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HomeMy WebLinkAboutAQ_F_1400166_20210108_CMPL_InspRpt 1q o0 tbb - A 16 NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Sealed Air Corporation-Hudson NC Facility ID 1400166 Inspection Report County/FIPS: Caldwell/027 Date: 01/25/2021 Facility Data Permit Data Sealed Air Corporation-Hudson Permit 07550/R09 2001 International Boulevard Issued 5/19/2020 Hudson,NC 28638 Expires 5/31/2025 Lat: 35d 50.3333m Long: 81d 29.4334m Class/Status Synthetic Minor SIC: 3086/Plastics Foam Products Permit Status Active NAICS: 32615/Urethane and Other Foam Product(except Polystyrene) Current Permit Application(s)None Manufacturing Program Applicability Contact Data SIP/112r Facility Contact Authorized Contact Technical Contact Vincent White Vincent White Vincent White Site Manager Site Manager Site Manager (828)726-2038 (828)726-2038 (828)726-2038 Compliance Data Comments: Inspection Date 01/08/2021 Inspector's Name Amro Ali Inspector's Signature: r Operating Status Operating �' Compliance Status Compliance-inspection Action Code FCE Date of Signature: ( J 12- f Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP *Highest HAP Emitted(inpounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested Introduction On January 8,2020,Amro Ali conducted an announced virtual compliance air quality inspection of Sealed Air Corporation in Hudson,North Carolina. I called the facility and spoke with Mr.Vincent White, Site Manager. Mr. White indicated that the facility contacts have not changed since the last compliance inspection. Therefore, all the contact information in the IBEAM database appeared correct. Mr.White indicated that he will send me all the records required by their air quality permit via email. Mr. White sent the required documents,photos, and videos on January 8,2020. Sealed Air manufactures polyethylene foam extruders which use VOC and non-VOC blowing agents in Hudson, North Carolina. Mr. White indicated that production is slightly up compared to the previous year. Note that the facility was issued a new permit on May 19,2020 due to replacement of thermal oxidizer OX-2 with thermal oxidizer OX-3. The new oxidizer will have a new monitoring requirement of a maintaining combustion zone temperature at a minimum 3-hour average of 1,600 degrees Fahrenheit during operation(unless otherwise established by stack testing). New quarterly enclosure monitoring is also now required. See photo below of the thermal oxidizer's stack that was taken by Mr. White: fN 4 s u:f r.. F ,, rs r i er ral ral EXT-4 gas-fired back-up at a maximum heat input ES-CR rne curing room(operating) of 9 million Btu per hour). Using natural gas fired backup because blowing agent is . _ not operating. ES-FP one fluff processing operation(not operating). PKG-1 and-- two package manufacturing systems N/A N/A PKG-2 (operating). a Insignificant/Exempt Sources Exemption tion� � Source of Title V': Source Source of TAPs? Pollutants?Regulation � � Pol ? I-1 -one fluidized sand bath 2Q .0102(h)(5) Yes --_—Yes The Permittee operates an electric fluidized sand bath burn-off oven(ID No. 1-1)to remove material that is deposited on foam extrusion heads. Periodically,the foam extruders(ID Nos. EXT-1,EXT-2,EXT-3 and EXT-4) are disassembled and the parts of the extrusion head assemblies that need to be cleaned are placed in the burn-off oven. The burn-off oven is considered exempt from permitting per 15A NCAC 2Q .0102 (h)(5) Safety When inspecting this facility,DAQ personnel are required to wear Cotton clothing,ear and eye protection and steel toe boots. Ensure electronics carried meet guidelines for extruding and curing rooms. General safety practices from the required HAZWOPER training should always be followed. Process Description This facility manufactures polyethylene(PE)foam sheets by heating PE pellets,then extruding and foaming the PE into sheets. The facility operates four polyethylene foam extruders which use VOC(propane)and non-VOC blowing agents. The extruded sheets are collected on rolls that are then taken to a curing room,before being moved the warehousing area. Off-spec material is collected in the fluff processing area. Negative pressure is maintained in the extruding room,in the curing room and in the fluff processing area and all of the air collected from these areas is sent to an electric regenerative thermal oxidizer(ID No. OX-1). Off-spec and scrap PE foam may be shredded to form faux snow,or recycled by melting and extruded shredded scrap to form