COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection July 2, / Fax: 814/

Transcription

1 COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection July 2, / Fax: 814/ SUBJECT: Review of Application for State Only Operating Permit AUTH ID# ; PF ID# ; APS ID # IDL Worldwide Cloverleaf Group East Butler Borough, Butler County TO: AQ/Facilities/F ACOP/ NM FROM: Matthew Williams /21. LJ Facilities Permitting Chief Air Quality Program -Northwest Region THROUGH: John F. Guthc:M Air Quality P7;:;r~m Manager Northwest Region Introduction: The Department received the subject application for a renewal of the Operating Permit for IDL Merchandising on December 28, The permit was previously issued on July 22, 2008 with an expiration of June 30, The sources covered by this Permit were constructed under Plan Approvals A and B. The facility operates printing presses, a screen wash unit, spray booth, emergency engines, and combustion units, as well as other insignificant sources. The emergency engines are subject to Federal requirements for Reciprocating Internal Combustion Engines (RICE). Site Level Requirements: The facility Standard Industrial Classification (SIC) code is Commercial Printing. The facility is required to comply with fugitive, fugitive particulate, malodor, opacity, and open burning requirements found in 25 Pa. Code Sections 123.1, 123.2, , , , , and respectively. The facility is not required to comply with the emissions reporting in accordance with 25 Pa. Code Sections 135.3, 135.4, and because the facility actual VOC emissions are much less than 10 TPY. For example, the actual emissions of the ink usage and VOC I HAP emissions summary for June 1, 2012 to May 31,2013 indicated the facility only emitted 336 pounds ofvoc and 34 pounds ofhaps. The VOC emissions from the engines and other combustion sources are less than 1 TPY. The permittee has a VOC emission limit of 49.5 TPY, a single HAP emission limit of9.8 TPY, and total HAPs emission limit of 24.8 TPY (each based on a consecutive 12-month rolling period). The emission limitations for VOC and HAPs were derived from each press using 5,000 gallons of ink per year (63,000

2 Cloverleaf Group Inc IDL Worldwide NMOP gallons/yr for the facility) and limiting the facility to "Minor" status(< 50 tpy VOC and < 10 tpy for any single HAP and < 25 TPY for total HAPs). The permittee is required to keep records of the 30-day rolling total and 12-month rolling totals for VOC and HAPs. The permittee must also keep records of the daily consumption of each solvent used (gallons/day); the density of each solved as supplied (or specific gravity); and the VOC I HAP content of each solvent as supplied (#/gallon of ink). The prohibition of air pollution in 25 Pa Code was added to the permit during this renewal. Sources and Requirements: Source 031: This source accounts for two combustion units which are rated over 2.5 mmbtulhr. The units are: C-1 2 Johnson Aerolator located in the Shipping area rated at 3,365,000 BTU/hr, and C-13 Johnson Aerolator located in the Shipping area rated at 4,925,000 BTU/hr. This source is subject to the particulate emission restrictions of and the sulfur restrictions of These requirements were added to the permit during this renewal. The faci lity is also required to maintain and operate these units in accordance with the manufacturers specifications and consistent with good air pollution control practices. Source 113, 117 and 118: These presses (Thieme 1 Press; Thieme 5 Press; and Thieme 5 XL Press) primarily use UV coatings but can also use VOC containing inks. There are no NSPS or NESHAP requirements for these presses. The presses are subject to the particulate emission restriction from 25 Pa. Code Section The presses are subject to recordkeeping requirements for preventative maintenance inspections (conducted weekly); daily consumption of each solvent used (gallons/day); the density of each ink as supplied (or specific gravity); and the VOC I HAP content of each ink as supplied and as used (#/gallon of ink). For ink series, the ink with the highest VOC and HAP content may be used to represent all inks of that series. These requirements originated from Plan Approval A and B. The facility is also required to maintain and operate the source in accordance with the manufacturer' s specifications and in accordance with good air pollution control practices. All solvent containers must be closed at all times except when filling, draining or performing cleanup operations. All solvent laden shop towels must be kept in a closed container when not being used to prevent fugitive emissions of volatile organic compounds. The press uses an electric heater for drying the coating. In the previous permit, the requirements for the sources were separated because they were from two different plan approvals. After further consideration, since the requirements are identical (except for the reference to the respective plan approval), they were combined into one group entitled "Presses". The facility also had other presses in the previous permit which have since been removed from the facility and have been removed from the permit during this renewal (Sources 105, 106, 109, 110, 112, and 114) The removal ofthe sources was verified by the August 25, 2010 and March 6, 2012 FCE inspections conducted by the Department.

