Introduction. Motor Vehicle Assembly Plant (001) (Plant No. 1) Motor Vehicle Assembly Plant (010) (Plant No. 2)

Transcription

1 Introduction Statement of Basis Honda Manufacturing of Alabama, LLC Lincoln, AL (Motor Vehicle Manufacturing) Major Source of VOCs & Hazardous Air Pollutant Emissions On September 1, 2017, Honda Manufacturing of Alabama, LLC, (Honda), submitted a Title V major source permit renewal application for the manufacture of Motor Vehicles (SIC # 3711). Honda is located in Lincoln, Alabama. This Title V permit issuance will be a renewal issuance with the following changes. With this permit, the newly permitted generators will be included to the permit (021) and (022). Motor Vehicle Assembly Plant (001) (Plant No. 1) Motor Vehicle Assembly Plant (010) (Plant No. 2) Plastic Injection (X001) (X010) Honda has a bumper plastic injection machine to manufacture vehicle bumpers. This configuration is duplicated in Plant No. 2. Mix Room (X001) (X010) The outside mix room is used for solvent paints. There is an interior mix room for mixing waterborne paints. Each of these rooms contains paint pots for mixing the paint. A warehouse next to the outside mix room is for the storage of bulk containers of paint. This configuration is duplicated in Plant No. 2. Body Painting (X001) (X010) The vehicle goes through the pretreatment line and then an E-coat process. The pretreatment line includes two areas with cleaners, two areas of industrial sprays and a surface conditioner. Then the car runs through a phosphate tank, two DI (deionized) water sprays, a DI dip, and a fogger. This process helps protect the body. The E-Coat process includes a permeate spray, where the clear liquid is separated from the paint, a permeate dip tank, a DI spray and dip, a final spray and then the vehicle goes through an oven where it dries for 55 minutes. This process helps ensure that the paint will adhere to the surface of the vehicle. The vehicle then goes through the e-coat sanding booth. Following this is the Sealing Line, Sealer Oven, and an area where employees wipe down the vehicle with tack cloths. The vehicle proceeds through a hand painting area and a robotic painting area where Primer/Surfacer is applied before it goes through the Primer/Surfacer

2 Oven, and another sanding booth. After the sanding booth the vehicle moves through another set of hand painting and robotic painting where the basecoat is applied. Finally the vehicle goes through a UVI oven and is coated with a clearcoat finish and Topcoat Oven to give the automobile a shiny appearance. Inspection Booths follow. There is also an on-line repair sanding area and wax/black out coating booth located here. There are also two separate Repair Booths and an oven (major and minor) located here and there is a minor repair booth in the assembly shop. There is a scrubber system that collects particulates from the main paint. In the penthouse, there are air handlers for the inlet and exhaust air. The Regenerative Thermal Oxidizer (RTO) on the roof is a 2-chamber natural gas fired unit for Plant No. 1. The following units are captured and directed to the Oven Exhaust RTO (1045) - E-Coat Oven, Sealer/Deadener Oven, Primer/Surfacer Oven, Clearcoat Booth Automatic Zone, and Topcoat/Clearcoat Oven. For Plant No. 2, the following units are captured and directed to the Oven Exhaust RTO (7045) - E-Coat Oven and Sealer/Deadener Oven, Primer/Surfacer Oven, and Topcoat/Clearcoat Oven. The following unit is being directed to the No. 2 Fluidized Bed Carbon Adsorption System with RTO2 (7056): Clear-coat Booth Automatic Zone. Various Operations Honda runs a windshield installation process and a VQD final inspection area. The VQD area is where Honda tests the completed vehicle through tests involving the brakes, transmission, and alignment of the vehicle. The fuel dispensing area (4006) is where the vehicles are filled with gasoline before leaving the assembly line. Sludge pit operations are also located here for wastewater from the painting operations. These configurations are duplicated in Plant No. 2. Honda also has ten (2200, 1650, 100, 310, 170, 270, 270, 1109, 1505, and 49 HP) Emergency Generators. They operate using low sulfur (transportation grade) diesel fuel. There is a 500-gallon day tank. These will be used for power outages and periodic testing only. All were installed in 2001 and are subject to the NESHAP for Stationary RICE (ZZZZ). Honda has added more generators in 2017, which include: two 526 HP diesel fired emergency fire pumps (ICE 013) and (ICE 014), one 374 HP natural gas fired emergency generator (ICE 015), and two 601 HP diesel

