AIR POLLUTION CONTROL PERMIT · 2012-09-21 · Air Pollution Control Division Waterbury, Vermont...

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DEC #RU96-0301

State of Vermont Agency of Natural Resources

Department of Environmental Conservation

Air Pollution Control Division Waterbury, Vermont

AIR POLLUTION CONTROL PERMIT

Operator:

Source:

Date Issued: August 14, 1991i

Ellison Surface Technologies, Inc. I no Anderson Bl vel. Hebron, KY 41 04:'1

Arc Plasma Coating Facility Ellison Surface Technologies - Rutland Division Airport Industrial Park North Clarendon, VT

FINDINGS OF FACT

#AP-96-021

(I) On July 17, 1996, Ellison Surface Technologies, Incorporated (hereinafter "EST" or operator) submitted plans and specifications to the Agency of Natural Resources, Department of Environmental Consetovation, Air Polltition Control Division (hereinafter 1

"Agency") for approval to construct and operate a new surface coating facility. The proposed facility is to be located in the town of North Clarendon, Vermont.

(2) The new facility will coat areas of turbine engine components using arc plasma spray metal coating technology. The facility will consist of three grit blasters, three arc plasma spray booths, drying ovens, space heating equipment, and facilities to clean and lubricate materials.

(3) The surface finishing and coating operations are classified as sources of air contaminants under Section 5-40 I (9) of the Vermont Air Pollution Control Regulations (hereinafter "Regulations"). Therefore, pursuant to 10 V.S.A §551i, the owner or operator of a source

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is required to obtain approval from the Agency in the form of an Air Pollution Control Permit prior to the construction, installation, operation or modification of the source.

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On August I, 1996, the Agency detennined that a complete application had been received concerning the proposed project.

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The total allowable emissions from the proposed project are to be less than lO tons per year. Furthermore, no single air contaminant is emitted at rates el(cceding thresholds which would cause this project to be classified as a major source.

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Pursuant to 10 V.S.A. §556, the Agency is not required to provide an opportunity for public comment regarding applications for sources with allowable emissions of less than 10 tons per year of all air contaminants. In consideration of the factors listed in lO V.S.A. §556, an opportunity for public comment was not provided for this application.

I i Based on the above findings of fact, the Agency's review of the proposed project, and subject to l the following permit conditions, it is determined that the proposed surface finishing and coating 1 operation will meet all applicable state and federal air pollution control regulations. Therefore, ! pursuant to I 0 V.S.A. §556, as amended, the Agency hereby issues a permit approving the i construction and operation of EST's proposed facility, as described in the above findings of fact, . subject to the following:

i! PERMIT CONDITIONS

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- Construction & Equipment Specification -

(I) EST shall construct and operate its arc-plasma coating facility according to the plans and specifications submitted in conjunction with its application to the Agency on July 17, 1996 and in accordance with the conditions set forth herein.

(2) EST shall vent the exhaust gases from the three arc-plasma coating systems through a stack or stacks with an outlet greater than twenty-five (25) feet above grade and at least four (4) feet above any roofline or structure that may significantly interfere with the dispersion of the exhaust gases. Furthermore, the stack shall be vertical and shall not be equipped with any device that would obstruct the upward discharge of the exhaust gases.

' (3) The coating systems shall be equipped with emissions control devices designed to capture and remove pmticulate matter greater than 5 microns at an efficiency of at least 99.999%. This control equipment shall be operational whenever the coating system is operational and shall be maintained in good working order according to the manufacture's specifications and recommendations.

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- Odors & Visible Emissions -

(4) Emissions of visible air contaminants from any vent or stack shall not exceed 20% opacity for more than a period or periods aggregating six (6) minutes in any hour. At no time shall visible emissions exceed 60% opacity.

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EST shall take reasonable precautions at all times to prevent the discharge of objectionable odors beyond the property lines of the facility.

- Record Keeping & Reporting -I

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(6) EST shall notify the Agency in writing of the date of initial start-up of the arc-plasma coating operations to produce product for sale within fifteen ( 15) days after such date.

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EST shall notify the Agency in writing of any proposed physical or operational change at the facility that may increase the emission rate of any air contaminant to the ambient air. If the Agency determines that a permit amendment is required, a new application and the appropriate application fcc shall be submitted. The permit amendment shall be issued before commencing any such change.

EST shall maintain a log book recording the dates and findings or inspections and description of any service or replacement conducted on or conceming the coating system's aii" pollution control equipment.

