PERMIT MEMORANDUM 2003-086-TVR (M-1) DRAFT 10

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM August 22, 2006

TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division

THROUGH: Grover Campbell, P.E., Existing Source Permits Section

Phil Martin, P.E., New Source Permits Section

THROUGH: Peer Review

FROM: Jian Yue, P.E., Engineering Section

SUBJECT: Evaluation of Permit Application No. 2003-086-TVR (M-1)

Boral Bricks

Muskogee Brick Plant (SIC 3251)

3101 W. 53rd St. S., Muskogee , Muskogee County, Oklahoma

SECTION I. INTRODUCTION

Boral Bricks has requested a significant modification to their current Part 70 operating permit for the Muskogee Brick Plant to authorize a one-year extension of the May 16, 2006 deadline to comply with Subpart JJJJJ under the provisions of 40 CFR Part 63.6(i). The reason for this request is that EPA was reconsidering the technology requirements of the final rule as a result of a petition, and Boral Bricks was unable to proceed with the purchase and installation of control because of the uncertainty associated with the reconsideration. With this permit modification, DEQ will approve a one-year extension under conditions set forth in Specific Condition No. 6. The facility is currently operating under Permit No. 2003-086-TVR.

This facility (SIC 3251) produces clay-facing bricks for use in the construction of buildings and other structures. A portion of the clay and shale used as primary raw materials are mined on the plant site property, while other raw materials are mined locally.

The facility emits more than 100 TPY of a regulated pollutant and is subject to Title V permitting requirements. Processes occurring at the plant are described as two primary Emission Unit Groups (EUG) in the following outline.

SECTION II. EMISSION GROUPS AND EQUIPMENT

EUG-01: Raw Material Storage, Handling, and Processing

This emission group consists of two emission units: EU-01, Clay Storage and EU-02, Clay Preparation.

EU-01, Clay Storage: Prior to entering the clay preparation process, raw materials are unloaded from dump trucks and stockpiled. Front-end loaders deliver some raw materials from the stockpile to the Clay Storage Building for dry storage. All raw materials are transported via front-end loader to a tipple hopper which feeds a conveyor to the Clay Preparation Building. Emissions are created as trucks are unloaded.

EU-02, Clay Preparation: Raw clay is then delivered to the Clay Preparation Building where it is processed first by a primary crusher, then separated by a scalping screen. Oversized materials are further processed by a grinder. All materials are then sized by a screen bank. Material not passing through the screens returns to the grinder, while material passing through the screens is conveyed to one of two storage bins. Sized material is collected from these two storage bins using a reclaimer, which consists of a series of rotating rakes which push material onto a conveyor. Since all clay preparation processes are performed in the Clay Preparation building, any emissions from the process only escape through open doors or vents.

EUG-02: Drying and Firing Process

A conveyor transfers fine clay from the Clay Preparation Building to the Manufacturing Building which has no baghouses or any other control devices. Clay is mixed with water in a pug mill and then extruded under pressure to form a column. The column is subsequently cut into individual bricks, which are stacked on kiln cars. Initial drying of the brick occurs in the holding room, which is heated with only a small portion of waste heat from the kiln diluted to a large extent with ambient air. There is no emission from the holding room. The dryer and the kiln also do not have particulate control devices.

EU-03, Tunnel Dryer: The loaded brick cars then pass through a tunnel dryer, which utilizes waste heat from the cooling section of the kiln to remove the moisture from the bricks. The temperatures in the tunnel dryer typically range between 350°F and 500°F. Under this range of temperature, a portion of the organic compounds naturally occurring in clay volatilize in the tunnel dryer.

EU-04, Tunnel Kiln: The dried cars of bricks are then pushed through a natural gas-fired tunnel kiln, in which they are heated to approximately 1,950°F to form a ceramic bond internally in the bricks. Emissions are exhausted through the kiln exhaust stack. Upon discharge from the kiln, fired bricks are removed from the cars and packaged for shipment.

SECTION III. EMISSIONS

The parameters of the stacks are tabulated below:

Operations / Diameter
(Inches) / Height
(Feet) / Flow Rate
(ACFM) / Temperature (°F)
EU-03, Tunnel Dryer / 36 / 28 / 12,700 / 180
EU-04, Tunnel Kiln / 60 / 28 / 48,000 / 500

The clay storage and preparation areas operate 10 hours per day, 5 days per week, and 52 weeks per year. The tunnel dryer and kiln areas operate 24 hours per day, every day of the year. The following table lists the production for each unit.

Process / Production/Throughput (TPY)
EU-01, Clay Storage / 281,402
EU-02, Clay Preparation / 281,402
EU-03, Tunnel Dryer / 245,534
EU-04, Tunnel Kiln / 245,534

The tunnel kiln has a heat capacity of 48.96 MMBTUH.

Emission factors for each emission unit are listed in the following table.

