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HomeMy WebLinkAboutDEQ-CFW_00087518• • • ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: Emission Unit Description: 11Regulatory Information• BS-C Butacite® Flake Dryer This emission unit is subject to the following regulations: 1. 15A NCAC 2D.0515 - Particulates From Miscellaneous Industrial Processes; and 2. 15A NCAC 2D.0521 - Control of Visible Emissions; The specific limits associated with each of these applicable regulations are as follows: 15A NCAC 2D .0515 states that allowable PM emissions from miscellaneous industrial processes shall be calculated using the equation: E = 4.1 times P to the 0.67 power; where E is equal to the allowable emission limit in lb/hr and P (ton/hr) is equal to the maximum process weight rate of all materials introduced into a specific process that may cause an emission of particulate matter. The flake dryer has a maximum process weight feed rate of 7,300 lb/hr (3.65 ton/hr). Thus for the flake dryer, allowable PM emissions (E) are calculated as = 4.1 (3.65)^0.67 = 9.76 lb/hr. 15A NCAC 2D .0521 requires for installations existing as of July 1, 1971 that visible emissions shall not be more than 40 percent opacity when averaged over a six -minute period except that six -minute periods averaging not more than 90 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. C. Control Device Information: This emission unit is equipped with a separator and bagfilter to control PM emissions. gAproj ects\fayett\d6a11 DEQ-CFW 00087518 ! SECTION D - FORM D6 (continued - page 2) ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION • 0 Emission Unit IDs: Emission Unit Description: D. Compliance Information: BS-C Butacite® Flake Dryer 15A NCAC 2D .0515 - As indicated in the calculations contained in Part A of this D6 Form, worst -case PM emissions are .estimated to be 0.667 lb/hr. As indicated in Part B of this D6 form allowable PM emissions are calculated to be 9.76 lb/hr. Thus, the worst -case emissions are approximately 7% of the allowable emissions, and therefore, no monitoring or recordkeeping is required because compliance with 2D.0515 will be maintained. The cyclone and bagfilter will be periodically inspected per standard operating procedure to ensure proper operation. 15A NCAC 2D .0521 - Because of the low PM emission levels, no opacity problems are expected. Furthermore, historical operating information indicates no opacity problems during normal operation. If there are any indications of unusual opacity problems, steps will be taken to correct the problem. In the event that there is an opacity problem lasting more than four hours NCDEHNR will be contacted as required by 15A NCAC 2D.0535. gAproj e cts\fay ett\d6al I ,Z- J� 0 DEQ-CFW 00087519 FILENAME: BUT-E4 . DBF R-2 SECTION E 44 COMPLIANCE PLAN (METHOD OF COMPLIANCE) A 14 REVISED 04115194 AIR QUALITY SECTION +ISSION SOURCE ID NO. BS-C REGULATED POLLUTANT pM APPLICABLE REGULATION 15A NCAC 2D. 0515 & 15A NCAC 2D. 0521 ALTERNATIVE OPERATING SCENARIO (ADS) NO:N/A MONITORING REQUIREMENTS IS ENHANCED MONITORING APPLICABLE? ( ► YES (X 1 NO IS ENHANCED MONITORING PROTOCOL ATTACHED? ( ) YES (X ) NO MONITORING DEVICE TYPE: Visual examination for opacity MONITORING LOCATION: Near emission point OTHER MONITORING METHODS (DESCRIBE IN DETAIL): potential PM emissions are 7-It of allowable emissions, and compliance is presumed based on compliance history of the source. Any malfunction or upset will be reported pursuant to 15A NCAC 2D.0535. GENERALLY DESCRIBE THE FREQUENCY AND DURATION OF MONITORING AND HOW THE DATA WILL BE RECORDED (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): Opacity monitoring will be performed