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Phillip Fielder, PE, Chie DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM June 28, 2019 TO: Phillip Fielder, P.E., Chief Engineer THROUGH: Richard Groshong, Env. Programs Manager, Compliance & Enforcement THROUGH: Phil Martin, P.E., Manager, Existing Source Permits Section THROUGH: Ryan Buntyn, P.E., Existing Source Permits Section FROM: Iftekhar Hossain, P.E., New Source Permits Section SUBJECT: Evaluation of Permit Application No. 2018-0681-TVR2 Elliott Manufactured Homes, Inc. Glas-Pro Division Fiberglass Molding Facility Facility ID: 5700 Section 31, T3S, R7W, Jefferson County, Oklahoma Latitude: 34.24749° Longitude: -97.96698° Location: 100 W. Eva, Addington, Oklahoma 73520 I. INTRODUCTION Elliott Manufactured Homes, Inc. (Elliott) has requested to renew their existing major source Operating Permit No. 2012-1199-TVR that was issued November 26, 2013, for their existing Fiberglass Molding Facility (SIC 3088). No changes have been made to the facility since the issuance of last permit (No. 2012-1199-TVR). The applicant has been manufacturing shower tubs and stalls since before March 6, 1996. Elliott manufactures fiberglass shower tubs, stalls and other related products for use in the manufactured and residential home building industry. Units are manufactured utilizing an open mold process. Hazardous air pollutants (HAPs) are generated and released from the fabrication process. The primary HAP generated from the facility is styrene, which is generated from the gelcoats and resins used in the fabrication processes. Particulate matter (PM) is generated during the sanding and finishing process and is filtered prior to air being exhausted to the outside. The applicant requests that a 75 TPY facility-wide Hazardous Air Pollutants cap continue as the facility emission limit. Emissions will be calculated and documented on a 12-month rolling total. No 12-month period will exceed the requested 75 TPY facility-wide Hazardous Air Pollutant cap. PERMIT MEMORANDUM NO. 2018-0681-TVR2 DRAFT 2 Potential to Emit Based on 8,760 hours per year operations and assuming that: 1) with adequate storage/drying capacity, 2) with one person devoted “full-time” applying gelcoat in one spray booth and one spray gun, 3) with another person working “full-time” applying resin/fiberglass with one “chop gun”, then Glas-Pro has the capacity to produce approximately 90 units per day (approximately 30,000 units per year), which could produce 36.00 TPY of HAPs. Glas-Pro’s current level of operations is 8 hours/day (0530 to 1400), for a total of 2,080 hr/yr producing approximately 4,000 units per year with approximately 4.49 TPY of HAPs. However, Elliot is requesting an operating permit for the Glas-Pro facility to allow a maximum actual of 75 TPY of HAPs for 8,760 hr/yr operations. Since the facility requests that 75 TPY of HAPs to continue as the facility-wide emission limit, it is subject to Part 70 permitting requirements and its renewal process needs to go through the Tier II permitting category. Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) as shown in the “Equipment" section below (SECTION III). II. PROCESS DESCRIPTION The Glas-Pro facility is primarily involved in the manufacturer and storage of reinforced fiberglass products, such as shower tubs, stalls and other related items. Resin Tank: Resin from the 5,400 gallon above-ground storage tank (AST) is plumbed into the building for application of resin to the molds. There are working and breathing losses from this tank. Spray Booth (Gelcoat Spray Gun): The current production method is an open-mold spray operation performed with a single spray gun in a single spray booth (with filters). The pre-manufactured molds are coated with a non-vapor suppressed gelcoat, with a non-atomized spray gun. It takes a worker approximately 5 to 7 minutes to completely and adequately cover the mold. Curing: After the mold is coated, it is allowed to sit and “cure” (dry). Fiberglass and Resin Application (Chop Floor/Chop Gun): The unit/mold is then moved to the “chop floor.” A single “chop gun” is used to apply fiberglass and resin to the back of the unit. This process is a non-atomized mechanical resin application with a non-vapor suppressed resin. Resin is pumped in from the 5,400 gallon above-ground resin storage tank into the building for application of resin to the molds. This process takes about 7 to 8 minutes per unit. Grinding/Sanding: After the resin has dried, the unit is removed from the molds and may undergo a limited amount of grinding, sanding and polishing. PERMIT MEMORANDUM NO. 2018-0681-TVR2 DRAFT 3 Storage: The units are then stored until shipment. Heaters: Propane heaters are used to heat the inside of the building during cold periods. III. EQUIPMENT The process operations occur in one