TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.:
105571
Company Name: Bell Helicopter Textron Inc.
APD
Reviewer:
Mr. Robert Chavez
Project No.:
192787
Unit Name:
PBR No(s).:
106.433
Bell Helicopter
GENERAL INFORMATION
Regulated Entity No.:
RN106501455
Project Type:
Permit by Rule Application
Customer Reference No.:
CN600131155
Date Received by TCEQ:
May 6, 2013
Date Received by Reviewer:
May 14, 2013
Physical Location:
400 tiltrotor dr
Account No.:
City/County:
Amarillo, Potter County
CONTACT INFORMATION
Responsible Official/ Primary
Contact Name and Title:
Mr. Chris Stone
General Manager
Phone No.:
Fax No.:
(806) 341-3080
(806) 341-3377
Email
:
CSTONE@BH.COM
Technical Contact/ Consultant
Name and Title:
Ms. Linda M Kelley
Sr Environmental & Safety
Specialist
Phone No.:
Fax No.:
(806) 341-3304
(806) 341-3939
Email
:
LKELLEY@BH.COM
GENERAL RULES CHECK
YES
NO
Is confidential information included in the application?
X
Are there affected NSR or Title V permits for the project?
X
Is each PBR > 25/250 tpy?
X
Are PBR sitewide emissions > 25/250 tpy?
X
Are there permit limits on using PBRs at the site?
X
Is PSD or Nonattainment netting required?
X
Do NSPS, NESHAP, or MACT standards apply to this
registration?
X
This is a revision of PBR#105571
MACT HHHHHH
MACT MMMM: recordkeeping only and certified not a major
source of HAPs
Does NOx Cap and Trade apply to this registration?
Is the facility in compliance with all other applicable rules and
regulations?
COMMENTS
X
X
Site is not in the HGA
In compliance with all rules and regulations
DESCRIBE OVERALL PROCESS AT THE SITE
Bell Helicopeter Textron Inc. owns and operates the Bell Helicopter Building #16 at 400 Tiltrotor Drive near Amarillo, Potter County.
DESCRIBE PROJECT AND INVOLVED PROCESS
Company has submitted a PI-7CERT for registration and supporting documentation under PBR rules 106.433 Surface Coating Facilities. This is a
revision of PBR#105571.
Current Operations
Operations at Building 16 include surface coating operations that occur inside an enclosed paint booth. Preparation, coating, and cleaning of new and
repaired aircraft assemblies of a new commercial helicopter line will be conducted in Building 16 (EPN 16-01). Building 16 currently houses one paint
booth (EPN 16-01) and one mix room (EPN 16-11). The paint booth and mix room stacks are equipped with unobtrusive rain protection devices. The
interior parts of the helicopter will be painted in the coating booth. The coating booth utilizes a curing process that uses a natural-gas fired heater with
a rated capacity of 0.9 MMBtu/hr to warm the air inside the paint booth to facilitate the drying of the coatings. The heat is not directly transferred
from the heating element to the aircraft part with the coating. In addition, a steam generating unit is used to control humidity in the paint booth. This
unit uses natural gas and has a maximum heat capacity of 0.8 MMBtu/hr. This unit is authorized per PBR §106.183 since combustion emissions do
not intermix with coating emissions; therefore, emissions are not included in this 106.433 registration. The enclosed paint booth will be equipped
with filters with 95% control efficiency for particulate matter.
All bulk coatings are mixed in the paint mix room using scales to measure the correct amounts per manufacturer and Bell process specifications.
Emissions from the mixing operations will be exhausted through the paint mix room's vent stack (EPN 16-11). Prior to painting, the parts may be
cleaned using solvents and paint strippers inside the paint booth. The primers and topcoats are then applied to the cleaned parts using a high volume
low pressure (HVLP) spray gun. The topcoats may be applied in a number of separate painting operations since the paint scheme may consist of
several colors, When the surface coating is completed, the spray gun is cleaned in a closed loop-gun cleaner using acetone. Emissions from the spray
gun cleaning are exhausted through the stack in the mix room.
Proposed Operations
The paint bench booth (EPN 16-02) is currently located in Building 9 of the Amarillo Assembly Center, The booth has three walls and a roof and will
meet the enclosed work area requirements of §106.433(6). Coating application will occur inside the booth, and emissions will exit stack EPN 16-02. In
addition, cleaning and paint stripping solvents may be used in small amounts. Helicopter parts will be coated using HVLP guns. The booth is
equipped with a filter wall with 95% efficiency. Spray gun cleaning will occur either inside the booth using acetone dip or wipes or just outside the
booth. Any cleaning and mixing occurring outside of the paint booth will be classified as De Minimis activities.
MSS Activities
MSS activities from current and proposed surface coating operations will include the replacement of filters on the paint booths and activities to catch
overspray from the paint spray guns. The filters will be changed whenever the pressure drop falls outside of the manufacturer recommendations.
Since the paint will adhere to the filter during removal, re-entrainment of the particles into the air is unlikely. To capture overspray, booth walls are
covered with a sticky contact paper, and the floor is covered with matting, which is taped to the floor. The booth paper and floor matting are routinely
1
TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.:
105571
Company Name: Bell Helicopter Textron Inc.
