ADEQ MINOR SOURCE AIR PERMIT

Transcription

1 ADEQ MINOR SOURCE AIR PERMIT IS ISSUED TO: 1910 Baldor Drive Ozark, AR Franklin County THIS PERMIT IS BALDOR ELECTRIC COMPANY S AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT S MINOR SOURCE AIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Mike Bates Chief, Air Division Date

2 Table of Contents Section I: FACILITY INFORMATION... 3 Section II: INTRODUCTION... 4 Summary... 4 Process Description... 4 Regulations... 5 Section III: PERMIT HISTORY... 6 Section IV: EMISSION UNIT INFORMATION... 7 Specific Conditions... 7 Section V: INSIGNIFICANT ACTIVITIES Section VI: GENERAL CONDITIONS

3 Section I: FACILITY INFORMATION PERMITTEE: PERMIT NUMBER: 1583-AR-5 FACILITY ADDRESS: 1910 Baldor Drive Ozark, AR COUNTY: Franklin CONTACT POSITION: Plant Manager Ryan Waite TELEPHONE NUMBER: (479) FAX NUMBER: (479) OFFICE CONTACT POSITION: Manufacturing Engineer Jose Shores TELEPHONE NUMBER: (479) FAX NUMBER: (479) REVIEWING ENGINEER: Siew Low UTM North-South (Y) Zone km N UTM East-West (X): Zone km E 3

4 Section II: INTRODUCTION Summary owns and operates an electric motor manufacturing facility in Ozark, Arkansas. The facility assembles and paints electric motors. This permit modification is issued to increase the VOC content of the lacquer thinner used at SN-01, to incorporate the acetone usage at SN-01, and to incorporate a HAP table to increase operational flexibility. Also, MEK has been delisted as HAP but it is still a VOC. Recordkeeping requirement of MEK as HAP has been removed. Process Description manufactures electric motors. The manufacturing of an electric motor involves several distinct process areas and the receiving and staging of many miscellaneous parts (manufactured off site). The basic manufacturing operations at this facility include the stator winding manufacturing lines, stator varnish line, shaft machine process line, rotor and shaft sub-assembly lines, motor band welding process (some motors use a cast metal housing), and sub-assembly of stator with motor bands or cast housings. The motor assembly lines combine all of these components and sub-assemblies to make the final assembled product. The exterior surfaces are then painted, dried and packaged for distribution. The stator varnish system (SN-02, SN-03a, and SN-03b) uses a low VOC (polyester resin based) varnish. The varnish is a mixture of polyester resin and vinyl toluene (not a HAP). The stator coating process consists of a stator conveyor loading area, a varnish dip tank with a drip drainage area (excess varnish is returned to the dip tank), a varnish curing oven, a cool down chamber, and the stator unload area. Vendor data indicates that emissions of 1.6 pounds VOC/gallon varnish applied occurs because a significant quantity of the VOC used in the varnish mixture polymerizes as the varnish cures. A preheat oven is utilized in the varnish process. The preheat oven is natural gas fired. Assembled motors are painted to customer specifications. The paint spray booths (SN-01) will be equipped with dry filters to control particulate matter. Painted motors are air dried. Waste paints and solvents are shipped off site for disposal. Coolant fluids and water based metal cleaning fluids from various machines are periodically replaced. Used fluids are fed to a natural gas fired evaporator (SN-05), which drives off water, leaving a waste residue. Waste sludge will be shipped off site for disposal. The evaporator operates at the boiling point of water. Oil constituents in the fluids have boiling points greater than that of water, resulting in emissions of water vapor and natural gas combustion products. Regulated pollutants generated from the welding operation (SN-04) include small amounts of particulate matter. Unregulated gaseous emissions include nitrogen, argon, and carbon dioxide. The welding processes will remain as previously permitted as an insignificant activity. 4

5 Regulations is subject to regulation under the Arkansas Air Pollution Control Code (Regulation 18) and the Arkansas Plan of Implementation for Air Pollution Control (Regulation 19). The following table is a summary of the facility s total emissions. Total Allowable Emissions Pollutant Emissions Rates Lb/hr tpy VOC Single HAP * Total HAPs and acetone * * HAPs include in VOC totals. 5