if there are indications of opacity problems. TEST METHODS ERENCE TEST METHOD DESCRIPTION: N/A REFERENCE TEST METHOD CITATION: RECORDKEEPING REQUIREMENTS DATA (PARAMETER) BEING RECORDED: Recordkeeping will be performed if there is a malfunction or upset pursuant to 15A NCAC 2D.0535. FREQUENCY OF RECOROKEEPING (HOW OFTEN IS DATA RECORDED): As necessary, upon detection of a problem. REPORTING REQUIREMENTS GENERALLY DESCRIBE WHAT IS REPORTED: Any malfunction or upset will be reported pursuant to 15A NCAC 2D.0535. QUENCY: 1 1 MONTHLY ! ! QUARTERLY ( X ) ONCE EVERY G MONTHS ( ) ONCE PER YEAR ( 1 OTHER (DESCRIBE): .7-Lii DEQ-CFW 00087520 r, 4 FILEMANE: BUT-136 R1 SECTION B B6 EMISSION SOURCE (PRINTING) VISED• 05/24/94 AIR QUALITY SECTION EMISSION SOURCE DESCRIPTION: Butacite Tinting EMISSION SOURCE ID NO: BS-D CONTROL DEVICE ID NO(S): EMISSION POINT ID NO(S): BEP-D INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAP REGULATIONS. ALTERNATE OPERATING SCENARIO NO: DESCRIBE PROCESS: Tinting is applied to Butaci to sheeting and dried in a steam heated oven. OPERATING SCHEDULE (ACTUAL) OPERATION DATE: 1985 HRS/DAY: 24 DAYS/WK: 7 WKS/YR: 52 SEASONAL VARIATION (%) JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-DEC: 25 TYPE OF PRINTING OPERATION: Rotogravure WHAT IS BEING PRINTED? Butacite Sheeting CONTINUOUS PRINTING NUMBER OF PRINT STATIONS: CONF WEIGHT OF MATERIAL BEING PRINTED (LB/FT2): CONF MAXIMUM WIDTH OF ITEMS BEING PRINTED (IN): CONF MAXIMUM SPEED (FT/MIN): CONF ACTUAL: CONF NON -CONTINUOUS PRINTING NUMBER OF PRINT STATIONS: WEIGHT OF MATERIAL (LB/100 ITEMS): IMUM DIMENSIONS (IN) LENGTH: WIDTH: MAXIMUM PRINTED/MINUTE: COATING USE ACTUAL USAGE MAXIMUM DESIGN CAPACITY PRINT STATION COATING(S) APPLIED AT THIS STATION (LIST ID) GAUHR GAL/YR GAUHR GAL/YR All V0000 CONF CONF CONF CONF NO. OF BAKE OVENS: METHOD OF HEATING: (XXX ) STEAM ( ) DIRECT FIRED ( ) ELECTRIC ( ) OTHER: FUEL USED: N/A TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR): MAXIMUM ANNUAL FUEL USE: MAXIMUM HOURLY FUEL USE: ACTUAL ANNUAL FUEL USE: ACTUAL HOURLY FUEL USE: DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST POINTS: INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g. hours of operation, material input rates, emission rates, C.) AND DESCRIBE HOW THESE LIMITS ARE MONITORED AND WITH WHAT FREQUENCY. See Form D3 -2 . COMMENTS: Actual coating usage is based on 1994 consumption. a- Ll a DEQ-CFW 00087521 • • • CONFIDENTIAL i I ERM—Southeast, Inc. BUTACITE® TINTING FIGURE CHARLOTTE, NORTH CAROLINA DUPONT - FAYETTEVILLE WORKS BS—D ERM DUART, NORTH CAROLINA D C DEQ-CFW 00087522 4 FILENAME: di . dbf r-1 REVISED: 05/24/94 SECTION 0 PRODUCT ANALYSIS WORKSHEET (VOC EMISSIONS) AIR QUALITY SECTION ATTACH TO APPROPRIATE'B' FORM H PRODUCT NAME: Generic Solvent PRODUCT NO: Generic 1 COATING ID NO: V9999 MANUFACTURER: NIA SUPPLIER: N/A UST EMISSION SOURCE ID NO(S) WHERE PRODUCT IS USED: Throughout facility DESCRIPTION OF USE: Generic solvent used throughout the production process. PRODUCT DENSITY (LB/GAL): varies % BY WEIGHT % BY VOLUME VOLATILE DENSITY IN PRODUCT (LB/GAL): varies LB. VOCIGAL. SOLID APPLIED: SUPPLIED TO APPLICATOR: SOLIDS VOLATILES vari es varies varies vari es KG. VOCILITER SOLID APPLIED: SUPPLIED TO APPLICATOR: WATER varies vari es PRODUCT BREAKDOWN Of CONSTITUENTS (ATTACH MATERIAL SAFETY DATA SHEETS) VOC CONSTITUENTS CAS NO. OF VOLATILES IN PRODUCT OF VOLATILES IN PRODUCT REACTIVITY (CIRCLE ONE) Reactive VOC 1 NIA NIA <5 R1 R2 R3 NR E Reactive VOC 2 NIA NIA <8 R1 R ' R3 NR E Reactive VOC 3 N/A NIA <20 R1 R2 Ra NR E Other VOC NIA NIA <OR=100 R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E R1 R2 R3 NR E TOTAL 100% TOTAL 100% R1 TOTAL <5 REACTIVE