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VERMONT AGENCY OF NATURAL RESOURCESDepartment of Environmental ConservationAir Quality & Climate DivisionTECHNICAL SUPPORT DOCUMENT FOR PERMIT TO CONSTRUCT AND OPERATE#AOP-18-020PIN# RU96-068permit dateEnergizer Manufacturing – Bennington, VTOwner/Operator:Energizer Manufacturing, Inc.401 Gage StreetBennington, Vermont 05201-0440Source:Energizer Battery Manufacturing Plant401 Gage StreetBennington, Vermont 05201Prepared By: Philip Cannata, Environmental EngineerAir Quality & Climate DivisionThis Technical Support Document details the Agency of Natural Resources, Department of Environmental Conservation, Air Quality & Climate Division review for the Air Pollution Control Permit to Construct and Operate and is intended to provide additional technical information, discussion and clarification in support of the Permit. It is not intended to provide a comprehensive review of the Facility or permit process or duplicate the information contained in the Permit.1.0INTRODUCTIONEnergizer Battery Manufacturing, Inc. (also referred to herein as "Permittee") owns and operates a battery manufacturing plant in Bennington, Vermont (also referred to herein as "Facility"). The Facility is classified within the Standard Industrial Classification Code - 3692 (Industry: Primary Batteries, Dry and Wet) and within the North American Industry Classification System (NAICS) 335912. The Facility is located on approximately 9 acres surrounded by residential and commercial property. The manufacturing processes are housed in two (2) buildings consisting of Plant 1 and Plant 2, totaling roughly 295,000 square feet, combined. The boilers are housed in a third building known as the Heating Plant and are fired on distillate fuel oil and compressed natural gas. The decompression system for the compressed natural gas (CNG) at the Facility is owned and operated by NG Advantage. The anticipated emissions from the unloading system is small, and the heater is below the Agency’s regulatory thresholds, so NG Advantage is not required to apply for an Air Pollution Control Permit to Construct for the CNG unloading system. The Permittee's equipment 'starts' at the gas meter, so the emissions from the operation of the unloading system are not included in the Permit review. The following is a description of the unloading system. The CNG off-loading station will consist of off-loading bays to allow a second or third full trailer to be dropped off before the first is empty. The Unloading System (“System”) is an integrated packaged process system designed to depressurize and transport CNG from a highly compressed state as delivered in tube trailers to a low-pressure gas at the Facility’s main building regulator. During the depressurization process in the System, the gas cools precipitously and heat must be continuously added to stop the freezing of process equipment. The System is comprised of two principal modules: the Unloading Skid Module (“USM”) and Gas Heating Module (“GHM”). The CNG in the trailers flows though reinforced hoses to the USM. The USM consists of process equipment, instruments, piping, valves and controls that regulate the pressure and temperature of the gas as it depressurizes. The process equipment and controls regulate the gas to process values and tolerances specified to meet the Permittee’s requirements. The GHM adds heat to the CNG prior to depressurization. A high-efficiency condensing boiler will use natural gas from the low-pressure side of the System (but prior to the Facility’s meter) to heat a 50/50 mix of ethylene glycol and water in a closed loop, consisting of pumps, pipes, and a heat exchanger. Once heated, the water/glycol mix will transfer heat to the cold CNG. One side of the heat exchanger will be high pressure CNG, and the other low-pressure water/glycol mix. The GHM will be fitted with a water and glycol make up system, based on delivering the make up glycol from a premixed storage tank. Administrative MilestonesTable 1-1: Administrative SummaryAdministrative ItemResult or DateDate Application Received:04/11/2018Date Administratively Complete:04/12/2018Date & Location Receipt of Application Noticed:04/12/2018Environmental Notice BulletinDate Technically Complete:04/01/2019Date Draft Decision:04/01/2019Date & Location Draft Decision/Comment Period Noticed:04/01/2019Environmental Notice BulletingDate & Location Public Meeting Noticed:None requestedDate & Location of Public Meeting:None requestedDeadline for Public Comments:04/15/2019Date Proposed Decision:Classification of Source Under 5-401:§5-401(6)(a) Fossil fuel-burning equipmentClassification of Application:Subchapter X Major SourceNew Source Review Designation of Source:Minor Stationary SourceFacility SIC Code(s):3692Facility SIC Code Description(s):Primary Batteries, Dry and WetThe allowable emissions for the Facility are summarized below:Table 1-2: Estimated Air Contaminant Emissions (tons/year)1PM / PM10 / PM2.5SO2NOxCOVOCTotal HAPsCO2e 227.90.15.42.8< 8.7< 6.15,112.51PM/PM10/PM2.5 - particulate matter, particulate matter of 10 micrometers in size or smaller and particulate matter of 2.5 micrometers in size or smaller, respectively (unless otherwise specified, all PM is assumed to be PM10 and PM2.5); SO2 - sulfur dioxide; NOx - oxides of nitrogen measured as NO2 equivalent; CO - carbon monoxide; VOCs - volatile organic compounds; HAPs - hazardous air pollutants as defined in §112 of the federal Clean Air Act.2CO2e ‘at the stack’ – includes emissions from biogenic sources. See section 3.3 for details. This is not a facility limit.2.0FACILITY DESCRIPTION AND LOCATION2.1Facility Locations and Surrounding AreaThe Permittee owns and operates the battery manufacturing plant located at 401 Gage Street in the city of Bennington, Vermont. The Facility is located approximately 15 miles south west of the Class I Federal Air Shed at Lye Brook Wilderness Area outside of Manchester, Vermont and greater than 100 miles from the Class I Federal Air Sheds at Great Gulf and Dry River Wilderness Areas in the Mount Washington Valley of New Hampshire. The Facility is located in downtown Bennington, Vermont. Mount Antony Union High School is located less than a half mile to the north. Memorial Park is located less than a half mile to the east. Southern Vermont College is located approximately 1.5 miles to the southwest. Residential households are located directly adjacent to the Facility on the north and west sides of the plant. 2.2Facility DescriptionCurrently, the Facility makes miniature “button” cell batteries for watch, hearing aid, calculator, camera, clock and portable electronic devices ranging in size from a ?” to ?” inch in diameter. The Facility is listed under the Standard Industrial Classification ("SIC") Code #3692, Primary Batteries, Dry and Wet. The production process for each line is similar. However, differences occur in the electrolyte mixture and the size of the equipment. The Facility also operates two (2) additional support operations including nylon gasket extrusion and packaging/printing operations. Historically, mercury containing button cells were manufactured at this location. However, the Facility no longer manufactures mercury containing button cells. Gasket cleaning was previously performed with trichloroethylene (CAS# 79-01-6). This process was ducted to the carbon adsorption unit as it was the only process at the Facility generating trichloroethylene emissions. For this permitting action, the Facility has proposed to perform the gasket cleaning process with isopropyl alcohol (CAS# 67-63-0) and decommission the carbon adsorption system.2.2.1Miniature Alkaline Cell Assembly ProcessThis process begins by adding a drop of either potassium hydroxide (CAS# 1310-58-3) or sodium hydroxide (CAS# 1310-73-2) to cathode cans. Silver oxide (CAS# 20667-12-3), nickel oxosilver or manganese dioxide (CAS# 1313-13-9) are then added in a pelletized form to the cathode cans. Next, barrier and/or soak up separators are pressed onto the cathode cans. This process occurs in Plant 1. Anode Cup Manufacturing Process (Off-Line Operation)Anode cups are manufactured from strips of various types of metal. This operation is located on the 1st floor of Plant 1. Cathode Can Manufacturing Process (Off-Line Operation)Miniature alkaline cathode cans are manufactured from metal. This operation is located the 1st floor of Plant 1. Electrolyte Addition to Cathode Can (Cell Assembly)This process involves dispensing a small amount of electrolyte into each cathode can. This process is located Plant 1 Floor 1. Cathode Pellet Manufacturing (Off-Line Operation)This process involves pressure molding cathode pellets that provide the oxidizing half of the electrochemical battery cell. Cathode pellet manufacturing operations occur on floors 1 and 2 of Plant 1. These operations are vented to dust collectors DC #2 and DC #3. Barrier Separator Process (Cell Assembly)This process mechanically presses a laminate separator material onto the cathode to ensure separation from the anode portion of the battery. Gasket Molding Process (Off-Line Operation)The Facility operates multiple injection molding machines, located on the 1st floor of Plant 2, that are used to manufacture miniature alkaline battery gaskets. The injection molding machines vent to blowers F72 and F21 which result in uncontrolled emissions of nitrogen oxide to the ambient atmosphere. Finished gaskets are transferred to the gasket coating process. Gasket Coating Process (Off-Line Operation)The gasket coating process occurs on the 1st floor of Plant 1. Trichloroethylene is currently emitted from the gasket coating tank and hood, tumbler, rag barrel, drying oven and cooling cabinets; however, isopropyl alcohol will replace the trichloroethylene used in this process. Every one of these emission points are equipped with various pick-ups and hoods which deliver the process air to the carbon adsorption system (Vent F68). Once the process is performed with Isopropyl alcohol (IPA), the carbon adsorption system will be decommissioned, and the IPA will be vented uncontrolled to the atmosphere. Coated gaskets are then placed in a drying oven to cure. After drying, gaskets are transferred to cooling cabinets where they are allowed to return to ambient temperature. At that point, the gaskets are ready for insertion into the battery assembly. Gasket Insertion Station (Cell Assembly)This process involves gaskets being oriented and fed into the insertion station where a punch places the gaskets into the half cells. Electrolyte Addition to the Completed Half-Cell (Cell Assembly)This process injects a salt solution and water to complete half cells. Anode Gel Manufacturing (Off-Line Operation)Anode