PERMIT MEMORANDUM 95-195-C (M-2) DRAFT 14
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM January 6, 2006
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division
THROUGH: Grover Campbell, P.E., Existing Source Permits Section
THROUGH: Phil Martin, P.E., New Source Permits Section
THROUGH: Peer Review
FROM: Doug Meese, P.E., New Source Permits Section
SUBJECT: Evaluation of Permit Application No. 95-195-C (M-2)
Johns Manville
812 North Bryant Avenue
Oklahoma City, Oklahoma County, Oklahoma
SECTION I: INTRODUCTION
Johns Manville (JM) has requested a construction permit for a modification to the above referenced existing facility (SIC 2952). The facility is an asphalt-based roofing materials manufacturing facility. JM was issued permit No. 95-195-O on August 28, 1995, and is currently permitted under Permit Number 95-195-O (M-1) as a “synthetic minor” facility which was constructed in 1960. The modification will add a coating line to the facility which will allow the facility to add a proprietary coating to some of the products manufactured there. After modification the facility will have potential VOC emissions over 100 TPY and will be a Part 70 source. This permit addresses the equipment to be added and gives the facility emissions before and after modification. In addition, the facility has requested corrections to the emissions of the existing combustion sources. The post-construction emissions estimates include the requested corrections. A complete description of the modified facility’s equipment and processes will be required in the Title V operating permit application which will be submitted later.
JM manufactures asphalt based roofing materials at this site. Fiberglass mat is used as the base mat for all rolled roofing manufactured at the site. The fiberglass mat is delivered to the plant by truck and stored in the raw material warehouse. There are some emissions due to off-gassing of the mat. These emissions are released from the building as fugitives (EPN: F-RM). Sand is delivered to the site by truck and bottom dumped (EPN: F-DUMP) to bucket elevators which transfer the sand to portable hoppers inside the process building. Emissions from dropping the sand into the hopper are released from the process building as fugitives (EPN: F-PB).
Filler materials are used for some of the products manufactured on the only production line. These silt-sized particles are delivered to the site in trucks. The filler is transferred to the filler storage tanks pneumatically (EPN: FF-1). The filler is then blown to an intermediate surge hopper (EPN: FF-2) before being dumped into the horizontal asphalt mixer where it acts as a thickener. The asphalt mixer is basically a closed device, preventing the release of particulate matter emissions. However, there are emissions of organic vapors from the asphalt. These emissions are released into the process building and emitted as fugitives (EPN: F-PB).
The asphalt is delivered to the site by truck and stored in tanks. It is circulated through piping and heated until it is needed. From the storage tanks, the asphalt is either pumped directly to the horizontal asphalt mixer, or it bypasses the mixer and directly enters the coater section.
In the coating section, fiberglass mat is conveyed through either of two coater units. Only one coater is used at a time. Emissions from the coaters are routed to a fabric filter which has two exhausts: the north stack (EPN: FF-N) and the south stack (EPN: FF-S). Emissions can be diverted to either stack or all sent to a single stack.
Once out of the coating section, the asphalt saturated mat is coated with either sand (EPN: FF-B) or Liquid Parting Agent (LPA is a soap and contains no volatile organics or HAPs. Basically, mat with the filled coating is coated with sand, while mat coated with the unfilled asphalt has LPA applied). Both serve to prevent the mat from adhering to itself when rolled for storage and shipment. After sand or LPA application, the mat is then marked with lines of paint to aid in installation (EPN: F-PB). After the mat is line marked, it is cooled and then rolled and packaged for storage and shipment. Emissions from the line painting and cooling of the mat leave the process building as fugitives (EPN: F-PB), through three powered roof vents (PV-1, PV-2, PV-3), and through the cooling section vent (CV-1). Emissions from degassing of the final product are fugitive emissions from the finished goods warehouse (EPN: F-FG).