COMMENTS: This is a generic non -reactive solvent. All solvents as applied at non -reactive. a-Q R2 R3 TOTAL TOTAL TOTAL <8 <20 ( i NONREACTIVE I the facility are R1,R2,R3 - <20 (XX ) DEQ-CFW 00087523 FILENAME: BUT-D3-I.DBF R-4 SECTION D SPECIFIC EMISSION SOURCE (EMISSION INFORMATION) D3-1 (*see note in instnictions concerning state air toxics regulations) 4REVISED: 04115194 AIR QUALITY SECTION t L r L EMISSION SOURCE DESCRIPTION: Butaci to Tinting EMISSION SOURCE ID NO.: BS-D IS THIS SOURCE A FUGITIVE SOURCE? ( 1 YES ( X I NO ALTERNATIVE OPERATING SCENARIO (ADS) NO: EMISSION RATE IN EMISSION RATE IN LBS(HR LBSIYR EMISSION FACTOR POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL voc 2 See Comment 9.04 79,200 38,200 Dimethyl formamide* 2 See Comment 9.04 79,200 38,200 COMMENTS: Actual emissions are based on 1995 operations. Potential hourly emissions vary depending upon process conditions, and are not quantified. Furthermore, there are no applicable limits associated with hourly emissions from the Tinting process. ote: Emissions of dimethyl formamide (DMF) are for actual and potential emissions prior to the MACT Standard Compliance date of May 1999. After May 1999, potential DMF emissions will be significantly lower. Once DuPont determines its approach for achieving compliance with the MACT Standard, potential emissions of DMF will be revised accordingly. a-qs DEQ-CFW 00087524 FILENAME: BUT.D3-2.DBF R-4 SECTION D D3 2 SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS) 4 REVISED: 04115194 AIR QUALITY SECTION ISSION SOURCE DESCRIPTION: Bu taci to Tin Ling EMISSION SOURCE ID NO: BS -D ALTERNATIVE OPERATING SCENARIO (ADS) NO: REGULATED POLLUTANT EMISSION AND OPERATING LIMITS APPLICABLE REQUIREMENT "Reactive" VOC as Photochemically reactive VOC < 40 lbs/day or 15A NCAC 2D.0518(d) defined in rule controlled by 85-t. Dimethyl Formamide *See Note Below 40CFR Part 63 Subpart KK COMMENTS: Only nonreactive inks are used and therefore the limit on photochemically reactive VOCs does not apply. *Note: DuPont is required to be in compliance with this requirement by May 1999. At this time, the actual approach for achieving compliance has not yet been determined. NCDEHNR will be contacted when ;is approach is determined. DEQ-CFW 00087525 41 FILENAME: BUT-D3-3.DBF R-5 SECTION D SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES) REVISED: 04/15/94 AIR QUALITY SECTION EMISSION SOURC E DESCRIPTION: Butaci to Tinting EMISSION SOURCE ID NO: BS-D REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION ACTIVITIES (LBSNEAR) (LBSNEAR) ACTIVITIES (ENTER CODES) (ENTER CODES) VOc See Note COMMENTS: DuPont maintains ongoing efforts to minimize emissions. DEQ-CFW 00087526 DEQ-CFW 00087526 SECTION D - FORM D6 • ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: BS-D Emission Unit Description: Butacite® Tinting A. Emissions Estimation Approach: Emissions from the Butacite® Tinting process are based on calculations presented in the 1995 Emissions inventory (see attached pages). Actual VOC emissions from Butacite® Tinting in 1995 were 19.1 tons during 4,225 hours of operation. Potential VOC are estimated as 8,760 / 4,225 * 19.1 tons which equals 39.6 tons per year. Actual hourly VOC emissions from the process are estimated as actual annual emissions divided by hours of operation or 19.1 tons 2,000 / 4,225 which equals 9.04 lbs/hour. Potential hourly emissions are not quantified because they depend upon several interrelated parameters. The solvent used in the Tinting process is Dimethylformamide which is a HAP, and is subject to a MACT standard as discussed below. B. Regulatory Information: This emission unit is subject to the following regulations: 15A NCAC 2D .0518 requires that facility -wide emissions of photochemically reactive VOCs (as defined in the rule) be less than 40 pounds per day or be controlled 85% or greater. 