DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
March 20, 2007
TO:
Phillip Fielder, P.E., Engr. Mgr. III, Air Quality Division
THROUGH:
Matt Paque, Supervising Attorney, Air Quality Division
THROUGH:
Kendal Stegmann, Senior Environmental Manager, Air Quality Division
THROUGH:
Richard Kienlen, P. E., Eng. Mgr.II, New Source Permits Unit
THROUGH:
Herb Neumann, P.E., Regional Office at Tulsa
THROUGH:
David Pollard, P.E., Regional Office at Tulsa
FROM:
Harold Wright, Regional Office at Tulsa
SUBJECT:
Evaluation of Permit Application No. 2006-008-O
Jensen International, Inc.
Jencast Ductile and Gray Iron Foundry
Section 13, T29N, R15E, Nowata County (Lat. 36.990º, Long. -95.628º)
Located in the Industrial Park of South Coffeyville, 0.5 miles west of US
Hwy. 169 and 0.5 mile south of the Oklahoma-Kansas border.
SECTION I.
INTRODUCTION
1.
Jensen International, Inc. (Jensen) owns and operates the Jencast Ductile and Gray Iron
Foundry (SIC 3321) facility (Jencast).
2.
In 2004, Jencast installed a second mold line (West Line), complete with pollution
control equipment.
3.
Jensen did not obtain a permit from the Oklahoma Department of Environmental Quality
(ODEQ) prior to installation of the West Line.
4.
Consent Order # 06-073 required Jencast to submit a Title V permit application, however,
a synthetic minor permit is requested for their existing facility.
5.
With this permit application submitted March 15, 2006, Jensen is seeking to modify their
operating permit to include the West Line.
6.
The permit is required to go through a Tier II process, but the facility will be issued a
synthetic minor permit on approval.
7.
Along with this permit action, Jensen also desires to increase the metal production rate
from 11,000 TPY to 15,000 TPY, allowing for increased operating flexibility.
PERMIT MEMORANDUM 2006-008-O
DRAFT
2
The facility was constructed under Permit 75-025-C, issued in April 1975, and received operating
permit 75-025-O in March 1977. The facility remained essentially unchanged until 1980, when a
porcelain coating process was added. For the purpose of establishing federally enforceable
permit conditions and “synthetic minor” status, an operating permit application was filed in
1997. The facility received operating permit 75-025-O (M-1) in May 1997. In 2000, the facility
submitted a permit application to increase permit limitations for VOC and SO2, based on an EPA
study, and received operating permit 75-025-O (M-2) in December 2000. The facility is
classified as a synthetic minor source and currently operates under provisions of Permit No. 75025-O (M-2).
SECTION II.
EUG-1
EU ID #
H1
H2
H3A
H3B
EUG-2
EU ID #
Charge
EIF-1
EIF-2
P&C
MAG
REF
SH-E
SH-W
SHAKE-E
SHAKE-W
GRIND
FINISH
CORE
EU-3
EU ID #
Bind
EQUIPMENT
EU Name
Construction/Modification Date
Preheater, 6.96 MMBTUH
Core Heater, 0.8 MMBTUH
Porcelain Heater, 1.2 MMBTUH
Porcelain Heater, 1.2 MMBTUH
1975
1975
1980
1980
EU Name
Construct/Modification Date
Charge Handling
Electric Induction Furnace
Electric Induction Furnace
Pouring and Casting
Magnesium Treatment
Refining (additives)
Sand handling East mold Line
Sand handling West mold Line
Casting Shakeout East Mold Line
Casting Shakeout West Mold Line
Sand Grinding
3 Shot Blasters and grinding equipment
Core Making
1974
1974
1974
1974
1974
1974
1974
2004
1974
2004
1974
1974
1974
EU Name
Construction/Modification Date
Bond, Binder, and Catalyst Usage
1974
PERMIT MEMORANDUM 2006-008-O
SECTION III.
DRAFT
3
PROCESS DESCRIPTION
The facility produces ductile and gray iron castings from pig iron, steel scrap and cast scrap. The
major processes involved are metal melting, refining and magnesium treatment, mold production,
core production, pouring, cooling, casting shakeout, and finishing. Currently, the facility has two
(2) molding lines, the East Line and the West Line. Essentially both lines are identical in
equipment and function, except the West Line is capable of producing larger part castings.
Raw material in the form of metals enter the plant by truck, whereas sand enters the facility by
rail cars. Both are unloaded inside the building, which encloses the facility. The metals are
deposited into storage bins. The sand is pneumatically transferred to a sand silo for storage, and
then pneumatically transferred to other areas where it is used in making molds and cores for the
metal castings. The estimated sand-handling rate for the East Line is 48 tons per hour, whereas
maximum sand-handling rate for the West Line is 63 tons per hour. Both the East Line and West
Line are equipped with sand mullers, which mix the sand with binders for use in mold production
and core production. The mullers are each rated at 40 tons per hour. However molds have a very
finite life and are best if poured within a few hours. Beyond eight (8) hours the molds are
unusable. The facility cannot produce enough metal to keep up with production at either the
maximum sand handling or muller processing rates. Therefore, the potential to emit for the
facility is operationally limited by the metal production rates of 4.2 tons per hour and 11,000
TPY, contained in the existing permit.
An overhead electric magnet transfers the metal feed material to a natural gas-fired preheater,
which heats the metal and removes any oil and grease prior to introduction to the charge
furnaces. From the preheater, the metal is lifted to two electric induction furnaces by a crane and
a charge bucket. Since there is only one power source on-site, the furnaces cannot operate
concurrently and must alternate, with one being tapped while the other is being charged. The
melting process is continuous during the daily operating schedule, with a maximum melting rate
of 4.2 tons of metal per hour. Charging and tapping occurs four times per hour.
Gray iron and ductile iron are produced by inoculation (refining) using various additives, while
the metal is either in the charge furnace or in the ladle. Primary additives to the furnaces include
silicon carbide and graphite. Primary additives to the ladle include magnesium, manganese, and
silicon. For various metal alloys, other metals such as chromium, nickel, and copper are used.
The addition of magnesium (magnesium treatment) to molten metal causes a violent reaction
between the magnesium and molten iron, resulting in smoke consisting of magnesium oxides and
metallic fumes. To minimize worker exposure to such fumes, the facility installed a cartridge
type dust collector. This dust collector, though not recognized in earlier permits, reduces the
emission potential from the melting, treatment, refining, tapping, and ladle operation associated
with the molten metal.
Sand molds are produced in either the East Line or West line, from a blend of fresh sand and
reclaimed sand, and along with cores, are used to produce the castings. In producing the molds,
the sand (silica sand) is mixed with a liquid chemical bond (not equal to “binder”) material,
brought into the facility by truck. The bond material is mixed and bonded to the sand in the sand
PERMIT MEMORANDUM 2006-008-O
DRAFT
4
muller. From the sand muller, the sand and bond mixture is used in making molds. In molds, the
sand is mechanically packed from the top and bottom around a casting pattern and core. The
process by which molds are produced without heating, such as the Jencast facility, is referred to
as “Green Sand” molding. Cores are also produced from a mixture of new sand and binders,
which are mixed together in any of three (3) mixers. Cores are dried either by air or in the core
oven. When a mold is finished, the pattern is removed. Casting patterns are prepared in a
separate building. Dusts generated in the mold and core processes are controlled by baghouse
filter systems.