SECTION II: EQUIPMENT
A description of the existing equipment is given here. Heat and steam requirements for the plant are met with two preheaters and two boilers (EPN: HEAT-W, HEAT- E, BLR-PM, BLR-CB). In addition to the two asphalt storage tanks, there are two other storage tanks at the site. These tanks store propane and are 250 gallons each. The propane tanks are pressured tanks and have only negligible emissions. Emissions due to vehicle refueling with propane is designated by EPN: F-PREF. Asphalt coating emissions (VOC and PM) are emitted from one of two stacks, FF-N and FF-S while emissions (VOC) from the asphalt mixer are fugitives, F-PB. Material (sand) handling operations emit only PM. These operations include truck unloading, F-DUMP1, and two sand drop operations, one inside the process and the other on the asphalt coating line, both fugitive sources, F-PB. There are fabric filters on the filler storage, FF-1, and on the surge hopper, FF-2. These also emit only PM. The warehouses storing finished goods and raw materials have fugitive emissions of VOCs only. The final existing emission source is the emission of VOC and of PM during cooling of the asphalt.
The equipment to be added as a result of the modification consists of a coating line with a paint booth where the coating is applied by spray to some asphalt roofing products passing through the new coating line. The coated products then pass through an infrared oven where the coating dries by volatilization of the VOCs contained in the coating.
A more detailed description of the equipment and processes will be required for processing of the Title V operating permit application.
SECTION III: AIR EMISSIONS
Potential emissions are based on maximum hourly emissions and assume continuous operation 8,760 hr/yr. All capacities were provided by Johns Manville–Oklahoma City. A natural gas heat content of 1,000 BTU/SCF was assumed. The combustion sources are used to meet process heat requirements. Emissions factors from the combustion units (HEAT-W, HEAT-E, BLR-PM, BLR-CB) are based on AP-42 (7/98), Section 1.4 factors. Since the gas to each source is not metered individually, natural gas usage was allocated based on the size of the combustion unit and continuous operation.
Emissions from propane refueling of fork lifts (F-PREF) are based on a propane refueling rate of 300 gal/hr, an emission factor of 0.05 lb/100 gallons, continuous operation, and a safety factor of 5 to cover future operations.
VOC and formaldehyde emissions from the main coating line (FF-N and FF-S) are based on stack tests conducted at a similar Johns Manville facility in Pittsburg, California by Acurex in 1991. PM10 emissions were based on stack testing performed at Oklahoma City on February 21, 1991. The testing at the Pittsburg, California facility, was measured at the production rate of 12.4 TPH. The testing conducted at the Oklahoma City facility were measured at a production rate of approximately 3.9 TPH. The emissions determined from these tests were assumed to increase/decrease linearly with production and were scaled to correspond to maximum coating rate of 17.1 TPH at the Oklahoma City facility. Emissions from the main coating operation are vented through a cartridge filter to the atmosphere through two stacks. It is assumed that the emissions are split evenly between the two stacks.
PM10 emissions from the sand truck bottom unload (F-DUMP) are based on the maximum unloading rate of 100 TPH, a wind speed of 12.4 mph, a moisture content of 0.7%, a control efficiency of 70%, and AP-42 (1/95), Section 11.2.3-3. PM10 emissions from sand dropped into the hopper(s) (F-PB) are based on the maximum process rate of 20 ton/hr, a wind speed of 1 mph, a moisture content of 0.7%, a primary control efficiency of 70%, a secondary control efficiency of 50%, and AP-42 (1/95), Section 11.2.3-3. (Controls are integral to the equipment, and control efficiencies are estimated based on technical articles.) PM10 emissions from sand drop to mat on process line (F-PB) are based on the maximum process rate of 20 ton/hr, a wind speed of 1 mph, a moisture content of 0.7%, a control efficiency of 70%, and AP-42 Section AP-42 (1/95), Section 11.2.3-3. PM10 emissions from the truck transfer of filler with the fabric filter (FF-1) are based on the maximum outlet grain loading of 0.02 gr/DSCF and an airflow of 500 scfm. PM10 emissions from filler transfer to surge hopper (FF-2) with a fabric filter is based on the maximum outlet grain loading of 0.02 gr/DSCF and an airflow rate of 2,300 scfm.
