STATEMENT OF BASIS. IIG MinWool LLC Phenix City, AL Russell County

Transcription

1 STATEMENT OF BASIS IIG MinWl LLC Phenix City, AL Russell Cunty This prpsed Title V Majr Surce Operating Permit renewal is issued under the prvisins f ADEM Admin. Cde R The abve named applicant has requested authrizatin t perfrm the wrk r perate the facility shwn n the applicatin and drawings, plans, and ther dcuments attached heret r n file with the Air Divisin f the Alabama Department f Envirnmental Management, in accrdance with the terms and cnditins f this permit. On Nvember 21, 2018, IIG MinWl LLC submitted a letter infrming the Department that their name has been frmally changed t Jhns Manville, effective January 1, Jhns Manville, lcated in Phenix City, Alabama, is a medium size manufacturing facility that prduces a variety f mineral wl insulatin prducts frm raw materials. Jhns Manville was issued its existing Majr Surce Operating Permit (MSOP) n Octber 15, 2013 with an expiratin date f Octber 14, Per ADEM Rule (2), an applicatin fr permit renewal shall be submitted at least six (6) mnths, but nt mre than eighteen (18) mnths, befre the date f expiratin f the permit. Based n this rule, the applicatin fr renewal was due t the Department n later than May 14, 2018, but n earlier than May 14, An applicatin fr permit renewal was received by the Department n April 16, N additinal infrmatin was deemed necessary fr prcessing f this MSOP. The fllwing are significant surces f air pllutin fr this facility: Cupla with Fiber Frmatin Prcess Mineral Wl Prcess Bard Line Mineral Wl Prcess Pipe Line 1

2 RENEWAL NOTES: 1. IIG requests revisins t the permit descriptins fr several pieces f equipment s that they are cnsistent with the facility. 2. IIG requests that the current annual cmpliance testing reprt due date be changed frm within 15 days f cmpletin f testing t within 30 days. 3. New MACT DDD emissin limits fr frmaldehyde, methanl, and phenl went int effect July 30, These limits are included in this renewal as well as the mnitring and testing requirements assciated with the limits. 4. IIG requests a name change frm the Industrial Insulatin Grup MinWl LLC t Jhns Manville. 2

3 Mineral Wl Cupla Furnace and Fiber Frmatin Cllectin Prcess Prcess Descriptin: The raw material blend (basalt, dlmite, and limestne) is laded int a cupla with cke (n mre than 0.7% sulfur cntent). As the cke is ignited and burned, the mineral charge is heated t the mlten state at a desired temperature. Emissins f fugitive PM frm this prcess have been calculated and meet the definitin f Insignificant Activity. The mlten mineral exits the cupla and prceeds t the fiber frmatin and cllectin prcess t be spun int mineral wl fibers. Once the melt is drpped int the spinner (frming drum), lng fibers f the melt are frmed and phenl frmaldehyde resin-based binder is applied. The binder is blwn tward a rtating drum under suctin. The fiber frm the cllectin area is either kept as a blanket fr prcessing in the Bard Insulatin Line r rlled int lgs fr use in the Pipe Insulatin Line. The emissins frm the cupla are suctined by negative pressure t the Thermal Oxidizer System that includes a separatr, baghuse, and thermal xidizer. The emissins frm the frming drum are sent t Filterhuse #1. The emissin pint is designated as Stack 101. Applicability: This surce is subject t the applicable requirements f ADEM Admin. Cde R , Majr Surce Operating Permits. This surce is subject t ADEM Admin. Cde R (1), Cntrl f Particulate Emissins fr Prcess Industries - General. Hwever, this unit has BACT PM limits in place which are mre stringent. This unit is subject t ADEM Admin. Cde R (1), Cntrl f Particulate Emissins Visible Emissins. This unit has enfrceable limits in place in rder t cmply with the applicable prvisins f ADEM Admin. Cde R Air Permits Authrizing Cnstructin in Clean Air Areas [Preventin f Significant Deteriratin]. Per , a mineral wl prductin facility is subject t the applicable prvisins f 40 CFR 63 Subpart DDD, Natinal Emissin Standards fr Hazardus Air Pllutants fr Mineral Wl Prductin. Per , a mineral wl prductin facility is subject t the applicable prvisins f 40 CFR 63 Subpart A, General Prvisins as listed in Table 1 f 40 CFR 63 Subpart DDD. This cupla is subject t 40 CFR 64, Cmpliance Assurance Mnitring. Pre-cntrl ptential carbn mnxide emissins exceed 100 TPY. Emissins Standards: 3

4 Opacity ADEM Admin. Cde R (1)(a)(b), states n persn shall discharge particulate emissins f an pacity greater than that designated as twenty (20%) pacity, as determined by a six minute average. During ne six (6) minute perid in any sixty (60) minute perid, a persn may discharge int the atmsphere frm any surce f emissin frty (40%) percent pacity. Particulate Matter The cmbined particulate matter (PM) emissins frm the Cupla, Fiber Frmatin/Cllectin Prcess, Mineral Wl Prcess (Bard Line), and Mineral Wl Prcess (Pipe Insulatin Lines) shall nt exceed (lb/hr) punds per hur. (ADEM Admin. Cde (9) BACT) Particulate matter (PM) emissins frm each existing, new, r recnstructed cupla shall nt exceed 0.05 kilgrams (kg) f PM per megagram (MG) (0.10 pund [lb] f PM per tn) f melt. (40 CFR (a)(1) Subpart DDD) The Permittee must cmply with these standards (Subpart DDD) at all times except during perids f startup, shutdwn, r malfunctin. (40 CFR Subpart DDD) Operating The cupla shall be vented t a baghuse and an xidizer in series. (ADEM Admin. Cde (9) BACT) The three-hur average temperature in the firebx f the thermal xidizer n the cupla shall nt be less than 1320 F while the cupla is perating. (ADEM Admin. Cde (9) BACT) The baghuse and xidizer shall nt be bypassed during startup r fr mre than fur (4) hurs during shutdwn perids. (ADEM Admin. Cde (9) BACT) The pressure drp acrss the baghuse shall nt drp belw 0.2 inches f water clumn while the cupla is perating. (ADEM Admin. Cde (9) BACT) Begin within ne hur after the alarm n a bag leak detectin system sunds, and cmplete in a timely manner, crrective actins as specified in yur peratins, maintenance, and mnitring plan required by f 40 CFR 63 Subpart DDD. (40 CFR (b)(1) Subpart DDD) When the alarm n a bag leak detectin system sunds fr mre than five percent f the ttal perating time in a six-mnth reprting perid, develp and implement a written quality imprvement plan (QIP) cnsistent with the cmpliance assurance 4

