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 #: FY Date: 12/1/05 Page 1 of 5 APPLICATION & OTHER COMMUNICATION: Date Description 8/31/05 Application received 10/21/05 Administrative Completeness Letter Sent PROJECT DESCRIPTION The purpose of this application is to renew the facility s existing State Permit to Operate, FP-S-0142, which expires on November 30, An application shield applies to the permit. FACILITY/PROCESS DESCRIPTION Peterboro Basket Co. (PBC) manufactures wooden baskets which are marketed as gifts and collectibles. The baskets are made from ash, which is chosen for its strength, among other properties. The ash is soaked in hot water and then cut into strips which are then woven into a mat. After the mat is woven, it is put into a steam oven for approximately 20 minutes in order to soften the ash strips so they may be bent and pressed into the desired shapes. Some baskets are purchased in bulk by companies for gifts or promotional items and require PBC to put the company s logo on the basket. This is done in a very small silkscreening room. PBC uses approximately 2 to 3 quarts of ink per year for this process. Due to the low usage, this process is not vented to the outside through a stack. VOC emissions from this operation are considered negligible and are not included in the permit or the current application. The staining operation consists of a small room with a 4-foot square open tank and another small tank (for special projects), both of which are vented through the same exhaust stack. Over 90% of the staining is performed in the larger tank. The tank is filled with the desired stain, and a reducer or solvent is usually added to the stain. The baskets are then coated with the stain and allowed to dry. PBC has a wood-fired boiler that is used to produce the steam necessary to mold and bend the ash strips. It also provides some heat for the manufacturing areas of the facility. A #2 fuel oil fired boiler rated at 0.14 MMBtu/hr provides heat for the office and gift shop. This device is below permitting thresholds. Details of the wood-fired boiler are listed below: Make: Dillon Model: NHB#8063 Serial #:MAWP 100 SU/RV 100 Nameplate Rating: 2.85 MMBtu/hr Max Fuel Usage: tons of wet wood and bark per hour (heating value = 4500 Btu/lb) Installation date: 1923 POLLUTION CONTROL EQUIPMENT PBC does not operate pollution control equipment for either its staining operations or for the wood-fired boiler. EMISSION CALCULATIONS Staining Operations PBC has a list of various stains and solvents that it could use in its process, but for the past few years they have predominately used the Honey Stain and the Stain Reducer. Using the actual usage data for these products it was estimated that maximum usage rate for the stain is 10 gal/hr and for the reducer it is 2.5 gal/hr. These numbers were used to determine the potential emission rates for VOCs.

2 AFS #: Application #: FY Date: 12/1/05 Page 2 of 5 Potential VOCs The amount of VOC per gallon of paint was determined based on either the number stated on the MSDS or by multiplying the density of the coating by the % volatile component. The coating with the highest VOC content is Red Aqua Stain with 7.39 lb VOC/gal coating. All of the solvents contain 100% VOC, therefore the one with the highest density, xylene, was used for the calculation. It is assumed that 100% of the VOCs are emitted. Maximum VOC from stain = 10 gal/hr (maximum stain usage rate) * 7.39 lb VOC/gal stain = 73.9 lb/hr VOC Maximum VOC from solvent = 2.5 gal/hr (maximum usage rate) * 7.22 lb/gal * 100% VOC = lb/hr VOC Total potential VOC emissions = ( ) lb/hr * 8760 hr/yr / 2,000 lb/hr = tpy. The source wishes to maintain its current permit limit of VOCs < 50 tpy in order to be a synthetic minor source. Wood-Fired Boiler Emissions for the wood-fired boiler were determined using USEPA AP-42 (5 th Edition 01/95), Chapter 1.6, Wood Residue Combustion in Boilers (updated 3/02). Emission factors used are those for bark and wet wood fired boilers. The following table shows the emission factors used and the calculated emission rates. No restrictions are required for the boiler; therefore the annual emission rates are equal to the potential emissions. Emission