ENGINEERING CALCULATION SHEET AIR RESOURCES DIVISION

Transcription

1 Page 1 of 6 DATE APPLICATION RECEIVED July 01, 1996; Application # FY96-TV045 FACILITY DESCRIPTION Venture-Seabrook ( Venture ), located at 700 Lafayette Road in Seabrook, New Hampshire, manufactures painted and unpainted thermoplastic components such as vehicle side claddings, bumper covers, wheel fender extensions and grille components for the automotive industry. Venture s plastic parts manufacturing process consists of injection molding, power washing/drying, plastic parts coating, and miscellaneous assembly activities. Venture uses three types of thermoplastics, namely polyethylene terephthalate resin (PET), thermopastic polyolefin (TPO), and thermoplastic polyurethane (TPU), to manufacture plastic parts. Injection molding involves heating of raw material as it is injected into a metal cavity or tool. This phase of the manufacturing process involves the storing, pneumatic transfer, blending, drying, heating, molding, degating, and de-flashing (or trimming) of thermoplastic resins. As part of the injection molding phase, Venture operates dryers to remove moisture from the plastic stock prior to molding. This phase also involves re-grinding (recycling) of plastic parts that did not meet quality control standards. After the parts are molded and trimmed, they are hung on one of two conveyor lines. Each of the two lines enters a power washer (spray tunnel) designed to remove dust and finger prints from the parts. The power washing operation consists of five stages. The first stage subjects the parts to a mildly acidic or alkaline (aqueous) detergent spray, followed by a heated rinse spray station, a second (unheated) rinse spray, a deionized water rinse spray station, and finally a dry-off oven. After the parts are washed, rinsed and dried, the conveyor moves through several paint spray booths where various coatings are sprayed. Four types of coatings are applied to the surface of thermoplastic automotive components: (1) conductive adhesion promoters (CAP), (2) flexible primers, (3) high bake color coatings, and (4) high bake clear coatings. Process equipment associated with the coating lines is cleaned daily. The paint supply lines and paint recirculation system are cleaned or flushed with solvent when the type (or color) of the coatings is changed. A number of the painted thermoplastic parts require attachment devices like clips, studs, emblems, brackets etc to be affixed to the part prior to packaging and shipping. This may also include the application of methyl isobutyl ketone (3M Tape Adhesion Promoter) so the adhesive on the double-stick mounting tape chemically melds with the painted surface. The air emissions, at the facility, are generated from fuel burning devices which emit criteria pollutants and from the manufacturing of thermoplastic parts which emits volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). The facility is a major source for VOCs & HAPs and is therefore required to obtain a. PROJECT DESCRIPTION To issue a Title Operating Permit. EMISSION UNIT DESCRIPTION Table 1 - Significant Activity Identification Emission Unit # Description of Emission Unit Emissions Unit Maximum Permitted Capacity EU01 Hodge Boiler #1 The maximum operating rate of the boiler is limited to MMBTU/hr of heat input (#4 fuel oil). EU02 Hodge Boiler #2 The maximum operating rate of the boiler is limited to MMBTU/hr of heat input (#4 fuel oil). EU03 Cleaver Brooks Boiler #3 The maximum operating rate of the boiler is limited to MMBTU/hr of heat