5 mnitring requirements f 64.8(b) (d) f 40 CFR part 64. (40 CFR (b)(2) Subpart DDD) Sulfur Dixide Sulfur dixide emissins frm the cupla shall nt exceed 88.5 (lb/hr) punds per hur. (ADEM Admin. Cde (9) BACT) Only cke derived frm cal shall be used as fuel. Such cke shall nt cntain sulfur which exceeds 0.7% by weight. (ADEM Admin. Cde (9) BACT) Carbn Mnxide Carbn mnxide emissins frm the cupla shall nt exceed 17.0 (lb/hr) punds per hur. (ADEM Admin. Cde (9) BACT) ges away after 7/30/18? Nitrgen Oxide Nitrgen xide emissins frm the cupla shall nt exceed 15.0 (lb/hr) punds per hur. (ADEM Admin. Cde (9) BACT) Hydrgen Sulfide Hydrgen sulfide (H2S) emissins frm the cupla shall nt exceed 1.0 (lb/hr) pund per hur. (ADEM Admin. Cde (9) BACT) Carbnyl Sulfide Carbnyl sulfide (COS) emissins frm the cupla shall nt exceed 3.4 punds per tn f melt. (40 CFR (a) Subpart DDD) Hydrgen Fluride Hydrgen fluride (HF) emissins frm the cupla shall nt exceed 0.13 punds per tn f melt. (40 CFR (a) Subpart DDD) Hydrgen Chlride Hydrgen chlride (HCl) emissins frm the cupla shall nt exceed 0.43 punds per tn f melt. (40 CFR (a) Subpart DDD) Frmaldehyde 5

6 Frmaldehyde emissins frm the fiber frmatin cllectin prcess shall nt exceed 0.17 lb per tn melt. (40 CFR (a) Subpart DDD) Methanl Methanl emissins frm the fiber frmatin cllectin prcess shall nt exceed 0.28 lb per tn melt. (40 CFR (a) Subpart DDD) Phenl Phenl emissins frm the fiber frmatin cllectin prcess shall nt exceed 0.85 lb per tn melt. (40 CFR (a) Subpart DDD) Cmpliance and Perfrmance Test Methds and Prcedures: If testing is required, the nitrgen xide (NOx) emissins shall be determined by Methds 7, 7a, 7b, r 7e f 40 CFR 60, Appendix A. (ADEM Admin. Cde ) If testing is required, the carbn mnxide (CO) emissins shall be determined by Methds 10 r 10b f 40 CFR 60, Appendix A. (ADEM Admin. Cde ) If testing is required, particulate matter emissins shall be determined by Methd 5e f 40 CFR Part 60, Appendix A. (ADEM Admin. Cde ) If testing is required, the hydrgen sulfide emissins shall be determined by Methd 11 f 40 CFR Part 60, Appendix A. (ADEM Admin. Cde ) If testing is required, sulfur dixide emissins shall be determined by Methds 6 r 6c f 40 CFR Part 60, Appendix A. (ADEM Admin. Cde )) If testing is required, carbnyl sulfide, frmaldehyde, phenl, and methanl emissins shall be determined by Methd 318 f 40 CFR Part 60, Appendix A. (40 CFR Subpart DDD) If testing is required, hydrgen fluride and hydrgen chlride emissins shall be determined by Methd 26A r 320 f 40 CFR Part 60, Appendix A. (40 CFR Subpart DDD) T cmply with the PM standards f Subpart DDD, yu must meet all f the fllwing: (40 CFR Subpart DDD) Install, adjust, maintain, and cntinuusly perate a bag leak detectin system fr each fabric filter. D a perfrmance test as specified in f this subpart and shw cmpliance with the PM emissin limits while the bag leak detectin system is installed, peratinal, and prperly adjusted. 6

7 Begin crrective actins specified in yur peratins, maintenance, and mnitring plan required by f this subpart within ne hur after the alarm n a bag leak detectin system sunds. Cmplete the crrective actins in a timely manner. Develp and implement a written QIP cnsistent with cmpliance assurance mnitring requirements f 40 CFR 64.8(b) thrugh (d) when the alarm n a bag leak detectin system sunds fr mre than five percent f the ttal perating time in a sixmnth reprting perid. T cmply with the COS, HF, and HCl standards f Subpart DDD, yu must meet all f the fllwing: (40 CFR Subpart DDD) Install, calibrate, maintain, and perate a device that cntinuusly measures the perating temperature in the firebx f each thermal incineratr. Cnduct a perfrmance test as specified in that shws cmpliance with the COS, HF, and HCl emissins limits while the device fr measuring incineratr perating temperature is installed, perating, and prperly calibrated. Establish the average perating temperature based n the perfrmance test as specified in (a). Fllwing the perfrmance test, measure and recrd the average perating temperature f the incineratr as specified in (b). Maintain the perating temperature f the incineratr s that the average perating temperature fr each three-hur blck perid never falls belw the average temperature established during the perfrmance test. Operate and maintain the incineratr as specified in yur peratins, maintenance, and mnitring plan required by T cmply with the frmaldehyde, phenl, and menthanl standards f Subpart DDD, yu must meet all f the fllwing: (40 CFR Subpart DDD) Install, calibrate, maintain, and perate a device that cntinuusly measures the perating temperature in the firebx f each thermal incineratr. Cnduct a perfrmance test as specified in while manufacturing the prduct that requires a binder frmulatin made with the resin cntaining the highest free-frmaldehyde cntent specificatin range. Shw cmpliance with the frmaldehyde, phenl, and methanl emissins limits, specified in Table 2 t this subpart, while the device fr measuring the cntrl device perating parameter is installed, peratinal, and prperly calibrated. Establish the average perating parameter based n the perfrmance test as specified in (a). During the perfrmance test that uses the binder frmulatin made with the resin cntaining the highest free-frmaldehyde cntent specificatin range, recrd the free-frmaldehyde cntent specificatin range f the resin used, and the frmulatin f the binder used, including the frmaldehyde cntent and binder specificatin. Fllwing the perfrmance test, mnitr and recrd the free-frmaldehyde cntent f each resin lt and the frmulatin f each batch f binder used, including the frmaldehyde, phenl, and methanl cntent. 7

