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The Moore Company (Fulflex Division) #AOP-12-036

0.5VERMONT AGENCY OF NATURAL RESOURCESDepartment of Environmental Conservation

Air Pollution Control Division

TECHNICAL ANALYSIS OF AN AIR CONTAMINANT SOURCEFOR A PERMIT TO CONSTRUCT AND OPERATE

#AOP-12-036DEC PIN# NS88-0017

April 30, 2013

Prepared By: Tony Mathis. Environmental Engineer

OWNER: The Moore Company (Fulflex Division)32 Justin Holden DriveBrattleboro, VT 05301

OPERATOR: The Moore Company (Fulflex Division)32 Justin Holden DriveBrattleboro, VT 05301

SOURCE: Rubber Processing & Manufacturing FacilityThe Moore Company (Fulflex Division)32 Justin Holden DriveBrattleboro, VT 05301

CONTACTS: Mr. Paul GreeenleafPlant EngineerTel: (802) 257-5256 ext 151Fax: (802) 257-5602

COUNTY: Windham

AREA DESIGNATION: Attainment for PM10, SO2, NO2, CO, & PbUnclassified for ozone

UTM COORDINATES: 699750 m E, 4750850 m N, Zone 18 (Center of Manufacturing Building)

This Technical Support Document by the Agency of Natural Resources, Department of Environmental Conservation, Air Pollution Control Division (hereinafter “Agency”) is intended to provide additional technical information, discussion and clarification in support of the Permit. It is not intended to provide a comprehensive review of the Facility or the permit process or to duplicate the information contained in the Permit or elsewhere.

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1.0 INTRODUCTION

The Moore Company, Fulflex Division (also referred to as “Permittee”) operates a rubber processing and rubber products manufacturing facility located on Justin Holden Drive in Brattleboro, Vermont (also referred to as “Facility”). The Facility was formerly known as Fulflex of Vermont, Inc.

This permit review includes the Permit to Operate Renewal and the Permit to Construct for the addition of compressed natural gas (CNG) as an additional fuel type at the Facility, and for operational changes to the Facility to reflect its current configuration. The previous permit (#AOP-09-024) formalized the previous letter approval for the relocation of three manufacturing processes from the Permittee’s Tennessee plant. However, these processes either were not installed at the Facility, or were installed and removed. These processes are summarized as follows:

The Curtin-Hebert Flexo Rubber Grinding Operation that was to be equipped with an internally vented Torit cartridge particulate control device. This process was never installed at the Facility.

The Solvent Based Adhesive Application for metal Back Product which planned to utilize a trichloroethylene (TCE) free adhesive instead of the more traditional TCE product for this process. This process was never installed at the Facility.

The Extruded Film (TPE) Process. The TPE Process was installed in a limited capacity at the Facility in 2009, and was removed in November of 2011.

The Permittee was served with a Notice of Violation (NOV) and Administrative Order (AO) on April 2, 2012 for alleged violations of Conditions 2, 12, 23, and 26 of #AOP-09-024. The NOV also identified violations portions of the federal Protection of Stratospheric Ozone Regulations found at 40 CFR Part 82, Subpart F (Subpart F)

The alleged violations of #AOP-09-024 were related to the following:

Failure to operate control devices as required by Condition 2. Failure to comply with the particulate emissions required by Condition 12. Stack

test results from dust collector D/C-6 were 0.18 lb/hour compared to the permit limitation of 0.093 lb/hr

Failure to maintain adequate records of the hours of outdoor discharge of each dust collector, as required by Condition 23.

Failure to maintain adequate records of the amount of plastic extruded through the Extruded Film Process, and required by Condition 26.

Failure to comply with the record-keeping provisions of Subpart F, as the Facility had a refrigeration units that contained greater than 50 pounds of R-22, which is defined as an ozone depleting substance.

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Administrative Milestones

Table 1-1: Administrative SummaryAdministrative Item Result or DateDate Application Received: 08/08/2011

Date Administratively Complete: 08/17/2012

Date Technically Complete: 10/22/2012

Date Proposed Decision:: 04/30/2013

Date & Location Draft Decision/Comment Period Noticed: 04/__/2013Environmental, Notice Bulletin

Date & Location Public Meeting Noticed: Not Required

Date & Location of Public Meeting: Not Required

Deadline for Public Comments: 04/10/2013

Classification of Source Under §5-401:

§5-401(6)(a) [Fossil fuel-burning equipment],§5-401(11) [Manufacturing, processing and application of chemicals, including the processing or application of plastics, rubbers or resins]

Classification of Application: Minor modification / Renewal

New Source Review Designation of Source: Subchapter X Major Stationary Source

Facility SIC/NAIC Code(s): 3069 / 326299

Facility SIC/NAIC Code Description(s): Fabricated Rubber Products, Not Elsewhere Classified

Table 1-2: Future Allowable Air Contaminant Emissions (tons/year)1

PM/PM10 SO2 NOx CO VOCs Total Criteria HAPs

15 40.8 9.5 0.7 12.0 >10 <10/25

1 PM/PM10 - particulate matter and particulate matter of 10 micrometers in size or smaller; SO2 - sulfur dioxide; NOx - oxides of nitrogen measured as NO2 equivalent; CO - carbon monoxide; VOCs - volatile organic compounds; HAPs - hazardous air pollutants as defined in §112 of the federal Clean Air Act.

2.0 FACILITY DESCRIPTION

2.1 Facility Locations and Surrounding Area

The Facility is located approximately 2.3 miles north of downtown Brattleboro. The area surrounding the Facility is primarily commercial and industrial. Areas north of the Facility are primarily industrial, and the Facility is bounded on the east by the Connecticut River. Commercial properties are located to the south and west of the Facility. Interstate 91 is

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located approximately 0.2 miles to the west of the Facility.

2.2 Facility Description

The rubber processing and manufacturing operations at the Facility are listed under the Standard Industrial Classification (“SIC”) 3069 (Fabricated Rubber Products, Not Elsewhere Classified), and under the North American Industrial Classification System Codes 326299 (Fabricated Rubber Products, Not Elsewhere Classified).

Process and space heating at the Facility is provided by two Cleaver-Brooks boilers, installed in 1966 and 1979 that are currently fired with No. 6 fuel oil. The Permittee has proposed to convert these boilers to a dual-fuel configuration so they may be fired with either No. 6 fuel oil or CNG.