factors were converted to units of lb/ton by multiplying the lb/mmbtu factor by the heating value of 4500 Btu/lb (9.0 MMBtu/ton). (Note that the previous permit and the current application used emission factors from the previous version of AP-42.) Pollutant Emission Factor (lb/mmbtu) Emission Factor (lb/ton) Emission Rate (lb/hr) Emission Rate (tpy) Total Particulate (TSP) PM NOx SO CO VOC AIR TOXICS ANALYSIS An air toxics analysis was conducted by looking at the facility s actual emissions. Even though the source listed 12 different stains and 3 different solvents, they predominately use only one of each. The source included annual usage numbers for calendar years 2001 to 2004 and daily emission rates for the period of 11/2/03 to 11/27/04. These numbers, along with MSDSs were used to calculate the maximum, actual emission rates for air toxics from the facility. Product Name Maximum Daily Usage (gal) Maximum Annual Usage (gal) Honey Stain Stain Reducer Walnut Stain Xylene Product Name Density (lb/gal) Component Name CAS # Weight % Honey Stain 6.75 Laktane % Aromatic Hydrocarbon Mixture % Toluene % Stain Reducer 6.4 Laktane % Walnut Stain 6.72 Laktane % Aromatic Hydrocarbon Mixture % VM&P Naphtha % Xylene 7.22 Xylene % Sample calculation for Laktane maximum daily emissions:

3 AFS #: Application #: FY Date: 12/1/05 Page 3 of 5 (55 gal Honey Stain * 6.75 lb/gal * 0.646) = lb/day (11 gal Stain Reducer * 6.4 lb/gal * 1.0) = 70.4 lb/day (55 gal Walnut Stain * 6.72 lb/gal * 0.669) = lb/day The source only uses one stain in a given day because the tank would need to be drained, cleaned and refilled in order to use a different stain. Therefore the higher emission rate from the two above stains was used to determine the maximum daily emissions: Total Laktane = = lb/day The facility expects that their emissions will increase by 20% in the upcoming years. Therefore the calculated, maximum emission rates were increased by a factor of 20%. The following table shows the maximum emissions of the compounds listed above and compares them to de minimus emission rates. Technically Laktane and the Aromatic Hydrocarbon Mixture and not listed RTAPs. It was decided to compare these compounds to limits developed for similar compounds. Laktane emissions are compared to the limits listed in Env-A 1450 for Stoddard solvent, CAS # and the Aromatic Hydrocarbon Mixture emissions are compared to the limits for VM & P Naphtha, CAS # Pollutant Emissions (lb/day) De minimus (lb/day) Emissions De minimus (lb/yr) (lb/yr) Laktane ,170 19,664 Aromatic Hydrocarbon Mixture ,275 7,581 Toluene ,927 VM & P Naphtha ,959 Xylene ,641 The daily and annual emissions of toluene and VM & P Naphtha and the annual emissions of xylene are less than the de minimus emission rates; therefore no further anaylsis is required for these emissions. An adjusted, in-stack concentration is calculated for the remaining emission rates and compared to the AALs. Two in-stack concentrations were calculated. The 24-hr concentration was calculated by using the daily emission rate divided by 24 hr/day, and the annual concentration was calculated using the annual emission rate divided by 8760 hr/yr. All concentrations and AALs listed are in units of μg/m 3. The stain room exhaust flow rate is 4040 acfm = m 3 /sec Sample calculation for daily Laktane emissions: (372 lb/day)/(24 hr/day) = 15.5 lb/hr * 10 6 /7.94 = μg/sec ( μg/sec)/( m 3 /sec)/400 = 2,560 μg/m 3 Pollutant 24-hr In-Stack Concentration 24-hr AAL (50%) Annual In-Stack Concentration Annual AAL (50%) Laktane 2,560 6,850 (3,425) ,262 (1,631) Aromatic Hydrocarbon Mixture 966 2,641 (1,321) 344 1,761 (881) Xylene 894 2,208 (1,104) na na Since the in-stack concentrations calculated using actual, projected emissions are less than 50% of the AALs, the source is in compliance with Env-A 1400 and no specific permit restrictions are required. MODELING No modeling is required for the air toxics because actual RTAP emissions are less than 50% of AALs using the in-stack concentration method. It was also decided that modeling was not required for the boiler. The only changes to the boiler since modeling was last conducted for this source in 2000 is the emission rates due to an update to AP-42.

