OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY … · State of Oregon Department of Environmental Quality ... CMS continuous monitoring system OAR ... these emissions are also routed

~

Review Report/Permit No.: 24-0142-TV -0 I Application number: 28028

Page I ofl3

~ •• , =<•1

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

State of Oregon Department of Environmental Quality

Source Information:

REVIEW REPORT Western Region

4026 Fairview Industrial Drive SE Salem, OR 97302

3089 I Source Categories (Pati and code)

326199

Compliance and Emissions Monitoring Requirements

Unassigned emissions CEMS

Emission credits PEMS

Compliance schedule Ambient monitoring

Source test [date(s)]

COMS

R R eportmg eqmrements

Anuual report (due date) Feb 15 Monthly report (due dates)

Emission fee report (due date) Feb 15 Excess emissions report

SACC (due date) Feb 15, Jul 30 Other reports (type)

Quarterly report (due dates)

Air Programs

NSPS (list subparts) Title V

NESHAP (list subparts) A,WWWW ACDP (SIP)

CAM Major HAP source

Regional Haze (RH) Federal major source

Synthetic Minor (SM) NSR

Part 68 Risk Management PSD

CFC Acid Rain

RACT

TACT

Revised 1/26/16

X

X

X

TABLE OF CONTENTS

Review Report/Permit No.: 24-0142-TV-01 Application number: 28028

Page 2 of 13

TABLE OF CONTENTS ..................................................................................................................................................... 2

LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT ................................................................................ 3

INTRODUCTION ................................................................................................................................................................ 4

PERMITTEE IDENTIFICATION ...................................................................................................................................... 4

FACILITY DESCRIPTION ................................................................................................................................................ 4

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION ..................................................... 4

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING .......................... 6

PLANT SITE EMISSION LIMITS ..................................................................................................................................... 8

HAZARDOUS AIR POLLUTANTS .................................................................................................................................. 8

MONITORING, RECORDKEEPING AND REPORTING REQUIREMENTS ............................................................ 9

GENERAL BACKGROUND INFORMATION ............................................................................................................... 9

COMPLIANCE HISTORY ................................................................................................................................................. 9

SOURCE TEST RESULTS ................................................................................................................................................. 9

PUBLIC NOTICE .............................................................................................................................................................. 10

EMISSIONS DETAIL SHEETS ....................................................................................................................................... 11

Revised I/26/16


Page 3 of 13

LIST OF ABBREVIATIONS USED IN TillS REVIEW REPORT

AQMA Air Quality Management Area N20 nitrous oxide (greenhouse gas) ASTM American Society of Testing and NA not applicable

Materials NESHAP National Emission Standard for BDT bone dry ton Hazardous Air Pollutants CEMS continuous emissions monitoring NOx oxides of nitrogen

system NSPS New Source Performance Standard CFR Code of Federal Regulations NSR New Source Review CH4 methane (greenhouse gas) o, oxygen CMS continuous monitoring system OAR Oregon Administrative Rules co carbon monoxide ORS Oregon Revised Statutes co,e carbon dioxide equivalent O&M operation and maintenance COMS continuous opacity monitoring Pb lead

system PCD pollution control device DEQ Oregon Department of PEMS predictive emissions monitoring

Environmental Quality system dscf dry standard cubic feet PM particulate matter EF emission factor PM10 particulate matter less than I 0 EPA United State Environmental microns in size

Protection Agency PM2.5 particulate matter less than 2.5 EU emissions unit microns in size FCAA Federal Clean Air Act PSD Prevention of Significant GHG greenhouse gas Deterioration gr/dscf grains per dry standard cubic feet PSEL Plant Site Emission Limit HAP hazardous air pollutant so, sulfur dioxide ID identification code ST source test I&M inspection and maintenance VE visible emissions MB material balance VMT vehicle mile traveled Mlb 1000 pounds voc volatile organic compound MM million

Revised l/26/16

Review Report/Permit No.: 24-0142-TV -01 Application number: 28028

Page 4 of 13

INTRODUCTION

I. The proposed permit is a new Oregon Title V operating permit. R&M Fiberglass was issued a Standard Air Contaminant Discharge Permit (ACDP) on January 24, 2014, due to a facility expansion and an increase in hazardous air pollutants (HAP) emissions. This increase in HAP emissions required the facility to obtain the Standard ACDP and apply for an Oregon Title V operating permit within one year after issuance of the Standard ACDP.