2 Page 2 of 6 Table 1 - Significant Activity Identification Emission Unit # Description of Emission Unit Emissions Unit Maximum Permitted Capacity EU04 EU hp Cummins Emergency Generator (uses Diesel as fuel) 255 hp Cummins Emergency Fire Pump (uses Diesel as fuel) input (#4 fuel oil/natural gas). Hours of operation limited to 500 hours/yr/each Combined NOx emissions are limited to 25 tons/yr. EU06 Injection molding 1 The maximum capacity of the injection molding process is limited to 20 million pounds (i.e.,10,000 tons) of thermoplastics per year. EU07 EU08 Paint Line A consisting of: 1. Power Wash 2 - Line A a) Wash Station b) Heated Rinse Station c) Dry-off Oven 2. Spray booth A1 (ACAP #1) 3. Spray booth A2 (ACAP #2) 4. Spray booth A3 (Color coat) 5. Spray booth A4 (Color coat) 6. Spray booth A5 (Clear coat) 7. Spray booth A6 (Clear coat) 8. Curing oven A 9. Curing oven C 10. Two small paint mix rooms 11. Mixing room/kitchen 3 Paint Line B consisting of: 1. Power Wash - Line B The wash stations/curing ovens are permitted to burn NG/Liquefied Petroleum Gas (LPG) and the maximum heat input to each device is limited as follows: Wash station MMBTU/hr Heated Rinse Station MMBTU/hr Drying Oven MMBTU/hr Curing oven A MMBTU/hr Curing oven C MMBTU/hr Paint line A (as of December 2003) is equipped with: Five electrostatic spray guns Five high volume low pressure (HVLP) spray guns Two robots (Nordson 4 RA Rotary Atomizer type) The wash stations/curing ovens are permitted to burn NG/LPG and the maximum heat input to each device is limited as follows: Washer Station MMBTU/hr. 1 Injection molding - Pursuant to Env-A (g), a permit is needed if actual VOC emissions are greater than 10 TPY; In the TV application this was identified as an insignificant activity. However, actual VOC emissions: 29 TPY (in 2002), 17.4 tons (in 2001), 18.4 tons (in 2000); Emission factor used = 10 lb VOCs emitted/ton of resin processed [Source: Michigan DEQ s Emission Calculation Fact Sheet (#9847 Rev. 12/01) for Plastic Production & Products Manufacturing] 2 Power wash operations - No RTAPs in the power wash solutions. 3 Main paint mixing for the entire facility.

3 Page 3 of 6 Table 1 - Significant Activity Identification Emission Unit # Description of Emission Unit Emissions Unit Maximum Permitted Capacity a) Wash Station b) Heated Rinse Station c) Heated Rinse Station d) Dry-off Oven 2. Spray booth B1 (BCAP #1) 3. Spray booth B2 (BCAP #2) 4. Spray booth B3 (Color coat) 5. Spray booth B4 (Color coat) 6. Spray booth B5 (Color coat) 7. Spray booth B6 (Clear coat) 8. Spray booth B7 (Clear coat) 9. Curing oven B with two zones Heated Rinse Station MMBTU/hr Heated Rinse Station MMBTU/hr Drying Oven MMBTU/hr Curing oven B Zone #1-2.5 MMBTU/hr Curing oven B Zone #2-3.0 MMBTU/hr Paint line B (as of December 2003) is equipped with: Two electrostatic spray guns Fourteen high volume low pressure (HVLP) spray guns Two robots (Nordson 4 RA Rotary Atomizer type) EU09 Blu-surf oven 4 The burner for the blu-surf oven is permitted to burn NG/LPG and is limited to 5.1 MMBTU/hr. EU10 Air make-up preheaters 5 Preheater A penthouse Preheater B North Preheater B South Preheater A penthouse is limited to a maximum heat input of 8.1 MMBTU/hr and is permitted to burn NG/LPG. Units B North and B South are limited to a maximum heat input of 6.5 MMBTU/hr each and are permitted to burn NG/LPG. 4 Blu-suf oven is below the permitting threshold of 200 lbs/hr of type 5 waste (Env-A (f)); According to an old ARD form (dated 2/1/1979), the oven s capacity is rated at 62 lbs/hr (also see PO-C-319). However actual emissions are greater than 1000 lbs/yr ( tons) and hence it is a significant activity. 5 These units are rated below the permitting threshold of 10 MMBTU/hr; However, actual emissions from each of these units are greater than 1000 lbs/yr.