40 CFR 63 Subpart KK in general requires each facility that is a major source of hazardous air pollutants (HAP) at which product rotogravure printing presses are operated, to limit emissions to no more than 5 percent of organic HAP applied for the month, or to demonstrate that materials used contain no more that 4% by weight organic HAP. C. Control Device Information: This emission units is not presently equipped with a control device. D. Compliance Information• 15A NCAC 2D .0518 - Only non -reactive inks are used at DuPont Fayetteville Butacite® facility, and therefore, compliance with the facility -wide limit of 401b/day of photochemically reactive VOC will be achieved. 40 CFR 63 Subpart KK - Compliance with this standard is required by May 1999. At this time, DuPont has not yet determined how they will achieve compliance with the standard. There are several possible options including changing to a new ink solvent (which could possibly be water or perhaps a "non -HAP" solvent) or installation of a control device. Once a decision is made, DuPont will contact North Carolina Division of Environmental Health and Natural Resources (NCDEHNR) and submit appropriate permit application forms as necessary. g:\projectsWayett\d6a]1 2 - q F DEQ-CFW 00087527 • • • BUTACITE0 TINTING EMISSIONS CALCULATIONS CONFIDENTIAL -09 DEQ-CFW 00087528 FILENAME:BUT—E4.D13F R-3 SECTION E COMPLIANCE PLAN (METHOD OF COMPLIANCE) 4 REVISED 04115/94 AIR QUALITY SECTION EMISSION SOURCE ID NO. BS—D REGULATED POLLUTANT VOC APPLICABLE REGULATION 15A NCAC 2D. 0518 (d) ALTERNATIVE OPERATING SCENARIO (ADS) NO:N/A MONITORING REQUIREMENTS IS ENHANCED MONITORING APPLICABLE? ( I YES (X ) NO IS ENHANCED MONITORING PROTOCOL ATTACHED? ( ) YES (X ) NO MONITORING DEVICE TYPE: MONITORING LOCATION: OTHER MONITORING METHODS (DESCRIBE IN DETAIL): See below. GENERALLY DESCRIBE THE FREQUENCY AND DURATION OF MONITORING AND HOW THE DATA WILL BE RECORDED (i.e., every 15 minutes, i minute instantaneous readings taken to produce an hourly average): TEST METHODS REFERENCE TEST METHOD DESCRIPTION: N/A REFERENCE TEST METHOD CITATION: RECORDKEEPING REQUIREMENTS DATA (PARAMETER) BEING RECORDED: N/A FREQUENCY OF RECORDKEEPING (HOW OFTEN IS DATA RECORDED): N/A REPORTING REQUIREMENTS GENERALLY DESCRIBE WHAT IS REPORTED: No reporting is necessary because only non -reactive solvents are used. FREQUENCY: ( ) MONTHLY ( ► QUARTERLY 1 1 ONCE EVERY 6 MONTHS ( I ONCE PER YEAR 1 1 OTHER (DESCRIBE): -S0 DEQ-CFW 00087529 FILENAME:BUT—E4.DBF R-6 SECTION E E4 COMPLIANCE PLAN (METHOD OF COMPLIANCE) REVISED 04115194 AIR QUALITY SECTION MISSION SOURCE ID N0. BS—D REGULATED POLLUTANT Dime thyl Formamide APPLICABLE REGULATION 40 CFR Part 63 Subpart KK ALTERNATIVE OPERATING SCENARIO (ADS) NO:N/A MONITORING REQUIREMENTS IS ENHANCED MONITORING APPLICABLE? ( ► YES (X ) NO IS ENHANCED MONITORING PROTOCOL ATTACHED? 1 ► YES (X ) NO MONITORING DEVICE TYPE: MONITORING LOCATION: OTHER MONITORING METHODS (DESCRIBE IN DETAIL): See below. GENERALLY DESCRIBE THE FREQUENCY AND DURATION OF MONITORING AND HOW THE DATA WILL BE RECORDED (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): TEST METHODS FERENCE TEST METHOD DESCRIPTION: N/A REFERENCE TEST METHOD CITATION: RECOROKEEPING REQUIREMENTS DATA (PARAMETER) BEING RECORDED: N/A FREQUENCY OF RECOROKEEPING (HOW OFTEN IS DATA RECORDED): N/A REPORTING REQUIREMENTS GENERALLY DESCRIBE WHAT IS REPORTED: DuPont is required to be in compliance with this requirement by May 1999. At this time, the actual approach for acheiving has not yet been determined. 