gel is manufactured on the 1st floor of Plant 1. Anode gels are manufactured to specific formulations depending on the cell type. Areas ventilated in the gel manufacturing room include the gel blending pot, metallic mercury weighing station, gel strainer and satellite hazardous waste accumulation area. Dust producing operations are vented to dust collector F/D7 while mercury vapor operations are vented to F/D19 and F67. Anode Mating Station (Cell Assembly)This process mates the anode cup with the half cell. Cell Swaging Station (Cell Assembly)This process swages the cell together forming the primary seal. Jet Spray Station (Cell Assembly)This process spray washes the cell with water in preparation for crimping. Cell Crimping Station (Cell Assembly)This process crimps the cell forming a secondary seal and setting the cell to final dimensions. Final Wash Station (Cell Assembly)This process gives the cells a final wash and rinse with water prior to final inspection and packaging. 2.2.2Miniature Zinc Air Cell Manufacturing ProcessThis process follows a production sequence similar to the miniature alkaline cell assembly and occurs on the Floor 3 of Plant 2.Air Electrode Mix Manufacturing (Off-Line Operation)This operation manufactures manganese dioxide and is located on Floor 3 of Plant 2. Water is added to the final mix. Nitrogen oxide is a byproduct of this process and is exhausted to the ambient atmosphere. Air Electrode Sandwich Manufacturing (Off-Line Operation)The electrode sandwich process is located on 2nd floor of Plant 2. The air electrode mix is rolled into a mix foil and vented to dust collector F/02. A metal screen is added to the mix and added to the cathode can. Parts Manufacturing (Off-Line Operation)This process adds a non-conductive gasket to the finished anode cups. Air Cell Gasket Coating (Off-Line Operation)This process involves coating each gasket with an adhesive / trichloroethylene mixture. Trichloroethylene is emitted from the gasket coating tank and hood, tumbler, rag barrel, drying oven and cooling cabinets. Every emission point is equipped with various pick-ups and hoods which deliver the process air to the carbon adsorption system (Vent F68). Coated gaskets are then placed in a drying oven to cure. After drying, gaskets are transferred to cooling cabinets where they are allowed to return to ambient temperature. At that point, the gaskets are ready for insertion into the battery assembly. Zinc Screening/Blending/Packaging (Off-Line Operation)In this process Zinc product and binder are mixed and transferred to a hopper to be used on the cell assembly line. This process vents to dust collector F/D21. Can Sealant Placement (Off-Line Operation)In this process, a drop of adhesive is placed at the center of the can and to insure that a good seal exists between the edge of the air diffusion membrane and the cathode can bottom, an adhesive compound (adhesive and isobutyl alcohol) is placed around the inside radius of the can. Anode Cup/Gasket Mating (Off-Line Operation)This process mates the anode cup with the gasket using an adhesive mix including adhesive and isobutyl alcohol. Air Distribution Layer Punch and Placement (Off-Line Operation)This process adds a membrane to the center of the cathode where it is held in place with an adhesive. Air Electrode Sandwich Punch and Placement (Off-Line Operation)This process adds an air electrode sandwich to the cathode can. Zinc Dispensing Station (Cell Assembly)This process feeds the zinc mixture from the hopper into pre-mated anode cups. Electrolyte Dispensing Station (Cell Assembly)This process dispenses electrolyte into the zinc mixture.Anode/Cathode Mating Station (Cell Assembly)This process mates the two half cells. The mated cell is transferred to the exit conveyor. Closing Station (Cell Assembly)The operation physically closes each cell and forms them to final dimension. Cell Taping Station (Cell Assembly)This operation places cells on tape as the final step in the production process. Activation Station (Cell Assembly)This process involves using a mechanical accelerator to activate each cell. Auto Cell Wash Station (Cell Assembly)This process washes and dries each cell. 2.3Description of Equipment Specifications and Control Equipment SpecificationsUpon issuance of Permit #AOP-18-020, the Facility will consist of the following equipment and control devices as listed below in Table 2-1 and Table 2-2, respectively: Table 2-1: Equipment SpecificationsBoilersCapacity/Size 1MMBTU/hr (hp)Fuel Type 2Date of Manufacture(installation)Boiler #2 Cleaver Brooks CB657-30012.5CNG/No.21966Boiler #3 Cleaver Brooks CB657-30012.5CNG/No.21966Boiler #4 Superior Boiler Works 7-X-500-S150-M4.01CNG/No.22018Emergency Diesel GeneratorsCapacitybhp (kW)Fuel TypeDate of Manufacture(installation)Kohler (Plant 1)158 bhp (100 kW)ULSD11/2007Kohler (Plant 2)100 bhp (30 kW)ULSD03/2000Chillersmax. capacitytons/hrdate of installationTwo (2) Heatcraft Model: WCU3000H2DS/N: A04K00011S/N: A04K0001070 (each)R-22-One (1) TRANE Model: RTWD130F2D01A1A1AA2A1Y1E000010000000200100D0S/N: U14E09293260R-134a-1 MMBTU/hr - Million British Thermal Units per hour maximum rated heat input. bhp – brake horsepower rated output as specified by the manufacturer. kW – generator kilowatt electrical output.2 CNG – Compressed Natural Gas. No. 2 – Distillate fuel oil not to exceed 0.0015% sulfur by weight. ULSD – Ultra-low sulfur diesel not to exceed 0.0015% sulfur by weight.Control Equipment SpecificationsDeviceProcess ServedControl Efficiency, % 1,2Carbon Adsorption System (Vent F68) 3 Vara International Single Bed Carbon Adsorption SystemProject #PC-12492MFG Date: 1992To be decommissioned in 2019Gasket Coating Process (Off-Line Operation)Floor 1 Plant 197% 4Torit DC #19 Cartridge FilterFloor 2 Plant 1 Silver Pellet Manufacturing90.0% efficient for particles 0.3-10 microns in size or larger. 