Attachment 1A Athol Corp. - CAM Plan

Transcription

1 Attachment 1A Athol Corp. - CAM Plan CAM Presentation Attachments, Page 1

2 Compliance Assurance Monitoring Plan SECTION COMPLIANCE ASSURANCE MONITORING (CAM) PLAN 5.1 Introduction and Background Information In accordance with 40 CFR Part 64.5 (b), the facility has been evaluated for CAM applicability (see Section 4.0 of this application) as a component of the permit renewal process. Athol has determined that Line 8 and its control device, the RTO, is subject to the Part 64 requirements. Athol has developed the CAM Plan contained in this section to address the requirements of 40 CFR Part 64. Below is additional information on the emission source and its control device. A. Pollutant Specific Emissions Unit (PSEU) Information Emission Source Description: Finishing Line No. 8 Emission Source ID No.: #8FINISH.ES Pollutant Controlled: VOCs B. Applicable Regulations, Emissions Limits, and Existing Monitoring Requirements Regulations: Emission Limits: NSPS, Subpart FFF (2D.0524) PSD (2D.0530) Avoidance 112(g) (2D.1112) Avoidance Monitoring Requirements 15A NCAC 2D.0524 (NSPS, Subpart FFF) 15A NCAC 2D.0530 Avoidance (PSD Avoidance) 15A NCAC 2D.1112 Avoidance (112(g) Avoidance) 85% VOC Control Efficiency < 40 TPY of VOC < 10 TPY of each HAP & < 25 TPY of aggregate HAP NSPS Subpart FFF requires continuous temperature monitoring of the stack to ensure the temperature does not drop 28 C (50.4 F) below the value established in the.last compliance test. In this Title V renewal, Athol is requesting to change this requirement from the stack temperature to the combustion zone temperature. C. Control Technology and Pre-controlled Emission Rate Control Device: Regenerative Thermal Oxidizer (RTO) Pre-controlled Potential Emission Rate: 798 TPY of VOC Section 5.0 Page 1 of 5 File: 5-CAMPLAN CAM Presentation Attachments, Page 2

3 Compliance Assurance Monitoring Plan Athol is required by permit to document that it complies with the PSD and 112(g) avoidance limits stated above. In order to document compliance with these two avoidance limits, Athol tracks the usage of VOC and HAP containing material. Compliance with these limits is documented by multiplying the usage by the VOC and/or HAP content and assuming 95% capture and control. The above coating usage and VOC/HAP content tracking will continue as a component of the re-issued Title V permit. This CAM plan has been, developed to use the combustion zone temperature as. the indicator for documenting compliance with the 95% capture and control efficiency. This use of combustion zone temperature versus stack gas temperature is further discussed in Section 6.3 of this application. Athol has developed this CAM Plan using the continuous parameter monitoring system (CPMS) (i.e., combustion zone temperature' monitoring) compliance procedure that has been proposed in the upcoming Paper and Other Web coating NESHAP (Proposed Rule dated 9/13/00; Subpart JJJJ). This CAM Plan has been developed to document that Line 8 meets 95% control and capture as required by the current permit. Athol believes that this compliance approach will also meet the requirements of the NESHAP, Subpart JJJJ, when this rule becomes applicable to the facility. By demonstrating an overall capture and destruction efficiency of 95%, Athol contends that the requirements of the NSPS, Subpart FFF would also be demonstrated. While Subpart FFF (which requires 85% overall reduction) requires the monitoring of stack temperature, Athol believes that the approach identified in this CAM plan represents the best overall approach to ensuring effective control of these emissions (See Section 6.3 for a complete discussion). 5.2 CAM Plan Submittal Requirements The components of this CAM Plan follow the requirements outlined in 40 CFR Part Part 64.4, paragraphs (a) through (g), lists the requirements or components for a CAM Plan submittal. Paragraphs (a), (b), (d), and (e) are applicable to the PSEU at Athol and are being followed in the development of the plan. The requirements of sections (a), (b), (d), and (e) are briefly outlined below: Paragraph (a) requires the submittal of monitoring that meets the Monitoring Design Criteria outlined in Part Paragraph (b) requires the submittal a justification for the proposed elements of the monitoring. Paragraph (d) requires the submittal of a test plan for obtaining the operating parameter data. Paragraph (e) requires the submittal of a schedule for implementing the CAM monitoring Monitoring Design Criteria (Part 64.3 Requirements) Section 64.4 defines the submittal requirements for the CAM Plan. The submittal is required to have the following items: (1) Indicators and ranges to satisfy 64.3 (a)(1-2) (2) Performance criteria to satisfy 64.3(b), and (3) Indicator Ranges and performance criteria for CEMS, COMS or PEMS pursuant to 64.3(d). Section 5.0 Page 2 of 5 File: 5-CAMPLAN CAM Presentation Attachments, Page 3