APD
Reviewer:
Mr. Robert Chavez
Project No.:
192787
Unit Name:
PBR No(s).:
106.433
Bell Helicopter
removed and replaced. All waste sheets and mats are placed into paint debris waste. Loose paint particles are vacuumed up and properly disposed of.
Thus, inherently low emissions are expected from these maintenance activities.
Emissions are calculated based on worst-case paint applied. Company is not applicable to Ch. 115.421 limit.
TECHNICAL SUMMARY - DESCRIBE HOW THE PROJECT MEETS THE RULES
§106.433 Surface Coating Facility
(1) Metalizing is not being performed at this site.
(2) Good housekeeping procedures will be practiced including:
(a) Spills are cleaned up immediately
(b) Booth and work area exhaust fans are operated during spray gun and equipment cleaning.
(c) All new and used coatings and solvents will be stored in closed containers. All waste coatings and solvents shall be removed from the site by an
authorized disposal service or disposed of at a permitted on-site waste management facility.
(3) No Non-electric drying ovens are used.
(4) There are no add-on controls used to reduce VOC emissions.
(a) The total annual VOC emission rate for all surface coating and/or stripping facilities at this site is 8.5 tpy VOC and 5.14tpy of exempt solvents.
(b) The total hourly VOC emission rate for all surface coating and/or stripping facilities at this site is 7.93 lb/hr of VOCs and 4.98 lb/hr of exempt
solvents.
(c) The total maximum hourly emission rates of VOC and exempt solvents are greater than 0.25 lb/hr (actual: 4.76 lb/hr).
(5) Opacity of visible emissions from new and existing surface coating facilities will not exceed 5.0%.
(6) Surface coating operations are performed in a completely enclosed work area or booth.
(a) No more than 6 lb/hr of VOC emissions, averaged over any five-hour period, and 500 pounds per week. Actual: 5.95 lb/hr and 493.25
lb/week.
(b) Minimum face velocity at the intake opening of the booth is rated to be 100 ft/min at any opening. Emissions will be exhausted through
elevated stacks that extend at least 1.5 times the building height above ground level. Stack will discharge vertically and rain protection will not restrict
or obstruct vertical flow.
(c) For spraying operations, emissions of particulate matter are controlled by a dry filter system with a minimum of 95% removal efficiency. The
face velocity at the filter will not exceed 250 ft/min. Filters will be replaced whenever the pressure drop across the filter no longer meets the
manufacturer’s recommendation.
(7) N/A: Surface coating operations are enclosed.
(8) Records will be maintained at the plant site for the most recent 24 months. Records include:
(a) Material Safety Data Sheets for all coating materials and solvents.
(b) Data of daily coatings and solvent use and the actual hours of operation of each coating and stripping operation.
(c) A summary report for each month that represents actual hours of operation and emissions from each operation to include:
(i) pounds per hour
(ii) pounds per day
(iii) pounds per week
(iv) tons emitted from the site during the previous 12 months
(d) Company does currently maintain a monthly report that shows examples of the method of data reduction including units, conversion factors,
assumptions, and the basis of the assumptions used to estimate emissions.
(9) A form PI-7 CERT was received to register the facility and certify emissions.
ESTIMATED EMISSIONS
EPN / Emission
Source
Specific VOC or
VOC
NOx
CO
PM10/PM
PM 2.5
SO2
Other Pollutants lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy lbs/hr tpy
ES
lbs/hr tpy
16-01/Paint Booth
Stack
6.63*
6.95
0.07
0.06
0.14
0.12
3.53
4.97
16-02/Paint Booth
Stack
1.3
1.56
0.02
0.02
0.03
0.04
1.45
0.04
16-51/Air Make-up
Heater
<0.01
0.02
0.01
0.03
0.01
0.03
0.09
0.39
0.07
0.32
<0.01
<0.01
16-11/Mix Room Stack
0.49
TOTAL EMISSIONS (TPY):
8.53
0.39
MAXIMUM OPERATING SCHEDULE:
Hours/Day
*Note: 5 hr average for EPN 16-01 is calculated to be 5.95 lb/hr
SITE REVIEW / DISTANCE
LIMIT
Yes
Site Review Required?
PBR Distance Limits Met?
No
X
X
0.32
Days/Week
Description/Outcome
0.11
0.19
Weeks/Year
Date
<0.01
Hours/Year
Reviewed by
Not required. Enclosed operations.
May 17, 2013
Robert Chavez
N/A. Enclosed operations.
May 17, 2013
Robert Chavez
2
0.12
5.14
8760
TECHNICAL REVIEW: AIR PERMIT BY RULE
Permit No.:
105571
Company Name: Bell Helicopter Textron Inc.
APD
Reviewer:
Mr. Robert Chavez
Project No.:
192787
Unit Name:
PBR No(s).:
106.433
Bell Helicopter
TECHNICAL REVIEWER
PEER REVIEWER
FINAL REVIEWER
SIGNATURE:
See Hard Copy.
PRINTED NAME:
Mr. Robert Chavez
DATE:
May 17, 2013
Ms. Anne M. Inman, P.E., Manager
BASIS OF PROJECT POINTS
Base Points:
Project Complexity Description and Points:
Complete in <14 days
Technical Reviewer Project Points
Assessment:
Final Reviewer Project Points Confirmation:
3
POINTS
1.5
1.0
2.5