Imation

Pre-Draft Title V Permit - Section III

VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT
Section III General Requirements

General Applicable Requirements

Rule 50, Opacity

Rule 52, Particulate Matter - Concentration

Rule 54.B.1, Sulfur Compounds - SOx at Point of Discharge

Rule 54.B.2, Sulfur Compounds - SOx at or Beyond Property Line

Rule 57.B, Combustion Contaminants - Fuel Burning

Rule 64.B.1, Sulfur Content of Fuels - Gaseous Fuels

Rule 64.B.2, Sulfur Content of Fuels - Solid or Liquid Fuels

Rule 68, Carbon Monoxide

Rule 71.3, Transfer of Reactive Organic Compound Liquids

Rule 74.6, Surface Cleaning and Degreasing

Rule 74.22, Natural Gas-Fired, Fan-Type Central Furnaces

VCAPCD Part 70 Permit No. 0029 - PRE-DRAFT

Ventura County Air Pollution Control District
Rule 50 Applicable Requirements
Opacity

Rule 50, "Opacity"

Federally-Enforceable Version Adopted 5/23/72

Federally-Enforceable OCS Version Adopted 2/20/79

District-Enforceable Version Adopted 2/20/79

Compliance with the conditions listed below will ensure compliance with both versions of this rule. The permit conditions below, therefore, are federally enforceable. The District-enforceable version of this rule will become federally enforceable when approved by EPA as part of the SIP.

Applicability:

This attachment applies to all emissions units at this stationary source.

Conditions:

Pursuant to Rule 50, you shall not discharge into the atmosphere any air contaminants for a period or periods aggregating more than three (3) minutes in any one (1) hour which are as dark or darker in shade as that designated as No. 1 on the Ringelmann Chart, or equivalent to 20% opacity and greater, unless specifically exempted by Rule 50.

You shall perform routine surveillance and visual inspections to ensure that compliance with Rule 50 is being maintained. A record shall be kept of any occurrence of visible emissions other than uncombined water greater than zero percent for a period or periods aggregating more than three (3) minutes in any one (1) hour. These records shall include the date, time, and identity of emissions unit. If the visible emissions problem cannot be corrected within 24 hours, you shall provide verbal notification to the District within the subsequent 24 hours. These visible emissions records shall be maintained at the facility and submitted to the District upon request.

On an annual basis, you shall certify that all emissions units at the facility are complying with Rule 50. This annual compliance certification shall include a formal survey identifying the date, time, emissions unit, and verification that there are no visible emissions other than uncombined water greater than zero percent for a period or periods aggregating more than three (3) minutes in any one (1) hour. As an alternative, the annual compliance certification shall include a formal survey identifying the date, time, emissions unit, and verification that there are no visible emissions for a period or periods aggregating more than three (3) minutes in any one (1) hour which are as dark or darker in shade as that designated as No. 1 on the Ringelmann Chart, or equivalent to 20% opacity and greater, as determined by a person certified in reading smoke using EPA Method 9.

Upon District request, opacity shall be determined during routine surveillance and during the annual compliance certification by a person certified in reading smoke using EPA Method 9 or a certified, calibrated monitoring system.

Ventura County Air Pollution Control District

Rule 52 Applicable Requirements

Particulate Matter - Concentration (Grain Loading)

Rule 52, "Particulate Matter - Concentration (Grain Loading)"

Adopted 5/23/72, Federally-Enforceable

Applicability:

This attachment applies to all external combustion emissions units and internal combustion engines at this stationary source that burn either natural gas or fuel oil. This attachment does not apply to steam generators or gas turbines while combusting liquid or gaseous fuels.

Conditions:

Pursuant to Rule 52, you shall not discharge into the atmosphere from any source particulate matter in excess of the concentration listed in the table shown in Rule 52. For the purpose of Rule 52, particulate matter includes any material which would become particulate matter if cooled to standard conditions.