Emissions from the horizontal asphalt mixer (F-PB) are based on production rate of 34,200 lb/hr of asphalt through the mixer and a maximum filling rate of 4,275 gal/hr. Emission factors are based on testing performed on similar tanks at the JM Pittsburg plant in March 1993. Maximum filling rate is based on maximum coating of 17.1TPH. Organic emissions assume saturation of the air with asphalt vapor, and that the emissions have the same composition as those reported for the coater. Emissions from line marking paint application (F-PB) are based on the maximum rate of application of line marking paint of 0.08 lb/roll of roofing material and maximum application rate 8.5 gal paint/hr. Emission from the line painting area are included as fugitive emissions in the cooling area. Based on MSDS, it is assumed that each color of paint contains a maximum of 2% (by weight) VOC and has a specific gravity of 1.5 or less.
Fugitive emissions from the warehouse are based on stack test conducted in 1995 at the Johns Manville Pittsburg, California warehouses adjusted to correspond to the number of rolls of both finished goods and mat in the OKC warehouses and a safety factor of 5 based on variability of stack test runs and capacity of warehouses. Emission from liquid parting agent (LPA-1) are based on a maximum application rate of 32 lb/hr and 280,000 lb/yr and an emission factor of 0.01 lb PM10/lb LPA.
Emissions from the storage tanks with cartridge filters (T-VASPH, T-HASPH) were based on stack testing conducted in 1993 of a similar tank at the Johns Manville Pittsburg, California facility, and an annual throughput of 37,400,000 gallon/year corresponding to a maximum coating rate of 17.1 TPH.
Emissions from filled coating surge tank (FF-N, North Stack; FF-S, South Stack) are based on a throughput of 34,200 lb/hr of asphalt and 37,400,000 gallons/year. Emissions from the coating line cooling area (F-PB, PV-1, PV-2, PV-3, and CV-1) are based on stack testing conducted in 1995 at the Johns Manville Pittsburg, California facility.
The insignificant/trivial activities listed below are those sources/activities that are considered to have negligible emissions due to size, type of activity, and/or production rate.
Insignificant/Trivial Activity List
Equipment/Activity / Pollutant / NotesHot water heaters / Criteria / Building/office hot water
Safety-Kleen Units / VOC / Covered parts washing
Bench lab equipment / VOC / QA/QC
Welding / CO, VOC / Maintenance
Spray painting / VOC / Maintenance/Spot usage
Propane storage tank / VOC / Pressurized tank
Propane refueling of forklifts / VOC / Pressurized tank
Coating roller cleaning / VOC / Emissions inside building
Fork trucks / Criteria / Mobile equipment
Pre-Construction Criteria Pollutant Potential Emissions
lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY
HEAT-W / West Pre-heater / 0.31 / 1.35 / 0.002 / 0.01 / 0.04 / 0.01 / 0.06 / 0.28 / 0.01 / 0.05
HEAT-E / East Pre-heater / 0.63 / 2.76 / 0.004 / 0.02 / 0.08 / 0.33 / 0.13 / 0.58 / 0.02 / 0.11