2. In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the same as the legal basis. However, when the regulation is not specific and only provides general requirements, this review report is used to provide a more thorough explanation of the factual basis for the draft permit conditions.

PERMITTEE IDENTIFICATION

3. R&M Fiberglass owns and operates a fiberglass manufacturing facility at 7095 Third Street in Turner, Oregon. The facility was built in 1979 and manufactures and coats fiberglass parts for bus conversions, trailers and specialty applications.

FACILITY DESCRIPTION

4. The production process begins at the Prep/Pull station, located just outside of B2 area of Building B, where the molds are cleaned and prepped with a common wax and, on occasion, a non-HAP containing mold release agent. The prepared mold is then manually moved on casters into the Gel-Coat Station, located in the B2 area of Building B. Gel-Coat is then applied to the mold using an airless air assisted atomized spray gun connected to a 55-gallon drum, 5-gallon bucket or canister of gel-coat. After the gel-coat is applied, it is allowed to cure for I to 2 hours in the rear of the B2 area. Once the gel-coat has cured, the mold is manually moved to the Lamination station located in the front-center of the B2 area. The mold is then laminated with resin and fiber using a mechanical, air-assisted spray gun with a device attached to chop uncut glass fiber into predetetmined lengths and project the fibers into the resin stream. In the same step of the process, the resin is mixed with a catalyst mixture. The catalyst mixture is pumped directly from a source located on the lamination gun's assembly. Once the appropriate thickness of fiberglass by weight and percent resin is attained, the laminated mold is manually rolled by production crew with bristle rollers to remove any air and fill any voids in the mold that may have occuned. The bristle rollers are cleaned with acetone to prevent resin build up. Upon curing, the mold is moved out of area B2 and into area B I, where it is trimmed and polished, then placed in racks or crated for shipping.

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

5. The emissions units at this facility are the following:

5.a. Gel Coat I (Emission Unit GCI)

Gel coat and resin are applied to large and common parts at GC!. GCl emits VOC, HAP, and PM. These emissions are routed through FIL-l, a fabric filter desigued to provide 97% control efficiency for PM emissions.

5.b. Pressure Pot I (Emission Unit PPl)

Revised 1126/16

Gel coat and resin are applied to miscellaneous parts and molds at PPl. PPl emits VOC, HAP, audPM. These emissions are routed through FIL-l, a fabric filter desigued to provide 97% control efficiency for PM emissions.

S.c. Laminating I (Emission Unit LAM!)

Review Report/Pmmit No.: 24-0142-TV -0 I Application number: 28028

PageS ofl3

Resin and catalyst chemicals are applied at this unit, which emits VOC, HAP, and PM. These emissions are routed through FIL-l, a fabric filter designed to provide 97% control efficiency for PM emissions.

S.d. Aggregate Insignificant (Emission Unit AI)

s.d.i. Post-control GCI, PPI, and LAM! emissions (stack emissions downstream ofthe particulate filter FIL-l) of PM, PM10, and PM25

S.d.ii. Catalyst usage: VOC (methyl ethyl ketone or MEK) emissions

S.d.iii. Mold preparation: uncontrolled VOC (styrene and MEK) emissions from wax and wax remover application

S.d.iv. Grinding area: PM, PM10 and PM25 emissions from grinding and trimming of parts after they are removed from molds; these emissions are also routed to the FIL-l control system, and stack emissions from the processes are insignificant

S.d.v. Natural gas usage: VOC uncontrolled combustion emissions from heating equipment

S.d.vi. Miscellaneous VOC emissions fi·om the handling of paints, glues, and adhesives used in the processes, as well as wastes generated by the processes

6. Categorically insignificant activities include the following:

• Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or less than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human Service's Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year

• Evaporative and tail pipe emissions from on-site motor vehicle operation • Natural gas and propane burning equipment rated at less than or equal to 2.0 million Btu!hr • Office activities • Janitorial activities • Groundskeeping activities including, but not limited to building painting and road and parking lot

maintenance • On-site laundry activities • Instmment calibration • Maintenance and repair shop • Air cooling or ventilating equipment not designed to remove air contaminants generated by or released

from associated equipment • Temporary construction activities • Warehouse activities • Accidental fires • Air vents from air compressors • Air purification systems • Fire suppression • Routine maintenance, repair, and replacement such as anticipated activities most often associated with and

performed during regularly scheduled equipment outages to maintain a plant and its equipment in good operating condition, including but not limited to steam cleaning, abrasive use, and woodworking

