Mr. Laumeyer Avery Dennison MFD 270 West Meadow Place Lowell, Indiana 46356 Re: 089-12713 Minor Source Modification to: Part 70 permit No.: 089-7463-00407 Dear Mr. Laumeyer: Avery Dennison MFD was issued Part 70 operating permit 089-7463-00407 on July 14, 1999 for a pressure sensitive vinyl coated products manufacturing operation. An application to modify the source was received on September 13, 2000. Pursuant to 326 IAC 2-7-10.5 the following emission units are approved for construction at the source: (a) One coating head, identified as CH-1 with a maximum capacity of 23,063 square feet per hour, using one (1) existing 9.8 MMBtu/hr natural gas fired thermal oxidizer as control, and exhausting to existing stack S-2. The following construction conditions are applicable to the proposed project: General Construction Conditions 1. The data and information supplied with the application shall be considered part of this source modification approval. Prior to any proposed change in construction which may affect the potential to emit (PTE) of the proposed project, the change must be approved by the Office of Air Management (OAM). 2. This approval to construct does not relieve the permittee of the responsibility to comply with the provisions of the Indiana Environmental Management Law (IC 13-11 through 13-20; 13-22 through 13-25; and 13-30), the Air Pollution Control Law (IC 13-17) and the rules promulgated thereunder, as well as other applicable local, state, and federal requirements. 3. Effective Date of the Permit Pursuant to IC 13-15-5-3, this approval becomes effective upon its issuance. 4. Pursuant to 326 IAC 2-1.1-9 and 326 IAC 2-7-10.5(I), the Commissioner may revoke this approval if construction is not commenced within eighteen (18) months after receipt of this approval or if construction is suspended for a continuous period of one (1) year or more. 5. All requirements and conditions of this construction approval shall remain in effect unless modified in a manner consistent with procedures established pursuant to 326 IAC 2. 6. Pursuant to 326 IAC 2-7-10.5(l) the emission units constructed under this approval shall not be placed into operation prior to revision of the source’s Part 70 Operating Permit to incorporate the required operation conditions.
Transcript
Mr. LaumeyerAvery Dennison MFD270 West Meadow PlaceLowell, Indiana 46356
Avery Dennison MFD was issued Part 70 operating permit 089-7463-00407 on July 14, 1999 fora pressure sensitive vinyl coated products manufacturing operation. An application to modify the sourcewas received on September 13, 2000. Pursuant to 326 IAC 2-7-10.5 the following emission units areapproved for construction at the source:
(a) One coating head, identified as CH-1 with a maximum capacity of 23,063 square feet perhour, using one (1) existing 9.8 MMBtu/hr natural gas fired thermal oxidizer as control,and exhausting to existing stack S-2.
The following construction conditions are applicable to the proposed project:
General Construction Conditions1. The data and information supplied with the application shall be considered part of this
source modification approval. Prior to any proposed change in construction which mayaffect the potential to emit (PTE) of the proposed project, the change must be approvedby the Office of Air Management (OAM).
2. This approval to construct does not relieve the permittee of the responsibility to complywith the provisions of the Indiana Environmental Management Law (IC 13-11 through13-20; 13-22 through 13-25; and 13-30), the Air Pollution Control Law (IC 13-17) and therules promulgated thereunder, as well as other applicable local, state, and federalrequirements.
3. Effective Date of the PermitPursuant to IC 13-15-5-3, this approval becomes effective upon its issuance.
4. Pursuant to 326 IAC 2-1.1-9 and 326 IAC 2-7-10.5(I), the Commissioner may revoke thisapproval if construction is not commenced within eighteen (18) months after receipt ofthis approval or if construction is suspended for a continuous period of one (1) year ormore.
5. All requirements and conditions of this construction approval shall remain in effectunless modified in a manner consistent with procedures established pursuant to 326 IAC2.
6. Pursuant to 326 IAC 2-7-10.5(l) the emission units constructed under this approval shallnot be placed into operation prior to revision of the source’s Part 70 Operating Permit toincorporate the required operation conditions.
The proposed operating conditions applicable to these emission units are attached to thisSource Modification approval. These proposed operating conditions shall be incorporated into the Part70 operating permit as a significant permit modification in accordance with 326 IAC 2-7-12.
This decision is subject to the Indiana Administrative Orders and Procedures Act - IC 4-21.5-3-5. Pursuant to Contract No. A305-0-00-36, IDEM, OAM has assigned the processing of this application toEastern Research Group, Inc., (ERG). Therefore, questions should be directed to Mike Pring, ERG,P.O. Box 2010, Morrisville, North Carolina 27560, or call (919) 468-7840 to speak directly to Mr. Pring.Questions may also be directed to Duane Van Laningham at IDEM, OAM, 100 North Senate Avenue,P.O. Box 6015, Indianapolis, Indiana, 46206-6015, or call (800) 451-6027, press 0 and ask for DuaneVan Laningham, or extension 3-6878, or dial (317) 233-6878.
Sincerely,
Paul Dubenetzky, ChiefPermits BranchOffice of Air Management
Attachments
ERG/MP
cc: File - Lake CountyU.S. EPA, Region V Lake County Health DepartmentNorthwest Regional OfficeAir Compliance Section Inspector - Ramesh TejujaCompliance Data Section - Karen NowakAdministrative and Development - Janet MobleyTechnical Support and Modeling - Michele Boner
PART 70 OPERATING PERMITOFFICE OF AIR MANAGEMENT
Avery Dennison MFD270 West Meadow Place
Lowell, Indiana 46356
(herein known as the Permittee) is hereby authorized to operate subject to the conditionscontained herein, the source described in Section A (Source Summary) of this permit.
This permit is issued in accordance with 326 IAC 2 and 40 CFR Part 70 Appendix A andcontains the conditions and provisions specified in 326 IAC 2-7 and 326 IAC 2-1-3.2 as requiredby 42 U.S.C. 7401, et. seq. (Clean Air Act as amended by the 1990 Clean Air Act Amendments),40 CFR Part 70.6, IC 13-15 and IC 13-17.
