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HomeMy WebLinkAboutDAQ-2024-007876 DAQE-AN141120013-24 {{$d1 }} James Neubauer Charlotte Pipe and Foundry Company PO Box 1339 Monroe, NC 28111-1339 jneubauer@charlottepipe.com Dear Mr. Neubauer: Re: Approval Order: Minor Modification to Approval Order DAQE-AN141120012-23 to Install Storage Silo Project Number: N141120013 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August 16, 2023. Charlotte Pipe and Foundry Company must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Dylan Frederick, who can be contacted at (385) 306-6529 or dfrederick@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:DF:jg cc: Southwest Utah Public Health Department DJ Law, EPA Region 8 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director April 18, 2024 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN141120013-24 Minor Modification to Approval Order DAQE-AN141120012-23 to Install Storage Silo Prepared By Dylan Frederick, Engineer (385) 306-6529 dfrederick@utah.gov Issued to Charlotte Pipe and Foundry Company - Plastics Division - Pipe Manufacturing Plant Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality April 18, 2024 TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 4 Project Description .................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 4 SECTION II: PERMITTED EQUIPMENT .............................................................................. 5 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 11 ACRONYMS ............................................................................................................................... 12 DAQE-AN141120013-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Charlotte Pipe and Foundry Company Charlotte Pipe and Foundry Company - Plastics Division - Pipe Manufacturing Plant Mailing Address Physical Address PO Box 1339 1177 North 5300 West Monroe, NC 28111-1339 Cedar City, UT 84721 Source Contact UTM Coordinates Name: James Neubauer 309,264 m Easting Phone: (704) 226-8335 4,174,696 m Northing Email: jneubauer@charlottepipe.com Datum NAD83 UTM Zone 12 SIC code 3084 (Plastic Pipe) SOURCE INFORMATION General Description Charlotte Pipe and Foundry Company - Plastics Division (Charlotte), operates a pipe manufacturing plant. The facility produces ABS, CPVC, and PVC pipes. The plant operates compound and resin rail car unloading stations, compound and resin storage silos, pneumatic material conveyors, extrusion machines, grinding operations equipment, and ink jet printing lines. Raw material for the pipes arrives in pellet or granular form and is conveyed from rail cars to storage silos. ABS pellets and CPVC compound are transferred directly from storage silos to the extrusion machines. PVC resin is transferred to a mixing station, where minor additives are mixed into the resin. The mixture is then transferred to a second storage silo, and from that storage silo to the extrusion machines. Waste pipe and/or raw material is recycled back into usable material through a pulverizing and grinding process. Ink jet printers are used to print a bar code and specification information on manufactured pipe. The finished pipe is then shipped off-site. NSR Classification Minor Modification at Minor Source Source Classification Located in Attainment Area Iron County Airs Source Size: SM DAQE-AN141120013-24 Page 4 Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Description Charlotte has requested to add a storage silo for PVC compounds at their production facility. The silo will store raw materials for PVC production. This modification will result in an increase in particulate emissions from the storage silo. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 6.13 Carbon Monoxide 0 0.04 Nitrogen Oxides 0 0.17 Particulate Matter - PM10 0.04 0.15 Particulate Matter - PM2.5 0.04 0.15 Sulfur Dioxide 0 0.01 Volatile Organic Compounds 0 22.76 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acrylonitrile (CAS #107131) 0 1000 Ethyl Benzene (CAS #100414) 0 1284 Generic HAPs (CAS #GHAPS) 0 2 Isophorone (CAS #78591) 0 19160 Methanol (CAS #67561) 0 694 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 460 Styrene (CAS #100425) 0 19960 Vinyl Chloride (CAS #75014) 0 99 Change (TPY) Total (TPY) Total HAPs 0 21.33 SECTION I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] DAQE-AN141120013-24 Page 5 I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Charlotte Pipe and Foundry Company - Plastics Division Pipe Manufacturing Plant, Cedar City II.A.2 Rail Car Unloading Station Cyclone exhausts through fabric filters II.A.3 Pipe Grinder for ABS Pipe Extrusion Process Cyclone exhausts through fabric filters II.A.4 Pipe Grinder for CPVC Pipe Extrusion Process Cyclone exhausts through fabric filter II.A.5 Pipe Grinder for PVC Pipe Extrusion Process Cyclone exhausts through fabric filters DAQE-AN141120013-24 Page 6 II.A.6 Injection Molding Process Injection molding process with: storage silos, molding machines, fittings grinder (with internally venting baghouse) II.A.7 Mixing Station with an Aspirator Controlled with a baghouse II.A.8 ABS Pipe Extrusion Processes No control II.A.9 One (1) CPVC Pipe Extruder No control II.A.10 Resin Rail Car Unloading Station Fabric filters II.A.11 PVC Pipe Extrusion Processes No control II.A.12 Ink Jet Printer Process Ink jet printer and associated equipment II.A.13 Emergency Generator Fuel Type: Diesel Electrical Output: 80 kW (107 hp) Manufacturer date: 2007 II.A.14 Pipe Pulverizer Cyclone exhausts through fabric filters II.A.15 Pellet Silo #1 No control II.A.16 Pellet Silo #2 No control II.A.17 Pellet Silo #3 For information only No control II.A.18 Pellet Silo #4 For information only II.A.19 Compound Silo #1 One (1) bin vent cartridge filter (fabric filter) II.A.20 Compound Silo #2 One (1) bin vent cartridge filter (fabric filter) II.A.21 Compound Silo #3 One (1) bin vent cartridge filter (fabric filter) II.A.22 Compound Silo #4 One (1) bin vent cartridge filter (fabric filter) DAQE-AN141120013-24 Page 7 II.A.23 Compound Silo #5 One (1) bin vent cartridge filter (fabric filter) II.A.24 Compound Silo #6 One (1) bin vent cartridge filter (fabric filter) II.A.25 Resin Silo #1 One (1) bin vent cartridge filter (fabric filter) II.A.26 Resin Silo #2 One (1) bin vent cartridge filter II.A.27 500-Gallon Diesel Above-Ground Storage Tank No control SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide II.B.1.a The owner/operator shall control process streams from the silos with fabric filters. All exhaust air from the silos shall be routed through the filters before being vented to the atmosphere. [R307-401-8] II.B.1.b The owner/operator shall install fabric filters in compound silo #6 that are certified to meet a PM10 removal efficiency of 99.8%. [R307-401-8] II.B.1.b.1 The owner/operator shall keep manufacturer records certifying this removal efficiency for the lifetime of the equipment. [R307-401-8] II.B.1.c The owner/operator shall install and operate a baghouse to control process streams from the aspirator. All exhaust air from the aspirator shall be routed through the baghouse before being vented to the atmosphere. [R307-401-8] II.B.1.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across the aspirator baghouse. [R307-401-8] II.B.1.d.1 The pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.1.d.2 The pressure gauges shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.1.e During operation of the aspirator baghouse, the owner/operator shall maintain the static pressure differential within the range recommended by the manufacturer for normal operations. [R307-401-8] II.B.1.e.1 The owner/operator shall record the static pressure differential at least once per operating day while the aspirator baghouse is operating. [R307-401-8] DAQE-AN141120013-24 Page 8 II.B.1.e.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Manufacturer recommended a static pressure differential for the unit; C. Daily static pressure differential readings; D. Date of reading. [R307-401-8] II.B.1.f The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All fabric filters and bin vent cartridge filters - 10% opacity. B. The diesel engine - 20% opacity. C. All other points - 20% opacity. [R307-401-8] II.B.1.f.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.g The owner/operator shall not consume/use more than 3,445 gallons of ink and additives in the Ink Jet Printers combined per rolling 12-month period. [R307-401-8] II.B.1.g.1 The owner/operator shall: A. Determine consumption/usage with an operations log. B. Record consumption/usage on a daily basis. C. Use the consumption/usage data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the consumption/usage records for all periods the plant is in operation. [R307-401-8] II.B.1.h The owner/operator shall not produce more than the following: A. 51,151 tons of ABS pipe per rolling 12-month period. B. 20,134 tons of pipe fittings per rolling 12-month period. C. 2,099 tons of CPVC pipe per rolling 12-month period. D. 99,505 tons of PVC pipe per rolling 12-month period. [R307-401-8] DAQE-AN141120013-24 Page 9 II.B.1.h.1 The owner/operator shall: A. Determine production with an operations log. B. Record production on a daily basis. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.1.i The owner/operator shall not produce more than the following: A. 11,678 pounds of ABS pipe per hour. B. 4,597 pounds of pipe fittings per hour. C. 124,000 pounds of PVC pipe per hour. [R307-401-8] II.B.1.i.1 The owner/operator shall: A. Determine production with an operations log. B. Determine an average hourly production rate for each operational hour for each day. C. Record production on a daily basis. D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.2 Emergency Engine Requirements II.B.2.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engine during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used. B. The duration of operation in hours. C. The reason for the emergency engine usage. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] DAQE-AN141120013-24 Page 10 II.B.2.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] II.B.2.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.3 VOC & HAP Requirements II.B.3.a The owner/operator shall not emit more than the following from pipe production and associated operations: A. 22.76 tons per rolling 12-month period for VOCs. B. 21.33 tons per rolling 12-month period for all HAPs combined. C. 0.50 tons per rolling 12-month period for acrylonitrile. D. 0.64 tons per rolling 12-month period for ethyl benzene. E. 9.59 tons per rolling 12-month period for isophorone. F. 0.35 tons per rolling 12-month period for methanol. G. 0.23 tons per rolling 12-month period for methyl isobutyl ketone. H. 9.98 tons per rolling 12-month period for styrene. I. 0.05 tons per rolling 12-month period for vinyl chloride. [R307-401-8] II.B.3.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] II.B.3.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] DAQE-AN141120013-24 Page 11 II.B.3.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material. B. The maximum percent by weight of VOCs and each HAP in each material used. C. The density of each material used. D. The volume of each VOC- and HAP-emitting material used. E. The amount of VOCs and the amount of each HAP emitted from each material. F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material. G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN141120012-23 dated June 20, 2023 Is Derived From NOI dated August 16, 2023 DAQE-AN141120013-24 Page 12 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds DAQE-IN141120013-24 March 13, 2024 James Neubauer Charlotte Pipe and Foundry Company PO Box 1339 Monroe, NC 28111-1339 jneubauer@charlottepipe.com Dear Mr. Neubauer: Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN141120012-23 to Install Storage Silo Project Number: N141120013 The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is subject to public review. Any comments received shall be considered before an Approval Order (AO) is issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO. Future correspondence on this ITA should include the engineer's name, Dylan Frederick, as well as the DAQE number as shown on the upper right-hand corner of this letter. Dylan Frederick, can be reached at (385) 306-6529 or dfrederick@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:DF:jg cc: Southwest Utah Public Health Department DJ Law, EPA Region 8 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN141120013-24 Minor Modification to Approval Order DAQE-AN141120012-23 to Install Storage Silo Prepared By Dylan Frederick, Engineer (385) 306-6529 dfrederick@utah.gov Issued to Charlotte Pipe and Foundry Company - Plastics Division - Pipe Manufacturing Plant Issued On March 13, 2024 {{$s }} New Source Review Section Manager Alan D. Humpherys {{#s=Sig_es_:signer1:signature}} TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 GENERAL INFORMATION ...................................................................................................... 3 CONTACT/LOCATION INFORMATION ............................................................................... 3 SOURCE INFORMATION ........................................................................................................ 3 General Description ................................................................................................................ 3 NSR Classification .................................................................................................................. 3 Source Classification .............................................................................................................. 3 Applicable Federal Standards ................................................................................................. 3 Project Description.................................................................................................................. 4 SUMMARY OF EMISSIONS .................................................................................................... 4 PUBLIC NOTICE STATEMENT............................................................................................... 4 SECTION I: GENERAL PROVISIONS .................................................................................... 5 SECTION II: PERMITTED EQUIPMENT .............................................................................. 6 SECTION II: SPECIAL PROVISIONS ..................................................................................... 7 PERMIT HISTORY ................................................................................................................... 12 ACRONYMS ............................................................................................................................... 13 DAQE-IN141120013-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Charlotte Pipe and Foundry Company Charlotte Pipe and Foundry Company - Plastics Division - Pipe Manufacturing Plant Mailing Address Physical Address PO Box 1339 1177 North 5300 West Monroe, NC 28111-1339 Cedar City, UT 84721 Source Contact UTM Coordinates Name: James Neubauer 309,264 m Easting Phone: (704) 226-8335 4,174,696 m Northing Email: jneubauer@charlottepipe.com Datum NAD83 UTM Zone 12 SIC code 3084 (Plastic Pipe) SOURCE INFORMATION General Description Charlotte Pipe and Foundry Company - Plastics Division (Charlotte), operates a pipe manufacturing plant. The facility produces ABS, CPVC, and PVC pipes. The plant operates compound and resin rail car unloading stations, compound and resin storage silos, pneumatic material conveyors, extrusion machines, grinding operations equipment, and ink jet printing lines. Raw material for the pipes arrives in pellet or granular form and is conveyed from rail cars to storage silos. ABS pellets and CPVC compound are transferred directly from storage silos to the extrusion machines. PVC resin is transferred to a mixing station, where minor additives are mixed into the resin. The mixture is then transferred to a second storage silo, and from that storage silo to the extrusion machines. Waste pipe and/or raw material is recycled back into usable material through a pulverizing and grinding process. Ink jet printers are used to print a bar code and specification information on manufactured pipe. The finished pipe is then shipped off-site. NSR Classification Minor Modification at Minor Source Source Classification Located in Attainment Area Iron County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal DAQE-IN141120013-24 Page 4 Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Description Charlotte has requested to add a storage silo for PVC compounds at their production facility. The silo will store raw materials for PVC production. This modification will result in an increase in particulate emissions from the storage silo. SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 6.13 Carbon Monoxide 0 0.04 Nitrogen Oxides 0 0.17 Particulate Matter - PM10 0.04 0.15 Particulate Matter - PM2.5 0.04 0.15 Sulfur Dioxide 0 0.01 Volatile Organic Compounds 0 22.76 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acrylonitrile (CAS #107131) 0 1000 Ethyl Benzene (CAS #100414) 0 1284 Generic HAPs (CAS #GHAPS) 0 2 Isophorone (CAS #78591) 0 19160 Methanol (CAS #67561) 0 694 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 460 Styrene (CAS #100425) 0 19960 Vinyl Chloride (CAS #75014) 0 99 Change (TPY) Total (TPY) Total HAPs 0 21.33 PUBLIC NOTICE STATEMENT The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Daily Spectrum on March 17, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as DAQE-IN141120013-24 Page 5 practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received. SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] DAQE-IN141120013-24 Page 6 SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT II.A.1 Charlotte Pipe and Foundry Company - Plastics Division Pipe Manufacturing Plant, Cedar City II.A.2 Rail Car Unloading Station Cyclone exhausts through fabric filters II.A.3 Pipe Grinder for ABS Pipe Extrusion Process Cyclone exhausts through fabric filters II.A.4 Pipe Grinder for CPVC Pipe Extrusion Process Cyclone exhausts through fabric filter II.A.5 Pipe Grinder for PVC Pipe Extrusion Process Cyclone exhausts through fabric filters II.A.6 Injection Molding Process Injection molding process with: storage silos, molding machines, fittings grinder (with internally venting baghouse) II.A.7 Mixing Station with an Aspirator Controlled with a baghouse II.A.8 ABS Pipe Extrusion Processes No control II.A.9 One (1) CPVC Pipe Extruder No control II.A.10 Resin Rail Car Unloading Station Fabric filters II.A.11 PVC Pipe Extrusion Processes No control II.A.12 Ink