The Facility is primarily engaged in the manufacturing and distribution of rubber threads for use in a variety of consumer applications and is designed to operate twenty-four (24) hours per day. From the Fulfex website: “Founded in 1932, Fulflex is the world's leading manufacturer of thin-gauge calendered and extruded elastic products. Fulflex manufactures natural and synthetic rubber and elastic tapes, threads, sheets and rings for personnel care products including baby diapers and adult incontinent products, a diverse range of consumer products from golf balls to toys, a wide range of textile apparel products and medical and healthcare products including tourniquets, bandages, athletic and therapy bands, and disposable protective clothing. Fulflex products are so versatile they are used almost anywhere there is a need for an elastic product.”

The Facility processes natural and synthetic rubbers into fully cured rubber products which are then manufactured into final products. Several different rubber compounds are used at the Facility including compounds #3 and #22. The operations can be split into two separate processes: (1) the processing of the raw, uncured rubber products through the final curing stage called rubber manufacturing and (2) the processing of those cured rubber products into other products called rubber products manufacturing.

Rubber manufacturing: The processing of the raw rubber begins with mixing raw natural or synthetic rubber with additives to form the desired compound. A Banbury mixer with a capacity of 500 pounds per batch and capable of mixing 150 batches per day is used to mix the product. The Banbury mixer uses counter rotating mixers to shear the product, and blend it with fillers and additives. Dust emissions from mixing are controlled by a Torit cartridge dust collector, while the mixing machines are cooled with a water jacket. Fluid in the water jacket is chilled with a refrigeration system at the Facility. Mixed product may be processed into finished products at the Facility, or sent to other facilities for final processing. Current annual mixing capacity at the Facility is estimated at 20 million pounds of mixed rubber material.

Following mixing, the still raw products undergo milling. Milling is used to add vulcanizing compounds to the rubber, homogenize recycled rubber compounds for reuse in the process and to heat the rubber for ease of handling and processing. The milled rubber is formed into sheets or strips for introduction into calenders or extruders. Following milling the rubber may be extruded or calendered. Extruding involves forcing

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the rubber compound through a die to form the desired shape, such as threads or sheets. Extruding may also be used to blend several different types of rubbers together. Calendering may be used instead of extruding to press the raw rubber product into a web of cloth fabric or metal mesh or similar reinforcing material. Finally the extruded or calendered raw rubber product is cured, or vulcanized, in a hot air oven.

Rubber products manufacturing: The final vulcanized rubber is then formed into other products through cutting, slitting, splicing and packing. These operations generate small amounts of dust from talc powder used to keep the rubber products from sticking. Equipment at the Facility is summarized in the following tables.

Table 2-1 Equipment Specifications – Oil-Fired Equipment

Equipment/Make/Model capacity/sizeMMBTU/hr (hp) fuel type date of manufacture

(installation)

Cleaver Brooks Model # CB600-300 oil / CNG-fired boiler

10.5 MMBtu/ hr 1

(250 HP) 2No. 6 Fuel Oil / CNG 19793

Cleaver Brooks Model # CB655-250 oil / CNG-fired boiler

10.5 MMBtu/ hr 1

((250 HP) 2No. 6 Fuel Oil / CNG 1966

1 MMBtu/hr - Million British Thermal Units per hour maximum rated heat input. 2 H.P. – Boiler horsepower rated output; 3 The CB600-300 boiler was originally rated at 12.6 MMBtu/300 HP, but was derated to 10.5 MMBtu as noted in the

Agency compliance inspection performed on 11 March, 2010. This compliance inspection report is dated 14 September, 2010.

Table 2-2: Equipment Specifications – Processing and Manufacturing Equipment

Process Collector Number Make/Model No. Air Flow

(acfm1)Air/Cloth

RatioStated

Efficiency

Extruding and Milling D/C-4 Torit Cartridge Filter #3D-24 10,800 1.8:1 99.9%

Menzel #1 Hood and Floor Pits D/C-6 Torit Cartridge Filter

DFT 3-36 15,400 1.6:1 99.9%

Banbury Mixer D/C11 Torit Cartridge Filter DFT 3-36 10,800 1.8:1 99.9%

Calendering D/C-5 Torit Cartridge Filter #3D/36 11,400 1.3:1 99.9%

Menzel #2 Hood and Floor Pits D/C-7 Torit Cartridge Filter

4DF-32 10,800 1.3:1 99.9%

Rubber Slitting (Front Line) D/C-8 Torit Cartridge Filter

TD2300 10,800 1.9:1 99.9%

Rubber Slitting (Back Line) D/C-9 Torit Cartridge Filter

TD2300 10,800 1.9:1 99.9%

Compounding D/C-13 Torit Cartridge Filter 2DF 12 4,800 1.6:1 99.9%

1 acfm – Air flow in cubic feet per minute relative to pressure, temperature and moisture conditions at the flow inlet.

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Equipment Listing – Insignificant Sources

Source Date Installed Stack Number Control Device

Industrial Chiller #1 and #2 NR1 Fugitive None

Splicing/Adhesive Application NR1 N/A None

Two (2) Cooling Towers NR1 N/A None

Underground Fuel Oil Storage Tank (capacity for storage of 20,000 gallons of fuel oil) 1997 N/A None

Laboratory Activities NR1 N/A None

Maintenance / Shop Activities NR1 Fugitive None

Solvent Metal Cleaning Unit / Graymills Handi Kleen Washer

NR1 Fugitive None

Knife Sharpening NR1 Fugitive None

1 NR– Not Reported

3.0 QUANTIFICATION OF POLLUTANTS

The quantification of emissions from a stationary source is necessary in order to establish the appropriate regulatory review process for the operating permit application and to determine applicability with various air pollution control requirements. These determinations are normally based upon allowable emissions. Allowable emission is defined as the emission rate calculated using the maximum rated capacity of the source and, if applicable, either: (a) the applicable emission standard contained in the Regulations, if any, or (b) the emission rate or design, operational or equipment standard specified in any order or agreement issued under the Regulations that is state and federally enforceable. An applicant may impose in its application an emission rate or design, or an operational or equipment limitation which may be incorporated in the Permit to restrict operation to a lower level. Such limitations may include fuel restrictions or production limits

Facility emissions can be separated as follows:

(1) Fuel combustion emissions from the two (2) boilers which provide space and process heat, and may be fired using either No. 6 fuel oil or CNG,

(2) Particulate emissions from dust collection equipment, comprised primarily of talc used to keep the rubber from sticking but also including processing dust from mixing materials and grinding, and;

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(3) Volatile organic compound (VOC), hazardous air pollutants (HAPs) and hazardous air contaminants (HACs) emissions from rubber mixing and processing, and from solvents used in cleaning and for the manufacturing of finished rubber products.