12.3 to 1 Air to Cloth Ratio7,431 acfmTorit DC #2 Cartridge FilterFloor 1 Plant 1 Silver Pellet Manufacturing90.0%efficient for particles 0.3-10 microns in size and larger.0.8 to 1 Air to Cloth Ratio3,314 acfmTorit DC #3 Cartridge FilterFloor 1 Plant 1 Silver Pellet Manufacturing90.0% efficient for particles 0.3-10 microns in size or larger.0.9 to 1 Air to Cloth Ratio3,533 acfmSly DC #8 Fabric FilterFloor 1 Plant 199.9% efficient for particles 2.0 microns in size or larger.2.2 to 1 Air to Cloth Ratio7,431 acfmSly DC #9 Fabric Filter (internally vented)Floor 2 Plant 1 Watch & Electronics Pellet Bowls99.9% efficient for particles 1.0 microns in size or larger.1.1 to 1 Air to Cloth Ratio.3,859 acfmSpencer #10 Fabric FilterFloor 1 Plant 1 Watch & Electronics House Vacuum & Process Vac99% efficient for particles 1.0 microns in size or larger.5.1 to 1 Air to Cloth Ratio2,250 acfmHoffman DC #11 Fabric FilterFloor 2 Plant 1 Building 23 House Vacuum & Process Vac99+% efficient for particles 1.0 microns in size and larger.2.3 to 1 Air to Cloth Ratio1,052 acfmHoffman DC #12 Fabric FilterFloor 2 Plant 1 Silver Pellet Manufacturing99+% efficient for particles 1.0 microns in size and larger.5.8 to 1 Air to Cloth Ratio1,290 acfmTorit DC #20 Cartridge FilterFloor 2 Plant 1 Silver Pellet Manufacturing90.0% efficient for particles 0.3-10 microns in size and larger.5.8 to 1 Air to Cloth Ratio3,533 acfmTorit DC #23Model DFO 3-3Serial #4135015AFloor 1 Plant 1 Zero Mercury Gel Room for the Collection of Zinc99.99% efficient fo particles 0.5 micros in size and larger.Filter Area: 570 sq. ft.Filter Rating: MERV 13Nominal Air Flow: 300 to 2400 cfmType of filter: Oval Nanofiber Cartridge (total of 3 Cartridges)1 Based on 100% capture efficiency.2 acfm – actual cubic feet per minute.3 Carbon adsorption system equipped with a flame ionization detector (FID) Model 400A monitoring device.4 Value based on equipment specification presented in original application.2.4Description of Compliance Monitoring Devices This Facility is not equipped with devices to continuously monitor the emission of air contaminants to the ambient air.2.5Proposed Modifications to FacilityThe Permittee has not proposed to modify the Facility. 2.6Identification of Sources with Insignificant or Negligible EmissionsAlthough not required for determining applicability with Subchapter X, quantifiable emissions from “insignificant activities” must be included for the purposes of establishing whether or not a source is subject to other air pollution control requirements, including, but not limited to: reasonably available control technology, major source status, and Title V operating permit applicability.Additionally, guidance provided by the U.S. EPA (entitled “White Paper for Streamlined Development of Part 70 Permit Applications”) lists activities which are considered as “trivial” sources of air contaminants, and may be presumptively omitted from operating permit applications.Table 2-3 lists activities at the Facility which were considered negligible or exempt sources of air contaminant emissions, and therefore were not considered as emission sources as part of the Operating/Construction Permit review. Table 2-3: Negligible Sources of Contaminant EmissionsMaintenance Department Paint Spray AreaPaint spray area consists of one spray booth. Annual paint consumption consists of less than the equivalent of 100 aerosol type cans.It should be noted that a process or piece of equipment which is considered a “negligible activity” does not relieve the owner or operator from the responsibility of complying with any applicable requirements associated with said process or equipment.2.7Proposed LimitationsThe Permittee has proposed to limit fuel usage in the boilers to less than 63,000 MMBtu of No.2 fuel oil or compressed natural gas in order to remain below major source thresholds. 3.0quantification of pollutantsThe quantification of emissions from a stationary source is necessary in order to establish the regulatory review process necessary for the operating permit application and to determine applicability with various air pollution control requirements. These determinations are normally based upon allowable emissions. Allowable emission is defined as the emission rate calculated using the maximum rated capacity of the source and, if applicable, either: (a) the applicable emission standard contained in the Regulations, if any, or (b) the emission rate or design, operational or equipment standard specified in any order or agreement issued under the Regulations that is state and federally enforceable. An applicant may impose in its application an emission rate or design, or an operational or equipment limitation which may be incorporated in the Permit to restrict operation to a lower level. Such limitations may include fuel restrictions or production limits. 