8 Maintain the free-frmaldehyde cntent f each resin lt and the frmaldehyde cntent f each binder frmulatin at r belw the specificatin ranges established during the perfrmance test. Fllwing the perfrmance test, measure and recrd the average perating temperature f the incineratr as specified in (b) f this subpart. Maintain the perating temperature f the incineratr s that the average perating temperature fr each three-hur blck perid never falls belw the average temperature established during the perfrmance test. Operate and maintain the incineratr as specified in yur peratins, maintenance, and mnitring plan required by f this subpart. The perfrmance tests cnducted t demnstrate cmpliance with the emissins limits in shall cnfrm t the test methds and prcedures specified in and Using the results f the perfrmance tests, the facility must use the fllwing equatin t determine cmpliance with the PM emissin limit: (40 CFR (a) Subpart DDD) C Q K1 E Where: P E = Emissin rate f PM, kg/mg (lb/tn) f melt. C = Cncentratin f PM, g/dscm (gr/dscf). Q = Vlumetric flw rate f exhaust gases, dscm/hr (dscf/hr). K1 = Cnversin factr, 1 kg/1,000 g (1 lb/7,000 gr). P = Average melt rate, Mg/hr (tn/hr). Using the results frm the perfrmance tests, the facility must use the fllwing equatin t determine cmpliance with the carbnyl sulfide, hydrgen fluride, and hydrgen chlride emissin limits: (40 CFR (b) Subpart DDD) E = C MW Q K 1 K 2 K 3 P 10 6 Where: E = Emissin rate f measured pllutant, kg/mg (lb/tn) f melt. C = Measured vlume fractin f pllutant, ppm. MW = Mlecular weight f measured pllutant, g/g-mle: Carbnyl sulfide = 60.07, hydrgen fluride = 20.01, hydrgen chlride =

9 Q = Vlumetric flw rate f exhaust gases, dscm/hr (dscf/hr). K1 = Cnversin factr, 1 kg/1,000 g (1 lb/453.6 g). K2 = Cnversin factr, 1,000 L/m 3 (28.3 L/ft 3 ). K3 = cnversin factr, L/g-mle. P = Average melt rate, Mg/hr (tn/hr). CAM Analysis: Surce Pllutant Precntrl Emissins (>100 TPY)? Cntrlled? Emissin Limit? CAM Applicable? If nt, why? Cupla CO Yes Yes Yes Yes H2S N Yes Yes N <100 tpy NOx N N N N Nt cntrlled PM Yes Yes Yes N Subject t pst 1990 rule (40 CFR Subpart DDD) SO2 N N Yes N Nt cntrlled Bard Line Oven Bard Line Cler Pipe Lines PM N Yes Yes N <100 tpy NOx N N N N Nt cntrlled VOC N N N N Nt cntrlled PM N N N N Nt cntrlled VOC N N N N Nt cntrlled PM N Yes Yes N <100 tpy VOC N N N N Nt cntrlled Cupla Particulate Matter MACT Mnitring 9

10 40 CFR 63 Subpart DDD was adpted after Nvember 15, The mnitring requirements specified in the subpart (detailed belw) are sufficient t satisfy CAM: Begin within ne hur after the alarm n a bag leak detectin system sunds, and cmplete in a timely manner, crrective actins as specified in yur peratins, maintenance, and mnitring plan required by f this subpart. When the alarm n a bag leak detectin system sunds fr mre than five percent f the ttal perating time in a six-mnth reprting perid, develp and implement a written quality imprvement plan (QIP) cnsistent with the cmpliance assurance mnitring requirements f 64.8(b) (d) f 40 CFR part 64. Install, adjust, maintain, and cntinuusly perate a bag leak detectin system fr each fabric filter. D a perfrmance test as specified in f this subpart and shw cmpliance with the PM emissin limits while the bag leak detectin system is installed, peratinal, and prperly adjusted. Begin crrective actins specified in yur peratins, maintenance, and mnitring plan required by f this subpart within ne hur after the alarm n a bag leak detectin system sunds. Cmplete the crrective actins in a timely manner. Develp and implement a written QIP cnsistent with cmpliance assurance mnitring requirements f 40 CFR 64.8(b) thrugh (d) when the alarm n a bag leak detectin system sunds fr mre than five percent f the ttal perating time in a sixmnth reprting perid. A bag leak detectin system must meet the fllwing requirements: The bag leak detectin system must be certified by the manufacturer t be capable f detecting PM emissins at cncentratins f 10 milligrams per actual cubic meter ( grains per actual cubic ft) r less. The sensr n the bag leak detectin system must prvide utput f relative PM emissins. The bag leak detectin system must have an alarm that will sund autmatically when it detects an increase in relative PM emissins greater than a preset level. The alarm must be lcated in an area where apprpriate plant persnnel will be able t hear it. Fr a psitive-pressure fabric filter, each cmpartment r cell must have a bag leak detectr. Fr a negative-pressure r induced-air fabric filter, the bag leak detectr must be installed dwnstream f the fabric filter. If multiple bag leak detectrs are required (fr either type f fabric filter), detectrs may share the system instrumentatin and alarm. Each tribelectric bag leak detectin system must be installed, perated, adjusted, and maintained s that it fllws EPA's Fabric Filter Bag Leak Detectin Guidance (EPA 454/R , September 1997). Other bag leak detectin 10

