PERMIT APPLICATION REVIEW SUMMARY

Transcription

1 PERMIT APPLICATION REVIEW SUMMARY New Hampshire Department of Environmental Services Air Resources Division P.O. Box 95, 29 Hazen Drive Concord, NH Phone: Fax: AFS #: Application #: Date: 10/02/09 Page 1 of 6 PROJECT DESCRIPTION Velcro USA Inc. (Velcro) has filed a minor permit amendment request on April 9, 2009, for its State Permit to Operate FP- S-0252, issued on October 14, 2004 (amended June 20, 2005, April 26, 2006, and April 11, 2008). This permit expires on October 31, Velcro would like to make changes to its monitoring and recordkeeping requirements for the two selective catalytic reduction (SCR) systems it operates on Engines #1 and #2 to accommodate changes in catalyst system design. Specifically, Velcro wants to change one monitoring requirement and add one additional recordkeeping requirement: Existing Condition IX. Air Pollution Control Equipment, Item E., page 9 The flue gas pressure drop across the SCR catalyst bed, as continuously measured by the differential pressure gauge installed on the SCR system, shall not exceed 5.0 inches of water. Proposed Condition IX. Air Pollution Control Equipment, Item E., page 9 The flue gas pressure drop across the SCR catalyst bed, as continuously measured by the differential pressure transmitter installed on the SCR system, shall be recorded once an hour while Engines #1 or #2 are in operation. This conflicts with the recordkeeping requirement in Condition XII. Recordkeeping Requirements, Item H.(2) which states: The owner or operator shall record the differential pressure once per day for each SCR system. Therefore, as a remedy for these conflicting requirements, DES is changing Condition IX., Item E. to read as follows: The flue gas pressure drop across the SCR catalyst bed shall be continuously monitored by a differential pressure transmitter installed on each SCR system while Engines #1 or #2 are in operation. The reason for changing this permit condition and removing the maximum differential pressure of 5.0 inches of water is because Velcro wants the flexibility in choosing catalyst bed materials, which may have different maximum differential pressure values for optimum operation and NOx removal efficiencies. Existing Condition XII. Recordkeeping Requirements, Item H.2., page 15 The owner or operator shall record the differential pressure once per day for each SCR system. On September 2, 2009, Velcro called and asked that permit condition H.2. remain the way it is, as they were afraid of a permit violation if the Energy Management System was down and failed to record data once an hour as it is currently set up to operate. Velcro asked for the addition of one more recordkeeping requirement for the SCR systems, Item H.4., page 15 The owner or operator shall follow manufacturer recommendations for operation and maintenance of SCR catalyst components. Scheduled and corrective maintenance activities for these components shall be recorded using the owner owned maintenance management system. DES has added this permit condition to the permit. CHANGES FROM PREVIOUS PERMIT Please read the project description section above for changes from the previous permit. By making these proposed changes to the operating permit, it gives Velcro flexibility in changing its SCR system design, including using different types of catalyst materials, while still requiring the same NOx reduction of 80% or more of the inlet NOx to the SCR system, requiring the weekly NOx analysis by the hand-held portable NOx analyzer on any of the Engines or Combustion Turbine operated greater than 10 hours in a week, and keeping the same ammonia slip stream emissions limit of 20 ppmvd at 15% oxygen from each SCR system/engine exhaust. DES asked Velcro for a copy of the SCR catalyst management plan and got a copy of it via on September 2, 2009.