3.1Estimating Potential Emission of Criteria Pollutants from the Existing Stationary SourceTable 3-1: Multi-Fuel Boiler Allowable EmissionsFuel input for boiler: No.2 Fuel Oil: 450,000 gallons/yr 0.015% sulfur (63,000 MMBtu/year)Compressed Natural Gas: 61,764,706 scf/year (63,000 MMBtu/year)PollutantEmission FactorAllowable Emissions (tons per year)FactorUnits 1,2SourceSO2Oil142Slb/1000 galAP-42, Table 1.3-1 (9/98)0.05CNG0.6lb/10^6 scfAP-42, Table 1.4-2 (7/98)0.02NOxOil20lb/1000 galAP-42, Table 1.3-1 (9/98)4.50CNG100lb/10^6 scfAP-42, Table 1.4-1 (7/98)3.09PMOil3.3lb/1000 galAP-42, Table 1.3-1 and 1.3-2 (9/98)0.74CNG7.6lb/10^6 scfAP-42, Table 1.4-2 (7/98)0.23COOil 5lb/1000 galAP-42, Table 1.3-3 (9/98)1.13CNG84lb/10^6 scfAP-42, Table 1.4-1 (7/98)2.59VOCOil 0.34lb/1000 galAP-42, Table 1.3-1 (9/98)0.08CNG5.5lb/10^6 scfAP-42, Table 1.4-2 (7/98)0.17HAPsOil0.062lb/1000 galAP-42, Table 1.3-8 and 1.3-9 (9/98)0.01CNG1.89lb/10^6 scfAP-42, Table 1.4-3 and 1.4-4 (7/98)0.061 lb/1000 gal: pounds of pollutant emitted per 1 thousand gallons of fuel oil input to the boiler 2 lb/10^6 scf: pounds of pollutant emitted per 1 million standard cubic feet on natural gas input to the boiler.Table 3-2: Diesel Engines – Estimated Emissions100 kW Kohler (Plant 1) and 30 kW Kohler (Plant2): 200 hours/year eachPollutantEmission FactorAllowable Emissions (ton/yearFactorUnitsSourceSO21.01S1lb/MMBtu 2AP-42, Chapter 3, Stationary Internal Combustion Sources, Large Stationary Diesel and All Stationary Dual-fuel Engines, Table 3.4-1 (10/1996)0.01PM0.31AP-42, Chapter 3, Stationary Internal Combustion Sources, Gasoline and Diesel Industrial Engines, Table 3.3-1 (10/1996)0.06NOX4.410.89CO0.950.19VOC0.350.07HAPs0.00645AP-42, Chapter 3, Stationary Internal Combustion Sources, Gasoline and Diesel Industrial Engines, Table 3.3-2 (10/1996)0.0011 S represents the weight % of sulfur in the oil. For example, if the fuel is 0.0015% sulfur, then S=0.0015 2 lb/MMBtu represents pounds of pollutant emitted per million British thermal units of heat input to the engine. Table 3-3: Dust Collector Units – Allowable Particulate EmissionsUnitEmission Factor (gr/dscf)Maximum Flow Rate (dscfm)Emission Rate (ton/yr)1Torit DC #19 Cartridge Filter 0.0274315.58Torit DC #2 Cartridge Filter 0.0233142.49Torit DC #3 Cartridge Filter 0.0235332.65Sly DC #8 Fabric Filter 0.0274315.58Sly DC #9 Fabric Filter 0.0238592.90Spencer #10 Fabric Filter0.0222501.69Hoffman DC #11 Fabric Filter0.0210520.79Hoffman DC #12 Fabric Filter0.0212900.97Torit DC #20 Cartridge Filter 0.0235332.65Torit DC #23 Cartridge Filter0.0224001.80Total Process Emissions27.101Annual emission rate based on 8760 hours of operation.Table 3-4: Process – Allowable EmissionsCompoundCAS NumberHAP / VOCAllowable Emissions (ton/yr)11,2-Dimethoxyethane110-71-4VOC0.4Cadmium7440-43-9HAP0.0Diacetone Alcohol123-42-2VOC0.05Dibutyl Phthalate84-74-2HAP/VOC0.0001Ethyl Alcohol64-17-5VOC1.1Formaldehyde50-00-0HAP/VOC0.0001Hydrazine302-01-2HAP/VOC3.0Hydrochloric Acid7647-01-0HAP0.025Hydrogen Sulfide7783-06-4HAP0.005Isobutyl Alcohol78-83-1VOC0.7Isopropyl Alcohol67-63-0VOC0.1Lead7439-92-1HAP0.000003Manganese Dioxide1313-13-9HAP0.0028Metallic Mercury7439-97-6HAP0.0008Methyl Alcohol67-56-1HAP/VOC0.95Methyl Ethyl Ketone78-93-3HAP/VOC2.0Methyl Isobutyl Ketone108-10-1HAP/VOC0.025n-Butyl Alcohol71-36-3VOC0.025Nitrogen Oxide10102-43-9-0.075Potassium Hydroxide1310-58-3-0.0025Propylene Carbonate108-32-7VOC0.01Silver Nickel Oxide12408-25-2-0.0001Silver Oxide7440-22-4-0.0028Sodium Hydroxide1310-73-2-0.0025Stoddard Solvent8052-41-3VOC0.0025Sulfuric Acid7664-93-9-0.025Trichloroethylene79-01-6HAP/VOC0.0876Zinc7440-66-6-0.003Total Process Emissions8.6Total HAP Emissions6.1Total VOC Emissions8.5Table 3-5: Summary of Allowable Air Contaminant Emissions by Source (tons/year)SourcePM / PM10 / PM2.5SO2NOxCOVOCTotal HAPsBoilers0.740.054.502.590.170.06Emergency Generators0.060.000.890.190.070.00Dust Collectors 27.10-----Process Emissions----8.456.10Estimated Facility Emissions27.910.055.392.798.696.16Allowable Facility Emissions27.90.15.42.8< 8.7< 6.2As summarized in Table 3-5 above:The Facility has allowable emissions of all air contaminants in the aggregate of ten (10) or more tons per year: the Facility is therefore subject to Subchapter X of the Regulations and is designated as a Subchapter X Major Source.The Facility does not have allowable emissions of any contaminant which would classify the source as a “Major Source” and therefore is not subject to the new source review requirements of §5-502 of the Regulations. The Facility does not have allowable emissions of any contaminant which would classify the source as a "Title V Subject Source" and therefore is not subject to the federal operating permit requirements of 40 C.F.R. Part 70 or 71.3.2Estimating Actual Emissions of Hazardous Air Contaminants from the Existing Stationary SourceThe following table summarizes the estimated actual emissions of HACs:Based on the facility’s annual registration information for the reporting years 2013 through 2017 the following table summarizes the estimated actual emission rate of HACs from the facility. To be conservative, for each HAC emitted, the year with the highest emission rate was used in this evaluation.Table 3-6 Quantification of HAC EmissionsHazardous Air ContaminantCAS #Toxic CategoryEmission Rate(lb/8-hrs)1Averaging Time (hrs)Action Level(lb/8-hrs)Silver