building. The equipment is listed in the table below. EQUIPMENT Construction/ Point EU ID EU Name/Model Modification ID Date EUG 1 1.00 Spray Booth No. 1 4/2004 Filter Type-Supra II 20” x 20” Pad (or equivalent), Filter Replacement Frequency – once a week or when the 2005 manometer reaches 0.10 inches per water Manometer Type – Dwyer Mark II No. 25 Inclined- 2005 Vertical Manometer. Gelcoat spray gun 2005 Resin Chop Gun 2005 EUG-2 F01 Fugitive Emissions N/A EUG 3 T01 5,400 gallon Resin Storage Tank 1/1998 Open transfer containers 2001 Open molds 1973 AEM Sander 2001 Spray Gun Equipment Number of Make Model Model No. Coating Pump Pressures Units BINKS ‘LEL’ Binks 1 102-3610 GelCoat 45-50 psi Gel Coat BINKS ‘LEL’ Binks 1 102-3655 Resin 45-50 psi Chop The spray guns utilize impinging fluid streams at low pressure to generate low velocity resin and gelcoat fans and are therefore defined by NESHAP 40 CFR part 63 as non-atomizing. IV. EMISSIONS Emissions from the fiberglass fabrication process consist of HAP (mainly styrene) that are also Volatile Organic Compounds (VOC) and are considered organic HAP. HAP emissions originate from several points located within the building but are primarily generated in the spraying booth during gel coating and from the chop floor area during resin application. PERMIT MEMORANDUM NO. 2018-0681-TVR2 DRAFT 4 As required in §§ 63.5796, 63.5799(a)(1) and (b), and 63.5810(a)(1), to calculate organic HAP emission factors for specific open molding process streams, a facility must use the equations in Table 1 of Subpart WWWW, which is reproduced on the following pages. The emission factors calculated using Table 1 of Subpart WWWW are in pounds of organic HAP emitted per ton of resin or gelcoat used and are based on the resin/gelcoat organic HAP content. HAP emission estimates from the use of resins and gelcoats were then calculated using the required NESHAP (Subpart WWWW) emission factors that were calculated using the equations in Table 1 of Subpart WWWW. Potential emissions from the use of the resins and gelcoats are based on the emission factors for the resin/gelcoats with the highest organic HAP content and the maximum estimated material usage. All other VOC/HAP emissions from other processes are based on the maximum VOC/HAP content of the material and material usage. All of these VOC/HAP’s are assumed to be emitted to the atmosphere. A small amount of particle matter will result from overspray of the material. The particulate emissions were calculated with 95% transfer efficiency and 95% collection efficiency. PM emission calculations demonstrate that the PM generated and collected in the finishing processes for the reinforced fiberglass production are less than 5 TPY and is therefore an insignificant activity. Emission calculations for heaters demonstrate that emissions of criteria pollutants are less than 5 TPY and are therefore an insignificant activity. The following is a list of emission points for Elliott: EUG-1: Spray Booth No.1 (Gelcoat Spray Gun). EUG-1: Fiberglass and Resin Application (Chop Floor/Chop Gun). EUG-2: Fugitive Emissions. EUG-3: 5,400 gallon Resin Storage Tank. EUG-1: Spray Booth No.1 (Gelcoat Spray Gun) and Fiberglass and Resin Application (Chop Floor/Chop Gun). Maximum capacity for this emission source will be based on the most conservative MACT material composition limits and calculations. The gelcoat operation is an open mold, non-atomized spray gelcoat application of a nonvapor-suppressed white/off white pigmented gelcoat. The fiberglass operation is an open mold, non-atomized mechanical (chop gun) resin application of a nonvapor-suppressed resin. The material used and emission calculations were determined with the maximum HAP composition limit allowed in Subpart WWWW Table 3. Gelcoats containing styrene are the only material used in the spray booth and thus the only air pollutant emitted. Maximum capacity is based on a ratio of existing number of units produced/material used vs. projected production/material usage. In 2005, a total of 3,790 units were produced using 41,225 PERMIT MEMORANDUM NO. 2018-0681-TVR2 DRAFT 5 lbs of gelcoat and 149,399 lbs of resin. At a maximum capacity of 30,000 units, it is projected that 326,319 lbs of gelcoat and 1,182,577 lbs of resin would be used resulting in a total of 36.00 TPY of organic HAP’s. Maximum capacity emissions are calculated using the emission factors in Table 1 of Subpart WWWW and the emission limits are derived from the equations in Table 3 of Subpart WWWW. EUG-2: Fugitive Emissions. Facility-wide, plant-wide fugitive emissions are from the manufacturing of fiberglass tubs, showers and other related items. This includes any fugitive emissions from the curing of resins and gelcoats once the units are removed from the spray booth.
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