Revised 1126/16


Page 6 of13

• Electric motors • Fire suppression and training • Paved roads aud paved parking lots within an urban growth boundary • Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except for those sources

that have processes or activities that contribute to the deposition and entrainment of hazardous air pollutants from surface soils

• Health, safety, and emergency response activities

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING

Oregon Administrative Rules (OAR)

7. The following Chapter 340 Oregon Administrative Rules that have specific requirements (e.g., emissions limits or standards, monitoring, recordkeeping, or reporting requirements) have been determined to be applicable to this facility. The "Oregon Title V Monitoring and Testing Guidauce" document was used to determine the frequency of inspection and maintenance schedules and testing requirements.

7.a. Division 208-0110(4)- Visible Emissions: The 20% opacity limit applies to all emissions units and activities at the facility, including the categorically insignificant activities.

The source is required to maintain a complaint log for any visible emissions complaints. The permittee shall maintain records of all complaints and corrective actions.

7.b. Division 208-0210: Fugitive Emissions Since this facility is located in a special control area, the requirement to minimize fugitive emissions by taking preventative measures applies. Compliance wiii be demonstrated by maintaining a complaint log for any excess fugitive dust emission complaints.

7.c. Division 208-0300- Nuisance Control Requirements: The source is required to immediately investigate any air quality nuisance complaints and to respond to the complainant within 24 hours. A record is to be maintained of complaints received, investigation results, and actions taken.

7 .d. Division 208-0450 - Pmticle Faiiout Limitations: The source is required to immediately investigate any pmticulate matter faiiout complaint and respond back to the complainant within 24 hours. A record is to be maintained of complaints received, investigation results, and actions taken.

7.e. Division 222-0020- Stationary Source Plant Site Emission Limits: Plant Site Emission Limits are required. The PSEL is being established on a plant-side basis with annual limits for all poiiutants above the de minimis level in accordance with DEQ rules.

7.f. Division 226-021 OCllCb)- Grain Loading- non-fuel burning equipment The 0.14 gr/dscfparticulate matter emission limit applies to ail non-fugitive emissions units constructed at this facility.

7.g. Division 228-0210(2)(b)- Grain Loading -fuel burning equipment

Revised 1126116

The 0.14 gr/dscf@ 12% C02 or 50% excess air for fuel burning equipment applies to ail fuel burning devices. This facility has smaii categorically insignificant space heaters.

Review Report/Permit No.: 24-0142-TV -01 Application nnmber: 2802S

Page 7 of 13

7.h. Insignificant activities As identified earlier in this Review Report, this facility has insignificant emissions nnits (IEUs) that include categorically insignificant activities and aggregate insignificant emissions, as defmed in OAR 340-200-0020. For the most part, the standards that apply to lEUs are for opacity (20% limit) and particulate matter (0.14 gr/dscf limit). The DEQ does not consider it likely that IE Us could exceed an applicable emissions limit or standard because IEUs are generally equipment or activities that do not have any emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions. Since there are no controls, no visible emissions, and the emissions are less than one ton per year, the DEQ does not believe that monitoring, recordkeeping, or reporting is necessary for assuring compliance with the standards.

Federal Requirements

S. The following federal requirements have been reviewed and those that apply, or do not apply to this source are noted as follows:

S.a. Accidental Release ( 40 CFR Part 6Sl The facility is not subject to this rule at this time.

8.b. NESHAP Standards [40 CFR Part 63, Subpart WWWW standards §63.5780-§63.5935 and OAR, Division 244-0220 (bbbb)]

On 4/21/03 (amended at 70 FR 50129, Aug. 25, 2005, and April20, 2006), EPA issued final NESHAP standards for HAP emissions from reinforced plastic composite production operations. R&M Fiberglass is a major source of HAP and is subject to this rule. The detailed emission limits and standards are outlined in the permit and have incorporated the latest revision to the standards. Updated Tables from the 2005 rule revision are included in the permit. Compliance with the emission limits and operating practices must be certified semi-annually. The facility uses the compliant material option that ensures each resin as applied meets the emission limits specified in the rule. Existing area sources that increase their HAP emissions or their potential to emit such that they become a major source of HAP must be in compliance within 3 years of the date they become a major source. R&M Fiberglass is required to demonstrate initial compliance with the rule by January 24, 2017.

