ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

Transcription

1 ADEQ ARK A N S A S Department of Environmental Quality Jarrnry 16, 2fSf3 Earl Hightower Fluid Systems Division - Mena Plant 500 Marrow Street North Mena,AR Re: Notice ofadministrative Amendment AFIN: , Permit No.: 1013-AR-5 Dear Mr. Hightower: Enclosed is revised Permit #1013-AR-5 completed in accordance with the provisions of Section of Regulation No. 19, Regulations of the Arkansas Plan of Implementation for Air Pollution Control. As requested by the facility, two electric ovens (SN-45 and SN-46) have been added to the insignificant activities list. Also, the facility's process description has been updated to include these two sources. Please place the revised permit in your files. Sincerely, W;; ~,... ;~~ Mike Bates Chief, Air Division MG Enclosure ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS / TELEPHONE / FAX

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3 ADEQ MINOR SOURCE AIR PERMIT Permit #: 1013-AR-5 IS ISSUED TO: Fluid Systems Division - Mena Plant 500 Morrow St. North Mena, AR Polk County THIS PERMIT IS Fluid Systems Division - Mena Plant's AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT'S MINOR SOURCE AIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC ETSEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signe~: t~t,1ki0; Mike Bates Chief~ Air Division..Jarurry 16, 2CD3 Date Amended

4 Table of Contents Section I: FACILITY INFORMATION 3 Section II: INTRODUCTION 4 Section III: PERMIT HISTORY 6 Section IV: EMISSION UNIT INFORMATION 7 Section V: INSIGNIFICANT ACTIVITIES 15 Section VI: GENERAL CONDITIONS 16 2

5 Section I: FACILITY INFORMATION PERMITTEE: Fluid Systems Division - Mena Plant PERMIT NUMBER: AR-5 FACILITY ADDRESS: COUNTY: 500 Morrow S1. North Mena,AR Polk County CONTACT PERSON: Earl Hightower CONTACT POSITION: Environmental Manager TELEPHONE NUMBER: REVIEWING ENGINEER: Melisha Griffin UTMZone: 15 UTM North-South (Y): UTM East-West (X):

6 Summary Section II: INTRODUCTION Fluid Systems Division - Mena Plant is located at 500 North Morrow Street, Mena, Arkansas, is a manufacturer of medium to large electrical motors. The purpose of this modification is to add acetone to the list of allowed pollutants for SN-0I, SN-02 and SN-03. Process Description This facility produces motors of many different sizes and configurations depending on customer needs and application. Die cast, metal fabrication, painting, and dip and bake operations are conducted at this facility. Some small parts are sometimes purchased from other locations. Raw aluminum is delivered to the plant and melted down to be poured into molds to form various motor parts. Raw steel comes in the form of bar stock and plate steel. The bar stock is machined into rotor shafts while the plated steel is stamped into various motor parts. Coil steel is punched out into motor/core laminations. Large motor parts are washed and cleaned prior to prime painting or prime dipping. At times, motor parts may be sandblasted before reaching the prime painting or prime dipping process. The machined parts are then assembled and wound with copper wiring to form the stator portion of an electric motor. The stators are then dipped in polyester resin and baked. An anti-rust paint is applied onto the steel lamination sections of the rotors and shaft assemblies. The final product is assembled, tested, tagged, and prepared for shipment. The facility also builds pilot prototype electric motor wound stator cores for a vehicle fuel cell program. The manufacturing process for each unit requires the use of two electric ovens (SN-45 and SN-46). One oven (SN-45) is used to heat the wound stator core to a temperature of 200 degrees. The unit is moved from the oven and has a resin catalyst mixture trickled through the wire and then moved to another electric oven (SN-46) to be heated until the resin is cured. Regulations This facility is subject to regulation under Regulation 18, Arkansas Air Pollution Control Code (Air Code) and the regulations under Regulation 19, Arkansas Plan ofimplementation for Air Pollution Control (SIP). 4 Amended

7 The following table is a summaryof the facility's total emissions. Table 1 - Total Allowable Emissions TOTAL ALLOWABLE EMISSIONS Pollutant Emission Rates Ib/hr tpy PM PM SOz VOC* CO NO x Acetone*** Total HAPs Any Single HAP ** 9.5 Total VOC emlsslon this mcludes all sources. There IS a plantwlde 92 ton/yr limit on VOC emissions from all solvent operations including SN-4Z. Included in Total HAP emissions. **Air Contaminants such as ammonia, acetone, and certain halogenated solvents are not VOCs or HAPs. 5