Periodic monitoring is not necessary to certify compliance with Rule 52. To certify compliance, a reference to the District analysis of Rule 52 compliance based on EPA emission factors is sufficient.

Ventura County Air Pollution Control District
Rule 54 Applicable Requirements
Sulfur Compounds - Sulfur Emissions from
Combustion Operations at Point of Discharge

Rule 54, "Sulfur Compounds"

Federally-Enforceable Version Adopted 7/5/83

District-Enforceable Version Adopted 6/14/94

Rule 64, "Sulfur Content of Fuels"

Federally-Enforceable Version Adopted 7/5/83

Federally-Enforceable OCS Version Adopted 6/14/94

District-Enforceable Version Adopted 6/14/94

Applicability:

This attachment applies to all combustion emissions units at this stationary source that combust gaseous or liquid fuels. This attachment addresses the requirements of Rule 54 for sulfur emissions at the point of discharge. It can be demonstrated that compliance with the fuel sulfur content limits of Rule 64 ensures compliance with the sulfur emission limits of Rule 54.

Conditions:

Pursuant to Rule 54, no person shall discharge sulfur compounds, which would exist as a liquid or gas at standard conditions, in excess of 300 ppm by volume from any combustion operation, calculated as sulfur dioxide (SO2) by volume at the point of discharge.

In order to comply with Rule 54, you shall comply with the fuel sulfur content limits of Rule 64. No additional periodic monitoring requirements for Rule 54 are required beyond the periodic monitoring requirements of Rule 64.

Upon District request, sulfur compounds at the point of discharge shall be determined by source testing using EPA Test Method 6, 6A, 6C, 8, 15, 16A, 16B, or South Coast AQMD Test Method 307-94 (Determination of Sulfur in a Gaseous Matrix), as appropriate.

Ventura County Air Pollution Control District
Rule 54 Applicable Requirements
Sulfur Compounds - Sulfur Dioxide Concentration at Ground Level

Rule 54, "Sulfur Compounds"

Federally-Enforceable Version Adopted 7/5/83

District-Enforceable Version Adopted 6/14/94

Applicability:

This attachment applies to all emissions units at this stationary source that emit sulfur compounds. This attachment addresses the requirements of Rule 54 for sulfur emissions at ground or sea level at or beyond the property line of the stationary source.

Conditions:

Pursuant to Rule 54, no person shall discharge sulfur compounds, which would exist as a liquid or gas at standard conditions, as sulfur dioxide which results in average ground or sea level concentrations at any point at or beyond the property line in excess of 0.25 ppmv averaged over any one hour period, or 0.04 ppmv averaged over any 24 hour period.

You shall maintain a representative fuel analysis or exhaust analysis, along with modeling data or other demonstration to ensure that compliance with Rule 54 is being maintained. This analysis and compliance demonstration shall be provided to the District upon request.

Upon District request, ground or sea level concentrations of SO2 shall be determined by Bay Area Air Quality Management District Manual of Procedures, Volume VI, Section 1, Ground Level Monitoring for Hydrogen Sulfide and Sulfur Dioxide with the following amendments:

a. The wind direction shall be continuously measured and recorded to within 5 degrees of arc, and wind speed shall be continuously measured and recorded to within 0.25 miles per hour (mph) at wind speeds less than 25 mph and with a threshold no greater than 0.2 mph.

b. The meteorological instruments and siting requirements shall comply with the guidelines in "Quality Assurance Handbook for Air Pollution Measurements Systems, Volume IV, Meteorological Measurements," EPA/600/4-90/003.

c. The gas standards shall be re-standardized against the reference wet chemical method at a minimum of once every 12 months, or be standardized using National Institute of Standards and Technology (NIST) standard gases.