small pellets which are then reintroduced to the foam extruders to produce a gray foam product(gray foam may be composed of up to 90%recycled scrap). Emissions from the waste grinding and recycling processes (ID No. GR-1)are controlled by one simple cyclone(ID No. CY-1),though emissions are no longer ducted outside the building. The facility was previously subject to regulation under Section 112(r)because on-site propane storage capacity is higher than the Threshold Quantity of 10,000 pounds(2,260 gallons). Propane is no longer a regulated substance under Section 112(r)and therefore the facility was not subject to Section 112(r)regulations for a period. Because the Permittee recently began using butane as a blowing agent,they are again subject Section 112(r). 1.) Directions: From Lenoir,follow Highway 321A south to International Blvd and turn right. Facility is located on the left. 2.) Facility Overview • Safety: Cotton clothing,ear and eye protection and steal toe boots.Ensure all electronics carried meet guidelines for extruding and curing rooms. • Discussion: On January 8,2021,Amro Ali conducted an announced virtual full compliance air quality inspection of Sealed Air Corporation in Hudson,North Carolina. According to Mr. White, all the facility's emission sources are in operation. However,I could not confirm these statements. • Facility Contacts: Vincent White, Site Manager 3.) Regulatory Review • Permit Conditions: Condition A.3—This contains the requirements for 2D .0515. This rule applies to the four polyethylene foam extruders(ID Nos.EXT-1,EXT-2,EXT-3 and EXT-4),the curing room(ID No.ES-CR)and the fluff processing(ID No.ES-FP). The rule limits the rate of particulate emissions to a rate based on the facility's production. The facility is expected to comply with 2D .0515. Condition A.4—This contains the requirements for 2D.0516. The facility is required to limit sulfur dioxide emissions from the facility's combustion sources. The sulfur dioxide emissions should not exceed 2.3 lb per MMBtu input. The four polyethylene foam extruders(ID Nos.EXT-1,EXT-2,EXT-3 and EXT- 4)use propane and butane as blowing agent. The combustion of propane gas will produce 0.22 lb of SO2 per MMBtu. While the combustion of butane gas will produce 0.34 lb of SO2 per MMBtu. These calculations were based upon emission factors found in AP-42.The facility is expected to be in compliance with 2D.0516. If the oxidizer continues to operate according to manufacturer specifications and with any applicable control devices,the sources will be in compliance with 2D.0521. According to Mr. White,the facility is operating according to the manufacturer's specification and with any applicable control devices. Condition A.6—This contains the requirements for 2D.0535. The facility is required to report to the DAQ any instances that create excess emissions that last for more than 4 hours. Mr. White indicated that there were no excess emissions lasting more than four hours from the facility's permitted and exempt sources. The facility appears to be in compliance with 2D.0535. Condition A.7—This contains the requirements for 2D.0540. The facility is required to prevent fugitive dust emissions that may cause excessive visible emissions or complaints beyond the property boundary. Based upon review of the facility's file,no recent fugitive dust complaints have been received by this office. According to Mr.White,no fugitive dust complaints were received against the facility and they did not observe any fugitive dust. The facility appears to be in compliance with 2D.0540. Condition A.8—This contains the requirements for 2D.0958 which requires the facility to adhere to certain work practice standards when dealing with sources of volatile organic compounds. I could not verify compliance with this condition. Condition A.9-This contains the requirements for 2D .1806 which-requires the owner or operator of a facility to not operate without implementing practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. There have been no odor complaints regarding operations at this facility over the past five years. I could not verify compliance with this condition during this virtual compliance inspection. Condition A.10—This contains the requirements for Rule 2D.2100-Accidental Release Prevention Requirements Under the Clean Air Act, Section 112(r).This facility is subject to the requirements of 112(r) because it has the potential to store greater than 10,000 pounds of butane. This substance is not used as a fuel source