11 systems must be installed, perated, adjusted, and maintained s that they fllw the manufacturer's written specificatins and recmmendatins. After initial adjustment, the range, averaging perid, alarm set pints, r alarm delay time may nt be adjusted except as specified in the peratins, maintenance, and mnitring plan required by f this subpart. In n event may the range be increased by mre than 100 percent r decreased by mre than 50 percent ver a 365 day perid unless a respnsible fficial as defined in 63.2 f the general prvisins in subpart A f this part certifies in writing t the Administratr that the fabric filter has been inspected and fund t be in gd perating cnditin. Cupla Carbn Mnxide Mnitring The facility prpses t cntinue cmplying with existing CAM plan: MONITORING APPROACH: Gas-fired Incineratr Indicatr N. 1 Indicatr N. 2 I. Indicatr Cupla Incineratr Temperature Inspectin and Maintenance Prvisins Measurement Apprach II. Indicatr Range III. Perfrmance Criteria Data Representativeness Verificatin f Operatin Status QA/QC Practices and Criteria Cupla incineratr temperature will be mnitred cntinuusly when the cupla is in peratin. Cupla incineratr temperature will be maintained at r abve 1320ºF while the cupla is in peratin (excludes startup and shutdwn). Cupla incineratr temperature will be mnitred with a temperature indicating device installed in the cmbustin chamber f the incineratr, prviding directly representative data. When peratinal, cupla incineratr temperature indicatr will display the incineratr temperature. Cupla incineratr temperature will be autmatically recrded. Fllw prcedures in sectin (b)(3) f 40 CFR 63 Subpart DDD Fllw prcedures in sectin (b)(3) f 40 CFR 63 Subpart DDD Fllw prcedures in sectin (b)(3) f 40 CFR 63 Subpart DDD Dcumented cmpletin f inspectin and maintenance activities in accrdance with sectin (b)(3) f 40 CFR 63 Subpart DDD Persns perfrming the inspectin and maintenance will be trained in prper techniques and prvided the prper backgrund t 11

12 Mnitring Frequency Data Cllectin Prcedures Cupla incineratr temperature is mnitred cntinuusly. Autmatic. Averaging perid N/A N/A effectively perfrm the inspectin and maintenance At least nce per year Recrds f cmpletins f inspectin and maintenance Justificatin Ratinale fr Selectin f Perfrmance Indicatrs Incineratr cmbustin chamber temperature was selected as a perfrmance indicatr based n its crrelatin t destructin efficiency fr CO and ther rganics. Generally, higher temperature ffer better destructin efficiency fr rganics. The minimum temperature is highly dependent f the types f rganics being cntrlled, the residence time in the unit, and the desired destructin efficiency. Fr IIG MinWl s Cupla #1, the minimum incineratr temperature f 1320ºF was chsen since it is equal t the current permit limit where cmpliance with the emissins limit f 17 lb CO/hr has been established by past surce tests. Cntinued mnitring f the incineratr temperature will prvide reasnable assurance that the cntrl efficiency f the incineratr and cmpliance with the emissins limit f 17.0 lb CO/hr is being maintained. Inspectin and maintenance prcedures in 40 CFR (b)(3) were selected as a perfrmance indicatr based n their direct impact n CO destructin efficiency. Imprper maintenance can result in lwer destructin efficiencies and increased CO emissins frm such items as (including but nt limited t): Imprper burner adjustment Insufficient air flw Ht r cld spts due t refractry deteriratin Imprper adjustment f cntrls, mtrs, etc. Peridic inspectin and maintenance will ensure the incineratr is perating as design fr maximum cntrl efficiency. Please nte: the chsen inspectin and maintenance prvisins are already being cnducted as part f cmpliance methd fr Subpart DDD fr PM10 emissins frm Cupla #1. Ratinale fr Selectin f Indicatr Ranges Fr incineratr temperature, the selected indicatr range is any temperature at r abve 1320ºF. This temperature crrespnds t a current permit limitatin established as part f a past permitting actin fr cmpliance with the PSD limit f 17.0 lb CO/hr. 12

13 There is n indicatr range fr the inspectin and maintenance prcedures, ther than maintaining accurate recrds f all inspectin and maintenance prcedures. Perfrmance Test Cmpliance surce tests fr CO are cnducted annually. Results f these surce tests indicate cntinued cmpliance with the CO emissins limit f 17.0 lb/hr and minimum cupla incineratr temperature f 1320ºF. N significant changes have been made t the cupla, incineratr, r temperature indicating systems. Emissin Mnitring: Carbn Mnxide emissins mnitring requirements under 40 CFR Part 64, Cmpliance Assurance Mnitring can be fund in the CAM analysis sectin belw. A mnitring device that cntinuusly measures and recrds the firebx temperature f the incineratr n the cupla shall be installed, calibrated, maintained, and perated. (ADEM Admin. Cde ) Instruments which measure the pressure drp acrss the filterhuses shall be maintained and perated. (ADEM Admin. Cde ) During the annual cmpliance test, minimum pressure drps shall be determined fr the filterhuses. (ADEM Admin. Cde ) Pressure drp acrss each filterhuse shall be mnitred and recrded daily, except when the surce f pllutin t the filterhuse is nt being perated. (ADEM Admin. Cde ) Emissins tests n Stack 101 are t be cnducted fr the fllwing pllutants at intervals nt t exceed ne year fllwing the date f previus cmpliance testing. All test reprts must be submitted t the Department within 30 days f cmpletin f testing. (ADEM Admin. Cde ) Particulate Carbn Mnxides Sulfur Dixide A bag leak detectin system must meet the fllwing requirements: (40 CFR Subpart DDD) The bag leak detectin system must be certified by the manufacturer t be capable f detecting PM emissins at cncentratins f 10 milligrams per actual cubic meter ( grains per actual cubic ft) r less. The sensr n the bag leak detectin system must prvide utput f relative PM emissins. 13

14 The bag leak detectin system must have an alarm that will sund autmatically when it detects an increase in relative PM emissins greater than a preset level. The alarm must be lcated in an area where apprpriate plant persnnel will be able t hear it. Fr a psitive-pressure fabric filter, each cmpartment r cell must have a bag leak detectr. Fr a negative-pressure r induced-air fabric filter, the bag leak detectr must be installed dwnstream f the fabric filter. If multiple bag leak detectrs are required (fr either type f fabric filter), detectrs may share the system instrumentatin and alarm. Each tribelectric bag leak detectin system must be installed, perated, adjusted, and maintained s that it fllws EPA's Fabric Filter Bag Leak Detectin Guidance (EPA 454/R , September 1997). Other bag leak detectin systems must be installed, perated, adjusted, and maintained s that they fllw the manufacturer's written specificatins and recmmendatins. At a minimum, initial adjustment f the system must cnsist f establishing the baseline utput in bth f the fllwing ways: Adjust the range and the averaging perid f the device. Establish the alarm set pints and the alarm delay time After initial adjustment, the range, averaging perid, alarm set pints, r alarm delay time may nt be adjusted except as specified in the peratins, maintenance, and mnitring plan required by f this subpart. In n event may the range be increased by mre than 100 percent r decreased by mre than 50 percent ver a 365 day perid unless a respnsible fficial as defined in 63.2 f the general prvisins in subpart A f this part certifies in writing t the Administratr that the fabric filter has been inspected and fund t be in gd perating cnditin An peratins, maintenance, and mnitring plan must be submitted t the Administratr fr review and apprval as part f the applicatin fr the title V permit. (40 CFR (a) Subpart DDD) The facility may change cntrl device and prcess perating parameter levels established during perfrmance tests and used t mnitr cmpliance if yu d the fllwing: (40 CFR Subpart DDD) The facility must ntify the Administratr f yur desire t expand the range f a cntrl device r prcess perating parameter level. Upn apprval frm the Administratr, the facility must cnduct additinal perfrmance tests at the prpsed new cntrl device r prcess perating parameter levels. Befre perating at these levels, the perfrmance test results must verify that, at the new levels, the facility cmply with the emissin limits in and f this subpart. The peratins, maintenance, and mnitring plan must include the fllwing: (40 CFR (b) Subpart DDD) 14