The estimation of potential to emit and allowable emissions of particulate matter (PM/PM10), sulfur dioxide (SO2), oxides of nitrogen (NOx), carbon monoxide (CO), volatile organic compounds (VOCs), hazardous air pollutants (HAPs) and hazardous air contaminants (HACs) from the these sources are described below.

3.1 Fuel Combustion Emissions:

Boilers Firing No. 6 Fuel Oil - Permittee has previously proposed to limit the fuel consumption of the two (2) Cleaver Brookes boilers to less than 260,000 gallons per year of No. 6 oil, with a sulfur content by weight not to exceed 2.0 percent. Combustion emissions were estimated using these limitations and emission factors published by the U.S. EPA in the Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources (5th Edition including Supplements A, B and C), AP-42, Office of Air Quality Planning and Standards, Chapter 1, External Combustions Sources, Section 1.3 – Fuel Oil Combustion, Tables 1.3-1, 1.3-3, and 1.3-4 (September 1999, corrected May 2010). Estimated emissions for combustion equipment and emission factors used for these estimates are shown in Table 3.1. Estimates were performed using a spreadsheet named caop12036.xlsx.

Table 3-1: Allowable Emissions - Boilers Firing No. 6 Fuel OilTotal Combined Fuel Input for Both Boilers: 260,000 gallons/yr No.6 Fuel Oil with 2% sulfur content

PollutantEmission Factor Allowable

Emissions (tons/year)Factor Units Source

PM 0.49 1 lb/MMBtu 2 §5-231(3 ) of the Regulations 9.6

SO2 157S 3 lb/1,000 gallons4 AP-42, Fuel Oil Combustion, Table 1.3-1, Footnote b. (September 1999) 40.8

NOx 72.74 5 lb/1,000 gallons4 AP-42, Fuel Oil Combustion, Table 1.3-1, Footnote d. (September 1999) 9.5

CO 5.0 lb/1,000 gallons4 AP-42, Fuel Oil Combustion, Table 1.3-1 (September 1999) 0.7

VOC 0.28 lb/1,000 gallons4 AP-42, Fuel Oil Combustion, Table 1.3-3 (September 1999) 0.04

HAPs 0.155 lb/1,000 gallons4 AP-42, Fuel Oil Combustion, Tables 1.3-8 to 1.3-10 (September 1999) 0.02

1 The PM emission factor is based on the regulatory requirements of §5-231(3) of the Regulations, which limit PM emissions for the 10.5 MMBtu boilers to 0.49 lb/MMBtu.

2 lb/MMBtu: pounds of pollutant emitted per 1 million British Thermal untis of heat input to the boiler3 S represents the weight % of sulfur in the oil. For example if the fuel is 2.0% sulfur, then S=2.04 lb/1000 gal: pounds of pollutant emitted per 1000 gallons of fuel input to the boiler.5 The NOx emission factor is based on the following empirical relationship: lb NO2/103 gal = 20.54 + 104.39(N), where N

is the weight % of nitrogen in the oil. The above factor assumes a weight % of 0.5.

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Boilers Firing CNG - The Permittee has proposed to fire the two (2) Cleaver Brookes boilers with CNG, as a full or partial replacement for No. 6 fuel oil. Accordingly, the maximum heat input of 260,000 gallons per year of No. 6 oil, was estimated to be 39,000 MMBtu, assuming a high heat value (HHV) for No. 6 oil of 150,000 Btu/gallon. This heat input is equivalent to 38.24 MMcf of CNG, assuming a HHV for CNG of 1,020 btu/cf.

Combustion emissions were estimated using these limitations and emission factors used for this estimate were those published by the U.S. EPA in the Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources (5th Edition including Supplements A, B and C), AP-42, Office of Air Quality Planning and Standards, Chapter 1, External Combustions Sources, Section 1.4 – Natural Gas Combustion, (July 1998). Estimated emissions for combustion equipment and emission factors used for these estimates are shown in Table 3.1. Estimates were performed using a spreadsheet named caop12036.xlsx.

Table 3-2: Allowable Emissions Boilers Firing CNGTotal Combined Fuel Input for Both Boilers 38.24 MMcf of CNG

PollutantEmission Factor Allowable

Emissions (tons/yearFactor Units 1,2 Source

SO2 0.6 lb/MMCF AP-42, Natural Gas Combustion, Table 1.4-2 (7/98) 0.01

NOx 100 lb/MMCF AP-42, Natural Gas Combustion, Table 1.4-1 (7/98) 1.9

PM 0.49 3 lb/MMBtu 2 §5-231(3 ) of the Regulations 9.6

CO 84 lb/MMCF AP-42, Natural Gas Combustion, Table 1.4-1 (7/98) 1.6

VOC 5.5 lb/MMCF AP-42, Natural Gas Combustion, Table 1.4-2 (7/98) 0.01

HAPs 1.89 lb/MMCF AP-42, Natural Gas Combustion, Tables 1.4-3 and 14-4 (7/98) 0.11

1 lb/MMBtu: pounds of pollutant emitted per 1 million British Thermal untis of heat input to the boiler2 lb/MMCF: pounds of pollutant emitted per million standard cubic feet of gas combusted.3 The PM emission factor is based on the regulatory requirements of §5-231(3) of the Regulations, which limit PM

emissions for the 10.5 MMBtu boilers to 0.49 lb/MMBtu.

3.2 Particulate Emissions from Dust Collectors

Particulate emissions from dust collectors were estimated based on discharges at the permit limits proposed by the Permittee, and for the permitted number of hours of outside discharge of each dust collector. The Permittee had proposed hour limitations on the discharge of the dust collectors to the ambient air. However, based on the particulate emissions rates from these dust collectors, there was no need to incorporate this limitation into the permit. Accordingly, emissions for dust collectors D/C-4, D/C-6,

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and D/C-11 were estimated as operating at 8,760 hours per year.

