SAN DIEGO COUNTY AIR POLLUTION CONTROL DISTRICT
RULE 67.1 - ALTERNATIVE EMISSION CONTROL PLANS
(Effective 5/21/91; Rev. Adopted & Effective 5/15/96)
Except as provided for in Section (g), this rule is applicable to any stationary source conducting operations subject to any of the following rules, when an owner or operator elects to comply with the corresponding subsections of these rules by means of an alternative emission control plan (AECP):
67.3 - Coating of Metal Parts and Products, Subsection (d)(l),
67.4 - Metal Container, Metal Closure and Metal Coil Coating Operations, Section (d),
67.5 - Paper, Film and Fabric Coating Operations, Subsection (d)(l),
67.9 - Aerospace Coating Operations, Subsection (d)(l),
67.11 - Wood Products Coating Operations, Subsection (d)(2),
67.16 - Graphic Arts Operations, Section (d),
67.18 - Marine Coating Operations, Subsections (d)(l) and (d)(2).
(b) DEFINITIONS (Rev. Effective 5/15/96)
For the purpose of this rule the following definitions shall apply:
(i) actual average VOC emissions from the affected operations per operating day during the two years prior to submittal of the AECP, or
(ii) allowable VOC emissions from the affected operations under the applicable District rule, or
(iii) allowable VOC emissions from the affected operations under the applicable State Implementation Plan (SIP) provision.
(i) an increase in production rate and/or increase in hours of operation, and
(ii) use of alternate materials containing VOC's provided that VOC emissions resulting from such use do not exceed limits allowable under the approved AECP.
(i) requires a written permit pursuant to Rule 10, and
(ii) is in operation, exempt from the permit requirements pursuant to the provisions of Rule 11 and is proposed to be included in the AECP. Such units will require permits to operate to be issued concurrently with the approved AECP.
(i) Submits an application for an AECP which:
(A) provides at least a 20 percent reduction in VOC emissions from the affected operations as compared to the baseline emissions on each and every calendar day of operation. Baseline emissions shall be calculated according to Subsection (c)(2)(vi) of this rule; and
(B) allows a determination of compliance on a daily basis.
(ii) Submits applications for new or modified permits to operate for all permit units to be included in the AECP;
(iii) Receives written approval of the AECP from the Air Pollution Control Officer prior to AECP implementation. Such approval shall include federally enforceable operating conditions applied to an permits to operate for permit units included in the approved AECP; and
(iv) Complies with all specified terms, conditions and/or requirements of the AECP.
(i) The applicable District rule;
(ii) A list of equipment subject to the alternative emission control plan located at the stationary source;
(iii) Daily hours of operations of affected equipment per every operating calendar day for the two years directly preceding the source's application for AECP.
(iv) Daily records of usage of each coating and thinner in accordance with Section (d) of this rule for a period of two years directly preceding the source's application for AECP;
(v) For all add-on VOC emission control equipment - operating records, key operating parameters including but not limited to temperature, pressure and/or flow rates, source tests, laboratory analyses and monitoring data sufficient to demonstrate the claimed VOC emission reduction efficiency, for a period of two years directly preceding the source's application for AECP; and
(vi) Calculations showing baseline emissions for each piece of equipment included in the AECP. The baseline emissions (BE) shall be calculated according to the following:
BE (lbs VOC/day) = EF (lbs VOC/gal solids) x CU (gal solids/hr) x HR (hrs/day)
EF - emission factor (EF) in pounds of VOC emitted per gallon (or pound) of coating solids as applied,
CU - average hourly capacity utilization in gallons (or pounds) of coating solids per hour,
H - number of hours of operation per operating day
Emission factor, capacity utilization and hours of operation used for baseline calculations shall be either actual values, values allowable by the applicable District rule or allowable VOC emissions under the applicable SIP provision, whichever is lowest. Actual values for CU and H shall be determined using average data for two years directly preceding the source's application for AECP.
Sources lacking records of operating hours may substitute the above calculations for VOC emissions with records of VOC emissions from usage of coatings, as applied, expressed as pounds VOC per day from each piece of equipment included in the AECP. VOC emissions shall be calculated on a solids basis per every operating calendar day for the two years directly preceding the source's application for AECP. Baseline emissions for each piece of equipment included in the AECP shall be the least of either actual VOC emissions, or allowable VOC emissions from the affected operations under the applicable District rule, or allowable VOC emissions from the affected operations under the applicable State Implementation Plan (SIP) provision.
Net baseline emissions included in the AECP are the sum of the baseline emissions from all equipment subject to AECP.
(vii) Calculations showing how the proposed 20 percent VOC emission reduction from the baseline emissions from affected operations will be achieved and maintained each calendar day of operation under an AECP.
(i) Include VOC emissions only and result from activities governed by only one source-specific District rule;
(ii) Be enforceable. To meet this requirement, the operating conditions which qualify the AECP for approval shall be included in a Permit to Operate enforceable by the District, Air Resources Board (ARB) and Environmental Protection Agency (EPA);
(iii) Be permanent. To meet this requirement, the VOC emission reductions shall be below baseline emissions by at least 20% on each and every day of operation under the approved AECP;
(iv) Be quantifiable. To meet this requirement, the VOC emission reductions shall be determined using methods specified in Section (e) of this rule, shall be demonstrated through daily records and shall be based on a consistent averaging time, not to exceed 24 hours; and
(v) Be surplus. To meet this requirement, the VOC emission reductions in AECP shall not be mandated by current regulations incorporated in the SIP, not already relied upon for SIP planning purposes, not banked as an emission reduction credit, and not used by the source to meet any other regulatory requirement. Surplus emission reductions shall be determined using as a reference appropriate baseline emissions calculated pursuant to Subsection (c)(2)(vi); and
(vi) Be real. To meet this requirement, the VOC emission reductions pertaining to AECP shall not likely be replaced by the VOC emission increases within the District.
(vii) Be calculated on a mass or volume of solids basis. To meet this requirement, the VOC content of materials, the amount of VOC emissions and emission reductions shall be calculated and reported as pounds of VOC per pound or gallon of coating solids as applied, excluding water and exempt compounds.
(i) Prior to modification of equipment subject to the AECP which may result in the increase of VOC emissions; or
(ii) Within 60 days following the date the source-specific rule pertaining to Section (a) and relating to the AECP is amended or an applicable lower VOC content or VOC emission limit goes into effect; or
(iii) After equipment shutdown or production curtailment related to the equipment included in AECP, with the new baseline calculations reflecting such shutdown or curtailment.
(i) a current list of coatings and thinners; and
(ii) type and/or category of coatings and thinners used; and
(iii) mix ratio of components; and
(iv) allowable and actual content of VOC, water and exempt compounds for each coating and thinner. VOC content of coatings shall be expressed in grams of VOC per liter of coating as applied, less water and less exempt compounds. VOC content of thinners shall be expressed in grams of VOC per liter of thinner.
(i) The amount of coatings and thinners used for each operation; and
(ii) The calculations of allowable and actual VOC emissions and the VOC emission reduction compared to baseline.
All records pertaining to Subsection (c)(4) shall be retained on site for at least three years and shall be submitted to the District immediately upon request .
(e) TEST METHODS
The same test method and averaging time shall be used to quantify emission reductions both before and after add-on control device.