4 Compliance Assurance Monitoring Plan Athol is proposing to monitor the combustion zone temperature as an indicator of compliance as allowed by the upcoming Paper and Other Web Coating NESHAP (POWC MACT). The proposed monitoring qualifies as a predictive emission monitoring system or PEMS. A PEMS is defined in Part 64.1 as a system that uses process and other parameters as inputs to a computer program or other data reduction system to produce values in terms of the applicable emission limitation or standard. By meeting the requirements of 64.3(d) Athol will meet all requirements of (d) states the following: "(1) if a CEMS, COMS or PEMS is required pursuant to other authority under the Act or state or local law, the owner or operator shall use such system to satisfy the requirements of this part. (2) The use of a CEMS, COMS or PEMS that satisfies any of the following monitoring requirements shall be deemed to satisfy the general design criteria in Paragraphs (a) and (b) of this section, provided that a COMS may be subject to the criteria for establishing indicator ranges under paragraph (a) of this section." 'Of the list of monitoring requirements listed in 64.3(d)(2) Athol will meet the monitoring requirement of 64.3(d)(2)(iii) which allows the use of Section 63.8 and any applicable performance specifications required pursuant to the applicable subpart of Part 63. (3) The owner or operator shall design the monitoring system subject to this paragraph (d) to: (i) allow for reporting of exceedances consistent with any period for reporting of exceedances in an underlying.requirement and (ii) provide an indicator range consistent with paragraph (a) for this section for COMS used to assure compliance with a PM standard. In order to comply with part 64.4 and 64.3 (a), Athol will conduct combustion zone monitoring and will follow the continuous parameter monitoring system (CPMS) compliance procedure that will be allowed in the proposed NESHAP, Subpart JJJJ. As stated above, the CPMS monitoring and compliance procedure meets the PEMS option in Part 64.3(d). Athol will satisfy the CAM requirements by meeting the following requirements from the proposed POWC NESHAP, Subpart JJJJ. 1. Control Device Monitoring Requirements { (e)(1) through (6)(vii)} For an oxidizer, CPMS must be installed and operated as follows: The CPMS must complete a minimum of one cycle of operation for each successive e 15-minute period. Valid data from at least 90 percent of the hours which the process operated. Determine hourly average of all recorded reading. Determine rolling 3-hour average of all recorded readings. Record results of each inspection, calibration and validation check For each temperature monitoring device: (1) Locate temperature sensor as specified in (e)(3), (2) temperature sensor must has a minimum tolerance of 2.2 C or 0.75 percent of the temperature value, whichever is larger, (3) shield the temperature sensor system from electromagnetic interference and chemical contaminants (4) if a chart recorder is used it must have minor division of 20 F, (5) perform semiannually electronic calibration checks, (6) conduct calibration and validation checks any time the sensor exceed the manufacturers specifications or install a new sensor and (6) perform monthly inspections of all components for integrity. Section 5.0 Page 3 of 5 File: 5-CAMPLAN Compliance Assurance Monitoring Plan CAM Presentation Attachments, Page 4

