request for alternative compliance methods for hazardous
TRANSCRIPT
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX
75 Hawthorne Street San Francisco CA 94105
SEP 2 0 2011
Mr Thomas A Ninke Environmental and Sustainability Team Leader Americas EHS Center ofExcellence Huntsman Corporation 8600 Gosling Road The Woodlands Texas 77381
Re Request for Clarification and Authorization ofCompliance Methods--40 CFR 63 Subparts VVVVVV and CCCCCCC Huntsman Advanced Materials Los Angeles California
Dear Mr Ninke
We have received your January 28 2011 request for clarification and authorization of alternative compliance methods under 40 CFR 63 Subpart VVVVVV National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources and 40 CFR 63 Subpart CCCCCCC National Emission Standards for Hazardous Air Pollutants for Area Sources Paints and Allied Products Manufacturing The request is regarding the operations at the Huntsman Advanced Materials facility in Los Angeles California (Huntsman or Facility) which has a batch manufacturing process permitted under the South Coast Air Quality Management District (SCAQMD) with several process vessels subject to Subpart VVVVVV and two process vessels subject to both subparts Per 6311500 when a chemical manufacturing process unit (CMPU) is subject to Subpart VVVVVV and another rule facilities may elect to comply only with the more stringent rule for that CMPU according to the provisions of63l1500(a) As described below some ofHuntsmans requests stem from this statement while others are requests for alternative compliance methods Regional offices are delegated the authority to review approve or disapprove these requests
Below are our determinations based on the information Huntsman provided to date
Item 1a - Subpart VVVVVV GACT Inspection Requirements - Process Equipment
Huntsman proposes to comply with Subpart VVVVVVs management practices at 6311495(a)(3)-to determine that process vessels and equipment are sound andfree ofIeales-by inspecting the PM collection system and baghouses in accordance with 6311602(a)(2)(ii) ofSubpart CCCCCCC in lieu ofinspecting the actual process vessel and equipment as required by Subpart vvvvvv Huntsman is asking ifthis inspection is as stringent as and meets the intent of the Subpart VVVVVV inspection requirements for controUing metal HAPs from process vessels that serve as independent mixpots
Huntsman states that the sites actual uncontrolled metal HAP emissions are less than 400 pounds per year Under Subpart VVVVVV the substantive standards for process vessels within a CMPU with
uncontrolled process vent emissions less than 10000 pounds per year are the management practices of section 6311495
Subpart Vvvvvv at 6311495(a)(I) requires that each process vessel in organic HAP service or metal HAP service be equipped with a cover or lid that must be in place at all time when the vessel contains HAP except for material addition and sampling~
Subpart VVVVVV at 6311495(a)(3) requires inspections ofprocess vessels and equipment for each CMPU in organic HAP service or metal HAP service at least quarterly to demonstrate compliance and to determine that the process vessels and equipment are sound and free of leaks This includes an inspection ofthe process vessel and cover as well as the defined equipment ie each pump compressor agitator pressure relief device sampling connection system open-ended valve or line valve connector and instrumentation system in or associated with a CMPU
Subpart CCCCCCC at 6311602(a)(2)(H) specifies inspection and maintenance requirements for each dry particulate control unit (A) weekly visual inspections of any flexible ductwork for leaks and (B) inspections ofthe rigid stationary ductwork for leaks and the interior ofthe dry particulate control unit for structural integrity and to determine the condition ofthe fabric filter (if applicable) every 12 months
The above requirements are non-overlapping because they pertain to different segments along the air emissions path process vesselsllids flexible ductwork rigidstationary ductwork and the dry particulate control unit Leaks can occur anywhere along the path
Specifically inspection ofthe baghouse and associated ductwork does not ensure that the process vessels covers or the equipment within the CMPU are sound and free ofleaks Therefore we do not approve Huntsmans proposal to inspect the PM collection system and baghouses in lieu of inspecting the actual process vessel cover and equipment for mixing pots that are subject to both subparts Process vessels covers and equipment subject to subpart VVVVVV must be inspected according to 6311495(a)(3)
Item 1b-Subpart VVVVVV [6311495(a)(3)Jand Subpart CCCCCCC [6311602(a)(2)(ii)J Inspection Requirements - Ductwork