Operation Permit No.: T089-7463-00407
Issued by:Janet G. McCabe, Assistant CommissionerOffice of Air Management
Issuance Date: July 14, 1999
First Minor Source Modification 089-12713 Pages Affected: 3, 4, 5, 28, 28a, 29, 31 31a, 32,32a, 39a
Issued by:Paul Dubenetzky, Branch Chief Office of Air Management
Issuance Date:
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Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6]C.15 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3]C.16 Compliance Monitoring Plan - Failure to Take Response Steps [326 IAC 2-7-5]C.17 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5]
Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]C.18 Emission Statement [326 IAC 2-7-5(3)(C)(iii)] [326 IAC 2-6] [326 IAC 2-7-19]C.19 Monitoring Data Availability [326 IAC 2-7-6(1)] [326 IAC 2-7-5(3)]C.20 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6]C.21 General Reporting Requirements [326 IAC 2-7-5(3)(C)]
Stratospheric Ozone ProtectionC.22 Compliance with 40 CFR 82 and 326 IAC 22-1
D.1 FACILITY OPERATION CONDITIONS - Two (2) pressure-sensitive vinyl coating lines andone (1) pressure-sensitive vinyl/paper coating line
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SECTION A SOURCE SUMMARY
This permit is based on information requested by the Indiana Department of Environmental Management(IDEM), Office of Air Management (OAM). The information describing the source contained in conditionsA.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, thePermittee should be aware that a physical change or a change in the method of operation that mayrenderthis descriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtainadditional permits or seek modification of this permit pursuant to 326 IAC 2, or change other applicablerequirements presented in the permit application.
A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)]The Permittee owns and operates a stationary vinyl coated manufacturing operation.
Responsible Official: Heinz Pichler, Vice President, Worldwide GraphicsSource Address: 270 West Meadow Place, Lowell, Indiana 46356Mailing Address: 270 West Meadow Place, Lowell, Indiana 46356SIC Code: 3089County Location: LakeCounty Status: Severe Nonattainment for Ozone,
Attainment for all other criteria pollutantsSource Status: Part 70 Permit Program
Major Source, under Emission Offset Rules;Major Source, Section 112 of the Clean Air Act
A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)]This stationary source consists of the following emission units and pollution control devices:
(1) One (1) pressure-sensitive vinyl rollcoating line, installed on July 1, 1980, identified asL-1, with maximum capacity of 24,750 square feet per hour, using one (1) 6.9 millionBritish thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOCcontrol, exhausting to one (1) stack (S-1);
(2) One (1) pressure-sensitive vinyl rollcoating line, installed on December 1, 1984, and one(1) surface coating head (CH-1), installed in 2001, identified together as L-2, withmaximum capacity of 23,063 square feet per hour, using one (1) 9.8 million Britishthermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-2); and
(3) One (1) pressure-sensitive vinyl/paper rollcoating line, installed on June 1, 1988,identified as L-3, with maximum capacity of 30,750 square feet per hour, using one (1)11.2 million British thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizeras VOC control, exhausting to one (1) stack (S-3).
A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)][326 IAC 2-7-5(15)]This stationary source also includes the following insignificant activities which are specificallyregulated, as defined in 326 IAC 2-7-1(21):
(1) VOC and HAP storage tanks with capacities less than or equal to 1,000 gallons andannual throughputs less than 12,000 gallons;
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SECTION D.1 FACILITY OPERATION CONDITIONS
Facility Description [326 IAC 2-7-5(15)]
(1) One (1) pressure-sensitive vinyl rollcoating line, installed on July 1, 1980, identified as L-1,with maximum capacity of 24,750 square feet per hour, using one (1) 6.9 million Britishthermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-1);
(2) One (1) pressure-sensitive vinyl rollcoating line, installed on December 1, 1984, and one (1)surface coating head (CH-1), installed in 2001, identified together as L-2, with maximumcapacity of 23,063 square feet per hour, using one (1) 9.8 million British thermal units perhour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control, exhausting to one (1)stack (S-2); and
(3) One (1) pressure-sensitive vinyl/paper rollcoating line, installed on June 1, 1988, identified asL-3, with maximum capacity of 30,750 square feet per hour, using one (1) 11.2 million Britishthermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-3).
Emission Limitations and Standards [326 IAC 2-7-5(1)]
D.1.1 Volatile Organic Compounds (VOC) [326 IAC 8-2-5](a) Pursuant to 326 IAC 8-2-5 (Paper Coating Operations), no owner or operator of a facility
engaged in the surface coating of pressure sensitive vinyl or paper may cause allow, orpermit the discharge into the atmosphere of any volatile organic compound (VOC) inexcess of two and nine-tenths (2.9) pounds per gallon of coating, excluding water,delivered to the coating applicator.
(b) When operating the thermal oxidizer to achieve the limit for 326 IAC 8-2-5, 2.9 poundsof VOC emitted to the atmosphere per gallon of coating less water delivered to theapplicator, the thermal oxidizer for line L-3 shall maintain a minimum 95% captureefficiency and 95% destruction efficiency. These efficiencies and the use of the thermaloxidizer are required by 326 IAC 8-1-2(a)(2). Based upon 326 IAC 8-1-2(c) and theoverall control efficiency of 90%, the VOC content of the coating shall not exceed 47.85pounds per gallon of coating solids delivered to the applicator.
D.1.2 Volatile Organic Compounds (VOC) [326 IAC 12] [40 CFR 60.440, Subpart RR]Pursuant to 40 CFR 60.442(a)(2), the Permittee shall demonstrate a ninety percent (90%)overall Volatile Organic Compound (VOC) emission reduction as calculated over a calendarmonth for the one (1) pressure-sensitive vinyl rollcoating line (L-2) and the one (1) pressure-sensitive vinyl/paper rollcoating line (L-3).
