Facility Name: Asama Coldwater Manufacturing Georgia City: Warrenton County: Warren AIRS #: Application #: 23751

Transcription

1 Facility Name: Asama Coldwater Manufacturing Georgia City: Warrenton County: Warren AIRS #: Application #: Date SIP Application Received: April 14, 2016 Date Title V Application Received: N/A Permit No: V-05-1 Program Review Engineers Review Managers SSPP Ginger Payment Manny Patel SSCP Fred Francis Farhana Yasmin ISMU Ross Winne Dan McCain TOXICS N/A N/A Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the referenced SIP permit to construct and operate and Section 502(b)(10) change to the Part 70 source. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Sections (1), (2), and (10) of the Georgia Rules for Air Quality Control, (2) Part 70 of Chapter I of Title 40 of the Code of Federal Regulations, and (3) Title V of the Clean Air Act Amendments of The following narrative is designed to accompany the permit and is presented in the same general order as the permit amendment. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Asama Coldwater Manufacturing Georgia, TV Page 1 of 16

2 I. Facility Description A. Existing Permits Table 1: Current Title V Permit and Amendments Comments Permit/Amendment Number Date of Issuance Yes No Permit No V-05-0 March 5, 2013 X Table 2: Comments on Specific Permits Permit Number Permit No V-05-0 Comments Title V renewal and name change B. Regulatory Status 1. PSD/NSR/RACT The facility is subject to PSD since it is classified as a secondary metal production facility which is one of the 28 named source categories in the PSD regulations. The foundry is a major source because it has the potential to emit more than 100 tons per year of at least one regulated PSD pollutant. 2. Title V Major Source Status by Pollutant Table 3: Title V Major Source Status Pollutant Is the Pollutant Emitted? If emitted, what is the facility s Title V status for the Pollutant? Major Source Status Major Source Requesting SM Status Non-Major Source Status PM Yes PM 10 Yes PM 2.5 Yes SO 2 Yes VOC Yes NO x Yes CO Yes TRS No H 2 S No Individual Yes Total HAPs Yes Total GHGs Yes Asama Coldwater Manufacturing Georgia, TV Page 2 of 16

3 II. Proposed Modification A. Description of Modification This application is for the construction and operation of two replacement Foundry Core Machines and for the construction and operation of a machining line (ML1) with dust collector. The two replacement Foundry Core Machines (Laempe LFB 50) will be named Foundry Core Machines #5 and #6 (ID Nos. 644 and 645) and will replace previous Foundry Core Machines #2 and #3 (ID Nos. 641 and 642) which have been taken out of service. Since these are similar replacements, these new Foundry Core Machines will not exceed any thresholds for PSD review. The new machining line (ML1) will consist of four turning machines and will have a maximum production rate of 820,000 front disc brake pieces per year. Emissions from the machining line will be exhausted to a new dust collector (DC1). B. Emissions Change There are no changes in emissions due to the replacement of the core machines because the replacements will be similar machines. The new machines will continue to be subject to the existing VOC emission limit of 5.8 lb/hr which is Condition 3.3.1b. of Permit No V The new machining line will have potential emissions of 5.9 tpy for PM emissions. The emissions were calculated from the air flow rate of the dust collector for the machining line and the standard emission rate of 0.02 gr/dscf from the dust collector. These emissions do not exceed the thresholds for PSD significant emission rates; therefore, this modification does not require PSD review. The new machining line will vent to its own stack and not through a stack with an established emission limit. Table 4: Emissions Change Due to Modification Pollutant Is the Pollutant Emitted? Net Actual Emissions Increase (Decrease) (tpy) Net Potential Emissions Increase (Decrease) (tpy) PM Yes PM 10 Yes PM 2.5 Yes SO 2 Yes VOC Yes NO x Yes CO Yes TRS No H 2 S No Individual Yes Total HAPs Yes Total GHGs Yes Asama Coldwater Manufacturing Georgia, TV Page 3 of 16

4 C. Title I Modification PSD/NSR Applicability This modification is not subject to PSD/NSR. NSPS Modification This modification is not subject to NSPS requirements. NESHAP Modification This modification is not subject to NESHAP requirements. Asama Coldwater Manufacturing Georgia, TV Page 4 of 16