Huntsman proposed several alternative inspection options Option 1 Exclude equipmentfrom quarterly [6311495(a)(3)J and weekly [6311602(a)(2)(ii)J inspection requirements ifunder vacuum and only inspect the emission control device according to 6311602(a)(2)(iii)lf EPAJinds this inadequate Huntsman proposes to either (1) inspect baghouse emissions on a weekly basis to verify that site PM emissions are adequately controlled or (2) inspect flexible and stationary ductwork at the specified timeframes whether or not emissions are being actively controlled on every vessel that uses the common control device header Option 2 Use monitoring devices (flow instruments pressure gauges or other available instrument) at the baghouse to verify that the capture equipment is properly operating in lieu oinspecting the ductwork
Subpart VVVVVV at 631 1495(a)(3) requires conducting inspections ofprocess vessels and equipment for each CMPU in organic HAP service or metal HAP service at least quarterly to demonstrate compliance and to determine that the process vessels and equipment are sound and free of leaks
Subpart VVVVVV at 631 1 495(a)(3) requires that inspections be conducted while the subject CMPU is operating
Subpart CCCCCCC at 6311602(a)(2)(ii) specifies inspection and maintenance requirements for each dry particulate control unit (A) weekly visual inspections of any flexible ductwork for leaks and (B) inspections of the rigid stationary ductwork for leaks and the interior of the dry particulate control unit for structural integrity and to determine the condition of the fabric filter (if applicable) every 12 months
As noted previously these requirements are non-overlapping because they pertain to different segments along the air emissions path process vessels and equipment flexible ductwork rigidstationary ductwork and the particulate control device
Based on the above Option 1 and Option 1 (I) are both inadequate for the same reasons as previously discussed The ductwork and control device inspections are not interchangeable with the process vessel and equipment inspections For mixing pots that are subject to both subparts the integrity of the process vessel lid and equipment as well as the integrity ofthe baghouse and ductwork each must be ensured by conducting periodic inspections Although the system is under vacuum this does not ensure that the process vessels are sound and free of leaks
Option 2 is also inadequate Based on information provided by Huntsman the monitoring devices are used primarily for monitoring the integrity of the baghouse Specifically the baghouse pressure drop is a parameter related to the control of emissions by the baghouse whereas the flexible ductwork inspections relate to ensuring adequate capture of emissions to the baghouse In the preamble to the final paints and coatings area source rule EPA has stated that both control and capture needs to be adequate to ensure proper overall emission control in relation to the standard EPA responded to several comments related to the monitoring of ductwork including the comment that visual leak inspections ofdry particulate control device ductwork should not be required because ductwork leaks under vacuum cannot be visually detected EPAs overall response to comments as a whole was Inspections and visible emissions monitoring of the particulate control device system provide data indicative of a well-operated and maintained control device The inspections will ensure there are no leaks in the duct work while the visible emissions monitoring will ensure that the particulate control device is operating as intended and that no excess emissions are emitted See 74 Fed Reg 63516-63517 Furthermore leaks in the ductwork may result in lower air flow where the vacuum drop lines connect to the vessel lids and this can result in reduced PM pickup efficiency
To meet the inspection requirements for the ductwork only Huntsman may proceed with Option 1 (2) inspect flexible and stationary ductwork according to 6311602(a)(2)(ii) as required at the specified
time-frames whether or not emissions are being actively controlled on every vessel that uses the common control device header Information provided by Huntsman indicates that the batch process vessels do not operate at the same time and may sit idle for days or weeks making it difficult to conduct quarterly inspections while all process vessels connected to the vacuum collection system are in operation Option 1 (2) allows for the periodic inspections to take place even when some of the process vessels are not in operation Approval of this option will also require additional recordkeeping indicating which process vessels were in operation during each inspection Approval of this option will further require that each mixing pot be operational at least once a year during quarterly inspections and at least once a quarter during weekly inspections Huntsman indicated that some mixing vessels in dual service are often used with materials without HAPs for extended time periods For such mixing vessels the inspections can be conducted while charging the vessel with material with or without HAP
3