D.1.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)]A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, ofthis permit, is required for this facility and any control devices.
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Compliance Determination Requirements
D.1.4 Volatile Organic Compounds and HAPs [326 IAC 2-3] [326 IAC 2-4.1]Input of VOC and HAP to the surface coating head (CH-1) shall be limited to less than fivehundred (500) tons per year. At a control efficiency of at least 98% for the thermal oxidizer,these usage limits shall effectively limit emissions of VOC and HAP to less than ten (10) tons peryear. Compliance with these limits shall make the Emission Offset and New source ToxicsControl rules not applicable.
(a) To determine compliance with § 60.442(a)(2), the Permittee shall calculate the requiredoverall Volatile Organic Compound (VOC) emission reduction for the one (1) pressure-sensitive vinyl rollcoating line (L-2) and the one (1) pressure-sensitive vinyl/paperrollcoating line (L-3) according to the following equation:
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Rq = (G - 0.20) / G * 100
where:
G = the calculated weighted average pound of Volatile Organic Compound(VOC) per pound of coating solids applied each calendar month.
If Rq is less than or equal to 90 percent, then the required overall Volatile OrganicCompound (VOC) emission reduction is Rq . If Rq is greater than 90 percent, then therequired overall Volatile Organic Compound (VOC) emission reduction is 90 percent.
(b) The Permittee shall determine calendar monthly compliance for the one (1) pressure-sensitive vinyl rollcoating line (L-2) and the one (1) pressure-sensitive vinyl/paperrollcoating line (L-3) by comparing the monthly required overall Volatile OrganicCompound (VOC) emission reduction Rq to the overall Volatile Organic Compound(VOC) emission reduction demonstrated in the most recent performance test whichcomplied with § 60.442(a)(2). If the monthly required overall Volatile Organic Compound(VOC) emission reduction is less than or equal to the overall Volatile Organic Compound(VOC) reduction of the most recent performance test, the affected facility is incompliance with § 60.442(a)(2).
(c) The Permittee shall continuously record the destruction device combustion temperaturefor the one (1) pressure-sensitive vinyl rollcoating line (L-2) and the one (1) pressure-sensitive vinyl/paper rollcoating line (L-3) during coating operations for thermalincineration destruction devices. The Permittee shall record all 3-hour periods (duringactual coating operations) during which the average temperature of the device is morethan 28 " C (50 " F) below the average temperature of the device during the most recentperformance test complying with § 60.442(a)(2).
(d) After the initial performance test required for the one (1) pressure-sensitive vinylrollcoating line (L-2) and the one (1) pressure-sensitive vinyl/paper rollcoating line (L-3)under § 60.8, compliance with the Volatile Organic Compound (VOC) emissionreduction limitation and percentage reduction requirements under § 60.442 is based onthe average emission reduction for one calendar month. A separate compliance test iscompleted at the end of each calendar month after the initial performance test, and anew calendar month’s average Volatile Organic Compound (VOC) emission reduction iscalculated to show compliance with the standard.
(e) Startups and shutdowns are normal operations for the one (1) pressure-sensitive vinylrollcoating line (L-2) and the one (1) pressure-sensitive vinyl/paper rollcoating line (L-3).Emissions from these operations are to be included when determining if the standardspecified at § 60.442(a)(2) is being attained.
D.1.6 Testing Requirements [40 CFR 60.444, Subpart RR] (a) Pursuant to 40 CFR 60.444, Subpart RR, the performance test for the one (1) pressure-
sensitive vinyl rollcoating line (L-2) and the one (1) pressure-sensitive vinyl/paperrollcoating line (L-3) shall be determined by averaging the results of three test runs asspecified in § 60.8(f).
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(1) Determine for each affected facility prior to each test run the weighted averagemass of Volatile Organic Compound (VOC) per mass of coating solids appliedbeing used at the facility. The weighted average shall be determined asspecified in § 60.443(a). In this application, the quantities of Wci , Wsi , and Mci
shall be determined for the time period of each test run and not a calendarmonth as specified in § 60.441.
where:Qbi = the volumetric flow rate of each effluent gas stream (I) entering
the emission control device, in dry standard cubic feet per hour. Cbi = the concentration of Volatile Organic Compound (VOC) (carbon
equivalent) in each gas stream (I) entering the emission controldevice, in parts per million by volume.
Qaj = the volumetric flow rate of each effluent gas stream (j) exiting theemission control device, in dry standard cubic feet per hour.
Caj = the concentration of Volatile Organic Compound (VOC) (carbonequivalent) in each gas stream (j) exiting the emission controldevice, in parts per million by volume.
Qfk = the volumetric flow rate of each effluent gas stream (k) emitted tothe atmosphere, in dry standard cubic feet per hour.
Cfk = the concentration of Volatile Organic Compound (VOC) (carbonequivalent) in each gas stream (k) emitted directly to theatmosphere, in parts per million by volume.
(A) The Permittee shall construct the overall Volatile Organic Compound(VOC) emission reduction systems to that all volumetric flow rates andtotal Volatile Organic Compound (VOC) emissions can be accuratelydetermined by the applicable test method and procedures specified in§ 60.446(b).
(B) The Permittee shall construct a temporary total enclosure around thecoating line applicator and flashoff area during the performance test forthe purpose of capturing fugitive Volatile Organic Compound (VOC)emissions. If a permanent total enclosure exists in the affected facilityprior to the performance test and the Commissioner is satisfied that theenclosure is totally capturing fugitive Volatile Organic Compound (VOC)emissions, then no additional total enclosure will be required for theperformance test.
(C) For each affected facility where the value of R is greater than or equal tothe value of Rq calculated in § 60.443(b), compliance with §60.442(a)(2) is demonstrated.