1VCDEHNR will be contacted when this approach is determined. QUENCY: 1 ) MONTHLY I 1 QUARTERLY ( ► ONCE EVERY 6 MONTHS ( ) ONCE PER YEAR ( I OTHER (DESCRIBE): DEQ-CFW 00087530 r As FILENAME: SECTION E F2 TITLE V INSIGNIFICANT ACTIVITIES SUMMARY REVISED: 04115/94 AIR QUALITY SECTION INSIGNIFICANT ACTIVITIES PER TITLE 15A NCAC 211.0507(b) DESCRIPTION OF EMISSION SOURCE UNITS BASIS FOR EXEMPTION (REF 15A NCAC 20.0507(b)) 1• PVA Unloading System and Silos (Insig-BI) tons/yr ISA NCAC 2Q .01,02(b)(2)(-4v)(i) 2• PVA Dissolver Tanks (Insig-B2) tons/yr I5A NCAC 2Q . 0102 (b) (2) (E) W 3• Rework Vacuum System (Insig-B3) tons/yr 15A NCAC 2Q . 0102 (b) (2) (E) (i) 4• Overseas Container System (Insig-B4) tons/yr 15A NCAC 2Q .0102 (b) (2) (E) (i) 5• Quench Tanks (Insig-B5) tons/yr 15A NCAC 2Q . 0102 (b) (2) (E) (i) 8• Butacite Fugitive Emissions (Insig-B6) tons/yr 15A NCAC 2Q .0102(b) (2) (E) (i) 7. Plasticizer Storage Tank (Insig-B7) tons/yr 15A NCAC 2Q . 0102 (b) (1) (H) (ix) and/or 15A NCAC 2Q. 0102 (b) (2) (F) 8.Butacite Extruders tons/yr 15A NCAC 2Q .0102 (b) (2) (E) W (See attached calculations) REQUEST FOR INSIGNIFICANT ACTIVITIES PER TITLE 15A NCAC 20.0508(aa) DESCRIPTION OF EMISSION SOURCE UNITS BASIS FOR EXEMPTION (SEE INSTRUCTIONS) i. 2. 3. DEQ-CFW 00087531 rI r � • ENGINEERING ANALYSIS OF EMISSIONS Emission Unit ID: Insig-B8 Emission Source Desc. Butacite Extruders Emission Estimation Approach: Emissions from the Butacite extruders are calculated using a mass balance approach. Based on the vapor pressure exerted by organic material in the extruder and the flow rate out of the extruder, material flowrates throughout the entire extruder process are calculated. There are a total of 6 extruders in the extruder operation. The extruder process consists of the extruder unit followed by a knock -out pot, and the steam jet vacuum system (see attached flowchart). Material flowrates into and out of each of these process steps are calculated below. General Steps for Quantifying Emissions: The primary purpose of the extruders is to remove water from the extruder feed material. This is accomplished by heating the feed material and operating the extruders under vacuum conditions. Vacuum is pulled on the extruder by a 2-stage steam jet vacuum system. The vacuum jet system consists of a 1st condenser followed by the 1st vacuum jet, 2nd condenser, 2nd vacuum jet, and lastly a final condenser. The purpose of the first condenser is to remove condensable substances so as to maximize efficiency of the steam jet. The purpose of the 2nd condenser is to condense steam injected into the 1 st vacuum jet in order to maximize efficiency of the 2nd vacuum jet. The purpose of the final condenser is to condense the steam that is injected into the 2nd vacuum jet. The general steps for quantifying emissions are as follows: STEP 1: Estimate VOC's vented from the extruder unit based on water and noncondensables that are vented, total system pressure, and approximate vapor pressure of organics. STEP 2: Calculate amount of VOC that passes through the first condenser based on temperature out of the first condenser, noncondensable flow, and system pressure. STEP 3: Calculate amount of VOC that passes through the second condenser based on temperature of the second condenser, noncondensable flow, and system pressure. STEP 4: Calculate amount of VOC that passes through the final condenser based on temperature of the final condenser, noncondensable flow, and pressure which will be at atmospheric. For Steps 1 and 2, VOC flowrates are calculated on a per extruder basis. For Steps 3 and 4, VOC flowrates are calculated per extruder and for all six extruders