BLR-PM / Powermaster Boiler / 0.33 / 1.47 / 0.0020 / 0.01 / 0.04 / 0.18 / 0.07 / 0.31 / 0.01 / 0.06
BLR-CB / Cleaver Brooks Boiler / 0.42 / 1.83 / 0.0025 / 0.01 / 0.05 / 0.22 / 0.09 / 0.38 / 0.02 / 0.07
FF-N / Coater #1, et al / 2.35 / 10.30 / 1.59 / 6.95
FF-S / Coater #2, et al / 3.39 / 14.87 / 1.59 / 6.95
FF-1 / Filler Storage Filter / 0.09 / 0.38
FF-2 / Surge Hopper Filter / 0.39 / 1.73
CV-1 / Cooling, Line Marking / 1.20 / 5.10 / 8.90 / 39.00
PV-1 / Cooling / 0.12 / 0.51 / 0.89 / 3.90
PV-2 / Cooling / 0.12 / 0.51 / 0.89 / 3.90
PV-3 / Cooling / 0.12 / 0.51 / 0.89 / 3.90
T-VA / Vert. Asphalt Storage / 0.15 / 0.66
T-HA / Horiz. Asphalt Storage / 0.15 / 0.66
F-PREF / Propane Refueling / 0.16 / 0.70
F-PB / Asphalt Mixer / 0.01 / 0.03 / 0.10 / 0.42
F-DUMP / Sand Delivery / 0.50 / 2.20
F-PB / Sand Drop to Hopper / 0.006 / 0.26
F-PB / Sand Drop to Mat / 0.004 / 0.02
F-FG / Finished Goods Storage / 0.05 / 1.05
F-RM / Raw Material Storage / 0.04 / 1.00
F-PB / Cooling / 0.81 / 3.50 / 6.20 / 27.00
F-PB / LPA Evaporation / 0.051 / 0.22
Kerosene Cleaning / 0.08 / 0.34
Coating Surge Tank / 0.10 / 0.42
Totals / 1.69 / 7.41 / 0.0105 / 0.05 / 9.37 / 40.90 / 0.35 / 0.35 / 21.84 / 97.14
Post-Construction Criteria Pollutant Potential Emissions
EPN / Source / NOx / SO2 / PM / CO / VOClb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY
HEAT-W / West Pre-heater / 0.30 / 1.32 / 0.0018 / 0.01 / 0.02 / 0.10 / 0.25 / 1.11 / 0.02 / 0.07
HEAT-E / East Pre-heater / 0.62 / 2.71 / 0.0037 / 0.02 / 0.05 / 0.21 / 0.52 / 2.27 / 0.03 / 0.15
BLR-PM / Powermaster Boiler / 0.32 / 1.42 / 0.0019 / 0.01 / 0.02 / 0.11 / 0.27 / 1.19 / 0.02 / 0.08
BLR-CB / Cleaver Brooks Boiler / 0.41 / 1.80 / 0.0025 / 0.01 / 0.03 / 0.14 / 0.35 / 1.51 / 0.02 / 0.10
FF-N / Coater #1, et al* / 2.35 / 10.30 / 1.64 / 7.16
FF-S / Coater #2, et al* / 3.39 / 14.87 / 1.64 / 7.16
FF-1 / Filler Storage Filter / 0.09 / 0.38
FF-2 / Surge Hopper Filter / 0.39 / 1.73
CV-1 / Cooling, Line Marking / 1.20 / 5.10 / 8.90 / 39.00
PV-1 / Cooling / 0.12 / 0.51 / 0.89 / 3.90
PV-2 / Cooling / 0.12 / 0.51 / 0.89 / 3.90
PV-3 / Cooling / 0.12 / 0.51 / 0.89 / 3.90
T-VA / Vert. Asphalt Storage / 0.15 / 0.66
T-HA / Horiz. Asphalt Storage / 0.15 / 0.66
F-PREF / Propane Refueling / 0.16 / 0.70
F-PB / Asphalt Mixer / 0.01 / 0.03 / 0.10 / 0.42
F-DUMP / Sand Delivery / 0.50 / 2.20
F-PB / Sand Drop to Hopper / 0.006 / 0.26
F-PB / Sand Drop to Mat / 0.004 / 0.02
F-FG / Finished Goods Storage / 0.05 / 1.05
F-RM / Raw Material Storage / 0.04 / 1.00
F-PB / Cooling / 0.81 / 3.50 / 6.20 / 27.00
F-PB / LPA Evaporation / 0.051 / 0.22
PB-1 / Paint Booth / 10.0 / 7.50 / 20.00 / 15.00
IR-1 / IR Oven / 30.00 / 22.50
Post-Construction Totals / 1.65 / 7.25 / 0.0099 / 0.05 / 18.80 / 49.32 / 1.39 / 6.09 / 71.71 / 136.52
Pre-Construction Totals / 1.69 / 7.41 / 0.0105 / 0.05 / 9.37 / 40.90 / 0.35 / 0.35 / 21.84 / 97.14
Changes / -0.04 / -0.16 / -0.0006 / 0.00 / 9.43 / 8.42 / 1.04 / 5.74 / 49.87 / 39.38
Pre-Construction HAP Emissions