All records, reports, and notifications required to be submitted to the Agency by this Permit shall be submitted to:

Fieltl Services Section Air Pollution Control Division D.E.C., Agency of Natural Resources 103 South lvfain Street, Bldg. J South Waterbury, Vermont 056 71-0402

Said records shall be made available to the Agency upon request and shall be maimained for a period of rive years from date of record.

- General Conditions -

These Permit conditions may be modified for cause upon the riling of a written request with the Secretary .of the Agency (hereinafter "Secretary") or upon the Secretary's own motion. Any modification shall be granted only with the written approval of the Secretary. lf the Secretary determines that modification is appropriate, only the conditions subject to modification shall be reopened. The filing of a request for modification does not stay any tcnns or conditions of this Permit. The Secretary may provide opportunity for public comment on any proposed moclit1cation of these conditions. If public comments are solicited, the Secretary shall follow the procedures set forth in lO V.S.A. Section 556.

This Permit ·does not convey any property rights of any sort or any exclusive privilege, nor does it authorize any injury to private property or any invasion of personal rights.

By acceptance of this Permit, the owner and operator agree to allow representatives of the State or Vennont access to the properties covered by the Permit, at reasonable times, to ascertain compliance with Vennont environmental and health statutes and regulations and with this Permit.

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All data, plans, specifications, analyses and other information submitted or caused to be submitted to the Agency as part of the application for this Permit or an amendment to this Permit shall be complete and truthful. Any such submission that is false or misleading shall be sufficient grounds for denial or revocation of this Permit, and may result in a fine and/or imprisonment under the authority of Vermont statutes.

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I 1 c 15) The operator of a source that emits more than five tons of any and all air contaminants

per year shall register the source with the Secretary, and shall renew such registration annually. Each day of operating a source that is subject to registration without a valid, current registration shall constitute a separate violation and subject the operator to a civil penalty not to exceed $100.00 per violation. The registration process shall follow the procedures set forth in Subchapter VIII of the Air Pollution Control Regulations. These procedures are summarized as follows: By February I of each year, the operator of each source subject to registration shall submit to the Air Pollution Control Officer source emissions data for the preceding year and any other information required to determine the appropriate registration fee; By May 15 of each year, the operator of each source subject to registration shall pay to the Air Pollution control Officer the appropriate fee, if any.

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( 16) These Permit conditions shall be binding upon and enforceable against the current owner and operator and all subsequent owners and operators of the source.

• ' ( 17) The provisions of this Permit are severable. If any provision of this Permit, or its application to any person, entity, or circumstance is held invalid, illegal, or unenforceable by court of competent jurisdiction, the invalidity shall not apply to any other portion of this Permit which can be given effect without the invalid provision or application thereof.

The Agency's issuance of this Air Pollution Control Permit relies upon the data, judgement, and other information supplied by the facility owner and/or operator. The Agency makes no assurances that the facility approved herein will meet performance objectives or vendor guarantees supplied to the facility owner and/or operator. It is the sole responsibility of the

, owner and/or operator of the facility to operate the facility in accordance with the conditions i herein and with all applicable state and federal standards and regulations. I

Dated this 11(-z)l, day of ----'-'tUt-=;;;~1""""'"'-"---------' 19'J6, 111 the town of ' Waterbury, county of Washington, sta&' of Vermont.

I i Agency of Natural Resources

I i William Brierley, Commissioner i Department of Environmental Conservation

II ~ ,/ . i!By:tf.i/~~· li i

MCB/mb

Richard A Valentinetti, Director Air Pollution Control Division

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VERMONT AGENCY OF NATURAL RESOURCES Department of Environmental Conservation

Air Pollution Control Division

TECHNICAL ANALYSIS OF AN AIR CONTAMINANT SOURCE

#AP-96-021 PIN#-RU96-0301

August 14, 1996

Prepared By: Mark Bannon, Environmental Engineer

APPLICANT:

SOURCE:

CONTACTS:

COUNTY:

AREA DESIGNATION:

UTM COORDINATES:

Ellison Surface Technologies, Inc. 1780 Anderson Blvd. Hebron, KY 41048

Arc Plasma Coating Ellison Surface Technologies - Rutland Division Airport Industrial Park North Clarendon, VT

Mr. Elmer Warnken (606) 586-9300

Rutland

Attainment for PM10, S02, NOx, CO, & Pb Unclassified for ozone

4821 405 m N, "65305 m E - Center of Building

Ellison surface Technologies - Rutland Division #AP-96-021

1.0 Introduction

Ellison Surface Technologies, Incorporated ("EST") has informed the Agency of Natural Resources, Department of Environmental Conservation, Air Pollution Control Division ("Agency"), of its intentions to constmct a new surface coating facility in the Airport Industrial Park located in North Clarendon Vermont. As a result of the proposed construction, EST must obtain approval from the Agency in the form of an Air Pollution Control Permit prior to constructing the facility.