Jet Printer Process Ink jet printer and associated equipment II.A.13 Emergency Generator Fuel Type: Diesel Electrical Output: 80 kW (107 hp) Manufacturer date: 2007 II.A.14 Pipe Pulverizer Cyclone exhausts through fabric filters II.A.15 Pellet Silo #1 No control DAQE-IN141120013-24 Page 7 II.A.16 Pellet Silo #2 No control II.A.17 Pellet Silo #3 For information only No control II.A.18 Pellet Silo #4 For information only II.A.19 Compound Silo #1 One (1) bin vent cartridge filter (fabric filter) II.A.20 Compound Silo #2 One (1) bin vent cartridge filter (fabric filter) II.A.21 Compound Silo #3 One (1) bin vent cartridge filter (fabric filter) II.A.22 Compound Silo #4 One (1) bin vent cartridge filter (fabric filter) II.A.23 Compound Silo #5 One (1) bin vent cartridge filter (fabric filter) II.A.24 Compound Silo #6 One (1) bin vent cartridge filter (fabric filter) II.A.25 Resin Silo #1 One (1) bin vent cartridge filter (fabric filter) II.A.26 Resin Silo #2 One (1) bin vent cartridge filter II.A.27 500-Gallon Diesel Above-Ground Storage Tank No control SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide II.B.1.a The owner/operator shall control process streams from the silos with fabric filters. All exhaust air from the silos shall be routed through the filters before being vented to the atmosphere. [R307-401-8] II.B.1.b The owner/operator shall install fabric filters in compound silo #6 that are certified to meet a PM10 removal efficiency of 99.8%. [R307-401-8] DAQE-IN141120013-24 Page 8 II.B.1.b.1 The owner/operator shall keep manufacturer records certifying this removal efficiency for the lifetime of the equipment. [R307-401-8] II.B.1.c The owner/operator shall install and operate a baghouse to control process streams from the aspirator. All exhaust air from the aspirator shall be routed through the baghouse before being vented to the atmosphere. [R307-401-8] II.B.1.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across the aspirator baghouse. [R307-401-8] II.B.1.d.1 The pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.1.d.2 The pressure gauges shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.1.e During operation of the aspirator baghouse, the owner/operator shall maintain the static pressure differential within the range recommended by the manufacturer for normal operations. [R307-401-8] II.B.1.e.1 The owner/operator shall record the static pressure differential at least once per operating day while the aspirator baghouse is operating. [R307-401-8] II.B.1.e.2 The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Manufacturer recommended a static pressure differential for the unit; C. Daily static pressure differential readings; D. Date of reading. [R307-401-8] II.B.1.f The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All fabric filters and bin vent cartridge filters - 10% opacity B. The diesel engine - 20% opacity C. All other points - 20% opacity. [R307-401-8] II.B.1.f.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.g The owner/operator shall not consume/use more than 3,445 gallons of ink and additives in the Ink Jet Printers combined per rolling 12-month period. [R307-401-8] DAQE-IN141120013-24 Page 9 II.B.1.g.1 The owner/operator shall: A. Determine consumption/usage with an operations log B. Record consumption/usage on a daily basis C. Use the consumption/usage data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the consumption/usage records for all periods the plant is in operation. [R307-401-8] II.B.1.h The owner/operator shall not produce more than the following: A. 51,151 tons of ABS pipe per rolling 12-month period B. 20,134 tons of pipe fittings per rolling 12-month period C. 2,099 tons of CPVC pipe per rolling 12-month period D. 99,505 tons of PVC pipe per rolling 12-month period. [R307-401-8] II.B.1.h.1 The owner/operator shall: A. Determine production with an operations log B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.1.i The owner/operator shall not produce more than the following: A. 11,678 pounds of ABS pipe per hour B. 4,597 pounds of pipe fittings per hour C. 124,000 pounds of PVC pipe per hour. [R307-401-8] DAQE-IN141120013-24 Page 10 II.B.1.i.1 The owner/operator shall: A. Determine production with an operations log B. Determine an average hourly production rate for each operational hour for each day C. Record production on a daily basis D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.2 Emergency Engine Requirements II.B.2.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engine during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] II.B.2.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] DAQE-IN141120013-24 Page 11 II.B.3 VOC & HAP Requirements II.B.3.a The owner/operator shall not emit more than the following from pipe production and associated operations: A. 22.76 tons per rolling 12-month period for VOCs B. 21.33 tons per rolling 12-month period for all HAPs combined C. 0.50 tons per rolling 12-month period for acrylonitrile D. 0.64 tons per rolling 12-month period for ethyl benzene E. 9.59 tons per rolling 12-month period for isophorone F. 0.35 tons per rolling 12-month period for methanol G. 0.23 tons per rolling 12-month period for methyl isobutyl ketone H. 9.98 tons per rolling 12-month period for styrene I. 0.05 tons per rolling 12-month period for vinyl chloride. [R307-401-8] II.B.3.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.3.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] DAQE-IN141120013-24 Page 12 II.B.3.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN141120012-23 dated June 20, 2023 Is Derived From NOI dated August 16, 2023 DAQE-IN141120013-24 Page 13 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by Environmental Protection Agency to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal Division of Air Quality use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i) GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818- 12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds Govt Public Notices Originally published at thespectrum.com on 03/17/2024 NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Charlotte Pipe and Foundry Company Location: Charlotte Pipe and Foundry Company - Plastics Division - Pipe Manufacturing Plant – 1177 North 5300 West, Cedar City, UT Project Description: Charlotte Pipe and Foundry Company operates a pipe manufacturing plant. They have requested to add a storage silo for PVC compounds at their production facility. This request will result in the addition of a storage silo with a maximum annual throughput of 87,600 tons per year of PVC compounds. In addition to the storage silo being added, some permit requirements have been reformatted to match the language in recently issued approval orders. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before April 16, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at dfrederick@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: March 17, 2024 Pub# 9958035 Published March 17, 2024 The Spectrum UPAXLP DAQE-NN141120013-24 March 13, 2024 Daily Spectrum Legal Advertising Department 275 E Street St. George, UT 84770 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Daily Spectrum on March 17, 2024. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions, contact Jeree Greenwood, who may be reached at (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Five County Association of Governments cc: Iron County 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director DAQE-NN141120013-24 Page 2 NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for consideration by the Director: Company Name: Charlotte Pipe and Foundry Company Location: Charlotte Pipe and Foundry Company - Plastics Division - Pipe Manufacturing Plant – 1177 North 5300 West, Cedar City, UT Project Description: Charlotte Pipe and Foundry Company operates a pipe manufacturing plant. They have requested to add a storage silo for PVC compounds at their production facility. This request will result in the addition of a storage silo with a maximum annual throughput of 87,600 tons per year of PVC compounds. In addition to the storage silo being added, some permit requirements have been reformatted to match the language in recently issued approval orders. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before April 16, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at dfrederick@utah.gov. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. Date of Notice: March 17, 2024 {{#s=Sig_es_:signer1:signature}} DAQE- RN141120013 March 6, 2024 James Neubauer Charlotte Pipe and Foundry Co. PO Box 1339 Monroe, NC 281111339 jneubauer@charlottepipe.com Dear James Neubauer, Re: Engineer Review: Minor Modification to DAQE-AN141120012-23 to Install Storage Silo Project Number: N141120013 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Charlotte Pipe and Foundry Co. should complete this review within 10 business days of receipt. Charlotte Pipe and Foundry Co. should contact Dylan Frederick at (385) 306-6529 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Dylan Frederick at dfrederick@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director. If Charlotte Pipe and Foundry Co. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Charlotte Pipe and Foundry Co. has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date) 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N141120013 Owner Name Charlotte Pipe and Foundry Co. Mailing Address PO Box 1339 Monroe, NC, 281111339 Source Name Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant Source Location 1177 North 5300 West Cedar City, UT 84721 UTM Projection 309,264 m Easting, 4,174,696 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3084 (Plastic Pipe) Source Contact James Neubauer Phone Number (704) 226-8335 Email jneubauer@charlottepipe.com Billing Contact James Neubauer Phone Number (704) 226-8335 Email jneubauer@charlottepipe.com Project Engineer Dylan Frederick, Engineer Phone Number (385) 306-6529 Email dfrederick@utah.gov Notice of Intent (NOI) Submitted August 16, 2023 Date of Accepted Application October 4, 2023 Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 2 SOURCE DESCRIPTION General Description Charlotte Pipe and Foundry Company - Plastics Division (Charlotte), operates a pipe manufacturing plant. The facility produces ABS, CPVC, and PVC pipes. The plant operates compound and resin rail car unloading stations, compound and resin storage silos, pneumatic material conveyors, extrusion machines, grinding operations equipment, and ink jet printing lines. Raw material for the pipes arrives in pellet or granular form, and are conveyed from rail cars to storage silos. ABS pellets and CPVC compound are transferred directly from storage silos to the extrusion machines. PVC resin is transferred to a mixing station where minor additives are mixed into the resin. The mixture is then transferred to a second storage silo and from that storage silo to the extrusion machines. Waste pipe and/or raw material is recycled back into useable material through a pulverizing and grinding process. Ink jet printers are used to print a bar code and specification information on manufactured pipe. The finished pipe is then shipped off-site. NSR Classification: Minor Modification at Minor Source Source Classification Located in Attainment Area Iron County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal Minor Modification to DAQE-AN141120012-23 to Install Storage Silo Project Description Charlotte has requested to add a storage silo for PVC compounds at their production facility. The silo will store raw materials for PVC production. This modification will result in an increase in particulate emissions from the storage silo. EMISSION IMPACT ANALYSIS All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP emissions are below their respective emission threshold values in R307-410-5. Therefore, no modeling is required for this source. [Last updated January 1, 2024] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 3 SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible. Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 6.13 Carbon Monoxide 0 0.04 Nitrogen Oxides 0 0.17 Particulate Matter - PM10 0.04 0.15 Particulate Matter - PM2.5 0.04 0.15 Sulfur Dioxide 0 0.01 Volatile Organic Compounds 0 22.76 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) Acrylonitrile (CAS #107131) 0 1000 Ethyl Benzene (CAS #100414) 0 1284 Generic HAPs (CAS #GHAPS) 0 2 Isophorone (CAS #78591) 0 19160 Methanol (CAS #67561) 0 694 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 460 Styrene (CAS #100425) 0 19960 Vinyl Chloride (CAS #75014) 0 99 Change (TPY) Total (TPY) Total HAPs 0 21.33 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding Storage Silo The new storage silo will increase potential emissions of particulates from PVC compounds stored and moved through the silo. The silo system operates with a filtration system that regulates air flow and is necessary for the process due to the potential for high loss of material as it moves through the silo. This filtration system can be equipped with add-on control devices to control emissions from the PVC compound material. The easiest option to incorporate into the existing filtration system are fabric filters. Charlotte evaluated fabric filters to control emissions from the silo. The proposed filters offer a control efficiency of up to 99.8% and are both technically and economically feasible to implement. This measure is accepted as BACT for the storage silo. BACT for control of PM10 and PM2.5 from the storage silo will be the use of fabric filters guaranteed by the manufacturer to meet a control efficiency of 99.8% and to maintain a 10% opacity limit. [Last updated February 12, 2024] SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307- 401-4] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 5 I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Charlotte Pipe and Foundry Co - Plastics Division Pipe Manufacturing Plant, Cedar City II.A.2 Rail Car Unloading Station Cyclone exhausts through fabric filters II.A.3 Pipe Grinder for ABS Pipe Extrusion Process Cyclone exhausts through fabric filters II.A.4 Pipe Grinder for CPVC Pipe Extrusion Process Cyclone exhausts through fabric filter II.A.5 Pipe Grinder for PVC Pipe Extrusion Process Cyclone exhausts through fabric filters II.A.6 Injection Molding Process Injection molding process with: storage silos, molding machines, fittings grinder (with internally venting baghouse) II.A.7 Mixing Station with an Aspirator Controlled with a baghouse II.A.8 ABS Pipe Extrusion Processes No control II.A.9 One (1) CPVC Pipe Extruder No control Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 6 II.A.10 Resin Rail Car Unloading Station Fabric filters II.A.11 PVC Pipe Extrusion Processes No control II.A.12 Ink Jet Printer Process Ink jet printer and associated equipment II.A.13 Emergency Generator Fuel Type: Diesel Electrical Output: 80 kW (107 hp) Manufacturer date: 2007 II.A.14 Pipe Pulverizer Cyclone exhausts through fabric filters II.A.15 Pellet Silo #1 No control II.A.16 Pellet Silo #2 No control II.A.17 Pellet Silo #3 For information only No control II.A.18 Pellet Silo #4 For information only II.A.19 Compound Silo #1 One (1) bin vent cartridge filter (fabric filter) II.A.20 Compound Silo #2 One (1) bin vent cartridge filter (fabric filter) II.A.21 Compound Silo #3 One (1) bin vent cartridge filter (fabric filter) II.A.22 Compound Silo #4 One (1) bin vent cartridge filter (fabric filter) II.A.23 Compound Silo #5 One (1) bin vent cartridge filter (fabric filter) II.A.24 NEW Compound Silo #6 One (1) bin vent cartridge filter (fabric filter) Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 7 II.A.25 Resin Silo #1 One (1) bin vent cartridge filter (fabric filter) II.A.26 Resin Silo #2 One (1) bin vent cartridge filter II.A.27 500-Gallon Diesel Above-Ground Storage Tank No control SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide II.B.1.a NEW The owner/operator shall control process streams from the silos with fabric filters. All exhaust air from the silos shall be routed through the filters before being vented to the atmosphere. [R307-401-8] II.B.1.b NEW The owner/operator shall install fabric filters in compound silo #6 that are certified to meet a PM10 removal efficiency of 99.8%. [R307-401-8] II.B.1.b.1 NEW The owner/operator shall keep manufacturer records certifying this removal efficiency for the lifetime of the equipment. [R307-401-8] II.B.1.c The owner/operator shall install and operate a baghouse to control process streams from the aspirator. All exhaust air from the aspirator shall be routed through the baghouse before being vented to the atmosphere. [R307-401-8] II.B.1.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across the aspirator baghouse. [R307-401-8] II.B.1.d.1 The pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.1.d.2 The pressure gauges shall measure the static pressure differential in 1-inch water column increments or less. [R307-401-8] II.B.1.e During operation of the aspirator baghouse, the owner/operator shall maintain the static pressure differential within the range recommended by the manufacturer for normal operations. [R307-401-8] II.B.1.e.1 The owner/operator shall record the static pressure differential at least once per operating day while the aspirator baghouse is operating. [R307-401-8] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 8 II.B.1.e.2 NEW The owner/operator shall maintain the following records of the static pressure differential: A. Unit identification; B. Manufacturer recommended static pressure differential for the unit; C. Daily static pressure differential readings; D. Date of reading. [R307-401-8] II.B.1.f NEW The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All fabric filters and bin vent cartridge filters - 10% opacity B. The diesel engine - 20% opacity C. All other points - 20% opacity. [R307-401-8] II.B.1.f.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.g NEW The owner/operator shall not consume/use more than 3,445 gallons of ink and additives in the Ink Jet Printers combined per rolling 12-month period. [R307-401-8] II.B.1.g.1 NEW The owner/operator shall: A. Determine consumption/usage with an operations log B. Record consumption/usage on a daily basis C. Use the consumption/usage data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the consumption/usage records for all periods the plant is in operation. [R307- 401-8] II.B.1.h NEW The owner/operator shall not produce more than the following: A. 51,151 tons of ABS pipe per rolling 12-month period B. 20,134 tons of pipe fittings per rolling 12-month period C. 2,099 tons of CPVC pipe per rolling 12-month period D. 99,505 tons of PVC pipe per rolling 12-month period. [R307-401-8] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 9 II.B.1.h.1 NEW The owner/operator shall: A. Determine production with an operations log. B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.1.i NEW The owner/operator shall not produce more than the following: A. 11,678 pounds of ABS pipe per hour B. 4,597 pounds of pipe fittings per hour C. 124,000 pounds of PVC pipe per hour. [R307-401-8] II.B.1.i.1 NEW The owner/operator shall: A. Determine production with an operations log B. Determine an average hourly production rate for each operational hour for each day C. Record production on a daily basis D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.2 Emergency Engine Requirements II.B.2.