For purposes of establishing the permit limits and in the absence of temperature and humidity information for air handled by the dust collectors, it was assumed that the actual airflow in cubic feet per minute was equal to the airflow in dry standard cubic feet per minute. Estimates were performed using a spreadsheet named caop12036.xlsx

Table 3-3 - Particulate Matter Emission Limitations

Source

Dust Collector

NoAir Flow (acfm1)

Annual Hours of

Discharge to Ambient

Air

Emission Limitations

gr/dscf 2 lbs/hour3 tons/yr

Extruding and Milling D/C-4 10,800 8,760 0.002 0.19 0.81

Menzel #1 Hood and Floor Pits D/C-6 15,400 8,760 0.001 0.13 0.58

Banbury Mixer D/C11 10,800 8,760 0.01 0.93 4.05

Calendering D/C-54 11,400 0 0.017 1.66 -

Menzel #2 Hood and Floor Pits D/C-74 10,800 0 0.001 0.093 -

Rubber Slitting (Front Line) D/C-84 10,800 0 0.001 0.093 -

Rubber Slitting (Back Line) D/C-94 10,800 0 0.001 0.093 -

Compounding D/C-134 4,800 0 0.002 0.082 -

Total Particulate Matter Emissions 5.44

1 acfm – Air flow in cubic feet per minute relative to pressure, temperature and moisture conditions at the flow inlet.2 gr/dscf equals grains of pollutant emitted per dry standard cubic foot of undiluted exhaust gas, corrected to 12% carbon

dioxide.3 lbs/hour equals pounds of pollutant emitted per hour.4 Dust collector is vented internally to the building at the Facility, and does not discharge to the ambient air.

3.3 VOC and Hazardous Air Pollutants (HAPs) / Hazardous Air Contaminants (HACs) Emissions from Rubber Mixing and Processing:

Emissions of VOCs and HAPs/HACs from the rubber manufacturing operations occur at the mixer as raw natural and synthetic rubber chemicals are combined with other chemicals and additives and mixed. Emissions of these same contaminants also continue to occur as the mixed rubber is milled (worked to uniform product), extruded into shape, calendered (pressed into fabrics etc for strength and other uses), and finally vulcanized in hot air ovens. There may also be VOC and HAP emissions in later processing operations after the vulcanizing such as grinding and use of solvent adhesives to bind the rubber product to itself or other products.

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Emissions from the rubber manufacturing operations were previously estimated using a combination of emission factors developed by the Permittee from on-site testing and the Rubber Manufacturer’s Association. The U.S. EPA has since published emission factors in Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources (5th Edition including Supplements A, B and C), AP-42, Office of Air Quality Planning and Standards, Chapter 4, Evaporation Loss Sources, Section 4.12 – Manufacture of Rubber Products (Draft November 2008). (AP-42, Section 4.12). The emissions were based on the greatest emission rate shown for any rubber compound in AP-42. This differs from the previous estimates which were generally based on emissions from manufacturing operations with rubber Compound 3 and rubber Compound 12. Previous emission estimates for certain manufacturing processes were retained where appropriate. Estimates were performed using a spreadsheet named caop12036.xlsx.

Emissions from solvent adhesives and cleaning compounds were estimated based on products usage rates provided in the 2011 annual registration. Maximum usage rates were presented in the 2011 annual registration for an annual production rate of 18,500,000 pounds of rubber products. These usage rates were proportionally adjusted upwards to a maximum potential production rate of 20,000,000 pounds of rubber. The solvent adhesive known as No. 4 cement contains petroleum distillates, hexane and toluene, and denatured ethyl alcohol (ethanol) is used as a cleaning solvent. The maximum estimated usage rate for No. 4 cement is 10 gallons/month, and the maximum estimated usage rate for ethanol is 16.2 gallons month. For both of these chemicals, it was assumed that the entire amount of solvent was emitted to the atmosphere.

Potential emissions of VOCs and total HAPs for the mixer, milling, extruding, and calendering processes are based on a maximum potential of 20,000,000 pounds of rubbers/plastics processed per year and AP-42 emission factors. Potential emissions of VOCs and total HAPs for the curing operations were based on a maximum potential of 20,000,000 pounds of rubber and emission factors developed by the Permittee from on-site testing.

The typical production rate for the Facility is less than 20,000,000 pounds per year. In 2008, the actual quantity of rubbers/plastics processed was 9,414,492 pounds in the mixing operations and 4,528,285 pounds in other operations. The difference is the result of some mixed rubber material being shipped to the Permittee’s Tennessee facility.

Table 3-4 Allowable VOC and HAP Emissions from Manufacturing Processes (ton/yr)

Activity VOC HAPMixing 1.36 0.59Milling 1.13 0.21Extruding 0.08 0.09Calendering 0.56 0.13Hot Air Curing 1.97 1.97Solvent Adhesives and Cleaning Compounds 1.01 0.84

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Emissions of individual HACs were estimated for manufacturing processes at the Facility using a combination of emission factors developed by the Permittee from on-site testing and from AP-42, Section 4.12 for a 20,000,000 pound per year production rate. The total individual HAC emissions were then compared against the emissions criteria for HACs contained in Appendix C of the Regulations. Category I & 2 contaminant emission rates were based on unrestricted annual operating hours of 8,760 hours/year. These estimates and the comparisons are shown in the following table. Estimated emissions that exceed the Appendix C Action Levels are indicated by highlighting and bold text.

Table 3-5 Estimated Individual HAC/HAP Emissions (from Manufacturing Processes)

Chemical Name CAS # HAC Category

Estimated Annual

Emissions (lbs/year)

Estimated Emission

Rate (lb/8-hrs)

Appendix C Action

Level (lb/8-hrs)

Percent of Action

Level

Exceeds Appendix C Action Level?

Total VOC --- 21,810 --- --- ---

Total Speciated Organics --- 19,621 --- --- ---Total Organic HAPs --- 13,476 --- --- ---Total Metal HAPs --- 19 --- --- ---

Total HAPs --- 13,

495 --- --- ---Total Particulate Matter --- 18,501 --- --- ---1,1,1-Trichloroethane 71-55-6 2 40 0.0368 83 0.04% No

1,2-Dichloroethane 107-06-2 1 4.10 0.0037 0.0032 117% Yes1,1-Dichloroethylene 75-35-4 1 12 0.0113 1.7 0.66% No

1,3-Butadiene 106-99-0 1 19.47 0.0178 0.0027 658% Yes1,4-Dichlorobenzene 106-37-6 2

2,4-Dinitrophenol 51-28-5 0

1,4-Dioxane 123-91-1 1 3 0.0031 0.027 11.3% No

2-Butanone 78-93-3 2 167 0.1526 415 0.04% No

2-Chloroacetophenone 532-27-4 0

2-Methylphenol 95-48-7 80

4-Aminobiphenyl 92-67-1 3

4-Methyl-2-Pentanone 108-10-1 2 919 0.8395 249 0.34% No

4-Nitrobiphenyl 92-93-3 13

4-Nitrophenol 100-02-7 0

Acetaldehyde 75-07-0 1 14 0.0127 0.038 33.4% No

Acetaldehyde + Isobutane 12

Acetonitrile 75-05-8 2 14 0.0125 5.0 0.25% No

Acetophenone 98-86-2 4,487

Acrolein 107-02-8 2 211.0 0.1927 0.002 9,636% YesAcrylonitrile 107-13-1 1 237.3 0.2167 0.0012 18,062% YesAniline 62-53-3 1 146.5 0.1338 0.051 262% YesBenzene 71-43-2 1 22.3 0.0204 0.011 185% Yes