1.1 Administrative Background

On July l, 1996, the Agency held a pre-application meeting with the applicant to discuss the permitting process. EST submitted its application and $500 application review fee on July 17, 1996. The Agency determined the application "administratively" complete on July 18, 1996. EST's application estimated emissions to be under the ten tons per year threshold requiring a public notice or comment period. On August l, 1996, the application was found "technically" complete.

Date application received: Date fees filed: Date of complete application: Future classification of source:

1.2 Project Description

07/17/96 07/17/96 ($500) . 08/01/96 Non-Major

EST is applying for an approval to construct a new facility. The new facility will coat areas of turbine engine components using arc plasma spray metal coating technology. The new facility will be located in an area zoned for industrial activity, a short distance from the Rutland Municipal Airport runway. A location map and building layout are attached in the Appendix.

The facility will consist of three gtit blasters, three arc plasma spray booths, small drying ovens, space heating equipment and facilities to· clean and lubricate materials. EST anticipates two production shifts per day and approximately 10 hours of each automatic spray gun per day for a 5-day work week.

1.3 Process Description

EST's process begins with parts delivered to the receiving department where they are sorted. From the receiving department, they are conveyed to the automatic suction blast station to grit blast the blade roots. Figure I, in the Appendix, describes EST's process t1ow.

Grit Blast

EST is proposing to install three grit blast booths, two of which arc larger automatic types, and

Ellison Surface Technologies - Rutland Division #AP-96-021

the other is a smaller manual version. The purpose of this operation is to roughen the surface and provide an oxide-free surface so that the powder coating will adhere. For the larger automatic booths, the operator will load a rack of blades into the blast cabinet and close the door. A btllton is pressed to initiate the cycle. Six blast nozzles, mounted on the horizontal gun mover, traverse the length of the blade rack etching the blades with grit (96.3% aluminum oxide and 3% titanium oxide). On the return stroke of the gun mover, the blast nozzles are turned off and blow-off nozzles remove residual gtit. The smaller manual booth is similar however, a single part is introduced into a smaller cabinet and manually turned with protective hand inserts. The blast cabinets are to be equipped with internally exhausted dust collectors.

Plasma Coating

Once the part is clean, it is conveyed over to a metal coating system. EST is proposing to install three plasma spray booths; two larger automatic types and one smaller manual booth. The metal coating systems use acoustical spray booths and fabric filter ventilation control systems. The two larger automatic booths are equipped with a robotic arm to snatch, hold, and turn the parts while the part is coated. Dty metal coating powder ( 60% copper, 35% Nickel and 5% Indium: 2% of the fines are less than II microns in size ) is injected into a high velocity inert gas stream heated by an arc plasma system within the spray gun apparatus. The partially molten particles are propelled against the part to be coated. The particles partially melt but do not atomize. They arc deposited as microscopic platelets. Approxima~ely 75% of the coating adheres to the substrate and masking fixtures. The plasma coating processes will vent to fabtic filter dust control systems that exhaust to the ambient air.

Sorting & Cleaning

Once coated, the part is conveyed to a sorting station equipped with a ventilation hood. Some parts may be .selected for further coating, returned for grit blasting or passed on to the cleaning station. The cleaning station uses a wire brush and a cleaning solution (methyl ethyl ketone) to remove excess matetials.

Check, Lube Coating & Bake Ovens

The parts are then quality and tolerance checked. Some parts may receive a dry lubricant coating. This lubricant coating must be heat set which is accomplished in a 500,000 B tu/hr propane fueled drying oven. Off-spec parts are stripped of coating using a nitric acid solution and then reworked.

2.0 Basis of Review

Pursuant to Section 5-401(9) of the Vermont Air Pollution Control Regulations (hereinafter "Regulations"), surface finishing and coating operations are classified as air contaminant sources that may cause or conttibute to air pollution, Therefore, pursuant to Section 5-50 I of the

-Regulations, the installation and operation of EST's arc plasma metal coating systems are subject


to Agency review and approval before construction, installation, and modification.