Item 2-Filter Cartridges versus Fabric Filters Huntsman uses rigidfilter cartridges in its baghouses to control PM emissions Huntsman believes that these do not meet the definition 0 abricfilter in 40 CFR 6311607 and thereore may be excludedrom the annual inspection requirement 040 CFR 6311602(a)(2)(ii)(B)
Subpart CCCCCCC at 63 11602( a)(2)(ii)(B) requires conducting inspections of the rigid stationary ductwork for leaks and the interior of the dry particulate control unit for structural integrity and to determine the condition of the fabric filter (if applicable) every 12 months Fabric filter is defined at 6311607 as an air collection and control system that utilizes a bag filter to reduce the emissions of metal HAP and other particulate matter
Huntsman has a Farr Gold cartridge-type dry particulate control unit that serves a building with several mixers two ofwhich are subject to both subparts Huntsman states that since this dust collector uses sealed cartridge filters checking the condition of the fabric filter is not feasible Information provided by Huntsman indicates that preventative maintenance includes filter-unit replacement (as a whole) when required based on pressure differential established in Condition 5 of the SCAQMD Permit to Operate (Permit No F97279) We have determined that this is an acceptable alternative to checking the condition of the fabric filter during the dry particulate control unit inspection as an internal visual inspection of each individual cartridge is not feasible Please note that Huntsman is still required to conduct inspections of the rigid stationary ductwork for leaks and of the interior of the dry particulate control unit for structural integrity according to 6311602(a)(2)(ii)(B)
This response was coordinated with the Office of Compliance in the Office ofEnforcement and Compliance Assurance (OCOECA) and the Office of Air Quality Planning and Standards (OAQPS)
If you have further questions please feel free to contact Tfulde Wang ofmy staff at (415) 972-3990
Sincerely
Douglas K McDaniel Chief Enforcement Office Air Division
cc Dr Barry Wallerstein Executive Officer SCAQMD
4
uncontrolled process vent emissions less than 10000 pounds per year are the management practices of section 6311495
Subpart Vvvvvv at 6311495(a)(I) requires that each process vessel in organic HAP service or metal HAP service be equipped with a cover or lid that must be in place at all time when the vessel contains HAP except for material addition and sampling~
Subpart VVVVVV at 6311495(a)(3) requires inspections ofprocess vessels and equipment for each CMPU in organic HAP service or metal HAP service at least quarterly to demonstrate compliance and to determine that the process vessels and equipment are sound and free of leaks This includes an inspection ofthe process vessel and cover as well as the defined equipment ie each pump compressor agitator pressure relief device sampling connection system open-ended valve or line valve connector and instrumentation system in or associated with a CMPU
Subpart CCCCCCC at 6311602(a)(2)(H) specifies inspection and maintenance requirements for each dry particulate control unit (A) weekly visual inspections of any flexible ductwork for leaks and (B) inspections ofthe rigid stationary ductwork for leaks and the interior ofthe dry particulate control unit for structural integrity and to determine the condition ofthe fabric filter (if applicable) every 12 months
The above requirements are non-overlapping because they pertain to different segments along the air emissions path process vesselsllids flexible ductwork rigidstationary ductwork and the dry particulate control unit Leaks can occur anywhere along the path
Specifically inspection ofthe baghouse and associated ductwork does not ensure that the process vessels covers or the equipment within the CMPU are sound and free ofleaks Therefore we do not approve Huntsmans proposal to inspect the PM collection system and baghouses in lieu of inspecting the actual process vessel cover and equipment for mixing pots that are subject to both subparts Process vessels covers and equipment subject to subpart VVVVVV must be inspected according to 6311495(a)(3)
Item 1b-Subpart VVVVVV [6311495(a)(3)Jand Subpart CCCCCCC [6311602(a)(2)(ii)J Inspection Requirements - Ductwork
Huntsman proposed several alternative inspection options Option 1 Exclude equipmentfrom quarterly [6311495(a)(3)J and weekly [6311602(a)(2)(ii)J inspection requirements ifunder vacuum and only inspect the emission control device according to 6311602(a)(2)(iii)lf EPAJinds this inadequate Huntsman proposes to either (1) inspect baghouse emissions on a weekly basis to verify that site PM emissions are adequately controlled or (2) inspect flexible and stationary ductwork at the specified timeframes whether or not emissions are being actively controlled on every vessel that uses the common control device header Option 2 Use monitoring devices (flow instruments pressure gauges or other available instrument) at the baghouse to verify that the capture equipment is properly operating in lieu oinspecting the ductwork
