The DeMinimis changes will result in a net increase in permitted particulate (PM/PM 10 ) emissions of 1.6 tons/yr for the facility.

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1 Page 1 of 7 STATEMENT OF BASIS for the issuance of Draft Air Permit #: 562-AR-3 1. PERMITTING AUTHORITY: Arkansas Department of Environmental Quality 8001 National Drive Post Office Box 8913 Little Rock, Arkansas APPLICANT: A. Tenenbaum 4500 West Bethany Road North Little Rock, AR PERMIT WRITER: James G. Siganos, P. E. 4. PROCESS DESCRIPTION AND NAICS CODE: NAICS Description: Recyclable Materials Merchant Wholesalers Ferrous Metals/Non Ferrous Metals Recycling NAICS Code: SUBMITTALS: 5/5/05 6. REVIEWERS NOTES: The A. Tenenbaum Co. submitted a request for a DeMinimis change on May 5, 2005 proposing to retrofit the metal shredder designated as source SN-03. The metal shredder uses an electrically powered hammer mill to reduce scrap metal, junk automobiles and appliances (white goods) into small pieces The existing air pollution control devices for emission source SN-03, consisting of two (2) cyclones and a wet scrubber will be replaced by: a Texas Shredder (TSI) Smart Water Injection System (WIS) and a single cyclone. The retrofitting of SN-03 will allow for increased production (metal shredding) with a trivial increase in particulate emissions. The installation of a TSI-WIS will enhance dust and particulate removal by applying water directly to the hammer impact area, thus yielding less particulate and smoke which may be controlled by a single cyclone. The only water released during the process is in the form of steam which is generated by heat build-up in the hammer mill during the shredding operation. The DeMinimis changes will result in a net increase in permitted particulate (PM/PM 10 ) emissions of 1.6 tons/yr for the facility. There is no AP-42 factor for a metal shredder. However, an emission factor for a metal shredder was obtained from a similar operation in Florida. See calculations for SN-03. The following SOB items have been modified for this permit: 5, 6, 9,12, 15, 17 and COMPLIANCE STATUS: The following summarizes the current compliance status of the facility including active/pending enforcement actions and recent compliance activities and issues

2 Page 2 of 7 8. APPLICABLE REGULATIONS: PSD Applicability: N/A Source and Pollutant Specific Regulatory Applicability Source Pollutant Regulation [NSPS, NESHAP (Part 61 & Part 63), or PSD only] SN-01 Dioxins/ Furans NESHAPS Subpart RRR 9. EMISSION CHANGES: The following table summarizes plant wide emission changes associated with this permitting action. Plant Wide Permitted Emissions (ton/yr) Pollutant Air Permit#: 562-AR-2 Air Permit#: 562-AR-3 Change PM/PM SO VOC CO NO X Dioxins/Furans TEQ 6.57x x

3 Page 3 of MODELING: Criteria Pollutants Examination of the source type, location, plot plan, land use, emission parameters, and other available information indicate that modeling is not warranted at this time. Other Modeling: N/A Odor: N/A H 2 S Modeling: N/A 11. Non-Criteria Pollutants 1st Tier Screening (PAER) - Previous Permit Estimated hourly emissions from the following sources were compared to the Presumptively Acceptable Emission Rate (PAER) for each compound. The Department deemed PAER to be the product, in lb/hr, of 0.11 and the Threshold Limit Value (mg/m 3 ), as listed by the American Conference of Governmental Industrial Hygienists (ACGIH). Pollutant TLV (mg/m 3 ) PAER (lb/hr) = 0.11*TLV Proposed lb/hr Pass? Dioxins and Furans 0.001* Yes *Hypothetical value. No TLVs were found for Dioxins and Furans. Thus, the reviewing engineer screened these pollutants based on a hypothetical TLV of mg/m 3. The emission rates for dioxins and furans were based on the requirements of 40 CFR Part 63, Subpart RRR - National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production.

