PERMIT APPLICATION REVIEW SUMMARY New Hampshire Department of Environmental Services Air Resources Division P.O. Box 95, 29 Hazen Drive Concord, NH 03302-0095 Phone: 603-271-1370 Fax: 603-271-7053 AFS #: 3301300051 Application #: 08-0521 Date: 09/18/2009 Page 1 of 6 PROJECT DESCRIPTION Kalwall Corporation Flatsheet Division (Kalwall) located at 40 River Rd, in Bow, New Hampshire is requesting a significant modification to it s Title V Operating. First, Kalwall is proposing to add a by-pass stack from the Regenerative Thermal Oxidizer (RTO) to Table 2 Stack Criteria, plus addition of it to the Exhaust Stack Identification Column in Table 1 Significant Activities Identification in the Title V Operating. The by-pass stack is only used when there is a malfunction of the RTO. An ambient air dispersion modeling analysis is required for methyl methacrylate at 8.0 lb/hr through this stack and for 6.5 lb/hr of styrene. See the modeling analysis section of this for a summary of results. Second, Kalwall has proposed to change the reporting requirements contained in Table 8, Item 4. Currently, Table 8, Item 4 states that The permittee shall submit a summary report of the items listed in Table 5, Item 1 and Table 6, Items #21, 22, 29, 30, 31, and 32, and permit deviations every 6 months.. This contained an incorrect reference to Table 5, Item 1, which is the facility wide VOC emission limit of 48.5 tons per year, which does not belong in the semi-annual permit deviation and monitoring report. This Item also contained an incorrect reference to Table 6, which should have been Table 7. The New Hampshire Department of Environmental Services, Air Resources Division (DES) and Kalwall have concluded that the information required to be recorded by Table 7, Items 30 and 32, should be included in the semi-annual permit deviation and monitoring report required by Table 8, Item 4. The draft permit that went to public notice included revised wording, as follows: Semi-annual Deviation and Monitoring Report a) The permittee shall submit a semi-annual permit deviation and monitoring report, which contains summaries of the pertinent data that demonstrate the source s compliance status with all monitoring and testing requirements contained in this permit and shows that the required data is being recorded and maintained, including Table 7, Item 30 and Table 7, Item 32; and b) The semi-annual permit deviation and monitoring report shall also include a summary of all permit deviations and excursions that have occurred during the reporting period. On August 5, 2009, Kalwall submitted written comments during the public comment period concerning this revised Title V Operating. Further discussions were held with the DES Compliance Bureau staff and the ting & Environmental Health Bureau staff concerning this permit requirement, i.e., the Semi-annual Deviation and Monitoring Report. As a result of these discussions, the ting & Environmental Health Bureau has come up with revised wording for the Semi-annual Deviation and Monitoring Report contained in Table 8, Item 4, which now reads as follows: The tee shall submit a semi-annual permit deviation and monitoring report, which contains: a. Summaries of all monitoring and testing requirements contained in this permit; and b. A summary of all permit deviations that have occurred during the reporting period. DES believes that this language is more concise. References to Table 7, Items 30 and 32 have been removed from Table 8, Item 4 based on further analysis of reporting requirements contained in the draft permit by DES. The reporting requirements of Items 9. b), (startup, shutdown, and malfunction reporting that was inconsistent with the Startup, Shutdown, and Malfunction Plan (SSMP)), 12. a) (this includes reporting of periods of startup, shutdown, and malfunction for Subpart WWWW), and 16. a) (reporting of periods of time when monitored parameters are outside of their established ranges) of Table 8 are based on information recorded by Table 7, Items 30 and 32. Third, DES needs to add a monitoring requirement for the RTO, which is required by Subpart SS, Section 63.995(c). Kalwall has submitted a monitoring plan for the RTO, which is will demonstrate continuous compliance with the 95% destruction efficiency of the wet-out area emissions required by 40 CFR 63 Subpart WWWW. Kalwall has suggested adding the following language to Table 6 Monitoring/Testing Requirements, Item 13:
AFS #: 3301300051 Application #: 08-0521 Date: 09/18/2009 Page 2 of 6 Kalwall shall operate the RTO and associated equipment in accordance with the monitoring plan submitted to DES on September 10, 2008: 1) Kalwall shall maintain a normal operating range of 1,475 1,525 degrees F for the RTO combustion zone temperature for the RTO controller set at 1,500 degrees F. (DES suggests, The owner or operator shall maintain a normal operating range of 1,475 1,525 degrees F for the RTO combustion zone temperature with the RTO combustion zone temperature controller setpoint set at 1,500 degrees F.) 2) During startup of the process, the resin pumps shall not be activated until the combustion zone temperature is at least 1,500 degrees F. 3) The combustion zone temperature shall be monitored continuously and recorded at a minimum of 5 minute intervals; and 4) If the combustion zone temperature falls to 1,450 degrees F, or lower, for a period of 5 minutes or longer, the RTO will automatically shutdown, an audible alarm will sound, the resin pumps will be disabled, and Kalwall will follow the malfunction procedures in its Site Specific Monitoring Plan (SSMP). Fourth, with respect to the ambient air dispersion modeling analysis required for the RTO bypass stack, the DES analysis used in issuance of the Temporary for the RTO, used an assumed maximum input of 5.0 lb/hr styrene and needs to be increased to the maximum input rate of 6.5 lb/hr. DES already performed modeling with 8.0 lb/hr of methyl methacrylate, but did not model this amount of emissions going out of the RTO by-pass stack or the 6.5 lb/hr styrene going out of the RTO by-pass stack. Kalwall requested DES to perform the ambient air dispersion modeling for the RTO bypass stack.. Fifth, DES has added an additional requirement for the combustion zone temperature monitor in Table 6, Item 14 related to the installation and calibration requirements for the temperature monitor. Finally, DES has clarified in Table 8 Reporting Requirements, who should receive each of the reports, i.e., DES and/or EPA. CHANGES FROM PREVIOUS PERMIT Addition of the RTO By-pass stack, Stack #5, to Table 2 Stack Criteria in the Title V Operating, plus addition of it to the Exhaust Stack Identification Column in Table 1 Significant Activities Identification. Change the reporting requirements in Table 8 - Reporting Requirements, Item #4 to read as follows: The tee shall submit a semi-annual permit deviation and monitoring report, which contains: a. Summaries of all monitoring and testing requirements contained in this permit; and b. A summary of all permit deviations that have occurred during the reporting period. Addition of the RTO monitoring plan, outlined above in Item #13 in Table 6 Monitoring/Testing Requirements, which includes the following language: Kalwall shall operate the RTO and associated equipment in accordance with the monitoring plan submitted to DES on September 10, 2008: 1. Kalwall shall maintain a normal operating range of 1,475 1,525 degrees F for the RTO combustion zone temperature with the RTO combustion zone temperature controller set at 1,500 degrees F; 2. During startup of the process, the resin pumps shall not be activated until the combustion zone temperature is at least 1,500 degrees F. 3. The combustion zone temperature shall be monitored continuously and recorded at a minimum of 5 minute intervals; and 4. If the combustion zone temperature falls to 1,450 degrees F, or lower, for a period of 5 minutes or longer, the RTO will automatically shutdown, an audible alarm will sound, the resin pumps will be disabled, and Kalwall will follow the malfunction procedures in its Site Specific Monitoring Plan (SSMP). Addition of installation and calibration requirements for the temperature monitor into Table 6, Item 14, which
AFS #: 3301300051 Application #: 08-0521 Date: 09/18/2009 Page 3 of 6 includes the following language: The owner or operator shall install, calibrate, operate, and maintain a temperature monitor accurate to within plus/minus 10 degrees Fahrenheit to measure the combustion zone temperature in the RTO. The owner or operator shall verify the accuracy of the temperature monitor twice each calendar year with a reference temperature monitor (traceable to National Institute of Standards and Technology (NIST) standards or an independent temperature measuring device dedicated for this purpose). During accuracy checking, the probe of the reference device shall be at the same location as that of the temperature monitor being tested. DES has clarified who (DES and/or EPA) to send reports to in Table 8 Reporting Requirements. DES corrected a typographical error in Table 6, Item 14, by replacing the term catalytic oxidizer (Dec-E-Tech Unit) with combustion zone of the RTO. FACILITY DESCRIPTION/PERMIT HISTORY Kalwall Corporation