La. Admin. Code tit. 33 § III-2149

Current through Register Vol. 50, No. 9, September 20, 2024

Section III-2149 - Limiting VOC Emissions from Batch Processing

A. Applicability

1. The provisions of this Subchapter apply to process vents associated with batch processing operations. This Subchapter shall apply to the stationary sources that emit, or have the potential to emit, 25 tons per year (TPY) or more of VOC in the affected parishes of Ascension, East Baton Rouge, Iberville, Livingston, and West Baton Rouge, or 50 TPY or more of VOC in the parishes of Calcasieu and Pointe Coupee. Once an operation is considered to be covered by this Subchapter, it shall be so considered ad infinitum. The scope of affected industries is limited to those industries in the following standard industrial classification (SIC) codes: 2821, 2833, 2834, 2861, 2865, 2869, 2879. Compliance with this rule shall be attained within a period of two years after promulgation. A facility that has become subject to this regulation as a result of a revision of the regulation shall comply with the requirements of this Section as soon as practicable, but in no event later than one year from the promulgation of the regulation revision. Any emission source that is subject to this rule and to the Waste Gas Disposal Rule (LAC 33:III.2115) shall comply with this rule only.

2. Exemptions from the provisions of this Subchapter, except for the reporting and recordkeeping requirements listed in Subsection G of this Section, are as follows:

a. combined vents from a batch process train which have a mass annual emission (AE) total as follows:

Volatility Range	Lower Limit of AE (1b/yr)
Low	26,014
Moderate	15,935
High	23,154

b. single unit operations that have mass AE of 500 lb/yr or less;

c. any batch process vent stream for which an existing combustion device or recovery device is employed to control VOC emissions is assumed to meet the 90 percent reduction requirement until the combustion device or recovery device is replaced for any reason. Such units shall be exempt from any monitoring, recordkeeping and reporting requirements under this Subchapter.

B. Definitions. Unless specifically defined in LAC 33:III.111, the terms in this Subchapter shall have the meanings commonly used in the field of air pollution control. Additionally, the following meanings apply, unless the context clearly indicates otherwise.

Aggregated- the summation of all process vents containing VOCs within a process.

Annual Mass Emissions Total- the sum of all VOC emissions (lb/yr), evaluated before control, from a vent. Annual mass emissions may be calculated from an individual process vent or groups of process vents by using emission estimation equations contained in Chapter 3 of the United States Environmental Protection Agency's (EPA) Batch Control Technology Guide (CTG), EPA-433/19-93-017 (November 1993) and then multiplying by the expected duration and frequency of the emission or groups of emissions over the course of a year. For processes that have been permitted, the annual mass emissions total should be based on the permitted levels, whether they correspond to the maximum design production potential or to the actual annual production estimate.

Average Flow Rate- the flow rate in standard cubic feet per minute averaged over the amount of time that VOCs are emitted during an emission event. For the evaluation of average flow rate from an aggregate of sources, the average flow rate is the weighted average of the average flow rates of the emission events and their annual venting time, or:

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Batch- a discontinuous process involving the bulk movement of material through sequential manufacturing steps. Mass, temperature, concentration, and other properties of a system vary with time. Batch processes are typically characterized as non-steady-state.

Batch Cycle- a manufacturing event of an intermediate or product from start to finish in a batch process.

Batch Process (for the purpose of determining RACT applicability)-the batch equipment assembled and connected by pipes, or otherwise operated in a sequence of steps, to manufacture a product in a batch fashion.

Batch Process Train- an equipment train that is used to produce a product or intermediate in batch fashion. A typical equipment train consists of equipment used for the synthesis, mixing, and purification of a material.

Control Devices- air pollution abatement devices, not devices such as condensers operating under reflux conditions, which are required for processing.

Emissions before Control- the emissions total prior to the application of a control device, or if no control device is used, the emissions total. No credit for discharge of VOCs into wastewater should be considered when the wastewater is further handled or processed with the potential for VOCs to be emitted to the atmosphere.

Emission Events- discrete venting episodes that may be associated with a single unit of operation. For example, a displacement of vapor resulting from the charging of a vessel with VOC will result in a discrete emission event that will last through the duration of the charge and will have an average flow rate equal to the rate of the charge. If the vessel is then heated, there will be another discrete emission event resulting from the expulsion of expanded vessel vapor space. Both emission events may occur in the same vessel or unit operation.

Primary Fuel- the fuel that provides the principal heat input to a device. To be considered primary, the fuel must be able to sustain operation without the addition of other fuels.

Process Vent- a gas stream containing greater than 500 ppm(v) total VOC that is discharged from a batch process. Process vents include gas streams that are discharged directly to the atmosphere or are discharged to the atmosphere after diversion through a recovery device. Process vents exclude relief valve discharges, leaks from equipment, vents from storage vessels, vents from transfer/loading operations, and vents from wastewater. Process gaseous streams that are used as primary fuels are also excluded. The lines that transfer such fuels to a plant fuel gas system are not considered to be vents.

