Air Quality Permit File SOOP # BenBilt Building Systems, LP I Finishing and Assembly Plant

Transcription

1 OFHClAL FlLE t;qf SOUTHWEST REGIONAL OFFICE MEMO TO FROM THROUGH DATE RE Air Quality Permit File SOOP # BenBilt Building Systems, LP I Finishing and Assembly Plant Sheila A. Shaffer ~ Air Quality Engineering Specialist Bureau of Air Quality ~ Barbara R. Hatch, P.E. ~ Environmental Engineering Manager Bureau of Air Quality January 8, 2015 Mar~~ Air Quality Manager Bureau of Air Quality Review of State Only Operating Permit Initial Application Unity Township, Westmoreland County APS# ; AUTH# ; PF# Background On July 30, 2014, an initial State Only Operating Permit (SOOP) application was received by the Department for BenBilt Building Systems, LP I Finishing and Assembly Plant for its wholesale building material facility located in Unity Township, Westmoreland County. BenBilt has complied with the municipal notification requirements contained in 25 Pa. Code and the application fee requirements contained in 25 Pa. Code (b)(3). On August 8, 2014, the SOOP application was determined Administratively Complete. The facility is currently operating under Plan Approval A that was authorized on December 4, On April 14, 2014, the Department received a Plan Approval Extension Form to extend Plan Approval A to facilitate the shake-down of sources and air cleaning. Authorization of the plan approval extension was effective June 4, 2014 (original expiration date). On October 23, 2014, the Department received another Plan Approval Extension Form to extend Plan Approval A to permit operation pending the issuance of a permit. Authorization of the plan approval extension was effective December 4, 2014 (expiration date of first extension) and the plan approval will now expire June 4, BenBilt is a private company that was established in 1998 and began construction, installation and operation of the Finishing Assembly Plant in Unity Township, Westmoreland County in 2011 without authorization from the Department. On November 20, 2013, the Department sent BenBilt a notice of violation (NOV) for construction and operation of air contamination sources without authorization from the Department. On June 6, 2014, the Department executed a Consent Assessment of Civil Penalty and received a civil penalty payment in the amount of $4, in resolution of the violations of25 Pa. Code and noted on November 20,

2 Sources, Control Devices and Emissions BenBilt operates 4 manual spray booths for surface coating of metal and fiberglass doors and wooden door jams and frames. These doors are used in exterior residential premises. After doors are prepared, they are placed on aluminum hooks and then hung on the line to be painted, clear coated, or stained. Each spray booth is connected to a passive (dry) air filter unit, Model No. Supra I Mini Mesh, and manufactured by Columbus Industries, Inc. The sources are identified in the proposed operating permit as the following: Source ID 101 Col-Met Paint Booth/Color Booth Source ID 102 Col-Met Spray Booth/Clear Coat Source ID 103 Col-Met Paint Booth/Paint and Clear Coat Station Source ID 104 Col-Met Stain Booth/Manual Brushing Station Source ID 105 Manual Stain Wiping Area Color or Clear Coat Source ID 106 Col-Met Infrared Drying Area Source ID I 07 Air Makeup Unit rated at MMBtulhr Below are the following process scenarios: Metal Doors: Metal doors are pushed into Spray Booth No. I (Source No. I 01), painted with the appropriate color by an air-assisted spray gun, Kremlin M22 P HPA, EN3, at a maximum speed of 5 ft/min with 63% transfer efficiency, and then pushed out of the booth where the motorized portion of the line picks up the doors and takes through a drying oven (Source No. 106 at 180 to 190 F temperature). The hot doors are left for cooling. Once the doors are cooled, they are inspected, removed from the line, and sent for packaging. The paint, UREPR , is either run through the plural mixing system via overhead lines or through one or five gallon pumps or in some cases it is hot potted. Fiberglass Doors: Fiberglass doors are sprayed with the stain, Blend-3032, with an air-assisted spray gun, Kremlin M22 G HPA, Gravity ENS, at a maximum speed of 5 ft/min with 65% transfer efficiency in Spray Booth No. 4 (Source No. I 04) and then pushed to the manual brushing stations. The M22 G HP A is a gravity fed gun that delivers outstanding finish quality with unsurpassed operator comfort. The "assist" of air happens at the tip, where air is mixed with fluid to form the spray pattern. However the entire pump system is not air "assisted", but rather completely air driven, or pneumatic. The doors are then left on the line to dry for 24 hours prior to applying the clear coat with a conventional air assisted spray gun, Kremlin Xcitel20, EN3, at a maximum speed of 5 ft/min with 86% transfer efficiency in Spray Booth No. 2 (Source No. 1 02). The dry stained doors are manually pushed to the spray booth to apply the first clear coat. The clear coated door is run through the plural mixing system. After the first coat, door is pushed out of the booth where the motorized line picks it up, and takes through the infrared drying oven (Source No. 1 06). The door exits the oven and is allowed to cool. The first coat of clear is lightly scuffed after cooling. The door is then returned to the same spray booth and the second 2