3 fired emergency generators (ICE 016) and (ICE 017). All are subject to the NESHAP for Stationary RICE (ZZZZ). Applicable Regulations (Coating Lines) Both Plant No. 1 and Plant No. 2 are subject to NSPS (MM), MACT NESHAPS (IIII), 112(G), and various BACT determinations. These are described in detail in the attached provisos. Testing of Emissions (Coating Lines) Initially, every three years, or after a significant model change, using the EPA document "Protocol for Determining Daily VOC Emission Rate of Automobile and Light Duty Truck Topcoat Operations", June 10, 1988, and revisions thereafter, Honda will determine destruction efficiency for the Plant No. 1 RTO (1045), Plant No. 2; RTO1 (7045) and No. 2 Fluidized Bed Carbon Adsorption System with RTO2 (7056), determine transfer efficiencies, booth splits, control efficiencies, and other items, and use Method 24 or 311 as appropriate for the coatings used in coating operations. Monitoring of Emissions (Coating Lines) These lines are subject to the NSPS as defined in 40 CFR 60, Subpart MM. These lines are also subject to case by case PSD-BACT decisions. These decisions involve VOC, PM, NOx, and CO. These lines are also subject to case by case 112 (g) decisions for HAPs. Honda keeps records as required by the NSPS for their automotive line. This source maintains the allowed Pound VOC/Pound of coating solids as applied calculations for the different operations through coating formulations and the use of the thermal oxidizers. The monitoring required is as outlined in the NSPS (MM). These are submitted quarterly to the department. For Honda s various PSD-BACT limits that involve VOCs, Honda maintains records of monthly coating usage, coating analysis, and control device destruction efficiency to show compliance with their permit limits. These are submitted quarterly to the department. Honda has limits on the overall usage of VOCs, usage of clean up/purge/flushing solvents, usage of Hazardous Air Pollutants (HAPs) for Miscellaneous Assembly Materials, and usage of HAPs for clean up/purge/flushing solvents. The E-Coat Oven, Sealer/Deadener Oven, Primer/Surfacer Oven, Clearcoat Booth Automatic Zone, and Topcoat/Clearcoat Oven are all vented to RTOs that are required to achieve a 95% destruction efficiency. There are thermocouples on the RTOs to monitor and record

4 temperature measurement. These records are maintained in a computer database for review. Honda reports exceedances within the General Proviso break-down requirements. Written reports are submitted with their quarterly report. The pressure differential between the supply air to the booth and the exhaust air from the booth shall be measured using a pressure differential gauge and shall be recorded daily. The water flow in the scrubbers/ water curtains shall be measured and recorded weekly. Records shall be recorded of these measurements. These measurements indicate proper manufacture s recommendations for the operation of the booths particulate control equipment and indicates compliance with the PM requirements. For Honda s various 112(g)-MACT limits that involve HAPs, Honda maintains records of monthly coating usage, coating analysis, and control device destruction efficiency to show compliance with their permit limits. These are submitted quarterly to the department. Honda has limits on the overall usage of HAPs, usage of clean up/purge/flushing and 112(g) limits on their automotive assembly line. Additionally, Honda s Plant No (g) limits mirror NESHAP regulations for Auto Manufacturing (IIII) with some additional requirements. In the proposed Title V permit, Honda will be required to meet the NESHAP regulations for Auto Manufacturing (IIII) with some additional requirements for HAPs usage that is not covered in the NESHAP regulation for both Plant No. 1 and Plant No. 2. Honda utilizes only natural gas as a fuel for the ovens and has installed low NOx burners. The use of natural gas will minimize emissions of PM and SO2. Due to the inherently low particulate and SO2 emissions using this fuel, no periodic monitoring will be required. The use of low NOx burners will minimize the emissions of NOx. Therefore, no emission monitoring will be required for this pollutant. Low NOx burners and natural gas only as a fuel are utilized throughout Honda on all sources where it is feasible to reduce NOx emissions. CO emissions are typically elevated inversely to NOx emissions, meaning efforts to reduce NOx emissions will generally increase CO emissions. For the small size of units at Honda, CO controls would be infeasible, and possibly counterproductive to the control of NOx. The stacks associated with these sources shall not exhibit greater than 10% opacity. If opacity of 5% or greater is observed from a stack, the operator shall investigate the cause and make any necessary corrective actions. This BACT limit is more stringent than the state allowable opacity. Due to the use of natural gas on all the burners and PM filters