Semi-Continuous- conduction of operations on a steady- state mode but only for finite durations (in excess of eight hours minimum) during the course of a year. For example, a steady-state distillation operation that functions for one month would be considered semi-continuous.

Unit Operations- those discrete processing steps that occur within distinct equipment that are used to prepare reactants, facilitate reactions, separate and purify products, and recycle materials.

Vent- a point of emission from a unit operation. Typical process vents from batch processes include condenser vents, vacuum pumps, steam ejectors, and atmospheric vents from reactors and other process vessels. Vents also include relief valve discharges. Equipment exhaust systems that discharge from unit operations also would be considered process vents.

Volatility- low volatility materials are defined as those which have a vapor pressure less than or equal to 75 mm Hg at 20 ° C, moderate volatility materials have a vapor pressure greater than 75 and less than or equal to 150 mm Hg at 20 ° C, and high volatility materials have a vapor pressure greater than 150 mm Hg at 20 ° C. To evaluate VOC volatility for single unit operations that service numerous VOCs or for processes handling multiple VOCs, the weighted average volatility can be calculated from the total amount of each VOC emitted in a year and the individual component vapor pressure, as shown in the following equation.

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C. Control Requirements

1. The VOC mass emission rate from individual process vents or for process vent streams in aggregate within a batch process shall be reduced by 90 percent if the actual average flow rate value (in the units of scfm) is below the value of FR calculated using the applicable RACT equation for the volatility range (low, moderate or high) of the material being emitted when the annual mass emission total, in the units of pounds per year, are input. The RACT equations, specific to volatility, are as follows.

FR = 0.07 (AE) - 1821	(Low Volatility)
FR = 0.031 (AE) - 494	(Moderate Volatility)
FR = 0.013 (AE) - 301	(High Volatility)

2. For aggregate streams within a process, the control requirements must be evaluated with the successive ranking scheme described below until control of a segment of unit operations is required or until all unit operations have been eliminated from the process pool.

a. If, for the process vent streams in aggregate, the value of FR calculated using the applicable RACT equation is negative (i.e., less than zero), then the process is exempt from the control requirements and there is no need to proceed with the successive ranking scheme described in Subparagraph C.2.f of this Section. This would occur if the mass annual emission rates are below the lower limits specified in Subparagraph A.2.a of this Section.

b. If, for the process vent streams in aggregate, the actual average flow rate value (in the units of scfm) is below the value of FR calculated using the applicable RACT equation, then the overall emissions from the batch process must be reduced by 90 percent and there is no need to proceed with the successive ranking scheme described in Subparagraph C.2.f of this Section. The owner or operator has the option of selecting which unit operations are to be controlled and to what levels so long as the overall control meets the specified level of 90 percent. Single units that are below the exemption level specified in Subparagraph A.2.b of this Section would not have to be controlled even if all units should qualify for the exemption.

c. If, for the process vent streams in aggregate, the actual average flow rate value (in the units of scfm) is greater than the value of FR calculated using the applicable RACT equation (and the calculated value of FR is a positive number), then the control requirements must be evaluated with the successive ranking scheme described in Subparagraph C.2.f of this Section until control of a segment of unit operations is required or until all unit operations have been eliminated from the process pool. Single units that are below the exemption level specified in Subparagraph A.2.b of this Section would not have to be included in the rankings and would not have to be controlled even if all units should qualify for the exemption.

d. Sources that will be required to be controlled to the level specified by the RACT (90 percent) will have an average flow rate that is below the flow rate specified by the RACT equation (when the source's annual emission total is input). The applicability criterion is implemented on a two-tier basis. First, single pieces of batch equipment corresponding to distinct unit operations shall be evaluated over the course of an entire year, regardless of what materials are handled or what products are manufactured in them. Second, equipment shall be evaluated as an aggregate if it can be linked together based on the definition of a process.

e. To determine applicability of a RACT option in the aggregation scenario, all the VOC emissions from a single process shall be summed to obtain the annual mass emission total, and the weighted average flow rates from each process vent in the aggregation shall be used as the average flow rate.

f. All unit operations in the batch process, as defined for the purpose of determining RACT applicability, shall be ranked in ascending order according to their ratio of annual emission (lb/yr) divided by average flow rate (in scfm). Sources with the smallest ratios shall be listed first. This list of sources constitutes the "pool" of sources within a batch process. The annual emission total and average flow rate of the pool of sources shall then be compared against the RACT equations to determine whether control of the pool is required. If control is not required after the initial ranking, unit operations having the lowest annual emissions/average flow rates ratios shall then be eliminated one by one, and the characteristics of annual emission and average flow rate for the remaining pool of equipment will have to be evaluated with each successive elimination of a source from the pool. Control of the unit operations remaining in the pool to the specified level shall be required once the aggregated characteristics of annual emissions and average flow rates have met the specified RACT. The owner or operator has the option of selecting which unit operations are to be controlled and to what levels so long as the overall control meets the specified level of 90 percent.

