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: Facility: Norcross Safety Products LLC Engineer: Doug Laughton Location: 103 Temple St., Nashua SIC Code: 3021 Phone: AFS #: Application #: FY Date: December 5, 2005 Page 1 of 3 APPLICATION & OTHER COMMUNICATION Date July 12, 2005 February 28, 2005 Brief Description Application received Annual Emissions Report received FACILITY DESCRIPTION Norcross Safety Products LLC (Norcross) located at 103 Temple St., Nashua 03060, manufactures PVC-Plasticol Overshoe footwear (combat safety shoes). The manufacture of combat safety shoes involves the following processes: 1. Mixing of PVC-Plasticol formulations; 2. Slush molding of overshoes using one of four slush molding machines; 3. Spraying of finished footwear with water-based finish coatings in one of the two paint spray booths. A third spray booth is used for touch-up work on finished boots. The plasticol formulation for manufacture of the boots is made up in approximately 1,840 pound batches. About 11 compounds are weighed and poured/dumped into a mixing tub. The mixture is blended for approximately 30 minutes. Exhaust gases from the mixing tub are routed up through an exhaust hood which captures the particulate emissions and vents outside the building. After the mixing operation is completed, the plasticizer mixture is immediately covered until final use in the slush molding machines. Next, a slush molding machine operator attaches different size boot molds to the system and fills them with the plastisizer material. Molds are then pre-heated in a salt bath and rinsed in a pre-heated rinse tank. After the rinse tank, the molds are heated to approximately 108 to 116 deg F in an open flame system until the plasticizer is hardened. After the plasticizer hardens, excess plasticizer within the molds is dumped into a holding tank for recycling. The molds are again pre-heated in a salt bath, rinsed in a pre-heated rinse tank, and cooled. The product is then removed from the mold and is taken to one of two paint spray booths. A layer of water-based boot lacquer (finish coating) is applied over the entire boot. Boots are then placed on a rack to allow the coating to dry. Workers then apply closure mechanisms on the boots and package them ready for shipment. PROJECT DESCRIPTION/PERMITTING HISTORY Norcross previously submitted an application for a Temporary Permit on November 6, 1997 and supplemental information on March 23, DES Air Resources Division issued a No Permit Required letter on April 10, This determination was based on Env-A (g) (actual VOC emissions less than 10 tons per year) and Env-A 1300 State Air Toxics Program. In 2004, the United States Government exercised a serge clause in the contract given to Norcross to produce combat overshoes for the U.S. military forces. This resulted in Norcross operating the plant 24 hours per day, 7 days a week, and 48 weeks per year. Norcross submitted an annual emissions report to DES on February 28, VOC emissions for 2004 were 34.2 tons. Pursuant to Env-A (g), Norcross is required to obtain a Temporary Permit for the operation of the facility. PROCESS/DEVICE DESCRIPTION Device/Process Slush Molding Machines #1, #2, #3, & #4 Paint Spray Booths #1 & #2 Paint Spray Booth #3 Description Combat overshoe boot manufacture Water-based coating applied to the finished boots. Touch-up spray painting of finished boots.

2 PERMIT APPLICATION REVIEW SUMMARY New Hampshire Department of Environmental Services Air Resources Division P.O. Box 95, 29 Hazen Drive Concord, NH Phone: Fax: Facility: Norcross Safety Products LLC Engineer: Doug Laughton Location: 103 Temple St., Nashua SIC Code: 3021 Phone: AFS #: Application #: FY Date: December 5, 2005 Page 2 of 3 INSIGNIFICANT ACTIVITIES Device/Process Description (Not applicable) POLLUTION CONTROL EQUIPMENT Fabric Filter in exhaust hood above mixing tub to catch any particulate matter from the mixing tub emissions. EMISSION CALCULATIONS For the slush molding operations: A Method 24 analysis was conducted on the plasticizer mixture used for the boot manufacturing step. Results are as follows: VOC content = lb VOC/gal or 1.75% by weight Density = 1.15 grams/ml (9.6 lb/gal) Total amount of plasticizer mixed in 2004 = 3,349,704.3 lb Total VOC emissions in 2004 = 3,349,704.3 lb/yr X = 58,620 lb/yr = 29.3 ton/yr VOC Theoretical Potential to Emit (TPE) Based on a maximum of 12 batches/24 hour day and lb plasticol/batch TPE = 12 X X = lb/day = tons/year if operated at maximum rate for 8,760 hours per year. For the Spray Painting of the Boots: Finished boots are sprayed with a water-based coating (New Black Boot Coating). The MSDS sheet indicates a VOC content of 0.83 lb VOC/gal. Total amount of New Black Boot Coating used in 2004 = 11,708 gal VOC emissions from boot coating = 11,078 gal/yr X 0.83 lb VOC/gal = 9718 lb/yr = 4.86 ton/yr One of the VOC s present in the coating is dipropylene glycol monobutyl ether, which is not an RTAP or HAP. STACK INFORMATION Not required. MODELING Not required. EMISSION TESTING Not required. SITE VISITS/INSPECTIONS Date August 31, 2005 Brief Description Karen Rantamaki/Doug Laughton went for an inspection and site tour.

