Analytical Laboratories - Potential and Restricted Emissions Kevin Tyson, Air Quality Analyst Wednesday, December 10, 2014

Pollutants Volatile Organic Compounds (VOCs) – any compound of carbon which participates in atmospheric photochemical reactions. Except for exempted compounds (40 CFR (s) ) Hazardous Air Pollutants (HAPs) – federally listed (section 112 (b) of the Clean Air Act) pollutants that cause or may cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental and ecological effects. Halogenated Organic Compounds (HOCs) - any compound of carbon (excluding metallic carbides or carbonates and ammonium carbonate) combined with a halogen. 2

Federal Potential to Emit (PTE) the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of fuel combusted, stored or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable. Federally enforceable means legal enforceability (a permit condition) and practical enforceability (ability to monitor and keep records with a short enough period to have meaning) 3

Potential To Emit For Labs – Worst Case operating scenario – Operating at maximum capacity as currently equipped – PTE may be above major source levels – Restrictions can cap emissions to limit PTE to below major source levels 4

Major Source 50 tons of VOC 10 tons of any single HAP 25 tons of all HAPs combined 5

Do you Know your Emissions? Amount of all chemicals used – Recordkeeping of monthly usage – Purchasing records as a way to estimate historical usage – MSDS sheets should have VOC content and HAP components listed Conservative estimate is all usage is emitted to the air – Chemical waste can be subtracted from usage if each chemical is specifically tracked 6

Sample Recordkeeping 7 Chemical Name: Methylene Chloride MonthAmount Used gallonsVOC ContentSpecific GravityPounds EmittedTons January11100% February15100% Each VOC containing compound needs to be tracked Each individual HAP needs to be tracked

Restricting Emissions 8 mited-emissions-record-keeping-and-reporting.html mited-emissions-record-keeping-and-reporting.html 25% or 50% Emissions Cap – Restrict emissions to less than 25 tons VOC, 12.5 tons of total HAPs, and 5 tons of your largest single HAP Restricted Emission Status (RES) – Cap Emissions below Major thresholds – More complicated and may want to meet to discuss

25%/50% Form 9 e/approvals/50-or-25-facility-emissions-cap- notification-form.html e/approvals/50-or-25-facility-emissions-cap- notification-form.html q/aq2550nf.doc q/aq2550nf.doc Let’s Fill it out

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