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HomeMy WebLinkAboutDAQ-2024-0105411 DAQC-CI129100001-24 Site ID 12910 (B1) MEMORANDUM TO: FILE – AMPAC, UTAH OPERATIONS – Production Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Jared James, Environmental Scientist DATE: May 15, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Iron County INSPECTION DATE: April 29, 2024 SOURCE LOCATION: 10622 West 6400 North Cedar City, UT 84721 DIRECTIONS: Take UT-56 W/200 N west from I-15 for approximately 4.5 miles then turn right onto Iron Springs Road. Follow Iron Springs Road for approximately 10.5 miles to the source location. Access is restricted through a security gate. SOURCE CONTACTS: Ryan Hess, EHS&S Manager 435-531-3244, ryan.hess@ampac.us OPERATING STATUS: Operating normally. PROCESS DESCRIPTION: AMPAC's Western Electrochemical Company (WECCO) division offers a variety of perchlorates serving aerospace, national defense, and commercial businesses. Applications include incorporation into solid rocket motor (SRM) propellant, defense related programs, fireworks, and road flares. AMPAC's American Azide division is located within the same facility. Sodium azide (formula: NaN3) is used primarily as an intermediate in the manufacture of pharmaceuticals. Sodium azide has also been used as a component in the gas generators used to inflate certain automotive airbag safety systems, providing the source of nitrogen gas necessary to inflate the bag instantaneously. Due to current market forces, the American Azide division is currently not operating. Also located at the facility is the Halotron division, maker of Halon fire extinguishers. 0 0 2 APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129100006-15, dated April 21, 2015 NSPS (Part 60) Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, MACT (Part 63) -CCCCCC : National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities, MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: AMPAC, Utah Operations Production Facility 10622 West 6400 North 10622 West 6400 North Cedar City, UT 847200 Cedar City, UT 84721 SIC Code: 2819: (Industrial Inorganic Chemicals, NEC) 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] 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] 3 I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. No limits appear to have been exceeded. No modifications to the equipment or processes that could affect the emissions covered by this AO have occurred. The source keeps records in an electronic database. The source appears to operate and maintain the equipment approved under this AO in a manner consistent with good air pollution control practices. No breakdowns have occurred. The source is not currently required to submit an emission inventory, referenced in condition I.7. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 AMPAC Utah Operations Production Plant II.A.2 Four Natural Gas-Fired Boilers Manufacturer: Clever Brooks Maximum Output Rating (each): 400 Hp (13.4 MMBTU/hr) Burner Rating (maximum): 9 ppm NOx II.A.3 Diesel Fire Water Pump Manufacturer: Cummins Maximum Rating: 400 Hp II.A.4 Anode Building (E4) Mist eliminator, Prefilter, and HEPA Filter II.A.5 Graphite Baghouse (E5) Cyclone, and an Airpro DCE Model 1/7/15 baghouse II.A.6 Combination Packed/Spray Scrubbers "A" circuit scrubber (caustic scrubber - E7) "B" circuit scrubber (caustic scrubber - E8) "C" circuit scrubber (caustic scrubber - E9) "D" circuit scrubber (caustic scrubber - E10) "E" circuit scrubber (caustic scrubber - E11) II.A.7 Spray Chamber Scrubbers "A" circuit vent scrubber (caustic scrubber - E12) "B" circuit vent scrubber (caustic scrubber - E13) "C" circuit vent scrubber (caustic scrubber - E14) 4 "D" circuit vent scrubber (caustic scrubber - E15) "E" circuit vent scrubber (caustic scrubber - E16) II.A.8 Packed Scrubbers HCl unloading scrubber (saddle packing - E17) "A" reactor/544A scrubber (saddle packing - E18) "B" reactor/544B scrubber (saddle packing - E19) II.A.9 Boliden Allis Cyclone and Scrubbers "A" dryer wet scrubber (E20) "B" dryer