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engine during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307- 401-8] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 10 II.B.2.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] II.B.2.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.2.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.3 VOC & HAP Requirements II.B.3.a NEW The owner/operator shall not emit more than the following from pipe production and associated operations: A. 22.76 tons per rolling 12-month period for VOCs B. 21.33 tons per rolling 12-month period for all HAPs combined C. 0.50 tons per rolling 12-month period for acrylonitrile D. 0.64 tons per rolling 12-month period for ethyl benzene E. 9.59 tons per rolling 12-month period for isophorone F. 0.35 tons per rolling 12-month period for methanol G. 0.23 tons per rolling 12-month period for methyl isobutyl ketone H. 9.98 tons per rolling 12-month period for styrene I. 0.05 tons per rolling 12-month period for vinyl chloride. [R307-401-8] II.B.3.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8] II.B.3.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 11 II.B.3.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons) [R307-401-8] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 12 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes DAQE-AN141120012-23 dated June 20, 2023 Is Derived From NOI dated August 16, 2023 REVIEWER COMMENTS 1. Comment regarding Emission Estimates: Emission estimates for this modification were calculated using the following methods: Silo Emissions - Emissions for each silo are calculated assuming an hourly throughput of 20,000 lbs of materials per hour, for 8760 hours per year. An emission factor is used from AP-42 Chapter 11.12, Emission Factors for Concrete Batching, Cement Unloading to Elevated Storage Silo (pneumatic). The emission factor is for PM10, and PM2.5 emissions are conservatively estimated to be equal to PM10 emissions. The new silo is estimated to control PM emissions with an efficiency of 99.80% per manufacturer specifications for the fabric filters in the baghouse controlling emissions. For all other silos, a control efficiency of 99.94% is assumed based on PVC resin particle size distribution. [Last updated January 2, 2024] 2. Comment regarding NSPS and MACT Review: 40 CFR 60 (NSPS) Subpart IIII applies to "Owners and operators of any stationary CI ICE that are modified or reconstructed after July 11, 2005 and any person that modifies or reconstructs any stationary CI ICE after July 11, 2005." The 80 kW emergency diesel generator was constructed and installed after the applicability date listed in this subpart, and is therefore applicable. The owner/operator must comply with the emission standards for emergency engines listed in section 60.4205 of this subpart that are applicable to the engine, based on the model year of the engine and total displacement of the engine cylinders. 40 CFR 63 (MACT) Subpart ZZZZ applies to owners and operators of "stationary RICE at a major or area source of HAP emissions". The 80 kW emergency engine meets the definition of a stationary RICE in this subpart, therefore, this subpart applies to the engine. Compliance with this subpart is met through compliance with NSPS Subpart IIII. [Last updated January 2, 2024] 3. Comment regarding Title V: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 61 (NESHAP) regulations. The facility is subject to 40 CFR 60 (NSPS), 40 CFR 63 (MACT) regulations. 40 CFR 70 (Title V permit) does not apply because NSPS IIII and MACT ZZZZ exempt Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 13 sources from the obligation to obtain a permit under a Title V permit, if the source is not otherwise required by law to obtain a permit. There are no other reasons why this source would be required to obtain a Title V permit; therefore, Title V does not apply to this facility. [Last updated February 12, 2024] Engineer Review N141120013: Charlotte Pipe and Foundry Co. - Plastics Division - Pipe Manufacturing Plant March 6, 2024 Page 14 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds NOTICE OF INTENT FOR AN APPROVAL ORDER NEW PVC COMPOUND SILO CHARLOTTE PIPE AND FOUNDRY COMPANY PLASTICS DIVISION CEDAR CITY, UTAH Prepared For: CHARLOTTE PIPE AND FOUNDRY COMPANY PLASTICS DIVISION MONROE, NORTH CAROLINA Prepared By: CIVIL & ENVIRONMENTAL CONSULTANTS, INC. CHARLOTTE, NORT CAROLINA CEC Project 310-458 AUGUST 2023 -i- CPFC New Compound Silo #6 August 2023 TABLE OF CONTENTS 1.0 SOURCE IDENTIFICATION INFORMATION ...........................................................1 1.1 Company Information ............................................................................................. 1 1.2 Area Designation .................................................................................................... 1 1.3 Federal requirement applicability ........................................................................... 1 1.3.1 Prevention of Significant Deterioration (PSD) ............................................2 1.3.2 Title V of the Clean Air Act Amendments ..................................................2 1.3.3 New Source Performance Standards (NSPS) ..............................................3 1.3.4 National Emission Standards for Hazardous Air Pollutants (NESHAP) ...................................................................................................3 1.3.5 Risk Management Plan (RMP) ....................................................................3 1.3.6 Stratospheric Ozone Protection ....................................................................3 1.4 Utah State Implementation Plan (SIP) Regulatory Applicability ........................... 4 1.4.1 R307-401-8 Silo Bin Vents ..........................................................................4 1.4.2 R307-401-8 Opacity.....................................................................................4 1.4.3 R307-401-8 Consumption Limits ................................................................4 1.4.4 R307-401-8 VOC and HAP Limitations......................................................4 1.4.5 R307-401-8 Pipe Production........................................................................4 1.5 Source Size Determination ..................................................................................... 5 2.0 NOI APPLICATION INFORMATION ..........................................................................6 2.1 project Description .................................................................................................. 6 2.2 Fuel, Raw Material and Products COnsumed / Produced....................................... 6 2.3 Description of Equipment and Operating Schedule................................................ 6 2.4 Changes to Process Rate and Production Rates ...................................................... 7 2.5 Best Available Control Technology (BACT) Analysis .......................................... 7 2.6 Emissions Related Information ............................................................................... 8 2.6.1 Summary of Emissions ................................................................................8 2.6.2 Emission Calculations ..................................................................................9 2.6.3 References and Assumptions .......................................................................9 2.6.4 Speciated HAP Emissions............................................................................9 2.7 Emission Impact Analysis....................................................................................... 9 2.8 Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) .......... 10 2.9 Major Sources in Attainment or Unclassified Areas (PSD) ................................. 10 -ii- CPFC New Compound Silo #6 August 2023 FIGURES Figure 1 Site Map and Proposed Silo Location ATTACHMENTS Attachment 1 - Form 2 – Company Information/Notice of Intent (NOI) Attachment 2 - Form 4 – Process Data Attachment 3 - Form 5 – Emissions information Attachment 4 - Emission Calculations Attachment 5 - Silo Dimensions Attachment 6 - Bin Vent Details Attachment 7 - Filter Cartridge Documentation -1- CPFC New Compound Silo #6 August 2023 1.0 SOURCE IDENTIFICATION INFORMATION Charlotte Pipe and Foundry Company (CPFC) located in Cedar City (Iron County) proposes to install a new PVC Compound Silo, “Compound Silo #6”. 1.1 COMPANY INFORMATION Form 2 - Company Information/Notice of Intent (NOI) is provided as Attachment 1. 1.2 AREA DESIGNATION Iron County is in attainment for all criteria pollutants. 