Subpart VVVVVV at 631 1495(a)(3) requires conducting inspections ofprocess vessels and equipment for each CMPU in organic HAP service or metal HAP service at least quarterly to demonstrate compliance and to determine that the process vessels and equipment are sound and free of leaks
Subpart VVVVVV at 631 1 495(a)(3) requires that inspections be conducted while the subject CMPU is operating
Subpart CCCCCCC at 6311602(a)(2)(ii) specifies inspection and maintenance requirements for each dry particulate control unit (A) weekly visual inspections of any flexible ductwork for leaks and (B) inspections of the rigid stationary ductwork for leaks and the interior of the dry particulate control unit for structural integrity and to determine the condition of the fabric filter (if applicable) every 12 months
As noted previously these requirements are non-overlapping because they pertain to different segments along the air emissions path process vessels and equipment flexible ductwork rigidstationary ductwork and the particulate control device
Based on the above Option 1 and Option 1 (I) are both inadequate for the same reasons as previously discussed The ductwork and control device inspections are not interchangeable with the process vessel and equipment inspections For mixing pots that are subject to both subparts the integrity of the process vessel lid and equipment as well as the integrity ofthe baghouse and ductwork each must be ensured by conducting periodic inspections Although the system is under vacuum this does not ensure that the process vessels are sound and free of leaks
Option 2 is also inadequate Based on information provided by Huntsman the monitoring devices are used primarily for monitoring the integrity of the baghouse Specifically the baghouse pressure drop is a parameter related to the control of emissions by the baghouse whereas the flexible ductwork inspections relate to ensuring adequate capture of emissions to the baghouse In the preamble to the final paints and coatings area source rule EPA has stated that both control and capture needs to be adequate to ensure proper overall emission control in relation to the standard EPA responded to several comments related to the monitoring of ductwork including the comment that visual leak inspections ofdry particulate control device ductwork should not be required because ductwork leaks under vacuum cannot be visually detected EPAs overall response to comments as a whole was Inspections and visible emissions monitoring of the particulate control device system provide data indicative of a well-operated and maintained control device The inspections will ensure there are no leaks in the duct work while the visible emissions monitoring will ensure that the particulate control device is operating as intended and that no excess emissions are emitted See 74 Fed Reg 63516-63517 Furthermore leaks in the ductwork may result in lower air flow where the vacuum drop lines connect to the vessel lids and this can result in reduced PM pickup efficiency
To meet the inspection requirements for the ductwork only Huntsman may proceed with Option 1 (2) inspect flexible and stationary ductwork according to 6311602(a)(2)(ii) as required at the specified
time-frames whether or not emissions are being actively controlled on every vessel that uses the common control device header Information provided by Huntsman indicates that the batch process vessels do not operate at the same time and may sit idle for days or weeks making it difficult to conduct quarterly inspections while all process vessels connected to the vacuum collection system are in operation Option 1 (2) allows for the periodic inspections to take place even when some of the process vessels are not in operation Approval of this option will also require additional recordkeeping indicating which process vessels were in operation during each inspection Approval of this option will further require that each mixing pot be operational at least once a year during quarterly inspections and at least once a quarter during weekly inspections Huntsman indicated that some mixing vessels in dual service are often used with materials without HAPs for extended time periods For such mixing vessels the inspections can be conducted while charging the vessel with material with or without HAP
3
Item 2-Filter Cartridges versus Fabric Filters Huntsman uses rigidfilter cartridges in its baghouses to control PM emissions Huntsman believes that these do not meet the definition 0 abricfilter in 40 CFR 6311607 and thereore may be excludedrom the annual inspection requirement 040 CFR 6311602(a)(2)(ii)(B)