3 coat of clear is applied. The drying process is repeated. Once the second clear coat is dry, door is allowed to cool, inspected, and then taken off the line for packaging. Wooden door Jambs/Frames: The jambs/frames are brushed stained with N-9028A or Blend 3032 and then manually wiped in Stain Wiping Area No. 1 (Source No. 1 05). The jambs/frames are slid on the ground into Spray Booth No. 3 (Source No. 103) to either be painted or clear coated with UREPR with an air assisted spray gun Kremlin M22 P HPA, EN3 with 63% transfer efficiency. Once the paint or clear coat has been applied, they are slid out of the spray booth to air dry in the staging area. BenBilt uses Infrared W-Series electric heater, Col-Met Enclosure with Infratech Lights (IR-FT DT) to dry the coatings at a temperature of 180 F-190 F at 5,000 scfm air flow. This drying oven also speeds up the drying time and therefore, allow for increased production. There are no combustion units of any kind inside the infratube fixtures and hence no emissions from this source. The facility is also equipped with a dust collector, manufactured by NR Murphy, Model No, MKA W-835-H. The dust collector is rated at 5,800 acfm at 70 degrees Fahrenheit and exhausts indoors. The dust collector collects saw dust from various wood working equipment used to make the wood door jambs and frames. The equipment connected to the dust collector is listed in the Miscellaneous Section of the proposed operating permit. The primary source of emissions from this facility is VOC emissions from the surface coating process. BenB ilt has voluntarily taken a V OC restriction of 25.1 tons per year. The facility-wide potential emissions are: 3.52 tpy NOx, 2.96 tpy CO, 25.1 tpy VOC, 5.0 tpy, 0.6 tpy single HAPs, and less than 1.0 tpy for all other criteria pollutants. The actual emissions for 2013 submitted in the Emission Inventory Production Report were: tpy VOC and 0.03 tpy HAPs. Regulatory Analysis 25 Pa. Code Surface Coating Processes - Per 25 Pa. Code 121.1, surface coating process is defined as "The application and solidification of a coating onto or into a substrate as the substrate proceeds through the equipment and activities of the manufacturing process." The operations at this facility do meet the definition of a surface coating process and the facility is subject to the miscellaneous metal parts and products emission limitations in Table 1. Therefore this section is incorporated into the proposed operating permit. 25 Pa. Code a. Control ofvoc emissions from large appliance and metal furniture surface coating processes - does not apply to this facility as it does not meet the definitions of large appliances or metal furniture surface coating process. 3

