Loading...
HomeMy WebLinkAboutAQ_F_1400166_20181030_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Sealed Air Corporation-Hudson NC Facility ID 1400166 Inspection Report County/FIPS: Caldwell/027 Date: 11/13/2018 Facility Data Permit Data Sealed Air Corporation-Hudson Permit 07550/R08 2001 International Boulevard Issued 6/26/2017 Hudson,NC 28638 Expires 5/31/2025 Lat:35d 50.3333m Long: 81d 29.4334m Classification 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 Facility Contact Authorized Contact Technical Contact SH'/112r 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 10/30/2018 Inspector's Name Amm Ali Inspector's Signature: �ji+-- Operating Status Operating Compliance Code Compliance-inspection i Action Code FCE Date of Signature: { j 3 g On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 *HAP 2016 0.0100 0.0100 2.51 22.79 1.76 0.0100 --- 2011 --- 4.26 19.64 9.52 --- --- *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 11/16/2017 Compliance Method 25A ES-CR,ES-FP,EXT-1,EXT-2, EXT-3,EXT-4 Introduction On October 30,2018,Amro Ali conducted an unannounced air quality inspection of Sealed Air Corporation in Hudson,North Carolina. Entry to the facility and access to records was unobstructed and I was accompanied by Mr. Vince White,the Site Manager and BI Moretz,the Maintenance Supervisor,during the inspection. 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. 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. According to Mr.Mortez,the facility operates from 8 AM Monday through Saturday,24 hours a day. The facility received its last inspection on November 16,2017,by Harold Brady,DAQ-ARO.At that time,the facility appeared to be operating in compliance with applicable Air Quality standards and regulations. Permitted Sources Emission Emission Source Control 7 Control System Source ID I� Description I _System I� Description EXT-1, four polyethylene foam extruders OX-2 one electric regenerative thermal oxidizer EXT-2, (115 kilowatt electric heaters with natural EXT-3 and gas injection for low VOC loading,natural EXT-4 gas-fired back-up at a maximum heat input ES-CR one curing room — of 9 million Btu per hour) ES-FP one fluff processing operation !L__ - - --____-___ . ....._. PKG-1 and two package manufacturing systems PKG=2 N/A - ----- ...... , N/A. Insignificant/Exempt Sources i Source Exemption Source of TAPS? Source of Title V Regulation Pollutants? I-1 11 one fluidized sand bath 2Q 0102(h)(5) Yes Yes The Permittee operates an electric fluidized sand bath bum-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. i 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). 2.) Directions: From Lenoir,follow Highway 321A south to International Blvd and turn right. Facility is located on the left. I i 3.) 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 October 30,2018,Amin Ali conducted an unannounced air quality inspection of Sealed L Air Corporation in Hudson,North Carolina. Entry to the facility and access to records was unobstructed and I was accompanied by Mr.Vince White,the Site Manager and BJ Moretz,the Maintenance Supervisor, during the inspection. Three of the four extruders were in operation. Extruder EXT-1 was operating at 60 pounds per hour, Extruder EXT-2 was not operating during the compliance inspection,Extruder EXT-3 was operating at a rate of 108 pounds per hour,and EXT-4 was operating at 801b/hr. At the time of the inspection,the oxidizer(ID No.OX-2)had an average bed temperature of 1839.6°F and the fan speed was set at 60 Hz. There were no visible emissions from the oxidizer at the time of the inspection. Required documentation of inspection and maintenance actives related to the oxidizer appeared to indicate compliance. Records reviewed at the time of the inspection indicated that the last internal inspection of the RTO was last conducted in October 17,2018. One of the two Konvu Retention Packaging lines was operating during this compliance inspection. These two packaging systems were added to the permit with a modification issued November 15,2011. They use a plastic film glued to cardboard substrate to retain or suspend the item being packaged. Air emissions come from the glue used to attach plastic film to cardboard and from an inkjet printer that labels the packaging with patent and serial numbers. The glue contains triethylamine(CAS No. 121-44-8)and the inks contain butanone(methyl ethyl ketone or MEK,CAS No.78-93-3). Both of these are classified as VOC. Triethylamine is also classified as a Hazardous Air Pollutant(HAP)and butanone has an additional classification as a Toxic Air Pollutant(TAP). • Facility Contacts: Vincent White, Site Manager 4.) 