5 and controls on stacks, it is unlikely that visible opacity would be emitted. A Stage II vapor control system or On Board Vapor Recovery system shall be installed and used during filling of the gas tank for each vehicle. Honda shall utilize good work practices that are practically and economically feasible that reasonably minimize clean-up/purge/general solvent usage in all operations. Coatings, solvents, and other VOC containing material will be handled in such a way as to minimize VOC emissions from storage, handling, coating, and cleanup. Closed containers shall be used for the storage and disposal of cloth or other material used for VOC containing material cleanup or usage. Coatings and other fresh or spent VOC coating material will be stored in closed containers. Engine Testing (015) Engine Test Firing Stands Engine Test Dynamometers (X001) (X010) (X015) There are four Engine Test Firing Stands (015) and two Engine Test Dynamometers for QA/QC purposes are located here (015). The four Engine Test Firing Stands are uncontrolled. The two Engine Test Dynamometers units are controlled by an incinerator afterburner. These lines are also subject to case by case PSD-BACT decisions. These decisions involve VOC, PM, NOx, and CO. The engine test stands and dynamometers are also subject to case by case 112 (g) decisions for HAPs with CO used as a surrogate indicator of compliance. A NESHAP regulation (PPPPP) requires no additional measures for existing sources. Monitoring of Emissions (Engine Testing) The Engine Test Dynamometer No. 1 and Engine Test Dynamometer No. 2 are vented to an incinerator afterburner that is required to achieve 99.9% destruction efficiency. There are thermocouples on the incinerator afterburner to monitor and record temperature measurement. These paper records are maintained for review. Honda reports exceedances within the General Proviso break-down requirements. Written reports are submitted with their quarterly report. The use of natural gas and low NOx burners on the incinerator afterburner should ensure compliance with Honda s PM and NOx limits for these units. Plastic Parts Coating Line (002) (Plant No. 1) Plastic Parts Coating Line (011) (Plant No. 2)

6 Bumper Painting (X002) (X011) These areas of Honda manufacture and prepare bumpers. This line (002) begins with Bumper Pretreatment, where the bumpers are degreased, rinsed twice, and conditioned. The bumpers then proceed through a Water Based Robotic Primer Booth (followed by a manual backup), flashoff, Robotic Basecoat Booth (followed by a manual backup), flash-off, Robotic Clearcoat Booth (followed by a manual backup), flash-off, and an electric curing Oven. There is also a bumper repair booth located here to fix any defects that might occur in the bumper during this process. These configurations are duplicated in Plant No. 2. For Plant No. 2, the Basecoat Booth (8007) and Clearcoat Booth (8025) are vented to Plant No. 2 Fluidized Bed Carbon Adsorption System with RTO2 (7056) (when constructed as part of the recent permitting activity) that are required to achieve a 95% destruction efficiency. There are thermocouples on the RTO to monitor and record temperature measurement. These records are maintained in a computer database for review. Honda reports exceedances within the General Proviso breakdown requirements. Written reports are submitted with their quarterly report. Bumper Painting (X002) The bumper painting units use an Epox fluid instead of water to collect the particulates. The bumper paint repair booth and the final repair booth utilize particulate filters. These configurations are duplicated in Plant No. 2. Monitoring of Emissions (Bumper Coating Lines) For Honda s various PSD-BACT limits that involve VOCs, Honda maintains records of monthly coating usage, coating analysis to show compliance with their permit limits. These are submitted quarterly to the department. Honda has limits on the overall usage of VOCs, usage of clean up/purge/flushing solvents, usage of Hazardous Air Pollutants (HAPs) for Miscellaneous Assembly Materials, and usage of HAPs for clean up/purge/flushing solvents. For Honda s various 112(g)-MACT limits that involve HAPs, Honda maintains records of monthly coating usage and coating analysis to show compliance with their permit limits. These are submitted quarterly to the department. Honda has limits on the overall usage of HAPs, usage of clean up/purge/flushing and 112(g) limits on their plastic parts coating line. The stacks associated with these sources shall not exhibit greater than 10% opacity. If opacity of 5% or greater is observed from a stack, the

