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How will emission factors be adjusted to account for the newly exempt compounds?

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Of the compounds proposed for exemption, there are only two that will have any material effect on ROC emission limits: acetone and ethane. The calculation for acetone will be fairly straightforward because there is ample data on the amount of acetone in the various products that contain acetone. In essence, acetone will simply be deducted from the ROC emission estimates. For ethane, APCD staff will adjust the ROC emission limits by backing out the ethane fraction from the emission factor used to establish the original permitted ROC limit. These data are typically provided in the background documentation for the permit. • It previously exceeded the BACT threshold and installed BACT. Subtracting out the newly-exempted compounds would put me below the BACT threshold. Must I still operate the control equipment and comply with BACT requirements? Yes. BACT will be enforced as specified in your permit, and will not change as a consequence of the new ROC definition. • It previously exceeded th

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