2 AFS #: Application #: Date: 10/02/09 Page 2 of 6 FACILITY DESCRIPTION The VELCRO USA Inc. (Velcro) facility is principally engaged in production of a unique fastener system used in a variety of applications. In support of operations at the facility, Velcro owns and operates a steam and electrical generation plant. The steam and electrical generation plant includes four internal combustion engines, each rated at 11.5 MMBtu/hr, firing No. 2 fuel oil or diesel fuel, with various dates of installation from 1990 to Co-Gen Unit No. 2 had an SCR installed in Co- Gen Unit No. 1 had an SCR installed in 2002 as part of a consent decree dated July 11, Also, there are two Boilers rated at 14.7 MMBtu/hr, installed in 1967, which can burn natural gas or No. 2 fuel oil. The facility installed a Combustion Turbine rated at MMBtu/hr which burns natural gas, with a heat recovery steam generator (no auxiliary fuel firing) in late In addition, Velcro has an Emergency Lighting Generator, a 55 kw propane-fired engine generator which provides power to emergency lighting during power outages. Velcro has replaced this Emergency Lighting Generator with a new Emergency Generator in the summer of 2004, which is a Model 3456 DITA, rated at 4.0 MMBtu/hr, fired with low sulfur diesel fuel with a sulfur content less than 0.05% sulfur, by weight. At the Velcro Electrical and Steam Generation Plant, steam is generated to supply process and space heating needs by extracting heat from the combustion turbine exhaust gas in a heat recovery boiler. There is no supplementary firing in the duct leading to the heat recovery steam generator (boiler) from the combustion turbine. All steam and electricity generated by the combustion turbine is used on site. Exhaust gas is vented to the atmosphere from the heat recovery steam generator via a new, dedicated stack. In the event that steam requirements are low or if there is a boiler malfunction, the combustion turbine exhaust gas may be directed to a by-pass duct connected to the same stack. It should be noted that Engine Generator Units #1 through 4 and Boilers #1 and 2 shall remain as a collective redundant system for periods when the combustion turbine/heat recovery boiler/electrical generator system is down, and for periods when facility electrical load exceeds the available capacity of the gas turbine. (Ambient conditions in summer reduce the turbine s capacity and Velcro s peak loads are in the summer.) Velcro operates the following devices or process units that are primarily sources of VOC emissions, with some RTAPs or HAPs: Coating Lines 1 & 2 Pressure sensitive adhesive coatings applied to webs of hook & loop fastener material and cured in steam and infrared heated ovens. Coating Lines 7 & 8 Water-based binder coatings applied to webs of hook & loop fastener material and cured in steam and infrared heated ovens. Wet Slasher Nylon or polyester yarn is roll-coated with a water-based starch product (sizing) then cured in an electric oven. As a final step, the yarn is roll-coated with a yarn lubricant. Hot Melt Coating Lines 5, 6, & 14 Applications of hot melt adhesives to PET release liner and roll-laminated to the back of hook & loop materials. (Adding Line 14 in April 2004, which is being relocated from another Velcro facility.) Dye House Operations Dyeing of various woven or knit fabrics in closed pressurized vessels. Procedyne A small electrically heated fluidized bed to burn off plastic residue from various tooling and dies. Wide Hot Melt Applications of hot melt adhesives to PET release liner and roll-laminated to the back of the hook & loop materials. High Tech Hook (HTH) Lines 1 through 14 Plastic resins (beads/pellets) heated to melt temperatures and extruded through dies. (Adding a new HTH Line #14 in April There is no HTH Line 2, hence there are a total of 13 HTH Lines.) Pelletizer Reprocessing of plastic resins into pellets by heating, extruding, cooling, and cutting. PEEK Process Proposed. Woven fiberglass hook & loop product passes through an oven at high temperatures for a short duration to burn off yarn coatings and to heat-set the product. Two Maintenance Spray Booths Various canned spray paints applied as needed to maintain facility equipment. Paint usage is for facility maintenance purposes only, no process use.

3 AFS #: Application #: Date: 10/02/09 Page 3 of 6 PERMIT HISTORY Application Permit Permit Permit Status # Number Issued Expires Facility Wide FP-S-0252 TBD TBD Renewal application for State Permit to Operate FP-S-0252, received 07/28/ SCR on Engine #1 & SCR on Engine FP-S-0252 TBD 10/31/09 Changes to SCR monitoring and recordkeeping requirements # Facility Wide FP-S /11/08 10/31/09 Admin. Amend. to correct typo in Condition VIII.B.1. (Process changes) Change from The process change does result in an exceedance to The process change does not result in an FY & FY exceedance Facility Wide FP-S /26/06 10/31/09 Minor Amendments Use of the new Testo 350 M/XL hand-held analyzer in place of the Land hand-held analyzer for NOx analyses of Engines and CT; and change from 3 60 minute test runs at 100% load to 3 30 minute test runs at 100% load for NOx testing in Condition XI.E.1. FY Facility Wide FP-S /20/05 10/31/09 Like-kind replacement of CT, removal of Velstick and Profile Process Lines and removal of Hot Melt Line 13 in Feb FY Facility Wide FP-S /14/04 10/31/09 Renewal of State Permit to Operate PROCESS/DEVICE DESCRIPTION Combustion Turbine Engine #1 Engine #2 Manufacturer, Model No., Serial No. Solar Centaur 50-T5900S CG99N B 8RM B 8RM00110 Fuel Burning s Install Date Nameplate Rating in MMBtu/hr and Permitted Fuel Type MMBtu/hr Natural gas - equivalent to 55,380 scf/hr (SCR installed in 2002) 1995 (SCR installed in 1998) MMBtu/hr Diesel fuel or No. 2 fuel oil equivalent to 84.0 gal/hr MMBtu/hr Diesel fuel or No. 2 fuel oil equivalent to 84.0 gal/hr 1 The hourly fuel rates presented in are set assuming a heating value of 1,025 Btu/scf for natural gas. 2 The hourly fuel rates for Engines #1 through #4 are set assuming a heating value of 137,000 Btu/gal for No. 2 fuel oil or diesel fuel.