wet scrubber (E21) II.A.10 Wet Dust Collectors Scrubber Type: Orifice Water Curtain (E22) Gas Flow Rate: 5945 actual cubic feet per minute (acfm)** Scrubber Type: Orifice Water Curtain (E23) Gas Flow Rate: 5800 acfm** Scrubber Type: Orifice Water Curtain (E24) Gas Flow Rate: 5800 acfm** II.A.11 Miscellaneous Scrubbers Sodium Amide Stainless Steel Reactors off-gas scrubber Azide (E-25) Scrubber Type: Packed Tower with Countercurrent Flow Maximum Air Flow Rate: 240 acfm** Liquid Recirculation Rate: No less than 44 gallons per minute (gpm) Scrubbing Liquid Exchange Rate: 0.67 to 5.1 gpm of fresh water added to system** Ammonia Hydroxide Storage Tank scrubber Azide (E-26) Scrubber Type: Packed Tower Maximum Air flow rate: 4.5 acfm** when in operation Minimum Liquid Flow Rate: 0.2 gpm when in operation II.A.12 Sodium Azide Dryer Dust Collector Scrubber 116 Dryer Building Azide (E-27) Scrubber Type: Type N Rotoclone Model LV Hydrostatic Maximum Air Flow Rate: 1,000 acfm** Maintenance Building Scrubber Azide 103 area (E-28) Scrubber Type: Packed Tower with Countercurrent Flow Maximum Air Flow Rate: 1200 acfm** Minimum Liquid Recirculation Rate: 23 gpm Scrubbing Liquid Exchange Rate: Eight gallons of fresh water per hour added to the system 5 II.A.13 Sodium Azide Blender Dust Collector Scrubber 125 Blender Building Azide (E-29) Scrubber Type: Orifice water curtain Air Flow Rate: 2500 acfm** ** These equipment specifications are listed for informational purposes only. II.A.14 Natural Gas-Fired Oil Heater (E-30) Type of Burner: 40 ppm NOx Maximum Heating Capacity: 5.4 MMBTU/hr II.A.15 Diesel-Fired Emergency Generators Maximum Output: 2700 kW (E-31) Maximum Output: 500 kW (E-32) II.A.16 Evaporation Ponds AZIDE Evaporation Pond - surface area - 200 ft x 200 ft at the mean water line (mean water line is 3.5 ft below the top of the pond) WECCO Evaporation Pond - surface area - 170 ft x 370 ft at the mean water line (mean water line is 4.0 ft below the top of the pond) II.A.17 Miscellaneous Hood Vents II.A.18 Fire Fighting Training Two burn pits Burn building Training tower Miscellaneous fire test pans that range up to 400 ft2 Status: In Compliance. The above equipment was noted onsite. In addition, the source has a 500 gallon gasoline tank used for the Fire Fighting Training in II.A.18. Additional equipment and process information gathered at the time of inspection: • II.A.2 - Four Natural Gas-Fired Boilers - The boilers are also equipped with propane backups for periods of natural gas curtailment. • II.A.3 - Diesel Fire Water Pump - This is a 429 horsepower, Caterpillar engine that was manufactured in 1988 and installed at the source location in 1992. • II.A.15 - Diesel-Fired Emergency Generators: o E-31 - This emergency engine is no longer operable. The source was reminded to contact NSR to modify the AO before installing a new emergency generator. 6 o E-32 - This is a 724 horsepower, Caterpillar engine that was manufactured in 1988 and installed at the source location in 1992. • II.A.16 - Evaporation Ponds - The AZIDE Evaporation Pond is no longer in use due to market forces ending AZIDE production. The WECCO Evaporation Pond is used to evaporate water from perchlorate. • The source indicated all scrubbers and dust collectors are tracked and managed through an automated, real-time, process control database in the control room. The database was viewed at the time of inspection. II.B Requirements and Limitations II.B.1 Limitations and Test Procedures II.B.1.a AMPAC shall notify the Director in writing when the installation of the 40 MMBTU/hr boilers in Condition II.A.2, have been completed and are operational, as an initial compliance inspection is required. To insure proper credit when notifying the Director, send your correspondence to the Director, attn: Compliance Section. If installation has not been completed by May 25, 2016, the Director shall be notified in writing on the status of the installation. At that time, the Director shall require documentation of the continuous installation of the equipment