2.1 Potential Air Contaminant Sources

The Agency has determined that the following processes and equipment have the potential to cause or contribute to air pollution as defined in Section 5-l 0 I (7) of the Regulations:

Table A: Potential Air Contaminant Source

Equipme1it or Process Primary Pollutant(s) ControVOpcl'ating Limit

(3) Arc Plasma Thermal Spray fine particulate matter- trace Torit Downflo 24 Cartridge fabric Coaters elements collector 6,000 SCFM

air to cloth ratio 0.99: I

Part Cleaning volatile org<mic compounds none

Dry Lubricant Api)lication and volatile orgwltc compounds none Curing

Chemical stripping of Defective volatile organic compounds - MEK annual limit 250 MEK Solvent coating

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Two Batch Truck Loading Propane Particulate matter, oxides of none . Ovens (0.5 MMBTU/hr) nitrogen, carbon rnonoxide

r---· One- DevilBiss Roof Mounted Air Particulate maHer. oxides of none

Make-Up Unit (3 MMBTUn1r) nitrogen, carbon monoxide --

2.2 Operating Restrictions Proposed by Applicant

TI1e applicant has proposed to limit solvent (MEK) usage to less th<m 250 gallons per year. This limit, through proper record keeping, is considered enforceable and can be used to estimate emissions from the solvent wipe process.

3.0 Emissions Profile

The quantification and characterization of emissions is necessary to establish the regulatory designation of the proposed new source and consequently the review performed in order to show compliance. Designations for the proposed facility are discussed. Under Section 5-lOI of the Regulations, a major stationary source means a source with allowable emissions of any air contaminant equal to or greater than 50 tons per year (5 tpy for lead). Sources with allowable emissions less than the major source thresholds are considered "non-major" or "minor" stationary sources.

The designation of a statio(lary source is determined by its allowable emissions. A source's allowable emissions are developed using applicable emission standards in the Regulations, existing or proposed permit conditions, and engineering estimates based on the reported

Ellison Surface Technologies ~ Rutland Division #AP-96-021

equipment parameters. If no regulation, enforceable condition, or inherent limit is considered appropriate, then allowable emissions are detennined assuming continuous operation of the statiomuy source (i.e., 8760 hours per year) at maximum capacity.

3.1 Combustion Emissions

The heating system and two ovens emit particulate matter (PM/PM 1o), sulfur dioxide (SO,), oxides of nitrogen (NOx), carbon monoxide (CO), and volatile organic compounds (VOC) through the combustion of propane fuel. Emissions ti·om the two ovens and heater were estimated using factors published by the U.S. EPA in Compilation of Air Pollutant Emission Factors, Volume/: Stationary Point am! Area Sources (4th Edition) Supplement F; AP-42, Office of Air Quality Planning and Standards, RTP, NC. September 1985. "Table 1: Allowable Combustion Emissions" found in the Appendix, describes the calculations and assumptions used in the calculations. "Table B: Combustion Emissions" summarizes the allowable emissions from the two ovens and one space heater.

Table B: Combustion 'Emissions (tpy)

3.2 Ar·c-Piasma Process Emissions

The arc-plasma coating system emits particulate matter. The powder has a typical particle distribution as follows:

%Wt Finer than 88 microns HXJ F~ner than 62 microns 97 Finer than 44 microns ?6 Finer than 31 microns 41 Finer tluin 22 microns 13 Finer than 16 microns 5 Finer than 11 microns 2 Finer than 7.8 microns <I A veragc = 36 microns

EST has proposed controlling particulate matter with fabric filter dust controls estimated by coating system's manufacturer, Progressive Technologies, Inc .. and Torit Products to be 99.999% efficient for particles over 5 miC!·ohs. EST's application estimates approximately 53 lbs of coating is used per day; 75% of the coating adheres to the part; the remainder either falls on the t1oor or is carded to the collection system. Taking into account the control, particle size distribution, and usage, the following calculation is used to derive a lb/hr worst-case emission rate:

[53 lh/day) I (24 hrs/day)* 25%] * [I% uncontrolled + ( 1-0.99999 controlled)]= 0.0055 lh/hr


Based on this estimate, emissions from the arc-plasma system would be less than 50 Ills/yr.

3.3 Solvent and Lubl'ication Process Emissions

Emissions from the solvent wipe, chemical stripping and dry lubrication processes are emitted as volatile organic com pounds and aerosol particulates. EST's application indicates that the total usage of this matelial will be less than 100 gallons per year. "Table C: Solvent & Lubricant Emissions" summarizes expected emissions from these processes.