4 AFS #: Application #: Date: 10/02/09 Page 4 of 6 Engine #3 Engine #4 Boiler #1 Boiler #2 Emergency Generator Manufacturer, Model No., Serial No. 3512A 24Z A 24Z03024 Cleaver Brooks CB Cleaver Brooks CB DITA TBD Fuel Burning s Install Date Nameplate Rating in MMBtu/hr and Permitted Fuel Type MMBtu/hr Diesel fuel or No. 2 fuel oil equivalent to 84.0 gal/hr MMBtu/hr Diesel fuel or No. 2 fuel oil equivalent to 84.0 gal/hr MMBtu/hr Natural gas equivalent to 14, 290 scf/hr or No. 2 fuel oil as alternate fuel equivalent to gal/hr MMBtu/hr Natural gas equivalent to 14, 290 scf/hr or No. 2 fuel oil as alternate fuel equivalent to gal/hr MMBtu/hr Low Sulfur Diesel Fuel equivalent to 29.2 gal/hr 3 Coating Lines 1 & 2 Coating Lines 7 & 8 Wet Slasher Hot Melt Coating Lines 5, 6, & 14 Dyehouse Operations Procedyne Wide Hot Melt High Tech Hook (HTH) Lines 1 through 14 (There is no HTH Line 2, hence a total of 13 HTH lines.) Pelletizer Hook/Loop Fastener System Production Equipment (Sources of VOCs) Description Pressure sensitive adhesive coatings applied to webs of hook & loop fastener material and cured in steam and infrared heated ovens. Binder coatings applied to webs of hook & loop fastener material and cured in steam and infrared heated ovens. Nylon or polyester yarn is roll-coated with a water-based starch product (sizing) then cured in an electric oven. Final step, the yarn is roll-coated with a yarn lubricant. Applications of hot melt adhesives to PET release liner and roll-laminated to the back of hook & loop materials. Dyeing of various woven or knit fabrics in closed pressurized vessels. A small electrically heated fluidized bed to burn off plastic residue from various tooling and dies. Applications of hot melt adhesives to PET release liner and roll-laminated to the back of the hook & loop materials. Plastic resins (beads/pellets) heated to melt temperatures and extruded through dies. Reprocessing of plastic resins into pellets by heating, extruding, cooling, and cutting. 3 The hourly fuel rate for the Emergency Generator is set assuming a heating value of 137,000 Btu/gal for low sulfur diesel oil.