15 Prcess and cntrl device parameters the facility will mnitr t determine cmpliance, alng with established perating levels r ranges fr each prcess r cntrl device. A mnitring schedule. Prcedures fr prperly perating and maintaining cntrl devices used t meet the standards in and f this subpart. These prcedures must include an inspectin f each incineratr at least nce per year. At a minimum, the facility must d the fllwing as part f an incineratr inspectin: Inspect all burners, pilt assemblies, and pilt sensing devices fr prper peratin. Clean pilt sensr if necessary. Ensure prper adjustment f cmbustin air, and adjust if necessary. Inspect, when pssible, all internal structures (such as baffles) t ensure structural integrity per the design specificatins. Inspect dampers, fans, and blwers fr prper peratin. Inspect mtrs fr prper peratin. Inspect, when pssible, cmbustin chamber refractry lining. Clean, and repair r replace lining if necessary. Inspect incineratr shell fr prper sealing, crrsin, and/r ht spts. Fr the burn cycle that fllws the inspectin, dcument that the incineratr is perating prperly and make any necessary adjustments. Generally bserve whether the equipment is maintained in gd perating cnditin. Cmplete all necessary repairs as sn as practicable. Prcedures fr keeping recrds t dcument cmpliance. Crrective actins the facility will take if prcess r cntrl device parameters vary frm the levels established during perfrmance testing. Recrdkeeping and Reprting Requirements: Recrds shall be maintained f the sulfur cntent f the cke used in the cupla. (ADEM Admin. Cde ) A semi-annual mnitring reprt shall be submitted t the Department accrding the fllwing schedule: (ADEM Admin. Cde (c)(3)) Reprting Perid January 1 st t June 30 th July 1 st t December 31 st Due Date August 31 st February 28 th A reprt shall be submitted semi-annually which cntains the fllwing: The perids when firebx temperate in the incineratr n the cupla was belw 1320 F and the crrective actin taken; The perids when the pressure drps acrss the filterhuses were belw the minimum pressure determined during the annual stack tests; 15

16 All recrd shall be maintained fr a minimum f 5 years. (ADEM Admin. Cde (c)(2)) This surce shall cmply with the ntificatin requirements specified in (40 CFR Subpart DDD) The facility must meet the fllwing recrdkeeping requirements: (40 CFR Subpart DDD) Maintain files f all infrmatin required by 63.10(b) f the general prvisins in subpart A f this part, including all ntificatins and reprts. Maintain recrds f the fllwing infrmatin als: Cupla prductin (melt) rate (Mg/hr (tns/hr) f melt). All bag leak detectin system alarms. Include the date and time f the alarm, when crrective actins were initiated, the cause f the alarm, an explanatin f the crrective actins taken, and when the cause f the alarm was crrected. Incineratr perating temperature and results f incineratr inspectins. Fr all perids when the average temperature in any three-hur blck perid fell belw the average temperature established during the perfrmance test, and all perids when the inspectin identified incineratr cmpnents in need f repair r maintenance, include the date and time f the prblem, when crrective actins were initiated, the cause f the prblem, an explanatin f the crrective actins taken, and when the cause f the prblem was crrected. Retain each recrd fr at least five years fllwing the date f each ccurrence, measurement, crrective actin, maintenance, recrd, r reprt. The mst recent tw years f recrds must be retained at the facility. The remaining three years f recrds may be retained ff site. Retain recrds n micrfilm, n a cmputer, n cmputer disks, n magnetic tape disks, r n micrfiche. Reprt the required infrmatin n paper r n a labeled cmputer disk using cmmnly available and cmpatible cmputer sftware. The facility must prepare and submit reprts t the Administratr as required by 40 CFR 63 Subpart DDD and f the general prvisins in subpart A f this part. These reprts include, but are nt limited t, the fllwing: A perfrmance test reprt, as required by 63.10(d)(2) f the general prvisins in subpart A f this part, that dcuments the prcess and cntrl equipment perating parameters during the test perid, the test methds and prcedures, the analytical prcedures, all calculatins, and the results f the perfrmance tests. A startup, shutdwn, and malfunctin plan, as described in 63.6(e)(3) f the general prvisins in subpart A f this part, that cntains specific prcedures fr perating and maintaining the surce during perids f startup, shutdwn, and malfunctin and a prgram f crrective actin fr malfunctining prcess and cntrl systems used t cmply with the emissin standards. In additin t the infrmatin required by 63.6(e)(3), the r plan must include the fllwing: 16