4 Page 4 of 7 SN 12. CALCULATIONS: Emission Factor Source (AP- 42, Testing, etc) Emission Factor and units (lbs/ton, lbs/hr, etc) 01 AP-42 lb/10 6 scf, Natural Gas Combustion, 14.5 lb/ton, 13 lb/ton 03 Emissions Testing of Metal Shredder in Florida 1.5 lbs/ hr for every 180 tons per hour scrap metal processed/shr edded 05 AP-42 lb/10 6 scf, Natural Gas Combustion, 14.5 lb/ton, 13 lb/ton 13. TESTING REQUIREMENTS: N/A 14. MONITORING OR CEMS Control Equipment Type ( if any) Control Equipment Efficiency Comments (Emission factor controlled/uncontrolled, etc) Afterburner 90% Calculation based on natural gas purchased (165,000 MMBtu/yr) rather than rated capacity. Also based on 1,250 tons of aluminum per year and 60 tons of zinc per year. Dioxins and furans emission rate based on 3.5x10-10 gr/dscf as required by NESHAP Subpart RRR and 5,000 cfm air flow rate. One cyclone and TSI-WIS 95% Emission factor includes factor of safety and is based upon stack testing of similar scrap metal shredder with cyclone and water injection system. A similar system was tested in Florida in order to show compliance with FDEP requirements. Baghouse 90% Calculation based on natural gas purchased (165,000 MMBtu/yr) rather than rated capacity. Also based on 1,250 tons of aluminum per year and 60 tons of zinc per year. (Same emissions as SN-01) The permittee must monitor the following parameters with CEMs or other monitoring equipment (temperature, pressure differential, etc), frequency of recording and the need for records included in any annual, semiannual or other reports. Parameter or Pollutant SN to be Monitored 01 Operating temperature of afterburner Method of Monitoring (CEM, Pressure Gauge, etc) Frequency* Report (Y/N)** Temperature monitoring device Continuously Yes, if out of compliance * Indicate frequency of recording required for the parameter (Continuously, hourly, daily, etc.) ** Indicates whether the parameter needs to be included in reports.

5 Page 5 of RECORD KEEPING REQUIREMENTS The following are items (such as throughput, fuel usage, VOC content of coating, etc) that must be tracked and recorded, frequency of recording and whether records are needed to be included in any annual, semiannual or other reports. SN Recorded Item Limit (as established in permit) Frequency* Report (Y/N)** 01 Amount of Natural Gas Used 165,000,000 scf/yr Monthly N Records of 15-minute Block Average Afterburner Operating Temperature Continuously N Records of the average temperature for each 3-hour block period. Records of Any 3-hour Block Period When the Average Temperature Falls Below the Compliant Value Records of Annual Afterburner Inspections Temperature must be Continuously N greater than 1600 F. As Needed Y --- Yearly N Reports as Required by Y Records for Continuous Monitoring Systems 03 Continuous operation of scrap metal processed/shredded. [Record keeping of shredded metal is not required since emission limit is based upon maximum operation. 180 tons per 8760 hrs =1,576,800 tpy] 01, 05 Amount of Aluminum / Zinc Processed N Cyclone and TSI-WIS shall be in operation whenever scrap metal shredder is in operation 1,250 tons/yr Aluminum 60 tons/yr Zinc N/A Monthly * Indicate frequency of recording required for the item (Continuously, hourly, daily, etc.) ** Indicates whether the item needs to be included in reports N N

6 Page 6 of OPACITY SN Opacity % Justification (NSPS limit, Dept. Guidance, etc) Compliance Mechanism (daily observation, weekly, control equipment operation, etc) Previous Permit Department guidance Previous Permit DELETED CONDITIONS: Former SC The previous permit contained the following deleted Specific Conditions. Justification for removal The permitted emissions for the scrap metal shredding system are based upon continuous operation of the metal shredder, which includes operation of the TSI-WIS and cyclone. Monthly record keeping is no longer required to show compliance since permitted emissions are based upon continuous operation (8760 hours) 18. VOIDED, SUPERSEDED OR SUBSUMED PERMITS List all active permits voided/superseded/subsumed by issuance of this permit for this facility. 19. CONCURRENCE BY: Permit # 562-AR-2 The following supervisor concurs with the permitting decision: Thomas Rheaume, P.E.