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 213.0515. 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.S02 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 appears to be in compliance with 2D.0516. Condition A.5—This contains the requirements for 2D.0521. The facility is required to control any visible emissions from the emission sources that may be discharged from vents or stacks.The emission sources were all manufactured after July 1, 1971.Therefore,the visible emissions for these sources are not to exceed 20 percent opacity when averaged over a six minute period. The oxidizer is the only equipment vented outside the building at the time of this inspection. The unit was observed to be operating with no visible emissions. Compliance with 2D .0521 is indicated. 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. 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. There was no dust observed outside the facility. 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. During inspection, there were no open containers of materials containing VOC(including wipe rags and clean-up materials), that were not in use. Also,there were no spills of materials containing VOC that were not cleaned up. The facility appears to be in compliance with 2D.0958. 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 and we did not observe objectionable odors at the time of this inspection. Compliance with Rule 2D.1806 is demonstrated. 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. At the time of this inspection BJ Moretz confirmed 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. 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 monitor the thermal oxidizer to ensure that minimum bed temperature is greater than 1790*F. 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 p 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. During the compliance inspection,Mr.Ali observed an oxidizer bed temperature of 1839.E°F. Therefore,assuming 97.8 percent capture efficiency,the facility achieves overall destruction efficiency 95.6 percent, The facility performs twice annually an internal inspection of the oxidizer. The latest internal inspections were conducted on April 18,2018 and October 17,2018. i 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 on January 5,2018,and reported that 30 tons of VOC were emitted during 2017. Compliance with 2Q.0315 is indicated. 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 0.107 lb/yr (71-43-2) benzo(a)pyrene 2.2 0.000 lb/yr (50-32-8) formaldehyde 0.04 0.0006 lb/hr (50-00-0) n-hexane 23 0.38 lb/day (110-54-3) methyl ethyl ketone 3.84 lb/day (78-93-3) 78 22.4 0.16lb/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-1 and PKG-2). There are no controls on this process so all MEK used will be assumed emitted. Actual emissions are based on data in the 2017 annual report that was submitted to DAQ on January 5,2018. The facility provided monthly emissions of toxic air pollutants listed above during 2017 and 2018 that demonstrated that the TAP emissions did not exceed the TPER. Continued compliance with 2Q .0711 is expected and will be verified through review of required fuel usage and material usage records. 5.) 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 other documented violations with their air permit in the last five years. 6.) Stack Test Review(since last inspection): The facility performed a stack test on November 17,2017. A stack testing was performed using EPA Method 1 through 4 and 25A to measure VOC emissions at the inlet and outlet of thermal oxidizer OX-2 to determine the VOC destruction efficiency. Civil&Environmental Consultants,Inc.(CEC)performed EPA Method I through 4 and 25A emissions testing at the inlet and outlet of regenerative thermal oxidizer OX-2 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. The oxidizer bed temperature averaged 1843°F during stack testing. Pollutant/Parameter Test Results Requirement Inlet VOC as carbon 145.9 lb/hr --- Outlet VOC as carbon 2.34 lb/hr --- Destruction Efficiency 98.4% >95% Capture Efficiency Not Tested 97% Overall Control Efficiency Not Determined 92% 7.) 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). 8.) Compliance Assistance: None 9.) Recommendation/Compliance Statement/Conclusion: • Recommendations: No permit modification were determined to be necessary at the time of the inspection. • Conclusion/Compliance Statement: At the time of inspection, Sealed Air's Hudson operations appeared to be in compliance with Air Quality Permit 07550R08 on visual observations and records review.