Table C: Solvent & Lubricant Emissions

propylene glycol 0.009 methyl ethyl ketone 0.3

toluene 0.01 moly-disulfidt'- "' 0.(X)5

n-butyl alcohol 0.004 antimony trioXJde " 0.003

graphite "" 0.002 dibasic lead phosphite * 0.{Xl2

formaldehyde {1.0005 nitric add* -0.05

xylene 0.001 n-butoxyethanol 0.001

as an

Based on the process design proposed in EST's application and unrestricted use of the products assuming 8760 hours per year, allowable emissions of volatile organic compounds arc approximately 1.5 tons per year: particulate matter is 0.5 tons per year.

3.4 Designation of the Future Facility

The size of the proposed facility is designated by its allowable emissions. Future allowable emissions are summarized in Table D, below.

Table D: Futtu·c Allowable Emi.;;:sions (tpy)

Based on the estimated future allowable emissions, as summarized in Table D, the proposed facility is designated as a non-major stationary source.

4.0 Emission Standards Review

The purpose of this section is to identify any pertinent regulatory standards that may limit the operations of the proposed source. This section is not intended to be all encompassing. In addition to identifying pertinent standards, a discussion of the facilities' ability to comply is included. EST's application did not address or review the proposed facility regarding these


standards. Therefore, the analysis is based on the Agency's experience with similar source categories. Compliance shall be verified by the Agency once the source is operating.

4.1 Vermont Air Pollution Control Regulations

The operations at EST may be subject to the following Sections of the Regulations: 5-211, 5-221, 5-231(1) & (3), 5-241, 5-253.13, 5-253.14, 5-802 and 5-1004. Applicability with Section 5-261: Control of Hazardous Air contaminants, shall be discussed in Section 5.0.

Section 5-211(2): This section specifies that emissions of visible air contaminants from any stack or vent at EST may not exceed 20% opacity for a period or periods aggregating to six minutes or more in any hour, and at no time can they exceed 60% opacity. It is unlikely that visible air contaminant~ will be emitted from the process equipment at this facility due to the particle size and nature of the pollutants. In addition, it is expected that no visible emissions above these limits would be emitted from the combustion equipment if they are maintained and operated according to the manufacturer's recommendations.

Section 5-22.lill: This section specifies that the fuel sulfur content used in any fuel buming equipment in Vermont shall not exceed 2 percent by weight. The applicant proposes to comply with this requirement by using propane fuel that inherently contains negligible amounts of sulfur.

Sections 5-23J.(_!J This section of the Regulations regulates the emissions of particulate matter (PM) from the processing operations at EST. Section 5-231 (l) regulates PM emitted from industrial process exhaust vents below the discharge rates identified within Table I: Industrial Process Weight Standards of the Regulations. As discussed in section 3.2, above, the facility is expected to comply with this section by equipping the arc plasma system with a particulate matter control system designed to control emissions 5 microns or greater by at least 99.999%. The Agency will propose a condition in any decision approving this project requiring abatement of particulate matter as described in EST's application.

Section 5-231Ql: This section specifies that a source may not discharge emissions of particulate matter (PM) from burning fossil fuel in fuel burning equipment with a rated heat input of less than 10 MMBTU/hr in excess of 0.5 pounds per hour per million BTU's heat input. It is not expected that particulate matter emissions above this limit would be emitted from the heating plant, so long as it is maintained and operated in accordance with the manufacturer's recommendations.

Section 5-241: This Section specifies that a source may not discharge, cause, suffer, all9w, or permit air contaminants that will be a source of odors or a nuisance to any considerable number of people or to the public. In consideration of the quantities of solvent used at the facility and the use of the proposed dust abatement equipment, the Agency feels that odor concerns are alleviated.

Section 5-253.13: This subsection applies to any miscellaneous metal parts and products coating

Ellison Surface Technologies - Rutla~d Division #AP-96-021

unit, except automobile, light-duty and heavy duty truck refinishing. The emission limits in section 5-253.13 do not apply to any coating unit within a source whose actual emissions without control devices from all miscellaneous metal part and product coating unit~ within the source are less than 5 tons per year. Arc-Plasma coating technology emits no measurable quantity of volatile organic compounds. Therefore, the emission limits specified in 5-253.13 do not apply to this facility. ·

Section 5-253.14: This subsection applies to all solvent metal cleaning sources other than some open-top vapor degreasing and conveyorized degreasing operations. "Solvent metal cleaning" means the process of cleaning soils from metal surfaces by cold cleaning, open-top vapor degreasing. or conveyorized degreasing. EST uses an MEK solvent to clean the metal parts. MEK is wiped on the part manually. The manual application of solvent does not meet the definition of cold cleaning. Therefore, subsection 5-253.14 is not applicable to the operations at the proposed facility.

