Statement of Basis. Daikin America, Inc. Morgan County Decatur, Alabama

Transcription

1 Statement of Basis Daikin America, Inc. Morgan County Decatur, Alabama Daikin America, Inc. ( Daikin ) has applied for renewal of Major Source Operating Permit No This proposed Title V Major Source Operating Permit is issued under the provisions of ADEM Admin. Code r The above named applicant has requested authorization to perform the work or operate the facility shown on the application and drawings, plans, and other documents attached hereto or on file with the Air Division of the Alabama Department of Environmental Management, in accordance with the terms and conditions of the permit. Background This facility is a chemical production plant which produces fluoropolymers. The facility is allowed to operate 8,760 hours per year unless otherwise specified. Based on the Title V permit application, this facility is a major source for particulate matter (PM) and volatile organic compounds (). Changes from existing permit: 1. Revised emission calculations were submitted by for the facility. The emissions from the adjacent facility, MDA Manufacturing, Inc. were included in Daikin s plant wide emission totals. 2. Updated Title V Permit to include source specific requirements of 40 CFR Part 63, Subpart DDDDDD for all applicable equipment. 3. Administratively changed unit title from Methanol tank to TFE Unit Tanks. 4. Administratively added storage tank M2-V561 to TFE Unit Tanks. 5. Administratively added C7-V301 to OIME Tanks. 6. Administratively incorporated air Permit No X023 for ETFE/FEP/EFEP Unit with Scrubber (N2-15) and Back-Up (N2-15B). 7. Administratively added the product TV Polymer to the ETFE/FEP/EFEP Unit.

2 8. Updated Title V Permit to include additional continuous compliance testing requirements of ADEM Admin. Code r ( CISWI ). 9. Administratively changed the compliance indicator for all particulate matter (PM) emission points of the ETFE/FEP/EFEP/TV and ETFE Batch units from daily visual observations to weekly. 10. Administratively deleted emission points N2-7 and N2-12. The emission points vent inside buildings and/or are not vented to the atmosphere. 11. Administratively deleted emission point N1-8. The emission point was a duplicate and is encompassed in the ETFE Batch unit. 12. Administratively deleted emission point N2-15B. The emission point N2-15 is routed to a scrubber for control. The scrubber associated with this emission point has a back-up. The scrubber can only operate in parallel. Therefore, emission point N2-15 encompasses the scrubber and back-up. Each of the individual production units is described below: TFE Unit The unit utilizes two natural gas fired 5.75 MMBtu/hr process furnaces (M1-1 and M1-9) which share a common stack and an 11.2 MMBtu/hr process furnace. The HCL storage tank (M1-2) and distillation columns (M1-3 through M1-8) are required to be routed to the T-Thermal oxidizer for control of, HAP, and CFC. The neutralization pit associated with the waste acid control system is routed to scrubber C1-T101 (J1-6) for control of. This unit is subject to minor PSD limitations for PM, NOx,, HAP, and CFC. Emission Standards The state opacity requirement is applicable to the process furnaces associated with this unit and the T-Thermal incinerator. Particulate The furnaces are subject to the state allowable particulate limit for fuel burning equipment. Based on 5.75 lb/mmbtu fuel input, the PM emissions from the furnaces, which share a common stack are required to be limited to 0.64 lb/mmbtu for each furnace. The PM emissions from the 11.2 MMBtu/hr process furnace are required to be limited to 0.48 lb/mmbtu.

3 NOx In order to maintain synthetic minor status with respect to PSD and Title V, the furnaces (M1-1 and M1-9) are required to limit the NOx emissions to 0.48 lb/hr for each unit. SO2 The furnaces are subject to the state allowable SO2 limit for fuel burning equipment. The furnaces are required to emit less than 4 lb/mmbtu for each unit. The emissions from the distillation columns (M1-3 through M1-8) are required to be routed to the T-Thermal incinerator in order to achieve a 99.99% destruction removal efficiency (DRE) of. The facility is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV for fugitive emissions in this unit. The scrubber, C1-T101 (J1-6), is associated with an adjacent facility, MDA Manufacturing (MDA). The unit is required to route all emissions from the neutralization pit to the scrubber and maintain emissions from J1-6 to less than 0.42 lb/hr. HAP The emissions from the HCL storage tank (M1-2) are required to be routed to the T- Thermal incinerator in order to achieve a 99.99% DRE of HAP. CFC The emissions from the distillation columns (M1-3 through M1-8) are required to be routed to the T-Thermal incinerator in order to achieve a 99.99% DRE of CFC. /Particulate Since the furnaces are permitted to fire natural gas only, the units would meet the opacity and particulate limits inherently. Therefore, no periodic monitoring is required. NOx Since the furnaces NOx limits are based on good combustion practices, the facility is required to conduct annual inspections of the burner and implement a standard operating procedure.