7 operator shall investigate the cause and make any necessary corrective actions. This BACT limit is more stringent than the state allowable opacity. Due to the use of natural gas on all the burners and PM filters and controls on stacks, it is unlikely that visible opacity would be emitted. Honda shall utilize good work practices that are practically and economically feasible that reasonably minimize clean-up/purge/general solvent usage in all operations. Coatings, solvents, and other VOC containing material will be handled in such a way as to minimize VOC emissions from storage, handling, coating, and cleanup. Closed containers shall be used for the storage and disposal of cloth or other material used for VOC containing material cleanup or usage. Coatings and other fresh or spent VOC coating material will be stored in closed containers. Due to the use of water curtains to control particulates from this operation and low PM emissions from this operation, daily monitoring of the stacks from the paint booths will not be required. Daily monitoring of the scrubbers/water curtains will also be unnecessary due to the low PM emissions. Honda utilizes only natural gas as a fuel for the ovens and has installed low NOx burners. The use of natural gas will minimize emissions of PM and SO2. Due to the inherently low particulate and SO2 emissions using this fuel, no periodic monitoring will be required. The use of low NOx burners will minimize the emissions of NOx. Therefore, no emission monitoring will be required for this pollutant. Low NOx burners and natural gas only as a fuel are utilized throughout Honda on all sources where it is feasible to reduce NOx emissions. CO emissions are typically elevated inversely to NOx emissions, meaning efforts to reduce NOx emissions will generally increase CO emissions. For the small size of units at Honda, CO controls would be infeasible, and possibly counterproductive to the control of NOx. Three 28.6 MMBTU/HR Natural Gas Fired Boilers (X003) Three 28.6 MMBTU/HR Natural Gas Fired Boilers (003) were constructed with the original Plant No. 1. These supply mostly space heat for the plant with some process heat. Monitoring of Emissions (BOILERS)(003) Honda will utilize only natural gas as a fuel for the boilers and have installed low NOx burners. The use of natural gas will minimize

8 emissions of PM and SO2. Due to the inherently low particulate and SO2 emissions using this fuel, no periodic monitoring will be required. The use of low NOx burners will minimize the emissions of NOx. The boiler burner manufacturer has tested the NOx ppm levels on these low NOx burners and found them satisfactory to meet the permit requirements. Therefore, no emission monitoring will be required for this pollutant. These boilers will be subject to the Boiler MACT, but because they will be natural gas fired only, no substantive requirements will be implemented. Four 8.3 MMBTU/HR Natural Gas Fired Boilers (X001) (X010) Honda has two 8.3 MMBtu/hr hot water boilers for Plant No. 1. One of these boilers supplies hot water to the painting process and the other boiler supplies hot water to the bumper process. This configuration is duplicated in Plant No. 2 for a total of MMBtu/hr boilers. Monitoring of Emissions (Paint Boilers)(1046, 2020, 7046, 8020) Honda will utilize only natural gas as a fuel for the boilers and have installed low NOx burners. The use of natural gas will minimize emissions of PM and SO2. Due to the inherently low particulate and SO2 emissions using this fuel, no periodic monitoring will be required. The use of low NOx burners will minimize the emissions of NOx. The boiler burner manufacturer has tested the NOx ppm levels on these low NOx burners and found them satisfactory to meet the permit requirements. Therefore, no emission monitoring will be required for this pollutant. These boilers will be subject to the Boiler MACT, but because of the size (<10 MMBTU/HR each) and natural gas fired only, no substantive requirements will be implemented. Storage Tanks with Stage I Recovery (004) (Plant No. 1) Storage Tanks with Stage I Recovery (013) (Plant No. 2) Utilities (Tank Farm) (X004)(X013) The tank farm for Plant No. 1 consists of one 20,000-gallon (T7) and one 10,000-gallon (T8) gasoline tanks. The tank farm for Plant No. 2 consists of one 20,000-gallon (A208) gasoline tank. Tanks T7 and A208 are subject to NSPS (Kb). There is a drum storage area for waste and other drummed fluids. The gasoline storage tanks have been equipped for Stage I recovery. Due to the nature of the permit and small emissions involved, only record-keeping is involved with the monitoring of emissions.

