ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM March 27, 2002

Transcription

1 ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM SUBJECT: Review of Application Title V Operating Permit Resolite Polyglas 1575 Lebanon School Road West Mifflin, PA RE: Operating Permit File No TO: FROM: Sandra L. Etzel Chief Engineer Timothy J. Novack, P.E. Air Pollution Control Engineer SOURCE DESCRIPTION: The Resolite Polyglas, Inc. facility is located at, 1575 Lebanon School Road, West Mifflin Borough, Allegheny County and is a minor source of all criteria pollutants and a major source of hazardous air pollutants (HAPs) as defined in section of Article XXI. The facility operates eight pultrusion lines in which fiberglas strands and mats are impregnated with polyester resin by being slowly pulled through a resin bath and subsequently cured in heated dies to desired shapes, producing fiberglas reinforced plastic. Styrene is the resin carrier and is emitted from the resin baths to the atmosphere. A small saw and dust collector cut the cured fiberglas reinforced plastic shapes to desired lengths. PROCESS DESCRIPTION: P-001 Process Description: Fiberglas reinforced plastic manufacture Process Units: Pultrusion lines no. 1 to no. 8 Maximum potential combined production rate: 3,000,000 lbs. per year Raw Materials: Polyester resin, fiberglas and styrene monomer Products: Cured, resin impregnated fiberglas shapes of various sizes. Emission controls: None Resin Bath (Wet Out Box), Drip Pan and Pump Data: Lines no.1 & no.2 each have only a wet out box with a maximum surface area of 22.4 ft 2. Lines no.3 through no.8 each have a maximum wet out box surface area of ft 2 and a maximum drip pan surface Resolite Polyglas Technical Support Document 1

2 are of 31.5 ft 2 of which only 50% serves to catch dripping resin. The active area of each drip pan is ft 2. Line no.3 through no.7 have recirculation pumps and line no.8 has a non-recirculating pump. Resin flow into and through the baths and drip pans is typically from a few drops to a few gallons per minute. The recirculation pumps may be steady flow or pulse flow with no. 8 pump being used only to fill the no.8 bath when needed. Due to the nature of the non-steady flow of resin into the wet out boxes the flow will be limited to a maximum 10 gpm averaged over a sixty minute period. Process Description: Fiberglas roving (strands) and mats are stored in racks termed creels. The roving and mats are slowly pulled from the creels, through preforming guides for shape and into a resin bath. The fiberglas is impregnated with polyester resin, sized and slowly pulled into a heated die where the resin cures. Upon curing, the reinforced fiberglas shapes are mechanically pulled to the moving cutoff saw where they are cut to the desired lengths. The saw is equipped with a dust collection system for particulate emission control. Styrene is present in the polyester resin from approximately 20% to 50%, as purchased, as a carrier solution. Additional styrene is added in the mixing process which is carried out in 55 gallon drums of purchased resin. Emission from the process consist of evaporative emissions of styrene with the amount being determined by styrene throughput with 5.5% evaporative emissions from the complete process including mixing. Only acetone is used as a solvent for maintenance and clean-up. P-002 Process Description: Maximum Potential Production Rate: Emission control: Reinforced fiberglas cutoff saw 3,000,000 lbs. per year - all pultrusion products are processed through the cutoff saw. One dust collector Dust collector specifications: Amount: 1 Make: Torit Model No.: TJ1080 Type: Fabric filter Bag material: Polyester felt Total filter area:1,000 Ft 2 Cleaning method: compressed air Capture efficiency: 70% - engineer s estimate Control efficiency: 99% - manufacturer s specifications Instrumentation:Continuous differential pressure monitor Resolite Polyglas Technical Support Document 2