8 Section III: PERMIT HISTORY Permit #1013-A was issued to U.S. Electrical Motors on AprilS, This was the first permit issued to the facility. Permit #1013-AR-l was issued to U.S. Electrical Motors on June 19, The purpose ofthis revision was to update emissions due to addition ofnew process equipment. Permit #1013-AR-2 was issued to U.S. Electrical Motors on August 2, The purpose of this revision was to reflect a reduction to 39.3 tons per year in its reported annual VOC emissions. Permit #1013-AR-3 was issued to U.S. Electrical Motors on July 15, The purpose ofthis revision was to allow U.S. Electrical Motors to increase the annual emissions ofvolatile organic compounds due to production expansion. Total VOC emissions from solvent use were 92 tons/yr based on a plantwide applicability limit. Permit #1013-AR-4 was issued to Fluid Systems Division - Mena Plant on February 5, The purpose of this modification was to replace the existing varnishing system (SN-9 thru SN-17) with a new varnishing system (SN-42) and to install an air cleaner system (SN-43) for removing smoke generated in the die-cast process. Both existing and proposed varnishing systems consisted of a dip tank and an oven. The new oven capacity was 2 MMBtu/hr, and the facility requested it to be considered an insignificant activity. The facility requested the use of a TLV table to allow increased flexibility of the type of HAP containing material used. 6

9 AFlN: Specific Conditions Section IV: EMISSION UNIT INFORMATION 1. The pennittee will not exceed the emission rates set forth in the following table. [ et seq. ofthe Regulations ofthe Arkansas Plan ofimplementation for Air Pollution Control, effective May 28,2006, (Regulation 19) and A.C.A as referenced by and ] Table 2 - Criteria Pollutants SN Description Pollutant Ib/hr tpy 01 Motor/Parts Spray Paint Booth VOC 18.0 PAL 02 Motor/Parts Spray Paint Booth VOC 18.0 PAL 03 Motor/Parts Spray Paint Booth VOC 18.0 PAL 04 Parts Washer Vent Large Rotors Spray Paint Booth VOC 12.0 PAL 08 Large Rotors Spray Paint Booth VOC 12.0 PAL 09 Dip and Bake Oven Retired from Service 10 Dip and Bake Oven Retired from Service 11 Dip and Bake Oven Retired from Service 12 Dip and Bake Oven Retired from Service 13 Dip and Bake Oven Retired from Service 14 Dip and Bake Oven Retired from Service 15 Dip and Bake Oven Retired from Service 16 Dip and Bake Oven Retired from Service 17 Dip and Bake Oven Retired from Service 18 North Dip Tank PM S VOC 0.6 PAL CO NOx Metal Pre-heating Electric Ovens

10 Permit #: 1013-AR-S 20 Bake-Out Oven PM S VOC 0.6 PAL CO NOx Electric Pre-Heat South Dip Tank PM S VOC 0.6 PAL CO NOx Nickel Plating Tank PM S VOC CO NOx Stator Bum Out Oven PM IO S VOC CO NOx Punch Press PM Primer Spray Booth VOC 10.0 PAL 27 Sand Blasting PM Samsco Water Evaporator PM S VOC CO NOx Primer Spray Booth VOC 10.0 PAL 30 Holcroft Furnace-Loading Door Holcroft Furnace PM S VOC CO NOx Holcroft Furnace PM S VOC CO NOx

11 33 Holcroft Furnace PM lo S VOC CO NOx Holcroft Furnace PM S VOC CO NOx Large Parts/Automated Dip Tank VOC 3.0 PAL 36 Large Parts/Automated Dip Tank VOC 3.0 PAL 37 Parts Washer Dryer Oven PM S VOC CO NOx Parts Washer Dryer Oven Bake Out Oven Moved to Insignificant Activities 42 Varnish Dip Tank (New) VOC Die Cast Process Vent PM (Fabric Filter).. PAL denotes Plantwlde Apphcablhty L,mIt of92 tons per year for VOC emissions from solvent operations. 9