4 SO2 Since the furnaces are permitted to fire natural gas only; the units would meet the SO2 limits inherently. Therefore, no periodic monitoring is required. The unit would be required to maintain the records equivalent to those listed in the requirements of 40 CFR Part 60, Subpart VV. The monitoring requirements for the T- Thermal incinerator are discussed under the T-Thermal incinerator unit section. HAP/CFC The monitoring requirements for the T-Thermal incinerator are discussed under the T- Thermal incinerator unit section. TFE Storage Tanks The TFE unit utilizes 2 tanks (M1-V501 and M2-V561) which store /HAP. The tanks are subject to synthetic minor PSD limitations for and HAP. Emission Standards /HAP In order to remain synthetic minor for PSD, the tanks are required to be equipped with a conservation vent. The tanks are stored at temperatures which would result in a vapor pressure below the thresholds for ADEM Admin. Code r ( loading). In order to remain below this level, Daikin would be required to calculate and maintain the vapor pressure below 1.5 psia. /HAP The vapor pressure of the material stored in the tank is required to be calculated and maintained for the life of the tanks.

5 PTFE-FD Unit The PTFE-FD unit emission points include a polymerization reactor and product dryer. The product dryer is required to be routed to a packed bed scrubber for control. The unit is subject to synthetic minor PSD limitations for. Emission Standards The state opacity requirement is applicable to the product dryer associated with this unit. Particulate The dryer is subject to the state process weight curve. Based on the process weight the particulate limit for the polymerization reactor is 3.0 lb/hr. In order to remain synthetic minor with respect to PSD and Title V for, the polymerization reactors (PTFE-FD-1A-G) are limited to lb /lb of PTFE at polymerization and 4.2 tpy total. Additionally, the unit is required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV. /Particulate As an indicator of compliance with the PM and opacity limits associated with this unit, the facility is required to conduct daily visual observations of the packed bed scrubber (PTFE- FD-2). If emissions greater than normal are noted, the facility must take corrective action within 2 hours. To ensure that the polymerization reactors are in compliance with the limits, the facility is required to maintain a vacuum ( 1 psig) during final polymerization reactor recovery. Additionally, the unit would be required to comply with the monitoring requirements for an LDAR program equivalent to 40 CFR Part 60, Subpart VV.

6 PTFE-M Unit The PTFE-M unit emission points include a polymerization reactor and product dryer. The product dryer is required to be routed to a packed bed scrubber for control. The unit is subject to synthetic minor PSD limitations for PM and. Emission Standards The state opacity requirement would be applicable to the product dryer associated with this unit. Particulate The dryer would be subject to the state process weight curve; however, in order to remain a synthetic minor source with respect to PSD, the facility has taken a more restrictive PM limit of 1.0 lb/hr. In order to remain a synthetic minor source with respect to PSD and Title V for, the polymerization reactors (PTFE-M-1) are limited 3.8 lb/hr. Additionally, the unit is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV. /Particulate As an indicator of compliance with the PM and opacity limits associated with this unit, the facility is required to conduct daily visual observations of the packed bed scrubber. To ensure that the polymerization reactors are in compliance with the limits, the facility is required to maintain a vacuum ( 1 psig) during final polymerization reactor recovery (i.e. not open to the atmosphere). Additionally, the unit would be required to comply with the monitoring requirements for an LDAR program equivalent to 40 CFR Part 60, Subpart VV. ETFE/FEP/EFEP/TV Unit The ETFE/FEP/EFEP/TV unit consists of several pieces of particulate handling process equipment. The particulate emission points associated with this unit include N1-2, N1-4,