Bow Flat Sheet Division (Kalwall) owns and operates a continuous lamination manufacturing process for making flat reinforced plastic (fiberglass) sheet or panels. It is a continuous process, but to a limited extent. It proceeds without interruption as long as raw materials are supplied to the feed end of the equipment. In practice, Kalwall injects resin supply to the applicator bath tank in 500 pound batches. Thus, the process is intermittent at Kalwall s facility. Rolls of fiberglass roving are chopped and mechanically distributed on a carrier surface to produce a uniform mat. The mat is then fed into a resin applicator bath at a measured rate. Resin is gravity fed to the applicator bath from a mezzanine mixing tank area. In the resin applicator bath, the fiberglass mat is impregnated with resin, then run through a squeeze roll to remove excess resin. The squeeze roll further compacts the resin into the fiber bundles or mat and also controls the sheet thickness. At this point a carrier film picks up the impregnated sheet and supports it from below. The production line continues with a second film applied from above to sandwich the resin-impregnated fiberglass between the two sheets. The automated production line then passes through a heating zone of 190 to 250 degrees Fahrenheit. This step accelerates the chemical reaction, and cures and hardens the finished material. The resulting fiberglass sheet is flexible enough to be coiled in rolls. Kalwall s practice, however, is to allow the sheet stock to cool and cure thoroughly before stripping away the carrier film. This practice reduces, if not eliminates, fugitive emissions of residual monomer from incompletely-cured product. Among the most common applications of the sheet product are construction panels, electrical insulating material, and glazing panels. The sheets may be opaque or translucent, flat or corrugated, depending on customer specifications. Additional uses include truck trailer paneling, refrigerator liners, sanitary paneling, solar collector covers, road signs, and other similar products. It has been demonstrated that the facility is a major source as defined in 40 CFR 63 Subpart A Section 63.2, i.e., it emits or has the potential to emit (considering controls in the aggregate), 10 tons per year or more of any individual Hazardous Air Pollutant (HAP) or 25 tons per year or more of any combination of HAPs. The Kalwall facility is subject to the National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production embodied in 40 CFR 63 Subpart WWWW, and its regenerative thermal oxidizer (RTO), an add-on piece of air pollution control equipment used to comply with Subpart WWWW, is also subject to applicable provisions in 40 CFR 63 Subpart SS National Emission Standards for Closed Vent Systems, Control Devices, Recovery Devices and Routing to a Fuel Gas System or Process. Temporary FP-T- 0133 was issued to Kalwall on January 20, 2006, for the installation, operation, and performance testing of the RTO unit for purposes of compliance with the requirements of 40 CFR 63 Subpart WWWW applicable to the facility.
AFS #: 3301300051 Application #: 08-0521 Date: 09/18/2009 Page 4 of 6 Table 1 ting History EU Device Number Issued Expires EU1 & PC1 EU1 & PC1 EU1 Continuous Fiberglass Reinforced Plastic (FRP) Lamination Line and Regenerative Thermal Oxidizer Continuous (FRP) Lamination Line and Regenerative Thermal Oxidizer Continuous (FRP) Lamination Line Title V Operating TV-OP-027 Temporary FP-T-0133 Title V Operating TV-OP-027 LIST OF INSIGNIFICANT ACTIVITIES Kalwall has listed the following as insignificant activities: Resin mixing in chemical storage room Customer sample preparation Paint storage ventilation and material Muffler furnace for lab-scale fire tests (2) gas-fired heating furnaces (< 1.5 mmbtu/hr each unit) (4) gas-fired space heating air units (2) solvent reclamation units Production welding Status 02/10/2006 02/28/2011 Renewal of Title V Operating with addition of the RTO 01/20/2006 07/31/2007 Temporary issued for installation of the RTO 07/21/2000 07/31/2005 Initial Title V Operating Storage tanks of such a size and vapor pressure as not to emit VOC or HAPs Steam vents, cleaning (18) gas-fired process burners for the production line (500,000 Btu/hr or less each) Kalwall has cross-referenced its previous Title V application submitted June 28, 1996 for a detailed listing of its insignificant activities and trivial activities. POLLUTION CONTROL EQUIPMENT Kalwall has the RTO for the destruction of HAPs, namely styrene and methyl methacrylate emissions from its production of fiberglass reinforced plastic sheets on a continuous lamination line. Performance testing conducted on June 19 and 20, 2007 determined that the optimum temperature for meeting the 95% destruction of wet-out area emissions was a combustion zone temperature of 1,500 +/- 25 degrees F. Combustion zone temperature is continuously monitored in accordance with the site specific monitoring plan that is included in Table 6, Item 13. EMISSION CALCULATIONS VOC and HAP Emissions Summary