5 III. Facility Wide Requirements A. Emission and Operating Caps There are no changes to facility-wide emission and operating caps due to this amendment. B. Applicable Rules and Regulations There are no changes to the facility-wide rules and regulations due to this amendment. C. Compliance Status There are no facility-wide compliance issues noted with this application. D. Operational Flexibility The facility did not request facility-wide operational flexibility with this application. E. Permit Conditions No changes to the facility-wide permit conditions were required for this amendment. Asama Coldwater Manufacturing Georgia, TV Page 5 of 16

6 IV. Regulated Equipment Requirements A. Brief Process Description Raw material handling operations include the receiving, unloading, storing, and conveying of raw materials required for furnace charging, core production, and mold preparation. Raw materials are placed into the coreless induction furnaces. The coils heat and mix the metal. Cores are molded sand shapes used to make the internal voids of a casting. Cores are made by mixing sand with organic binders and then molding it into the desired shape. Cores are then dipped into a water-based refractory coating and placed into one of four drying ovens. Finished cores are transferred to the molding machines. Molten metal is poured from the pressure pouring furnace into the molds. The metal is allowed to cool and then separated from the mold. Castings are mechanically separated from gates and risers. Grinders remove remaining riser or gate material from the casting. Finished castings are then sent to shipping. This application is for the replacement of the two Foundry Core Machines and for a new machining line. The new machining line (ML1) will consist of four turning machines and will have a maximum production rate of 820,000 front disc brake pieces per year. Emissions from the machining line will be exhausted to a new dust collector (DC1). B. Equipment List for the New or Modified Process(es) Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions 020 Core Sand Bulk 021 Core Sand Bulk 040 New Sand Bulk 041 New Sand Bulk 045 New Sand Day 051 Miscellaneous Bulk Materials 40 CFR CFR SAN 40 CFR , 6.2.1, 6.2.2, 6.2.8, 6.2.9, , 5.2.1, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , 865 Bin Vent Filter Bin Vent Filter , 3.4.2, Bin Vent Filter 951 Asama Coldwater Manufacturing Georgia, TV Page 6 of 16

7 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions 052 Miscellaneous 3.4.1, 3.4.2, Bin Vent Filter 952 Bulk Materials 053 Premix Storage 3.4.1, 3.4.2, Bin Vent Filter 953 Silo 060 Miscellaneous Bulk Materials 061 Miscellaneous Bulk Materials 062 Premix Storage Silo 063 Miscellaneous Bulk Materials 064 Miscellaneous Bulk Materials 070 Railcar Unloading Dump Pit 071 Railcar Unloading Dump Pit 072 Pneumatic Conveying Equipment 090 Scrap Metal Vibrating Feeder CSA 100 Alloy Blend Station CSA 110 Vibrating Pan MPCS 40 CFR Coreless Induction Furnace MPCS 40 CFR CFR 63 Subpart EEEEE 120 Vibrating Pan MPCS 40 CFR Coreless Induction Furnace MPCS 40 CFR CFR 63 Subpart EEEEE 130 Vibrating Pan MPCS 40 CFR , 3.4.2, Bin Vent Filter , 3.4.2, Bin Vent Filter , 3.4.2, Bin Vent Filter , 3.4.2, Bin Vent Filter , 3.4.2, Bin Vent Filter , 3.4.2, Bag Filter , 3.4.2, Bag Filter , 3.4.2, Bag Filter , N/A N/A N/A 3.4.1, N/A N/A N/A 2.2.1, 3.2.1, 3.3.2, 5.2.5, 6.2.4, 6.2.5, 2.2.1, 3.2.1, 3.3.2, 5.2.5, 6.2.4, 6.2.5, 810 Melt System 810 Melt System 810 Melt System 810 Melt System 810 Melt System Asama Coldwater Manufacturing Georgia, TV Page 7 of 16

8 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions 131 Coreless Induction Furnace MPCS 40 CFR CFR 63 Subpart EEEEE 2.2.1, 3.2.1, 3.3.2, 5.2.5, 6.2.4, 6.2.5, 810 Melt System Vibrating Pan MPCS 40 CFR Coreless Induction Furnace MPCS 40 CFR CFR 63 Subpart EEEEE 200 Autopouring MPCS 40 CFR CFR 63 Subpart EEEEE 2.2.1, 3.2.1, 3.3.2, 5.2.5, 6.2.4, 6.2.5, 2.2.1, 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.4, 5.2.5, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , , 810 Melt System 810 Melt System 201 Pouring Ladles MPCS N/A N/A N/A 210 Disa Molding Machine MPCS 40 CFR Pouring MPCS 40 CFR CFR 63 Subpart EEEEE 230 In-Mold Cooling MPCS 40 CFR Sand Shakeout MPCS 40 CFR Casting Cooling FIN 40 CFR Desprue FIN 40 CFR , 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.4, 5.2.5, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , , Finish 930 Asama Coldwater Manufacturing Georgia, TV Page 8 of 16

