APCD Alcan Foil VOC bubble permit conditions and LLFlex ABO Comparison

Permit Conditions
Permit Requirement
ABO Requirement
1.
The conditions and provisions of the emission bubble as described in the "SIP Revision application" shall be the applicable regulation.
No substantive permit requirements.  The relevant conditions and provisions of the "SIP Revision application" are contained in the permit conditions.
2., 1[st] par.
The nine machines 6, 7, 8, 9, 10 (formerly 13), 11, 14, 15, 16 shall be treated as one affected facility under the bubble.
Applies to these same units only.  Machine number 16 has been removed from the facility and shall not be operated.
2., 2[nd] par.
Over control by use of water-borne coatings/inks can be used for credit during baseline determination but not post-baseline calculations.  Credit can be taken for water-borne coatings/inks developed and used after the baseline period.
This provision is not needed in the ABO.  Baseline emissions were established in 1990 as 69.54 tpy. (55 FR 2842, January 29, 1990.)  The SIP, at APCD Regulation 4.1.2, does not allow reductions to be used for post-baseline calculations: "The emission reduction [for an emission reduction credit] must represent a real and permanent decrease in emissions below the applicable baseline level used in the SIP attainment demonstration."  
2., 3[rd] par.
Conditions applied to machine 16, now removed.
NA
2., 4[th] par.
Conditions applied to machine 16, now removed.
NA
2., 5[th] par.
246 VOC operating days/year allowed.
No limit to VOC operating days/year allowed (365).  Approved in 1998 because daily VOC emissions allowable were adjusted accordingly.  (63 FR 1927, January 13, 1998.)
2., 6[th] par.
The company shall follow the production scheduling and recordkeeping procedures specified in the "SIP Revision application."
No substantive permit requirements.  The relevant conditions and provisions of the "SIP Revision application" are contained in the permit conditions.
3.
The company may include in the bubble 214 tpy of VOC emission reduction credits purchased from Federal Paper Board Company.
This is included in the VOC bubble limit that still applies.
4.
The company shall use daily averaging to demonstrate compliance.
Required at Conditions 6 and 7.b.

5.a.
Supply information, as required by the District, to demonstrate compliance on a daily basis.
Required at Condition 4.

5.b.
Use the compliance reporting system as specified in the "SIP Revision application."
Conditions 4 and 6 require the company to keep sufficient records and to calculate the VOC emissions daily.

Also, as stated in the District's narrative, the company is still required to report the amount and types of coatings used as well as technical material specifications sufficient to determine compliance.
5.c.
Maintain records of 1) the date, 2) machine number, 3) yards run, 4) output width, 5) output laydown rate, and 6) coating used.

5.d.
Verify accuracy of the laydown rates according to Attachment 2 of the "SIP Revision application."

5.e.
Maintain records of daily emissions.
Required at Condition 6.
5.f.
Compliance reports submitted for each calendar month.
Condition 8 requires semiannual reporting.  This is consistent with EPA's Recordkeeping and Reporting Burden Reduction rulemaking of 1999.  (64 FR 7458, February 12, 1999.)
6.
Daily VOC limit of 2,164 lb/day; annual limit of 266.1 tpy.  (2,164 lb/day x 246 days/yr = 266.1 tpy)
Condition 1 requires a more stringent daily limit and an equivalent annual limit.
Daily VOC limit of 1,458 lb/day; annual limit of 266.2 tpy.  (1,458 lb/day x 365 days/yr = 266.1 tpy)
7.
Machines shall comply with a daily RACT allowable:
  65% by weight control for solvent-based inks,
  75% water by volume in volatile portion of coatings, and
  use of high solids content coatings/inks with greater than 60% nonvolatile material.
Retained as Condition 2.

A new compliance option is added:
  All inks and coatings, as applied to the substrate, used on the affected facility shall contain no more than 0.5 pounds of VOC per pound of solids.
This new option was previously added the Jefferson County portion of the SIP as provision 3.1.3 of Rule 6.29, Section 3.  (58 FR 54,516, October 22, 1993; and 82 FR 47,376, October 12, 2017.)  In addition, LLFlex submitted documentation to show how this additional compliance option will not result in greater emissions than the existing compliance options.
8.
The company shall perform any additional compliance testing as required by the District (as specified in Regulation 1.04; Regulation 6.01, Section 4; and Regulation 6.29, Section 4).
EPA test methods 1, 2, 3, 4, 24, 24A, 25 and 25A shall be used to determine the efficiency of control devices as requested by the District.
These are SIP and federal testing requirements that the District may require pursuant to APCD Regulation 1.04, Section 2.  These are requirements of the SIP that are not needed for purposes of the VOC bubble and do not need to be included in the ABO.
9.
If additional VOC control equipment is installed, the company shall conduct a performance test within 60 days.
This is a general provision that is not needed for purposes of the bubble.  Any additional VOC control equipment installed would be required to undergo performance testing via the construction permit. (Regulation 2.03 Section 1, 1.1.)
10.a. thru 10.f.
The company shall implement a program to periodically certify accuracy of coating data. If greater than 10% variation in VOC content was found from manufacturer's specifications, the company was required to use the greater of the two for emissions calculations until the discrepancy is resolved.
Chemical contents reporting requirements were relatively new at the time the original permit was adopted in 1989.  The District is unable to find an instance where the company found greater than 10% variation. 

The District believes technical specifications from the manufacturers are generally reliable today.  Manufacturer specifications, including those required in Safety Data Sheets (pursuant to OSHA's Hazard Communication Standard and EPA's Toxic Substances Control Act) are regularly relied upon by the District to enforce material VOC content requirements.
11.
Additional emission reductions may be imposed for future ozone SIPs.
Retained in the last un-numbered paragraph of the BACKGROUND AND DISCUSSION section.