4 Page 4 of 6 INSIGNIFICANT ACTIVITIES Table 2 - Insignificant activities Unit # Description Reason 1. 4 space heaters each rated at 3 MMBTU/hr each. They use NG/LPG as fuel 2. LP Heater rated at 1 MMBTU/hr 3. Unit BCAP booths AMU (Air makeup preheater) rated at 3.5 MMBTU/hr Below permitting threshold; Actual emissions are less than 1000 lbs/yr. 4. Preheater A booth 4 rated at 4.5 MMBTU/hr Air make-up pre heater rated at 4.0MMBTU/hr. 5. Safety-kleen Degreaser 6 Below permitting threshold; Actual emissions are less than 1000 lbs/yr. MINOR CORE ACTIVITY In accordance with Env-A (d), minor core activities of VOCs at a stationary source, as defined in Env-A , having total aggregate emissions of not more than 5 tons per year, combined for all classifiable and unclassifiable processes and/or devices, shall be excluded from the provisions of Env-A CALCULATIONS Boilers 1, & 2 rated at MMBTU/hr each, #4 fuel oil Table 3 - for Hodge Boilers 1 & CO VOCs Emission rates are for each boiler. Maximum sulfur content of the fuel oil = 1% 6 Not subject to VOC RACT for solvent metal cleaning (Env-A , old rule); Actual VOC emissions are less than 5 TPY; See below: AP-42 Chapter 4.6 Solvent Degreasing, Table Emissions for the entire unit (Cold cleaner) = 0.33 tons/yr/unit. EIIP, Volume III, Solvent Cleaning, Table 6.5-1, Safety-kleen Emissions Data for Cold Cleaners - worst case annual solvent loss for a Safety-kleen model degreaser is 81 gallons x 6.7 lb/gal = 543 lbs/yr.

5 Page 5 of 6 Cleaver Brooks Boiler #3 rated at MMBTU/hr, #4 fuel oil/ng fired Table 4 - for Boiler # CO 0.52 (for oil) (for NG) 5.13 VOCs Emergency generator rated at 335 HP Table 5 - for the Emergency Generator CO Fuel flow rate = 16.5 gal/hr Emergency fire pump rated at 255 HP Table 6 - for the Emergency Generator CO Fuel flow rate = 10.8 gal/hr Heating Values of fuels:

6 Page 6 of 6 LPG = 94,000 BTU/gal #4 Fuel oil = 140,000 BTU/gal Diesel = 137,000 BTU/gal Natural gas = 1050 BTU/scf APPLICABLE RULES NSPS N/A NESHAP Facility is subject to 40 CFR 63, subpart PPPP - Surface coating of Plastic Parts; On August 22, 2003, EPA issued the final rule for surface coating of plastic parts and products. This rule has not yet been published in the Federal Register. The degreaser is not subject to 40 CFR 63, subpart T Halogenated Solvent Cleaning because the solvent used in it does not contain any of the HAPs listed in 40 CFR (a) in concentrations greater than 5% by weight. Facility is not subject to MACT standard for Reinforced Plastic Composites Production (40 CFR 63, subpart WWWW). Pursuant to 40 CFR , this standard is applicable to those facilities using thermoset resins. Venture uses thermoplastics as raw material for it s injection molding process. Facility is subject to 40 CFR 63, subpart DDDD??? check Env-A 609 Title V operating permits Env-A 700 Permit Fee System Env-A 800 Testing & Monitoring Procedures Env-A 900 Owner/Operator Obligations Env-A 1204 VOC RACT requirements for Surface coating of Plastic parts (Env-A ) Facility is also subject to Env-A (Miscellaneous and Multi category VOC sources). Venture has one classifiable core process namely, Plastic Parts Coating Process (EU07 & EU08) and one unclassifiable core process namely, Injection Molding (EU06). This Title V permit requires Venture to initiate a VOC RACT order process for the injection molding process within three months after the issuance of this (compliance plan). Env-A 1211 All emergency generators including the fire pump, are limited to operate less than 500 hours during any consecutive 12 monthperiod and the combined theoretical potential emissions of from all such generators are limited to less than 25 tons for any consecutive 12-month period. Facility-wide emissions are limited to less than 50 TPY to opt out of RACT for miscellaneous stationary source (in accordance with Env-A (n)). Actual emissions of never exceeded 50 TPY since Env-A 1400 Regulated Toxic Air s Env-A 1600 Fuel Specifications Env-A 1900 Incinerators (applicable to Blu-surf oven) Env-A 2000 Fuel burning devices Env-A 2100 Process, Manufacturing, & Service based Industries Note: A facility-wide VOC limit will be established under a PAL (plant-wide applicability limit) permit. MODELING SUMMARY AND CONCLUSIONS In summary, the operations as applied for will be capable of meeting all regulations and standards for air quality. Title V Permit shall therefore be issued.