The facility is an existing source as they were constructed in 1979.

S.c. New Source Perfmmance Standards (40 CFR Part 60) There are no sources at this facility for which New Source Performance Standards (NSPS) have been promulgated.

S.d. New Source Review (NSR) This source is located in an attainment area for all pollutants and is not currently subject to federal regulations for NSR.

S.e. Prevention of Significant Deterioration (PSD) This source is not currently subject to federal regulations for PSD.

8.f. Compliance Assurance Monitoring (CAM) Rule

Revised 1/26/16

This source is subject to the federal regulations of the CAM rule because the facility must have a Title V permit. Since the MACT standards are applicable to the facility, those standards already incmporate CAM if a control device were to be used. However, since the facility is not using a control device for control of HAP, CAM does not apply to any emission units.

Review Repmi/PermitNo.: 24-0142-TV-01 Application number: 28028

Page 8 ofl3

PLANT SITE EMISSION LIMITS

9. Proposed plant site emission limits, components oftbe PSEL, and an analysis of significant emission rates increases are provided below. At the sources request, the proposed PSEL for VOC is the generic VOC PSEL of 39 tons per year. Emission calculations for individual devices and emission units are found in Appendix 1.

10. The Plant Site Emission Limits are as follows:

Baseline Plant Site Emission Limit (PSEL) Emission Netting Basis Previous PSEL

Rate Previous Proposed PSEL Proposed PSEL Increase Pollutant (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) PM 0 0 0 NA de minimis 0 PM10 0 0 0 NA de minimis 0 PM25 0 0 0 NA de minimis 0 co 0 0 0 NA de minimis 0 NOx 0 0 0 NA de minimis 0 so, 0 0 0 NA de minimis 0 voc 0 0 0 39 39 0 GHG(C02e) 0 0 0 NA de minimis 0

IO.a. There is no baseline emission rate because the facility was not in operation during the baseline period.

IO.b. The netting basis is zero in accordance with OAR 340-222-0046(2)(c)(B). lO.c. The proposed PSEL for VOC is equal to the Generic PSEL in accordance with OAR 340-222-

0040(1). IO.d. No PSELs are being established for PM, PM10, PM2.s. CO, NOx, S02, or GHG as the potential

emissions of theses pollutants are all less than the Department's de minimis levels in OAR 340-200-0020(39).

I O.e. The PSEL is a federally enforceable limit on the potential to emit.

SIGNIFICANT EMISSION RATE

I 1. The proposed VOC Plant Site Emission Limit is less than the Netting Basis plus the significant emission rate, thus no further air quality analysis is required.

Increase above the netting Netting Basis Proposed PSEL basis Significant Emissions Rate (SER)

(tons/yr) (tons/yr) (tons/yr) (tons/yr)

0 39 39 40

HAZARDOUS AIR POLLUTANTS

12. A major source is a facility that has the potential to emit 10 tons/yr or more of any single HAP or 25 tons/yr or more of combined HAPs. This source became major source of hazardous air pollutants upon issuance of the Standard ACDP permit with a PTE established above Title V thresholds. Establishing the VOC PSEL at 39 tons/year ofVOC, with the majority of the sources VOC emissions as styrene, the source's potential to emit is greater than 10 tons/yr of an individual HAP. The HAP emissions detail is provided in Attachment 1. Provided below is a summary of the HAP emissions.

Revised 1/26/16

Hazardous Air Pollutant

Cobalt (non-VOC)

Methyl Methacrylate

Styrene

Total


Page 9 ofl3

Potential to Emit (tons/year)

0.24

2.20

10.80

13.24

MONITORING, RECORDKEEPING AND REPORTING REQUIREMENTS

13. FACILITY WIDE COMPLIANCE MONITORING REQUIREMENTS

A log of complaints will be used to monitor for excess fugitive emissions, air quality nuisance conditions, and the particulate fallout size standard. The permittee shall maintain a log recording all written complaints, or complaints received via telephone or in person by tbe responsible official or a designated appointee, that specifically refer to a complaint of fugitive dust, odor, or particulate fallout nuisance condition. The permittee will also record the permittee's actions to investigate, make a determination as to the validity of the complaint, and resolve the nuisance problem, if possible, within 24 hours of receiving the complaint. The log will be submitted to the DEQ with each annual report.