Ventura County Air Pollution Control District
Rule 57.B Applicable Requirements
Combustion Contaminants - Specific - Fuel Burning Equipment

Rule 57.B, "Combustion Contaminants - Specific", Fuel Burning Equipment

Federally-Enforceable Version Adopted 8/17/76

Federally-Enforceable OCS Version Adopted 6/14/77

District-Enforceable Version Adopted 6/14/77

Compliance with the conditions listed below for the 6/14/77 version of the rule will ensure compliance with both versions of this rule. The permit conditions below, therefore, are federally enforceable. The District-enforceable version of this rule will become federally enforceable when approved by EPA as part of the SIP.

Applicability:

This attachment applies to all external combustion emission units, internal combustion engines, and gas turbines at this stationary source that burn either natural gas or fuel oil.

Conditions:

Pursuant to Rule 57.B, you shall not discharge into the atmosphere from any fuel burning equipment combustion contaminants exceeding in concentration at the point of discharge, 0.1 grain per cubic foot of gas calculated to 12 percent of carbon dioxide (CO2) at standard conditions.

Combustion contaminants are defined as particulate matter discharged into the atmosphere from the burning of any kind of material containing carbon in a free or combined state.

Periodic monitoring is not necessary to certify compliance with Rule 57.B. To certify compliance, a reference to the District analysis based on EPA emission factors and a representative source test is sufficient.

Ventura County Air Pollution Control District
Rule 64 Applicable Requirements
Sulfur Content of Fuels - Gaseous Fuel Requirements

Rule 64, "Sulfur Content of Fuels"

Federally-Enforceable Version Adopted 7/5/83

Federally-Enforceable OCS Version Adopted 6/14/94

District-Enforceable Version Adopted 6/14/94

Applicability:

This attachment applies to all combustion emissions units at this stationary source while the emissions units are combusting gaseous fuel.

Conditions:

Pursuant to Rule 64, no person shall burn at any time gaseous fuel containing sulfur compounds in excess of 50 grains per 100 cubic feet of gaseous fuel (788 ppmv), except for natural gas which is limited to 15 grains per 100 cubic feet (236 ppmv), calculated as hydrogen sulfide at standard conditions, unless specifically exempted by Rule 64. Natural gas is a gaseous fuel purchased or transported under a Federal Energy Regulatory Commission or a California Public Utility Commission (PUC) jurisdictional tariff.

If only PUC-quality natural gas, propane, or butane are combusted at this facility, it will be assumed that you are complying with Rule 64 without additional periodic monitoring requirements.

If other than PUC-quality natural gas is being combusted, you shall analyze the sulfur content of the fuel on an annual basis using South Coast AQMD Method 307-94 - Determination of Sulfur in a Gaseous Matrix. This annual fuel analysis shall be maintained at the facility and shall be provided to the District with the annual compliance certification.

Ventura County Air Pollution Control District
Rule 64 Applicable Requirements
Sulfur Content of Fuels - Solid or Liquid Fuel Requirements

Rule 64, "Sulfur Content of Fuels"

Federally-Enforceable Version Adopted 7/5/83

Federally-Enforceable OCS Version Adopted 6/14/94

District-Enforceable Version Adopted 6/14/94

Applicability:

This attachment applies to all combustion emissions units at this stationary source while the emissions units are combusting solid or liquid fuel. This attachment does not apply to any combustion emission unit with sulfur emission controls.

Conditions:

Pursuant to Rule 64, no person shall burn any solid or liquid fuels with a sulfur content in excess of 0.5 percent, by weight, unless specifically exempted by Rule 64.

For each solid or liquid fuel delivery, you shall either obtain the fuel supplier's certification, or shall test the sulfur content of the fuel using ASTM Method D4294-83 or D2622-87, to ensure that compliance with Rule 64 is being maintained. The fuel sulfur content by weight data shall be maintained at the facility and shall be provided with the annual compliance certification.

Ventura County Air Pollution Control District
Rule 68 Applicable Requirements
Carbon Monoxide

Rule 68, "Carbon Monoxide"

Federally-Enforceable Version Adopted 5/23/72