Conveyors transfer the molds to the ladle, where metal is poured into the mold to create the
castings. The castings are cooled and are then removed by a casting shakeout process. Dust
generated in the shakeout process for each line is controlled by baghouse filter systems. Where
possible, sand used in the mold is transferred back to the sand muller for reuse. Unusable sand
(“spent”) is screened through metal grates, in an outdoor process, removing metal scrap, which
returns to the melt process. The spent sand is conveyed to a central location, loaded into roll off
boxes by a bobcat, and sent offsite for disposal. Casting metal is periodically tested for desired
properties. When necessary, castings are heat treated at a temperature from 1,500o F to 1,650o F
in two baking ovens, located at a separate building (Marjen) adjacent to the foundry. This
facility is included as part of the total facility, and is part of the foundry. This building also has
two small (insignificant) ovens for laboratory testing purposes. Castings to be heat-treated are
loaded on flat-bed trucks and transported approximately 300 feet to the heat-treating building
(Marjen). After heat-treating, the castings are returned to the foundry for finishing. Castings are
finished by shot blasting and grinding. The facility has three (3) shot blasters and multiple
grinders. The dust generated by the finishing operation is controlled by a cartridge filter system.
Some castings receive a porcelain coating after finishing. Prior to coating, the porcelain is
prepared by a Frit ball mill until it is liquid. The liquid porcelain is allowed to flow onto the
casting. Heat from the induction furnaces removes water from the Frit. After drying, the
porcelain-coated casting is cured in one of the natural gas-fired heat treating furnaces at the
Marjen building. Castings are then packaged and stored, until they are shipped offsite to
customers.
Operating Schedule and Production Rates
The facility generally operates up to 16 hours per day for 5 days per week and 52 weeks per year
for a total of 4,160 hours per year. Because the two (2) existing electric induction (EIF) furnaces
have only one power source, there is a maximum metal production rate of 4.2 tons of metal per
hour. One EIF is being charged while the other is melting metal and being tapped. An EIF is
tapped approximately four (4) times per hour. Based on the 4.2 tons of metal per hour, the
facility could produce approximately 36,800 tons of metal per year. However, the facility does
not operate continuously and the current operating permit provides an operational limitation of
11,000 tons of metal production per year. Sand handling, mixing, and mold production are
directly related to the metal production, and are therefore, limited as well. The facility desires
additional operating flexibility, and with this permit application requests an increase in limitation
on metal production from 11,000 TPY to 15,000 TPY, as well as the limits on binder
consumption.
PERMIT MEMORANDUM 2006-008-O
SECTION IV.
DRAFT
5
EMISSIONS
Process operations
Principle process operations include:
1.
2.
3.
4.
5.
6.
Metal Preparation
Preheater
Melting and Casting
Electric Induction Furnace A
Electric Induction Furnace B
Magnesium Treatment
Refining
Pouring
Cooling
Cleaning and Finishing
Casting Shakeout-East Line
Casting Shakeout-West Line
Grinding
Finishing
Shotblaster 1
Shotblaster 2
Shotblaster 3
Grinders
Core and Mold Preparation
Core Making
Core Oven
Sand Handling
Mold making-East line
Mold making-West line
Spent Sand Screening
Heat Treating and/or Porcelain Curing
Porcelain Curing/Heat Treating 1
Heat Treating 2
Laboratory Oven 1
Laboratory Oven 2
Emission Factors
The most current emission factors were used. Emission estimates were prepared using emission
factors obtained from EPA’s Compilation of Air Pollutant Emission Factors (AP-42), EPA’s
Aerometric Information Retrieval System (AIRS) and EPA’s factor Information Retrieval data
system (FIRE 6.25), which contains AP-42 data. Factors were selected for each source
classification code (SCC) within the foundry facility.
PERMIT MEMORANDUM 2006-008-O
DRAFT
6
Other sources of emission factors include “Calculating Emission Factors for Pouring, Cooling
and Shakeout,” American Foundrymen’s Society, Modern Casting, October 1994, and “Preferred
and Alternative Methods for Estimating Air Emissions from Secondary Metal Processing,”
EPA’s Emission Inventory Improvement Program (EIIP), 2001. In previous permits, emission
factors were increased by 10%. In this permit application, no adjustments were made to
published factors. Emission factors are presented with emission estimates contained in tables to
follow.
Emssion Controls
The facility has several particulate control devices that capture emissions from melting, refining,
magnesium treatment, pouring ladle, core and mold production, casting shakeout, and finishing
operations. Beginning with the initial construction and subsequent operating permit applications,
the control efficiency of the Kice baghouse dust collector was stated as 99.95% control
efficiency, but then reduced to 90% for estimating emission and permit limitations. With a few
exceptions, the majority of the control equipment at the facility has a manufacturer’s rated
efficiency of 99.9% or higher for particles > 1 micron. The applicant states that manufacture
ratings for the control efficiencies in devices at the facility range from 99.9 % to 99.95 % or
higher. To be conservative, Jencast has assumed only a 99 % efficiency. Additionally, though
not in previous permits for the facility, Jencast has installed a cartridge type baghouse reverse
pulse jet collector controlling emissions from the melting, magnesium treatment, refining, and
pouring operations. A listing of control equipment, manufacturer’s ratings, and process
controlled are presented in Table 5 of the application.
During the review of this permit application, two controls were removed with their emissions
being re-routed. The Aget baghouse was removed and the Pangborn Filter was replaced with a
Rotoblast 6LK-7 table blaster.
Table 5 Control Devices (as indicated in application)
Control *
Device
Pangborn PC3-36 Baghouse
Operation
Controlled
Melt/Treat./Pour
Inst.
2000
Eff.
%
99.9
Kice W-528 Dyna Jet Twin
Baghouse, exhaust 1
Kice
W-528
Dyna
Jet
Baghouse
Kice w-528 Dyna Jet Twin
Baghouse exhaust 2
Pangborn
PC318
Filter
(Replaced with a Rotoblast
6LK-7 table blaster)
MS 10-672-8299 Steel Craft
Filtrex Baghouse
Sand
mold/
shakeout/east
Sand silo return
east line
Sand
mold/shakeout/east
Shot blasters 1&2
& grinders
1975
99.95
1975
99.95
1975
99.95
1999
90
Sand
2004
mold/shakeout west
& shot blaster 3, &
grinders
99.9
Exhaust
Size
12”x24”
x 20’
36”x60”
x 45’
36”x60”
x 45’
36”x60”
x 45’
12”x24”
x 20’
Exhaust
ACFM
10 M
Exhaust
temp º F
600
25.9 M
Ambient
25.9 M
Amb.
29.5 M
Amb.
60”x60”
x 30’
50 M
Amb.
350
PERMIT MEMORANDUM 2006-008-O
MS 10-672-8299 Steel Craft
Filtrex Baghouse
Dynamic Air series B. H., vent
type purges back into tank
Dynamic Air series B. H., vent
type purges back into tank
PO16842 N.Y. south exhaust
Blower
Dynamic Air series 200 Dust
collector
DRAFT
Sand silo ret. west
2004
99.9
Bond silo east line
1975
90
60”x60”
x 30’
4”x 30’
Bond silo west line
1975
90
4”x 30’
Pre-heater
2006
N/A
18”x6’
Bond Auger west 2004
line
4”x30’
7
50 M
350
Not
driven
Not
driven
5.5 M
350
Not
driven
Amb.
350
80
* Model, Make, Type
The paragraph below was submitted by the applicant from RFS Consulting, Inc.