GENERAL BACKGROUND INFORMATION

14. R&M Fiberglass submitted a Standard ACDP permit application on July 17,2013 and was issued a Standard ACDP on January 24, 2014 due to a facility expansion and an increase in hazardous air pollutants (HAP). Because this is an existing major source as of January 24, 2014, the compliance date for the rule is January 24, 2017. The facility submitted a thnely Title V permit application on January 23,2015.

This facility is outside the SICATS boundary. The source is located in an attainment area for all pollutants.

The source is not located within 10 kilometers of any Class I Air Quality Protection Area.

COMPLIANCE HISTORY

15. The facility was last inspected on June 5, 2013. One Pre-Enforcement Notice (PE-SLM-AQ-2013-0096) was issued on June 5, 2013, and revised on September 16,2013, for failure to submit a permit application prior to becoming subject to ACDP permitting. The source became subject to permitting requirements on June 1, 2013 and submitted their permit application on July 12, 2013. The facility was issued a Notice of Civil Penalty and Order, AQ/AC-WR-13-076, on October 4, 2013. This penalty was resolved on September 19,2013.

SOURCE TEST RESULTS

16. No source testing required at tbis time.

Revised 1126116

PUBLIC NOTICE


Page 10 of 13

This permit was put on public notice fi·om December 10,2015 to Janmuy 15,2016. DEQ received one public comment expressing opposition to the expansion ofR&M Fiberglass. Expansion ofthe facility is a land use issue, which is addressed by city planning authorities and controlled through local zoning regulations. The City of Turner planning authority is responsible for monitoring and certifying compliance with conditions contained in the Land Use Compatibility Statement (LUCS). Due to an increase in production, the source triggered the threshold for an air permit. The air permit contains requirements that the source monitor emissions monthly and report compliance status with all conditions in the air permit to DEQ semi-annually. DEQ will also conduct on-site inspections. The facility is in compliance with all State and Federal applicable rules and has met all the requirements for issuance of a permit. A proposed permit was sent to EPA for 45-day on February 15, 2016. EPA had no objection to the issuance of this permit.

Revised 1126/16


Page II of 13

Attachment 1

EMISSIONS DETAIL SHEETS

1-TabteD-1. Su~ma~Tabl~ I I I I I I I I i -- --- ---- --- -.. --------- -- --. ----- --i I I i i i I I

I Cobalt Methyl Ethyl Methyl Compounds l{etone Methacrylate Styrene voc

CAS No. 7440-48-4 78-93-3 80-62-6 100-42,5 --VOC? N y y y y

HAP? y N y y --Opell_M_oldingEmission_s (tpy) 0.24 1.07 2.20 10.80 14.08

Grindin£ Emissions (tp_v) -- -- -- -- --Total Emissions a (tp_y) 0.24 1.07 2.20 10.80 14.08

,I I I iCurrentP'I_'E assumes a throughput increase of: j 32% I I t

I This throug-hput increase was permitted in the site's initial ACDP action. I ! I i

Table D-7. Emissions from Sanding, Grinding, Sawing, and Buffing ........ . ... -------- T ---------

Potential Gel Coat Throughput (lb/yr)

Potential Resin Throughput (lb/yr)

a Losses from safi_cling, grinding! ~awing, and buffi!lg a_!)~ll:~ed to be: i b Cont~ol efficienc -from ~iltra-tion s stem assumed to ~e: I

Revised 1126/16

98,372

366,300

112,000

576,672

5,767

173

0.09

i 1

HAP

----y

13.25

--13.25

I I

llo/o

[97%

I I I

PM/PMto PM2.s

-- ---- ---- --

0.06 0.03

0.09 --0.15 0,03

I I

•


Page 12 of 13

Table D-6. Emissions from Open Molding i '

Uncaptured Captured PM Uncontrolled PM Fugitive PM Emissions from Total PM Total PMts