17 Prcedures t determine and recrd what caused the malfunctin and when it began and ended. Crrective actins the facility will take if a prcess r cntrl device malfunctins, including prcedures fr recrding the actins taken t crrect the malfunctin r minimize emissins. An inspectin and maintenance schedule fr each prcess and cntrl device that is cnsistent with the manufacturer's instructins and recmmendatins fr rutine and lng-term maintenance. A reprt f each event as required by 63.10(b) f the general prvisins in subpart A f this part, including a reprt if an actin taken during a startup, shutdwn, r malfunctin is incnsistent with the prcedures in the plan as described in 63.6(e)(3) f the general prvisins in subpart A f this part. An peratins, maintenance, and mnitring plan as specified in f this subpart. A semiannual reprt as required by 63.10(e)(3) f the general prvisins in subpart A f this part if measured emissins exceed the applicable standard r a mnitred parameter varies frm the level established during perfrmance testing. The reprt must cntain the infrmatin specified in 63.10(c) f the general prvisins, as well as the relevant recrds required by (b) f this subpart. A semiannual reprt stating that n excess emissins r deviatins f mnitred parameters ccurred during the reprting perid as required by 63.10(e)(3)(v) f the general prvisins in subpart A f this part if n deviatins have ccurred. Semi-annual mnitring reprt required by 40 CFR 63 Subpart DDD shall be submitted t the Department accrding the fllwing schedule: (40 CFR 60.10(a)(5)) Reprting Perid January 1 st t June 30 th July 1 st t December 31 st Due Date August 31 st February 28 th Emissins: Emissin data is based n AP-42 emissins factr and mass balance. Per air permit applicatin frms submitted, emissins frm these units are as fllws: Emissin Pint Pllutant Allwable Expected Emissins Emissins (lb/hr) (TPY) (lb/hr) (TPY) 101 CO SO PM* NOx VOC CO2e 8, , Ttal HAP * - cmbined limit 17

18 Mineral Wl Prcess Bard Line Prcess Descriptin: The bard line ven receives the blanket f bnded fibers frm the fiber frmatin and cllectin prcess. The ven is a series f tw cnveyrs that transprt and cmpress the fiber int the final thickness and density. The fiber is cured as the thermal setting phenl frmaldehyde is heated and sets the prduct dimensins. There are tw gas fired burners fr the ven, ne fr thermal destructin and the ther t heat the curing air. The curing air is frced thrugh the fiber, then drawn int the thermal destructin chamber that is maintained at a minimum f 1,200 F. This air then passes back thrugh the tp f the ven t pre-heat the tp ven cnveyr befre it is sent t Filter Huse #3. The semi-finished blanket f prduct emerges frm the ven ver a cnveyr that suctins ambient air thrugh the fiber t cl the prduct. This air is exhausted untreated thrugh the rf. The cled bard insulatin is cut, packaged, and mved t the warehuse. Trimmings are recycled t the Frming unit, and emissins frm the handling and prcessing f the recyclable material are cntrlled by Filter Huse #2. The designated stack fr this prcess is Stack 102. Applicability: This surce is subject t the applicable requirements f ADEM Admin. Cde R , Majr Surce Operating Permits. This surce is subject t ADEM Admin. Cde R (1), Cntrl f Particulate Emissins fr Prcess Industries - General. Hwever, this unit has PM limits in place which are mre stringent. This unit is subject t ADEM Admin. Cde R (1), Cntrl f Particulate Emissins Visible Emissins. This unit has enfrceable limits in place in rder t cmply with the applicable prvisins f ADEM Admin. Cde R Air Permits Authrizing Cnstructin in Clean Air Areas [Preventin f Significant Deteriratin]. Per , a mineral wl prductin facility is subject t the applicable prvisins f 40 CFR 63 Subpart DDD, Natinal Emissin Standards fr Hazardus Air Pllutants fr Mineral Wl Prductin. Per , a mineral wl prductin facility is subject t the applicable prvisins f 40 CFR 63 Subpart A, General Prvisins as listed in Table 1 f 40 CFR 63 Subpart DDD. Emissins Standards: Opacity 18

19 ADEM Admin. Cde R (1)(a)(b), states n persn shall discharge particulate emissins f an pacity greater than that designated as twenty (20%) pacity, as determined by a six minute average. During ne six (6) minute perid in any sixty (60) minute perid, a persn may discharge int the atmsphere frm any surce f emissin frty (40%) percent pacity. Particulate Matter The cmbined particulate matter (PM) emissins frm prcesses the Cupla, Fiber Frmatin/Cllectin Prcess, Mineral Wl Prcess (Bard Line), and Mineral Wl Prcess (Pipe Insulatin Line) shall nt exceed (lb/hr) punds per hur. (ADEM Admin. Cde (9) BACT) Operating The baghuse and incineratr shall nt be bypassed during startup r fr mre than fur (4) hurs during shutdwn perids. (ADEM Admin. Cde (9)) Maintain the free-frmaldehyde cntent f each resin lt and the frmaldehyde cntent f each binder frmulatin at r belw the specificatin ranges f the resin and binder used during the perfrmance test. (40 CFR (b)(1) Subpart DDD) Maintain the perating temperature f each incineratr s that the average perating temperature fr each three-hur blck perid never falls belw the average temperature established during the perfrmance test. (40 CFR (b)(2) Subpart DDD) The Permittee must cmply with these standards (Subpart DDD) at all times except during perids f startup, shutdwn, r malfunctin. (40 CFR Subpart DDD) The temperature in the firebx f the afterburner n the curing ven shall nt be less than 1200 F while the curing ven is perating. (ADEM Admin. Cde (9) BACT) Frmaldehyde Frmaldehyde emissins frm the curing prcess shall nt exceed 0.17 lb per tn melt. (40 CFR (a) Subpart DDD) Methanl Methanl emissins frm the curing prcess shall nt exceed 0.28 lb per tn melt. (40 CFR (a) Subpart DDD) Phenl 19