D. Measuring Emissions and Flow Rate

1. Determination of Uncontrolled Annual Emission Total. Determination of the annual mass emissions total may be achieved by engineering estimates of the uncontrolled emissions from a process vent or group of process vents within a batch process train and multiplying by the potential or permitted number of batch cycles per year. Engineering estimates should follow the guidance provided in the EPA Batch CTG. Alternatively, if an emissions measurement is to be used to measure vent emissions, the measurement must conform with the requirements of measuring incoming mass flow rate of VOCs as described in Subparagraph E.2.b and Clauses E.2.c.ii and iii of this Section.

2. Determination of Average Flow Rate. To obtain a value for average flow rate, the owners or operators may elect to measure the flow rates or to estimate the flow rates using suitable estimation methods (e.g., EPA document EPA-453/R4-93-017, November 1993). For existing manifolds, the average flow rate is often the flow that was assumed in the design.

E. Performance Testing

1. For the purpose of demonstrating compliance with the control requirements of this Subchapter, the process unit shall be run at full operating conditions and flow rates during any performance test.

2. The following methods in LAC 33:III.Chapter 60, shall be used to comply with the percent reduction efficiency requirement listed in Subsection C of this Section.

a. Method 1 or Method 1A in 40 CFR Part 60, Appendix A, as incorporated by reference at LAC 33:III.3003, as appropriate, shall be used for selection of the sampling sites if the flow rate measuring device is a rotameter. No traverse is necessary when the flow measuring device is an ultrasonic probe. The control device inlet sampling sites for determination of vent stream VOC composition reduction efficiency shall be prior to the control device and after the control device.

b. Method 2, Method 2A, Method 2C, or Method 2D in 40 CFR Part 60, Appendix A, as incorporated by reference at LAC 33:III.3003, as appropriate, shall be used for determination of gas stream volumetric flow rate. Flow rate measurements should be made continuously.

c. Method 25A or Method 18 in 40 CFR Part 60, Appendix A, as incorporated by reference at LAC 33:III.3003, if applicable, shall be used to determine the concentration of VOC in the control device inlet and outlet.

i. The sampling time for each run will be the entire length of the batch cycle in which readings will be taken continuously if Method 25A ( 40 CFR Part 60, Appendix A, as incorporated by reference at LAC 33:III.3003) is used or as often as is possible using Method 18 ( 40 CFR Part 60, Appendix A, as incorporated by reference at LAC 33:III.3003), with a maximum of one-minute intervals between measurements throughout the batch cycle.

ii. The emission rate of the process vent or inlet to the control device shall be determined by combining continuous concentration and flow rate measurements at simultaneous points throughout the batch cycle.

iii. The mass flow rate of the control device outlet shall be obtained by combining continuous concentration and flow rate measurements at simultaneous points throughout the batch cycle.

iv. The efficiency of the control device shall be determined by integrating the mass flow rates obtained in Clauses E.2.c.ii and iii of this Section over the time of the batch cycle and dividing the difference in inlet and outlet mass flow totals by the inlet mass flow total.

F. Monitoring Requirements

1. The owner or operator of an affected facility that uses an incinerator to seek to comply with the VOC emission limit specified under Subsection C of this Section shall install, calibrate, maintain, and operate according to manufacturer's specifications a temperature monitoring device equipped with a continuous recorder and having an accuracy of +-0.5°C, or alternately +-1 percent, as follows.

a. Where an incinerator other than a catalytic incinerator is used, a temperature monitoring device shall be installed in the firebox or in the ductwork immediately downstream of the firebox before any substantial heat exchange is encountered.

b. Where a catalytic incinerator is used, temperature monitoring devices shall be installed in the gas stream immediately before and after the catalyst bed.

2. The owner or operator of an affected facility that uses a flare to seek to comply with Subsection C of this Section shall install, calibrate, maintain, and operate according to manufacturer's specifications a heat sensing device, such as an ultra-violet beam sensor or thermocouple, at the pilot light to indicate continuous presence of a flame.

3. The owner or operator of an affected facility that uses an absorber to comply with Subsection C of this Section shall install, calibrate, maintain, and operate according to manufacturer's specifications the following equipment:

a. a scrubbing liquid temperature monitoring device having an accuracy of +-1 percent of the temperature being monitored expressed in degrees Celsius or +-0.02 of a specific gravity unit, each equipped with a continuous recorder; or

b. an organic monitoring device used to indicate the concentration level of organic compounds exiting the recovery device based on a detection principle such as infrared photoionization or thermal conductivity, each equipped with a continuous recorder.