9 Aluminum Operations: HP Melting Furnace (3.3 TPH), 2-High Pressure Die Cast Machines, and Heat Treatment Furnace T5 (005) (Plant No. 1) Aluminum Operations: LP Melting Furnace (2.0 TPH), 3-Low Pressure Die Cast Machines, and Heat Treatment Furnace T6 (006) (Plant No. 1) No. 2 Aluminum Operations: HPDC Aluminum Melting Furnace No. 2 (3.3 TPH), LPDC Aluminum Melting Furnace No. 2 (2.0 TPH), Ton High Pressure Die Cast Machine, Ton Low Pressure Die Cast Machines, 4 Sand Mold Core WJ Machines, 4 Sand Mold Core Port. Machines, No. 2 T-6 Heat Treatment Process, and Aluminum Machining (014) No. 2 Ferrous Machining Operations and Gas Soft Nitriding (GSN) Furnace (016) Aluminum Operations (X005) The High and Low Pressure Melt Furnaces melt charges of aluminum. They then transfer the metal to the Holding Furnace. The metal then goes to the Die Cast Machines to manufacture engine blocks and heads. The engines then go to a Heat Treatment Furnace which is an aging process for the blocks which subjects them to 450 F for 3-5 hours. Aluminum Operations (X006) Honda has low pressure casting machines to make the heads for the engines. The T-6 Heat Treating Oven with water quench heats the parts at a higher temperature and longer time than the T-5 Oven. The Sand Mold Equipment mixes sand and resin to make molds for the aluminum to be poured. The (Plant No. 1) High Pressure Melt Furnace, the (Plant No. 1) Low Pressure Melt Furnace, and the Sand Mold Equipment are vented to a cyclone before exiting to the atmosphere. This building also contains a Head Line where the line boring, finishing, rough milling, tapping, leak testing, installation of parts, and finally shipping occur. There is also a Block Line where the milling, drilling, tapping, line boring, and washing occur of the engine blocks. Aluminum Operations (X014) The High and Low Pressure Melt Furnaces melt charges of aluminum. They then transfer the metal to the Holding Furnace. The metal then goes to the high pressure and low pressure die cast machines to manufacture engine blocks and heads. Plant No. 2 also has another T-6 Heat Treating Oven. Machining operations mill and grind the parts to specifications.

10 No. 2 Ferrous Machining Operations and Gas Soft Nitriding (GSN) Furnace (X016) Honda takes ferrous cast material manufactured elsewhere and milling, drilling, tapping, boring, grinding, and polishing occur on these parts. Some of the parts are subjected to a Gas Soft Nitriding (GSN) treatment in a furnace for surface hardness development. Monitoring of Emissions (Aluminum Furnaces and other Operations) Honda will utilize only natural gas as a fuel for the furnaces and have installed low NOx burners. Only aluminum blocks and clean scrap will be used to feed the furnaces. The use of natural gas will minimize emissions of PM and SO2. Due to the inherently low particulate and SO2 emissions using this fuel, no periodic monitoring will be required. The use of low NOx burners will minimize the emissions of NOx. The boiler burner manufacturer has tested the NOx ppm levels on these low NOx burners and found them satisfactory to meet the permit requirements. Therefore, no further monitoring will be required for these pollutants. These furnaces will not be subject to the Aluminum MACT (RRR), because of the clean nature of the aluminum feed. Title V Permitted Units The following is a list of all of the facility's sources (individual emissions units) which will be part of the facility s Title V Major Source Operating Permit: Permit Unit No. Description of Unit 001 MOTOR VEHICLE ASSEMBLY PLANT WITH WATER CURTAINS, RTO, AND LOW NOX BURNERS (PLANT NO.1) 002 PLASTIC PARTS COATING LINE (PLANT NO. 1) MMBTU/HR NATURAL GAS FIRED BOILERS (PLANT NO. 1) MMBTU/HR NATURAL GAS FIRED BOILERS (PLANT NO. 1) MMBTU/HR NATURAL GAS FIRED BOILERS (PLANT NO. 2) 004 STORAGE TANKS WITH STAGE I RECOVERY (PLANT NO 1)