for heat,but rather as a blowing agent in the manufacturing process. Therefore,this process is subject Section 112(r). The facility was previously subject to regulation under Section 112(r)because on-site propane storage capacity is higher than the Threshold Quantity of 10,000 pounds(2,260 gallons). Propane is no longer a regulated substance under Section 112(r)and therefore the facility was not subject to Section 112(r) regulations for a period. Because the Permittee recently began using butane as a blowing agent,they are again subject Section 112(r). A Notice of Deficiency(NOD)was issued to Sealed Air Corp on October 3,2014 to address findings during a review of the Permittee's Risk Management Program on August 28,2014. The facility responded to the NOD with supporting documentation which appeared to be adequate. See compliance dated August 28,2014. Mr. White stated that the facility had continued to maintain the Process Safety Management (PSM)program and a Risk Management Plan(RMP). Compliance with 2D .2100 was demonstrated. Note that due to COVID-19,the facility delayed emergency simulation activity with the local emergency response committee. The facility planned to simulate accidental release and a scenario of the count response. The facility plans to perform this simulation activity soon. Condition A.11—This contains the requirements for 2Q .0315,which requires the facility that has a Synthetic Minor classification to limit potential emissions of VOC to less than 100 tons per year;thus, avoiding the facility classification of Title V. The facility is required to use a thermal oxidizer to control VOC emissions from the extrusion processes (ID Nos.EXT-1,EXT-2,EXT-3 and EXT-4). In addition,the facility must perform annual internal inspections and maintenance(I&M)as recommended by the manufacturer on the thermal oxidizer. In addition,the facility must perform an annual internal inspection of the thermal oxidizer. The facility must also record all,inspection and maintenance requirements in a logbook. In addition,the facility must The minimum combustion zone temperature shall be maintained at a minimum 3-hour average of 1600 degrees Fahrenheit, unless otherwise established by stack testing. A data-logger and/or chart recorder shall be used to record the combustion zone temperature of the thermal oxidizer to ensure that the 3-hour average temperature remains at or above 1600 degrees Fahrenheit or no less than the 3-hour average temperature recorded during the most recent DAQ approved test of the thermal oxidizer for volatile organic compounds. The Permittee shall assume no emissions control for any period during which the minimum combustion temperature is not met. Furthermore,the capture efficiency at all times should be greater than 97%and the destruction efficiency greater than 95%. The facility must also meet the"total enclosure"requirements as explained in their permit. The facility is required to keep records of the monthly and total annually facility-wide VOC emissions. In addition,the on a quarterly basis,the facility must record both the supply and exhaust air flow volumes for the production room enclosing the extruders,the curing room,and fluff processing. Finally,records of inspection,maintenance,and monitoring requirements must be recorded in a logbook and available to DAQ upon request. The facility is required to report within 30 days after each calendar year,the monthly VOC emissions for each of the 12-month periods within the previous year and the total VOC emissions for each of the 12- month periods within the previous year. The facility can achieve 100%capture efficiency because the room that houses the extruders and the curing room(ES-CR)meet the definition of"total enclosure"(Ref. July 16, 1993 letter from the company. However,the blowing agent remains the product when it is ready for shipment;therefore,the facility assumes 97.8 percent capture efficiency. During a stack test on November 16,2017,the facility demonstrated that they can achieve 98.4 percent destruction efficiency at an average oxidizer bed temperature of 1843°F. According to Mr. White,the facility is checking their thermal oxidizer temperature every 8 hours. The facility provided a video of their thermal oxidizer inspection log, and according to their records,their last thermal oxidizer internal inspections were conducted on November 20,2020 and December 20,2020. The facility typically performs an internal inspection of their thermal oxidizer every 6 months. Mr. White provided