20 Phenl emissins frm the curing prcess shall nt exceed 0.85 lb per tn melt. (40 CFR (a) Subpart DDD) The facility must cntrl emissins frm each existing, new, r recnstructed curing ven by limiting emissins f frmaldehyde t either f the fllwing: (40 CFR (a) Subpart DDD) 0.03 kg f frmaldehyde per MG (0.06 lb f frmaldehyde per tn) f melt r less. A reductin f uncntrlled frmaldehyde emissins by at least 80 percent. Cmpliance and Perfrmance Test Methds and Prcedures: If testing is required, particulate matter emissins shall be determined by Methd 5e f 40 CFR Part 60, Appendix A. (ADEM Admin. Cde ) If testing is required, frmaldehyde, phenl, and methanl emissins shall be determined by Methd 318 f 40 CFR Part 60, Appendix A. (40 CFR Subpart DDD) T cmply with the frmaldehyde standards, the facility must meet all f the fllwing: (40 CFR Subpart DDD) Install, calibrate, maintain, and perate a device that cntinuusly measures the perating temperature in the firebx f each thermal incineratr. D a perfrmance test as specified in f this subpart while manufacturing the prduct that requires a binder frmulatin made with the resin cntaining the highest free-frmaldehyde cntent specificatin range. Shw cmpliance with the frmaldehyde emissin limits while the device fr measuring incineratr perating temperature is installed, peratinal, and prperly calibrated. Establish the average perating temperature as specified in (a) f this subpart. During the perfrmance test that uses the binder frmulatin made with the resin cntaining the highest free-frmaldehyde cntent specificatin range, recrd the free-frmaldehyde cntent specificatin range f the resin used, and the frmulatin f the binder used, including the frmaldehyde cntent and binder specificatin. Fllwing the perfrmance test, mnitr and recrd the free-frmaldehyde cntent f each resin lt and the frmulatin f each batch f binder used, including the frmaldehyde cntent. Maintain the free-frmaldehyde cntent f each resin lt and the frmaldehyde cntent f each binder frmulatin at r belw the specificatin ranges established during the perfrmance test. Fllwing the perfrmance test, measure and recrd the average perating temperature f the incineratr as specified in (b) f this subpart. 20

21 Maintain the perating temperature f the incineratr s that the average perating temperature fr each three-hur blck perid never falls belw the average temperature established during the perfrmance test. Operate and maintain the incineratr as specified in yur peratins, maintenance, and mnitring plan required by f this subpart. With prir apprval frm the Administratr, the facility may d shrt-term experimental prductin runs using resin where the free-frmaldehyde cntent, r binder frmulatins where the frmaldehyde cntent, is higher than the specificatin ranges f the resin and binder used during previus perfrmance tests, r using experimental pllutin preventin prcess mdificatins withut first ding additinal perfrmance tests. Ntificatin f intent t perfrm a shrtterm experimental prductin run must include the fllwing infrmatin: The purpse f the experimental run. The affected prductin prcess. Hw the resin free-frmaldehyde cntent r binder frmulatin will deviate frm previusly apprved levels r what the experimental pllutin preventin prcess mdificatins are. The duratin f the experimental run. The date and time f the experimental run. A descriptin f any emissins testing t be dne during the experimental run. The perfrmance tests cnducted t demnstrate cmpliance with the emissins limits in shall cnfrm t the test methds and prcedures specified in and Using the results f the perfrmance tests, the facility must use the fllwing equatin t determine cmpliance with the CO and frmaldehyde numerical emissin limits: (40 CFR Subpart DDD) C MW O K1 K 2 E 6 K P 10 3 where: E = Emissin rate f measured pllutant, kg/mg (lb/tn) f melt. C = Measured vlume fractin f pllutant, ppm. MW = Mlecular weight f measured pllutant, g/g-mle: Frmaldehyde = Q = Vlumetric flw rate f exhaust gases, dscm/hr (dscf/hr). K1= Cnversin factr, 1 kg/1,000 g (1 lb/453.6 g). 21

22 K2= Cnversin factr, 1,000 L/m 3 (28.3 L/ft 3 ). K3= Cnversin factr, L/g-mle. P = Average melt rate, Mg/hr (tn/hr). CAM Analysis: Surce Pllutant Precntrl Emissins (>100 TPY)? Bard Line Oven Bard Line Cler Cntrlled? Emissin Limit? CAM Applicable? If nt, why? PM N Yes Yes N <100 tpy* NOx N N N N Nt cntrlled VOC N N N N Nt cntrlled PM N N N N Nt cntrlled VOC N N N N Nt cntrlled *Thugh this prcess is subject t a cmbined limit f 117 lb/hr, the bard line is nt capable t emit particulate that quantity itself. The Bard Line has the PTE tpy f uncntrlled particulate. Emissin Mnitring: A mnitring device that cntinuusly measures and recrds the firebx temperature f the afterburner n the curing ven shall be installed, calibrated, maintained, and perated. (ADEM Admin. Cde (9)) Instruments which measure the pressure drp acrss the filterhuses shall be maintained and perated. (ADEM Admin. Cde ) During the annual cmpliance test, minimum pressure drps shall be determined fr the filterhuses. (ADEM Admin. Cde ) Pressure drp acrss each filterhuse shall be mnitred and recrded daily, except when the surce f pllutin t the filterhuse is nt being perated. (ADEM Admin. Cde ) An emissins test n Stack 102 is t be cnducted fr ttal PM at intervals nt t exceed ne year fllwing the date f previus cmpliance testing. All test reprts must be submitted t the Department within 30 days f cmpletin f testing. (ADEM Admin. Cde ) 22

23 An peratins, maintenance, and mnitring plan must be submitted t the Administratr fr review and apprval as part f yur applicatin fr the title V permit. (40 CFR (a) Subpart DDD) The fllwing prcedures must be dne t establish the average perating temperature f the curing ven incineratr: During the perfrmance test, the facility must establish the average perating temperature f an incineratr as fllws: Cntinuusly measure the perating temperature f the incineratr. Determine and recrd the average temperatures in cnsecutive 15-minute blcks. Determine and recrd the arithmetic average f the recrded average temperatures measured in cnsecutive 15-minute blcks fr each f the nehur perfrmance test runs. Determine and recrd the arithmetic average f the three ne-hur average temperatures during the perfrmance test runs. The average f the three nehur perfrmance test runs establishes the temperature level t use t mnitr cmpliance. T cmply with the requirements fr maintaining the perating temperature f an incineratr after the perfrmance test, the facility must measure and recrd the average perating temperature f the incineratr as required by and f this subpart. This average perating temperature f the incineratr is based n the arithmetic average f the ne-hur average temperatures fr each cnsecutive three-hur perid and is determined in the same manner described in paragraphs (a)(1) thrugh (a)(4) f this sectin. The facility may change cntrl device and prcess perating parameter levels established during perfrmance tests and used t mnitr cmpliance if yu d the fllwing: The facility must ntify the Administratr f yur desire t expand the range f a cntrl device r prcess perating parameter level. Upn apprval frm the Administratr, yu must cnduct additinal perfrmance tests at the prpsed new cntrl device r prcess perating parameter levels. Befre perating at these levels, the perfrmance test results must verify that, at the new levels, yu cmply with the emissin limits in and f this subpart. The peratins, maintenance, and mnitring plan must include the fllwing: (40 CFR (b) Subpart DDD) Prcess and cntrl device parameters yu will mnitr t determine cmpliance, alng with established perating levels r ranges fr each prcess r cntrl device. A mnitring schedule. 23