9 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions 270 Shot Blast FIN 40 CFR Finish Grinding Unit FIN 40 CFR Grinding Unit FIN 40 CFR Grinding Unit FIN 40 CFR Autopouring MPCS 40 CFR CFR 63 Subpart EEEEE 310 Disa Molding Machine MPCS 40 CFR Pouring MPCS 40 CFR CFR 63 Subpart EEEEE 330 In-Mold Cooling MPCS 40 CFR Sand Shakeout MPCS 40 CFR Casting Cooling FIN 40 CFR , 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.4, 5.2.5, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , , 2.2.1, 3.3.1, 3.3.2, 3.3.3, 3.4.1, 3.4.2, 5.2.4, 5.2.5, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , , 830 Finish Finish Finish Sand 820 Sand Asama Coldwater Manufacturing Georgia, TV Page 9 of 16

10 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions 360 Desprue FIN 40 CFR Finish Shot Blast FIN 40 CFR Grinding Unit FIN 40 CFR Grinding Unit FIN 40 CFR Grinding Unit FIN 40 CFR Paint Application 388 Rust Inhibitor Application 389 Rust Inhibitor Application 600 Day Storage Bin #1 601 Day Storage Bin #2 602 Day Storage Bin #3 603 Day Storage Bin #4 610 Fluidized Sand Classifier # , 6.2.8, 6.2.9, 855 Cartridge Collector Finish Finish Finish 930 RUST 3.4.1, N/A N/A N/A RUST N/A N/A N/A RUST N/A N/A N/A Asama Coldwater Manufacturing Georgia, TV Page 10 of 16

11 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions 611 Fluidized Sand Classifier #2 612 Fluidized Sand Classifier #3 613 Fluidized Sand Classifier #4 620 Weigh Hopper #1 621 Weigh Hopper #2 622 Weigh Hopper #3 623 Weigh Hopper #4 630 Batch Mixer #1 COR 40 CFR Batch Mixer #2 COR 40 CFR Batch Mixer #3 COR 40 CFR Asama Coldwater Manufacturing Georgia, TV Page 11 of 16

12 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions 633 Batch Mixer #4 COR 40 CFR Core Machine #1 643 Core Machine #4 644 Core Machine #5 645 Core Machine #6 COR 40 CFR COR 40 CFR COR 40 CFR COR 40 CFR Core Dryer #1 COR 40 CFR (2)(g) 681 Core Dryer #2 COR 40 CFR (2)(g) 682 Core Dryer #3 COR 40 CFR (2)(g) 683 Core Dryer #4 COR 40 CFR (2)(g) 700 Weigh Hoppers SAN 40 CFR Sand Cooler SAN 40 CFR Blender/Convey ing 715 Returned System Sand Storage Bin SAN 40 CFR SAN 40 CFR , 3.3.4, 3.4.1, 3.4.2, 5.2.2, 6.2.1, 6.2.2, 6.2.7, 6.2.8, 6.2.9, 3.3.1, 3.3.4, 3.4.1, 3.4.2, 5.2.2, 6.2.1, 6.2.2, 6.2.7, 6.2.8, 6.2.9, 3.3.1, 3.3.4, 3.4.1, 3.4.2, 5.2.2, 6.2.1, 6.2.2, 6.2.7, 6.2.8, 6.2.9, 3.3.1, 3.3.4, 3.4.1, 3.4.2, 5.2.2, 6.2.1, 6.2.2, 6.2.7, 6.2.8, 6.2.9, 3.3.1, 3.4.1, 3.4.2, 3.4.3, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , 3.3.1, 3.4.1, 3.4.2, 3.4.3, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , 3.3.1, 3.4.1, 3.4.2, 3.4.3, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , 3.3.1, 3.4.1, 3.4.2, 3.4.3, 6.2.1, 6.2.2, 6.2.8, 6.2.9, , 821/824 Scrubber/Core Machine Cyclone 821/824 Scrubber/Core Machine Cyclone 821/824 Scrubber/Core Machine Cyclone 821/824 Scrubber/Core Machine Cyclone Asama Coldwater Manufacturing Georgia, TV Page 12 of N/A N/A 980/98 5 N/A N/A 981/98 6 N/A N/A 982/98 7 N/A N/A 983/98 8