AFS #: 3301300051 Application #: 08-0521 Date: 09/18/2009 Page 5 of 6 Resins used in the flat sheet production line contain the volatile organic compounds (VOC) styrene (CAS # 100-42-5) and/or methyl methacrylate (MMA) (CAS # 80-62-6), both of which are listed as federal Hazardous Air Pollutants (HAPs) and state Regulated Toxic Air Pollutants (RTAPs) contained in Chapter Env-A 1400. Resins used at the Kalwall facility are of a proprietary nature. Annual emissions for calendar year 2003 are as follows: 2003 Total resin usage = 3,812,644 pounds 2003 Styrene emissions = 25,077 pounds or 12.54 tons 2003 MMA emissions = 29,689 pounds or 14.84 tons 2003 Total actual VOC or HAP emissions = 54,766 pounds or 27.38 tons Potential Uncontrolled Styrene Emissions = 49.0 tons per year Potential Styrene Emissions With the RTO = 5.79 tons per year (49 - (49.0 X 0.9 X 0.98)) (This is assuming a 90% capture efficiency and 98% destruction efficiency.) Potential Uncontrolled MMA Emissions = 65.0 tons per year Potential MMA Emissions With the RTO = 7.67 tons per year (65 (65 X 0.9 X 0.98)) (This is assuming a 90% capture efficiency and 98% destruction efficiency.) Table 2 - Emission Summary (tpy) Device/Process PM 10 SO 2 NO x CO VOCs HAPs Potential EU1 Continuous FRP Lamination Line Facility 48.5 (Cappped) MODELING 13.46 with RTO Please refer to the attached modeling memo dated May 14, 2009, for a detailed analysis of the modeling performed for all of the regulated toxic air pollutants being exhausted through the RTO bypass stack. The facility was found to be in compliance with the 24-hr and annual ambient air limits for both styrene and methyl methacrylate emissions being exhausted through the RTO bypass stack. EMISSION TESTING Initial performance test was conducted on June 19 and 20, 2007. The RTO was found to have a capture efficiency of 95.2% and a destruction efficiency of >99.0% at 1,500 degrees +/- 25 degrees F. COMPLIANCE STATUS Emission Testing Completed and discussed above. Inspections 04/30/2008 Full Compliance Evaluation by USEPA Region 1 No compliance issues found. 04/12/2006 Full Compliance Evaluation Record Review by DES No violations Reports 2008 Annual Compliance Certification received on April 7, 2009 2008 VOC Emissions Statement received on April 7, 2009 2008 Annual Emissions Statement and Payment of Emissions-based Fees received on April 7, 2009 RTO Monitoring Plan received on September 15, 2008 July through December 2008 Semiannual Deviation & Monitoring Report received on January 30, 2009.
AFS #: 3301300051 Application #: 08-0521 Date: 09/18/2009 Page 6 of 6 Fees 2008 Emissions-based fees paid on April 7, 2009 REVIEW OF REGULATIONS State Regulations Env-A 612.06 Significant Modifications: Title V Operating s Applicable - Because of a relaxation in reporting requirements in Table 8, Item 4 and addition of a new monitoring requirement, i.e., Table 6, Item 13. Env-A 1400, Regulated Toxic Air Pollutants Applicable to EU1 and PC1, please refer to the modeling section of this application review summary. Federal Regulations 40 CFR 63 Subpart WWWW National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production Applicable to EU1 & PC1 Deletion of some Subpart WWWW recordkeeping requirements that were mistakenly included in the semi-annual permit deviation and monitoring report. Addition of the monitoring requirement for the continuous monitoring of the RTO combustion zone temperature, and what the minimum combustion zone temperature is, in order to demonstrate compliance with the 95% destruction efficiency of the wet-out area emissions. 40 CFR 63 Subpart SS - National Emission Standards for Closed Vent Systems, Control Devices, Recovery Devices and Routing to a Fuel Gas System or Process Applicable to EU1 & PC1 - No changes in this significant permit modification. 40 CFR 64, Compliance Assurance Monitoring Not Applicable, facility is covered by stricter standards contained in 40 CFR 63 Subparts WWWW and SS. SUMMARY AND CONCLUSIONS Based on review of the permit application and compliance with the state air toxics program demonstrated by the ambient air dispersion modeling analysis, DES is issuing a draft permit for public review and comment.