and may revoke the AO in accordance with R307-401-18. [R307-401-18] Status: In Compliance. Notification was received at DAQ offices on November 23, 2015, and can be found in the source file as well as in eDocs under document ID DAQ-2015-012784. The boilers in condition II.A.2 are rated at 13.4 MMBTU/hr. These ratings were confirmed at the time of inspection. II.B.1.b Visible emissions from the following emission points shall not exceed the following values: A. 5% opacity for visible or fugitive emissions associated with the sodium azide operation B. 10% opacity for visible or fugitive emissions associated with the ammonium perchlorate operation C. 10% opacity for the fume hoods D. 10% opacity for baghouses E. 10% opacity for boilers F. 15% opacity for all scubbers and wet dust collectors G. 20% opacity for all diesel fired generators and fire pumps H. All other points - 20% opacity 7 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point during the inspection. II.B.1.c The following production and consumption limits shall not be exceeded: A. 3,000 tons sodium azide production per rolling 12-month period B. 15,600 tons 28% ammonium hydroxide solution production per rolling 12-month period C. 3,830 tons 50% sodium hydroxide solution production per rolling 12-month period D. 5,130 tons of ammonia gas consumed per rolling 12-month period E. 2,050 tons of nitrous oxide consumed per rolling 12-month period F. 21.0 tons of silicon dioxide consumed per rolling 12-month period G. 334 MMCF total natural gas consumption per rolling 12-month period H. 40,000,000 pounds of perchlorate and/or chlorate production per rolling 12-month period I. 7,920 hours of operation per rolling 12-month period for emission point E4 J. 8,000 hours of operation per rolling 12-month period for each emission point E20, E21, E22, E23, and E24 K. 4,400 hours per rolling 12-month period of operation for emission point E28 L. 90 hours per rolling 12-month period of operation for emission point E31 M. 70 hours per rolling 12-month period of operation for emission point E32 N. 5,000.0 tons of 2,2-dichloro-1,1,1-trifluorethane, AKA R123, HCFC-123 per rolling 12-month period To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of consumption/production shall be kept for all periods when the plant is in operation. Production/consumption shall be determined by production logs and operation logs. The records of consumption/production shall be kept on a daily basis. Hours of operation shall be determined by the supervisor monitoring and maintaining an operations log. [R307-401-8] Status: In Compliance. The 12-month rolling totals for the period ending March 31, 2024, are as follows: A. 0 tons of sodium azide production B. 0 tons 28% ammonium hydroxide solution production C. 0 tons 50% sodium hydroxide production D. 829.3 tons of ammonia gas consumed 8 E. 0 tons of nitrous oxide consumed F. 0 tons of silicon dioxide consumed G. 127.9 MMCF total natural gas consumption H. 14,767,374 pounds of chlorate production I. 1,852.9 hours of operation for emission point E4 J. 4,920.9 hours of operation for emission point E20 3,002.3 hours for E21 3,160.9 hours for E22 2,935.4 hours for E23 3,089.7 hours for E24 K. 0 hours of operation for emission point E28 L. 0 hours of operation for emission point E31 M. 1.3 hours of operation for emission point E32 N. 259.3 tons of HCFC-123 See attached records. II.B.1.d The emergency generators shall not exceed 100 hours of operation per generator for maintenance checks and readiness testing per year unless records are maintained indicating that Federal, State, or local standards require maintenance and testing of emergency affected emission units beyond 100 hours per year. Any operation other than emergency operation, and maintenance and testing as permitted in this Condition, is prohibited. Records documenting the generator usage shall be kept in a log and they shall show the date the generators were used, the duration in hours of the generator usage, and the reason for each generator usage. [R307-401] Status: In