7 N1-5, N1-6, N1-9/N1-9B, N1-10A, B, and C, N1-11, N1-12/N1-12B, N1-16, N1-17, N1-18, N1-19/N1-19B/N1-19C, N1-23, and N1-25/N1-25B. The unit also consists of several emission points. The emission points associated with this unit include N1-4, N1-14/N1-14B, N1-20, N1-21, AND N1-22. The unit is subject to synthetic minor PSD limitations for PM and. Emission Standards The state opacity requirement would be applicable to emission points with the potential to emit particulate matter (N1-2, N1-4, N1-5, N1-6, N1-9/N1-9B, N1-10A, B, and C, N1-11, N1-12/N1-12B, N1-16, N1-17, N1-18, N1-19/N1-19B/N1-19C, N1-23, and N1-25/N1-25B) in this unit. Particulate All particulate matter emission points are subject to the state process weight curve; however, in order to avoid PSD review, the facility has committed to more stringent PM limits on each particulate point. The limits for each emission point are listed in the table below. Emission Point PM limit (lb/hr) N N N N N N1-9B 0.06 N1-10A, B, C 0.05 N N1-12/N1-12B 0.15 N N N N N1-19B/C 0.08 N N1-25/N1-25B 0.46

8 In order to remain synthetic minor for, the emission point N1-4 has a emission limit of 2.0 lb/hr. The emission points N1-14, N1-14B, N1-20, N1-21, and N1-22 are required to be vented to the T-Thermal incinerator to ensure a 99.99% DRE for and CFC. The unit is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VV. /Particulate The facility was previously required to conduct daily visual observations for the following PM emission points: N1-4, N1-5, N1-6, N1-9, N1-9B, N1-10A, B, C, N1-11, N1-12, N1-12B, N1-16, N1-17, N1-18, N1-19, N1-19B/C, N1-23, N1-25, and N1-25B. The facility has proposed to conduct weekly visual observations for each emission point listed above. Based on the unit s operation and past visual inspections, the Department has determined that weekly visual inspection for these emission points would be appropriate. Additionally, weekly visual observations are also required for emission points N1-2 and N1-23. Therefore, weekly visual observations are required for all emission points within the ETFE/EFEP/FEP/TV unit. The T-Thermal monitoring requirements are discussed under the T-Thermal incinerator unit section below. The unit would be required to maintain the monitoring, recordkeeping, and reporting requirements equivalent to 40 CFR Part 60, Subpart VV. ABCO Boilers The two ABCO boilers are 35.7 MMBtu/hr natural gas fired boilers with No. 2 fuel oil backup utilized to provide process heat. The boilers are equipped with low NOx burners. The unit is subject to synthetic minor PSD limitations for PM, SO2, and NOx. When firing No. 2 fuel oil, the boiler would be subject to 40 CFR Part 63, Subpart JJJJJJ. The boilers would be classified as existing oil fired units. Since the boilers would be classified as existing with respect to Subpart JJJJJJ, no emission limits would be applicable to the boilers while firing No. 2 fuel oil. The facility would be required to conduct an initial tune-up and biennial tune-ups of the boilers.

9 The boilers are subject to the requirements of 40 CFR Part 60, Subpart Dc. The boilers are limited to discharge with an opacity no greater than 20% (6-minute average), except for one 6-minute period per hour of not more than 27% opacity. The state opacity requirement would be applicable to the boilers; however, the Subpart Dc requirement is more stringent. Particulate The boilers are subject to the state requirement for particulate matter from indirect heating equipment. Based on the equation, the allowable particulate from the boilers are 0.29 lb/mmbtu each. Since the boilers are permitted to burn No. 2 fuel oil, the facility has committed to an ash limit in the No. 2 fuel oil of less than 0.1% by weight in order to remain synthetic minor with respect to PSD. NOx In order to remain synthetic minor with respect to PSD and Title V for NOx, the boilers are limited to 8.5 lb/hr total while firing No. 2 fuel oil. Additionally, the boilers are limited to 3,819,798 gal/yr of fuel oil. SO2 The boilers are subject to the state requirement for sulfur emissions from fuel burning sources. The boilers would be limited to 4 lb/mmbtu each. Subpart Dc requires the facility to utilize fuel oil in these units with a sulfur content less than 0.5 % by weight; however, the boilers have a more stringent limit for sulfur content in the fuel of less than 0.1% by weight in order to remain a synthetic minor source with respect to Title V and PSD for SO2. /Particulate The ash content of the No. 2 fuel oil fired in this unit is maintained and recorded. When firing No. 2 fuel oil, visual observations of the boiler stacks would be performed. NOx As an indicator of compliance with the NOx limitations, the facility has implemented standard operating procedures, maintenance procedures, and performs inspections of the low NOx burners within 15 months of the last completed inspections. As an indicator of compliance with the NOx limits when firing No. 2 fuel oil, the records of the amount of fuel fired in the units are maintained.