Oxide7440-22-427.76256E-0587600.66Zinc CompoundsN/A00.0041095898760-Trichloroethylene79-01-610.00168036587600.04Ethyl Acetate141-78-620.005922374876095Ethyl Alcohol64-17-520.076415525876037.2Isobutyl Alcohol78-83-120.03105022887608.7Manganese Dioxide1313-13-920.00807305987600.004Mercury CompoundsN/A28.61872E-0587600.02Methyl Alcohol67-56-120.000180365876097Nitric Oxide10102-43-920.00536415587600.93Phenol108-95-220.00024885887605.3Methyl Ethyl Ketone78-93-320.1546757998760415Acetic Acid64-19-730.19648200031 For category 3 contaminants, emission rate is based on either the actual hours of operation or 2,000 hours/year of operation. For category 1 & 2 contaminants, the emission rate is based on 8,760 hours/year.3.3 – Estimating Potential Green House Gas EmissionsTable 3-7: Global Warming PotentialCO2CH4N2O125292Table 3-8 Annual Greenhouse Gas EmissionsFuel TypeCO2 (lb)CH4 (lb)N2O(lb)Distillate Fuel Oil #210,190,439413.382.7Table 3-9: CO2 EquivalentTotal CO2 Emissions – Equivalent (Fossil CO2e + Biogenic CH4 & N2O)5,112.5 tons/yrAll CO2e emissions at stack (Fossil CO2e + Biogenic CO2e)5,112.5 tons/yr4.0Discussion of select APPLICABLE and non-applicable REQUIREMENTSThe Agency will assess compliance with these regulations during any inspections of the Facility. The inspections will include confirmation of the proper operation and maintenance of equipment and air pollution control devices, visual observations of emission points, and review of any records required by the Permit.4.1Vermont Air Pollution Control Regulations and Statutes§5-201 and §5-202 - Open Burning Prohibited and Permissible Opening BurningThis emission standard, which regulates the open burning of materials, applies to the entire Facility. Open burning of materials is prohibited except in conformance with the requirements of this sectionBased on information provided by the Permittee, open burning is not typically conducted at the Facility. During future inspections of the Facility, the Agency will verify if there has been open burning activity at the Facility and if these activities are in compliance with this requirement. §5-211(2) - Prohibition of Visible Air Contaminants - Installations constructed subsequent to April 30, 1970This emission standard applies to all of the fuel burning equipment at the facility including the Cleaver Brooks boilers located in the Heating Plant as these boilers we converted to burn CNG as well as No.2 fuel oil in 2014.§5-221(1) - Prohibition of Potentially Polluting Materials in Fuel; Sulfur Limitation in FuelThis prohibition applies to all stationary fuel burning equipment used on-site. Based on the application submittal, the applicant is expected to comply with this regulation based on the use of distillate oil. Distillate oil, by its official fuel specification definition, complies with this requirement. §5-231(1)(b) - Prohibition of Particulate Matter; Industrial Process EmissionsThis emission standard applies to cartridge and fabric filters at the facility. The estimated permit allowable particulate emissions from the process unit is 0.02 grains per cubic foot, which is less than the regulatory standard of 0.06 grains per dry standard cubic foot (gr/dscf). Therefore the applicant is expected to comply with the respective particulate matter emission limit of this section. §5-231(3) - Prohibition of Particulate Matter; Combustion ContaminantsBased on the application submitted and information available to the Agency, this Facility currently has applicable fuel burning equipment subject to this regulation. The allowable particulate emissions from the subject equipment is shown in Table 4-1. (i)0.5 pounds per hour per million BTU's of heat input in combustion installations where the heat input is 10 million BTU's or less per hour.For combustion installations where the heat input is greater than 10 million BTU's per hour, but where the heat input is equal to or less than 250 million BTU's per hour, the applicable limit is determined by using the following formula:EPM = 10[-0.47039(log10HI)+0.16936where:EPM -is the particulate matter emission limit, expressed to the nearest hundredth pound per hour per million BTU's; andHI -is the heat input in millions of BTU's per hour.For the Cleaver Brooks boiler when firing oil:EPM = 10[-0.47039(log1012.5)+0.16936EPM = 0.45 lb/MMBtuTable 4-1: Equipment Subject to §5-231(3)EquipmentRating (MMBtu/hr)Emission Standard, (lb/MMBtu)Allowable Emissions, (lb/hr)Boiler #2 Cleaver Brooks CB657-30012.50.455.63Boiler #3 Cleaver Brooks CB657-30012.50.455.63Boiler #4 Superior Boiler Works 7-X-500-S150-M4.010.52.01§5-231(4) - Prohibition of Particulate Matter; Fugitive Particulate MatterThis section requires the use of fugitive PM control equipment on all process operations and the application of reasonable precautions to prevent PM from becoming airborne during the handling, transportation, and storage of materials, or use of roads. This requirement applies to the entire Facility, and the Facility is therefore expected to comply with the fugitive emission limitations of this section.