NOx
(lb/ton) / CO
(lb/ton) / VOC
(lb/ton) / SO2
(lb/ton) / PM
(lb/ton) / PM10
(lb/ton)
EU-01 / - / - / - / - / 0.039a
EU-02 / - / - / - / - / 0.025b / 0.0023b
EU-03 / - / - / 0.03c / - / -
EU-04 / 0.35d / 1.20d / 0.024c / 0.67d / 0.96b / 0.87b

a AP-42 (1/95) Table 11.9-2: Emission Factors for Uncontrolled Open Dust Sources at Western Coal Mines.

b AP-42 (8/97) Table 11.3-2.

c AP-42 (8/97) Table 11.3-5.

d AP-42 (8/97) Table 11.3-3.

Calculated Emissions

Source / NOx / CO / VOC / SO2 / PM / PM10
lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY
EU-01* / - / - / - / - / - / - / - / - / 2.05 / 2.65 / - / -
EU-02 / - / - / - / - / - / - / - / - / 2.72 / 3.52 / 0.25 / 0.32
EU-03 / - / - / - / - / 1.6 / 7 / - / - / - / -
EU-04 / 9.81 / 42.97 / 33.63 / 147.32 / 0.84 / 3.68 / 18.78 / 82.25 / 26.91 / 117.86 / 24.39 / 106.81
Total / 9.81 / 42.97 / 33.63 / 147.32 / 2.44 / 10.68 / 18.78 / 82.25 / 31.68 / 123.98 / 24.64 / 107.13

* The clay storage building is enclosed, so a control efficiency of 50% is applied since the emission factor is uncontrolled.

The following table lists HAP emission factors from the kiln based on AP-42 (8/97) Tables 11.3-4 and 11.3-6.

HF
(lb/ton) / HCl
(lb/ton) / Benzene
(lb/ton)
EU-04 / 0.37 / 0.17 / 0.0029
Chemical Constituent / CAS# / Emission
lb/hr / TPY
Benzene / 71-43-2 / 0.078 / 0.35
Hydrochloric acid / 7647-01-0 / 5.88 / 25.74
Hydrogen fluoride / 7664-39-3 / 10.66 / 46.67

SECTION IV. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified on Part 1b of the forms in the application and duplicated below were confirmed by the initial operating permit inspection. Records were available to confirm the insignificance of the activities. Appropriate record keeping of activities indicated below with “*”, is specified in the Specific Conditions.

(1)* Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours/year. There is one natural gas/propane emergency generator to run a kiln roof cooling fan when electric power is lost (60 KW rated).

(2) Space heaters, boilers and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). There are three natural gas and two diesel space heaters for employees and hydraulic equipment in cold weather.

(3)* Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. There is one 1,650-gallon diesel tank used for four pieces of heavy equipment used in the mine site and four forklifts in the brickyard. There is also one 800-gallon gasoline tank on site used for one company pick up truck and two welders.

(4) Cold degreasing operations utilizing solvents that are denser than air. There is one 25-gallon solvent tub used for washing parts in maintenance.

(5) Sanitary sewage collection and treatment facilities other than incinerators and Publicly Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are also included (i.e., lift station). There is one lift station and a sewage lagoon for fifty two employees.

(6) Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. Occasionally may have spray can of computer contact cleaner.

(7) *Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant. EU-01 and EU-02 each has PM emissions less than 5 TPY. The throughput of EU-01 and EU-02 is limited by kiln brick production. Since the kiln brick production is set as a permit limit in the Specific Conditions, no additional recordkeeping will be required for these two emission units.

SECTION V. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards.

OAC 252:100-4 (New Source Performance Standards) [Not Applicable]

Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on September 1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart BBBB, Subpart DDDD, Subpart HHHH, and Appendix G. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-5 (Registration, Emission Inventory, and Annual Fees) [Applicable]

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories have been submitted and fees paid for the past years.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requirements for part 70 permits. Any planned changes in the operation of the facility which result in emissions not authorized in the permit and which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may require a permit modification. Insignificant activities mean individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits:

·  5 TPY of any one criteria pollutant

·  2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emissions limitations have been incorporated from the previously issued permits and updated to reflect current operations.

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]

In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Part 70/Title V sources must report any exceedance that poses an imminent and substantial danger to public health, safety, or the environment as soon as is practicable. Under no circumstances shall notification be more than 24 hours after the exceedance.

OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter) [Applicable]

This subchapter specifies a particulate matter (PM) emission limitation of 0.6 lb/MMBTU from fuel-burning equipment with a rated heat input of 10 MMBTUH or less and a lowest limitation of 0.1 lb/MMBTU for fuel-burning equipment with a rated heat input of 10,000 MMBTUH or greater. AP-42 (7/98), Table 1.4-1 lists natural gas PM emissions to be 7.6 lb/million scf or about 0.0076 lb/MMBTU, so the natural gas fired kilns are in compliance.

This subchapter also specifies PM emissions limitations based on process weight rate. Based on a process rate maximum of 28 tons/hr, the allowable emissions rate is 39.6 lb/hr. The overall estimated maximum emission of 31.7 lb/hr is in compliance with this limitation.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. When burning natural gas, the fuel-burning equipment has very little possibility of exceeding opacity standards, therefore no periodic observation is necessary.