3 B-001 Make: Eclipse (3EM-E-HL) Model: 1503EMGHL Installation date: 1969 Max. rated heat input: MMBtu/hr Fuel: Natural gas Maximum fuel usage: x 10 6 scf/yr based on a fuel heating value of 1,020 btu/scf The boiler has no controls and exhausts through stack B001. EMISSION SOURCES OF MINOR SIGNIFICANCE: The department has designated the existing 275 gallon, above ground, fixed roof, diesel fuel storage tank, 8 natural gas space heaters with a combined maximum heat input rating of 0.82 MMBtu/hr, the preimpregnated epoxy coated fiberglas lamination process and the approximate 20 car paved parking lot as sources of minor significance. ALLOWABLE EMISSIONS SUMMARY: Pollutant Emission Sources lbs/hr tons/yr Volatile Organic Compounds Processes P Boiler B Volatile Organic Compounds Total Styrene Processes P Particulate Matter/PM-10 Process P Boiler B Particulate Matter/PM-10 Total Nitrogen Oxides Boiler B Carbon Monoxide Boiler B Sulfur Oxides Boiler B A year is defined as any consecutive 12-month period Resolite Polyglas Technical Support Document 3

4 EMISSION CALCULATIONS: P-001, Pultrusion lines no.1 through no.8 and mixing: Maximum potential production = 3,000,000 lbs/year Maximum allowable % styrene in resin bath = 70% by weight 1999 Data: 1. Actual production = 2,351,150 lbs 2. Resin use = 681,060 lbs 3. Styrene in resin = 238,573 lbs 4. Average % styrene in resin = 35% 5. Pure styrene used = 118,860 lbs 6. Total styrene throughput = 357,433 lbs 7. Total resin bath throughput = 799,920 lbs Maximum potential emissions: 1. (3,000,000 lbs/2,351,150 lbs) x (799,920 lbs x 0.7) = 714,473 lbs styrene/yr = tons styrene/yr (usage) 2. Maximum potential styrene evaporative loss during mixing and pultrusion is taken as 5.5% of total styrene throughput = 39,296 lbs/yr = tpy = 4.48 lbs/hr. The 5.5% evaporative loss is the average loss from pultrusion as stated in US EPA AP-42, Section 4.4, pulled on The March 3, 1999 update posted on the Clearinghouse for Inventory and Emissions Factors (CHIEF), US EPA OAQPS, states that the section was removed because the emission factors appeared to under predict styrene emissions from most polyester resin operations. The update referenced three sets of material that document and analyze much of the data that was used to remove the section. Upon reviewing the material it was found that no data was documented and analyzed for pultrusion processes, therefore, the original emission factor appears not to be in question. No other emission data was found on pultrusion elsewhere and the original emission factor has been used for estimation of styrene emissions from pultrusion lines no.1 through no.8. Processes P-002, movable cutoff saw: Typical finished product length = 108" long Cut width = 0.5" Amount of potential material removed = 3,000,000 lbs X (0.5/108)/2,000 = 7.0 tons/yr = maximum potential PM/PM-10 emissions. Resolite Polyglas Technical Support Document 4

5 Captured PM/PM-10 = 7.0 tons/yr x 0.7 = 4.9 tons/yr Fugitive PM/PM-10 = 7.0 tons/yr x 0.3 = 2.1 tons/yr = 0.48 lbs/hr Dust collector emissions = 4.9 tons/yr x 0.01 = 0.05 tons/yr = lbs/hr Total emissions = 2.15 tons/yr = 0.49 lbs/hr Boiler B-001: POLLUTANT LBS/MMBTU LBS/HR TPY BASIS PARTICULATE MATTER Article XXI PARTICULATE MATTER < 10 MICRONS Article XXI NITROGEN OXIDES NA AP-42, 5th ed. CARBON MONOXIDE NA AP-42, 5th ed. SULFUR DIOXIDE AP-42, 5th ed. VOLATILE ORGANIC COMPOUNDS NA AP-42, 5th ed. Pre-impregnated epoxy coated fiberglas lamination process: The lamination process uses high solids resin to laminate fiberglas. The fiberglas is put into a press and sealed except for the short side edges of the piece to be laminated. The piece is then pressed and heated in a sealed condition where almost all of the volatile contents become part of the finished product. The piece is then left to cool and removed. The only VOC emissions possible from this process are from the edges of the lamination piece during processing. Since these two edges are at most 2 to 3 feet long and less than 1/8" in thickness and the fact that the piece is pre-impregnated offsite with no resin addition on site, emissions from this process are negligible. OPERATING PERMIT APPLICATION COMPONENTS: 1. Revised Operating Permit Application No. 0015, dated March 20, 2001 Resolite Polyglas Technical Support Document 5