Benzidine 92-87-5 1 0.61 0.00060.000001

2 46,545% Yes

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Estimated Annual


Estimated Emission

Rate (lb/8-hrs)

Appendix C Action

Level (lb/8-hrs)

Percent of Action

Level


Biphenyl 92-52-4 1 81.9 0.0748 0.00015 49,860% Yesbis(2-Ethylhexyl)phthalate 117-81-7 72

Bromoform 75-25-2 1 6 0.0051 0.074 6.87% No

Bromomethane 74-83-9 2 1 0.0010 0.4 0.26% No

Cadmium (Cd) Compounds1 1 0 0 0.000046 0% No

Carbon Disulfide 75-15-0 2 2,120 1.9362 54.5 3.55% No

Carbon Tetrachloride 56-23-5 1 936.0 0.8548 0.0055 15,542% YesCarbonyl Sulfide 463-58-1 467

Chloroethane 75-00-3 52

Chloroform 67-66-3 1 13.8 0.0126 0.0036 349.5% YesChloromethane 74-87-3 2 22 0.0200 7.5 0.27% No

Chromium (Cr) Compounds 2 8 0.0069 0.01 6992% No

Cobalt (Co) Compounds 1 0 0.0003 0.00083 41.8% No

Cumene 98-82-8 2 134 0.1221 33.2 0.37% No

Di-n-butylphthalate 84-74-2 2 170 0.1550 0.25 62.0% No

Dibenzofuran 132-64-9 67

Dimethylaminoazobenzene 60-11-7 0

Dimethylphthalate 131-11-3 2 2 0.0017 9.9 0.02% No

Ethyl Acrylate 140-88-5 95

Ethylbenzene 100-41-4 1 100 0.0912 8.30 1.10% No

Hexachlorobutadiene 87-68-3 1 3 0.0031 0.0037 85.1% No

Hexachloroethane 67-72-1 1 24.6 0.0225 0.021 107.1% YesHexane 110-54-3 2 2,471 2.2563 581 0.39% No

Hydroquinone 123-31-9 1 526.5 0.4809 0.00083 57936% YesIsooctane 540-84-1 120

Isophorone 78-59-1 1 242 0.2211 5.87 3.77% No

Lead (Pb) Compounds 1 0 0.0004 0.00083 44.60% No

m-Xylene + p-Xylene 2 318 0.2904 8.30 3.5% No

Methylene Chloride 75-09-2 1 1,082.4 0.9885 0.17 581.4% YesN,N-Dimethylaniline 121-69-7 0

N-Nitrosodimethylamine 86-30-6 0

Naphthalene 91-20-3 1 120.0 0.1096 0.02 547.8% YesNickel (Ni) Compounds 1 11.72 0.0107 0.00017 6,294% YesNitrobenzene 98-95-3 1 0 0.0004 0.012 3.07% No

o-Toluidine 95-53-4 1 7.46 0.0068 0.0012 567.4% Yeso-Xylene 95-47-6 2 1,160 1.0592 8.30 12.76% No

Pentachlorophenol 87-86-5 1 0 0.0002 0.0024 9.52% No

Phenol 108-95-2 2 542 0.4953 5.3 9.34% No

Propanal 123-38-6 67

Propylene Oxide 75-56-9 1 174.4 0.1592 0.022 723.8% YesStyrene 100-42-5 1 156 0.1421 8.30 1.71% No

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Estimated Annual


Estimated Emission

Rate (lb/8-hrs)

Appendix C Action

Level (lb/8-hrs)

Percent of Action

Level


t-Butyl Methyl Ether1634-04-

4 160

Tetrachloroethylene 127-18-4 1 87.1 0.0795 0.015 530.2% YesToluene 108-88-3 2 733 0.6692 24.9 2.69% No

Trichloroethylene 79-01-6 1 11 0.0101 0.04 25.2% No

Vinyl Acetate 108-05-4 1 47 0.0428 1.7 2.5% No

Vinyl Chloride 75-01-4 1 1 0.0008 0.0091 9.2% No

1 The Permittee indicated in the application for AOP-09-024 that Cadmium was not used at the Facility.

The estimated emissions of HAC/HAP compounds that exceed the Action Levels and their associated emission factors for each manufacturing process are summarized in Table 3.6, as follows:

Table 3-6 Emission Factors for HAC/HAP CompoundsEstimated to Exceed Appendix C Action Levels

Chemical Name CAS #

Emission Factor(lbs/lb of rubber)

Mixing Milling Extruding CalenderingHot Air Curing

1,2-Dichloroethane 107-06-2 --- 4.06E-08 --- 1.22E-07 ---1,3-Butadiene 106-99-0 --- --- --- --- 1.24E-06Acrolein 107-02-8 8.26E-07 --- 3.10E-07 7.82E-8 9.34E-06Acrylonitrile 107-13-1 1.17E-05 1.29E-07 5.08E-07 --- ---Aniline 62-53-3 5.13E-07 5.32E-06 2.69E-07 9.44E-08 8.85E-07Benzene 71-43-2 6.61E-07 5.99E-08 1.26E-08 4.54E-08 4.88E-05Benzidine 92-87-5 1.80E-08 --- 1.68E-08 --- ---Biphenyl 92-52-4 5.63E-08 4.16E-08 --- 1.78E-08 3.96E-06Carbon Tetrachloride 56-23-5 4.68E-05 --- --- --- 4.20E-08Chloroform 67-66-3 6.51E-07 --- 3.81E-08 --- ---Hexachloroethane 67-72-1 1.23E-06 --- --- --- ---Hydroquinone 123-31-9 2.62E-05 --- --- 3.73E-08 ---Methylene Chloride 75-09-2 3.86E-05 1.01E-06 1.32E-5 4.71E-08 3.61E-06Naphthalene 91-20-3 3.08E-07 3.73E-07 1.96E-06 1.21E-07 3.23E-06Nickel (Ni) Compounds 9.53E-08 --- 4.91E-07 --- ---o-Toluidine 95-53-4 2.23E-07 --- 1.50E-07 --- ---Propylene Oxide 75-56-9 --- --- 1.75E-06 --- ---Tetrachloroethylene 127-18-4 --- 8.39E-08 1.71E-07 --- ---

Reported emissions for 2011 from the Facility were also compared to the Appendix C action levels. The actual 2011 emissions were based on different estimating procedures

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than those used for developing Tables 3-5 and 3-6, not in any difference in the operations at the Facility. This comparison is shown in Table 3.7.