5 2. Capture System Monitoring Requirements { (f)} A capture and control system is proposed for documenting compliance with the 95% control efficiency. Athol will be using a permanent total enclosure (PTE). The following CAM monitoring is proposed to meet (f)(1) and (2): The exhaust fan will be the parameter that is monitored during the compliance test to ensure proper operation of the PTE and control device. The exhaust fan is the appropriate parameter for PTE monitoring because if the capture system meets the PTE requirements during performance testing, the continued operation of the fan will ensure appropriate exhaust flow during operation of the casting line. As stated above, the monitoring of the exhaust fan operation will be the specific monitoring procedure. The coating line and the fan operation will be electronically interlocked such that the coating line cannot operate without exhaust fan operation. The above capture system monitoring plan satisfies all requirements of (f)(1) through (3) of Part Performance Testing Requirements { (e) and (f)} Performance testing will be conducted as follows to document compliance with the 95% capture and control requirement: The applicable requirements of (e)(1) through (3) will be followed to determine control efficiency and combustion zone temperature. The applicable requirements of (f) will be followed to determine the capture efficiency. 4. RTO Compliance Demonstration - Compliance with 95% Capture and - Control ( (k)} Compliance with the 95% capture and control efficiency will be demonstrated as follows: The initial compliance and continuing compliance demonstration will follow the requirements of (k)(1)(i) through (iii). The requirements of (k)(2)(i) will be followed to determine the control efficiency. Assuming that the' control efficiency calculated in (k)(2)(i) is greater than or equal to 95%, continued compliance as allowed under (k)(3) will be documented as long as the oxidizer is operated such that the average temperature for each 3-hour period is greater than monitored in the performance testing and the exhaust fan is operational when operating the coating line Justification for the Proposed Elements of the Monitoring Athol is using the CPMS compliance monitoring requirements of a proposed NESHAP regulation, Paper and Other Web Coating codified in 40 CFR Part 63, Subpart JJJJ. The use of a proposed NESHAP will conform with the requirements of 64.4(b) for CAM. Section 5.0 Page 4 of 5 File: 5-CAMPLAN CAM Presentation Attachments, Page 5

6 Compliance Assurance Monitoring Plan Test Plan Athol will conduct a test to obtain the operating parameter data based on the requirements specified in (a)(2). During this test Athol will determine the destruction efficiency and the combustion zone temperature according to (e) and the capture efficiency according to (f) Schedule for Implementing CAM Monitoring Athol will perform the performance testing to establish the required monitoring parameters within 180 days of permit issuance as specified in 64.4(e). 5.3 CAM Recordkeeping and Reporting Athol will adhere to the requirements in Part 64.9 and Part 70.6(a)(3)(iii). Temperature monitoring will be conducted as specified in the proposed POWC NESHAP and a summary will be submitted in the semi-annual Title V compliance reports. 5.4 CAM Exception When using aqueous coatings, the facility is permitted to operate Line 8 without operation of the RTO. Under this operating scenario, the facility is not subject to the CAM requirements listed in 40 CFR Part 64 and the CAM Plan outlined above. In addition to the above exception, the HAP component of this CAM Plan will no longer be applicable when Line 8 commences demonstrating compliance with the POWC NESHAP. At this point, the HAP emissions (including the 95% capture and control component) will only be subject to the POWC NESHAP and not the 112(g) non-applicability FEL. Section 5.0 Page 5 of 5 File: 5-CAMPLAN CAM Presentation Attachments, Page 6