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(b) Pursuant to 40 CFR 60.446, Subpart RR:
(1) Reference Test Method 25 shall be used to determine the Volatile OrganicCompound (VOC) concentration in parts per million by volume, of each effluentgas stream entering and exiting the solvent destruction device or its equivalent,and each effluent gas stream emitted directly to the atmosphere for the one (1)pressure-sensitive vinyl rollcoating line (L-2) and the one (1) pressure-sensitivevinyl/paper rollcoating line (L-3). Reference Methods 1, 2, 3, and 4 shall be usedto determine the sampling location, volumetric flow rate, molecular weight, andmoisture of all sampled gas streams. For Reference Method 25 and 25A, thesampling time for each of three runs must be at least 1 hour. The minimumsampling volume must be 0.003 dscm except that shorter sampling times orsmaller volumes, when necessitated by process variables or other factors, maybe approved by the Commissioner.
(2) If the Permittee can demonstrate to the Commissioner’s satisfaction that testingof representative stacks yields results comparable to those that would beobtained by testing all stacks, the Commissioner will approve testing ofrepresentative stacks on a case-by-case basis.
D.1.7 Volatile Organic Compounds (VOC)Compliance with the VOC content and usage limitations contained in Condition D.1.1 shall bedetermined pursuant to 326 IAC 8-1-4(a)(3)(A) and 326 IAC 8-1-2(a)(7) using formulation datasupplied by the coating manufacturer. IDEM, OAM, reserves the authority to determinecompliance using Method 24 in conjunction with the analytical procedures specified in 326IAC 8-1-4.
D.1.8 Volatile Organic Compounds (VOC) and HAPs [326 IAC 2-3] [326 IAC 2-4.1]Compliance with the VOC and HAP usage limitations contained in Condition D.1.4 shall bedetermined using formulation data supplied by the coating manufacturer.
D.1.9 Volatile Organic Compound (VOC) [40 CFR 60.445, Subpart RR]Pursuant to 40 CFR 60.445, the Permittee shall install, calibrate, maintain, and operate amonitoring device which continuously indicates and records the temperature of the solventdestruction device’s exhaust gases for the one (1) pressure-sensitive vinyl rollcoating line (L-2)and the one (1) pressure-sensitive vinyl/paper rollcoating line (L-3). The monitoring device shallhave an accuracy of the greater of ± 0.75 percent of the temperature being measured expressedin degrees Celsius or ± 2.5 N C.
D.1.10 Thermal OxidizerTo ensure compliance with Conditions D.1.1 and D.1.2, the Line 2 and Line 3 thermal oxidizersshall operate at all times that the two (2) rollcoating lines are operated. When operating, thethermal incinerator shall maintain a minimum operating temperature of 1,083 o F for Line 2 and1,273 BF for Line 3 or a temperature, fan amperage, or duct velocity determined in thecompliance tests to maintain an overall 90% control efficiency.
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Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]
D.1.11 Record Keeping Requirements(a) To document compliance with Condition D.1.1 and D.1.4, the Permittee shall maintain
records in accordance with (1) through (6) below. Records maintained for (1) through (6)shall be taken daily and shall be complete and sufficient to establish compliance with theVOC usage limits and/or the VOC emission limits established in Condition D.1.1.
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(1) The amount and VOC content of each coating material and solvent used.Records shall include purchase orders, invoices, and material safety datasheets (MSDS) necessary to verify the type and amount used. Solvent usagerecords shall differentiate between those added to coatings and those used ascleanup solvents;
(2) A log of the dates of use;
(3) The volume weighted VOC content of the coatings used for each day;
(4) The cleanup solvent usage for each day;
(5) The total VOC usage for each day; and
(6) The weight of VOCs emitted for each compliance period.
(b) Pursuant to 40 CFR 60.445:
(1) The Permittee shall maintain a calendar month record of all coatings used forthe one (1) pressure-sensitive vinyl rollcoating line (L-2) and the one (1)pressure- sensitive vinyl/paper rollcoating line (L-3) and the results of thereference test method specified in § 60.446(a) or the manufacturer’s formulationdata used for determining the Volatile Organic Compound (VOC) content ofthose coatings.
(2) Records of the measurements required by §§ 60.443 and 60.445 must beretained for at least two years following the date of the measurements.
(c) All records shall be maintained in accordance with Section C - General Record KeepingRequirements, of this permit.
D.1.12 Reporting Requirements [40 CFR 60.447, Subpart RR](a) For the one (1) pressure-sensitive vinyl rollcoating line (L-2) and the one (1) pressure-
sensitive vinyl/paper rollcoating line (L-3), the performance test and results from the performance test shall be submitted to the Commissioner as specified in § 60.8(a) of theGeneral Provisions (40 CFR part 60, subpart A).
(b) Following the initial performance test for the one (1) pressure-sensitive vinyl rollcoatingline (L-2) and the one (1) pressure-sensitive vinyl/paper rollcoating line (L-3), thePermittee shall submit quarterly reports to the Commissioner of exceedances of theVolatile Organic Compound (VOC) emission limits specified in § 60.442. If no such exceedances occur during a particular quarter, a report stating this shall be submitted tothe Commissioner semi-annually.
(c) The Permittee shall also submit reports at the frequency specified in § 60.7(c) when theincinerator temperature drops as defined in § 60.443(e). If no such periods occur, thePermittee shall state this in the report.
(d) The requirements of this subsection remain in force until and unless EPA, in delegatingenforcement authority to a State under section 111(c) of the Act, approves reportingrequirements or an alternate means of compliance surveillance adopted by such States. In that event, affected sources within the State will be relieved of the obligation tocomply with this subsection, provided that they comply with the requirementsestablished by the State.
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D.1.13 Reporting Requirements [326 IAC 2-3]A quarterly summary of the information to document compliance with Condition D.1.4 shall besubmitted to the addresses listed in Section C - General Reporting Requirements, of this permit,using the reporting forms located at the end of this permit, or their equivalent, within thirty (30)days after the end of the quarter being reported.