1.3 FEDERAL REQUIREMENT APPLICABILITY Applicability or non-applicability of the following regulatory programs is addressed in this section: • Prevention of Significant Deterioration (PSD) permitting; • Title V of the 1990 Clean Air Act Amendments; • New Source Performance Standards (NSPS); • National Emission Standards for Hazardous Air Pollutants (NESHAP); • Risk Management Plan (RMP); • Stratospheric Ozone Protection; and • Utah State Implementation Plan (SIP) regulations. In addition to providing a summary of applicable requirements, this section of the application also provides non-applicability determinations for certain regulations. Explanations of non- applicability are limited to those regulations for which there may be some question of applicability specific to CPFC. Regulations that are categorically non-applicable are not discussed. -2- CPFC New Compound Silo #6 August 2023 1.3.1 Prevention of Significant Deterioration (PSD) PSD standards are applicable to major stationary sources of air pollution. Major stationary sources are those sources with the potential to emit (PTE) 250 tons per year or more of a regulated New Source Review (NSR) pollutant. For sources in specific categories (none of which CPFC is included in), the PTE threshold is 100 tons per year. The PSD regulations are applicable to sources located in an attainment or unclassifiable area. [40 CFR 51.21] CPFC facility-wide PTE emissions of regulated NSR pollutants will be less than 250 tons per year after the proposed installation of the PVC Compound Silo. Therefore, PSD regulations are not applicable. 1.3.2 Title V of the Clean Air Act Amendments Any operation meeting the criteria for a major source must apply for an Operating Permit. Operating Permits are required by Title V of the Clean Air Act Amendments. Utah Administrative code (UAC) R307-415-3 defines a major source: “(a) A major source under Section 112 of the Act, Hazardous Air Pollutants…is defined as: … any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit, in the aggregate, ten tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of such hazardous air pollutants.” “(b) A major stationary source of air pollutants, as defined in Section 302 of the Act,…directly emits or has the potential to emit, 100 tons per year or more of any air pollutant…” UAC R307-401-2 defines potential to emit (PTE): “Potential to emit” means the maximum capacity of a stationary source to emit an air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on -3- CPFC New Compound Silo #6 August 2023 hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is enforceable.” CPFC facility-wide PTE controlled emissions after the proposed addition of Compound Silo #6 will be less than 100 tons per year of criteria pollutants, less than 10 tons per year of any single HAP and less than 25 tons per year of any combination of HAP. Therefore, Title V regulations are not applicable. 1.3.3 New Source Performance Standards (NSPS) Section 111 of the Clean Air Act authorizes the EPA to develop technology based standards which apply to specific categories of stationary sources. These standards are referred to as New Source Performance Standards (NSPS) and are found in 40 CFR Part 60. No NSPS were identified as potentially applicable to the Compound Silo. 1.3.4 National Emission Standards for Hazardous Air Pollutants (NESHAP) No area source (non-major) NESHAPs were identified as potentially applicable to the Compound Silo. 1.3.5 Risk Management Plan (RMP) Processes at CPFC do not exceed threshold quantities of regulated substances in a process, as determined under §68.115; therefore this rule is not applicable. 1.3.6 Stratospheric Ozone Protection CPFC does not use ozone depleting substances in facility processes. CPFC will ensure certified professionals are utilized to service air conditioning units. -4- CPFC New Compound Silo #6 August 2023 1.4 UTAH STATE IMPLEMENTATION PLAN (SIP) REGULATORY APPLICABILITY Specific emission control standards that apply to the proposed equipment are contained in Utah Administrative Code R307. These regulations are discussed below. 1.4.1 R307-401-8 Silo Bin Vents Proposed Compound Silo #6 will be equipped with a bin vent. All exhaust air will be vented through the bin vent filters before being vented to atmosphere. 1.4.2 R307-401-8 Opacity Emissions from proposed Compound Silo #6 will not exceed 10% opacity. 1.4.3 R307-401-8 Consumption Limits CPFC is not proposing a change in annual production and/or consumption limits or to hourly production limits. 1.4.4 R307-401-8 VOC and HAP Limitations CPFC is not proposing a change in VOC and HAP emission limitation. 1.4.5 R307-401-8 Pipe Production CPFC is not proposing a change in pipe production. -5- CPFC New Compound Silo #6 August 2023 1.5 SOURCE SIZE DETERMINATION With this modification the CPFC facility-wide potential to emit will be less than 100 tons per year for each criteria pollutant, less than 10 tons per year for each single HAP, and less than 25 tons per year total HAPs. Therefore, CPFC will continue to remain a minor source. -6- CPFC New Compound Silo #6 August 2023 2.0 NOI APPLICATION INFORMATION Form 4 – Process Data is provided as Attachment 2. 2.1 PROJECT DESCRIPTION Charlotte Pipe and Foundry Company (CPFC) located in Cedar City (Iron County) proposes to install a new PVC Compound Silo, “Compound Silo #6”. The proposed silo will be located with the existing compound silos adjacent to the rail car transfer station, as shown in Figure 1 (Site Plan). PVC resin used in the extrusion of PVC pipe is delivered in bulk to CPFC via rail cars. The material is pneumatically conveyed from the rail cars to storage silos. From the storage silos the PVC Resin is transferred to mixing stations where minor additives are introduced to the raw material. The mixed PVC compound is then pneumatically conveyed to a PVC Compound silo. PVC compound from the storage silos is transferred directly to extrusion machines for pipe manufacturing. 2.2 FUEL, RAW MATERIAL AND PRODUCTS CONSUMED / PRODUCED Compound Silo #6 will provide additional storage for PVC compound, which is a mixture of PVC Resin and a proprietary blend of additives. CPFC is not proposing an increase in PVC resin (raw material) throughput or storage, or in PVC pipe production. 2.3 DESCRIPTION OF EQUIPMENT AND OPERATING SCHEDULE Compound Silo #6 will be equipped with a have a rated throughput of 20,000 pounds per hour and is proposed to be operated 8,760 hours per year. The maximum annual silo throughput rate is proposed to be 87,600 tons per year. -7- CPFC New Compound Silo #6 August 2023 The silo will be equipped with a bin vent filtration system as specified below. Drawings and specifications are provided as Attachments 5, 6, and 7. Site-specific data from the CPFC facility located in Monroe, NC has indicated the following particle size distribution for PVC Compound: PVC Compound Particle Size Distribution Size µm Weight % of Total Cumulative % 0-1 0 0 1-10 0 0 10-25 1 1 25-50 1 2 50-100 98 100 >100 0 100 Manufacturer data provided for the filter (Attachment 7) indicates that particle removal efficiency for particles greater than 8.50 µm is 99.8%. Emission calculations are provided as Attachment 4. 2.4 CHANGES TO PROCESS RATE AND PRODUCTION RATES The proposed PVC Compound will allow additional storage of the same quantities of PVC Compound currently mixed at the facility. There are no proposed changes to piping throughput or production rate. 2.5 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS The proposed silo will be equipped with a filtration system that regulates air flow and prevents loss of material (PVC compound) from the silos during material transfer to and from the silo. It is not feasible to operate the silos without this filtration system due to extensive loss of raw material. The filtration system has a minimum PVC compound (particulate) control efficiency of 99.8%. Controlled particulate emissions are calculated to be 4.12E-02 tons per year. Back calculating, a particulate control device added in series would require an annualized cost of less than $610, -8- CPFC New Compound Silo #6 August 2023 assuming $15,000 per ton PM controlled is economically feasible ($15,000 per ton PM x 4.12E- 02 tons PM). A review of Engineer Reviews associated with recent issued Approval Orders (AO) was conducted to identify recent BACT determinations for the control of particulate from silos: Recent DAQ BACT Determinations DAQ Project No. Date Facility Equipment BACT Determination N143660002 June 1, 2021 Amcor Masonry Products Silo Bin vents with 99% efficient fabric filters Maintain opacity less than 10% N108200008 December 1, 2021 Geneva Rock Products Storage Silo Filter bin vents Maintain opacity less than 10% N161190001 June 13, 2023 Kilgore Companies Silo Use of fabric filters/bin vents on all storage silos CPFC proposes that BACT for the new silo is the use of fabric filters and maintaining less than 10% opacity. 