Table 3-7 Reported 2011 Individual HAC Emissions from Manufacturing Processes (ton/yr)

HAC/HAP Name CAS #HAC

Category

Reported 2011


Estimated Emission Rate

(lb/8-hrs)

Appendix C Action Level

(lb/8-hrs)

Appendix C Action

Level Exceeded?

Hexachlorobenzene 118-74-1 1A 0.11 0.000100 0.00018 No

Nickel (Ni) Compounds 1-7 1A 6.26 0.005717 0.00017 Yes

Biphenyl 92-52-4 1A 42.33 0.038658 0.00015 YesEthylbenzene 100-41-4 1B 0.44 0.000402 8.3 No

Styrene Monomer 100-42-5 1B 0.86 0.000785 8.3 No

1,3-Butadiene 106-99-0 1B 0.81 0.000740 0.0027 No

Ethylene Dichloride (1,2-dichloroethylene) 107-06-2 1B 0.8 0.000731 0.0032 No

Tetrachloroethylene 127-18-4 1B 0.84 0.000767 0.015 No

Lead (Pb) Compounds 2-6 1B 0.15 0.000137 0.00083 No

Cobalt (Co) Compounds 3-3 1B 0.11 0.000100 0.00083 No

Carbon Tetrachloride 56-23-5 1B 1.9 0.001735 0.0055 No

Aniline 62-53-3 1B 57.43 0.052447 0.051 YesChloroform 67-66-3 1B 0.4 0.000365 0.0036 No

Benzene 71-43-2 1B 4.21 0.003845 0.011 No

Methylene Chloride 75-09-2 1B 481.51 0.439735 0.17 Yes

1,1-Dichloroethylene 75-35-4 1B 0.88 0.000804 1.7 No

Isophorone 78-59-1 1B 116.04 0.105973 5.87 No

Naphthalene 91-20-3 1B 33.6 0.030685 0.02 YesNitrobenzene 98-95-3 1B 0.21 0.000192 0.012 No

Acrolein 107-02-8 2A 4.98 0.004548 0.002 YesMethyl Isobutyl Ketone 108-10-1 2A 190.7 0.174155 249 No

m-Xylene 108-38-3 2A 0.36 0.000329 8.3 No

Toluene 108-88-3 2A 154.95 0.141507 24.9 No

Phenol 108-95-2 2A 27.86 0.025443 5.3 No

Dimethyl Phthalate 131-11-3 2A 3.67 0.003352 9.9 NoChromium Compounds, Except for Cr (VI) compounds

2-4 2A 3.36 0.003068 0.01 No

Methyl Chloride 74-87-3 2A 10.74 0.009808 7.5 No

Carbon Disulfide 75-15-0 2A 27.47 0.025087 54.5 No

Dibutyl Phthalate 84-74-2 2A 13.02 0.011890 0.25 No

Cumene 98-82-8 2A 18.85 0.017215 33.2 No

N-Hexane 110-54-3 2B 233.52 0.213260 581 No

Methyl Ethyl Ketone 78-93-3 2B 17.2 0.015708 415 No

As may be seen in the above table, the 2011 reported emissions of Acrolein, Aniline,

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Biphenyl, Methylene chloride, Naphthalene and Nickel also exceed the Action Levels described in Appendix C.

3.4 Summary of Facility Allowable Emissions and Significance Determination.

Allowable emissions from the Facility, based on the estimations described above, are summarized in Table 3-8 as follows:

Table 3-8 - Allowable Emissions Summary (ton/yr)

ActivityPM / PM10 SO2 NOx CO VOC HAP GHG

Boiler Emissions

Boilers fining No. 6 Oil 9.6 40.8 9.5 0.7 0.04 0.02 3,239.3

Boilers fining CNG 9.6 0.01 1.9 1.6 0.01 0.11

PM Emissions - Dust Collectors - Aggregate Emissions from Manufacturing Processes 5.4 -- -- -- -- -- --

VOC and HAP Emissions - Manufacturing Processes

Mixing -- -- -- -- 4.44 0.59 --Milling -- -- -- -- 1.13 0.21 --Extruding -- -- -- -- 0.12 0.09 --Calendering -- -- -- -- 0.56 0.13 --Hot Air Curing -- -- -- -- 4.65 1.97 --

Solvent Adhesives and Cleaning Compounds 1.01 0.84

Totals 15 40.8 9.5 1.6 12.0 3.9 3,239.3

Major Modification Applicability for Firing CNG – The allowable emissions from the Facility for PM, NOx, NO2, CO and VOCs when firing CNG were not greater than, than their respective significance levels. Therefore, the net change in emissions of any of these pollutants could not have exceeded its respective significance level. However, for PM10, PM2.5 and SO2 the average of the actual emissions from 2009-2010 were compared against the allowable emissions to confirm any changes to the allowable emissions did not exceed a significance level. This comparison is shown in Table 3-9

Table 3-9: Major Modification Applicability Determination for Boilers Firing CNG

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Pollutant

Allowable Facility

Emissions when firing

CNG(ton/yr))

2009-2010 Average Actual Emissions from No. 6 Fuel Oil

(TPY)

Net Change(+ = increase)(- = decrease)

Significant Emissions /

Major Source Threshold

(TPY)

Proposed Modification Significant?

(T/F)

NOx 1.9 5.15 -3.25 40 FALSE

NO2 1.9 5.15 -3.25 40 FALSE

CO 1.6 0.36 1.24 50 FALSE

PM 15.0 7.71 7.29 25 FALSE

PM10 15.0 7.71 7.29 15 FALSE

PM2.5 15.0 7.71 7.29 10 FALSE

SO2 0.01 22.5 -22.49 40 FALSE

VOC 6.1 0.7 5.4 40 FALSE

4.0. APPLICABLE REQUIREMENTS

Pursuant to §5-1006(e)(4) of the Regulations, the Owner/Operator of a stationary air contaminant source applying for a Permit to Operate is required to identify and certify compliance with all applicable state and federal air pollution control requirements before a permit may be issued. These requirements include state and federal regulations, state statutes, the federal Clean Air Act, and the requirements of any construction permit issued under 10 V.S.A. §556 and §5-501 of the Regulations. Applicable federal regulations may include Federal New Source Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants (NESHAP) found in 40 CFR, Parts 60, 61, and 63. The applicable requirements and the Agency's findings are presented below. Applicability of §5-261 (Control of Hazardous Air Contaminants) is discussed separately under Section 8 below.