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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENTOFFICE OF AIR MANAGEMENTCOMPLIANCE DATA SECTION
Part 70 Quarterly Report
Source Name: Avery Dennison MFDSource Address: 270 West Meadow Place, Lowell, Indiana 46356Mailing Address: 270 West Meadow Place, Lowell, Indiana 46356Part 70 Permit No.: 089-7463-00407Facility: Surface Coating Head CH-1Parameter: VOCLimit:: Ten (10) tons per twelve (12) consecutive month period
YEAR:
MonthVOC/HAP Usage (tons) VOC/HAP Usage (tons)
This Month 12 Month Total
Month 1
Month 2
Month 3
9 No deviation occurred in this quarter.
9 Deviation/s occurred in this quarter.Deviation has been reported on:
Submitted by: Title / Position: Signature: Date: Phone:
Attach a signed certification to complete this report.
Page 1 of 7
Indiana Department of Environmental ManagementOffice of Air Management
Technical Support Document (TSD) for a Part 70 Minor Source Modification
The Office of Air Management (OAM) has reviewed a modification application from AveryDennison MFD relating to the construction of the following emission units and pollution controldevices:
(a) One coating head, identified as CH-1 with a maximum capacity of 23,063 square feet perhour, using one (1) existing 9.8 MMBtu/hr natural gas fired thermal oxidizer as control,and exhausting to existing stack S-2.
History
On September 13, 2000, Avery Dennison MFD submitted an application to the OAM requesting toadd an additional coating head to their existing plant. Avery Dennison MFD was issued a Part 70permit on July 14, 1999.
Enforcement Issue
There are no enforcement actions pending.
Recommendation
The staff recommends to the Commissioner that the Part 70 Minor Source Modification beapproved. This recommendation is based on the following facts and conditions:
Unless otherwise stated, information used in this review was derived from the application andadditional information submitted by the applicant.
An application for the purposes of this review was received on September 13, 2000. Additionalinformation was received on October 23, 2000.
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Emission Calculations
See Appendix A of this document for detailed emissions calculations (Appendix A pages 1 and2).
Potential To Emit of Modification
Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of astationary source to emit any air pollutant under its physical and operational design. Anyphysical or operational limitation on the capacity of a source to emit an air pollutant, including airpollution control equipment and restrictions on hours of operation or type or amount of materialcombusted, stored, or processed shall be treated as part of its design if the limitation isenforceable by the U. S. EPA.”
This table reflects the PTE before controls. Control equipment is not considered federallyenforceable until it has been required in a federally enforceable permit.
Pollutant Potential To Emit (tons/year)
PM 0
PM-10 0
SO2 0
VOC 518
CO 0
NOx 0
HAP’s Potential To Emit (tons/year)
Toluene 111TOTAL 111
Justification for Modification
The Part 70 Operating permit is being modified through a Part 70 Minor Source Modification. Thismodification is being performed pursuant to 326 IAC 2-7-10.5(d)(9) as the coating head is subjectto and will comply with the same applicable requirements as the existing coating units.
(a) Volatile organic compounds (VOC) and oxides of nitrogen (NOx) are precursors for theformation of ozone. Therefore, VOC and NOX emissions are considered whenevaluating the rule applicability relating to the ozone standards. Lake County has beendesignated as nonattainment for ozone. Therefore, VOC and NOx emissions werereviewed pursuant to the requirements for Emission Offset, 326 IAC 2-3.
Avery Dennison MFD Page 3 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
Source Status
Existing Source PSD or Emission Offset Definition (emissions after controls, based upon 8760hours of operation per year at rated capacity and/or as otherwise limited):
Pollutant Emissions (tons/year)
PM less than 100
PM-10 less than 100
SO2 less than 100
VOC greater than 250
CO less than 100
NOx less than 100
(a) This existing source is a major stationary source because a severe non-attainmentregulated pollutant is emitted at a rate of 25 tons per year or more.
(b) These emissions are based upon the TSD for T 089-7463-00407.
Potential to Emit of Modification After Issuance
The table below summarizes the potential to emit, reflecting all limits, of the significant emissionunits after controls. The control equipment is considered federally enforceable only afterissuance of this Part 70 source modification.
Potential to Emit(tons/year)
Process/facility PM PM-10 SO2 VOC CO NOX HAPs
Coating Head(CH-1)
10 10
The source has accepted a limit of 10 tons per year VOC and 10 tons per year total HAP for thenew coating head CH-1.
Therefore, this modification to an existing major stationary source is not major because theaggregated emissions increase over the last five (5) years is less than the Emission Offsetsignificant levels and pursuant to 326 IAC 2-3, the Emission Offset requirements do not apply.
Federal Rule Applicability
(a) The coating head (CH-1) is subject to the New Source Performance Standard, 326 IAC12, (40 CFR 60.440, Subpart RR). Pursuant to this subpart, the Permittee shall demonstrate a ninety percent (90%) overall Volatile Organic Compound (VOC) emissionreduction as calculated over one calendar month. A compliance test performedaccording the EPA Method 25 and 25A shall determine compliance with thisrequirement.
(b) There are no National Emission Standards for Hazardous Air Pollutants (NESHAPs)(326IAC 14 and 40 CFR Part 63) applicable to this proposed modification.
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State Rule Applicability - Individual Facilities
326 IAC 8-2-5 (Paper Coating Operations)The coating head CH-1 is subject to the requirements of 326 IAC 8-2-5 (Paper CoatingOperations) because it has 100% substrate saturation, it will be constructed after July 1, 1990,and is expected to have volatile organic compound (VOC) emissions greater than fifteen (15)pounds per day before add-on controls.
Pursuant to 326 IAC 8-2-5 (Paper Coating Operations), the Permittee shall not cause allow, orpermit the discharge into the atmosphere of any volatile organic compound (VOC) in excess oftwo and nine-tenths (2.9) pounds per gallon of coating, excluding water, delivered to the coatingapplicator from a paper, plastic, metal foil, or pressure sensitive tape/labels coating line.