A Best Available Control Technology (BACT) analysis is required when the potential emissions
exceed 100 tpy for any criteria air pollutant, such as with the installation of the West Line. The
West Line is equipped with a high efficiency collection system and baghouse to control
emissions from the sand handling (mold making) and shakeout operations. According to
manufacturer’s data, the baghouse filter has a 99.9% control efficiency for particle sizes with an
aerodynamic diameter of > 1 µm. According to EPA’s RACT/BACT/LEAR Clearinghouse
(RBLC) database, baghouse dust collectors are essentially the only control technology used on
these types of process operations and state control efficiencies ranging from 91.4% to 99.9%,
with exhaust concentrations ranging from 0.0045 gr/cf to 0.01 gr/cf. Of the facilities reviewed in
RBLC data, there was only one instance with a wet dust removal system. The control efficiency
for the wet dust removal system was stated as 99%. Of the baghouse filter systems, the most
common exhaust concentration was 0.005 gr/cf. Based on the manufacturer’s rating for the
baghouse currently installed on the West Line at Jencast, the control efficiency more than
satisfies BACT. Using estimated releases from the sand handling and shakeout operations on the
west line and the rated control efficiency of 99.9%, this equates to 0.00045 gr/cf in the exhaust,
which is significantly better than BACT. At an assumed lesser efficiency of 99%, the exhaust
concentration is 0.003 gr/cf, still satisfying BACT. Therefore, the facility proposes to use this
equipment as BACT, and assume emissions based on this lesser removal efficiency.
Emission Estimates
All tables below refer to table numbers in the application. Emission estimates for foundry
operations at existing permit limitations are listed in (Table 1) below. As noted above, control
efficiencies have been increased from 90% to 99%, to more closely reflect manufacturer’s rated
efficiencies. Emissions at desired limitations are shown in Table 2, and reflect increased
production to 15,000 tpy and increased binder consumption (Table 7). Potential emissions from
the West Line are shown in Table 3, and were calculated as if uncontrolled. Heater/furnace
emissions are shown in Table 4. Control devices were shown previously in Table 5. Emission
estimates associated with binder usage at existing permit limits and at desired limitations are
shown in Table 6 and Table 7, respectively.
PERMIT MEMORANDUM 2006-008-O
DRAFT
8
Table 1 (from Application and revised February 8, 2007)
Potential to Emit – Existing Limits
Tons per year = 11,000
Basis: FIRE 6.25, AIRS, AP-42, Initial permit application, and 3/19/97 Marburger letter (Grant
Marburger was an Environmental Consultant, also a former DEQ employee, who submitted
combustion emissions from the preheater for burning off oil and grease from charge material)
Unit ID
Seq.
No.
Description
Charging
3
3
Handling
Preheat
Melting/
Casting
1A&B
Induction
Furnace
Pour/Cool
4
2
2
Sand
Handling
System
Cleaning/
Finishing
East
West
Spent
Sand
5East
5West
6
8A
8B
Mg
Treatment
Refining
Sand
Handling 4
Sand
Handling 4
Sand
Handling
Casting
Shakeout
Casting
Shakeout
Sand
Grind/Mix
Finishing
(shot blast/
Grind
Heat Treat
Porcelain
Heater
Heat Treat
Porcelain
Heater
Ref.
Cont.
Effic.
%
0
0
PM10
1.98
0.23
NOx
8.37
CO
1.80
VOC
0.16
SO2
8.022
Lead
-
0
4.73
-
-
-
-
0.55
Fire/
AP42
Fire
99
0.11
-
-
2.21
0.11
-
99
0.02
-
-
-
-
-
Fire/
Airs
Fire
99
0.17
-
-
0.03
-
-
99
0.33
-
-
-
-
-
Fire
99
0.33
-
-
-
-
-
Fire
0
33.00
-
-
-
-
-
Fire
99
0.12
-
-
18.94
-
-
Fire
99
0.12
-
-
18.94
-
-
Fire/
AP42
Fire
99
0.01
-
-
-
-
-
0
0.02
-
-
-
-
-
AP42
0
0.02
0.264
0.222
0.015
0.002
-
AP42
0
0.02
0.264
0.222
0.015
0.002
-
Fire
Init.
Pmt.
Fire
Emissions (TPY)
PERMIT MEMORANDUM 2006-008-O
DRAFT
9
Table 1 continued
Unit ID
Seq.
No.
Cold/Mold
Prep.
7
Description
Core
Making
Core Oven
Ref.
Fire
AP42
Cont.
Effic.
99
Emissions (TPY)
-
-
-
-
-
-
0
0.013
0.18
0.15
0.01
0.001
-
Total
40.78
9.07
2.39
21.38 8.14
0.55
4
Sandhandling and shakeout show for the West Line and East Line, as if both were being charged.
Maximum metal melting will allow for only the equivalent of one line at capacity. Thus total emissions
only include one line.
Table 2 is a prediction of emissions for 15,000 Tons per year metal production.
Table 2 (from Application and revised February 8, 2007)
Desired Limits
Tons per year = 15,000
Basis: FIRE 6.25, AIRS, AP-42, Initial permit application, and 3/19/97 Marburger letter
Unit ID
Seq.
DescripRef. Cont.
Emissions (TPY)
No.
tion
Effic.
PM10 NOx CO
VOC SO2
Charging
3
3
Handling
Preheat
Melting/
Casting
1A&B
Induction
Furnace
Pour/Cool
4
2
2
Sand
Handling
System
East
West
Spent
Sand
Mg
Treatment
Refining
Sand
Handling 4
Sand
Handling 4
Sand
Handling
Lead
Fire
Init.
Pmt.
Fire
0
0
2.70
0.23
8.37
1.80
0.16
8.022
-
0
6.45
-
-
-
-
0.75
Fire/
AP42
Fire
99
0.15
-
-
3.29
0.15
-
99
0.03
-
-
-
-
-
Fire/
Airs
Fire
99
0.23
-
-
0.04
-
-
99
0.45
-
-
-
-
-
Fire
99
0.45
-
-
-
-
-
Fire
0
45.00
-
-
-
-
-
PERMIT MEMORANDUM 2006-008-O
DRAFT
10
Table 2 continued
Unit ID
Seq.
No.
Description
Cleaning/
Finishing
5East
Casting
Shakeout
Casting
Shakeout
Sand
Grind/Mix
5West
6
8A
8B
Cold/Mold
Prep.
7
Finishing
(shot blast/
Grind
Heat Treat
Porcelain
Heater
Heat Treat
Porcelain
Heater
Core
Making
Core Oven
Ref.
Cont.
Effic.
Emissions (TPY)
Fire
99
0.17
-
-
28.23
-
-
Fire
99
0.17
-
-
28.23
-
-
Fire/
AP42
Fire
99
0.01
-
-
-
-
-
0
0.03
-
-
-
-
-
AP42
0
0.02
0.264
0.222
0.015
0.002
-
AP42
0
0.02
0.264
0.222
0.015
0.002
-
Fire
99
-
-
-
-
-
-
AP42
0
0.013
0.18
0.15
0.01
0.001
-
Total
55.51
9.07
2.39
31.76 8.18
0.75
4
Sandhandling and shakeout show for the West Line and East Line, as if both were being charged.
Maximum metal melting will allow for only the equivalent of one line at capacity. Thus total emissions
only include one line.
Table 3
Actual Existing Limits – West Line Only
Tons per year = 11,000
Basis: FIRE 6.25, AIRS, AP-42, Initial permit application, and 3/19/97 Marburger letter
Unit ID
Cont.