12 2. The pennittee will not exceed the emission rates set forth in the following table. [ ofthe Arkansas Air Pollution Control Code, effective February 15, 1999 (Regulation 18) and A.c.A as referenced by and ] Table 3 - Non-Criteria Pollutants SN Description Pollutant Ib/hr tpy 01 Motor/Parts Spray Paint Booth Acetone Motor/Parts Spray Paint Booth Acetone Motor/Parts Spray Paint Booth Acetone North Dip Tank PM Bake-Out Oven PM South Dip Tank PM Nickel Plating Tank PM Stator Bum Out Oven PM Punch Press PM Sand Blasting PM Samsco Water Evaporator PM Holcroft Furnace PM Holcroft Furnace PM Holcroft Furnace PM Holcroft Furnace PM Parts Washer Dryer Oven PM Die Cast Process Vent PM (Fabric Filter) 3. Visible emissions will not exceed the limits specified in the following table ofthis pennit as measured by EPA Reference Method 9. [A.C.A as referenced by and ] Table 4 - Visible Emissions SN Limit Regulatory Citation 01 20% Regulation % Regulation 19 10

13 03 20% Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation % Regulation The pennittee will not cause or pennit the emission ofair contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation #18, ifthe emission ofthe air contaminant constitutes air pollution within the meaning ofac.a [ ofregulation 18, and AC.A as referenced by and ] 5. The pennittee will not conduct operations in such a manner as to unnecessarily cause air contaminants and other pollutants to become airborne. [ ofregulation 18, and AC.A as referenced by and ] 11

14 6. The pennittee shall not exceed 92 tons per year ofvoc from solvent operations based on a plantwide basis. [ et seq ofregulation 19 and A.c.A as referenced by and ] 7. The pennittee shall maintain monthly records which demonstrate compliance with Specific Condition 6. Records shall be updated by the fifteenth day of the month following the month to which the records pertain. A twelve (12) month rolling total shall be kept on site, and shall be made available to Department personnel upon request. [ ofregulation 19 and A.C.A as referenced by and ] 8. The pennittee shall not exceed the fonnulation ofhaps for the given minimum TLV in the following table in any HAP containing compound used at the facility. [ of the Arkansas Air Pollution Control Code, effective February IS, 1999 (Regulation 18) and A.C.A as referenced by and ] MinimumTLV Maximum Single HAP Content (mg/m3) (lb/gal) I The pennittee shall keep a copyofthe MSDS or other infonnation with HAP content for each HAP containing material. [ of Regulation 18 and A.C.A as referenced by and ] 10. The pennittee shall not emit in excess of9.5 tons ofany single hazardous air pollutant or 22.5 tons ofany combination ofhazardous air pollutants during any consecutive twelve (12) month period. [ ofregulation 18 and A.C.A as referenced by and ] 12

15 11. The permittee shall maintain monthly records which demonstrate compliance with Specific Condition 10. Records shall be updated by the fifteenth day ofthe month following the month to which the records pertain. A twelve (12) month rolling total shall be kept on site, and shall be made available to Department personnel upon request. [ ofregulation 18 and A.C.A as referenced by and ] 12. The permittee shall not exceed tons per year ofvoc emissions from varnish operations (SN-42). [ et seq ofregulation 19 and A.c.A as referenced by and I] 13. The permittee shall maintain monthly records which demonstrate compliance with Specific Condition 12. Records shall be updated by the fifteenth day of the month following the month to which the records pertain. A twelve (12) month rolling total shall be kept on site, and shall be made available to Department personnel upon request. [ ofregulation 19 and A.C.A as referenced by and ] 14. The HAPs known as MOl (CAS ) and HOI (CAS ) are each limited to one (I) ton per year. Due to extremely low vapor pressures these two compounds will not be subject to the TLV table established in Specific Condition 8. Furthermore, solutions containing these compounds may only be allowed to air dry. [ of Regulation 19 and A.C.A as referenced by and ] 15. The permittee shall maintain monthly records which demonstrate compliance with Specific Condition 14. Records shall be updated by the fifteenth day ofthe month following the month to which the records pertain. A twelve (12) month rolling total shall be kept on site, and shall be made available to Department personnel upon request. [ ofregulation 19 and A.C.A as referenced by and ] 16. The permittee shall not use any HAP containing material in which the total HAP content exceeds 6 Ib HAP per gallon. Compliance with this condition will be demonstrated by compliance with Specific Condition 8 and Specific condition 9. [ ofregulation 19 and A.C.A as referenced by and ] 17. The permittee shall only bum natural gas or propane as fuel for this facility. [ of Regulation 19 and A.C.A as referenced by and ] 18. The permittee shall not use more than 576 gallons per day ofpaint products containing HAPs. [ ofregulation 19 and A.C.A as referenced by and ] 13