Section 5-802: This Section requires sources actually emitting air contaminants at rates of five tpy or greater to register on an annual basis: EST's allowable emissions are approximately 6 tons per year. However, most of EST's emissions come from the space heating equipment assumed continuous use at maximum capacity. This situation is unlikely to occur. Therefore, emissions are not expected to trigger the requirements under Section 5-802 for this source requiring participation in the annual registration program.

Section 5-lOQ.:J:: This Section requires sources subject to Section 5-1003 to apply for an Operating Permit as desctibed in Subchapter X of the Vermont Regulations. EST is a designated source of air contaminants, however, its future allowable aggregated emissions are less than 10 tons per year. Therefore, EST is not required to file additional applications for approval to operate.

4.2 Federal Regulations

The federal government has promulgated a national emission standard for lumu-dous air pollutants (NESHAP) for halogenated solvent cleaning processes. EST does not use halogenated solvent. Therefore, this NESHAP does not apply to this facility. There are no other federal regulations identified as applying to the proposed facility at this time.

5.0 Hazardous Air Contaminants

Section 5-261 of the Regulations addresses the release of hazardous air contaminants into the ambient air. If Section 5-261 is determined applicable, the source must then apply control technology. This control technology must show that the emissions will be controlled to the "hazardous most stringent emissions rate." An air quality impact evaluation may be required to further assess impacts that may be attributable to the source regarding hazardous ambient air standards.


5.1 Applicability Determination

Applicability with Section 5-261 is based on a comparison of allowable emissions of hazardous air contaminants with their respective "Action Level" (AL). A source is subject to Section 5-261 if any hazardous air contaminant exceeds its respective AL. Exceeding an Action Level only indicates that the source is subject to review under this section; the Action Levels arc not emission limits. Table E, below summarizes the hazardous air contaminant emissions from the proposed facility. Coating system HAC emission rates were derived from the 5.5 x w·' lb/hr rate described in section 3.2 multiplied by eight to calculate lb/8hr. Solvent emission rates were provided by EST.

The only contaminant found subject to Section 5-261 was nickel. The powder coating used in the arc-plasma process contains between 33-45% nickel. Using the mass-balance estimate described in section 3.2, nickel could be potentially emitted at a rate of 0.02 lb/8hr. This

Table E: Haz.·H'dous Air Contaminant Emissions

xylenl' 0.008 methyl ethyl ketont;> 2.4

toh!t;>.ne 0.08 moly-disulfid.o 0.04

n-butyl alcohol 0.032 antimony trioxide 0.012

graphite 0.016 dibas1c lead phosphite 0.016

formaldehyde 0.(){)4 n1tric ac1d 0.4

copper O.Ol3 mdium 0.001

nickel * 0.019 2-hutoxyethanol 0.008

over

estimate assumes that all of the over-spray is exhausted to the collection system and that none of the spray remains in the booth. The Agency has investigated dibasic lead phosphate in regards to the threshold for lead compounds (0.014 lb/8hr). Dibasic lead phosphate is estimated to be emitted at a rate of 0.016 lb/8hr, however, when the lead content is prorated based on the molecular weight, dibasic lead phosphate will not trigger an Action Level.

5.2 Hazardous Most Stringent Emission Rate

Section 5-26l.states that "applicable sources shall apply control technology, production processes, or other techniques adequate to achieve the hazardous most stringent emission rate (HMSER). Once the Agency has determined HMSER for a stationary source and included it in an order, permit, or agreement, said determination shall remain in effect for five years. At the end of said five years, the determination shall expire unless the source demonstrates that such emission rate

-still represents HMSER."


EST has shown that fabric filtration technology designed to control emiSSIOns of particulate matter to 5 microns by 99.999% achieves the HMSER for this source. The HMSER for nickel from the arc-plasma coating processes at EST is 2.5 x l o-' lb/hr.

5.3 Hazardous Air Contaminant Air Quality Impact Evaluation

Under Section 5-26!, the Agency may require a subject source to submit an air quality impact evaluation which shows whether the source shall cause or contribute to ambient air concentrations in excess of any Hazardous Ambient Air Standard. EST has submitted a screening study to further investigate the ambient impacts. The Agency found this study inconclusive due to assumptions employed in the study. Nevertheless, the study showed that a higher stack was needed to promote good dispersion. EST has revised the original design to incorporate a 25-foot stack.