Subpart CCCCCCC at 63 11602( a)(2)(ii)(B) requires conducting inspections of the rigid stationary ductwork for leaks and the interior of the dry particulate control unit for structural integrity and to determine the condition of the fabric filter (if applicable) every 12 months Fabric filter is defined at 6311607 as an air collection and control system that utilizes a bag filter to reduce the emissions of metal HAP and other particulate matter
Huntsman has a Farr Gold cartridge-type dry particulate control unit that serves a building with several mixers two ofwhich are subject to both subparts Huntsman states that since this dust collector uses sealed cartridge filters checking the condition of the fabric filter is not feasible Information provided by Huntsman indicates that preventative maintenance includes filter-unit replacement (as a whole) when required based on pressure differential established in Condition 5 of the SCAQMD Permit to Operate (Permit No F97279) We have determined that this is an acceptable alternative to checking the condition of the fabric filter during the dry particulate control unit inspection as an internal visual inspection of each individual cartridge is not feasible Please note that Huntsman is still required to conduct inspections of the rigid stationary ductwork for leaks and of the interior of the dry particulate control unit for structural integrity according to 6311602(a)(2)(ii)(B)
This response was coordinated with the Office of Compliance in the Office ofEnforcement and Compliance Assurance (OCOECA) and the Office of Air Quality Planning and Standards (OAQPS)
If you have further questions please feel free to contact Tfulde Wang ofmy staff at (415) 972-3990
Sincerely
Douglas K McDaniel Chief Enforcement Office Air Division
cc Dr Barry Wallerstein Executive Officer SCAQMD
4
Subpart VVVVVV at 631 1 495(a)(3) requires that inspections be conducted while the subject CMPU is operating
Subpart CCCCCCC at 6311602(a)(2)(ii) specifies inspection and maintenance requirements for each dry particulate control unit (A) weekly visual inspections of any flexible ductwork for leaks and (B) inspections of the rigid stationary ductwork for leaks and the interior of the dry particulate control unit for structural integrity and to determine the condition of the fabric filter (if applicable) every 12 months
As noted previously these requirements are non-overlapping because they pertain to different segments along the air emissions path process vessels and equipment flexible ductwork rigidstationary ductwork and the particulate control device
Based on the above Option 1 and Option 1 (I) are both inadequate for the same reasons as previously discussed The ductwork and control device inspections are not interchangeable with the process vessel and equipment inspections For mixing pots that are subject to both subparts the integrity of the process vessel lid and equipment as well as the integrity ofthe baghouse and ductwork each must be ensured by conducting periodic inspections Although the system is under vacuum this does not ensure that the process vessels are sound and free of leaks
Option 2 is also inadequate Based on information provided by Huntsman the monitoring devices are used primarily for monitoring the integrity of the baghouse Specifically the baghouse pressure drop is a parameter related to the control of emissions by the baghouse whereas the flexible ductwork inspections relate to ensuring adequate capture of emissions to the baghouse In the preamble to the final paints and coatings area source rule EPA has stated that both control and capture needs to be adequate to ensure proper overall emission control in relation to the standard EPA responded to several comments related to the monitoring of ductwork including the comment that visual leak inspections ofdry particulate control device ductwork should not be required because ductwork leaks under vacuum cannot be visually detected EPAs overall response to comments as a whole was Inspections and visible emissions monitoring of the particulate control device system provide data indicative of a well-operated and maintained control device The inspections will ensure there are no leaks in the duct work while the visible emissions monitoring will ensure that the particulate control device is operating as intended and that no excess emissions are emitted See 74 Fed Reg 63516-63517 Furthermore leaks in the ductwork may result in lower air flow where the vacuum drop lines connect to the vessel lids and this can result in reduced PM pickup efficiency
To meet the inspection requirements for the ductwork only Huntsman may proceed with Option 1 (2) inspect flexible and stationary ductwork according to 6311602(a)(2)(ii) as required at the specified