4. The owner or operator of an affected facility that uses a condenser or refrigeration system to comply with Subsection C of this Section shall install, calibrate, maintain, and operate according to manufacturer's specifications the following equipment:

a. a condenser exit temperature monitoring device equipped with a continuous recorder and having an accuracy of +- 1 percent of the temperature being monitored expressed in degrees Celsius or +-0.5°C, whichever is greater; or

5. The owner or operator of an affected facility that uses a carbon adsorber to comply with Subsection C of this Section shall install, calibrate, maintain, and operate according to manufacturers specifications the following equipment:

a. an integrating steam flow monitoring device having an accuracy of +-10 percent and a carbon bed temperature monitoring device having an accuracy of +-1 percent of the temperature being monitored expressed in degrees Celsius or +-0.5°C, whichever is greater, both equipped with a continuous recorder; or

c. where a pressure swing adsorption (PSA) unit is the final recovery device in the recovery system the temperature of the bed near the inlet and near the outlet shall be continuously recorded. The temperature monitoring devices shall have an accuracy of +-1 percent of the temperature being measured or +-0.5°C. Proper operation shall be evidenced by a uniform pattern of temperature increases and decreases near the inlet and a fairly constant temperature near the outlet.

G. Reporting/Recordkeeping Requirements

1. Each batch processing operation subject to this Subchapter shall keep records for a minimum of two years of the following emission stream parameters for each process vent contained in the batch process:

a. the annual mass emission total and documentation verifying these values; if emission estimation equations are used, the documentation shall be the calculations coupled with the expected or permitted (if available) number of emission events per year. If the annual mass emission total is obtained from measurement in accordance with Subsection E of this Section, this data should be available;

b. the average flow rate in standard cubic feet per minute (scfm) and documentation verifying these values.

2. Each batch processing operation subject to this Subchapter shall keep records of the following parameters required to be measured during a performance test required under Subsection E of this Section and required to be monitored under Subsection F of this Section:

a. where an owner or operator subject to the provisions of this Section seeks to demonstrate compliance with Subsection C of this Section through use of either a thermal or catalytic incinerator, the average firebox temperature of the incinerator (or the average temperature upstream and downstream of the catalyst bed for a catalytic incinerator), measured continuously and averaged over the same time period as the performance testing;

b. where an owner or operator subject to the provisions of this Section seeks to demonstrate compliance with Subsection C of this Section through use of a smokeless flare, flare design, (i.e., steam-assisted, air-assisted or nonassisted), all visible emission readings, heat content determinations, flow rate measurements, and exit velocity determinations made during the performance test; continuous flare pilot flame monitoring; and all periods of operations during which the pilot flame is absent;

c. where an owner or operator subject to the provisions of this Section seeks to demonstrate compliance with Subsection C of this Section:

i. where an absorber is the final control device, the exit specific gravity (or alternative parameter which is a measure of the degree of absorbing liquid saturation, if approved by the administrative authority*) and average exit temperature of the absorbing liquid measured continuously and averaged over the same time period as the performance testing (both measured while the vent stream is routed normally); or

ii. where a condenser is the control device, the average exit (product side) temperature measured continuously and averaged over the same time period as the performance testing while the vent stream is routed normally; or

iii. where a carbon adsorber is the control device, the total steam mass flow measured continuously and averaged over the same time period as the performance test (full carbon bed cycle), temperature of the carbon bed after regeneration (and within 15 minutes of completion of any cooling cycle(s), and duration of the carbon bed steaming cycle (all measured while the vent stream is routed normally); or

iv. the concentration level or reading indicated by an organic monitoring device at the outlet of the absorber, condenser, or carbon adsorber, measured continuously and averaged over the same time period as the performance testing while the vent stream is routed normally; or

v. where a pressure swing adsorption (PSA) unit is the final recovery device in the recovery system the temperature of the bed near the inlet and near the outlet shall be continuously monitored and recorded. The temperature monitoring devices shall have an accuracy of +-1 percent of the temperature being measured or +-0.5°C. Proper operation shall be evidenced by a uniform pattern of temperature increases and decreases near the inlet and a fairly constant temperature near the outlet.

La. Admin. Code tit. 33, § III-2149

Promulgated by the Department of Environmental Quality, Office of Air Quality and Radiation Protection, Air Quality Division, LR 21:387 (April 1995), amended LR 22:1212 (December 1996), LR 23:1507 (November 1997), amended by the Office of Environmental Assessment, Environmental Planning Division, LR 30:747 (April 2004).

AUTHORITY NOTE: Promulgated in accordance with R.S. 30:2054.