The Agency will assess compliance with these regulations during any inspections of the Facility. The inspections will include confirmation of the proper operation and maintenance of equipment and air pollution control devices, visual observations of emission points, and review of any records required by the Permit

4.1 Vermont Air Pollution Control Regulations and Statutes

§§5-201, 5-202, and 5-203 - Open Burning Prohibited. "No person shall engage in any open burning except in conformity with the provisions of Section 5-201, 5-202, and 5-203".

Based on the application submittal and information available to the Agency, no open burning is conducted at the Facility.

§5-211(1) - Prohibition of Visible Air Contaminants - Installations constructed prior to April 30, 1970. "No person shall cause, suffer, allow or permit the emission of any visible air contaminant from installations constructed prior to April 30, 1970, for more

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than a period or periods aggregating six (6) minutes in any hour, which has a shade, or density, greater than 40% opacity (No. 2 on the Ringelmann Chart). At no time shall the visible air contaminants have a shade, density, or appearance greater than 60% opacity (No. 3 of the Ringelmann Chart).”

These emission standards do not apply to the Facility as it has been assumed the entire Facility was reconstructed or modified subsequent to 1970.

§5-211(2) - Prohibition of Visible Air Contaminants - Installations constructed subsequent to April 30, 1970. "No person shall cause, suffer, allow or permit the emission of any visible air contaminant from installations constructed subsequent to April 30, 1970, for more than a period or periods aggregating six (6) minutes in any hour, which has a shade, or density, greater than 20% opacity (No. 1 of the Ringelmann Chart). At no time shall the visible air contaminants have a shade, density, or appearance greater than 60% opacity (No. 3 of the Ringelmann Chart)."

These emission standards apply to all installations at the Facility as it has been assumed the entire Facility was reconstructed or modified subsequent to 1970. The applicant is expected to comply with these emission standards based on proper equipment design, operation and maintenance.

Any emission testing conducted to demonstrate compliance with the above emission limits shall be performed in accordance with 40 CFR Part 51, Appendix M, Methods 203B and 203C, respectively, or equivalent methods approved in writing by the Agency

§5-221(1)(a) - Prohibition of Potentially Polluting Materials in Fuel. "No person shall cause or permit the use, purchase, or sale for use in stationary combustion installations within the State of Vermont for heat or power generation of:

(i) , fuels containing more than 2.0% sulfur by weight, except as otherwise provided below;

(ii) No. 2 and lighter distillate oils and animal and vegetable fuel oils with a sulfur content greater than 0.05% by weight beginning on July 1, 2014, and ending on June 30, 2018;

(iii) No. 2 and lighter distillate oils and animal and vegetable fuel oils with a sulfur content greater than 0.0015% by weight, beginning on July 1, 2018"

(iv) No. 4 residual oil with a sulfur content greater than 0.25% by weight, beginning on July 1, 2018; and

(v) No. 5 and No. 6 residual oils and heavier residual oils with a sulfur content greater than 0.5% by weight, beginning onf July 1, 2018.

Compliance with this standard is based on fuel analyses following the procedures prescribed by the American Society of Testing Materials ("ASTM").

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This regulation applies to all the stationary fuel burning equipment at the Facility including the two (2) Cleaver Brooks boilers. The permit application indicates that the fuel used at the Facility is No. 6 fuel oil and CNG. Based on historical fuel sulfur content records and the inherent low sulfur content of CNG, the applicant is expected to comply with this regulation.

§5-231(3)(a) - Prohibition of Particulate Matter; Combustion Contaminants. "A person shall not discharge, cause, suffer, allow or permit the emission of particulate matter caused by the combustion of fossil fuel in fuel burning equipment from any stack or chimney in excess of the following emission limits:

(i) 0.5 pounds per hour per million BTUs of heat input in combustion installations where the heat input is 10 million BTUs or less per hour.

(ii) For combustion installations where the heat input is greater than 10 million BTUs per hour, but where the heat input is equal to or less than 250 million BTUs per hour, the applicable limit is determined by using the following formula:

where:

EPM - is the particulate matter emission limit, expressed to the nearest hundredth pound per hour per million BTUs; and

HI - is the heat input in millions of BTUs per hour."

Compliance with this emission standard shall be determined in accordance with 40 CFR, Part 60, Appendix A, Reference Method 5 or an alternative method approved in writing by the Agency.

This emission standard applies to the two (2) Cleaver Brooks boilers. Emission limits under this regulation will be as follows:

Table 4-1 Particulate Matter Emission Limitations - Boilers

BoilerEmission Limitations

lbs/MMBtu1 lbs/hour2

Cleaver Brooks Model # CB600-300 oil / CNG-fired 10.5 MMBtu/hr boiler 0.49 5.1

Cleaver Brooks Model # CB655-250 oil / CNG-fired 10.5 MMBtu/hr boiler 0.49 5.1

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Emissions from the boilers estimated using procedures described in Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources (5th Edition including Supplements A, B and C), AP-42, Office of Air Quality Planning and Standards, Chapter 1, External Combustions Sources, Section 1.3 – Fuel Oil Combustion, Tables 1.3-4 (September 1999, corrected May 2010).will be approximately 21.8 lbs/1,000 gallons of fuel, or 0.15 lbs/MMBtu. Thus, the boilers are anticipated to comply this with limitation.

§5-231(4) - Prohibition of Particulate Matter; Fugitive Particulate Matter. ."A person shall not cause, suffer, allow, or permit any process operation to operate that is not equipped with a fugitive particulate matter control system. A person shall not cause, suffer, allow, or permit any materials to be handled, transported, or stored; or a building, its appurtenances, or a road to be used, constructed, altered, repaired or demolished without taking reasonable precautions to prevent particulate matter from becoming airborne. Public roads will not be subject to this section unless a public nuisance is created."

This requirement applies to the entire Facility, and the Facility is therefore expected to comply with the fugitive emission limitations of this section.