2.6 EMISSIONS RELATED INFORMATION 2.6.1 Summary of Emissions Criteria Pollutant DAQE- AN141120012-23 (TPY) Change (Project) (TPY) Total (TPY) CO2 Equivalent 6.13 0 6.13 Carbon Monoxide 0.04 0 0.04 Nitrogen Oxides 0.17 0 0.17 Particulate Matter - PM10 0.11 4.12E-02 0.15 Particulate Matter - PM2.5 0.11 4.12E-02 0.15 Sulfur Dioxide 0.01 0 0.01 Volatile Organic Compounds 22.76 0 22.76 -9- CPFC New Compound Silo #6 August 2023 Hazardous Air Pollutant DAQE- AN141120012-23 (TPY) Project (TPY) Total (lbs/yr) Acrylonitrile (CAS #107131) 1000 0 1000 Ethyl Benzene (CAS #100414) 1284 0 1284 Generic HAPs (CAS #GHAPS) 2 0 2 Isophorone (CAS #78591) 19160 0 19160 Methanol (CAS #67561) 694 0 694 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 460 0 460 Styrene (CAS #100425) 19960 0 19960 Vinyl Chloride (CAS #75014) 99 0 99 DAQE- AN141120012-23 (TPY) Project (TPY) Total (TPY) Total HAPs 21.33 0 21.33 2.6.2 Emission Calculations Detailed emission calculations are provided as Attachment 4. 2.6.3 References and Assumptions See Attachment 5, Silo Dimensions; Attachment 6, Bin Vent Details; and Attachment 7, Filter Cartridge. 2.6.4 Speciated HAP Emissions There are no HAP emissions associated with the proposed PVC Compound silo. 2.7 EMISSION IMPACT ANALYSIS In accordance with Utah Administrative Code R307-410-4: Modeling of Criteria Pollutant Impacts in Attainment Areas, a modification to an existing source located in an attainment area which increases the total controlled emission rate per pollutant of the source in an amount greater than or equal to those specified in Table 1 of R307-410-4 shall conduct air quality modeling. -10- CPFC New Compound Silo #6 August 2023 The proposed increase in PM10 and PM2.5 emissions are below the thresholds in Table 1 of R307- 410-4; therefore, an impact analysis is not required. 2.8 NONATTAINMENT/MAINTENANCE AREAS – MAJOR NSR/MINOR (OFFSETTING ONLY) The CPFC facility is located in an area that is in attainment for all pollutants. This rule is not applicable [R307-403]. 2.9 MAJOR SOURCES IN ATTAINMENT OR UNCLASSIFIED AREAS (PSD) The CPFC facility is located in an area that is in attainment for all pollutants and is not a major source. These rules are not applicable [R307-405, R307-406]. FIGURES 8 34567 12 8 34567 12 A B C D E F G H A B C D E F G H DE S C R I P T I O N DA T E NO RE V I S I O N R E C O R D DA T E : DW G S C A L E : DR A W N B Y : CH E C K E D B Y : AP P R O V E D B Y : PR O J E C T N O : SHEET OF DRAWING NO.: SI T E M A P 18 0 - 4 4 2 1" = 1 0 0 ' MA R C H 2 0 1 8 JK S DR A F T DR A F T C100 CH A R L O T T E P I P I N G A N D F O U N D R Y CE D A R C I T Y , U T A H REFERENCE NORTH ww w . c e c i n c . c o m 19 0 0 C e n t e r P a r k D r i v e - S u i t e A - C h a r l o t t e , N C 2 8 2 1 7 Ph : 9 8 0 . 2 3 7 . 0 3 7 3 · F a x : 9 8 0 . 2 3 7 . 0 3 7 2 New Compound Silo Location ATTACHMENT 1 FORM 2 – COMPANY INFORMATION/NOTICE OF INTENT (NOI) DAO 2018 002272 ATTACHMENT 2 FORM 4 – PROCESS DATA Page 1 of 1 Form 4 Company____________________________ Project Information Site ______________________________ Utah Division of Air Quality New Source Review Section Process Data - For Modification/Amendment ONLY 1. Permit Number_______________________________ If submitting a new permit, then use Form 3 Requested Changes 2. Name of process to be modified/added: _______________________________ End product of this process: _______________________________ 3. Permit Change Type: New Increase* Equipment Process Condition Change ____________________ Other ______________________________ Other ______________________________ Other ______________________________ 4. Does new emission unit affect existing permitted process limits? Yes No 5. Condition(s) Changing: 6. Description of Permit/Process Change** 7. New or modified materials and quantities used in process. ** Material Quantity Annually 8. New or modified process emitting units ** Emitting Unit(s) Capacity(s) Manufacture Date(s) *If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an emissions increase and a public comment period. **If additional space is required, please generate a document to accommodate and attach to form. Doc.uim:i'ii D^lc: 02/28/2018 DAQ 2018-002274 ATTACHMENT 3 FORM 5 – EMISSIONS INFORMATION Utah Division of Air Quality Company____________________________ New Source Review Section Site/Source__________________________ Date____________________ Form 2 Process Information Process Data 1. Name of process:2. End product of this process: 3. Primary process equipment: _______________ Manufacturer:__________________________________ Make or model: _________________________ Identification #: ________________________________ Capacity of equipment (lbs/hr): Year installed:__________________________________ Rated _____________ Max.____________ (Add additional sheets as needed) 4. Method of exhaust ventilation: □Stack □ Window fan □ Roof vent □ Other, describe _______________________ Are there multiple exhausts: □ Yes □ No Operating Data 5. Maximum operating schedule: __________ hrs/day __________days/week __________weeks/year 6. Percent annual production by quarter: Winter ________ Spring _______ Summer ________ Fall ________ 7. Hourly production rates (lbs.): Average ________ Maximum ________ 8. Maximum annual production (indicate units): __________________ Projected percent annual increase in production: __________________ 9. Type of operation: □ Continuous □Batch □Intermittent 10. If batch, indicate minutes per cycle ________ Minutes between cycles ________ 11. Materials used in process Raw Materials Principal Use Amounts (Specify Units) Page 1 of 3 X Page 2 of 3 Process Form 2 (Continued) 12. Control equipment (attach additional pages if necessary) Item Primary Collector Secondary Collector a. Type b. Manufacturer c. Model d. Year installed e. Serial or ID# f. Pollutant controlled g. Controlled pollutant emission rate (if known) h. Pressure drop across control device i. Design efficiency j. Operating efficiency Stack Data (attach additional pages if necessary) 13. Stack identification: 14. Height: Above roof ________ft Above ground ________ft 15. Are other sources vented to this stack: □ Yes □ No If yes, identify sources: 16. □ Round, top inside diameter dimension _________ □ Rectangular, top inside dimensions length ________ x width ________ 17. Exit gas: Temperature ________ oF Volume ________ acfm Velocity ________ ft/min 18. Continuous monitoring equipment: □ yes □ no If yes, indicate: Type ____________________ Manufacturer _________________________________ Make or Model ____________ Pollutant(s) monitored __________________________ Emissions Calculations (PTE) 19. Calculated emissions for this device PM10 ___________ Lbs/hr___________ Tons/yr PM2.5 ____________ Lbs/hr ___________ Tons/yr NOx____________ Lbs/hr___________ Tons/yr SOx _____________ Lbs/hr___________ Tons/yr CO ____________ Lbs/hr___________ Tons/yr VOC _____________ Lbs/hr___________ Tons/yr CO2 ___________ Tons/yr CH4 _____________ Tons/yr N2O ____________Tons/yr HAPs_________ Lb s/hr (speciate)__________Tons/yr (speciate) Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix. Page 3 of 3 Instructions Note: 1. Submit this form in conjunction with Form 1. 2. Call the Division of Air Quality (DAQ) at (801) 536-4000 if you have problems or questions in filling out this form. Ask to speak with a New Source Review engineer. We will be glad to help! This is a general form regarding processes and should be completed by all sources. Please answer all questions. If the item does not apply to the source operations write “n/a”. If the answer is not known write "unknown". 1. Indicate the generally accepted name for the process (i.e., asphalt batching, glass manufacturing, oil refining, etc.). 2. Specify the end product of this process (i.e., asphaltic concrete, benzene, soaps, etc.). 3. Indicate the specific process equipment for this form along with the manufacturer, model number, identifying name or code year it was or will be installed, and rated (normal) and maximum capacity of equipment. 4. Indicate the method of exhaust ventilation and indicate if there are more than one exhausts. 5. Complete the process equipment's normal operating schedule in hours per day, days per week, and weeks per year. 6. Complete the percent annual production by season for a year’s production of finished units. The four seasons should total to 100%. 7. Specify the average and maximum hourly production rates in pounds. The average is the year's production rate divided by the total yearly hours of production or operation. 8. Specify the annual production for this process equipment and indicate the appropriate units. Estimate the annual increase in production. 9. Check whether the process is continuous, intermittent, or batch. A batch operation normally has significant down time between completion and startup of each operation or cycle. 10. If batch, complete the minutes per production cycle and minutes between the production cycles. A "cycle" refers to the time the equipment is in operation. 11. List all general types of raw materials employed in the process, indicate the principle use (i.e., product, binder, catalyst, fuel, etc.) and specify the normal amount used in pounds per hours, tons per year, etc. 12. If your control device is not listed below complete items a through j. If your process includes any of the control devices listed below, please indicate which ones and submit the associated forms with your application. The primary collector and secondary collector refer to separate control devices or equipment for collecting similar or different air pollutants. If there is a third collector, complete the same data for that collector on a separate sheet. Addition information may be attached. Complete the proper form listed below for any air pollution control device: ___ Form 3 Afterburners ___ Form 4 Flares ___ Form 5 Adsorption Unit ___ Form 6 Cyclone ___ Form 7 Condenser ___ Form 8 Electrostatic Precipitators ___ Form 9 Scrubber ___ Form 10 Fabric Filter (Baghouse) 13. Indicate the company's identification for the stack or exhaust. 