3 CloverleafGroup Inc IDL Worldwide NMOP Source 107 The screen wash machine is manufactured by Image Technology and is model SWR2000. The machine is used for the washing of ink from screens from the screen-printing operations. The machine uses a non VOC solution for cleaning and therefore there are no VOC emissions from this source. The source shall be maintained and operated in accordance with manufacturer's specifications and in accordance with good air pollution control practices. Source 115 This source was approved under Plan Approval A. The facility had two identical spray paint booths (one in the wood shop area and one in the prototype area). The booths are manufactured by Global Finishing Solutions and are model PEC The design inlet volume is F. A wall of filter banks to capture particulate matter controls the spray booths. The booths are subject to the particulate emission restriction from 25 Pa. Code Section The sources are also subject to the surface coating regulations from 25 Pa. Code Section The permittee must keep records of the preventative maintenance inspections ofthe control device (conducted on a weekly basis) and the pressure drop across the control device. The permittee must operate the control device at all times that the source is in operation. The facility is also required to maintain and operate the source in accordance with the manufacturer's specifications and in accordance with good air pollution control practices. The minimum pressure drop provided to the Department as part of the maintenance record during the January, 29, 2008 initial operating permit inspection was 0.06 inches for the prototype spray booth. The booth in the wood shop area is no longer in service and therefore the description of this source was modified to reflect only one spray booth. Source 116 This source was approved under Plan Approval A. The wood shop consisted of various equipment that exhaust to a 20, 000 cfrn baghouse. The baghouse was removed from service as indicated in a letter from the facility received on November 30, The equipment was re-routed to two small internally vented dust collectors which were installed in the facility. These two collectors are not subject to any additional requirements because the emissions are indoors. Source 116 was removed from the permit during this renewal Emergency Generators and Fire Pump The facility has emergency power and emergency fire suppression equipment at the facility. This source consists of five units. Two ofthe units are Onan Generators (60 KW and 7.5 KW) each less than 100 HP. A third unit is a Kohler Emergency Generator that is fueled by natural gas (30 KW). The Fourth unit is a Caterpillar Emergency Generator fueled with diesel (370 KW I 545 HP based on the nameplate information). The final unit is a Patton Fire Pump with a Cummins Diesel engine rated at 255 HP (nameplate). The units were exempted from plan approval based on 25 Pa. Code Section (a)(8) exemption list item #6. The combined NOx emissions from all these sources is less than 100 lbs/hr, 1000 lbs/day, 2.75 tons per ozone season and 6.6 tons per year on a 12-month rolling basis. The engines were restricted to operating less than 500 hours per year. The Facility shall maintain sufficient records

4 Cloverleaf Group Inc IDL Worldwide NMOP to determine compliance with the restriction on hours of operation including the times the source is operated (hours, date, and duration of each time the engine is operated and the reason the source was operated). The emergency generators and emergency fire pump shall only be used during electrical failures I emergency fires, or to perform preventative maintenance. The emergency generators shall not be used to supplement the primary power supply to the facility. The Facility shall keep a record of the date of any electrical interruption, the cause of the electrical interruption, and the duration of the electrical interruption. The units were constructed prior to The units are subject to the 40 CFR 63 Subpart ZZZZ pertaining to the NESHAPs for Stationary RICE Requirements as follows: The engines are subject to the ZZZZ requirements because the facility is an area source and the RICE uses reciprocating motion to convert heat energy into mechanical work and it is not mobile The stationary RICE is located at an area source and commenced construction prior to June 12, 2006 and is therefore considered an existing affected source The compliance date for the diesel engines which are compression ignition (CI) is May 3, The natural gas spark ignition (SI) engines must be in compliance by October 19, The engines are subject to Table 2d of the Subpart which includes: a. Change oil and filter every 500 hours of operation or annually, whichever comes first; b. Inspect spark plugs every 1,000 hours of operation or annually, whichever comes first, and replace as necessary (for the SI engines) and for the CI engines the inspection is for the air cleaner; c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary Operate and maintain the affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions Operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop your own maintenance plan. Minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes. The facility has the option of utilizing an oil analysis program in order to extend the specified oil change requirement by comparison of the Total Acid Number (for SI engines) and Total Base Number (for CI engines), viscosity, and percent water content with established parameters Comply with the work or management practices by: i. Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or ii. Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. Operation of the engine for maintenance checks and readiness testing cannot exceed 100 hours. There is no time limit on emergency use. The nonemergency use was clarified in the January 2013 amendment to include up to 50 hours of nonemergency use such as peak shaving, load management, and demand response provided that the use does not exceed 50 hours and is part ofthe 100 hour limit. When the engines were exempted, they were limited to use during electrical failures I emergency fires, or for preventative maintenance. They were not allowed to be used to supplement the primary power supply to the facility Keep records of each occurrence and duration of each malfunction of operation. Keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan. Keep records of actions taken during malfunctions. Keep records of