EST has supplemented the impact study with a discussion of the phys1cal behavior of the submicron particles found in the coating. EST concludes that the over-spray materials tend to adhere to each other. As the particles adhere, the particle size increases and more of the material is caught in the control devices. The Agency has determined this argument to be supported by documented investigations into Vander Walls forces and Brownian motion studies.

Considering the physical behavior of the submicron particles and EST's use of a higher stack to provide better dispersion, the Agency has found that this source will not cause or contribute to a violation of the Hazardous Ambient Air Standard for nickel.

6.0 Criteria Pollutant Air Quality Impacts

An ambient air quality impact evaluation for criteria pollutants may be required for proJects proposing to increase allowable emissions of particulate matter, sulfur dioxide, oxides of nitrogen, or carbon monoxide above ten tons per year. This project has allowable emissions less than lO tons. Therefore, an ambient air quality impact study is not required for this project. The proposed facility will not cause or contribute to violations of the Ambient Air Quality' Standards and Prevention of Significant Deterioration increments for criteria pollutants.

7.0. Conclusions

Based on this technical analysis of the proposed arc-plasma coating facility, the following conclusions arc made:

A. The proposed project subject to the recommended permit conditions, will meet the applicable emission standards contained in the Regulations. Furthermore, it is expected that emissions from the proposed modification will not significantly deteriorate air quality, nor will they cause or contribute to a violation of an ambient air quality standard.

B. Pursuant to regulatory definition, the proposed source is designated as a non-major


stationary source of air contaminants.

C. It is expected that this facility will not be subject to the requirements described in Section VIII: Registration of Air Contaminant Sources, of the Regulations.

D. The proposed project does not have the potential to emit air contaminants at rates that wouid trigge!' the opportunity for public comment under 10 V.S.A. Section 556.

E. Recommended Pe1mit Conditions

· Construction & Equipment Specification -

(I) Ellison Surface Technologies, Incorporated, (hereinafter "EST" or "operator") shall construct and operate its arc-plasma coating facility according to the plans and specifications submitted in conjunction with its application to t,he Agency on July 17, 1996 and in accordance with the conditions set forth herein.

(2) EST shall vent the exhaust gases from the three arc-plasma coating systems through a stack or stacks with an outlet greater than twenty-five (25) feet above grade and at least four ( 4) feet above any roofline or structure that may significantly interfere with the dispersion of the exhaust gases. Furthermore, the stack shall be vertical and shall not be equipped with any device that would obstruct the upward discharge of the exhaust gases.

(3) The coating systems shall be equipped with emissions control devices designed to capture and remove particulate matter greater than 5 microns at an efficiency of at least 99.999%. This control equipment shall be operational whenever the coating system is operational and shall be maintained in good working order according to the manufacture's specifications and recommendations.

- Odors & Visible Emissions -

(4) Emissions of visible air contaminants from any vent or stack shall not exceed 20% opacity for more than a period or periods aggregating six (6) minutes in any hour. At no time shall visible emissions exceed 60% opacity.

(5) EST shall take reasonable precautions at all times to prevent the discharge of objectionable odors beyond the property lines of the facility.

- Record Keeping & Reporting -

(6) EST shall notify the Agency in writing of the date of initial start-up of the arcplasma coating operations to produce product for sale within fifteen (15) days after such date.

Ellison Surface Technologies ~ Rutland Division #AP-96-021

(7) EST shall notify the Agency in writing of any proposed physical or operational change at the facility that may increase the emission rate of any air contaminant to the ambient air. If the Agency determines that a permit amendment is required, a new application and the appropriate application fee shall be submitted. The permit amendment shall be issued before commencing any such change.

(8) EST shall maintain a log book recording the dates and findings of inspections and description of any service or replacement conducted on or concerning the coating system's air pollution control equipment.

(9) All records, reports, and notifications required to be submitted to the Agency by this Permit shall be submitted to:

Field Services Section Air Pollution Control Division D.E.C .. Agency or Natural Resources 103 South Main Street. Bldg. 3 South Waterbury, Vermont 05671-0402

. (10) Said records shall be made available to the Agency upon request and shall be maintained for a period of five years from date of record.

