How to Select Permit Conditions That Ensure Maximum Operational Flexibility: A Case Study at a Cardboard Manufacturing Site

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Courtesy of Coto Consulting, Inc.

The identification and acquisition of flexible permit conditions has been essential to the successful operation and compliance status of a cardboard manufacturing site in Los Angeles. In 1999, the owner was cited for exceeding the volatile organic compound (VOC) emission limits on two stationary sources by the California Air Quality Management District (CAQMD). A notice of violation (NOV) was issued and prompted a review and detailed evaluation of the old permit conditions. The original permits had extremely rigid permit conditions that allowed little operational flexibility. In addition, the owner's production rates, as well as the number of permitted sources, had slowly increased from 1996 to 1999. The previous permits and permit conditions were unable to accommodate this growth. The cardboard manufacturer needed broad operational flexibility on a daily basis for six manufacturing lines because of fluctuations in customer orders and the marketplace.

The author developed emission estimates for toxics (such as formaldehyde) and VOCs and developed daily and annual emission limits in conjunction with CAQMD. CH2M HILL also suggested pollution prevention (P2) methods to the owner that included testing of ultra-low VOC adhesives and coatings. A successful P2 strategy was tracking emissions on a daily basis and altering production schedules if emissions approached any daily emission limit. As a result of these successful P2 measures, the cardboard manufacturer reduced its emissions from 5.9 tons per year (tpy) to 1.4 tpy and maintained compliance with their permit conditions for more than 3 years. Another benefit of these P2 strategies is remaining below the Title V threshold of 8 tpy and avoid this type of permit entirely.

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