Imation
Pre-Draft Title V Permit - Section I
VCAPCD Part 70 Permit No. 0029
- PRE-DRAFT
Section I
A. Stationary Source Description
Since its opening in 1963, Imation Camarillo
(formerly 3M) has manufactured magnetic recording products. Currently,
this facility manufactures only magnetic data storage tape, with three
standard product lines. The products are:
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- Mini cartridges/3.5 inch
cartridges - stores up to 2 Gbytes of information;
- Travan cartridges/TR1 through TR4 - stores up to 8 Gbytes of information;
- Data cartridges/5.25 inch cartridges - stores up to 26 Gbytes of information.
The processes used in the manufacture of magnetic data storage tape include kneading, milling, filtration, coating the magnetic media dispersion onto a plastic web, magnetic particle orientation, drying the coated web, surface treating, slitting, data cartridge assembly, labeling, packaging, quality control, and warehousing. The less obvious of these manufacturing processes are briefly described below.
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Kneading - metal pigments
are loaded dry into a kneader and wetting agents are added incrementally.
Small agglomerates form and eventually coalesce into larger agglomerates.
This becomes a premix to which a binder and other additives are introduced.
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Milling - metal/ceramic beads,
cylinders, or another randomly shaped dispersing media are placed
in a container with the magnetic dispersion. Physical action in the
container disperses the metal pigments within the magnetic dispersion
so they can be surrounded by the binder and other additives. The size
of the metal/ceramic dispersing media ranges from a couple of millimeters
in diameter to slightly less than one millimeter. The milling time
may last from a few hours to several days.
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Filtration - lumps, aggregates,
and agglomerates can not be tolerated in the magnetic media dispersion
and are therefore filtered out. Filters are made with synthetic yarns
which are graded in size as well as closeness in structure.
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Coating - after the kneading,
milling, and filtering processes the magnetic dispersion is fed to
a coater which applies the magnetic media dispersion onto a plastic
web. The coating machinery functions as a giant tape transport system
that feeds a cleaned and stress-relieved plastic web at a constant
speed to a station where the wet magnetic media dispersion is applied.
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Magnetic Particle Orientation
- immediately after coating and while the web is still wet it undergoes
orientation in a magnetic field, whereby the magnetic particles are
aligned.
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Drying - after coating and
magnetic particle orientation, the tape enters a drying oven where
all the solvents are evaporated and removed with the aid of heat and
airflow. The drying oven is divided into multiple zones.
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Slitting - the coated film
is cut to the proper width and length for use in finished cartridges.
The slitting operation results in reels of tape, commonly called pancakes.
This facility uses four coater/oven lines to apply the solvent based magnetic media dispersion onto the plastic web. The solvent is evaporated from the web by heat in the oven portion of the coating/oven line. These solvents, or ROCs, and ventilation air from certain other magnetic data storage tape manufacturing equipment and rooms are ducted to Imation's solvent recovery unit (SRU). The ventilation air ducted to the SRU includes the plant's charging, milling, and tunnel rooms. Some of the data storage tape manufacturing equipment ducted or hard-piped to the SRU are mixing kettle lip exhaust, conservation vents (on spent/inventoried magnetic media dispersion tanks, mix and feed tanks, and raw material tanks), distillation columns, and the two recycling processes described below under support operations.
To control ROC emissions, the SRU uses carbon adsorption and nitrogen desorption. The SRU is comprised of two separate and essentially identical systems which are referred to as plant A and plant B. Plants A and B each have two carbon adsorption vessels which are numbered A1 and A2, and B1 and B2, respectively. During typical operations, one carbon vessel from each SRU plant is being used for adsorption and one carbon vessel is desorbing (or has completed the desorbing process and is in standby mode). An SRU carbon vessel can adsorb with hourly efficiencies in excess of 95% for upwards of 25 hours. The desorbed solvents are subsequently distilled into their individual components and then recycled back to manufacturing for reuse.