10 SO2 As an indicator of compliance with the SO2 limits when firing No. 2 fuel oil, the sulfur content of the fuel oil fired in the units is maintained. Nebraska Boilers The Nebraska boiler is a 73.8 MMBtu/hr natural gas fired boiler with No. 2 Fuel oil back up utilized to provide process heat. The unit is subject to synthetic minor PSD limitations for NOx and SO2. When firing No. 2 fuel oil, the boiler would be subject to 40 CFR Part 63, Subpart JJJJJJ. The boiler would be classified as an existing oil fired unit. Since the boiler would be classified as existing with respect to Subpart JJJJJJ, no emission limits would be applicable to the boiler while firing No. 2 fuel oil. The facility would be required to conduct an initial tune-up and biennial tune-ups of the boiler. The boiler is subject to the requirements of 40 CFR Part 60, Subpart Dc. The boiler is limited to discharge with an opacity no greater than 20% (6-minute average), except for one 6-minute period per hour of not more than 27% opacity. The state opacity requirement would be applicable to the boiler; however, the Subpart Dc requirement is more stringent. Particulate The boiler is subject to the state requirement for particulate matter from indirect heating equipment. Based on the equation, the allowable particulate from the boiler would be 0.21 lb/mmbtu. Since the boiler is permitted to burn No. 2 fuel oil, the facility has committed to an ash limit in the No. 2 fuel oil of less than 0.1% by weight in order to remain synthetic minor with respect to PSD. NOx In order to remain synthetic minor with respect to PSD and Title V for NOx, the boilers are limited to firing 2,687,068 gal/yr. SO2 The boiler is subject to the state requirement for sulfur emissions from fuel burning sources. The boiler would be limited to 4 lb/mmbtu.

11 Subpart Dc requires the facility to utilize fuel oil in this unit with a sulfur content less than 0.5 % by weight; however, the boiler has a more stringent limit for sulfur content in the fuel of less than 0.1% by weight in order to remain a synthetic minor source with respect to Title V and PSD for SO2. /Particulate The ash content of the No. 2 fuel oil fired in this unit is maintained and recorded. When burning No. 2 fuel oil, visual observations of the boiler stacks would be performed. NOx As an indicator of compliance with the NOx limits when firing No. 2 fuel oil, the records of the amount of fuel fired in the unit are maintained. SO2 As an indicator of compliance with the SO2 limits when firing No. 2 fuel oil, the sulfur content of the fuel oil fired in the unit is maintained. OIME Storage Tanks The utilities area within the facility utilizes 2 storage tanks (C2-V004 and C7-V301) which store OIME (). C2-V004 is subject to BACT limitations for. C7-V301 is subject to synthetic minor PSD limitations for. Emission Standards Storage tank C2-V004 is required to be vented to a water seal pot as determined by BACT. The content of the water is limited to 10% by weight. In order to remain synthetic minor with respect to PSD for, storage tank C7-V301 is required to be equipped with a conservation vent. Emission Monitoring

12 The facility is required to conduct monthly monitoring of the water in the water seal pot of tank C2-V004 for a phase split to ensure the content of the water does not exceed 10%. Additionally, the facility is required to conduct daily monitoring of the seal pot to ensure that the water level is above the discharge of the vent pipe. The tank C7-V301 is equipped with a conservation vent. No additional monitoring is required. ETFE Batch The ETFE Batch process was permitted as an expansion to the original ETFE/FEP/EFEP/TV process. The ETFE Batch unit consists of several pieces of particulate handling process equipment. The particulate emission points associated with this unit include N2-2, N2-7, N2-8, N2-9/N2-9B, N2-10/N2-10B, N2-11, N2-12, and N2-15/N2-15B. The unit also consists of multiple emission points. The emission points associated with this unit include N2-5 and N2-13. The unit is subject to synthetic minor PSD limitations for PM and. Each particulate emission point within this unit is subject to the state opacity regulations. Particulate All particulate matter emission points are subject to the state process weight curve; however, in order to avoid PSD review, the facility has committed to more stringent PM limits on each particulate point. The limits for each emission point are listed in the table below. Emission Point PM limit (lb/hr) N N N N2-9/N2-9B 0.15 N2-10/N2-10B 0.23 N N N2-15/N2-15B 0.05