Compliance. The 2700 kW (E31) emergency generator is no longer operable and has not operated since prior to 2019. The 900-kW emergency generator is for the decommissioned Azide operation and operated for 1.3 hours during the 12-month period ending March 31, 2024. II.B.1.e The following emission point scrubber liquid flow rates shall be maintained with the indicated ranges: A. (E7-E11) Not less than 250 gallons per minute B. (E12-E16) Not less than 1 gallon per minute C. (E17-E-19) Not less than 16 gallons per minute D. (E20-E21) Not less than 10 gallons per minute E. (E25) Not less than 44 gallons per minute F. (E28) Not less than 23 gallons per minute 9 The flow rates shall be continuously monitored when the scrubbers are in operation with equipment located such that an inspector/operator can safely read the output at any time. The monitoring devices shall be certified by the manufacturer. The monitored flow rate of the devices shall be accurate to within plus or minus 5 percent. The scrubbing liquid flow rate shall not fall below the above-stated flow rate for more than 10 minutes within any 60-minute period. The monitoring devices must be calibrated on an annual basis in accordance with the manufacturer's instructions. Emission point E-25 flow rate shall be continuously recorded. All other emission point flow rates shall be recorded once per shift. [R307-401-8] Status: In Compliance. The source conducts annual maintenance and calibration of each gauge. Each gauge has a calibration tag affixed to it. All gauges were calibrated in May or June 2023. Flow rates are monitored through an automated, real-time, process control database in the control room. The database was viewed at the time of inspection. Flow rate data provided following the inspection were recorded as follows: A. E7: 268 gpm, E8: 261 E9 - E11: Not currently in operation. E9 through E11 are part of the Azide operation and are currently out of commission due to market forces. B. E12: 1.3 gpm, E13: 1.6 E14 - E16: Not currently in operation. E14 through E16 are part of the Azide operation and are currently out of commission due to market forces. C. E17 - E19: Operate with a continuous monitoring system with a low flow minimum setting of 16 gpm. An alarm is triggered when flow drops to this level and the source takes immediate action to correct the problem. All were above 20 gpm during the inspection. D. E20 - E21: Operate with a continuous monitoring system with a low flow setting of 10 gpm. An alarm is triggered when flow drops to this level and the source takes immediate action to correct the problem. Both were above 12 during the inspection. E. E25: Operate with a continuous monitoring system with a low flow setting of 46 gpm and a low-low setting of 44 gpm. An alarm is triggered when flow drops to this level and the source takes immediate action to correct the problem. E25 is part of the Azide operation and is currently out of commission due to market forces. F. E28: Operate with a continuous monitoring system with a low flow setting of 25 gpm and a low-low setting of 23 gpm. An alarm is triggered when flow drops to this level and the source takes immediate action to correct the problem. E28 is part of the Azide operation and is currently out of commission due to market forces. II.B.1.f AMPAC shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of pressure drop. The pressure drop shall not be less than 5.5 inches of water column at the inlet and not more than 12.0 inches of water column for the Perchlorate and/or Chlorate Blender A and B Wet Dust Collector (E23 and E24) and the Sodium Azide Blender Dust Collector Scrubber (E-29). [R307-401-8] Status: In Compliance. The requirements of this condition were reviewed at the time of inspection. Information viewed in the source's real-time database confirmed the pressure drops were within the required range. 