combined. EXTRUDERALS, nonconf 10/11/96 a-s3 Page 1 of 5 DEQ-CFW 00087532 0 ENGINEERING ANALYSIS OF EMISSIONS • Emission Unit ID: Insig-B8 Emission Source Desc. Butacite Extruders Process Parameters Used in the Calculations: Total Feed: Fraction Water in Feed: Fraction Water in Output Stream: System Pressure up to the first vacuum jet: Avg. Ext. Vap. Space Temp. Organic Vapor Pressure @ 150 deg. C' Condenser Outlet Temperatures Organic Vapor Pressure @ 35 deg. C' System Pressure between 1 st and 2nd jets: Noncondensable flow through system: Water vapor pressure @ 35 deg. C Plasticizer Molecular Weight CONFIDENTIAL Ibs/hr per extruder CONFIDENTIAL CONFIDENTIAL 90 mmHg 150 degrees Celsius 0.5 mmHg 35 degrees Celsius 0.05 mmHg 225 mmHg 20 Ibs/hour 42.2 mmHg 418 lb/lb-mole ' The vapor pressure is based on a plasticizer which is added to the polyvinyl butyral (PVB) product. This plasticizer is called "4G7" and is tetra ethylene glycol di-heptanoate and has a molecular weight of 418 IbAb-mole. The Butacite product contains approximately 28% 4G7. As is normally the case for compounds with high molecular weights, 4G7 has a very low vapor pressure. According to the MSDS, the vapor pressure of 4G7 is 0.5 mmHg at 200 deg. C and less than 0.01 mmHg at ambient conditions. Other materials are added to PVB to give it various properties, however all of these materials have negligible vapor pressures and are added in very small amounts (0.1 % or less). Nevertheless, to be conservative and to account for overall organic vapor pressure, it is assumed that the organics exert a pressure of 0.5 mmHg at 150 degrees C (this is equal to the vapor pressure of 4G7 at 200 degrees C and allows for some pressure to be exerted by trace constituents) and 0.05 mmHg at 35 degrees C (this accounts for the fact that the vapor pressure of 4G7 which is less than 0.01 mmHg at ambient conditions will be slightly higher at 35 degrees C and also allows for some pressure to be exerted by trace constituents). These vapor pressure values are conservative because it is expected that they overestimate actual vapor pressures primarily because they do not account for mole fractions in the extruder feed (i.e. Raoult's Law), and furthermore, they do not account for molecular level interactions that resist volatilization (this is why all of the water is not removed even though the extruders operate in excess of the atmospheric boiling point temperature of water and under vacuum). EXTRUDER.XLS, nonconf 11/5/96 Page 2 of 5 z- 5� DEQ-CFW 00087533 • ENGINEERING ANALYSIS OF EMISSIONS Emission Unit ID: Insig-B8 Emission Source Desc. Butacite Extruders STEP 1: VOC's vented from extruder: Mass in extruder off -gas (excluding organics): Water 175.5 Ibs/hr Noncondensables 20 Ibs/hr Moles in extruder off -gas (excluding organics): Water 9.75 lb-moles/hr Noncondensables 0.71 lb-moles/hr TOTAL: 10.46 lb-moles/hr Mole fraction of organics: VOC 0.56% Thus, total moles: 10.52 lb-moles/hr 0 Moles VOC: 0.058 lb-moles/hr E Mass VOC 24.44 lb/hour Equals Total Feed times water fraction removed (CONFID) Based on vacuum jet performance curves Based on 18 pounds per lb -mole Based on 28 pounds per lb -mole Calculated as vapor pressure of organics (0.5 mmHg) divided by sys. pressure (90 mmHg) Calculated as moles in offgas (excluding org.) divided by 1 minus VOC mole fraction Calculated as total moles minus moles excluding organics Calculated as moles VOC times plasticizer molecular weight (it is assumed all VOC is plasticizer). EXTRUDERALS, nonconf 10111f96 Page 3 of 5 0�-55 DEQ-CFW 00087534 • ENGINEERING ANALYSIS OF EMISSIONS Emission Unit ID: Insig-B8 Emission Source Desc. Butacite Extruders STEP 2• VOC's passing through the first