Particulate generated at any workstation located within a total enclosure, including particulate from handling of powdered raw materials, is captured and routed for control to a baghouse. To maintain the integrity of the total enclosure, the exhaust of the baghouse is routed to the SRU for control of any VOC and HAPs.
Various support operations are ongoing at the plant. These include:
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Steam generation using two
gas-fired boilers equipped with low NOx burners and flue gas recirculation.
These boilers provide process heating, restroom and cafeteria hot
water, and space heating.
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Above-ground storage of raw
material solvents, in-process solvents, recycled solvents, and spent
and inventoried magnetic media dispersion in 3,000 gallon tanks and
5,000 gallon tanks.
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55 gallon drum and other warehouse/raw
material storage.
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Recovery/recycling of spent
magnetic media dispersion in two separate operations. In the first
operation, solvents are removed from spent dispersion via a rotary
dryer. In the second operation, steam coils are used to heat waste
filters and other solid waste recovering the solvents; this is basically
a batch distillation process. Condensed solvents from both of these
operations are hard-piped to a common mix tank within the distillation
process.
B. Permitted Equipment and Applicable Requirements Table
1. Purpose
The purpose of this table is to list the emission units at this stationary source that are permitted to operate. The table also provides a list of requirements that are specifically applicable to these emission units. Permit conditions that enforce these requirements are listed in Section II, "Permitted Emissions, Specific Applicable Requirements, and Other Permit Conditions," of this permit.
In addition to the emission unit specific requirements in Section II, there are additional general requirements that may apply to the emission units listed in this table, or to the stationary source as a whole. Furthermore, some general requirements may apply to emission units or short-term activities not required to be specifically listed on the permit. These general requirements are contained in the following sections of the permit: Section III, "General Applicable Requirements;" and Section V, "General Permit Conditions."
2. Equipment Description
This portion of the table provides a brief description of the permitted equipment at this stationary source. Attached to the table is an "Equipment List Description Key" that contains definitions and explanations for some of the terminology used in the equipment description.
3. Applicable Requirements
The applicable requirements portion of the table is a matrix of applicability for the specific requirements that apply to the listed emission units. The columns are labeled with APCD rule numbers or references to federal requirements. An "X" in the row corresponding to the emission unit indicates the requirement is specifically applicable to that unit. For cases where a rule has multiple compliance options, a number appears instead of an "X." The number is a code key that corresponds to the "Title V Applicable Requirement Code Key" attached to the table. The code key table contains specific citations for the portions of the rule that are applicable.
40 CFR Part 63, Subpart EE (Magnetic Tape Manufacturing Operations MACT) is listed in the table as a future specific applicable requirement. This standard does not currently apply to the source, but the standard will become applicable once the source relinquishes the HAP limits described in Section II.A of this permit. The requirements associated with Subpart EE are included in the "Title V Applicable Requirement Code Key," and were included as part of the streamlining analysis described in Section II.B. Pursuant to the results of the streamlining analysis, the requirements of Subpart EE are written into this permit as specific, enforceable conditions.
VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT
Permit to Operate No. 0029 Permitted Equipment and Applicable Requirements |
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74.6.1 |
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Coating
Dispersion Application/Drying Equipment used for Magnetic Tape Production Enclosed magnetic tape coating/curing line (Coater 41) Enclosed magnetic tape coating/curing line (Coater 42) Enclosed magnetic tape coating/curing line (Coater 43) Enclosed magnetic tape coating/curing line (Coater 44) Coating Dispersion Compounding Equipment Mills, kettles, homogenizers, filters, pumps, and associated equip. Other Related Equipment Coating dispersion storage tanks (each < 5,000 gallons) Cold solvent wash tank Wet scrap dryer, Solidaire SJS 24-14 Wash sinks Sparge bins ROC Control/Recovery System Rekusorb carbon adsorption/nitrogen desorption solvent recovery unit (SRU) Solvent recovery storage tanks (each < 5,000 gallons) Solvent distillation column Flame ionization analyzers FTIR-CEMS Flowmeter CEMS Baghouse Baghouse for control of particulate generated at workstations within the total enclosures. Boilers 1 - 39.3 MMBTU/Hr boiler (NS-C-44); Low NOx (WB-1-20-FGR) 1 - 28.6 MMBTU/Hr boiler (M64-C-13); Low NOx (WB-1-20-FGR) |
1 2 2 X |
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2 2 2 2 2,4 1,4 2,4 1,4 2,4 1,4 X 1,4 1,4 X VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT |
TITLE V EQUIPMENT LIST DESCRIPTION KEY
1. Coating Dispersion Application/Drying Equipment used for Magnetic Tape Production:
- 4 enclosed magnetic tape coating/curing lines (designated as 41, 42, 43, and 44);
- Each magnetic tape coating/curing line enclosure consists of a coater room and a drying/curing oven which exhausts to the ROC control/recovery system;
- All of the coating lines are contained within a total enclosure that has no natural draft openings.
2. Coating Dispersion Compounding Equipment, consisting of:
- Sand mills, shaker mills, mixing kettles, resin kettles, homogenizers, and associated pumps and equipment;
- All direct exhausts for each of the mixing kettles, such as conservation vents (pressure/vacuum release valves) and lip exhausts, are routed to the ROC control/recovery system;
- The compounding room is equipped with room vents which are routed to the coater oven supply duct, which in turn leads to the ROC control/recovery system.
3. Other Related Equipment, including:
- Coating dispersion storage tanks, all less than or equal to 5,000 gallons capacity;
- Each storage tank containing ROC is equipped with a conservation vent (pressure/vacuum relief valve) which exhausts to the ROC control/recovery system;
- cold solvent wash tanks;
- wet scrap dryer, Solidaire SJS 24-14; this is part of the recycling operation which recovers solvents from spent dispersion via a rotary dryer. Condensed solvents from this operation are hard-piped to a common mix tank within the distillation process.
- wash sinks
- sparge bins; this is part of the recycling operation which recovers solvents from waste filters and other solid waste via batch distillation. Condensed solvents from this operation are hard-piped to a common mix tank within the distillation process.
4. ROC (Reactive Organic Compound) Control/Recovery System, consisting of:
- Rekusorb carbon adsorption/nitrogen desorption/solvent recovery system (SRU), 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;
- Above ground storage tanks of less than or equal to 5,000 gallons, used for storage of virgin, in-process, recycled, and spent solvents, the storage of spent and inventoried magnetic media dispersion, and the storage of diesel fuel. With the exception of tanks used to store diesel fuel, all of the above ground storage tanks have a closed vent system that exhausts to the ROC control/recovery system and/or have nitrogen blankets;
- Distillation columns, which exhaust to the ROC control/recovery system;
- A continuous emissions monitoring system, used to monitor the efficiency of the carbon adsorption system by monitoring the concentration (in ppmv) of total hydrocarbons at the following locations:
- the solvent laden air duct
- the exhaust stack for carbon adsorption vessels A1 and A2;
- the exhaust stack for carbon adsorption vessels B1 and B2; and
- the common exhaust stack for the four carbon adsorption vessels;
- total hydrocarbon analyzer monitors concentrations at the solvcnt laden air duct, while another monitors concentrations at the carbon adsorption exhaust stacks;
- A continuous emission monitoring system using extractive fourier transform infrared spectrometry (FTIR-CEMS), used to speciate and quantify ROC at the common exhaust stack for the four carbon adsorption vessels;
- A flowmeter continuous monitoring system, used in conjunction with the FTIR-CEMS for ROC quantification at the common exhaust stack for the four carbon adsorption vessels;
- Emissions which are routed to the ROC control/recovery system are typically routed from the applicable local exhaust system to either a 36" duct or a 60" duct, with these two ducts combining to form the "solvent laden air duct" which leads to the ROC control/recovery system;
- The 36" duct generally handles emissions from the following sources:
- The solvent drum hook-up vents, overhead cold solvent wash tank vents, and the tunnel room exhaust;
- Conservation vents from various tanks;
- Conservation vents from compounding room mixing kettles; and
- The solvent recovery storage tank farm and distillation column vents associated with the solvent recovery system;
- The 60" duct generally handles emissions from the four coating/oven line enclosure exhausts;
- Emissions are indirectly routed to the 60" duct from the following sources (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):
- The tunnel room exhausts; and
- Compounding room mixing kettle lip exhausts;
- Emissions are routed directly to the solvent laden air duct from the vapor extraction wells.