16 19. The pennittee shall maintain daily records which demonstrate compliance with Specific Condition 18. These records shall be kept on site, and shall be made available to Department personnel upon request. [ ofregulation 19 and A.c.A as referenced by and I ] 20. The pennittee shall not emit in excess of9.5 tons ofacetone in SN-Ol, SN-02 and SN-03 combined during any consecutive twelve (12) month period. [ ofregulation 18 and A.C.A as referenced by and ] 21. The pennittee shall maintain monthly records which demonstrate compliance with Specific Condition 20. Records shall be updated by the fifteenth day ofthe month following the month to which the records pertain. A twelve (12) month rolling total shall be kept on site, and shall be made available to Department personnel upon request. [ ofregulation 18 and A.C.A as referenced by and ] 14

17 Section V: INSIGNIFICANT ACTIVITIES The Department deems the following types ofactivities or emissions as insignificant on the basis ofsize, emission rate, production rate, or activity in accordance with Group A ofthe Insignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activity emission determinations rely upon the information submitted by the permittee in an application dated 11/15/2006. Table 5 - Insignificant Activities Description Category Primer Spray Paint Booth (SN-39) Regulation 19, Appendix A, Group A, #13 Bake Oven (SN-40) Regulation 19, Appendix A, Group A, #13 Bake Oven (SN-41) Regulation 19, Appendix A, Group A, #13 Bake Oven (located at SN-42) Regulation 19, Appendix A, Group A, #13 3 Stage Parts Washer Regulation 19, Appendix A, (SN-05, SN-06 and SN-44) Group A, #13 Electric Oven (SN-45) Regulation 19, Appendix A, Group A, #13 Electric Oven (SN-46) Regulation 19, Appendix A, Group A, #13 15 Amended

18 AFlN: Section VI: GENERAL CONDITIONS 1. Any tenns or conditions included in this pennit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (AC.A l et seq.) as the sole origin ofand authority for the tenns or conditions are not required under the Clean Air Act or any ofits applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (AC.A et seq.). Any tenns or conditions included in this pennit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (AC.A et seq.) as the origin ofand authority for the tenns or conditions are enforceable under this Arkansas statute. 2. This pennit does not relieve the owner or operator ofthe equipment and/or the facility from compliance with all applicable provisions ofthe Arkansas Water and Air Pollution Control Act and the regulations promulgated under the Act. [AC.A as referenced by AC.A and ] 3. The pennittee will notify the Department in writing within thirty (30) days after commencement ofconstruction, completion ofconstruction, first operation ofequipment and/or facility, and first attainment of the equipment and/or facility target production rate. [ ofthe Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation 19) and/or AC.A as referenced by AC.A and ] 4. Construction or modification must commence within eighteen (18) months from the date ofpennit issuance. [ (B) of Regulation 19 and/or (B) ofthe Arkansas Air Pollution Control Code (Regulation 18) and AC.A as referenced by AC.A and ] 5. The pennittee must keep records for five years to enable the Department to detennine compliance with the tenns ofthis pennit; such as hours ofoperation, throughput, upset conditions, and continuous monitoring data. The Department may use the records, at the discretion ofthe Department, to detennine compliance with the conditions ofthe pennit. [ ofregulation 19 and/or ofregulation 18 and AC.A as referenced by AC.A and ] 6. A responsible official must certify any reports required by any condition contained in this pennit and submit any reports to the Department at the address below. [ of Regulation 19 and/or ofregulation 18 and AC.A as referenced by AC.A and ] 16