6 TESTING REQUIREMENTS: The facility will be tested once during the term of this permit in order to demonstrate compliance with emission limitations for pultrusion lines no. 1 through no.8. APPLICABLE REQUIREMENTS: New Source Performance Standards (NSPS): There are no applicable NSPS for this source. National Emission Standards for Hazardous Air Pollutants (NESHAPs): There are no applicable NESHAPS for this source. Article XXI, Requirements for Issuance: The requirements of Article XXI, Parts B and C for the issuance of major operating permits have been met for this facility. Article XXI, Part D, Part E & Part H will have the necessary sections addressed individually. 40 CFR PART 64, Compliance Assurance Monitoring : The requirements of 40 CFR Part 64, Compliance Assurance Monitoring, were found not to be applicable to this facility due to the pre-control potential particulate emissions of the movable cutoff saw being less than the major source threshold in Allegheny County of 100 tons/yr. STREAMLINING: Boiler no. 1, SO2 allowable emissions: The sulfur dioxide emissions standard of a.1 of Article XXI provides for allowable sulfur dioxide emissions of 1.0 lbs/mmbtu of actual heat input, for natural gas combustion Maximum potential emissions of sulfur dioxide in lbs/mmbtu for natural gas combustion for boiler no.1 is lbs/mmbtu Emissions above the maximum potential to emit are not possible if the boiler is operated and maintained properly according to proper combustion practices and using the fuel type specified c.4. of Article XXI requires the application of RACT on all existing sources. The above allowable emission limit from a.1. represents a generic, minimum standard for allowable emissions. Case-by-case Resolite Polyglas Technical Support Document 6

7 RACT for sulfur dioxide emissions from boilers no.1 has been determined to be maximum potential emissions under proper operation and maintenance of the boiler, along with record keeping and reporting requirements for fuel usage. REGULATED POLLUTANTS WITH NO ESTABLISHED REGULATORY EMISSION LIMITATION: Section a.2.B. of Article XXI requires that RACT be applied to pollutants regulated by Article XXI with established regulatory emission limitations. RACT for nitrogen oxides, carbon monoxide and volatile organic compound emissions from boiler no. 1 has been determined to be proper operation and maintenance of the boiler according to accepted combustion practices, therefore, the emission limitations for these pollutants will be the maximum potential emissions under proper operation of the boiler as shown in the above emission summary. METHOD OF COMPLIANCE DETERMINATION: Compliance with the emission limitations of pultrusion lines no.1 through no.8 and resin mixing may be demonstrated by compliance with the maximum styrene content of the resin baths, the maximum operating flowrates of the bath pumps and the maximum surface are of the resin baths and drip pans, along with testing, monitoring, record keeping and recording requirements that include resin and raw styrene usage, styrene bath content, production and operating hours. Compliance with the emission limitations for the movable cutoff saw may be demonstrated by periodic inspections of the collection and control system and production and maintenance records. Compliance with the boiler emission limitations may be demonstrated by compliance with the maximum fuel usage limitations and record keeping and recording requirements that include inspection, maintenance and repair data and monthly usage of natural gas. See the Operating Permit No for the compliance methods, record keeping and reporting requirements for the facility. RECOMMENDATIONS: The facility is in compliance with all applicable regulations of Article XXI and it is recommended that the Operating Permit No be issued. Resolite Polyglas Technical Support Document 7