The thermal oxidizer for the coating head CH-1 shall be in operation at all times the coatinghead CH-1 is in operation to ensure compliance with this requirement since the coating used inthis coating head contains 5.4 (lb VOC/gallon).
326 IAC 2-4.1 (New Source Toxics Control)The coating head CH-1 is not subject to 326 IAC 2-4.1 (New Source Toxics Control) as it will notbe a major source of HAP since it will be subject to a limit of ten (10) tons per year total HAP.
Compliance Requirements
Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstratecompliance with applicable state and federal rules on a more or less continuous basis. All stateand federal rules contain compliance provisions, however, these provisions do not always fulfillthe requirement for a more or less continuous demonstration. When this occurs IDEM, OAM, inconjunction with the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As aresult, compliance requirements are divided into two sections: Compliance DeterminationRequirements and Compliance Monitoring Requirements.
Compliance Determination Requirements in Section D of the permit are those conditions that arefound more or less directly within state and federal rules and the violation of which serves asgrounds for enforcement action. If these conditions are not sufficient to demonstrate continuouscompliance, they will be supplemented with Compliance Monitoring Requirements, alsoSection D of the permit. Unlike Compliance Determination Requirements, failure to meetCompliance Monitoring conditions would serve as a trigger for corrective actions and notgrounds for enforcement action. However, a violation in relation to a compliance monitoringcondition will arise through a source’s failure to take the appropriate corrective actions within aspecific time period.
Proposed Changes
A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)]This stationary source consists of the following emission units and pollution control devices:
(1) One (1) pressure-sensitive vinyl rollcoating line, installed on July 1, 1980, identified asL-1, with maximum capacity of 24,750 square feet per hour, using one (1) 6.9 millionBritish thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOCcontrol, exhausting to one (1) stack (S-1);
(2) One (1) pressure-sensitive vinyl rollcoating line, installed on December 1, 1984, andone (1) surface coating head (CH-1), installed in 2001, identified together as L-2,with maximum capacity of 23,063 square feet per hour, using one (1) 9.8 million British
Avery Dennison MFD Page 5 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-2); and
(3) One (1) pressure-sensitive vinyl/paper rollcoating line, installed on June 1, 1988,identified as L-3, with maximum capacity of 30,750 square feet per hour, using one (1)11.2 million British thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizeras VOC control, exhausting to one (1) stack (S-3).
SECTION D.1 FACILITY OPERATION CONDITIONS
Facility Description [326 IAC 2-7-5(15)]
(1) One (1) pressure-sensitive vinyl rollcoating line, installed on July 1, 1980, identified as L-1,with maximum capacity of 24,750 square feet per hour, using one (1) 6.9 million Britishthermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-1);
(2) One (1) pressure-sensitive vinyl rollcoating line, installed on December 1, 1984, and one (1)surface coating head (CH-1), installed in 2001, identified together as L-2, with maximumcapacity of 23,063 square feet per hour, using one (1) 9.8 million British thermal units perhour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control, exhausting to one (1)stack (S-2); and
(3) One (1) pressure-sensitive vinyl/paper rollcoating line, installed on June 1, 1988, identified asL-3, with maximum capacity of 30,750 square feet per hour, using one (1) 11.2 million Britishthermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-3).
D.1.4 Volatile Organic Compounds and HAPs [326 IAC 2-3] [326 IAC 2-4.1] Input of VOC and HAP to the surface coating head (CH-1) shall be limited to less than fivehundred (500) tons per year. At a control efficiency of at least 98% for the thermaloxidizer, these usage limits shall effectively limit emissions of VOC and HAP to less thanten (10) tons per year. Compliance with these limits shall make the Emission Offset andNew source Toxics Control rules not applicable.
D.1.8 Volatile Organic Compounds (VOC) and HAPs [326 IAC 2-3] [326 IAC 2-4.1]Compliance with the VOC and HAP usage limitations contained in Condition D.1.4 shall bedetermined using formulation data supplied by the coating manufacturer.
D.1.11 Record Keeping Requirements(a) To document compliance with Condition D.1.1 and D.1.4, the Permittee shall maintain
records in accordance with (1) through (6) below. Records maintained for (1) through (6)shall be taken daily and shall be complete and sufficient to establish compliance with theVOC usage limits and/or the VOC emission limits established in Condition D.1.1.
D.1.13 Reporting RequirementsA quarterly summary of the information to document compliance with Condition D.1.4shall be submitted to the addresses listed in Section C - General Reporting Requirements,of this permit, using the reporting forms located at the end of this permit, or theirequivalent, within thirty (30) days after the end of the quarter being reported.
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENTOFFICE OF AIR MANAGEMENT
Avery Dennison MFD Page 6 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
COMPLIANCE DATA SECTION
Part 70 Quarterly Report
Source Name: Avery Dennison MFDSource Address: 270 West Meadow Place, Lowell, Indiana 46356Mailing Address: 270 West Meadow Place, Lowell, Indiana 46356Part 70 Permit No.: 089-7463-00407Facility: Surface Coating Head CH-1Parameter: VOC/HAPLimit: Five Hundred (500) tons per twelve (12) consecutive month period
YEAR:
MonthVOC/HAP Usage (tons) VOC/HAP Usage (tons)
This Month 12 Month Total
Month 1
Month 2
Month 3
99 No deviation occurred in this quarter.
99 Deviation/s occurred in this quarter.Deviation has been reported on:
Submitted by: Title / Position: Signature: Date: Phone:
Attach a signed certification to complete this report.
Avery Dennison MFD Page 7 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
Conclusion
The construction of this proposed modification shall be subject to the conditions of the attachedproposed Part 70 Minor Source Modification No. 089-12713-00407.