3 PERMIT APPLICATION REVIEW SUMMARY New Hampshire Department of Environmental Services Air Resources Division P.O. Box 95, 29 Hazen Drive Concord, NH Phone: Fax: Facility: Norcross Safety Products LLC Engineer: Doug Laughton Location: 103 Temple St., Nashua SIC Code: 3021 Phone: AFS #: Application #: FY Date: December 5, 2005 Page 3 of 3 COMPLIANCE REPORTS/EMISSION FEES See the attached page of historical emissions for the facility provided by the Compliance Bureau. Based upon this information, the facility was above the permitting threshold of 10 tons per year of actual VOC emissions beginning in Note that actual VOC emissions have been below a maximum of 41 tons from 1997 through 2004, allowing the facility to opt out of the VOC RACT requirements in Env-A 1204, provided the facility takes a permit restriction of less than 50 tons per year of actual VOC emissions going forward. REVIEW OF REGULATIONS State Regulations Env-A (g) Temporary Permit required for VOC emissions > 10 ton/yr. Env-A Annual payment of emission-based fees. Env-A (a) 20% opacity standard for all process vents. Env-A Record retention for 5 years. Env-A General VOC recordkeeping requirements. Env-A VOC recordkeeping requirements for surface coating and printing operations. Env-A 906 Additional recordkeeping requirements, tracking rolling 12 month total facility wide VOC emissions. Env-A VOC reporting requirements. Env-A 907 General reporting requirements, i.e., annual emissions report. Env-A (b) Permit deviation reporting. Facility is taking a 50 ton VOC emissions limit per consecutive 12 month period to stay a minor source and to stay out of VOC RACT requirements. Env-A 1400 State Air Toxics Program requirements. Below deminimus values for mineral spirits and adjusted in stack concentration of Stoddard solvent is below 24 hour and annual ambient air limits. Polyvinyl chloride is in a liquid emulsion kept below its melting point and hence is not emitted. Calcium oxide is mixed into the liquid boot filling mixture and not emitted anywhere in the boot manufacturing process. See Attachment A for a summary table and Attachment A Air Toxics Analysis Notes for further discussion and details. Federal Regulations (None applicable) CHANGES FROM PREVIOUS PERMIT (Not applicable) Current Permit (permit #) Renewal Reason for change SUMMARY AND CONCLUSIONS Based upon a review of the application, the facility meets all applicable requirements, and a draft Temporary Permit has been prepared for public notice and comment.

4 Engineering Summary Historical Emissions 12/05/2005 Norcross Safety Products Facility ID# Permit App# FY Year Total Plastisol Mixed (lbs) VOCs (tons) Total Spray Coating Used (gal) VOCs (tons) Total VOCs (tons) , , ,143, , ,104, , ,411, , ,257, , ,364, , ,349, , (through August) 1,860,

5 ATTACHMENT A List of RTAPs and Emission Rates Evaluated RTAP CAS # Process(es) Slush Molding Machines Emission Rate (lb/day) Compliance Determination Method Liquid emulsion kept below melting point Adjusted-In- Stack Concen. In solution, not emitted Polyvinyl Chloride Slush Molding Machines Stoddard Solvent Slush Molding Machines Calcium Oxide Mineral Spirits Slush Molding Machines 4.49 De minimus Notes: 1. Annual emissions were evaluating assuming the devices run at maximum capacity for 8760 hr/yr. 2. Compounds and emission rates listed in bold print signify that controls are required for compliance.