Emissions (TPY)
Description Eff.
PM
NOx CO VOC SO2 Lead Mg Ferric
Oxide
Charging
Melting/
Casting
Handling
Preheat
Induct. Furn.
Pour/Cool
Mg
Treatment
Refining
-
-
-
-
2.21
-
0.11
-
-
-
-
-
-
-
-
-
-
-
-
-
PERMIT MEMORANDUM 2006-008-O
DRAFT
11
Table 3 continued
Unit ID
Description
Sand
Handling
Clean/
Finish
8A
8B
Core/Mold
Prep.
East Line ¹
West Line ¹
East Casting
Shakeout ¹
West Cast’g
Shakeout ¹
Sand
Grind/Mix
Shotblast/Grind
Heat Treat/
Porcelain
Heater
Heat Treat/
Porcelain
Heater
Core Making
Cont.
Eff.
PM
NOx
CO
Emissions (TPY)
VOC SO2 Lead
Mg
Ferric
Oxide
0
-
220.0
-
-
-
-
-
-
-
-
0
17.60
-
-
18.94
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Core Oven
Total
237.60 0
0
21.15 0.11 0
0
0
¹ Sandhandling and shakeout show for the West Line and East Line, as if both were being charged.
Maximum metal melting will allow for only the equivalent of one line at capacity. Thus total emissions
only include one line.
Table 4
Emission Estimates – Heaters
Equipment parameters
Equipment
ID Number
Preheater
Core Furnace
Heat Treating/Porcelain Furnace
Heat Treating/Porcelain Furnace
Function
Heats metal charge
Dries cores
Heat treat product or cure porcelain coating
Heat treat product or cure porcelain coating
Design Duty
MM BTU/hr
6.9600
0.8000
1.2000
1.2000
PERMIT MEMORANDUM 2006-008-O
DRAFT
12
Criteria Air pollutant Emissions
Basis: Emission factors (EF) from AP-42; Hours of operation = 4,400; Btu/scf = 1,000 (nat. gas)
ID #
NOx
CO
VOC
SOx
PM
EF
TPY EF TPY EF
TPY
EF TPY
EF
TPY
Lb/mmscf
Pre-heater
Preheater
HC Burnoff
Core
Furnace
Heat
Treating/Porcelain
Furnace
Heat
Treating/Porcelain
Furnace
Total
100.0
67.0
1.531
6.839
84.0
5.0
1.286
0.510
5.50
0.760
0.084
0.078
0.6
78.5
0.009
8.013
7.6
2.0
0.116
0.204
100.0
0.176
84.0
0.148
5.50
0.010
0.6
0.001
7.6
0.013
100.0
0.264
84.0
0.222
5.50
0.015
0.6
0.002
7.6
0.020
100.0
0.264
84.0
0.222
5.50
0.015
0.6
0.002
7.6
0.020
9.075
2.388
0.201
8.027
0.374
Hazardous Air Pollutants
ID
Preheater
Design
<100
mmbtu/hr
---
Preheater
HC
Burnoff
Core
<100
Furnace
mmbtu/hr
Heat
<100
Treating/
mmbtu/hr
Porcelain
furnace
Heat
<100
Treating/
mmbtu/hr
Porcelain
furnace
Annual HAPs
Lb/hr HAPs
Estimated Emissions (TPY)
Hexane Lead Napthalene n-pentane
Toluene
Total
HAPs
-
0.028
-
-
0.040
-
0.068
-
-
-
-
-
-
-
-
-
-
0.003
-
-
0.005
-
.008
-
-
0.005
-
-
0.007
-
0.012
-
-
0.005
-
-
0.007
-
0.012
-
-
0.40
0.018
-
-
0.058
0.026
-
0.099
0.045
Chrysene
Dichlorobenzene
-
PERMIT MEMORANDUM 2006-008-O
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13
HAP Emission Factors
Basis: HAP constituent factors from AP 42, Natural Gas Combustion
Design
Class
<
100
mmbtu/hr
Chrysene
2.60E-06
DichloroBenzene
1.20E-03
Hexane
EF, lb/mmscf
Lead
Toluene
1.80E+00
5.40E-04
2.05E-02
Naphthalene
n-pentane
2.63E-03
2.6
Preheater HC Burnoff accounts for oil and grease burned off of scrap metal based on 6.96
mmbtu/hr and 150,000 btu/gallon of fuel oil, and AP-42 fuel oil factors.
Fuel oil equivalent = 6.96 x 10 6 btu/hr x 1/150,000 btu/gallon = 46.4 gallons of fuel oil per hour.
Emssion factors from Tables 1.3-2 and 1.3-4 for utility boiler burning No. 6 fuel oil in units of
lbs/1,000 gallons. Assumes 0.5 wt% sulfur in oil.
“TABLE 5” was listed under “Emission Controls” in a prior location.
Table 6
Estimated Emissions from Binder Usage – Existing Limitations (Tons per year = 11,000)
Phenolic Urethane Binders and Seacoal Bonds
Proposed Permit Limits, TPY =
(no limit)
Pollutant
(Part I and Part II)
Ammonia
Hydrogen Sulfide
Nitrogen Oxides
Sulfur Dioxide
Total Hydrocarbons
Acrolein
(HAP)
Benzene
(HAP)
Formaldehyde
(HAP)
Hydrogen Cyanide
M Xylene
(HAP)
Naphthalene
(HAP)
O Xylene
(HAP)
Phenol
(HAP)
Toluene
(HAP)
Aromatic Amines
Aldehydes
HAP
36.0
28.8
64.8
15.2
1,650
Emission Factor
Lb/lb
0.000083
0.000057
0.000044
0.000061
0.023377
0.000031
0.005351
0.000022
0.001053
0.000439
0.000022
0.000132
0.003904
0.000833
0.000351
0.000219
0.012355
Part I Isocure IM 397
Part II Isocure IM 697
Part I and II Total
Isocure Cat 702
JPSC 172 Bonds
Emissions
TPY
0.0054
0.0037
0.0029
0.0040
1.5148
0.0020
0.3467
0.0014
0.0682
0.0284
0.0014
0.0086
0.2530
0.0540
0.0227
0.0142
0.8006
PERMIT MEMORANDUM 2006-008-O
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14
Isocure Catalyst 702¹
Dimethylethylamine
JPSC 17 Bond (Seacoal ²)
Ammonia
Hydrogen Sulfide
Nitrogen Oxides
Sulfur Dioxide
Total Hydrocarbons
Acrolein
(HAP)
Benzene
(HAP)
Formaldehyde
(HAP)
Hydrogen Cyanide
M Xylene
(HAP)
Naphthalene
(HAP)
O Xylene
(HAP)
Phenol
(HAP)
Toluene
(HAP)
Aromatic Amines
Aldehydes
HAP
Total VOC
Total HAP
100 %
15.2 TPY
Emission Factor
Lb/lb
Emissions
TPY
0.000065
0.000832
0.000562
0.000253
0.011941
0.000002
0.000611
0.000004
0.000118
0.000021
0.000021
0.000021
0.000131
0.000063
0.000021
0.000063
0.001076
0.0241
0.3039
0.2086
0.0939
4.4331
0.0007
0.2268
0.0015
0.0438
0.0078
0.0078
0.0078
0.0486
0.0234
0.0078
0.0234
0.3995
21.15
1.20
Notes
Source: Binder emission estimates based on “Calculating Emissions Factors for Pouring, Cooling and
Shakeout, “American Foundrymen’s Society, Modern Casting, October, 1994.