Page 1 of 7
Indiana Department of Environmental ManagementOffice of Air Management
Technical Support Document (TSD) for a Part 70 Minor Source Modification
The Office of Air Management (OAM) has reviewed a modification application from AveryDennison MFD relating to the construction of the following emission units and pollution controldevices:
(a) One coating head, identified as CH-1 with a maximum capacity of 23,063 square feet perhour, using one (1) existing 9.8 MMBtu/hr natural gas fired thermal oxidizer as control,and exhausting to existing stack S-2.
History
On September 13, 2000, Avery Dennison MFD submitted an application to the OAM requesting toadd an additional coating head to their existing plant. Avery Dennison MFD was issued a Part 70permit on July 14, 1999.
Enforcement Issue
There are no enforcement actions pending.
Recommendation
The staff recommends to the Commissioner that the Part 70 Minor Source Modification beapproved. This recommendation is based on the following facts and conditions:
Unless otherwise stated, information used in this review was derived from the application andadditional information submitted by the applicant.
An application for the purposes of this review was received on September 13, 2000. Additionalinformation was received on October 23, 2000.
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Emission Calculations
See Appendix A of this document for detailed emissions calculations (Appendix A pages 1 and2).
Potential To Emit of Modification
Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of astationary source to emit any air pollutant under its physical and operational design. Anyphysical or operational limitation on the capacity of a source to emit an air pollutant, including airpollution control equipment and restrictions on hours of operation or type or amount of materialcombusted, stored, or processed shall be treated as part of its design if the limitation isenforceable by the U. S. EPA.”
This table reflects the PTE before controls. Control equipment is not considered federallyenforceable until it has been required in a federally enforceable permit.
Pollutant Potential To Emit (tons/year)
PM 0
PM-10 0
SO2 0
VOC 518
CO 0
NOx 0
HAP’s Potential To Emit (tons/year)
Toluene 111TOTAL 111
Justification for Modification
The Part 70 Operating permit is being modified through a Part 70 Minor Source Modification. Thismodification is being performed pursuant to 326 IAC 2-7-10.5(d)(9) as the coating head is subjectto and will comply with the same applicable requirements as the existing coating units.
(a) Volatile organic compounds (VOC) and oxides of nitrogen (NOx) are precursors for theformation of ozone. Therefore, VOC and NOX emissions are considered whenevaluating the rule applicability relating to the ozone standards. Lake County has beendesignated as nonattainment for ozone. Therefore, VOC and NOx emissions werereviewed pursuant to the requirements for Emission Offset, 326 IAC 2-3.
Avery Dennison MFD Page 3 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
Source Status
Existing Source PSD or Emission Offset Definition (emissions after controls, based upon 8760hours of operation per year at rated capacity and/or as otherwise limited):
Pollutant Emissions (tons/year)
PM less than 100
PM-10 less than 100
SO2 less than 100
VOC greater than 250
CO less than 100
NOx less than 100
(a) This existing source is a major stationary source because a severe non-attainmentregulated pollutant is emitted at a rate of 25 tons per year or more.
(b) These emissions are based upon the TSD for T 089-7463-00407.
Potential to Emit of Modification After Issuance
The table below summarizes the potential to emit, reflecting all limits, of the significant emissionunits after controls. The control equipment is considered federally enforceable only afterissuance of this Part 70 source modification.
Potential to Emit(tons/year)
Process/facility PM PM-10 SO2 VOC CO NOX HAPs
Coating Head(CH-1)
10 10
The source has accepted a limit of 10 tons per year VOC and 10 tons per year total HAP for thenew coating head CH-1.
Therefore, this modification to an existing major stationary source is not major because theaggregated emissions increase over the last five (5) years is less than the Emission Offsetsignificant levels and pursuant to 326 IAC 2-3, the Emission Offset requirements do not apply.
Federal Rule Applicability
(a) The coating head (CH-1) is subject to the New Source Performance Standard, 326 IAC12, (40 CFR 60.440, Subpart RR). Pursuant to this subpart, the Permittee shall demonstrate a ninety percent (90%) overall Volatile Organic Compound (VOC) emissionreduction as calculated over one calendar month. A compliance test performedaccording the EPA Method 25 and 25A shall determine compliance with thisrequirement.
(b) There are no National Emission Standards for Hazardous Air Pollutants (NESHAPs)(326IAC 14 and 40 CFR Part 63) applicable to this proposed modification.
Avery Dennison MFD Page 4 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
State Rule Applicability - Individual Facilities
326 IAC 8-2-5 (Paper Coating Operations)The coating head CH-1 is subject to the requirements of 326 IAC 8-2-5 (Paper CoatingOperations) because it has 100% substrate saturation, it will be constructed after July 1, 1990,and is expected to have volatile organic compound (VOC) emissions greater than fifteen (15)pounds per day before add-on controls.
Pursuant to 326 IAC 8-2-5 (Paper Coating Operations), the Permittee shall not cause allow, orpermit the discharge into the atmosphere of any volatile organic compound (VOC) in excess oftwo and nine-tenths (2.9) pounds per gallon of coating, excluding water, delivered to the coatingapplicator from a paper, plastic, metal foil, or pressure sensitive tape/labels coating line.
The thermal oxidizer for the coating head CH-1 shall be in operation at all times the coatinghead CH-1 is in operation to ensure compliance with this requirement since the coating used inthis coating head contains 5.4 (lb VOC/gallon).
326 IAC 2-4.1 (New Source Toxics Control)The coating head CH-1 is not subject to 326 IAC 2-4.1 (New Source Toxics Control) as it will notbe a major source of HAP since it will be subject to a limit of ten (10) tons per year total HAP.
Compliance Requirements
Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstratecompliance with applicable state and federal rules on a more or less continuous basis. All stateand federal rules contain compliance provisions, however, these provisions do not always fulfillthe requirement for a more or less continuous demonstration. When this occurs IDEM, OAM, inconjunction with the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As aresult, compliance requirements are divided into two sections: Compliance DeterminationRequirements and Compliance Monitoring Requirements.