7 Attachment 1B Athol Corp. CAM Permit Language CAM Presentation Attachments, Page 7

8 CAM Example Regenerative Thermal Oxidizer 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING (40 CFR 64) a. The Permittee shall ensure that volatile organic compounds emitted from Nos. 8 and 10 finishing lines are reduced by a minimum of 95 weight percent by monitoring the following capture and control device operating parameters: i. the motor amperage of the exhaust fan for the permanent total enclosure (PTE) on the Nos. 8 and 10 finishing lines (ID No. #8FINISH.ES and #10FINISH.ES) and ii the combustion zone temperature of the regenerative thermal oxidizers (ID No. 7-8RTO.CD and 10RTO.CD). b. The minimum combustion zone temperature for RTO (ID No. 7-8RTO.CD) shall be F. c. The minimum and maximum exhaust fan amperages of PTE for No. 8 finishing line (ID No. #8FINISH.ES) shall be 17A and 19.43A, respectively. d. The minimum 3-hour average RTO combustion zone temperature for RTO (ID No. 10RTO.CD) shall be determined through performance testing and the Permittee shall request that the value be incorporated into this permit by request for an administrative change within 180 days after initial start-up for No. 10 finishing line(id No. #10FINISH.ES). e. The minimum and maximum PTE exhaust fan amperages for No. 10 finishing line (ID No. #10FINISH.ES) shall be determined through performance testing and the Permittee shall request that these instantaneous values be incorporated into this permit through a request for an administrative change within 180 days after initial start-up for No. 10 finishing line(id No. #10FINISH.ES). Testing f. The Permittee must conduct a performance test to establish the destruction efficiency of the regenerative thermal oxidizer (ID No. 10RTO.CD) according to the methods and procedures below. The Permittee shall establish the associated minimum combustion zone temperature for the RTO according to the procedures in paragraph 2.1 E.6.f.iii. i. An initial performance test to establish the destruction efficiency of the RTO must be conducted such that oxidizer inlet and outlet testing is conducted simultaneously, and the data are reduced in accordance with the reference methods and procedures in 2.1 E.6.f.i.(A) through (I) below: (A) Method 1 or 1A of 40 CFR part 60, appendix A, must be used for sample and velocity traverses to determine sampling locations. (B) Method 2, 2A, 2C, 2D, 2F, or 2G of 40 CFR part 60, appendix A, must be used to determine gas volumetric flow rate. (C) Method 3, 3A, or 3B of 40 CFR part 60, appendix A, must be used for gas analysis to determine dry molecular weight. (D) Method 4 of 40 CFR part 60, appendix A, must be used to determine stack gas moisture. (E) The gas volumetric flow rate, dry molecular weight, and stack gas moisture must be determined for each run specified in paragraph 2.1 E.6.f.i.(G). (F) Method 25 of 40 CFR part 60, appendix A, must be used to determine volatile organic compound concentration, except as provided in paragraphs 2.1 E.6.f.i.(F)(1) and (2) below. You must submit notice of the intended test method to the DAQ (Regional Office) for approval along with notice of the performance test required under 40 CFR 63.7(c). You may use Method 25A of 40 CFR part 60, appendix A; if (1) The volatile organic compound concentration at the inlet to the control system and the required level of control are such that result in exhaust gas volatile organic compound concentrations of 50 ppmv or less; or (2) Because of the high efficiency of the control device, the anticipated volatile organic compound concentration at the control device exhaust is 50 ppmv or less, regardless of inlet concentration. (G) Except as provided in 40 CFR 63.7(e)(3), each performance test must consist of three separate runs; each run conducted for at least 1 hour under the conditions that exist when the affected source is operating under normal operating conditions. For the purpose of determining volatile organic compound concentrations and mass flow rates, the average of the results of all the runs will apply. (H) Organic volatile matter mass flow rates must be determined for each run specified in paragraph 2.1 E.6.f.i.(G) above using the following equation: M f = Q sd C c [12] [0.0416] [10-6 ] where: M f = the total volatile organic matter mass flow rate in kg per hour, Q sd = the volumetric flow rate of gases entering or exiting the control device, as determined by CAM Presentation Attachments, Page 8