¹ Isocure Catalyst not mentioned in Source, therefore assumed 100% volatilized.
² According to MSDS, JPSC17 is composed of 22.5% by weight seacoal, therefore bond quantity was
reduced to this amount.
PERMIT MEMORANDUM 2006-008-O
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Table 7
Estimated Emissions from Binder Usage – Desired Limitations (Tons per year = 15,000)
Phenolic Urethane Binders and Seacoal Bonds
Proposed Permit Limits, TPY =
(no limit)
Pollutant
(Part I and Part II)
Ammonia
Hydrogen Sulfide
Nitrogen Oxides
Sulfur Dioxide
Total Hydrocarbons
Acrolein
(HAP)
Benzene
(HAP)
Formaldehyde
(HAP)
Hydrogen Cyanide
M Xylene
(HAP)
Naphthalene
(HAP)
O Xylene
(HAP)
Phenol
(HAP)
Toluene
(HAP)
Aromatic Amines
Aldehydes
HAP
49
39
88
21
2,250
Part I Isocure IM 397
Part II Isocure IM 697
Part I and II Total
Isocure Cat 70
JPSC Bonds
Emission Factor
Lb/lb
0.000083
0.000057
0.000044
0.000061
0.023377
0.000031
0.005351
0.000022
0.001053
0.000439
0.000022
0.000132
0.003904
0.000833
0.000351
0.000219
0.012355
Emissions
TPY
0.0073
0.0050
0.0039
0.0054
2.0657
0.0027
0.4728
0.0019
0.0930
0.0388
0.0019
0.0117
0.3450
0.0736
0.0310
0.0194
1.0917
Isocure Catalyst 702¹
The Isocure catalyst was assumed to volatilize 100%. The existing permit limited the Isocure to
15.2 TPY. With this permit Jencast desired to increase throughput (melt) from 11,000 TPY to
15,000 TPY. Therefore, the Isocure quantity was ratioed up via 15.2 x 15,000/11,000 = 20.727
TPY.
Dimethylethylamine
100 %
20.727
PERMIT MEMORANDUM 2006-008-O
JPSC Bonds (Seacoal ²)
Ammonia
Hydrogen Sulfide
Nitrogen Oxides
Sulfur Dioxide
Total Hydrocarbons
Acrolein
(HAP)
Benzene
(HAP)
Formaldehyde (HAP)
Hydrogen Cyanide
M Xylene
(HAP)
Naphthalene
(HAP)
O Xylene
(HAP)
Phenol
(HAP)
Toluene
(HAP)
Aromatic Amines
Aldehydes
HAP
Total VOC
Total HAP
0.000065
0.000832
0.000562
0.000253
0.011941
0.000002
0.000611
0.000004
0.000118
0.000021
0.000021
0.000021
0.000131
0.000063
0.000021
0.000063
0.001076
DRAFT
JPSC-22
0.0329
0.4212
0.2845
0.1281
6.0451
0.0010
0.3093
0.0020
0.0597
0.0106
0.0106
0.0106
0.0663
0.0319
0.0106
0.0319
0.5447
16
JPSC GSW1
0.0475
0.6084
0.4110
0.1850
8.7319
0.0015
0.4468
0.0029
0.0863
0.0154
0.0154
0.0154
0.0958
0.0461
0.0154
0.0461
0.7868
31.52
1.88
Notes
Source: Binder emission estimates based on “Calculating Emissions Factors for Pouring, Cooling and Shakeout,
“American Foundrymen’s Society, Modern Casting, October, 1994.
¹ Isocure Catalyst not mentioned in Source, therefore assumed 100% volatilized.
² According to MSDS, JPSC-22 and JPSC GSW1 are composed of 22.5% and 32.5% by weight seacoal,
respectively, therefore bond quantity was reduced to this amount. JPSC GSW1 is used in producing the West Mold
Line. Because emission estimates are higher for this material than the JPSC-22, the totals for VOC and HAP
emissions assume that the entire annual quantity of bonds consumed were this material.
Table 8 is based on process weight formula in Appendix G of the ODEQ rules.
REVISED DATA WAS SENT AND RECEIVED FEBRUARY 8, 2007.
Based on ODEQ rule Appendix G:
Allowable Emission, E = 4.10 P 0.67, where E = rate of emission in lb/hr and P = process rate in
tons/hr. Since the processing rate is 4.2 tons per hour, E = 4.1 * 4.2 0.67 , or 10.72 lbs/hr.
Allowable emissions are based on metal production only. Sand handling is actually 4 to 7 times
higher than metal production. Also, there is only one occurance of Sand Handling and Casting
Shakeout, since based on metal production, only one equivalent line is operational. Only one
PERMIT MEMORANDUM 2006-008-O
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17
induction furnace can operate at a time. There is only one electrical transformer, and it must be
switched from furnace to furnace.
Table 8
Allowable Emissions based on Process rate
Process rate limit = 4.2 TPY, Allowable Emissions, E=4.10 P 0.67, where E = rate of emission in
lb/hr and P = process weight rate in tons/hr.
Process
Charge handling
Electric Induction Furnace
Pouring/Cooling
Magnesium Treatment
Refining
Sand Handling
Casting Shakeout
Grinding
Finishing (Shot blasting and grinding)
Heat Treat/Porcelain Heater
Heat Treat/Porcelain Heater
Core Making
Allowable Emission Total
Allowable Emission Total
Allowable Emissions (lb/hr)
10.72
10.72
10.72
10.72
10.72
10.72
10.72
10.72
10.72
10.72
10.72
10.72
128.69 lb/hr
267.67 TPY
Revised based on Tables 1 and 2 received February 8, 2007.
Given total PM10 from Table 2 (revised) =
Using the normal operating schedule =
Estimated hourly emissions =
55.51 TPY
4,160 hours/year
26.69 lbs/hr
Therefore in compliance
SECTION V.
INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application and listed in OAC 252:1008, Appendix I, are listed following. Recordkeeping for activities indicated with “*” is listed in
the Specific Conditions.
1)
Space heaters, boilers, process heaters, and emergency flares less than or equal to 5
MMBTUH/hr heat input (commercial natural gas). The facility has 32 space heaters.
2)
* Emissions from fuel storage/dispensing equipment operated solely for facility owned
vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day
period. The facility has one 300-gal gasoline storage tank.
PERMIT MEMORANDUM 2006-008-O
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3)
* Storage tanks with less than or equal to 10,000 gallons capacity that store volatile
organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum
storage temperature. The facility has one 250-gallon diesel storage tank.
4)
Welding, brazing, soldering for maintenance purposes.
5)
* Emissions from storage tanks constructed with a capacity less than 39,894 gallons
which store VOC with a vapor pressure less than 1.5 psia at maximum storage
temperature. The facility has none at this time.
6)
Hazardous waste and hazardous materials drum staging areas.
7)
* Activities having the potential to emit no more than 5 TPY (actual) of any criteria
pollutant.
SECTION VI.
OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions)
Subchapter 1 includes definitions but there are no regulatory requirements.
[Applicable]
OAC 252:100-3 (Air Quality Standards and Increments)
[Applicable]
Subchapter 3 enumerates the primary and secondary ambient air quality standards and the
significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these
standards.
OAC 252:100-4 (New Source Performance Standards)
[Not Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on September
1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B,
Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart BBBB,
Subpart DDDD, Subpart HHHH, and Appendix G. NSPS requirements are addressed in the
“Federal Regulations” section.
OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees)
[Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission
inventories annually, and pay annual operating fees based upon total annual emissions of
regulated pollutants. Emission inventories were submitted and fees paid for previous years as
required.
OAC 252:100-7 (Permits for Minor Facilities)
[Applicable]
Subchapter 7 sets forth the permit application fees and the basic substantive requirements of
permits for minor facilities. This permit is now a synthetic minor source, although it is going
through a Tier II review process due to of a Consent Order (No. 06-073) requiring a Title V
permit application because the PTE for the sand mold line exceeds the major source threshold for
PM. Since criteria pollutant emissions are less than 100 TPY for each pollutant and emissions of
Hazardous Air Pollutants (HAP) will not exceed 10 TPY for any one HAP or 25 TPY for any
PERMIT MEMORANDUM 2006-008-O
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aggregate of HAP, the facility is defined as a synthetic minor source. As such, BACT is not
required. Permit conditions are appropriate requiring maintenance of the baghouses to ensure the
source remains minor.
OAC 252:100-9 (Excess Emissions Reporting Requirements)
[Applicable]
In the event of any release which results in excess emissions, the owner or operator of such
facility shall notify the Air Quality Division as soon as the owner or operator of the facility has
knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10)
working days after the immediate notice is given, the owner or operator shall submit a written
report describing the extent of the excess emissions and response actions taken by the facility.
OAC 252:100-13 (Open Burning)
[Applicable]
Open burning of refuse and other combustible material is prohibited except as authorized in the
specific examples and under the conditions listed in this subchapter.
OAC 252:100-19 (Particulate Matter (PM))
[Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with
emission limits based on maximum design heat input rating. Appendix C specifies a PM
emission limitation of 0.60 lbs/MMBTU for all equipment at this facility with a heat input rating
of 10 Million BTU per hour (MMBTUH) or less. Fuel-burning equipment is defined in OAC
252:100-19 as any internal combustion engine or gas turbine, or other combustion device used to
convert the combustion of fuel into usable energy. Thus, the furnaces and preheater are subject
to the requirements of this subchapter.
AP-42 (7/98) Table 1.4-2 lists natural gas total PM emissions to be 7.6 lbs/million scf or about
0.0076 lbs/MMBTU, which is in compliance.
OAC 252:100-25 (Visible Emissions and Particulates)
[Applicable]
No discharge of greater than 20% opacity is allowed except for short-term occurrences which
consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed
three such periods in any consecutive 24 hours. In no case shall the average of any six-minute
period exceed 60% opacity. The permit will require maintenance of the baghouses to maintain
compliance with this limitation.
OAC 252:100-29 (Fugitive Dust)
Applicable]
No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the
property line on which the emissions originated in such a manner as to damage or to interfere
with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere
with the maintenance of air quality standards. Under normal operating conditions, this facility
has negligible potential to violate this requirement; therefore it is not necessary to require specific
precautions to be taken.
OAC 252:100-31 (Sulfur Compounds)
[Applicable]
Part 2 limits the ambient air impact of hydrogen sulfide (H2S) emissions from any existing source
or new source to 0.2 ppm for a 24-hour average (equivalent to 280 g/m3). An analysis of inlet
gas to this facility showed no hydrogen sulfide content.
PERMIT MEMORANDUM 2006-008-O
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Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972).
Fuel-burning equipment at this facility uses commercial natural gas, with the preheater burning
off oil and grease deposits from scrap. The facility uses pipeline quality natural gas which has a
sulfur content less than 343 ppmv, which is below the limit of 0.2 lbs/MMBTU.
OAC 252:100-33 (Nitrogen Oxides)
[Not Applicable]
This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or
equal to 50 MMBTUH to emissions of 0.20 lbs of NOx per MMBTU, three-hour average. There
is no equipment, including space heaters, that exceed the 50 MMBTUH threshold.
OAC 252:100-35 (Carbon Monoxide)
[Not Applicable]
This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum
catalytic cracking units, and petroleum catalytic reforming units. It requires removal of 93% or
more of CO by “complete secondary combustion” from new sources and also from existing
sources located in or significantly impacting a non-attainment area for CO. There are no affected
sources.
OAC 252:100-37 (Volatile Organic Compounds)
[Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system. There are no storage tanks of greater than 400 gallons on the
facility, and existing tanks are not subject.
Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not
normally conduct coating or painting operations except for routine maintenance of the facility
and equipment, which is exempt.
Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC
emissions. Temperature and available air must be sufficient to provide essentially complete
combustion. The Electric Induction Furnaces are designed to provide essentially complete
combustion of organic materials.
OAC 252:100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Not Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties. The facility is
in Nowata County, and is not subject.
OAC 252:100-41 (Hazardous Air Pollutants)
[Not Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted
by reference as they exist on September 1, 2005, with the exception of Subparts B, H, I, K, Q, R,
T, W and Appendices D and E, all of which address radionuclides. In addition, General
Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control
Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, L, M, N, O, Q,
R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS,
TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO,
PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF, GGGG,
HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT,
PERMIT MEMORANDUM 2006-008-O
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UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE,
FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP,
QQQQQ, RRRRR, SSSSS, and TTTTT are hereby adopted by reference as they exist on
September 1, 2005. These standards apply to both existing and new sources of HAP. These
requirements are covered in the “Federal Regulations” section.
Part 5 was a state-only requirement governing sources of toxic air contaminants that had
emissions exceeding a de minimis level. However, Part 5 of Subchapter 41 has been superseded
by OAC 252:100-42, effective June 15, 2006.
OAC 252:100-42 (Toxic Air Contaminants (TAC))
[Applicable]
Part 5 of OAC 252:100-41 was superseded by this subchapter. Any work practice, material
substitution, or control equipment required by the Department prior to June 11, 2004, to control a
TAC, shall be retained unless a modification is approved by the Director. Since no Area of
Concern (AOC) has been designated there are no specific requirements for this facility at this
time.
OAC 252:100-43 (Testing, Monitoring, and Recordkeeping)
[Applicable]
This subchapter provides general requirements for testing, monitoring and recordkeeping and
applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.
To determine compliance with emissions limitations or standards, the Air Quality Director may
require the owner or operator of any source in the state of Oklahoma to install, maintain and
operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant
source. All required testing must be conducted by methods approved by the Air Quality Director
and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol
shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.
Emissions and other data required to demonstrate compliance with any federal or state emission
limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and
submitted as required by this subchapter, an applicable rule, or permit requirement. Data from
any required testing or monitoring not conducted in accordance with the provisions of this
subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive
use, of any credible evidence or information relevant to whether a source would have been in
compliance with applicable requirements if the appropriate performance or compliance test or
procedure had been performed.
The following Oklahoma Air Pollution Control Rules are not applicable to this facility:
OAC 252:100-8
OAC 252:100-11
OAC 252:100-15
OAC 252:100-17
OAC 252:100-23
OAC 252:100-24
OAC 252:100-39
OAC 252:100-47
Major Sources
Alternative Reduction
Mobile Sources
Incinerators
Cotton Gins
Feed & Grain Facility
Nonattainment Areas
Landfills
not in source category
not eligible
not in source category
not type of emission unit
not type of emission unit
not in source category
not in a subject area
not in source category
PERMIT MEMORANDUM 2006-008-O
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SECTION VII. FEDERAL REGULATIONS
PSD, 40 CFR Part 52
[Not Applicable]
PSD does not apply. Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant.