24 Prcedures fr prperly perating and maintaining cntrl devices used t meet the standards in and f this subpart. These prcedures must include an inspectin f each incineratr at least nce per year. At a minimum, yu must d the fllwing as part f an incineratr inspectin: Inspect all burners, pilt assemblies, and pilt sensing devices fr prper peratin. Clean pilt sensr if necessary. Ensure prper adjustment f cmbustin air, and adjust if necessary. Inspect, when pssible, all internal structures (such as baffles) t ensure structural integrity per the design specificatins. Inspect dampers, fans, and blwers fr prper peratin. Inspect mtrs fr prper peratin. Inspect, when pssible, cmbustin chamber refractry lining. Clean, and repair r replace lining if necessary. Inspect incineratr shell fr prper sealing, crrsin, and/r ht spts. Fr the burn cycle that fllws the inspectin, dcument that the incineratr is perating prperly and make any necessary adjustments. Generally bserve whether the equipment is maintained in gd perating cnditin. Cmplete all necessary repairs as sn as practicable. Prcedures fr keeping recrds t dcument cmpliance. Crrective actins yu will take if prcess r cntrl device parameters vary frm the levels established during perfrmance testing. Recrdkeeping and Reprting Requirements: A semi-annual mnitring reprt shall be submitted t the Department accrding the fllwing schedule: (ADEM Admin. Cde (c)(3)) Reprting Perid January 1 st t June 30 th July 1 st t December 31 st Due Date August 31 st February 28 th A reprt shall be submitted semi-annually which cntains the fllwing: The perids when the temperature f the afterburner n the curing ven was belw 1200 F and the crrective actin take; The perids when the pressure drps acrss the filterhuses were belw the minimum pressure determined during the annual stack tests; All recrd shall be maintained fr a minimum f 5 years. (ADEM Admin. Cde (c)(2)) This surce shall cmply with the ntificatin requirements specified in (40 CFR Subpart DDD) 24

25 The facility must meet the fllwing recrdkeeping requirements: (40 CFR Subpart DDD) Maintain files f all infrmatin required by 63.10(b) f the general prvisins in subpart A f this part, including all ntificatins and reprts. Maintain recrds f the fllwing infrmatin als: All bag leak detectin system alarms. Include the date and time f the alarm, when crrective actins were initiated, the cause f the alarm, an explanatin f the crrective actins taken, and when the cause f the alarm was crrected. The free-frmaldehyde cntent f each resin lt and the binder frmulatin, including frmaldehyde cntent, f each binder batch used in the manufacture f bnded prducts. Incineratr perating temperature and results f incineratr inspectins. Fr all perids when the average temperature in any three-hur blck perid fell belw the average temperature established during the perfrmance test, and all perids when the inspectin identified incineratr cmpnents in need f repair r maintenance, include the date and time f the prblem, when crrective actins were initiated, the cause f the prblem, an explanatin f the crrective actins taken, and when the cause f the prblem was crrected. Retain each recrd fr at least five years fllwing the date f each ccurrence, measurement, crrective actin, maintenance, recrd, r reprt. The mst recent tw years f recrds must be retained at the facility. The remaining three years f recrds may be retained ff site. Retain recrds n micrfilm, n a cmputer, n cmputer disks, n magnetic tape disks, r n micrfiche. Reprt the required infrmatin n paper r n a labeled cmputer disk using cmmnly available and cmpatible cmputer sftware. The facility must prepare and submit reprts t the Administratr as required by this subpart and f the general prvisins in subpart A f this part. These reprts include, but are nt limited t, the fllwing: A perfrmance test reprt, as required by 63.10(d)(2) f the general prvisins in subpart A f this part, that dcuments the prcess and cntrl equipment perating parameters during the test perid, the test methds and prcedures, the analytical prcedures, all calculatins, and the results f the perfrmance tests. A startup, shutdwn, and malfunctin plan, as described in 63.6(e)(3) f the general prvisins in subpart A f this part, that cntains specific prcedures fr perating and maintaining the surce during perids f startup, shutdwn, and malfunctin and a prgram f crrective actin fr malfunctining prcess and cntrl systems used t cmply with the emissin standards. In additin t the infrmatin required by 63.6(e)(3), yur plan must include the fllwing: Prcedures t determine and recrd what caused the malfunctin and when it began and ended. 25

26 Crrective actins yu will take if a prcess r cntrl device malfunctins, including prcedures fr recrding the actins taken t crrect the malfunctin r minimize emissins. An inspectin and maintenance schedule fr each prcess and cntrl device that is cnsistent with the manufacturer's instructins and recmmendatins fr rutine and lng-term maintenance. A reprt f each event as required by 63.10(b) f the general prvisins in subpart A f this part, including a reprt if an actin taken during a startup, shutdwn, r malfunctin is incnsistent with the prcedures in the plan as described in 63.6(e)(3) f the general prvisins in subpart A f this part. An peratins, maintenance, and mnitring plan as specified in f this subpart. A semiannual reprt as required by 63.10(e)(3) f the general prvisins in subpart A f this part if measured emissins exceed the applicable standard r a mnitred parameter varies frm the level established during perfrmance testing. The reprt must cntain the infrmatin specified in 63.10(c) f the general prvisins, as well as the relevant recrds required by (b) f this subpart. A semiannual reprt stating that n excess emissins r deviatins f mnitred parameters ccurred during the reprting perid as required by 63.10(e)(3)(v) f the general prvisins in subpart A f this part if n deviatins have ccurred. Semi-annual mnitring reprt required by 40 CFR 63 Subpart DDD shall be submitted t the Department accrding the fllwing schedule: (40 CFR 60.10(a)(5)) Reprting Perid January 1 st t June 30 th July 1 st t December 31 st Due Date August 31 st February 28 th Emissins: Emissin data is based n AP-42 emissins factr and mass balance. Per air permit applicatin frms submitted, emissins frm these units are as fllws: Emissin Pint Pllutant Allwable Expected Emissins Emissins (lb/hr) (TPY) (lb/hr) (TPY) 102 CO PM* NOx VOC SO CO2e 1,991 8, Ttal HAP * - cmbined limit 26