5 AFS #: Application #: Date: 10/02/09 Page 5 of 6 PEEK Process Maintenance Spray Booths (Two) LIST OF INSIGNIFICANT ACTIVITIES Not applicable POLLUTION CONTROL EQUIPMENT Hook/Loop Fastener System Production Equipment (Sources of VOCs) Description Woven fiberglass hook & loop product passes through an oven at high temperatures for a short duration to burn off yarn coatings and to heat-set the product. Various canned spray paints applied as needed to maintain facility equipment. Paint usage is for facility maintenance purposes only, no process use. Selective Catalytic Reduction (SCR) System on Engine #1 and SCR System on Engine #2 are used for control of nitrogen oxide (NOx) emissions. Engines 1 & 2 are required to be operated at all times in conjunction with their corresponding SCR system, with the exception of the initial startup of the engine. Upon startup, the SCR system catalyst temperature needs to reach 550 degrees F (the minimum operating temperature required for efficient operation of the SCR system) before ammonia can be injected and then engine exhaust gases can be brought into the SCR for NOx removal. Velcro is required to monitor the combustion air temperature entering the intake air manifold and is required to keep it below 200 degrees F, to help prevent NOx formation/generation. Each engine has cooling water flow monitored and automatically controlled to keep the combustion air temperature entering the intake air manifold below 200 degrees F. In addition, Engines 1 & 2 have electronic ignition timing that automatically adjusts the ignition timing of each Engine to the most optimum degree of ignition retard for the minimization of NOx emissions without exceeding permitted opacity limits. Velcro is required to operate and maintain the SCR systems so as to maintain a minimum 80% removal efficiency of NOx emissions from Engines 1 & 2. The SCR catalyst ammonia (27.9% by weight, ammonia in aqueous solution) consumption rate shall not exceed 4.0 gal/hr, as continuously measured by the ammonia flow meter installed on the SCR system. Velcro is required to record ammonia flow electronically by the Energy Management System at least once an hour and when the value is outside of the normal indicator range. Maximum ammonia slip emissions from the SCR systems shall not exceed 20 ppmvd, corrected to 15% oxygen, dry basis. Velcro is required to perform ammonia slip testing once every three years with its required NOx RACT testing of the Engines. The SCR catalyst temperature operating range shall be limited to a minimum of 550 degrees F, as continuously measured by the thermocouple installed in the catalyst bed area of the SCR systems. NOx removal efficiency is reduced at temperatures below 550 degrees F. The flue gas pressure drop across the SCR catalyst bed shall be continuously monitored by a differential pressure transmitter installed on each SCR system while Engines #1 or #2 are in operation. The SCR ammonia to fuel ratio, as measured by both the ammonia flow meter and the fuel flow metering devices on Engines 1 and 2 shall be maintained such that a NOx reduction of 80% is achieved while minimizing ammonia slip emissions. When Engines 1 and 2 are in operation, Velcro shall use a hand-held analyzer approved by DES to check NOx emissions and make appropriate adjustments to the ammonia to fuel ratio to achieve the 80% NOx reduction requirement. The Energy Management System shall record the SCR catalyst bed temperature at least once per hour and when the value is outside of the normal indicator range (less than 550 degrees F).

6 AFS #: Application #: Date: 10/02/09 Page 6 of 6 The owner or operator shall record the differential pressure once per day for each SCR system. The ammonia to fuel ratio for each SCR system shall be recorded once per 8 hour period, electronically by the Energy Management System. The owner or operator shall follow manufacturer recommendations for operation and maintenance of SCR catalyst components. Scheduled and corrective maintenance activities for these components shall be recorded using owner owned maintenance management system. EMISSION CALCULATIONS Please refer to permit application FY for detailed emissions calculations information. This permit application was the basis for this current State Permit to Operate. There are no changes in emissions. MODELING No modeling is required for a minor permit amendment, in that there is no change in emissions. EMISSION TESTING NOx RACT testing is required once every three years for the Combustion Turbine and each of the four engines. COMPLIANCE STATUS Emission Testing Engines 1 and 2 were last tested on August 3, 2006 for NOx, CO, and ammonia. Test results were within all permit limits. This was a retest of Engine 2, due to catalyst problems that caused an exceedance of the ammonia slip limit when the first round of testing of Engine 2 was completed on April 13, The Combustion Turbine was tested on April 11, 2006 and found to meet all permit limits. Engine 1 was tested on April 12, 2006 and was in compliance with all permit conditions. Engine 3 was tested on April 14, 2006 and found to be in compliance with all permit conditions. Inspections The facility was last inspected on-site on March 20, No deficiencies were found as a result of the inspection. In the closing meeting the inspector informed the facility that it should document the periodic review of its air toxics compliance determination. During the inspection, the inspector did see some evidence of work in progress with respect to this issue. Reports On April 14, 2009 DES received the annual emissions report, NOx Emissions Statement, and VOC Emissions Statement. Fees The annual emission-based fees for calendar year 2008 were received by DES on April 14, REVIEW OF REGULATIONS State Regulations Env-A 600 Permitting Applicable Minor Permit Amendments: Temporary Permits and State Permits to Operate - The facility filed a minor permit amendment request for a proposed change to an existing permit condition which will not result in an increase in the amount of a specific air pollutant currently emitted by the source or device and will not result in the emission of any regulated air pollutant or regulated toxic air pollutant currently not emitted by the source or device and submitted the required information in Env-A (b). Federal Regulations No changes.