NSPS, 40 CFR Part 60
[Not Applicable]
There are no surface coating subparts that affect this facility. Of the many metallurgical
operations subparts, only Subpart Z for ferroalloy production could possibly apply. The
provisions of this subpart are applicable to the following affected facilities: Electric submerged
arc furnaces (electrical energy is converted to heat energy by transmission of current between
electrodes) which produce silicon metal, ferrosilicon, calcium silicon, silicomanganese
zirconium, ferrochrome silicon, silvery iron, high-carbon ferrochrome, charge chrome, standard
ferromanganese, silicomanganese, ferromanganese silicon, or calcium carbide; and dust-handling
equipment. The furnaces at this facility are electric induction (heat applied by an induction of a
conductive medium) furnaces.
NESHAP, 40 CFR Part 61
[Not Applicable]
There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium,
coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of
benzene. Subpart J (Equipment Leaks of Benzene) concerns only process streams which contain
more than 10% benzene by weight. Analysis of Oklahoma natural gas indicates a maximum
benzene content of less than 1%.
NESHAP, 40 CFR Part 63
[Not Applicable]
The following subparts might affect this facility if it were a major source of HAP, which it isn’t:
EEEEE, “Integrated Iron and Steel Manufacturing”, issued April 22, 2004 and FFFFF, “Iron
Foundries”, issued May 22, 2003.
Chemical Accident Prevention Provisions, 40 CFR Part 68
[Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments). More information on this federal
program is available on the web page: www.epa.gov/ceppo.
Stratospheric Ozone Protection, 40 CFR Part 82
[Applicable]
This facility does not produce, consume, recycle, import, or export any controlled substances or
controlled products as defined in this part, nor does the facility perform service on motor (fleet)
vehicles, which involves ozone-depleting substances. Therefore, as currently operated, this
facility is not subject to these requirements. To the extent that the facility has air-conditioning
units that apply, the permit requires compliance with Part 82.
PERMIT MEMORANDUM 2006-008-O
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SECTION VIII. COMPLIANCE
Inspection
A compliance inspection was conducted on July 6, 2006, by Hal Wright, AQD Permit Writer,
assisted by Alvie Hornburger, Corporate Environmental/Safety Manager, and Gerald Robertson,
Maintenance Manager. The main facility contacts were Alvie Hornburger and Ron Sober,
Professional Engineer for RFS Consulting, Inc. All significant sources were observed. All
equipment was operating. Records of periodic testing or material usage for a recent period of
time were discussed and they were able to be retrieved from computer. All sources and activities
were found to be as listed in this permit. All air pollution control devices were confirmed to be
in place and operational. Baghouse records of purging and products (monthly) usage are being
kept on-site.
Tier Classification and Public Review
This application has been classified as a Tier II based on the request for a Title V operating permit
by a consent order. The basis for this determination is that it is a Consent Order Tier II Title V
Operating permit for an existing synthetic minor source. On March 15, 2006, the permittee
submitted an affidavit that they are not seeking a permit for land use or for any operation upon land
owned by others without their knowledge. The affidavit certifies that the applicant owns the real
property. The applicant will publish a “Notice of Filing a Tier II Application” and along with this a
notice that a draft of the permit would be available for 30 days. These notices will be published at
the same time in a newspaper of general circulation in Nowata County (a Coffeyville, KS
newspaper will be sufficient, if necessary). The notice will state that the application will be
available at a convenient public location in Nowata County, and at the DEQ Air Quality Division’s
regional office in Tulsa, 3105 E. Skelly drive, Suite 200, Tulsa, OK, 74105. The facility is within
50 miles of the Oklahoma border with the state of Kansas. That state will be notified of the draft
permit. Information on all permit actions is available for public review in the Air Quality section of
the DEQ web page: www.deq.state.ok.us.
Fees Paid
Per the consent order, $2,000 was paid for a Title V permit application. This permit will be
converted to a synthetic minor after public and EPA reviews.
SECTION IX.
SUMMARY
This facility was constructed as described in the application. There are no active Air Quality
compliance or enforcement issues that would affect the issuance of this permit. Active Air
Quality enforcement issues existed against the applicant, but have been resolved. Issuance of the
synthetic minor permit is recommended contingent on public and EPA reviews.
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
Jensen International, Inc.
Jencast Ductile and Gray Iron Foundry
Permit No. 2006-008-O
The permittee is authorized to operate in conformity with the specifications submitted to Air
Quality on March 15, 2006, with supplemental information received March 30, May 2 and 8, June
5, 7, and 13, August 22, 23, and 31, October 5, and January 31, February 8, and March 6, 2007.
The Evaluation Memorandum dated March 20, 2007, explains the derivation of applicable permit
requirements and estimates of emissions; however, it does not contain operating limitations or
permit requirements. Continuing operations under this permit constitutes acceptance of, and
consent to, the conditions contained herein:
1.
Points of emissions and emission limitations for each point:
Unit ID
Charging
Melting/
Casting
Seq.
No.
Description
3
3
1A&B
Handling
Preheat
Induction
Furnace
Pour/Cool
Mg
Treatment
Refining
Sand
Handling
Sand
Handling
Sand
Handling
Casting
Shakeout
Casting
Shakeout
Sand
Grind/Mix
Finishing
(shot blast/
Grind
Heat Treat
Porcelain
Heater
4
2
Sand
Handling
System
Cleaning/
Finishing
2
East
West
Spent
Sand
5East
5West
6
8A
Emissions (TPY)
PM10
NOx
CO
VOC
SO2
Lead
2.70
0.23
6.45
8.37
-
1.80
-
0.16
-
8.022
-
0.75
0.15
0.03
-
-
3.29
-
0.15
-
-
0.23
0.45
-
-
0.04
-
-
-
0.45
-
-
-
-
-
45.00
-
-
-
-
-
0.17
-
-
28.23
-
-
0.17
-
-
28.23
-
-
0.01
-
-
-
-
-
0.03
-
-
-
-
-
0.02
0.264
0.222
0.015
0.002
-
SPECIFIC CONDITIONS 2006-008-O
Unit ID
Seq.
No.
Description
8B
Heat Treat
Porcelain
Heater
Core
Making
Core Oven
Cold/Mold
Prep.
7
DRAFT
2
Emissions (TPY)
PM10
NOx
CO
VOC
SO2
Lead
0.02
0.264
0.222
0.015
0.002
-
-
-
-
-
-
-
0.013
0.18
0.15
0.01
0.001
-
Total Facility Emissions
Pollutant
PPH
NOX
4.36
CO
1.15
VOC
15.27
SO2
3.93
PM
26.69
Lead
0.36
TPY
9.07
2.39
31.76
8.18
55.51
0.75
2.
The permittee shall conduct shot blasting, sand removal from casts and sand reclamation
with process discharges vented to 90% efficient reverse pulse jet felt bag, Kice W-528
“Dyna Jet” fabric air filters or equivalent PM emissions control devices. Each baghouse on
the shotblasting and sand reclamation operations shall be purged twice per day.
3.
The permittee shall maintain a vent-type baghouse on the binder silo with the exhaust
routed inside the plant.
4.
Compliance with the limits of Specific Condition #1 shall be demonstrated by the following
raw materials usage and ductile and gray iron production rates.
Raw Materials
Isocure I IM 397 C binder:
Isocure II IM 697 C binder:
Isocure Catalyst 702:
49
39
21
TPY
TPY
TPY
Gray and Ductile Production
4.2 TPH
15,000 TPY
5.