6 Section III: PERMIT HISTORY Permit No A was issued to in 1995 for the initial construction of the facility. Five emission sources were permitted. The paints and varnish formulations allowed and their usages were used for compliance assurance in this permit. Permit Limits were: PM/PM tpy, SO tpy, VOC tpy, CO tpy, and NO x tpy. Permit No AR-1 was issued to on June 15, 1998 to establish the facility as a minor source not subject to Title V permitting. The amount of HAPs emitted were listed in the permit but no limits were established. Compliance assurance for VOC emissions was changed to a material balance and the paint usage limits were removed. Permit Limits were: PM/PM tpy, SO tpy, VOC tpy, CO tpy, and NO x tpy. Permit No AR-2 was issued to on November 20, 2000 to add a paint booth and to reflect changes made when the plant was expanded. Permit Limits were: PM/PM tpy, SO tpy, VOC tpy, CO tpy, and NO x tpy, MEK tpy, Xylene tpy, and Toluene 5.06 tpy. Permit No AR-3 was issued to on May 8, 2001 to add a paint booth (for operating efficiency no increase in actual painting) and add equipment to the insignificant activities list. Permit Limits were: PM/PM tpy, SO tpy, VOC tpy, CO tpy, and NO x tpy, MEK tpy, Xylene tpy, and Toluene 5.06 tpy. Permit No AR-4 was issued to on June 25, 2003 to change the paint booths (SN-01a, SN-01B, and SN-01c) into a single source (SN-01) and to increase the emission limit for that source to allow for increased painting at the facility. Permit Limits were: VOC 59.6 tpy, MEK 2.1 tpy, Xylene 9.1 tpy, and Toluene 9.8 tpy. Permit No AR-5 was issued to on January 22, This permit modification was issued to increase the VOC content allowed in the stator coating system (SN-03a) and authorized the use of a spray-on insulator/stiffener in the motor repair operation, as an insignificant activity. 6

7 Section IV: EMISSION UNIT INFORMATION Specific Conditions 1. The permittee will not exceed the emission rates set forth in the following table. [Regulation 19, et seq., effective May 28, 2006 and A.C.A as referenced by and ] SN Description Pollutant lb/hr Tpy 01 Paint Application Booths No. 1, 2, and 3 VOC Varnish Dip Tanks Emissions are included in SN-03a 03a Varnish Curing Ovens VOC b Varnish Cool Down Chamber Emissions are included in SN-03a 2. The permittee will not exceed the emission rates set forth in the following table. [Regulation 18, , effective February 15, 1999, and A.C.A as referenced by ' and ] SN Description Pollutant lb/hr tpy 01 Paint Application Booths No. 1, 2, and 3 * HAPs include in VOC totals. Single HAP* Combined HAPs and acetone* Visible emissions will not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [A.C.A as referenced by and ] SN Limit Regulatory Citation SN-01 20% SN-03a SN-03b 10% The permittee will not cause or permit the emission of air contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation #18, if the emission of the air contaminant constitutes air pollution within the meaning of A.C.A [Regulation 18, and A.C.A as referenced by and ] 5. The permittee will not conduct operations in such a manner as to unnecessarily cause air contaminants and other pollutants to become airborne. [Regulation 18, , and A.C.A as referenced by and ] 7

8 SN-01 Conditions 6. The permittee shall not use paints or thinner at SN-01 which exceed the following compositional limits: [Regulation 19, of and A.C.A as referenced by and ] Pollutant Volatile Organic Compounds Content Limit lb/gal Paint 6.22 Thinner The permittee will maintain monthly records which demonstrate compliance with Specific Condition #6. The permittee will update the records by the fifteenth day of the month following the month to which the records pertain. The permittee will keep the records onsite, and make the records available to Department personnel upon request. [Regulation 19, of and A.C.A as referenced by and ] 8. The permittee shall complete a volatile organic compound material balance by the twentieth of each month for the previous 12 months on the paint and solvent usage at the paint booths and should not include the material usage at stator varnish system process. The 12 month summary shall have a total of no more than 35.5 tons of volatile organic compounds usage. These records shall be kept on site, and shall be made available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] 9. The permittee shall not exceed the Hazardous Air Pollutant (HAP) and acetone content limits set forth in the following at SN-01. [Regulation 18, of and A.C.A as referenced by and ] TLV greater than or equal to (mg/m3) Maximum Allowable Content *