Throughput o/o Solids Emissions • Emissions b Filter f Stackc Emissions d Emissions e

ProductTvue Product flbi~ri fwt%1 flb/vrl flb/vrl flbivrl flbMl flb/vrl

Resins" Ash DX Resin

Cor Resin

234,204 66.38% 1,554.64 15.55 46,17 61.72 30.86

110,188 69.50% 765,81 7.66 22.74 30.40 15.20

Ash Hetron Resin 2,677 69.00% 18.4:7 0.18 0,55 0)3 0.37

r--------b·-~--t''-';''-"'£!BI,_oc,k,Re,,l,nr --------------~+--"'"''·""'-''~f---''"''"-·':c4~ ____________ .clr:r4!c7·ce58,_--t~~'"·4"B'- 4.38 5.86 2.93 Gel Coats VAL White Pilon 4,396 65,00% 28.57 0.29 0,85 1.13 0.57

CCPWhitFilon 33,194 68,82% 228.43 2.28 6.78 9.07 4.53

CCPDoveGrayMC 16,595 67.87% 112.64 1.13 3.35 4.47 2.24

CCPCharcoa!MC 16,062 68,00% 109.23 1.09 3.24 4.34 2.17

CCP Black ISO 3,280 57.87% 18.98 0.19 0.56 0.75 0.38

CCP FireblockGelcoat 3,274 79.27% 25.95 0,26 0.77 1.03 0.52

HKR Bronze Revolution 3,300 70.00% 23.10 0,23 0.69 0,92 0.46

VAL Black 2,376 60,00% 14.26 0,14 0.42 0.57 0,28

CCPVelmontGray 1,885 100.00% 18.85 0.19 0.56 0.75 0.37

CCP Cool Vanilla MC 2,772 69.57% 19.28 0.19 0.57 0.77 0,38

CCP BlackEXTMC [No Liner) 2,105 67.50% 14.21 0,14 0.42 0.56 0,28

CCP Slate M_C 702 68.80% 4,83 0.05 0.14 0.19 0.10

CCPWhiteHAP33 750 68.35% 5.12 0.05 0,15 0.20 0.10

CCPBlackMC 709 68.1~% 4,83 0.05 0.14 0.19 0.10

VAL ValmontGray 444 70.00% 3,10 0.03 0.09 0.12 0.06

VAL Axtec LE Cool \'?nil!a 396 65~QO% 2.57 0.03 0.08 0.10 0.05

CCp Dove Gray HAP37 Hi Gloss 726 63.58% 4.62 0.05 0.14 0.18 0.09

CCPCharcoa\ArmorcoatMC 700 63.16% 4.42 0.04 0,13 0.18 0.09

CCP Cool Vanilla HAP37 693 ~5.06% •t51 0.05 0.13 0.18 0.09

CCP l;'{hite Base 66 70.~6% 0.46 0.00 0.01 0.02 0.01

N~C-~h<!r~(Ja!Gr_ayL~wVOC 700 62.00% 4.34 0,04 __ 0.~3 0.17 0.09

NAC_~!ackLowVOC 700 ~~0QO% 4.34 0.04 0.13 0.17 0.09

NAC Integrity Black 59 68.00% 0.40 0,00 0.01 0.02 0,01

Styrene Monomer Stablized 54 0.00% 0.00 _ 0,00 0.00 0.00 0.00

DBF Putty 1,426 70.00% 9.98 0.10 0.30 0.40 0.20

VALPutty 594 70.00% 4.16 0,04 0.12 0.17 0.08

OrangeTool 178 ~-q8% 0.97 0,01 0.03 0.04 0.02

9.1:~-~!I}~<A .................................. ~~-~ ........... --~~}§9-:'~ ... . _ ......... h·.?Z ......... ....... --~_.QL ................ .Q:9.1 .................. R~~-~---- ............ . 9.-Q?_ ....... . Catalysts MEKP-9H 4,741 70.00% 33.19 Q,33 0.99 1.32 0.66

DSO 1,764 70.00% 12.34 0.12 0.37 0.49 0.25

L50A 655 70.00% 4,58 0.05 0,14 0.18 0.09

TOTALS 471,831 -- 3,210,04 32.10 95.34 127.44 63.72

'The following factors in wt% ar~ applied above W calrulate PM, PM1o. and PM~s emissions from resin use.