5 CloverleafGroup Inc IDL Worldwide NMOP hours of operation through the non-resettable meter. Document the time operated classified as emergency, maintenance, and non-emergency Format and duration of the records that need to be kept Table 8 to this subpart shows which parts of the General Provisions in 63.1 through apply Refer to 40 CFR for the definitions that applies to this subpart Parts Washer During the previous Operating Permit inspection, a new parts washer was identified but not yet operational. This source is subject to 25 Pa. Code Section (a). The source was created in the permit. This source was never used and the facility decided to instead use a solvent free Smart Washer which is not subject to the requirements of and therefore, this source was removed from the permit during this renewal. The Sources have been identified as follows in the Miscellaneous Section of the Permit: Source 113 (Thieme 1 Press) consists of the following: 1. Thieme 1 press (Thieme 3060L) (600 sheetslhr) 2. SPS TS Electric dryer Source 115 (Paint Booth) consists of the following: 1. Global Finishing Solutions spray paint booth model PEC-1610 controlled by individual wall of filter banks for each booth located in the Prototype area. Source 117 (Thieme 5 Color Screen Press) consists of the following: 1. Thieme 5 press (Thieme 5060XL) (800 sheetslhr) 2. Thieme Electric dryer ( 4,803 cfmlunit) Source 118 (Thieme 5 Color Screen Press) consists of the following: 1. Thieme 5 press (Thieme 5060XL) (800 sheets/hr) 2. Thieme Electric dryer (4,803 cfrn/unit) Source 119 consists of the following emergency power and fire suppression equipment: 1. ONAN 60 Emergency Generator, Natural Gas, installed in 1989 (60KW I 90 HP). 2. ONAN 7.5 Emergency Generator, Natural gas, relocated from facility security room to Building 300 in 1989 (7.5KW I HP). 3. KOHLER Emergency Generator, Natural Gas, Installed January 1979 (30KW I 45 HP). 4. Caterpillar Emergency Generator, Diesel, Installed 1979 (370KW I 545 HP). 5. Patton Fire Pump w I Cummins Diesel, Manufactured January 1972 (255 HP). Additional Sources: The facility also has the following insignificant sources which are not subject to additional requirements:

6 CloverleafGroup Inc IDL Worldwide NMOP Combustion sources fueled with natural gas only as identified as follows: a. C-1 Raypak Boiler located on S 1 roof rated at 419,000 BTU/hr b. C-2 Raypak Boiler located on S 1 roof rated at 419,000 BTU/hr c. C-3 Raypak Boiler located on S2 roof rated at 319,000 BTU/hr d. C-4 Raypak Boiler located on S2 roof rated at 319,000 BTU/hr e. C-5 Raypak Boiler located on R5 roof rated at 501,600 BTU/hr f. C-6 Raypak Boiler located on R5 roof rated at 501,600 BTU/hr g. C-7 Raypak Boiler located on R6 roof rated at 501,600 BTU/hr h. C-8 Raypak Boiler located on R6 roof rated at 501,600 BTU/hr i. C-9 Peerless Boiler located in the Prototype area rated at 1,512,000 BTU/hr j. C-1 0 Johnson Aerolator located in the Woodshop area rated at 2,400,00 BTU/hr k. C-11 Johnson Aerolator located in the Connector area rated at 1,800,000 BTU/hr 1. C-14 Infrasave radiant heater located in the Shipping area rated at 130,000 BTU/hr m. C-15 Infrasave radiant heater located in the Shipping area rated at 130,000 BTU/hr n. C-16 Infrasave radiant heater located in the Shipping area rated at 130,000 BTU/hr o. C-17 Infrasave radiant heater located in the Shipping area rated at 130,000 BTU/hr p. C-18 Dayton radiant heater located in the Lunchroom area rated at 90,000 BTU/hr q. C-19 Dayton radiant heater located in the Lunchroom area rated at 90,000 BTU/hr r. C-20 Dayton radiant heater located in the Lunchroom area rated at 90,000 BTU/hr s. C-21Dayton radiant heater located in the Lunchroom area rated at 90,000 BTU/hr t. C-22 Re-Verber-Ray heater located in the Screen Prep area rated at 150,000 BTU/hr u. C-23 Re-Verber-Ray heater located in the Screen Prep area rated at 150,000 BTU/hr v. C-24 Re-Verber-Ray heater located in the Screen Prep area rated at 150,000 BTU/hr w. C-25 Infrasave radient heater located in the Fulfillment area rated at 130,000 BTU/hr x. C-26 Infrasave radient heater located in the Packaging area rated at 130,000 BTU/hr y. C-27 Infrasave radient heater located in the Packaging area rated at 130,000 BTU/hr z. C-28 Reznor heater located in the Maintenance area rated at 105,000 BTU/hr aa. C-29 lnfrasave radient heater located in the Receiving area rated at 130,000 BTU/hr ab. C-30 Re-Verber-Ray heater located in the Box Making area rated at 150,000 BTU/hr ac. C-31 Re-Verber-Ray heater located in the Die Making area rated at 150,000 BTU/hr ad. C-32 Hot water heater (97 gal) located in the Receiving area rated at 197,000 BTU/hr ae. C-33 Hot water heater ( 40 gal) located in the Maintenance area rated at 34,000 BTU/hr af. C-34 Hot water heater (75 gal) located in the Cafeteria area rated at 75,000 BTU/hr 2. Production/ Process Sources as follows: a. P-1 Digitial Printing consisting of 3 inkjet plotters, Inca digital printer, and Butek Digital Printer. These sources use minor quantities of acetone, isopropyl alcohol, printing inks and UV inks. b. P-2 Prototype assembly located in the Prototype area- uses minor quantities of glues and adhesives. c. P-3 Production assembly located in the Assemble areas -use minor quantities of glues and adhesives. d. P-4 Foam packaging located in the Packaging area -uses minor quantities of a 2-part expandable foam. e. P-5 Die Cutting I Die Making located in the Production area- uses minor quantities of glue.