9 TLV greater than or equal to (mg/m3) Maximum Allowable Content * * The maximum content is the HAP content, as stated in (or calculated from) the MSDS in lb/gal, divided by the VOC content limit in lb/gal stated in Specific Condition No The permittee shall maintain records which demonstrate compliance with the limits set in Specific Condition #9, and which may be used by the Department for enforcement purposes. Compliance shall be determined by inspecting the American Conference of Governmental Industrial Hygienists (ACGIH) TLV values as listed on current MSDS forms, or in the most recently published ACGIH handbook of Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs), and properly noting on the monthly HAP and acetone records (required by Specific Condition #11) whether the material in question is compliant with the table contained in Specific Condition #10. These records shall be maintained on site and shall be provided to Department personnel upon request. [Regulation 18, and A.C.A as referenced by and ] 11. The permittee shall maintain monthly records of the HAP and acetone emissions from the facility in order to demonstrate compliance with tons per year emission limits. All HAPs and acetone that are capable of being emitted as air emissions and are contained in materials issued for use at the facility shall be considered to be emitted to a fume incineration unit. A 12-month rolling total and each individual month s data shall be maintained on a facilitywide basis. These records shall be maintained on site and shall be made available to Department upon request. [Regulation 18, , and A.C.A as referenced by and ] SN-03a Conditions 12. The permittee shall not use more than 30,000 gallons per rolling 12 month period of polyester resin in the stator varnish system process. [Regulation 19, and A.C.A as referenced by and ] 13. The permittee shall keep records of the usage of polyester resin in the stator varnish system process. A summary shall be completed by the twentieth of each month for the previous 12 months. These records shall be kept on site, and shall be made available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] 14. The polyester resin used in the stator varnish system process shall have a modified EPA Method 24 VOC content (measured content of VOC not consumed in the polymerization process) of less than 1.6 pounds per gallon as certified by the material supplier. [Regulation 19, of and A.C.A as referenced by and ] 15. The polyester resin used in the stator varnish system shall not contain compounds which result in hazardous air pollutant emissions greater than the de minimis levels. The resins can 9

10 contain compounds similar to the cobalt compounds contained in the current resins which get polymerized in the finished solid product. [Regulation 18, and A.C.A as referenced by and ] 10

11 Section V: INSIGNIFICANT ACTIVITIES The Department deems the following types of activities or emissions as insignificant on the basis of size, emission rate, production rate, or activity in accordance with Group A of the Insignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activity emission determinations rely upon the information submitted by the permittee in an application dated June 12, Description SN-02 Varnish Dip Tank SN-04 Welding Systems SN-05 Evaporator Varnish Curing Oven Burner Fume Hoods - Rotor Balance Stations Spray-on Insulator/Stiffener Usage Motor Repair Category A13 A13 A13 A1 A13 A13 11

12 Section VI: GENERAL CONDITIONS 1. Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A et seq.) as the sole origin of and authority for the terms or conditions are not required under the Clean Air Act or any of its applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A et seq.). Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A et seq.) as the origin of and authority for the terms or conditions are enforceable under this Arkansas statute. 2. This permit does not relieve the owner or operator of the equipment and/or the facility from compliance with all applicable provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated under the Act. [A.C.A as referenced by A.C.A and ] 3. The permittee will notify the Department in writing within thirty (30) days after commencement of construction, completion of construction, first operation of equipment and/or facility, and first attainment of the equipment and/or facility target production rate. [Regulation 19, and/or A.C.A as referenced by A.C.A and ] 4. Construction or modification must commence within eighteen (18) months from the date of permit issuance. [Regulation 19, (B) and/or Regulation 18, (B) and A.C.A as referenced by A.C.A and ] 5. The permittee must keep records for five years to enable the Department to determine compliance with the terms of this permit such as hours of operation, throughput, upset conditions, and continuous monitoring data. The Department may use the records, at the discretion of the Department, to determine compliance with the conditions of the permit. [Regulation 19, and/or Regulation 18, and A.C.A as referenced by A.C.A and ] 6. A responsible official must certify any reports required by any condition contained in this permit and submit any reports to the Department at the address below. [Regulation 19, and/or Regulation 18, and A.C.A as referenced by A.C.A and ] Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor Post Office Box