!Deposition Ertldency{De]: , 99% - ' '

' 'Spray Booth Capture Effidency (Cae): 99%

! !'!_Iter Control Efficiency (Coe): 97%

Uncontrolled PM emissions are the pnxluctofthroughput(lbfyr),% solids, and (100%-% deposition efficiency).

b. Uncapture_d fugitive PM emissions are the product of uncontrolled PM emissiens (100% ·% caJJture efficiency).

'·captured PM emlssioos from FIL-l stack are the product of uncontrolled PM emi_sslons,% capture efflctency,aud (lOO'Ij.-% oontrol efficiency).

d,Total PM emissions ore the sum of the ~ncaJltured fugitive emissions and the emissions from the FIL-l stack

•. TotalPM1s emissions are estimated using the following PM1.s/PM1o ratio:

·, PM1.s Fraction of PM10: I, 50%

Revised 1126116

...

' I Table D-5. E_~~~!L'lfi:O_In_ Open Molding I ........... .

I ___ ) __ _

CJlSNo.

V~C?

HAP?

ProductType Product

.. .

Throughput (lb/V<'l

Resins • Ash DX Resin

Co_rRe~in

n.1._2o4 ~lO,lf!_B

2,677

Gel Coats b.<

A~~ Hetron R~~ln

f.~~~~!~~g~~!!~--------- ... )2 .. ?}! .... VAL Whlt(l Filon

CCP Whit Fi!on

CCP Dove G~ay ~_c

CCP Charcoal MC

CCP Bjac_!dSO

-- 4,_3_'!6_

_____________ n,!?_1 16,595

16,062

~,?_80

CC_P Fir!!lJI_()~~-{!e_l_c_o~!

HKR Bronze Revolution

VAL Black

CCP Yel_lll_on_t Gray_ __

_ _ __ _ _ <;:~f ~.291Y!!~_li!l~M~q::~_B_l?.~k E_x:r MC (No Linerl

CCP Sll!teMC

CCP White HAP33

<;:~rl!I_a_s\<_11~-

IJA~ l{a_!_Jl)O!l_~_GrlJy

VAL Axtec LE Cool Vanilla

CCP Dove Gray HAP37 Hi Gloss

CCP Cha_rs:Qa! A_r!Jl-Qrsoat MC

CC_P C!JQ! Van!!!_ a_ Ht-~~?

CCP White Base

NAC Charcoal Gray Low VOC

NAPtl<!_c~~~~yo~

~J_\G_IJ1{¥grl~Bl~_ck_

~tyrene: Monomer Stablized

DBF Putty

Y~V~_tty

{)rl!!JR~T(Iol

Green Too\

1 _____ 1P1_

3,~00

2,37~

1,11_8_5_ -

-~,?_7_2_ --2_,105

702

750

709

_444-

396 -

!26

700

~-~~ -

66

700

_709

- !1_9 54

1,426

,'i_94- --

178 238

Catalysts <>l MEKP-9H

D?O

L50A

4,741

1,_Z64

655

TOTALS 471831

Cobalt Comu.ounds

Methyl Ethyl Ketone

_74-4,1)_·411·4 7B~?_N _

N y y N

Emissions Emissions [lb/\c) (lb/V<')

~?7,36 9-Q_Q O.OQ 0.00

5.3? 0.00

.. • •• 9.-.QQ .... ............. .Q:9.9 ... .. 1~_-26 O.OQ

!Q~}_3 _o_,Q_Q 25.7? 0.00

58.79 0.00

4,_~~ Q,OQ

- - __ Q_,_~2- _Q,IJ_Q 0.00 0.00

23.76 0.00

0.00 _O,QQ

},§_~ Q,Q_Q_

~,p _q.Qo 1.10 0.00

1.15 0.00

_:!}!§ __ O,O_Q

1_..44 _Q,QQ 3.96 0.00

1.29 0.00

_2,8_0l 0,90

J.F _0_,9_9 0.06 0.00

0.00 0.00

O.OQ Q,QO __

_Q,O_Q -: -- _Q,QQ_ 0.00 0.00

3.56

5_,~4

9-!7 2.28

0.00

0.0_0

0.00

489

0.00

_Q,Q_Q 0.00

0.00

1,4_22.43

~2_9.Q§

196.42

21411


Page 13 of 13

Methyl Metl1acrvlate

8Q:§_~_:§

y

y

Emissions (lb/V<')