9 Method 2, 2A, 2C, 2D, 2F, or 2G, dry standard cubic meters per hour, and C c = the concentration of organic compounds as carbon, parts per million by volume (I) Emission control device efficiency must be determined using the following equation : E =[M fi - M fo ]/M fi where: E = the organic volatile matter control efficiency of the control device in percent M fi = the organic volatile matter mass flow rate at the inlet to the control device in kg per hour M fo = the organic volatile matter mass flow rate at the outlet of the control device in kg per hour ii. You must record such process information as may be necessary to determine the conditions in existence at the time of the performance test (e.g., the PTE exhaust fan motor amperage). Operations during periods of start-up, shutdown, and malfunction will not constitute representative conditions for the purpose of a performance test. iii. The average of the combustion zone temperature values recorded during the performance test must be computed to establish the minimum combustion temperature in the combustion zone. This must be accomplished by locating the temperature sensor in the combustion zone. The Permittee must collect temperature data every 15 minutes during the entire period of the 3-hour performance test and determine the average temperature over the 3-hour performance test by computing the average of all of the 15-minute readings. iv. The average of the fan amperage values recorded during the performance test must be computed to establish the maximum amperage for the PTE exhaust fan. The Permittee must collect amperage data every 15 minutes during the entire period of the 3-hour performance test and determine the average amperage over the 3-hour performance test by computing the average of all of the 15-minute readings. g. A capture efficiency of 100 percent may be assumed if the capture system is a permanent total enclosure (PTE). The Permittee must confirm that the capture system is a permanent total enclosure by demonstrating that it meets the requirements of section 6 of EPA Method 204 of 40 CFR part 51, appendix M, and that all exhaust gases from the enclosure are delivered to the RTO. The minimum exhaust fan amperage to meet the face velocity requirement of 200 feet per minute at each natural draft opening shall be determined at the time the face velocities are verified to satisfy the requirements for a PTE. Monitoring h. A continuous monitoring system for RTO (ID Nos. 7-8RTO.CD and 10RTO.CD) combustion zone temperature (continuous parametric monitoring system - CPMS) shall be installed and operated according to the following: i. the CPMS must complete a minimum of one cycle of operation for each successive 15-minute period and a minimum of four successive cycles of operation must be present to have a valid hour of data; ii. valid data from at least 90 percent of the hours during which the process operated on an annual basis must be obtained; iii. the hourly average of all recorded readings must be determined 1 ; iv. each three-hour period average of all recorded readings for each operating period must be determined; v. the results of each inspection, calibration, and validation check must be recorded; and vi. for the temperature monitoring device: (A) locate the temperature sensor in the RTO combustion zone; (B) use a temperature monitoring device equipped with a continuous recorder with an accuracy of one percent of the temperature being monitored in 0 C or 1 0 C, whichever is greater; (C) shield the temperature sensor system from electromagnetic interference and chemical contaminants; (D) if a chart recorder is used, it must have a sensitivity in the minor division of at least 20 degrees Fahrenheit; (E) an electronic calibration must be performed at least quarterly according to the procedures in the manufacturer s owners manual. (F) conduct calibration and validation checks any time the sensor exceeds the manufacturer s specified maximum operating temperature range or install a new temperature sensor; and (G) at least monthly, inspect all components for integrity and all electrical connections for continuity, oxidation, and galvanic corrosion. i. The Permittee shall monitor PTE exhaust fan amperages for Nos. 8 and 10 finishing lines (ID Nos. #8FINISH.ES and #10FINISH.ES) daily using a calibrated amp meter and record the value in the log book. The fan motor amperage shall be determined from an acceptable amp meter that is capable of monitoring the fan amperage range such that the reading are between 25 and 75 percent of the scale offered by the meter. The amp meter shall be maintained in working order during all periods of RTO operation. 1 If combustion zone temperature readings of any 1-hr cycle are equal to or above F (i.e., all four measurements taken every 15 minutes equal or exceed this value), then calculations for average combustion zone temperature for that 1-hr cycle is not required. CAM Presentation Attachments, Page 9

10 j. RTO (ID No. 7-8RTO.CD and 10RTO.CD) combustion zone temperature and fan motor amperage readings of PTE on Nos. 8 and 10 finishing lines (ID No. #8FINISH.ES and #10FINISH.ES) are not required during periods when the RTO is not being used to achieve the required destruction efficiencies for regulatory compliance. However, the Permittee shall record each period (times and dates) that the affected equipment is operating using waterborne coatings for which the RTO is not required to achieve regulatory compliance. k. If the limit for a given operating parameter is exceeded six times in any semiannual reporting period, then any subsequent exceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed in any given 24-hour period. [40 CFR 64.7] l. Proper maintenance. At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment. m. Continued operation. Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. n. Response to excursions or exceedances. i. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. ii. Determination of whether the owner or operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process [40 CFR 64.7(d)(2)]. o. Documentation of need for improved monitoring. After approval of monitoring under this part, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the permitting authority and, if necessary, submit a proposed modification to the permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters [40 CFR 64.8]. p. Based on the results of a determination made pursuant to 2.1 E.6.n.ii., the DAQ may require the Permittee to develop and implement a QIP if an accumulation of exceedances of any permitted operating parameter exceeds 5 percent duration of the RTO operating time for a reporting period [40 CFR 64.3]. i. If required the Permittee shall maintain a written QIP, if required, and have it available for inspection. ii. The plan initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: (A) improved preventive maintenance practices, (B) process operation changes, (C) appropriate improvements to control methods, (D) other steps appropriate to correct control performance, and/or (E) more frequent or improved monitoring. iii. If a QIP is required, the Permittee shall develop and implement a QIP as expeditiously as practicable and shall notify the DAQ if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. CAM Presentation Attachments, Page 10