13 In order to remain synthetic minor for, the emission point N2-5 and N2-13 are required to be vented to the T-Thermal incinerator to ensure a 99.99% DRE for and CFC. The unit is also required to implement an LDAR program equivalent to 40 CFR Part 60, Subpart VVa. /Particulate The facility was previously required to conduct daily visual observations for N2-2, N2-7, N2-8, N2-9/N2-9B, N2-10/N2-10B, N2-11, N2-12, and N2-15/N2-15B. The facility has proposed to conduct weekly visual observations for each emission point listed above. Based on the unit s operation and past visual inspections, the Department has determined that weekly visual inspection for these emission points would be appropriate. Therefore, weekly visual observations are required for all emission points within the ETFE batch unit. The T-Thermal monitoring requirements are discussed under the T-Thermal incinerator unit section below. The unit would be required to maintain the monitoring, recordkeeping, and reporting requirements equivalent to 40 CFR Part 60, Subpart VVa. Unidyne The primary emission point from the Unidyne unit is the Unidyne thermal oxidizer (U1-1). Emission Standards The state opacity requirement would be applicable to the Unidyne thermal oxidizer (U1-1). PM The unit is subject to the state requirements for incinerators. The Unidyne thermal oxidizer (U1-1) is subject to a PM limit of 0.2 lb/100 lb charged. HAP/VCM The Unidyne process unit is subject to 40 CFR Part 63, Subpart DDDDDD (PVC MACT for Area Sources). Subpart DDDDDD requires the unit to control the HAP and VCM

14 emissions from each emission source based on the type of resin being produced as listed in the table below. Additionally, Subpart DDDDDD also requires the implementation of an LDAR program equivalent to 40 CFR through , , through , and through of Subpart UU for equipment in HAP service as stated in 40 CFR (a). In addition to the requirements of Subpart UU, the requirements for pumps, compressor, and agitators and pressure relief devices listed in 40 CFR (b) and (c), are required. Vent Classification Pollutant Emission Limit PVC-only process vents Vinyl chloride All resin types 5.3 parts per million by volume (ppmv) PVC-only process vents Total Hydrocarbons or total organic HAP 46 ppmv measured as propane or 140 ppmv, PVC-only process vents Dioxins/furans (toxic equivalency basis) All resin types Stripped Resin Process Vents Vinyl Chloride Dispersion resin Stripped Resin Process Vents Total non-vinyl chloride organic HAP Dispersion resin Process Wastewater Vinyl Chloride All resin types /PM respectively ng/dscm 1,500 ppmw 230 ppmw 2.1 ppmw Since the Unidyne thermal oxidizer (U1-1) is permitted to fire natural gas and process gas only, the unit should meet the opacity requirement inherently. HAP/VCM Process Vents As a determiner of compliance, Subpart DDDDDD requires the facility to conduct performance testing every 5 years for each pollutant listed in Table1 of Subpart DDDDDD.

15 Additionally, daily vinyl chloride concentration in stripped resin and the monthly concentration of non-vinyl chloride organic HAP is required to be measured and maintained. Ambient Monitoring As a determiner of compliance, a Vinyl chloride monitoring system is required to be installed in accordance with the requirements of 40 CFR Wastewater As a determiner of compliance, the facility is required to measure and maintain the concentration of vinyl chloride and non-vinyl chloride organic HAP in each wastewater stream that must be treated according to the requirements of 40 CFR (b). Additionally, annual performance tests are required to be performed for each wastewater stream which is determined not to be treated according to the requirements of 40 CFR (b). Equipment Leaks The facility would be required to maintain the monitoring, recordkeeping, and reporting requirements equivalent to 40 CFR Part 63, Subpart UU and the applicable requirements of Subpart DDDDDD. T-Thermal Incinerator Emission Standards The only emission point associated with his unit is the thermal oxidizer and wet scrubber in series. The T-Thermal incinerator is subject to ADEM Admin. Code r (CISWI). The T-Thermal incinerator is subject to synthetic minor PSD limitations for SO2,, and CFC. The state opacity requirement would be applicable to the T-Thermal incinerator. The incinerator is routed to a wet scrubber prior to venting to the atmosphere. PM The state PM requirement for incinerators would be applicable to the T-Thermal incinerator. The incinerator would be required to maintain particulate emissions below 0.1