Q,QQ 0.00

0.00

.... 9.-.QQ _1_§1-_.84

--- __ !_,?_4_2_,~~-871.24

843.24

_!23.Q~

HLU 74.25

o,oo

!WQ _H?_._5} __

94.74

36.87

28.12

~1~~Q

1_~-~-~ 14.85

0.00

0~99 O,O_Q ___ _

0.00

26.24

~_6,2_4

D_,?9 0.00

0.00

Q_~oo

?J:S 8.91

0.00

Q,OO

0.00

4403

Stvrene

!_OQ_:47·5 y

y

Emissions (lb/V<')

M~~.53

3_,~11,69

88.75

. .. 1Z~,~~ 1~8.57

_2L6},_~l

1,393.65

1,344.69

1~5./!3

~2_Q,5j_

2119.58

381,35

o,oo ~J!:!_.J2- --182.22

56.97

66.16

5_~._?4- ---

~-6~_0_~ 38.61

??.113

9§.20

-~4,?_9-6.40

75.21

7_5,~_1

_5_.?_~

12.62

53.89

---- 2_2_,4-~ _31~27

43.48

0.00

Q,QO-

0.00

21608

TotalVOC

y

Emissions (lb/V<')

~.665_,5_3

- 3!~11.69

88.75

... ±?.~:~.L ~-~-3.4-1

Total HAP

y

Emissions

(lb/v>")

8,852.90

3,911.69

94.11

........ 1Z?.,~~-· _§3?.36

-- 1JQ_~2_?_ 1---- _4,5_09.49 2,264.89 - 2,290.61

2,187.93 2,246.72

5_~8,§.1 §Q3.52

?_~_7,_8_§

363.83

381.35

MO

~-!iH~--276.96

~3.83

94.27

n,?~

5_?,??

53.46

99.83

96.20

-- 114.69

6.40

101.44

101_A:4

-~-6-~ 12.62

53.89

2_2.45

-~6.62

52.39

1,422.43

_5_29,Q6

196.42

211159

- _3@,2_6

363.83

4Q5.11

9,90

-- _)_§!~_,!_!

280.08

94-.93

95.43

n,IQ __ --- - 57.10

57.42

101.12

2?-9_3

~6.06

6.46

101.44

!_01.44

6.68

12.62

57.45

_2_8J9

36.79

54.67

0.00

o.o__o 0.00

26 500

"jspectated emissions from resins are calrulated using 100% of the throughput multiplied by the wt% of the compound in the resin, with the ex'eption ofstyrene emissions. Styrene emhsions are calru!ated using Le!n~~iO!l_factors in T~ble Jl:1, ~tet)lyl !_lle~-!m~late_~llte_n_tin !esi!ls_is negligi~l_e, __ _ __ _ __

'i' Spectated emissions of cobalt and methyl ethyl ketone from gel coats are calru!ated using 100% of the throughput multiplied by the wt% of the compound in tha resin. Spectated emissions of methyl methacrylate and styrene are calculated using emission factors in Table D-4. When a gel goat does not contain methyl methacrylate, it is generally assumed that use of the gel coat does not generate methyl methacrylate

___ ~~~~j~sj_~n_~. _ _a_!!!l_ no_ ~!l_l_~sl_o_n_f_a_c~o!l_s g~!!e!'!!_e_d_ ~ u~_c_d, ___ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ ,' i If a styrene or methyl methacrylate emission factor is not available in Table D-4 for a specific poDutant and a specific resin/gel coat/catalyst, then emissions arc assumed to be zero for that pollutant and product '"Jhis js_the_ case_oJJly for polJu!E~Jl!S t~a_tare not p~cs_entin the spcci~tion of the resin/ ge_l!)lat { catalys~

dis ectated emissions from catalvsts arecalrulated usin 100% of the throu h ut mul · lied b thewt% of the com ound in the catalvst Meth I metha late and s ene content in cata sts is ne II "b!e.

Revised 1/26/16

Documents

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY … · State of Oregon Department of Environmental Quality ... CMS continuous monitoring system OAR ... these emissions are also routed