10 II.B.1.g The scrubber liquid in the Perchlorate and/or Chlorate Blender A and B Wet Dust Collector (E23 and E24) and the Sodium Azide Dust Collector Scrubbers (E-27 and E-29) shall not exceed 1130 grams of weight per liter of liquid or 130 grams of particulate dissolved in 1 liter of water. Measurements shall be taken and recorded once per shift. [R307-401-8] Status: In Compliance. Scrubber liquid measurements were provided as follows: E23: 1010 grams per liter of liquid E24: 1020 grams per liter of liquid E27: Not in use E29: Not in use II.B.1.h AMPAC shall not exceed the following fuel consumption limits at the fire training pits without prior approval: A. 500 gallons of gasoline per month B. 500 gallons of propane per month C. 500 gallons of natural gas per month D. 500 gallons of JP-4 per month E. 500 gallons of JP-5 per month F. 50 gallons of oil/hydraulic fluid per month G. 15,000 gallons of heptane per rolling 12-month period H. 55 tons of untreated wood per rolling 12-month period Compliance with the annual limitations shall be determined on a rolling 12-month total. By the 15th day of each month, a new 12-month total shall be calculated using the previous 12 months. Records of consumption shall be kept for all periods when the plant is in operation. The records shall be kept on a monthly basis. [R307-401-8] Status: Not Applicable. The source has not used the fire training pits in the last two years. Training is provided by a third party off-site. The source did report using 200 gallons of heptane during the 12-month period for spring and fall fire brigade. II.B.1.i The time elapsed for fuel to remain in the pit, when not ignited, shall not exceed eight hours. The elapsed time period shall include periods prior to ignition, as well as elapsed time periods after the fire is extinguished. Unburned fuel shall be recovered from the pit through the use of a sump and storage tank system. [R307-401-8] Status: Not Applicable. The source has not used the fire training pits in the last two years. Training is provided by a third party off-site. II.B.1.j Access is restricted for any person(s) not directly related to the fire fighter training exercise to not less than 250 feet from the point of the burn. Means to enforce the restriction shall include, but not be limited to, barricades of public roads, signs posting against unauthorized access, and personnel available to enforce this restriction. [R307-401-8] Status: Not Applicable. The source has not used the fire training pits in the last two years. Training is provided by a third party off-site. 11 Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. The boilers only operate on natural gas. The source maintains records of natural gas consumption. See attached record. MACT (Part 63) -CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Status: In Compliance. The source has a 500-gallon gasoline storage tank. The source keeps monthly records of gasoline throughput. The average monthly throughput for the 12-month period ending March 31, 2024, was 867 gallons. The tank appeared to be well maintained, no spills were observed, and all pipes were capped. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The generators operate less than 100 hours for testing. Regular maintenance is conducted, the last oil change taking place on May 16, 2023. Oil changes are on the PM schedule for May 2024. Non-resettable hour meters are on each generator. Ultra-low sulfur fuel is used for operation. The 2700 kW generator is no longer operable. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. Only ultra-low sulfur fuel is used. Stationary Sources [R307-210] Status: In Compliance. Boilers only operate on natural gas. Records of natural gas consumption are kept. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. Compliance with this rule is met by compliance with Subpart 63, ZZZZ. EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from AMPAC, Utah Operations – Production Facility on the Approval Order (AO) DAQE-AN129100006-15, dated April 21, 2015. PTE are supplied for supplemental purposes only. 12 Criteria Pollutant PTE tons/yr Ammonia 6.55 CO2 Equivalent 5467.00 Carbon Monoxide 96.54 Nitrogen Oxides 7.04 Particulate Matter - PM10 17.65 Particulate Matter - PM10 (Fugitives) 18.23 Particulate Matter - PM2.5 17.65 Particulate Matter - PM2.5 (Fugitives) 18.23 Sulfur Dioxide 0.74 Volatile Organic Compounds 56.80 Hazardous Air Pollutant PTE lbs/yr Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 1000 Methanol (CAS #67561) 16240 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN129100006-15, dated April 21, 2015: AMPAC should be considered in compliance. The facility appeared to be well maintained and properly operated. Records were made available during the inspection and by email post inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as normal. The source is looking to add some equipment and are having discussions with NSR. Check to see if a new AO has been issued. Access to the source is restricted through a security checkpoint. A safety training must be completed before access beyond the front office is granted. Rubber slip-on safety shoes are required to tour source operations and are provided at the front office. Safety glasses are also required PPE. The source operates 7 am to 4:30 pm Monday through Thursday with every other Friday off. NSR RECOMMENDATIONS: The source is looking to replace the emergency generator E-31 in II.A.15 and add a product line. Boilers may also need to add propane as backup fuel. ATTACHMENTS: VEO Form, Email, Records 12 month Rolling Apr-23 May-23 Jun-23 Jul-23 Aug-23 Sep-23 Oct-23 Nov-23 Dec-23 Jan-24 Feb-24 Mar-24 12 month Rolling Allowed Sodium Azide Production 0 0 0 0 0 0 0 0 0 0 0 0 0.0 3000 Tons Ammonium Hydroxide 0.0 0.0 0.0 0 0 0.0 0.0 0 0 0 0 0 0.0 15600 Tons Sodium Hydroxide 0 0 0 0 0 0 0 0 0 0 0 0 0.0 3830 Tons Ammonia Gas (AAC)0 0 0 0 0 0 0 0 0 0 0 0 0.0 Ammonia Gas (WECCO)147,743 94,433 108,141 85,295 130,988 57,878 132,511 162,974 225,422 97,480 184,298 231,515 829.3 Total Ammonia Consumption 829.3 5130 Tons Nitrous Oxide Gas 0 0 0 0 0 0 0 0 0 0 0 0 0.0 2050 Tons Silicon Dioxide 0 0 0 0 0 0 0 0 0 0 0 0 0.0 21 Tons Natural Gas 9,851 6,878 7,995 6,840 10,119 9,176 9,305 11,599 14,339 12,855 14,451 14,529 127.9 334 MMCF Perchlorate Production 754,120 935,657 863,667 1,032,046 884,685 1,211,014 1,344,935 1,731,431 1,874,319 1,269,704 1,517,447 1,348,349 14,767,374 40 Million Pounds E4 emission point - Anode Building 80.4 140.3 143.8 141.7 195.1 157.9 171.8 124 175.6 203.2 153.1 166 1852.9 7920 hours E20 emission point - A Crystallizer 547.6 485.3 283.9 566.4 421.6 503.8 0 251.6 507.8 492.2 405.6 455.1 4920.9 8000 hours E21 emission point - B Crystallizer 0.5 0 0 300.5 184.6 140 279.6 385.6 400 421.3 477.3 412.9 3002.3 8000 hours E22 emission point - Batch Dryer 203.7 266.4 175 166.8 291.7 238.3 331.3 219.4 318.2 326.3 302.2 321.6 3160.9 8000 hours E23 emission point - A Blender 242.8 274.9 168.5 253.4 298.8 291.5 49.3 207 138 233.5 404 373.7 2935.4 8000 hours E24 emission point - B Blender 201.2 153.5 410.6 142.9 271.3 217 452.2 199.7 296.7 160.3 223.6 360.7 3089.7 8000 hours E28 emission point - Azide Maint. Building 0 0 0 0 0 0 0 0 0 0 0 0 0.0 4400 hours No Production E31 emission point - 2.5 MW Genrator 0 0 0 0 0 0 0 0 0 0 0 0 0.0 90 hours Out of Service E32 emission point - 900kW Generator 0.5 0.3 0.5 0 0 0 0 0 0 0 0 0 1.3 70 hours Turned Off for Testing HCFC-123 32,000 65,100 31,500 0 28,920 27,700 64,600 34,760 34,040 63,200 102,660 34,180 259.3 5000 tons Fire Test Area - Fuel Type Burned Limit Date Amt Consumed 2020 Amt By Month II.B.1.h Gasoline 500 gal/month 23-24 0 Propane 500 gal/month 23-24 0 Natural Gas 500 gal/month 23-24 0 JP-4 500 gal/month 23-24 0 JP-5/KEROSENE 500 gal/month 23-24 0 Oil/hydraulic fluid 50 gal/month 23-24 0 Untreated wood 55 T/year 23-24 0 Heptane 15,000 gal/year 23-24 200 Gasoline Consumption 897.2 834.8 872 754.6 933.4 871 797 716.7 846.5 1032.6 863.8 988.9 10408.5 Gal Diesel Consumption 972.7 1001.3 1107.9 1095.8 1268.9 1306.2 1135.7 948.9 1280.6 1383.3 1334.6 1337.5 14173.4 Gal Calibration E7 May-24 E8 Jun-24 E10 Jun-24 E12 Jun-24 E13 Jun-24 E15 Jun-24 E17 May-24 E18 May-24 E19 May-24 E20 May-24 E21 May-24 Spring Fire Brigade 100 gal, Fall Fire Brigade 100 gal