Data Sheet dated 6/8/95, Specialty Ink Company's 8061F invisible ink contains no ROCs and no exempt organic compounds.
In order to demonstrate compliance with this condition, monthly usage records for all ROC-containing letterpress inks, additives, and cleanup materials shall be maintained as required by Condition No. 21. In addition, for any inks, additives, or cleanup solvents which the permittee claims contain no ROCs, manufacturer's documentation shall be maintained which supports the claim.
This permit, or a copy, shall be posted reasonably close to the subject equipment and shall be readily accessible to inspection personnel (Rule 19). This permit is not transferable from one location to another unless the equipment is specifically listed as being portable (Rule 20).
In reliance upon the statement of the applicant that operation of the equipment described herein shall meet the requirements as specified in the Rules and Regulations of the Air Pollution Control District, permission is hereby granted to operate; provided, however, the permission granted hereby shall not be construed to permit said equipment to operate in violation of any applicable State or Federal emission standard or Rules and Regulations of the District.
For:
Karl E. Krause, Manager
Engineering SectionRichard H. Baldwin
Air Pollution Control Officer