19 Arkansas Department ofenvironmental Quality Air Division ATTN: Compliance Inspector Supervisor 5301 Northshore Dive North Little Rock, AR The permittee will test any equipment scheduled for testing, unless stated in the Specific Conditionsof this permit or by any federally regulated requirements, within the following time frames: (1) newly constructed or modified equipment within sixty (60) days ofachieving the maximum production rate, but no later than 180 days after initial start-up ofthe permitted source or (2) existing equipment already operating according to the time frames set forth by the Department. The permittee must notify the Department ofthe scheduled date ofcompliance testing at least fifteen (15) days in advance ofsuch test. The permittee must submit compliance test results to the Department within thirty (30) days after the completion of testing. [ of Regulation 19 and/or of Regulation 18 and A.c.A as referenced by A.C.A and ] 8. The permittee will provide: [ of Regulation 19 and/or 18.l002 of Regulation 18 and A.C.A as referenced by A.C.A and ] a. Sampling ports adequate for applicable test methods; b. Safe sampling platforms; c. Safe access to sampling platforms; d. Utilities for sampling and testing equipment. 9. The permittee will operate equipment, control apparatus and emission monitoring equipment within their design limitations. The permittee will maintain in good condition at all times equipment, control apparatus and emission monitoring equipment. [ ofregulation 19 and/or ofregulation 18 and AC.A as referenced by AC.A and ] 10. Ifthe permittee exceeds an emission limit established by this permit, the permittee will be deemed in violation ofsaid permit and will be subject to enforcement action. The Department may forego enforcement action for emissions exceeding any limits established by this permit provided the following requirements are met: [ f Regulation 19 and/or 18.l101 ofregulation 18 and AC.A as referenced by AC.A and ] a. The permittee demonstrates to the satisfaction ofthe Department that the emissions resulted from an equipment malfunction or upset and are not the result ofnegligence or improper maintenance, and the permittee took all reasonable measures to immediately minimize or eliminate the excess emissions. 17 Amended

20 b. The permittee reports the occurrence or upset or breakdown ofequipment (by telephone, facsimile, or overnight delivery) to the Department by the end ofthe next business day after the occurrence or the discovery ofthe occurrence. c. The permittee must submit to the Department, within five business days after the occurrence or the discovery ofthe occurrence, a full, written report ofsuch occurrence, including a statement ofall known causes and ofthe scheduling and nature ofthe actions to be taken to minimize or eliminate future occurrences, including, but not limited to, action to reduce the frequency ofoccurrence ofsuch conditions, to minimize the amount by which said limits are exceeded, and to reduce the length oftime for which said limits are exceeded. Ifthe information is included in the initial report, the information need not be submitted again. 11. The permittee will allow representatives of the Department upon the presentation of credentials: [AC.A as referenced by A.C.A and ] a. To enter upon the permittee's premises, or other premises under the control ofthe permittee, where an air pollutant source is located or in which any records are required to be kept under the terms and conditions ofthis permit; b. To have access to and copy any records required to be kept under the terms and conditions ofthis permit, or the Act; c. To inspect any monitoring equipment or monitoring method required in this permit; d. To sample any emission ofpollutants; and e. To perform an operation and maintenance inspection ofthe permitted source. 12. The Department issued this permit in reliance upon the statements and presentations made in the permit application. The Department has no responsibility for the adequacy or proper functioning ofthe equipment or control apparatus. [AC.A as referenced byac.a and 8-4-3II] 13. The Department may revoke or modify this permit when, in the judgment of the Department, such revocation or modification is necessary to comply with the applicable provisions ofthe Arkansas Water and Air Pollution Control Act and the regulations promulgated the Arkansas Water and Air Pollution Control Act. [ I9.41O(A) of Regulation 19 and/or I8.309(A) ofregulation 18 and A.C.A as referenced by A.C.A and 8-4-3II] 14. This permit may be transferred. An applicant for a transfer must submit a written request for transfer ofthe permit on a form provided by the Department and submit the disclosure statement required by Arkansas Code Annotated 8-I-I06 at least thirty (30) days in advance ofthe proposed transfer date. The permit will be automatically 18

21 transferred to the new pennittee unless the Department denies the request to transfer within thirty (30) days ofthe receipt ofthe disclosure statement. The Department may deny a transfer on the basis ofthe infonnation revealed in the disclosure statement or other investigation or, deliberate falsification or omission ofrelevant infonnation. [ (B) ofregulation 19 and/or (B) ofregulation 18 and ACA as referenced by AC.A and ] 15. This pennit shall be available for inspection on the premises where the control apparatus is located. [AC.A as referenced by AC.A and ] 16. This pennit authorizes only those pollutant emitting activities addressed herein. [A.CA as referenced by and ] 17. This pennit supersedes and voids all previously issued air pennits for this facility. [Regulation 18 and 19 and A.CA as referenced by and 8-4-3l1] 18. The pennittee must pay all pennit fees in accordance with the procedures established in Regulation No.9. [AC.A 8-l-l05(c)] 19

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