§5-241(1) & (2) - Prohibition of Nuisance and Odor This requirement applies to the entire Facility and prohibits the discharge of air contaminants that would be a nuisance to the public or the discharge of objectionable odors beyond the property-line of the Facility. Based on the application submittal and information available to the Agency, the Facility currently is in compliance with this regulation. The Agency will verify compliance with this requirement in the future during any inspections of the Facility. Additionally, the Agency investigates complaints that it receives in order to determine whether or not there is a violation of this requirement. §5-253.13 - Coating of Miscellaneous Metal PartsThis subsection applies to any miscellaneous metal parts and products coating unit, except automobile refinishing, located at a Facility whose actual emissions from all miscellaneous plastic and metal coating operations are 3 tons per rolling twelve month period or more of VOCs. Based on the application submittal and information available to the Agency, this Facility currently is not subject to this regulation as emissions from the coatings are estimated to be less than 3 tons per rolling 12-month period. Should emissions of VOCs exceed 3 tons per rolling 12-month period, conditions have been included in the permit to ensure continued compliance with this regulation.§5-261 - Control of Hazardous Air Contaminants See Section 5.0 below.§5-271 – Control of Air Contaminants from Stationary Reciprocating Internal Combustion EnginesThis emission standard applies to all stationary reciprocating internal combustion engines with a brake horsepower output rating of 300 hp or greater. This section applies to the emergency generators at the Facility. Based on the application submittal and information available to the Agency, the Facility currently is in compliance with this regulation, as they have no stationary reciprocating engines with an output rating of 300 bhp or greater. However, a condition will be included as part of the permit to specifically identify this limitation. The Agency will verify compliance with this requirement in the future during any inspections of the Facility.§5-402 – Written Reports When Required This section gives the Agency authority to require the Facility to submit reports summarizing records required to be maintained by the Agency. The Agency will assess compliance with this regulation in the future during any inspections of the Facility. §5-403 – CircumventionThis section prohibits the dilution or concealment of an air discharge in order to avoid air pollution control requirements. The Agency will assess compliance with this regulation in the future during any inspections of the Facility. §5-404 – Methods for Sampling and Testing of SourcesThis section allows the Agency to require testing of air emissions from the Facility and to specify the methods of testing. Based on the application submittal and information available to the Agency, the Facility currently is in compliance with this regulation. The Agency will assess compliance with this regulation in the future during any required testing or inspections of the Facility. Subchapter VIII – Registration of Air Contaminant Source. This Subchapter requires the owner or operator of a stationary source register with the Agency if the source produces five (5) tons per year or greater of actual emissions during the preceding calendar year. The owner or operator of a source is required to submit information regarding their operations and pay a fee based upon the quantity of emissions they produce and the fuels that they use at the source. The Permittee is currently in compliance and has been registering its emissions with the Agency annually on those years when its total emissions exceed 5 tons per year. 4.2Federal Air Pollution Control Regulations and the Clean Air ActSection 111 of the Clean Air Act - New Source Performance Standards (NSPS). NSPSs are promulgated under Title 40 of the Code of Federal Regulations ("40 C.F.R.") Part 60. The NSPSs that were reviewed for applicability and the applicable NSPSs are summarized in the following table. Table 4-2Applicable Requirements from Section 111 of the Clean Air Act New Source Performance Standards (NSPSs)40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units. Applies to all boilers 10 MMBTU/hr or greater manufactured after June 9, 1989. Units larger than 30 MMBTU per hour installed after February 27, 2005 are subject to additional particulate matter requirements. The two (2) Cleaver Brooks boilers were installed prior to 1989 and the conversion to CNG and No.2 fuel oil do not meet the definition of modification under 40 CFR Part 60. In addition, the new Superior Boiler Works boiler capacity does not meet the definition; therefore, these boilers are not subject to this regulation.40 CFR Part 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE). Applies to CI RICE model year 2007 and later as well as those ordered after July 11, 2005 and with an engine manufacture date after April 1, 2006. This standard also applies to stationary CI RICE that are modified or reconstructed after July 11, 2005. This regulation established emission rates for affected engines, requires routine engine maintenance and sets maximum sulfur content for the diesel fuel. Beginning October 1, 2010 applicable engines shall only use diesel fuel with a maximum sulfur content of 15 ppm (ULSD). Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart IIII is not anticipated to apply to the 100 kW emergency Kohler engine located in Plant 1 at the Facility because it was installed prior to 2005. Subpart IIII is anticipated to apply to the 30 kW emergency Kohler engine located in Plant 2 at the Facility.Section 112 of the Clean Air Act - National Emission Standards for Hazardous Air Pollutants (NESHAPs). NESHAPs are promulgated under 40 C.F.R. Part 61 and Part 63. Total HAP emissions are estimated to be less than 1 ton per year, so the Facility would be classified as an area source of HAPs. The applicable NESHAPs are summarized in the following table. Table 4-3Applicable Requirements from Section 112 of the Clean Air Act National Emission Standards for Hazardous Air Pollutants (NESHAPs)40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. Applies to new engines that commenced construction (installed) on or after June 12, 2006 at area sources of HAPs. Requires such engines to comply with NSPS Subpart IIII or JJJJ, as applicable. Also applies to existing engines that commenced construction (installed) prior to June 12, 2006 at area sources of HAPs. By May 3, 2013 requires engines equal and greater than 300 bhp to meet CO emission standards which may necessitate catalytic controls, must install crankcase ventilation system, and requires ULSD fuel. Engines <300 bhp need only meet maintenance requirements including changing oil & filter and, inspecting and replacing if necessary, air filter, hoses and belts. Does not apply to existing emergency units at an area source residential/commercial/institutional facility unless they are enrolled in demand response programs. Subject emergency units are subject to maintenance requirements, must install an elapsed hour meter and must use ULSD commencing January 1, 2015 if used for DR. For engines firing landfill or digester gas comprising 10% or more of the heat input, the engines are subject to management practices only (change oil & filter, inspect plugs, and inspect hoses and belts every 1440 hours or annually, whichever occurs first) as well as operating in accordance with manufacturer’s recommendations and minimizing time at idle.Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart ZZZZ is anticipated to apply to the two (2) Kohler emergency engines at this Facility. Since the 30 kW Kohler emergency engine commenced construction (installed) on or after June 12, 2006 it is anticipated to comply with the new engine requirements of Subpart ZZZZ by complying with Subpart IIII.40 CFR Part 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers. Applies to new and existing fuel oil and solid fuel fired boilers located at area sources (major sources are subject to Subpart DDDDD). Natural gas or propane fired boilers are not subject. This gas exemption allows use of backup fuel during gas curtailments and up to 48 hours of elective use. Oil fired hot water boilers less than 1.6 MMBTU/hr are not subject. The rule requires a tune-up for each boiler once every two years except boilers with oxygen trim and oil boilers less than 5 MMBTU/hr must conduct tune-ups every five years. New boilers greater than 10 MMBTU/hr are subject to PM emission limits. Boilers that commenced construction on or before June 4, 2010 are considered an existing source.Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart JJJJJJ is anticipated to apply to the two (2) Cleaver Brooks boilers and the one Superior Boiler Works boiler at the Facility since Energizer will maintain fuel oil burning capability and has not declared the boilers as gas-fired only. The boilers are anticipated to be subject to the work practice standards as well as notification, reporting, and recordkeeping requirements established in this rule. The work practice standards include biennial tune-ups and a one-time energy assessment. Since the Facility is not a major source of HAPs, the Facility is not subject to Subpart DDDDD.5.0hazardous air contaminantsThe emissions of hazardous air contaminants (“HACs”) are regulated under to §5-261 of the Regulations. The Owner/Operator of a source must quantify its emissions of HACs regulated by this rule. Any Facility whose emission rate of a HAC exceeds its respective Action Level (“AL”) is subject to the rule for the HAC, and the Owner/Operator must then demonstrate that the emissions of the HAC are minimized to the greatest extent practicable by achieving the Hazardous Most Stringent Emission Rate (“HMSER”) for that HAC. If the emission rate of any HAC after achieving HMSER is still estimated to exceed its action level after achieving HMSER, an air quality impact evaluation may be required to further assess the ambient impacts for compliance with the Hazardous Ambient Air Standard (“HAAS”) or Stationary Source Hazardous Air Impact Standard (“SSHAIS”). The emission of hazardous air pollutants (“HAPs”) may also be regulated separately under to §112 of the Federal Clean Air Act. This facility has a permit condition limiting the emissions of HAPs to 6.2 tons/year of all HAPS combined, therefore the facility is not subject to the federal HAP standards.As shown in Section 3, the facility isn’t expected to exceed any action levels and therefore is not subject to §5-261. The Facility was previously found to have emissions of trichloroethylene (TCE) in excess of the Action Level, and HMSER was determined to be 0.02 pounds of TCE per hour. The Facility has since discontinued the use of TCE and is therefore no longer expected to exceed the Action Level for TCE. ................
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