sent me via email a picture of the thermal oxidizer temperature meter, and showed a bed temperature of 1640 F. The facility is also logging the combustion zone temperature of the thermal oxidizer to ensure that the 3-hour average temperature remains at or above 1600 degrees Fahrenheit or no less than the 3-hour average temperature as shown in the photo below. Relative to the extrusion process,the VOC emissions from printing operations associated with the package manufacturing systems(ID Nos.PKG-1 and PKG-2)are very low. The last annual report submitted by the Permittee was received by this office via email on January 7,2021 and reported that around 19.9 tons of VOC were emitted during 2020. Mr.White stated that the facility is keeping track of toxic emissions. Compliance with 2Q .0315 is demonstrated. Condition A.12—This contains the requirements for 2Q .0317. The facility has the potential to exceed 250 tons of VOCs per year and has a PSD avoidance limit to keep actual emissions below this level. Compliance with this regulation is monitored through the Synthetic Minor limit,recordkeeping, and reporting. Condition A.13—This contains the requirements for 2Q .0711 -Toxic Emission Rates Requiring a Permit. Though this facility is toxics triggered,it has not exceeded any TPERs. Therefore,no modeling has been required. Toxic Pollutant Emission Rates(TPERs)are included for the following toxics: Pollutant Carcinogens Chronic Acute Acute 2017 (CAS Number) (lb/yr) Toxicants Systemic Irritants Actual (lb/day) Toxicants (lb/hr) Emissions (lb/hr) benzene 8.1 0.1071b/yr (71-43-2) benzo(a)pyrene 2.2 0.000 lb/yr (50-32-8) formaldehyde 0.04 0.0006lb/hr (50-00-0) n-hexane 23 0.38 lb/day (110-54-3) Pollutant Carcinogens Chronic Acute Acute 2017 (CAS Number) (lb/yr) Toxicants Systemic Irritants Actual (lb/day) Toxicants (lb/hr) Emissions lb/hr methyl ethyl ketone 3.84 lb/day (78-93-3) 78 22.4 0.161b/hr toluene 0.00072 (108-88-3) 98 14.4 lb/day 0.00003 lb/hr With the exception of MEK,potential TAP emissions are from combustion of hydrocarbons(natural gas, propane and butane)and based on natural gas combustion. As shown in the table above for 2017, all TAP emission rates are well below applicable TPERs. MEK emissions come from printing of the package manufacturing systems(ID Nos. PKG-I and PKG-2). There are no controls on this process so all MEK used will be assumed emitted. Actual emissions for MEK are based on data in the 2020 annual report that was submitted to DAQ on January 7,2020. Continued compliance with 2Q .0711 is expected and will be verified through review of required fuel usage and material usage records. 4.) Five Year Compliance History A Notice of Deficiency(NOD)was issued to Sealed Air Corp on October 3, 2014 to address findings during a review of the Permittee's Risk Management Program. There have been no documented violations with their air permit in the last five years. 5.) Stack Test Review: The facility performed a stack test on August 11,2020 due to installation of a new thermal oxidizer(OX-3)that replaced thermal oxidizer OX-2. The facility submitted the stack test report with results on August 21,2020. A stack testing was performed using EPA Method I through 4 and 25A to measure VOC emissions at the inlet and outlet of thermal oxidizer OX-3 to determine the VOC destruction efficiency. Civil& Environmental Consultants,Inc. (CEC)performed EPA Method 1 through 4 and 25A emissions testing at the inlet and outlet of regenerative thermal oxidizer OX-3 to determine the VOC destruction efficiency. The VOC emissions test results show that the oxidizer efficiency meets VOC destruction efficiency requirement listed in the permit. Pollutant/Parameter Test Results Requirement Destruction Efficiency 98.9% >95% Capture Efficiency Not Tested 97% Overall Control Efficiency Not Determined 92% 6.) 112(r)review: This facility is subject to 112(r)requirements because it has the potential to store greater than 10,000 pounds of propane and butane. Neither of these substances are used as a fuel source for heat,but rather as a blowing agent in the manufacturing process. (See Regulatory Review of Specific Condition 10 above). 7.) Compliance Assistance: None 8.) Conclusion: • Recommendations: No permit modification were determined to be necessary at the time of the inspection. • Conclusion/Compliance Statement: As a result of the compliance inspection and the phone conversation with Mr. White, Sealed Air's Hudson operations appeared to be in compliance with Air Quality Permit 07550R09.