6 Engineering Summary Attachment A - Air Toxics Analysis Notes 12/05/2005 Norcross Safety Products Facility ID# Permit App# FY There are 11 main ingredients in the Plasticizer used in the 4 slush molding machines which are described below: 1. PVC Solvin Homopolymer Resin PVC Resin Homopolymer CAS # >98% by weight, a liquid emulsion Melting point = deg F, Decomposition at > 248 deg F The liquid plasticol mixture for making the boots goes through a heated bath and is kept between 108 and 116 degrees F for curing of the plasticol mixture. Hence, this is below the melting point of the PVC resin homopolymer and there will be no air emissions of this compound from the slush molding machines. Considered a VOC and an RTAP, not emitted as it is kept below 167 deg F. 2. Vestinol 9 Diisononyl phthalate CAS # , a liquid Melting point = 54 deg C, Boiling point = 485 deg F, Flash point = 470 deg F This is a VOC and not an RTAP or HAP 3. Sanitizer 160 Plasticizer Benzyl butyl phthalate CAS # , > 98% by wt., a liquid Boiling point = 464 deg F, Flash point = 390 deg F A VOC, not an RTAP or HAP 4. Plas-Chek 775 Epoxidized Soybean Oil CAS # , 100% by weight Boiling point = 600 deg F A VOC, not an RTAP or HAP 5. Akrostab R-4086 Stoddard Solvent CAS # , 41% by wt., a VOC and RTAP, but not a HAP Aromatic hydrocarbon solvent CAS # , 5% by wt., a VOC, not an RTAP or HAP 27 lb Akrostab R-4086 X 0.41 lb Stoddard Solvent/lb Akrostab R-4086/ lb plasticol batch = X lb Stoddard Solvent/3,349,704 lb plasticol mix total in 2004 X = 20,166.5 lb Stoddard Solvent/year and lb Stoddard Solvent/day assuming 365 day operation per year 24 hour deminimus = 21 lb/day Annual deminimus = 7581 lb/year This is well above the deminimus levels so one can next look at adjusted-in-stack concentration for demonstrating compliance with Env-A Note that each of the four slush molding machine stack discharge points are oriented horizontally and unobstructed. Air flow for each of the four slush molding machines is 450 actual cubic feet per minute (ACFM) on Machines 1 and 2 and 500 ACFM on Machines 3 and 4. Assuming production is equally split on the four machines, 21 lb/day/4 machines = 5.25 lb/day per machine OR

7 lb/hr Stoddard Solvent emissions from each machine. Worst case emissions would be with the lower air flow of 450 ACFM at 0.22 lb/hr Stoddard Solvent on Machines 1 and 2. Y (grams/second pollutant) = X (lb/hr Stoddard Solvent)/7.94 Y = 0.22/7.94 = gr/sec Stoddard Solvent Z (micrograms Stoddard Solvent/second) = Y X 1,000,000 Z = X = 27,708 micrograms Stoddard Solvent/second B = Stack flow in actual cubic meters/second = A (actual cubic feet/minute)/2119 B = 450/2119 = actual cubic meters/second In-stack concentration (micrograms/cubic meter) = Z (micrograms Stoddard Solvent/second)/cubic meters/second) In-stack concentration = 27708/ = micrograms/cubic meter Adjusted-In-Stack (AIS) concentration = In-stack concentration/400 AIS = /400 = micrograms/cubic meter 24 hr AAL = 2641 micrograms/cubic meter Annual AAL = 1761 micrograms/cubic meter Hence, the AIS is less than 50% of either of the AALs and no permit restrictions are necessary for demonstrating compliance. 6. Interstat 50 Oleic acid CAS # , 5% by wt., a liquid Flash point = 200 deg F A VOC, not an RTAP or HAP 7. Emersol 233 LL Oleic Acid Oleic acid CAS # , 74% by wt. Palmitoleic acid CAS # , 11% by wt. Linoleic acid CAS # , 4% by wt. Myristoleic acid CAS # , 3% by wt. Flash point = 364 deg F All of these compounds are VOCs, not RTAPs or HAPs 8. Vertical Quicklime Calcium oxide CAS # , received as powder in tote bags and fed into mix tank Calcium oxide is an RTAP. No particulate emissions, No VOCs or HAPs. Assuming no particulate emissions, as it is mixed into the liquid plasticol mixture for overshoe production on the slush molding machines. 9. Black Repiplast/U Liquid paste, Boiling point > 190 deg F Has no VOC s, HAPs, or RTAPs. 10. Therm-Chek 8V100 Mineral spirits CAS # , 5-10% by wt., a VOC and RTAP Triphenyl phosphate CAS # , 5-10% by wt., a VOC A liquid with a flash point = 165 deg F 9 lb Therm-Chek X 0.10 lb Mineral Spirits/lb Therm-Chek/ lb plasticol batch = 2

8 X lb Mineral Spirits/3,349,704 lb plasticol mix total in 2004 X = lb Mineral Spirits/year and 4.49 lb Mineral Spirits/day assuming 365 day operation per year 24 hour deminimus = 7.9 lb/day Annual deminimus = 2888 lb/year Well under deminimus levels and no permit conditions required to restrict operations. 11.Cabosil Amorphous Fumed Silica Silicon dioxide CAS # , 100% by weight, a powder Not a VOC, RTAP, or HAP 3