7 Cloverleaf Group Inc IDL Worldwide NMOP Non-Production Sources as follows: a. NP-1 Facility Maintenance Shop/ Facility-Wide areas use minor quantities of latex paints, greases, lubricants, and cleaners. b. NP-2 Welding Activities Maintenance Shop/ Facility-Wide areas use minor quantities of welding/brazing materials. c. NP-3 Facility Cleaning- use of commercial janitorial supplies. 4. Delta 8" Joiner 5. Morbidelli CNC Drill 6. Biesse Rouer 20 CNC Drill 7. Thermo wood Router (2) 8. Gibon Prismatic 2 Panel Saw 9. Busellata Jet Drill (The above units (4-9) are controlled by two small internally vented dust collectors (Dantherm Filtration Dust collector, model NFP , sin and Disa Dust collector, model NFP2H, s/n ). 10. EFI Vutek Model digital printer which was exempted from plan approval on July 7, 2010 because it was determined a de-minimis increase in PM (0.001 TPY) and VOC (0.02 TPY). 11. Tiger M-Press digital printer which was exempted from plan approval on May 12, 2011 because the printing involves non-voc containing UV curable inks and flushing solution and it was a de-minimis increase in PM (0.002 TPY). 12. Solvent Free Smart Parts washer using Ozzy Juice which is not subject to Additional Notes: In addition to the above sources, the plan approvals also covered Sources 101, 102, 103, 104, 108, and 111 (presses that were not constructed based on the initial operating permit inspection). These sources were not added to the original operating permit. The facility proposed construction of a vulcanizing operation which would generate VOCs less than 2. 7 TPY. The Department exempted this source from plan approval on November 8, 2011 based on actual VOC emissions of2.63 TPY upon condition that the facility keeps records to clearly demonstrate to the Department that the applicable thresholds are not exceeded and that these changes be included in the operating permit at the time of the renewal. This source has not been installed, and therefore, it was not included in the permit during this renewal. The facility proposed construction of rubber molding finishing process, die board production, and die making operations. The approval of the proposed RFD was granted on November 8, 2011 by way of a de-minimis increase (rubber molding TPY PM-10), (die board production TPY PM-10), (die making operations 0.1 TPY PM-1 0, TPY SOx, TPY NOx, TPY VOC, and TPY CO). The two laser cutting units associated with this would be controlled by a 2000 dscfm dust

8 CloverleafGroup Inc IDL Worldwide NMOP " collector with a HEPA filter that would vent externally. This source has not been installed, and therefore, it was not included in the permit during this renewal. Compliance The facility was inspected on September 30,2008, July 20, 2009, August 25, 2010, May 12, 2011, March 6, 2012, and January 3, 2013 for purposes of a Full Compliance Evaluation. None ofthese inspections indicated any violations. Recommendation A renewal permit inspection was conducted at the facility by the writer on June 25, The permit was discussed with the facility and a tour of the facility was conducted. No additional sources were noted. The draft Operating Permit was submitted to the company on May 16, 2013 for their review. The Notice oflntent to Issue the Operating Permit was published in the Pa. Bulletin on June 1, The Notice indicated there was a 30-day comment period. There were no additional comments received during the comment period. Issuance of the Renewal Operating Permit is recommended with the appropriate conditions in the permit. cc: Larry Vogel District Supervisor New Castle Office -AQ