Alternative binders, different from the products listed in Specific Condition No. 4, may be
used, but shall not exceed the emission levels of Specific Condition No. 1.
6.
The fuel-burning equipment shall be fired with pipeline-grade natural gas, or other gaseous
fuel with sulfur content less than 343 ppmv. Compliance can be shown by the following
methods: for pipeline-grade natural gas, a current gas company bill; for other gaseous fuel,
a current lab analysis, gas contract, tariff sheet, stain tube analysis, etc.
SPECIFIC CONDITIONS 2006-008-O
7.
3
The following records shall be maintained on-site. All such records shall be made available
to regulatory personnel upon request. These records shall be maintained for a period of at
least five years after the time they are made.
a)
b)
c)
d)
e)
8.
DRAFT
Monthly and 12-month rolling total summaries of the quantity of the usage of each
raw material listed in Specific Condition No. 4 by weight.
Monthly and 12-month rolling total summaries of the quantity of melt.
Weight of each alternative raw material used (if applicable).
Records of baghouse purging.
For the fuel(s) burned, the appropriate document(s) as described in Specific
Condition 6.
This permit shall supersede all other Air Quality permits for this facility, which are null and
void.
Ron Sober
RFS Consulting, Inc.
P.O. Box 470947
Tulsa, OK 74147-0947
Subject:
Operating Permit No. 2006-008-O
Jencast Ductile and Gray Iron Foundry
South Coffeyville, Nowata County, Oklahoma
Dear Mr. Sober:
Air Quality Division has completed the initial review of your permit application referenced above. This
application has been determined to be a Tier II. In accordance with 27A O.S. § 2-14-302 and OAC
252:002-4-7-13(c), the enclosed draft permit, along with the application, are now ready for public review.
The requirements for public review include the following steps that you must accomplish:
1. Publish at least one legal notice (one day) in at least one newspaper of general circulation within the
county where the facility is located. A Coffeyville, KS paper is sufficient if this is applicable.
(Instructions enclosed)
2. Provide for public review (for a period of 30 days following the date of the newspaper
announcement) a copy of this draft permit and a copy of the application at a convenient location within
the county of the facility.
3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any
additional comments or requested changes that you may have on the draft permit.
Thank you for your cooperation. If we may be of further service, please contact me at (918) 293-1613 or
by mail at DEQ Regional Office at Tulsa, 3105 East Skelly Drive, Suite 200, Tulsa, Oklahoma, 74105.
Sincerely,
Hal Wright
Regional Office at Tulsa
AIR QUALITY DIVISION
Enclosure:
Copy of Draft Permit No. 2006-008-O
Kansas Department of Health and Environment
Bureau of Air and Radiation
Forbes Field, Building 283
Topeka, KS 66620-0001
SUBJECT:
Permit Number: 2006-008-O
Facility: Jencast Ductile and Gray Iron Foundry
Location: South Coffeyville, OK
Permit Writer: Hal Wright
Dear Sir/Madame:
The subject facility has requested a Synthetic Minor operating permit following a Tier II review.
This is treated as a Title V permit, but will be issued as a synthetic minor. Air Quality Division
has completed the initial review of the application and prepared a draft permit for public review.
Since this facility is within 50 miles of the Oklahoma-Kansas border, a copy of the draft permit
will be provided to you upon request. Information on all permits and a copy of this draft permit
are also posted in the Air Quality Section of the DEQ Web Page: http://www.deq.state.ok.us
Thank you for your cooperation. If you have any questions, please refer to the permit number
above and contact me at (405) 702-4100, or the permit writer at (918) 293-1600.
Sincerely,
Dawson Lasseter, P.E., Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(September 1, 2005)
A. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act. The permit does not relieve the holder of the obligation to comply
with other applicable federal, state, or local statutes, regulations, rules, or ordinances. This
specifically includes compliance with the rules of the other Divisions of DEQ: Land Protection
Division and Water Quality Division.
B. A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252:100-7-15(g)) if the construction
is not commenced within 18 months after the date the permit or authorization was issued, or if
work is suspended for more than 18 months after it is commenced.
[OAC 252:100-7-15(f)]
C. The recipient of a construction permit shall apply for a permit to operate (or modified
operating permit) within 60 days following the first day of operation.
[OAC 252:100-7-18(a)]
D. Unless specified otherwise, the term of an operating permit shall be unlimited.
E. Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 10 days after such date.
A new permit is not required.
[OAC 252:100-7-2(f)]
F.
The following limitations apply to the facility unless covered in the Specific Conditions:
1. No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility.
[OAC 252:100-3]
2. All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory. Instructions and forms are available on the Air
Quality section of the DEQ web page. www.deq.state.ok.us
[OAC 252:100-5]
3. All excess emissions shall be reported to the Director of the Air Quality Division as soon as
practical during normal office hours and no later than the next working day following the
malfunction or release. Within ten (10) business days further notice shall be tendered in
writing containing specific details of the incident.
[OAC 252:100-9]
4. Open burning of refuse and other combustible material is prohibited except as authorized in
the specific examples and under the conditions listed in the Open Burning subchapter.
[OAC 252:100-13]
5. No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 0.6 lbs/MMBTU.
[OAC 252:100-19]
6. No discharge of greater than 20% opacity is allowed except for short-term occurrences,
which consist of not more than one six-minute period in any consecutive 60 minutes, not to
exceed three such periods in any consecutive 24 hours. In no case shall the average of any
six-minute period exceed 60% opacity.
[OAC 252:100-25]
MINOR SOURCE STANDARD CONDITIONS
September 1, 2005
2
7. No visible fugitive dust emissions shall be discharged beyond the property line on which the
emissions originate in such a manner as to damage or to interfere with the use of adjacent
properties, or cause air quality standards to be exceeded, or interfere with the maintenance of
air quality standards.
[OAC 252:100-29]
8. No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2
lbs/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur
dioxide.
[OAC 252:100-31]
9. Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and with a
capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system.
[OAC 252:100-37-15(b)]
10. All fuel-burning equipment shall at all times be properly operated and maintained in a
manner that will minimize emissions of VOCs.
[OAC 252:100-37-36]
G. Any owner or operator subject to provisions of NSPS shall provide written notification as
follows:
[40 CFR 60.7 (a)]
1. A notification of the date construction (or reconstruction as defined under §60.15) of an
affected facility is commenced postmarked no later than 30 days after such date. This requirement
shall not apply in the case of mass-produced facilities which are purchased in completed form.
2. A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies, unless that change is
specifically exempted under an applicable subpart or in §60.14(e). This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall include
information describing the precise nature of the change, present and proposed emission control
systems, productive capacity of the facility before and after the change, and the expected
completion date of the change. The Administrator may request additional relevant information
subsequent to this notice.
3. A notification of the actual date of initial start-up of an affected facility postmarked within 15
days after such date.
4. If a continuous emission monitoring system is included in the construction, a notification of
the date upon which the test demonstrating the system performance will commence, along with a
pretest plan, postmarked no less than 30 days prior to such a date.
H. Any owner or operator subject to provisions of NSPS shall maintain records of the
occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected
facility or any malfunction of the air pollution control equipment.
[40 CFR 60.7 (b)]
I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file
suitable for inspection. This file shall be retained for at least five years following the date of
such measurements, maintenance, and records.
[40 CFR 60.7 (d)]
J. Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s). Test(s) shall be conducted
within 60 days after achieving the maximum production rate at which the facility will be
operated, but not later than 180 days after initial start-up.
[40 CFR 60.8]