4 AFS #: Application #: FY Date: 12/1/05 Page 4 of 5 STACK INFORMATION The following table details the stack parameters for the permitted devices at the source: Stack Exit Area Height (ft) Exhaust Flow Exhaust Temperature Stack Configuration (ft 2 ) (acfm) ( F) Staining Operations , Vertical/unobstructed Boiler unkown unkown Vertical/unobstructed EMISSION TESTING - No emissions testing will be required at this time. SITE VISITS/INSPECTIONS Date Description 7/2/03 and 7/17/03 Gary Milbury conducted an onsite compliance evaluation of the facility. The only concern noted in the report concerned the emissions of VOCs that were not listed as RTAPs (see discussion above concerning air toxics.) ANNUAL EMISSION REPORTS/FEES Annual emissions reports and fees for the facility are current through Actual emissions for the previous five years are summarized below: Year Particulates SO 2 NOx CO VOCs Total CHANGES FROM PREVIOUS PERMIT The source requested in their application that the permitted emissions for the facility be increased by 20%. The boiler is currently permitted at its potential emission rates and the staining operations are permitted for a maximum of 50 tpy of VOCs. It is not possible to increase these permitted rates. The fuel flow rate of the boiler was based on a heating value of 3800 Btu/lb. The updated permit used a heating value of 4500 Btu/lb which caused the maximum fuel flow rate to decrease from tons/hr to tons/hr. The new permit does not contain limits on the types or amounts of materials used in the staining operations. The emission limits for the boiler are different in the new permit because AP-42 emission factors for wood combustion were updated since the time that the previous permit was written. The new permit does not contain specific limits on individual RTAPs. The source will be required to maintain records to show compliance with the most recent version of Env-A The source will no longer be required to submit quarterly VOC emission reports. REVIEW OF REGULATIONS State Regulations Env-A 600 Permitting (effective 7/28/04) (a) NO The oil-fired boiler has a capacity < 10 MMBtu/hr

5 AFS #: Application #: FY Date: 12/1/05 Page 5 of (c) YES The wood-fired boiler has a capacity > 2 MMBtu/hr (g) YES Actual VOC emissions from the facility > 10 tpy (n) YES The facility is a synthetic minor source for VOCs (v) NO In-stack concentration <50% of AALs using actual emissions. Env-A 1200 Prevention, Abatement, and Control of Stationary Air Pollution (effective 12/31/02) NO Source is opting out of VOC RACT by accepting a permit restriction for VOCs of < 50 tpy Env-A 1400 Regulated Toxic Air Pollutants (effective 6/11/04) 1402 YES The facility is able to show compliance using either de minimus emission rates or in-stack concentrations. Env-A 2000 Fuel Burning Devices (effective 4/23/05) YES visible emissions shall not exceed 40% YES TSP emissions are limited to 0.60 lb/mmbtu. Note: AP-42 emission factor for total particulates from the burning of wet wood and bark is 0.56 lb/mmbtu. Env-A 2100 Particulate Matter and Visible Emissions Standards (effective 11/24/04) YES TSP emissions shall be limited according to the formula stated in ((b) YES visible emissions from the staining operations shall not exceed 20% Federal Regulations 40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. The boiler has a rating less than 10 MMBtu/hr and was installed prior to the applicability date, and is therefore not subject to this part. SUMMARY AND CONCLUSIONS The facility will be capable of meeting all regulations and standards for air quality. A State Permit to Operate has been drafted.