11 iv. Following implementation of a QIP, upon any subsequent determination pursuant to 2.1 E.6.n.ii., the DAQ may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: (A) failed to address the cause of the control device performance problems; or (B) failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. v. Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the Act. Recordkeeping and Reporting q. The Permittee must maintain the following records on a monthly basis in accordance with the requirements of 40 CFR 63.10(b)(1): i. records specified in 40 CFR 63.10(b)(2) of all measurements of operating parameters including: (A) control device and capture system operating parameter data and (B) overall control efficiency determination using capture efficiency test and oxidizer destruction efficiency test, and ii. records specified in 40 CFR 63.10(c) for each continuous parametric monitoring system operated by the Permittee. r. Semi annual compliance reports must cover the semiannual reporting period from January 1 through June 30 and the semiannual reporting period from July 1 through December 31. Each compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. The compliance report must contain the following information: i. Company name and address, ii. a statement by a responsible official with that official s name, title, and signature, certifying the accuracy of the content of the report, iii. the date of report and beginning and ending dates of the reporting period, iv. a statement that there were no excursion outside of the allowable operating parameter limits during the reporting period (as applicable), and that no continuous parametric monitoring system (CPMS) was inoperative, inactive, malfunctioning, out-of-control, repaired, or adjusted. Or for each exceedance of an allowable operating parameter that occurs, the compliance report must contain: (A) the total operating time of the source during the reporting period, (B) information on the number, duration, and cause of exceedances (including unknown cause), if applicable, and the corrective action taken, (C) information on the number, duration, and cause for CPMS downtime incidents, if applicable, other than downtime associated with zero and span and other daily calibration checks, CAM Presentation Attachments, Page 11

12 Attachment 2A Lexington Furniture CAM Plan CAM Presentation Attachments, Page 12

13 COMPLIANCE ASSURANCE MONITORING FABRIC FILTER FOR PM CONTROL I. Background A. Emission Unit Description: Wood Material Collection Systems Identification: ES4-WD1, ES4-WD1A, and ES5-WD1 Facility Lexington Furniture Industries - Plant 5 Lexington, North Carolina B. Applicable Regulation, Emission Limit, and Monitoring Requirements Regulation: 15A NCAC 2D.0512 and.0521 Emissions Limits: Opacity: 40% opacity (ES4-WD1) & 20% opacity (ES5 WD1 and ES4-WD1A) Particulate Matter: Adequate ductwork and properly designed collectors. C. Control Technology Bagfilters (ID Nos. CD4-DF1 through CD4-DF9 and CD5-BF1 through CD5-BF4) operated under negative pressure. II. Monitoring Approach The key elements of the monitoring approach are presented in Table A.1. CAM Presentation Attachments, Page 13

14 JUSTIFICATION I. Background The pollutant specific emissions control unit at Lexington Furniture Industries Plant 5 is the bagfilter. The plant uses thirteen bagfilters to control wood dust emissions. Bagfilters are used to remove particulate matter prior to emission into the atmosphere. II. Rationale for Selection of Performance Indicators Visible emissions were selected as the performance indicator because it is indicative of good operation and maintenance of the bagfilter. When the bagfilter is operating properly, there will not be any visible emissions from the exhaust. Any increase in visible emissions indicates reduced performance of a particulate control device, therefore, the presence of visible emissions is used as a performance indicator. In general, bagfilters are designed to operate at a relatively constant pressure drop. Monitoring pressure drop provides a means of detecting a change in operation that could lead to an increase in emissions. An increase in pressure drop can indicate that the cleaning cycle is not frequent enough, cleaning equipment is damaged, the bags are becoming blinded, or the airflow has increased. A decrease in pressure drop may indicate broken or loose bags, but this is also indicated by the presence of visible emissions. A pressure drop across the bagfilter also serves to indicate that there is airflow through the control device. III. Rationale for Selection of Indicator Ranges The selected indicator range is no visible emissions. When an excursion occurs, corrective action will be initiated, beginning with an evaluation of the occurrence to determine the action required to correct the situation. All excursions will be documented. An indicator range of no visible emissions was selected because an increase in visible emissions is indicative of an increase in particulate emissions. The selected QIP threshold for bagfilter visible emissions is five excursions in a six month period. This level is 3 percent of the total visible emissions observation. If the QIP threshold is exceeded in a semiannual period, a QIP will be developed and implemented. The indicator range chosen for the bagfilter pressure drop is less than 5.0 in. H20. An excursion triggers an inspection and corrective action. The pressure drop is recorded daily. As the pressure drop approaches five in. H 2 O, the bags are scheduled for replacement. The bags are typically changed yearly. This indicator is also used to monitor for bypass of the control device. If the pressure drop falls below 1.0 in. H2O during normal process operation, the possibility of bypass is investigated. No QIP threshold has been selected for this indicator CAM Presentation Attachments, Page 14