Compliance Determination Requirements in Section D of the permit are those conditions that arefound more or less directly within state and federal rules and the violation of which serves asgrounds for enforcement action. If these conditions are not sufficient to demonstrate continuouscompliance, they will be supplemented with Compliance Monitoring Requirements, alsoSection D of the permit. Unlike Compliance Determination Requirements, failure to meetCompliance Monitoring conditions would serve as a trigger for corrective actions and notgrounds for enforcement action. However, a violation in relation to a compliance monitoringcondition will arise through a source’s failure to take the appropriate corrective actions within aspecific time period.
Proposed Changes
A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)]This stationary source consists of the following emission units and pollution control devices:
(1) One (1) pressure-sensitive vinyl rollcoating line, installed on July 1, 1980, identified asL-1, with maximum capacity of 24,750 square feet per hour, using one (1) 6.9 millionBritish thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOCcontrol, exhausting to one (1) stack (S-1);
(2) One (1) pressure-sensitive vinyl rollcoating line, installed on December 1, 1984, andone (1) surface coating head (CH-1), installed in 2001, identified together as L-2,with maximum capacity of 23,063 square feet per hour, using one (1) 9.8 million British
Avery Dennison MFD Page 5 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-2); and
(3) One (1) pressure-sensitive vinyl/paper rollcoating line, installed on June 1, 1988,identified as L-3, with maximum capacity of 30,750 square feet per hour, using one (1)11.2 million British thermal units per hour (mmBtu/hr) natural gas fired thermal oxidizeras VOC control, exhausting to one (1) stack (S-3).
SECTION D.1 FACILITY OPERATION CONDITIONS
Facility Description [326 IAC 2-7-5(15)]
(1) One (1) pressure-sensitive vinyl rollcoating line, installed on July 1, 1980, identified as L-1,with maximum capacity of 24,750 square feet per hour, using one (1) 6.9 million Britishthermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-1);
(2) One (1) pressure-sensitive vinyl rollcoating line, installed on December 1, 1984, and one (1)surface coating head (CH-1), installed in 2001, identified together as L-2, with maximumcapacity of 23,063 square feet per hour, using one (1) 9.8 million British thermal units perhour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control, exhausting to one (1)stack (S-2); and
(3) One (1) pressure-sensitive vinyl/paper rollcoating line, installed on June 1, 1988, identified asL-3, with maximum capacity of 30,750 square feet per hour, using one (1) 11.2 million Britishthermal units per hour (mmBtu/hr) natural gas fired thermal oxidizer as VOC control,exhausting to one (1) stack (S-3).
D.1.4 Volatile Organic Compounds and HAPs [326 IAC 2-3] [326 IAC 2-4.1] Input of VOC and HAP to the surface coating head (CH-1) shall be limited to less than fivehundred (500) tons per year. At a control efficiency of at least 98% for the thermaloxidizer, these usage limits shall effectively limit emissions of VOC and HAP to less thanten (10) tons per year. Compliance with these limits shall make the Emission Offset andNew source Toxics Control rules not applicable.
D.1.8 Volatile Organic Compounds (VOC) and HAPs [326 IAC 2-3] [326 IAC 2-4.1]Compliance with the VOC and HAP usage limitations contained in Condition D.1.4 shall bedetermined using formulation data supplied by the coating manufacturer.
D.1.11 Record Keeping Requirements(a) To document compliance with Condition D.1.1 and D.1.4, the Permittee shall maintain
records in accordance with (1) through (6) below. Records maintained for (1) through (6)shall be taken daily and shall be complete and sufficient to establish compliance with theVOC usage limits and/or the VOC emission limits established in Condition D.1.1.
D.1.13 Reporting RequirementsA quarterly summary of the information to document compliance with Condition D.1.4shall be submitted to the addresses listed in Section C - General Reporting Requirements,of this permit, using the reporting forms located at the end of this permit, or theirequivalent, within thirty (30) days after the end of the quarter being reported.
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENTOFFICE OF AIR MANAGEMENT
Avery Dennison MFD Page 6 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
COMPLIANCE DATA SECTION
Part 70 Quarterly Report
Source Name: Avery Dennison MFDSource Address: 270 West Meadow Place, Lowell, Indiana 46356Mailing Address: 270 West Meadow Place, Lowell, Indiana 46356Part 70 Permit No.: 089-7463-00407Facility: Surface Coating Head CH-1Parameter: VOC/HAPLimit: Five Hundred (500) tons per twelve (12) consecutive month period
YEAR:
MonthVOC/HAP Usage (tons) VOC/HAP Usage (tons)
This Month 12 Month Total
Month 1
Month 2
Month 3
99 No deviation occurred in this quarter.
99 Deviation/s occurred in this quarter.Deviation has been reported on:
Submitted by: Title / Position: Signature: Date: Phone:
Attach a signed certification to complete this report.
Avery Dennison MFD Page 7 of 7 Lowell, Indiana Source Mod #:089-12713-00407Permit Reviewer: ERG/MP
Conclusion
The construction of this proposed modification shall be subject to the conditions of the attachedproposed Part 70 Minor Source Modification No. 089-12713-00407.
Pounds of VOC per Gallon Coating less Water = (Density (lb/gal) * Weight % Organics) / (1-Volume % water)
Pounds of VOC per Gallon Coating = (Density (lb/gal) * Weight % Organics)
Potential VOC Pounds per Hour = Pounds of VOC per Gallon coating (lb/gal) * Gal of Material (gal/unit) * Maximum (units/hr)
Potential VOC Pounds per Day = Pounds of VOC per Gallon coating (lb/gal) * Gal of Material (gal/unit) * Maximum (units/hr) * (24 hr/day)
Potential VOC Tons per Year = Pounds of VOC per Gallon coating (lb/gal) * Gal of Material (gal/unit) * Maximum (units/hr) * (8760 hr/yr) * (1 ton/2000 lbs)