16 lb/100 lbs refuse charged if the charging rate is greater than 50 tons per day and 0.2 lb/100 lbs of refuse charged for charging rates less than or equal to 50 tons per day. The unit would also be subject to synthetic minor PSD limitations for PM since the T- Thermal incinerator would be capable of firing No. 2 fuel oil. In order to maintain synthetic minor status for PM, the T-Thermal incinerator would be required to fire No. 2 fuel oil in the unit with an ash content of less than 0.1% by weight. SO2 The unit would be subject to synthetic minor PSD limitations for SO2 since the T-Thermal incinerator would be capable of firing No. 2 fuel oil. In order to maintain synthetic minor status for SO2, the T-Thermal incinerator would be required to fire No. 2 fuel oil in the unit with a sulfur content of less than 0.1% by weight. NOx The unit would be subject to synthetic minor PSD limitations for NOx since the T-Thermal incinerator would be capable of firing No. 2 fuel oil. In order to maintain synthetic minor status for NOx, the T-Thermal incinerator is required to limit the NOx emissions to 0.27 lb/hr while firing No. 2 fuel oil. CISWI The unit would be classified as an existing unit (constructed before November 30, 1999). The emission limitations for existing units is listed in the table below. Pollutant Cadmium Carbon Monoxide Dioxins/furans Hydrogen Chloride Lead Mercury Nitrogen Oxides Particulate Matter Sulfur Dioxide Limit (units at a 7% oxygen dry basis, except opacity) mg/dscm 157 ppmvd 0.41 ng/dscm 62 ppmdv 0.04 mg/dscm 0.47 mg/dscm 388 ppmdv 70 mg/dscm 20 ppmdv 10 percent (6-minute averages) /CFC

17 Multiple vents throughout the facility are routed to the T-Thermal incinerator. The incinerator is required to achieve a destruction removal efficiency (DRE) of 99.99% for and CFC in order to remain synthetic minor with respect to PSD. /PM Since the emissions from the T-Thermal incinerator are routed to a wet scrubber for control, no monitoring would be required while firing natural gas only. As an indicator of compliance while firing No. 2 fuel oil, the records of the ash content are required to be maintained. CISWI Since a wet scrubber is utilized for control, the facility has established operating limits for 4 parameters in order to indicate compliance. The parameters monitored, operating limit set during the most recent compliance testing, and the averaging time for each value are listed below. Parameter Operating Limit Averaging Time Charge Rate <110% of rate during 3-hour rolling compliance testing Scrubber Pressure Drop > 1.85 in H2O 3-hour rolling Scrubber Liquor Flow 55 gpm 3-hour rolling Rate Scrubber Liquor ph 7 3-hour rolling The facility would also be required to inspect the control device annually. Additionally, performance testing is required annually and within 60 days of a process change made to the unit. /CFC In order to comply with the synthetic minor limitations for and CFC, the T-Thermal incinerator is required to maintain a firebox temperature of greater than or equal to 2300 F. The firebox temperature is to be recorded continuously and maintained. SO2

18 As an indicator of compliance while firing No. 2 fuel oil, the facility would maintain records of the sulfur content of the fuel. NOx The facility would be required to conduct performance testing in order to determine compliance with the NOx limit while firing No. 2 fuel oil. Generators The description, date installed, and operating capacity of the emergency generators and firewater pumps utilized by the facility are listed in the table below. All generators are utilized as emergency use only. All engines are diesel fired compression ignition reciprocating internal combustion engines (RICE) and are subject to 40 CFR Part 63, Subpart ZZZZ. Generator ID Installation Date Operating Capacity Administration Building Generator Utility Generator # Unidyne Emergency Generator Fire Pump # Utility Generator # Fire Pump # Emission Standards All emergency generators and firewater pumps associated with this facility are subject to the state opacity requirements. HAP The engines are subject to the emission limitations listed in Table 2c of Subpart ZZZZ. In order to remain classified as emergency, the engines would be required to operate according to the requirements of 40 CFR (f)(1)-(4).

19 HAP As an indicator of compliance, records of operation of the engines in emergency and nonemergency service, which is recorded through a non-resettable hour meter, are required to be maintained for each engine. Compliance Assurance Monitoring (CAM) Based on compliance assurance monitoring (CAM) applicability criteria, the facility has determined that two emission points would potentially be subject to CAM: PTFE-M-1 and PTFE-FD-1-A-G. Each emission point is controlled by compressor and vacuum systems. The facility has stated that each emission point would have an uncontrolled potential to emit greater than 100% of the major source threshold for. However, since the facility has stated that the compressor and vacuum system is for recovery of TFE material, the emission points would not be considered control devices as defined in CAM. Therefore, the emission points listed above would not be subject to the requirements of CAM.