time-frames whether or not emissions are being actively controlled on every vessel that uses the common control device header Information provided by Huntsman indicates that the batch process vessels do not operate at the same time and may sit idle for days or weeks making it difficult to conduct quarterly inspections while all process vessels connected to the vacuum collection system are in operation Option 1 (2) allows for the periodic inspections to take place even when some of the process vessels are not in operation Approval of this option will also require additional recordkeeping indicating which process vessels were in operation during each inspection Approval of this option will further require that each mixing pot be operational at least once a year during quarterly inspections and at least once a quarter during weekly inspections Huntsman indicated that some mixing vessels in dual service are often used with materials without HAPs for extended time periods For such mixing vessels the inspections can be conducted while charging the vessel with material with or without HAP
3
Item 2-Filter Cartridges versus Fabric Filters Huntsman uses rigidfilter cartridges in its baghouses to control PM emissions Huntsman believes that these do not meet the definition 0 abricfilter in 40 CFR 6311607 and thereore may be excludedrom the annual inspection requirement 040 CFR 6311602(a)(2)(ii)(B)
Subpart CCCCCCC at 63 11602( a)(2)(ii)(B) requires conducting inspections of the rigid stationary ductwork for leaks and the interior of the dry particulate control unit for structural integrity and to determine the condition of the fabric filter (if applicable) every 12 months Fabric filter is defined at 6311607 as an air collection and control system that utilizes a bag filter to reduce the emissions of metal HAP and other particulate matter
Huntsman has a Farr Gold cartridge-type dry particulate control unit that serves a building with several mixers two ofwhich are subject to both subparts Huntsman states that since this dust collector uses sealed cartridge filters checking the condition of the fabric filter is not feasible Information provided by Huntsman indicates that preventative maintenance includes filter-unit replacement (as a whole) when required based on pressure differential established in Condition 5 of the SCAQMD Permit to Operate (Permit No F97279) We have determined that this is an acceptable alternative to checking the condition of the fabric filter during the dry particulate control unit inspection as an internal visual inspection of each individual cartridge is not feasible Please note that Huntsman is still required to conduct inspections of the rigid stationary ductwork for leaks and of the interior of the dry particulate control unit for structural integrity according to 6311602(a)(2)(ii)(B)
This response was coordinated with the Office of Compliance in the Office ofEnforcement and Compliance Assurance (OCOECA) and the Office of Air Quality Planning and Standards (OAQPS)
If you have further questions please feel free to contact Tfulde Wang ofmy staff at (415) 972-3990
Sincerely
Douglas K McDaniel Chief Enforcement Office Air Division
cc Dr Barry Wallerstein Executive Officer SCAQMD
4
Item 2-Filter Cartridges versus Fabric Filters Huntsman uses rigidfilter cartridges in its baghouses to control PM emissions Huntsman believes that these do not meet the definition 0 abricfilter in 40 CFR 6311607 and thereore may be excludedrom the annual inspection requirement 040 CFR 6311602(a)(2)(ii)(B)
Subpart CCCCCCC at 63 11602( a)(2)(ii)(B) requires conducting inspections of the rigid stationary ductwork for leaks and the interior of the dry particulate control unit for structural integrity and to determine the condition of the fabric filter (if applicable) every 12 months Fabric filter is defined at 6311607 as an air collection and control system that utilizes a bag filter to reduce the emissions of metal HAP and other particulate matter
Huntsman has a Farr Gold cartridge-type dry particulate control unit that serves a building with several mixers two ofwhich are subject to both subparts Huntsman states that since this dust collector uses sealed cartridge filters checking the condition of the fabric filter is not feasible Information provided by Huntsman indicates that preventative maintenance includes filter-unit replacement (as a whole) when required based on pressure differential established in Condition 5 of the SCAQMD Permit to Operate (Permit No F97279) We have determined that this is an acceptable alternative to checking the condition of the fabric filter during the dry particulate control unit inspection as an internal visual inspection of each individual cartridge is not feasible Please note that Huntsman is still required to conduct inspections of the rigid stationary ductwork for leaks and of the interior of the dry particulate control unit for structural integrity according to 6311602(a)(2)(ii)(B)
This response was coordinated with the Office of Compliance in the Office ofEnforcement and Compliance Assurance (OCOECA) and the Office of Air Quality Planning and Standards (OAQPS)
If you have further questions please feel free to contact Tfulde Wang ofmy staff at (415) 972-3990
Sincerely
Douglas K McDaniel Chief Enforcement Office Air Division
cc Dr Barry Wallerstein Executive Officer SCAQMD
4