5. 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-1-20-FGR, 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.
40 CFR Part 60 Subpart SSS, "Standards of Performance for Magnetic Tape Coating Facilities"
(53 FR 38914, Oct. 3, 1988)
1. You shall ventilate all VOC emissions from the total enclosure to the control device and maintain control device efficiency at or above 95 percent, based on a three-day rolling average, computed daily. (60.712(b)(2)(i))
2. You shall control emissions from the coating mix preparation equipment by installing and using covers that meet the specifications below and venting VOC emissions from the equipment to a VOC control device: (60.712(d)(1))
·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;
·Cover shall extend at least 2 cm beyond the outer rim of the opening or shall be attached to the rim;
·Cover shall be of such design and construction that contact is maintained between cover and rim along the entire perimeter;
·Any breach in the cover (such as an opening for insertion of a mixer shaft or port for addition of ingredients) shall be covered consistent with ( c) (2) and (3) of 60.712 when not actively in use. An opening sufficient to allow safe clearance for a mixer shaft is acceptable during those periods when the shaft is in place; and
·A polyethylene or nonpermanent cover may be used provided it meets the requirements of ( c) (2), (3), and (4) of 60.712. Such a cover shall not be reused after once being removed.
Rule 74.3, "Paper, Fabric, and Film Coating Operations"
(District: 12/10/91 SIP: 12/10/91)
1. You shall reduce reactive organic compound (ROC) emissions from the coating application process by a combined capture and destruction efficiency of no less than 90 percent, averaged over a rolling 24 hour period. Destruction efficiency shall be measured across an emission control device.
If the coating applied contains more than 1200 grams ROC per liter of coating applied, less water and less exempt solvent, then, in addition to the above, emissions shall be limited to 120 grams of ROC per liter of coating applied, less water and less exempt solvent, using a rolling 24 hour average. (74.3.B.1.c)
2. Containers and mixing equipment not controlled pursuant to 74.3.B.1.b or 74.3.B.1.c and containing reactive organic compound material shall not leak and shall be covered when in use. Covers shall not be required when adding or removing material or during cleaning operations. (74.3.B.2)
Rule 74.6.1, "Cold Cleaners"
(District: 7/9/96 SIP Submittal: 10/96)
1. All cold cleaners, except remote reservoir cold cleaners, shall be equipped with the following devices: (74.6.1.B.1)
a. A drying rack suspended above the solvent, or other facility for draining cleaned parts such that the drained solvent is returned to the cleaner.
b. A cover which prevents the solvent from evaporating when not processing work in the degreaser. The cover must be designed so that it can be easily operated with one hand.
c. A freeboard height of at least 6 inches (15.2 centimeters), if low volatility solvent is used.
d. At least one of the following control devices, if high volatility solvent is used:
i) A freeboard such that the freeboard ratio is at least 0.75.
ii) A water cover if the solvent is insoluble in and heavier than water.
iii) An emission collection system vented to a control device. The overall efficiency of the emission control system (product of the capture efficiency and the control efficiency) shall be at least 85 percent.
e. A permanent conspicuous mark locating the maximum allowable solvent level which conforms with the applicable freeboard requirement.
f. A permanent conspicuous label or sign summarizing the applicable operating requirements appropriate for cold cleaning operations.