13 Emission Units Specific Limitations/Requirements Air Pollution Control Devices Description Process Applicable Corresponding Stack Description Group Requirements/Standards Permit Conditions SAN 40 CFR Returned System Sand Storage Bin 730 Sand Mixer SAN 40 CFR Sand Mixer SAN 40 CFR ML1 Machining Line MAC 3.2.2, 3.4.1, 3.4.2, 4.2.3, 5.2.6, 5.2.7, 6.2.1, 6.2.2, 6.2.9, DC1 Dust Collector DC1 * Generally applicable requirements contained in this permit may also apply to emission units listed above. The lists of applicable requirements/standards and corresponding permit conditions are intended as a compliance tool and may not be definitive. C. Equipment & Rule Applicability Emission and Operating Caps The emissions from the Dust Collector are based on an emission limit of 0.02 gr/dscf. Because this emission limit was used to determine that the proposed machining line is not subject to PSD review, it will be included in the permit. Applicable Rules and Regulations - Rules and Regulations Assessment: There are no additional rules or regulations required for this application. The two replacement Foundry Core Machines will be subject to the existing stack emission limit for Stack 921 as established through a previous BACT determination. These will also continue to be subject to Georgia Rule (b) and Georgia Rule (e). No changes were required for applicability to these rules. The new machining line (ML1) will be subject to Georgia Rule (b) and Georgia Rule (e). Because these rules are already included in the permit, the rules did not need to be added again. The machining line will not be subject to a PSD review because the emissions did not exceed the PSD significance threshold. The emissions from the machining line will not exhaust out of any of the regulated stacks. Emission and Operating Standards: There are no additional emission or operating standards for the two replacement Foundry Core Machines as these will be subject to the same existing conditions as the previous core machines. Asama Coldwater Manufacturing Georgia, TV Page 13 of 16

14 D. Compliance Status There are no equipment-related compliance issues noted with this application. E. Operational Flexibility The facility did not request equipment-related operational flexibility with this application. F. Permit Conditions Condition is a new condition which limits the particulate matter emissions from Dust Collector DC1 to 0.02 gr/dscf. Asama Coldwater Manufacturing Georgia, TV Page 14 of 16

15 V. Testing Requirements (with Associated Record Keeping and Reporting) A. Individual Equipment: Condition is a new condition which requires an initial performance test on Dust Collector DC1 for compliance with the PM emission limit and also requires subsequent performance tests. B. Equipment Groups (all subject to the same monitoring requirements): There are no additional testing requirements for equipment groups required for this application. VI. Monitoring Requirements (with Associated Record Keeping and Reporting) A. Individual Equipment: Condition is a new condition which requires a daily visible emission checks for Dust Collector DC1. Condition is a new condition which requires the facility to monitor the pressure drop across the dust collector. B. Equipment Groups (all subject to the same monitoring requirements): There are no additional monitoring requirements for equipment groups required for this application. VII. Other Record Keeping and Reporting Requirements Condition 6.1.7c.iii. is a new condition which requires an excursion of the pressure drop for Dust Collector DC1 to be reported. Asama Coldwater Manufacturing Georgia, TV Page 15 of 16

16 VIII. Specific Requirements A. Operational Flexibility The facility did not request operational flexibility with this application. B. Alternative Requirements There are no alternative requirements associated with this application. C. Insignificant Activities There are no additional insignificant activities added as part of this application. D. Temporary Sources The facility did not request temporary sources with this application. E. Short-Term Activities There are no short-term activities associated with this application. F. Compliance Schedule/Progress Reports There are no compliance issues noted with this application. G. Emissions Trading Not applicable. H. Acid Rain Requirements None applicable. I. Prevention of Accidental Releases Not applicable. J. Stratospheric Ozone Protection Requirements None applicable. K. Pollution Prevention None applicable. L. Specific Conditions None applicable. Asama Coldwater Manufacturing Georgia, TV Page 16 of 16