11 005 ALUMINUM OPERATIONS: HP MELTING FURNACE(5002), 2-HP DIE CAST MACHINES, AND T5 HEAT TREATMENT FURNACE (PLANT NO. 1) 006 ALUMINUM OPERATIONS: LP MELTING FURNACE(5002), 3 LP DIE CAST MACHINES, AND T6 HEAT TREATMENT PROCESS (PLANT NO. 1) 010 MOTOR VEHICLE ASSEMBLY PLANT WITH WATER CURTAINS, 2-RTOS, AND LOW NOX BURNERS (PLANT NO.2) 011 PLASTIC PARTS COATING LINE WITH RTO (PLANT NO. 2) 013 STORAGE TANKS WITH STAGE I RECOVERY (PLANT NO 2) 014 NO. 2 ALUMINUM OPERATIONS: HP ALUMINUM MELTING FURNACE NO. 2 (6002), LP ALUMINUM MELTING FURNACE NO. 2 (6016), 1 HP DIE CAST MACHINE, 4 LP DIE CAST MACHINES, 4 SAND MOLD CORE WJ MACHINES, 4 SAND MOLD CORE PORT. MACHINES, NO. 2 T-6 HEAT TREATMENT PROCESS, AND ALUMINUM MACHINING (PLANT NO. 2) ENGINE TEST FIRING STANDS PLANT NO. 1 2-ENGINE TEST FIRING STANDS PLANT NO. 2 NO. 1-ENGINE TEST DYNAMOMETER PLANT NO. 1 W/ INCINERATOR AFTERBURNER NO. 2-ENGINE TEST DYNAMOMETER PLANT NO. 1 W/ INCINERATOR AFTERBURNER 016 NO. 2 FERROUS MACHINING OPERATIONS AND GAS SOFT NITRIDING (GSN) FURNACE 021 GENERATOR(S) CAM Compliance Assurance Monitoring (CAM) is not applicable for the NESHAP (MACT) regulations within this Title V permit because these regulations were proposed post November 15, 1990 (Automotive Manufacturing, Plastic Parts Coating, Boilers, Aluminum Operations, and Engine Testing). Compliance Assurance Monitoring (CAM) is not applicable for the Title V permit for the other units listed herein because

12 potential uncontrolled emissions of criteria pollutants do not exceed 100 tons per year on any one unit with control device(s). Monitoring of Emissions from the automobile and plastic parts coating lines will be accomplished by a Compliance Assurance Monitoring (CAM) plan for the thermal oxidizers and compliant coatings. For the thermal oxidizer, the minimum set-point temperature of the combustion chamber was set by performance testing. The temperature will be monitored and recorded continuously using a thermocouple and chart. This facility shall maintain emission records and supporting background documents to this Department and submit records that pertain to their MSOP whenever requested. Permitting Fees Title V major sources are subject to operating permit fees which charge the facility a yearly amount based on the actual emission rate of pollutants for the previous year. Affected States Notification Standard practice is to notify of the issuance of this major source operating permit to all states bordering Alabama. Recommendations I recommend that the attached permit be issued to Honda. October 2017 Kevin Fulmer Chemical Branch KMF: kmf C:\KMF\1A_MINE\COMP\TITLEV\HONDA\RENEW2017\AC10050B_2_00.doc