15 I. Indicator Measurement Approach Visible emissions TABLE A.1 MONITORING APPROACH Visible emission from the bagfilter exhaust will be monitored daily using EPA Reference Method 22-like procedures. Pressure Drop Pressure drop across the bagfilter is measured with a differential pressure gauge. II. Indicator Range An excursion is defined as the presence of visible emissions. Excursions trigger and inspection and corrective action. An excursion is defined as a pressure drop greater than 5.0 in. H 2 O. If the pressure drop falls below 1.0 in. H 2 O, the possibility of bypass is investigated. QIP Threshold The QIP threshold is 5 excursions in a six-month period. The QIP threshold is 5 excursions in a six-month period. III. Performance Criteria A. Data Representativeness B. Verification of Operational Status Measurements are being made at the emission point (bagfilter exhaust): NA Pressure taps are located at the baghouse inlet and outlet. The gauge has an indication range from 0.0 in. H 2 O to 10.0 in. H2O and has an accuracy of plus or minus 2% of full scale, at 70 F. The actual temperature of the monitored exhaust will vary depending on seasonal changes. NA C. QA/QC Practices and Criteria D. Monitoring Frequency Data Collection Procedure The observer will be familiar with Method 22 and follow Method 22-like procedures. A 6-minute Method 22-like observation is performed daily. The visible emission observation is documented by the observer The pressure gauge is calibrated semi-annually. Pressure taps are checked for plugging daily. Pressure drop is continuously monitored while the bagfilter is in operation. Pressure drop is manually recorded daily. Averaging Period NA NA CAM Presentation Attachments, Page 15

16 Attachment 1B Lexington Furniture CAM Permit Language CAM Presentation Attachments, Page 16

17 CAM Example Bagfilter 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING a. Per 40 CFR 64 and 15A NCAC 2D.0614, the Permittee shall comply with the following. b. Background i. Emission Unit. (A) Description. Wood Material Collection Systems (B) Identification. ES4-WD1 and ES5-WD1 ii. Applicable Regulation, Emission Limit, and Monitoring Requirements. (A) Regulation. 15A NCAC 2D.0512 and.0521 (B) Emission Limits. 1. Opacity. 40% opacity (ID No. ES4-WD1) 20% opacity (ID No. ES5-WD1) 2. Particulate. Adequate ductwork and properly designed collectors. (C) Control Technology. Bagfilters (ID Nos. CD4-DF1 through CD4-DF7, CD4-DF9, and CD5-BF1 through CD5-BF4) operated under negative pressure. c. Monitoring Approach. The key elements of the monitoring approach are presented in the following table. Indicator Measurement Approach Indicator Range QIP Threshold Performance Criteria/Data Representativeness Verification of Operational Status QA/QC Practices and Criteria Monitoring Frequency Data Collection Procedure Averaging Period Visible Emissions Visible emissions from the bagfilter exhaust will be monitored daily using EPA Reference Method 22-like procedures. An excursion is defined as the presence of visible emissions. Excursions trigger an inspection and corrective action. The QIP threshold is five excursions in a six-month period. Measurements are being made at the emission point (bagfilter exhaust) NA The observer will be familiar with Method 22 and follow Method 22-like procedures. A six-minute Method 22-like observation is performed daily. The visible emissions observation is documented by the observer. NA Pressure Drop Pressure drop across the bagfilter is measured with a differential pressure gauge. An excursion is defined as a pressure drop greater than 5.0 inches of water. If the pressure drop falls below 1.0 inches of water, the possibility of bypass is investigated. The QIP threshold is five excursions in a six-month period. Pressure taps are located at the bagfilter inlet and outlet. The gauge has an indicator range from 0.0 to 10.0 inches of water and has an accuracy of plus or minus 2 percent of full scale, and 70 O F. The actual temperature of the monitored exhaust will vary depending on seasonal changes. NA The pressure gauge is calibrated semi-annually. Pressure taps are checked for plugging daily. Pressure drop is continuously monitored while the bagfilter is in operation. Pressure drop is manually recorded daily. NA CAM Presentation Attachments, Page 17