13 Little Rock, AR The permittee will test any equipment scheduled for testing, unless stated in the Specific Conditions of this permit or by any federally regulated requirements, within the following time frames: (1) newly constructed or modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start up of the permitted source or (2) existing equipment already operating according to the time frames set forth by the Department. The permittee must notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. The permittee must submit compliance test results to the Department within thirty (30) days after the completion of testing. [Regulation 19, and/or Regulation 18, and A.C.A as referenced by A.C.A and ] 8. The permittee will provide: [Regulation 19, and/or Regulation 18, and A.C.A as referenced by A.C.A and ] a. Sampling ports adequate for applicable test methods b. Safe sampling platforms c. Safe access to sampling platforms d. Utilities for sampling and testing equipment 9. The permittee will operate equipment, control apparatus and emission monitoring equipment within their design limitations. The permittee will maintain in good condition at all times equipment, control apparatus and emission monitoring equipment. [Regulation 19, and/or Regulation 18, and A.C.A as referenced by A.C.A and ] 10. If the permittee exceeds an emission limit established by this permit, the permittee will be deemed in violation of said permit and will be subject to enforcement action. The Department may forego enforcement action for emissions exceeding any limits established by this permit provided the following requirements are met: [Regulation 19, and/or Regulation 18, and A.C.A as referenced by A.C.A and ] a. The permittee demonstrates to the satisfaction of the Department that the emissions resulted from an equipment malfunction or upset and are not the result of negligence or improper maintenance, and the permittee took all reasonable measures to immediately minimize or eliminate the excess emissions. b. The permittee reports the occurrence or upset or breakdown of equipment (by telephone, facsimile, or overnight delivery) to the Department by the end of the next business day after the occurrence or the discovery of the occurrence. c. The permittee must submit to the Department, within five business days after the occurrence or the discovery of the occurrence, a full, written report of such occurrence, including a statement of all known causes and of the scheduling and nature of the actions to be taken to minimize or eliminate future occurrences, 13

14 including, but not limited to, action to reduce the frequency of occurrence of such conditions, to minimize the amount by which said limits are exceeded, and to reduce the length of time for which said limits are exceeded. If the information is included in the initial report, the information need not be submitted again. 11. The permittee shall allow representatives of the Department upon the presentation of credentials: [A.C.A as referenced by A.C.A and ] a. To enter upon the permittee's premises, or other premises under the control of the permittee, where an air pollutant source is located or in which any records are required to be kept under the terms and conditions of this permit; b. To have access to and copy any records required to be kept under the terms and conditions of this permit, or the Act; c. To inspect any monitoring equipment or monitoring method required in this permit; d. To sample any emission of pollutants; and e. To perform an operation and maintenance inspection of the permitted source. 12. The Department issued this permit in reliance upon the statements and presentations made in the permit application. The Department has no responsibility for the adequacy or proper functioning of the equipment or control apparatus. [A.C.A as referenced by A.C.A and ] 13. The Department may revoke or modify this permit when, in the judgment of the Department, such revocation or modification is necessary to comply with the applicable provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated the Arkansas Water and Air Pollution Control Act. [Regulation 19, (A) and/or Regulation 18, (A) and A.C.A as referenced by A.C.A and ] 14. This permit may be transferred. An applicant for a transfer must submit a written request for transfer of the permit on a form provided by the Department and submit the disclosure statement required by Arkansas Code Annotated ' at least thirty (30) days in advance of the proposed transfer date. The permit will be automatically transferred to the new permittee unless the Department denies the request to transfer within thirty (30) days of the receipt of the disclosure statement. The Department may deny a transfer on the basis of the information revealed in the disclosure statement or other investigation or, deliberate falsification or omission of relevant information. [Regulation 19, (B) and/or Regulation 18, (B) and A.C.A as referenced by A.C.A and ] 15. This permit shall be available for inspection on the premises where the control apparatus is located. [A.C.A as referenced by A.C.A and ] 14

15 16. This permit authorizes only those pollutant emitting activities addressed herein. [A.C.A as referenced by A.C.A and ] 17. This permit supersedes and voids all previously issued air permits for this facility. [Regulation 18 and 19 and A.C.A as referenced by A.C.A and ] 18. The permittee must pay all permit fees in accordance with the procedures established in Regulation No. 9. [A.C.A (c)] 15

16