14. Specify the stack's or exhaust's height, in feet (ft.) above ground and above the attached roof. 15. Indicate if other sources are also vented to this same stack or exhaust and identify those sources. 16. Specify the inside dimensions of the stack or exhaust at the outlet to the atmosphere. 17. Complete the specifications of the stack's or exhaust's exit gas. (Temperature in degrees Fahrenheit, volume flow rate in actual cubic feet per minute, and velocity in feet per minute.) If the properties of the exit gas vary, use the average values. 18. Indicate if the stack or exhaust is equipped with air pollution monitoring equipment. If so, specify the type, manufacturer, make or model, and the pollutant or pollutants monitored. 19. Supply calculations for all criteria pollutants and HAPs. Use manufacturers’ data or AP-42 to complete your calculations. f:\aq\engineer\generic\Forms 2010\Form02 Process Information.doc Revised 12/20/10 Page 1 of 1 Company___________________________ Site _____________________________ Form 5 Emissions Information Criteria/GHGs/ HAP’s Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2e CO2e CO2 CH4 N2O HFCs PFCs SF6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act ) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Jccumonl Dcjlc: 02/28/2018 ATTACHMENT 4 EMISSION CALCULATIONS Annual operating hours 8,760 hr/yr Maximum material throughput 87,600 ton/yr 20,000 lb/hr Uncontrolled Emissions EMISSION FACTOR1,2 EMISSION SOURCE (lb/ton)(lb/hr)(ton/yr) Resin Silo 0.47 4.70 20.59 Resin Silo #2 0.47 4.70 20.59 Compound Silo #1 0.47 4.70 20.59 Compound Silo #2 0.47 4.70 20.59 Compound Silo #3 0.47 4.70 20.59 Compound Silo #4 0.47 4.70 20.59 Compound Silo #5 0.47 4.70 20.59 Total Before Project 32.90 144.10 Compound Silo #6 0.47 4.70 20.59 TOTAL After Project 37.60 164.69 Controlled Emissions EMISSION FACTOR1,2 EMISSION SOURCE (lb/ton)(lb/hr)(ton/yr) Resin Silo 0.47 99.94%2.82E-03 1.24E-02 Resin Silo #2 0.47 99.94%2.82E-03 1.24E-02 Compound Silo #1 0.47 99.94%2.82E-03 1.24E-02 Compound Silo #2 0.47 99.94%2.82E-03 1.24E-02 Compound Silo #3 0.47 99.94%2.82E-03 1.24E-02 Compound Silo #4 0.47 99.94%2.82E-03 1.24E-02 Compound Silo #5 0.47 99.94%2.82E-03 1.24E-02 Total Before Project 0.02 0.09 Compound Silo #6 0.47 99.80%9.40E-03 4.12E-02 TOTAL After Project 0.03 0.13 Notes: 1 It is assumed PM2.5 is equal to PM10 2 Emission factor based on AP-42 Chapter 11.12, Emission Factors for Concrete Batching, Cement Unloading to Elevated Storage Silo (pneumatic). 3 The Resin Silo and Compound Silos will utilize fabric filters to control particulate matter emissions. Example Calculations: 1. For Uncontrolled Potential Emissions: Potential Emissions (lb/hr) = Potential Throughput (ton/yr) x [Emission Factor (lb/ton) / Potential Hours of Operation (hr/yr)] Potential Emissions (ton/yr) = Potential Throughput (ton/yr) x [Emission Factor (lb/ton) / 2000 (lb/ton)] 2. For Controlled Potential Emissions: Potential Emissions (lb/hr) = Potential Throughput (ton/yr) x [Emission Factor (lb/ton) / Potential Hours of Operation (hr/yr)] x (1-Control Efficiency) Potential Emissions (ton/yr) = Potential Throughput (ton/yr) x [Emission Factor (lb/ton) / 2000 (lb/ton)] x (1-Control Efficiency) 4 Compound Silo #6 based on manufacturers data for particle sizes up to 8.50 µm. Manufacturer efficiency data for all other silos is based on PVC resin particle size distribution, 100% capture of particle sizes greater than 74 µm and 98.91% capture of particle sizes less than 74 µm. PVC resin is the smallest particle size processed at the facility. RESIN AND COMPOUND SILO EMISSIONS POTENTIAL EMISSIONS CHARLOTTE PIPE AND FOUNDRY COMPANY - PLASTICS DIVISION CEDAR CITY, UTAH POTENTIAL EMISSIONS PM10 / PM2.5 Control Efficiency3,4 PM10 / PM2.5 POTENTIAL EMISSIONS ATTACHMENT 5 SILO DIMENSIONS Design Plast Inc. ATTACHMENT 6 BIN VENT DETAILS Inc.Plast TOLERANCE: MATERIAL NOTES: 1:8 other use may be made of this work.DRAWN DATE: SHEET NUMBER: AP SCALE: STAINLESS STEEL MATERIAL CONTACT (TUBESHEET). + OR - 1/16" (.0625) 1 of 64/3/2023 23-011 OTHERWISE DCEDAR CITY, UTUNLESS SPECIFIED SOCIETY.SHEET SIZE: DRAWN BY: CHARLOTTE PIPE CARBON STEEL PLENUM. 101 DEBURR ALL SHARP EDGES AND ROUND ALL SHARP CORNERS. ALL WELDING SHALL BE IN ACCORDANCE WITH THE SPECIFICATIONS OF THE AMERICAN WELDING Design 58SBV25 TOP BAG REMOVAL BIN VENT This work is the copyright protected property of DesignPlast, Inc. (DPI) as recognized by the United States Copyright Act of 1976, 17 USCS 101 et. seq. DPI has communicated this work to a limited number of persons to be used for limited purposes and only in connection with projects performed by DPI. No JOB NUMBER: 13 16 2 10 9 10 4 1 18 22 2423 6 1 14 12 14 9 AIR MANIFOLD ASSEMBLY DETAIL 8" ODx11GA TUBE 18 3'-8 1/2" OUTSIDE HOUSING 7 9 / 1 6 " ITEM NO QTY DESCRIPTION Source 1 2 1" NPT HALF-COUPLER MC#4464K226 PURCHASED 2 1 1" NPT PLUG, SQ DRIVE, MC#44605K663 PURCHASED 3 1 1" x 3/8" CLOSED-CELL SPONGE RUBBER DOOR SEAL, 120" LG PURCHASED 4 1 1' to 1/4"NPT BUSHING, MC#44605K348 PURCHASED 5 2 1/4" NPT HALF COUPLER, MC#4513K71 PURCHASED 6 1 1/4" NPT T-HANDLE STOP-COCK, MC#4793K846 PURCHASED 7 1 1/4" NPT to 1/4" AIR PUSH-CONNECT FITTING, MC#5779K109 PURCHASED 18 2 1/8"NPT to 1/4" TUBE PUSH-TO-CONNECT AIR FITTING, MC#51495K184 PURCHASED 9 5 1/8"NPT to 1/4" TUBE SWIVEL 90-PUSH-TO-CONNECT AIR FITTING, MC#51495K234 PURCHASED 10 5 3/4" DIAPHRAGM VALVE (GOYEN #RCAC 20ST 4002) PURCHASED 11 5 3/4" GOYEN DOUBLE BULKHEAD FITTING PURCHASED 12 5 3/4"NPTx3"LG HALF-NIPPLE, MC#7753K135 PURCHASED 13 5 3/4"NPTx6" LG HALF NIPPLE, MC#7753K155 PURCHASED 14 2 4"OD TUBE CAP PURCHASED 15 1 DWYER DIFFERENTIAL PRESSURE GAUGE #2008 PURCHASED 16 1 DWYER SVT-5 SOLENOID VALVE ENCLOSURE W/TIMER PURCHASED 17 25 FILTER TOP LOAD CARTRIDGE #KF30093-GW, 5" ODx58" LG, 35 PLEAT, 31.8 SQFT, SPUNBOND POLYESTER, NO GROUNDING PURCHASED 18 1 PRESSURE GAUGE, 0-160, 1/4"NPT, MC#3846K124 PURCHASED 19 12 1/2" FLAT WASHER HARDWARE 20 8 1/2"-13 NYLOCK NUT HARDWARE 21 8 1/2"-13x1-1/2" BOLT HARDWARE 22 4 1/4" WASHER HARDWARE 23 4 1/4"-20 NYLOCK NUT HARDWARE 24 4 1/4"-20x1" BOLT HARDWARE 25 4 3/8" FLAT WASHER HARDWARE 26 4 3/8"-16 NYLOCK NUT HARDWARE 27 4 3/8"-16x1-1/2" BOLT HARDWARE 28 9 3/8"-16x4" BOLT HARDWARE 29 1 25 CARTRIDGE TUBE SHEET FAB 30 5 BLOWPIPE ASM FAB 31 1 DIFFERENTIAL PREASSURE GAUGE MOUNTING BRACKET FAB 32 1 HOLD DOWN HANDLE-MIDDLE FAB 33 8 HOLD DOWN HANDLE-PERIMETER FAB 34 9 HOLD DOWN HANDLE FAB 35 4 PIVOT ASSIST FAB DATE REVISION DESCRIPTION REV. BY APP 03/08/2023 RELEASE TO PRODUCTION 0 AP PAINT NOTE:SHOP PRIME ONE COAT SHERWIN-WILLIAMS OFF-WHITE PRIMER #B50WZI PAINT ONE COAT SHERWIN-WILLIAMS WHITE ENAMEL #B55W311 ALL CARBON STEEL.STAINLESS STEEL TUBESHEET UNPAINTED 35 11 32 16 35 29 31 34 15 34 57 18 33 34 17 58SBV25 TOP BAG REMOVAL BIN VENT 1 REQ'D 3'-8 1/2" OUTSIDE HOUSING 2 ' - 7 9 / 1 6 " 3 ' - 3 1 / 1 6 " 8 ' - 3 / 4 " 34 *34 3334 33 34 32343334 3334 34 33 15 3133 18 1'- 7/8" 20 25 STAINLESS STEEL TUBESHEET CARBON STEEL PLENUM 19 21 27 26 ATTACHMENT 7 FILTER CARTRIDGE DOCUMENTATION Date:TEST NO. Filter Description Manufacturer Filter Model Part Number Generic Filter Type Nominal Dimensions (H x W x D) Pocket / Pleat Quantity Media Type Est. Gross Media Area Adhesive Type Initial Efficiency / Resistance ASHRAE Standard 52.2 11-0850 Tel: (502) 357-0132 Fax (502) 267-8379 2820 S. English Station Road - Louisville, KY 40299 15-Jun-11 Test Report Environmetal Services Pulse Pleat TA625 Industrial 6.13" X 22" 0 PE 806 14.5 ft2 NA Test Conditions Loading Dust Type KCl Test Air Temp (degrees F.) 71 Barometric Pressure (In. Hg.) 29.88 Relative Humidity (%) 44 Airflow Rate (CFM) Nominal Face Velocity (fpm) Initial Resistance (in WG) E1 (%) Initial Efficiency 0.30 - 1.0 um E2 (%) Initial Efficiency 1.0 - 3.0 um E3 (%) Initial Efficiency 3.0 - 10.0 um Estimated * Minimum Efficiency Reporting Value (MERV) * If initial data is minimum Comments Tested For: KCl Efficiency at 50 CFM. Tested in Vertical Duct 0 0 Approval:Page 1 of 3 96 10 35 0.210 56 50 3.44 Test Results 7/12/2011 11-0850 GE Eff 50CFM TSI Jun152011Page 1 of 3 Test No. 11-0850 Date: 15-Jun-11 Initial Particle Size Removal Efficiency 0.060 0.085 0.125 0.210 0.320 0.0 0.1 0.1 0.2 0.2 0.3 0.3 0.4 0 10203040506070 Re s i s t a n c e ( i n W G ) Airflow Rate (CFM) Air Flow vs Resistance Clean Device 32 . 9 33 . 0 35 . 1 40 . 5 46 . 5 48 . 7 56 . 7 73 . 8 88 . 9 96 . 6 99 . 5 99 . 8 0 10 20 30 40 50 60 70 80 90 100 0.10 1.00 10.00 Re m o v a l E f f i c i e n c y % Particle Diameter (um) Initial Particle Size Removal Efficiency 7/12/2011 11-0850 GE Eff 50CFM TSI Jun152011Page 2 of 3 Test No. 11-0850 Date: 15-Jun-11 Data - Initial Resistance Airflow Resistance Resistance Corrected (CFM) (in WG) Plate Resistance 12.5 0.070 0.010 0.060 25 0.100 0.015 0.085 37.5 0.140 0.015 0.125 50 0.230 0.020 0.210 62.5 0.350 0.030 0.320 Data - Particle Removal Efficiency Geometric Mean Diam (um) 0.35 32.9 0.48 33.0 063 35 1 Initial Particle Size Range (um) Particle Removal Efficiency (%) 0.63 35.1 0.85 40.5 1.15 46.5 1.45 48.7 1.90 56.7 2.60 73.8 3.50 88.9 4.75 96.6 6.25 99.5 8.50 99.8 . 7/12/2011 11-0850 GE Eff 50CFM TSI Jun152011Page 3 of 3