18 d. Justification i. Background. The pollutant specific emissions control units at the facility are the bagfilters (ID Nos. CD4-DF1 through CD4-DF7, CD4-DF9, and CD5-BF1 through CD5-BF4). The twelve bagfilters (ID Nos. CD4-DF1 through CD4-DF7, CD4-DF9, and CD5-BF1 through CD5-BF4) are used to control wood dust emissions by removing particulate matter prior to emission into the atmosphere. ii. Rationale for Selection of Performance Indicators. Visible emissions were selected as the performance indicator because it is indicative of good operation and maintenance of the bagfilters (ID Nos. CD4-DF1 through CD4-DF7, CD4-DF9, and CD5-BF1 through CD5- BF4). When the bagfilters (ID Nos. CD4-DF1 through CD4-DF7, CD4-DF9, and CD5- BF1 through CD5-BF4) are operating properly, there will not be any visible emissions from the exhaust. Any increase in visible emissions indicates reduced performance of a particular control device; therefore, the presence of visible emissions is used as a performance indicator. In general, bagfilters are designed to operate at a relatively constant pressure drop. Monitoring pressure drop provides a means of detecting a change in operation that could lead to an increase in emissions. An increase in pressure drop can indicate that the cleaning cycle is not frequent enough, cleaning equipment is damaged, the bags are becoming blinded, or the airflow has increased. A decrease in pressure drop may indicate broken or loose bags, but this is also indicated by the presence of visible emissions. A pressure drop across the bagfilter also serves to indicate that there is airflow through the control device. iii. Rationale for Selection of Indicator Ranges. The selected indicator range is no visible emissions. When an excursion occurs, corrective action will be initiated, beginning with an evaluation of the occurrence to determine the action required to correct the situation. All excursions will be documented. An indicator range of no visible emissions was selected because an increase in visible emissions is indicative of an increase in particulate emissions. The selected QIP threshold for bagfilter visible emissions is five excursions in a six-month period. This level is three percent of the total visible emissions observations conducted for the period. If the QIP threshold is exceeded in a semi-annual period, a QIP will be developed and implemented. The indicator range chosen for the bagfilter pressure drop is less than five inches of water. An excursion triggers an inspection and corrective action. The pressure drop is recorded daily. As the pressure drop approaches five inches of water, the bags are scheduled for replacement. The bags are typically changed yearly. This indicator is also used to monitor for bypass of the control device. If the pressure drop falls below one inch of water during normal process operation, the possibility of bypass is investigated. The selected QIP threshold for bagfilter pressure drop is five excursions in a six-month period. This level is three percent of the total pressure drop observations conducted for the period. If the QIP threshold is exceeded in a semi-annual reporting period, a QIP will be developed and implemented. CAM Presentation Attachments, Page 18

19 Attachment 3 CAM Plan Submittal Form CAM Presentation Attachments, Page 19

20 CAM Plan Submittal Forms I. Background A. Emissions Unit Description: (Type of emission point) Identification: (Emission point number) B. Applicable Regulation, Emission Limits, and Monitoring Requirements Regulation No.: Pollutant: Pollutant: Emission Limit: Emission Limit: Monitoring Requirements: C. Control Technology (Describe control technology) II. Monitoring Approach The key elements of the monitoring approach are presented in Table 1. III. Justification (Present justification for selection of monitoring approach and indicator range(s).) CAM Presentation Attachments, Page 20

21 Table 1. Monitoring Approach Indicator No. 1 Indicator No. 2 I. Indicator Measurement Approach II. Indicator Range QIP Threshold (optional) III. Performance Criteria A. Data Representative B. Verification of Operational Status C. QA/QC Practices and Criteria D. Monitoring Frequency Data Collection Procedures Averaging Period CAM Presentation Attachments, Page 21