- General Conditions -

(II) These Permit conditions may be modified for cause upon the filing of a written request with the Secretary of the Agency (hereinafter "Secretary") or upon the Secretary's own motion. Any modification shall be granted only with the written approval of the Secretary. If the Secretary detennines that modification is appropriate, only the conditions subject to modification shall be reopened. The filing of a request for modification docs not stay any terms or conditions of this Permit. The Secretary may provide opportunity for public comment on any proposed modification of these conditions. If public comments are solicited, the Secretary shall follow the procedures set forth in 10 \I.S.A. Section 556.

(12) This Permit does not convey any property rights of any sort or any exclusive privilege, nor does it authorize any injury to private property or any invasion of personal rights.

(13) By acceptance of this Permit, the owner and operator agree to allow representatives of the State of Vermont access to the properties covered by the Permit, at reasonable times, to ascertain compliance with Vermont environmental and health statutes and regulations and with this Permit.

(14) All data, plans, specifications, analyses -and other information submitted or caused to be submitted to .the Agency as part of the application for this Permit or an


amendment to this Permit shall be complete and truthful. Any such submission that is false or misleading shall be sufficient grounds for denial or revocation of this Permit, and may result in a fine and/or imprisonment under the authority of Vermont statutes.

(15) The operator of a source that emits more than five tons of any and all air contaminants per year shall register the source with the Secretary, and shall renew such registration annually. Each day of operating a source that is subject to registration without a valid, current registration shall constitute a separate violation and subject the operator to a civil penalty not to exceed $l00.00 per violation. The registration process shall follow the procedures set forth in Subchapter V!II of the Air Pollution Control Regulations. These procedures are summarized as follows: By February 1 of each year, the operator of each source subject to registration shall submit to the Air Pollution Control Officer source emissions data for the preceding year and any other information required to determine the appropriate registration fee; By May 15 of each year, the operator of each source subject to registration shall pay to the Air Pollution control Officer the appropriate · fee, if any.

(16) These Permit conditions shall be binding upon and enforceable against the current owner and operator and all subsequent owners and operators of the source.

( 17) The provisions of this Permit are severable. If any provision of this Permit, or its application to any person, entity, or circumstance is held invalid, illegal, or unenforceable by court of competent jurisdiction, the mvalidity shall not apply to any other portion of this Permit which can he given effect without the invalid provision or application thereof.

Ellison Surface Technologies - Rutland Division

APPENDIX

Figure 1: Plant Layout

Figures 2-3: USGS Topographical Map & Orthophoto

Figure 4: Process Flow Diagram

Table 1: Combustion Emissions Calculations

#AP-96-021

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DRAF_T .COPY TABLE 1: Allowable Combustion Emissions

Company: EST - Rutland Division File No. AP-96-021

DATE: 07/30/96 AUTHOR: M. Bannon

================·=======================::::::::::::::::::============================·=====================================

FACill TY FUNCTIO.N:

UNIT MANUFACTURER: UNIT TYPE: UNIT USE: Utli T RATING (MMBtu/Hour): DATE OF INSTALLATION: UIHT CLASSIFICATION: NUMBER Of ZONES:

FUEL PARAMETERS:

fMXIMUM LPG HEAT INPUT (HP): LPG HIGH /IEAT VALUE: LPG SULFUR CONTENT %:

AP-42 El<l!SSIOfJ FACTORS:

LPG COMBUST!OU UUIT EHISS!OUS REV!EU UORpHEET

Ovens & Space Heat

New England truck load Oven 0.5 1996 .Small One

lndust.

120

0

PM: SOZ:

CO: NOx:

NHOC:

New England truck toad Oven 0.5 1996 Small Indust. One

(HHBTU/HR)= (HHBTU/GAL)=

LPG 0.6

0 3.2

19 0.5

NO.OF COMBUSTION

Oevi lbiss Roof Mount Spa.ce Heat 3

1996 Industrial One

4 0.094

UNITS: 3

============================================================================================================== OPERATING PARAMETERS:

POTEtH IAL !lOURS: POTENTIAL FUEL USE:

ANUUAL FUEL USE:

LPG 8760 HOURS

4.3E+01 GALLONS/HOUR 3. 7E+05 GALLONS

============================================================================================================== EMISSIONS POTEilTIAlS (tpy):

PH S02 co

NOX NMOC

0.1 0.0 0.6 3.6 0.1

S!Gil!FICMH LEVELS:

15 40 50 40 40

MAJOR THRESHOLD:

50 50 50 50 50

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AIR POLLUTION CONTROL PERMIT · 2012-09-21 · Air Pollution Control Division Waterbury, Vermont...

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Transcript of AIR POLLUTION CONTROL PERMIT · 2012-09-21 · Air Pollution Control Division Waterbury, Vermont...