condenser: Note: Much of the VOC in the extruder off -gas is expected to be captured in the knock -out pot. However, for the purposes of these calculations, it is assumed that all of the VOC enters into the 1st condenser. All of the noncondensables pass through the first condenser. Most of the water and most of the VOC are condensed. The vapor pressure of water and VOC at the condenser outlet are used to calculate their overall mole fraction. Based on this and the known moles of noncondensables passing through the condenser, the mass of VOC and water passing through the condenser is calculated. Mole fraction of Water 46.89% mole fraction Calculated as water vapor pressure (42.2 mmHg) divided by system pressure (90 mmHg) Mole fraction of VOC 0.056% Calculated as VOC vapor pressure (0.05 mmHg) divided by system pressure (90 mmHg) Mole fraction of 53.06% mole fraction Calculated as 1 minus mole fraction of water and VOC noncondensables Total Moles 1.346 lb-moles/hr Calculated as lb -moles of noncondensables (0.71 lb/moles per hour) divided by noncondensable mole fraction. Mass of VOC in 0.313 lb/hour Calculated as mole fraction of VOC (0.056%) times total condenser outlet moles (1.346) times molecular weight (418). EXTRUDER.XLS, nonconf 10111M Page 4 of 5 .� - 5Lo DEQ-CFW 00087535 • • • • ENGINEERING ANALYSIS OF EMISSIONS Emission Unit ID: Insig-BB Emission Source Desc. Butacite Extruders STEP 3• VOC's passing through the second condenser: In general the same approach used in Step 2 is applied here with the only difference being that the system pressure is slightly higher which results in a slightly lower VOC mole fraction. Mole fraction of Water 18.76% mole fraction Calculated as water vapor pressure (42.2 mmHg) divided by system pressure (225 mmHg) Mole fraction of VOC 0.022% Calculated as VOC vapor pressure (0.05 mmHg) divided by system pressure (225 mmHg) Mole fraction of 81.22% mole fraction Calculated as 1 minus mole fraction of water and VOC noncondensables Total Moles 0.879 lb-moles/hr Calculated as lb -moles of noncondensables (0.71 lb/moles per hour) divided by noncondensable mole fraction. Mass of VOC in 0.082 lb/hour per Calculated as mole fraction of VOC (0.022%) times total condenser outlet extruder moles (0,879) times molecular weight (418). Total Potential Emis. 4,294 lb/year Calculated as 0.082 Ib/hr per extruder times 6 extruders before final cond. times 8,760 hours per year. STEP 4: VOC'spassing _through the final condenser: In general the same approach used in Steps 2 and 3 is applied here with the only difference being that the system pressure is atmospheric at the condenser outlet which results in a lower VOC mole fraction. Mole fraction of Water 5.55% mole fraction Calculated as water vapor pressure (42.2 mmHg) divided by system pressure (760 mmHg - atmospheric) Mole fraction of VOC 0.0066% Calculated as VOC vapor pressure (0.05 mmHg) divided by system pressure (760 mmHg) Mole fraction of 94.44% mole fraction Calculated as 1 minus mole fraction of water and VOC noncondensables Total Moles 0.756 lb-moles/hr Calculated as lb -moles of noncondensables (0.71 lb/moles per hour) divided by noncondensable mole fraction. Mass of VOC in 0.021 lb/hour per Calculated as mole fraction of VOC (0.0066%) times total condenser outlet extruder moles (0.756) times molecular weight (418). Total Extruder 1,093 lb/year Calculated as 0.021 Ib/hr per extruder times 6 extruders Potential Emissions times 8,760 hours per year. EXTRUDER.XLS, nonconf 10/11/96 Page 5 of 5 -Sri DEQ-CFW 00087536 r- C CONFIDENT�AL ERM—Southeast, Inc. CHARLOTTE, NORTH CAROLINA BUTACITE ® EXTRUDERS DUPONT — FAYETTEVILLE WORKS DUART, NORTH CAROLINA FlGURE INSIG B8 DEQ-CFW 00087537