4 25 Pa. Code b. Control of VOC emissions from paper, film and foil surface coating processes - does not apply to this facility as it does not meet the definitions of a paper, film or foil surface coating process. 25 Pa. Code c. Control ofvoc emissions from flat wood paneling surface coating processes - does not apply to this facility as it does not meet the definitions of flat wood paneling surface coating process. 25 Pa. Code Graphic arts systems - does not apply to this facility as it does not meet the definitions of rotogravure or flexographic printing. National Emission Standards for Hazardous Air Pollutants (NESHAPS) for Surface Coating of Miscellaneous Metal Parts and Products from 40 CFR Part 63 Subpart MMMM does not apply to this facility. Per 40 CFR Section (b), "You are subject to this subpart if you own or operate a new, reconstructed, or existing affected source, as defined in , that uses 946 liters (250 gallons (gal)) per year, or more, of coatings that contain hazardous air pollutants (HAP) in the surface coating of miscellaneous metal parts and products defined in paragraph (a) of this section; and that is a major source, is located at a major source, or is part of a major source of emissions of HAP." The facility is an area source of HAP emissions; therefore this subpart does not apply. NESHAPS for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources from 40 CFR Part 63 Subpart HHHHHH does not apply to this facility. Per Section , this subpart establishes national emission standards for HAP for area sources involved in any ofthe activities in paragraphs (a) through (c) of this section. This facility is an area source for HAP but will not be involved in paint stripping operations using MeCl, spray application of coatings to motor vehicles or mobile equipment, or spray application of coatings containing the "target HAP" per Therefore this subpart does not apply. NESHAPS for Standards for Nine Metal Fabrication and Finishing Source Categories from 40 CFR Part 63 Subpart XX:XXXX does not apply to this facility. Subpart XXXXXX was promulgated on July 23, Per 40 CFR (b), this subpart applies if you use materials that contain or have the potential to emit metal fabrication or finishing metal HAP (MFHAP), defined to be the compounds of cadmium, chromium, lead, manganese, and nickel, or any these material in elemental form with the exception of lead as follows: Material containing MFHAP means a material containing one or more MFHAP. Any material that contains cadmium, chromium, lead, or nickel in amounts greater than or equal to 0.1% by weight (as the metal), and contains manganese in an1ounts greater than or equal to 1.0% by weight (as the metal), as shown in formation data provided by the manufacturer or supplier, such as the Material Safety Data Sheet for the material, is considered to be a material containing MFHAP. This facility does not use materials that contain MFHAP; therefore, this subpart does not apply. 4

5 BenBilt facility is not subject to Title V Permitting, NSR or PSD regulations because the proposed emission rates, with controls and material usage limitations, will be below major source thresholds. Compliance The emissions from all sources and associated air pollution control equipment covered under this Operating Permit must not equal or exceed any of the following on a 12-month rolling basis: 25.1 tons VOC, and 0.6 tons any individual hazardous air pollutant (HAP). Particulate matter emissions are not to exceed 0.04 gr/dscf. The opacity is not to exceed 10 percent for a period or periods aggregating three minutes in any one-hour or equal to or greater than 30 percent at any time. A facility-wide inspection during daylight hours for the presence of any visible stack emissions, fugitive emissions, and any potentially objectionable odors at the property line at a minimum of once each week while the sources are operating must be performed. Records of each inspection must be maintained in a log on-site. The facility must maintain daily records of each coating including: volume used, mix ratio, density, weight percent of total volatiles, volume percent of solids, and VOC content as described in The facility is required to report VOC and HAP emissions by March 1st of each year for the preceding calendar year. The facility must maintain and comply with the written Work Practice Implementation Plan developed. Public Notice: On January 3, 2015, the Notice oflntent to Issue was published in the PA Bulletin for a 30-day public comment. The proposed initial Operating Permit will be submitted to BenBilt for review as well as the Department's Air Quality Specialist. Recommendation: On November 6, 2013, an initial operating permit inspection was performed by Jesse Parihar, Air Quality Engineering Specialist, and Phil Sapala, Air Quality Specialist. The violations noted from this inspection have been addressed and rectified. It is my recommendation that the initial State Only Operating Permit for BenBilt Building Systems, LP I Finishing and Assembly Plant, SOOP , be issued with the proposed conditions/restrictions summarized above. 5