Rule 74.15, "Boilers, Steam Generators and Process Heaters"
(District: 11/8/94 SIP: 11/8/94)
1. You shall not allow the discharge into the atmosphere oxides of nitrogen emissions in excess of 40 parts per million volume. Carbon monoxide emissions from units subject to this rule shall not exceed 400 ppmv. (74.15.B.1)
40 CFR Part 63 Subpart EE, "National Emission Standards for Magnetic Tape Manufacturing Operations"
(59 FR 64596, Dec. 15, 1994)
1. You shall limit gaseous HAP emitted from each solvent storage tank, piece of mix preparation equipment, coating operation, waste handling device, and condenser vent in solvent recovery by an overall HAP control efficiency of at least 95 percent. (63.703(c)(1))
2. You may meet the requirements of 63.703(c)(1) by venting the room, building, or enclosure in which the HAP emission point is located to an add-on air pollution control device, as long as this method meets an overall HAP control efficiency of at least 95 percent. (63.703(c)(3))
3. You shall use an enclosed transfer method to perform particulate HAP transfer. (63.703(d)(1)) OR You shall direct emissions from particulate HAP transfer through a hood or enclosure to a baghouse or fabric filter that exhibits no visible emissions while controlling HAP emissions from particulate HAP transfer. (63.703(d)(2))
4. For any solvent storage tank, piece of mix preparation equipment, waste handling device, condenser vent in solvent recovery, wash sink for cleaning removable parts, and set of equipment for flushing of fixed lines, you may, instead of meeting the requirements of 63.703 (c)(1), (e)(1)(i), or (f)(1)(i), vent the gaseous HAP emissions to an add-on air pollution control device other than an incinerator that, in conjunction with capture equipment or ductwork, is designed to achieve an overall HAP control efficiency of at least 95 percent for the emissions from the coating operation, and achieve an alternate outlet concentration limit when coating operations are not occurring. (63.703(i))
C. Exempt Equipment List
Under the District's Title V Federal Operating Permit Program, insignificant activities have been defined to be equivalent to the operations, equipment, or emissions units that are exempt from permit as detailed in APCD Rule 23, "Exemptions From Permit." APCD Rule 33.2.A.11 (Part 70 Permits - Application Contents) requires the applicant to provide a list of all emissions units located at the stationary source that are exempt pursuant to APCD Rule 23 based on size or production rate.
This section of the permit contains a table entitled, "Insignificant Activities (Exempt Equipment)." This table is a list of insignificant activities (exempt equipment) at the facility that are exempt from permit based on a size or production rate exemption in APCD Rule 23, "Exemptions From Permit."
This table is presented for informational purposes only. Any changes to this list are not considered to be permit modifications, nor is the list considered to be enforceable. As detailed in APCD Rule 33.2.A.11, this list is required to be submitted with an application for initial permit issuance or reissuance. The general requirements listed in Sections III and V of this permit may apply to these insignificant activities.
INSIGNIFICANT ACTIVITIES (EXEMPT EQUIPMENT) |
List all insignificant activities (exempt equipment) which are exempted because of size or production rate.
INSIGNIFICANT
ACTIVITIES (EXEMPT EMISSION UNITS) |
BASIS FOR EXEMPTION (Size/Rate) |
RULE 23 CITATION |
Abrasive blast cabinet-dust filter integral combination units with blast section internal volume < 50 cubic feet (glass bead glove box) | Equipment size | 23.B.7 |
Emergency internal combustion engines operated either during an emergency or during maintenance of the engine. Engine maintenance operation is limited to 50 hours per calendar year per engine (portable emergency generators; portable emergency air compressor) | Production rate | 23.D.7 |
Equipment for loading of reactive organic compound liquid into transportable containers of 100 gallons or less (misc. solvents). | Equipment size | 23.F.3 |