§5-241(1) and (2) - Prohibition of Nuisance and Odor. "A person shall not discharge, cause, suffer, allow, or permit from any source whatsoever such quantities of air contaminants or other material which will cause injury, detriment, nuisance or annoyance to any considerable number of people or to the public or which endangers the comfort, repose, health or safety of any such persons or the public or which causes or has a natural tendency to cause injury or damage to business or property. A person shall not discharge, cause, suffer, allow, or permit any emissions of objectionable odors beyond the property line of a premises."

Based on the application submittal and information available to the Agency, the Facility is currently in compliance with this regulation.

§5-253.14- Solvent Metal Cleaning. This subsection shall apply to any solvent metal cleaning equipment, and contains several requirements designed to minimize the generation of VOCs from such equipment. Specifications are listed within this section for air pollution control devices and work practice standards.

The solvent metal cleaning equipment operated by the Permittee for equipment cleaning is subject to the standards for cold cleaning operations. Based on the information available to the Agency, the Facility is currently in compliance with this regulation

§5-403 - Circumvention. "No Person shall build, erect, install or use any article, machine, equipment or other contrivances, the use of which, without resulting in a reduction in the total release of air contaminants to the atmosphere, reduces or conceals an emission which otherwise would constitute a violation of these regulations."

Based on the application submittal and information available to the Agency, the Facility is currently in compliance with this regulation.

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Subchapter VIII - Registration of Air Contaminant Source. "Each operator of a source which emits more than five tons of any and all air contaminants per year shall register the source with the Secretary, and shall renew such registration annually."

The applicant is currently in compliance and has been registering its emissions with the Agency annually.

4.2. Federal Air Pollution Control Regulations and the CAA

Section 111 of the Clean Air Act establishes New Source Performance Standards (NSPS). NSPSs apply to new sources, and are promulgated under 40 CFR, Part 60. Section 112 of the Clean Air Act establishes National Emission Standards for Hazardous Air Pollutants (NESHAPs). NESHAPs are promulgated under 40 C.F.R. Part 61 and Part 63, and may apply to new or existing sources. Potentially applicable NSPSs and NESHAPs are summarized in Table 4-2.

Table 4- 2 Review of Requirements fromFederal Regulations and the Clean Air Act

40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units: §60.42c Standards for sulfur dioxide; §60.43c Standards for particulate matter; §60.48c Reporting and recordkeeping requirements. Applicable to all units of 10 MMBTU per hour or greater manufactured after June 9, 1989.

Units larger than 30 MMBTU per hour installed after February 27, 2005 are subject to additional particulate matter requirements.

This regulation would not be applicable to the Facility, as the two (2) Cleaver Brooks boilers at the Facility were both manufactured before June 9, 1989

40 CFR Part 63, Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, Institutional Boilers and Process Heaters. This regulation applies to new and existing boilers located at major sources (area source are subject to Subpart JJJJJJ). The final rule is effective 3/21/2011. Boilers that commenced construction on or before June 4, 2010 are considered an existing source.

This regulation would not be applicable to the Facility, as the Facility is not a major source.

40 CFR Part 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers. This regulation will apply to new and existing fuel oil and solid fuel fired boilers located at area sources (major sources are subject to Subpart DDDDD). It does not apply to natural gas or propane fired boilers. The final rule is effective 3/21/2011. Boilers that commenced construction on or before June 4, 2010 are considered an existing source.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart JJJJJJ is anticipated to apply to the two (2) Cleaver Brooks boilers at the Facility. Amendments to Subpart JJJJJJ were proposed December 23, 2011 that may affect final applicability

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Table 4- 2 Review of Requirements fromFederal Regulations and the Clean Air Act

40 CFR Part 60, Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984. Applicability: The affected facility to which this subpart applies is each storage vessel with a capacity greater than or equal to 75 m3 (19,804 gal) that is used to store volatile organic liquids (including petroleum). This subpart does not apply to the following:1. Any storage vessel with a capacity less than 75 m3

2. Any storage vessel storing a liquid with a vapor pressure less than 3.5 kPa3. Any storage vessel with a capacity > 75 m3 and <151 m3 with a v.p. <15.0 kPa4. Pressure vessels >29.7 psi and without emissions to the atmosphere. 5. Vessels permanently attached to mobile vehicles.6. Vessels located at bulk gasoline plants.7. Vessels located at gasoline service stations.For affected facilities, there are recordkeeping requirements and depending upon the material stored there may be standards for the tank’s vent system.

This regulation would not be applicable to the Facility. The potentially affected units are used to store No. 6 fuel oil which has a vapor pressure less than 3.5 kPa. As such, storage vessels containing No. 6 fuel oil would not be subject to this requirement.

40 CFR Part 63, Subpart VVVVVV - National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources. This regulation will apply to chemical manufacturing area sources (CMAS) with chemical manufacturing process units (CMPU) that use, produce or generate hazardous air pollutants defined in Table 1 of this regulation (Table 1 HAP) in concentrations greater than 0.1.0% for carcinogens and 1.0% for noncarcinogens The regulation requires notification implementation of management practices and semi-annual reporting requirements. Emissions reductions will be required for facilities that emit Table 1 HAP in excess of specified thresholds. The final rule is effective 10/29/2009.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Based on the SIC codes for applicability of Subpart VVVVVV, and the SIC codes that describe the Facility, Subpart VVVVVV is not anticipated to apply to the mixing, milling extruding, calendering and curing operations at the Facility.

Clean Air Act §608; 40 CFR Part 82, Subpart F – Recycling and Emissions Reductions. This requirement is applicable to any facility that owns, services, maintains, repairs, and disposes of appliances containing ozone depleting substances.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation It is likely this regulation would be applicable to the roof mounted industrial refrigeration / chiller units at the Facility

C. Non-Applicable Requirements for Which a Permit Shield Provision Has Been Requested

Pursuant to §5-1015(a)(14) of the Regulations, the Owner/Operator may request a permit shield from specific state or federally enforceable regulations and standards which are not applicable to the source.

The Permittee has requested a permit shield with respect to several potentially applicable requirements. The Agency has reviewed this request and is hereby granting

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a permit shield in accordance with §5-1015(a)(14) of the Regulations for the following requirements which have been determined not to be applicable to the Facility based on the information provided by the Permittee.

Table 4- 3 Non-Applicable Requirements for which a Permit Shield is Granted

§5-241 (3) of the Regulations – Control of Odor from Industrial Processes

This determination is applicable only to current operations as they are presently configured and operated

§5-251 (1) of the Regulations – Control of Nitrogen Oxides Emissions – Steam Generating Fuel Burning Equipment.

This regulation is not applicable to the Facility, as the steam generating equipment at the Facility has a heat input rating of less than 250 MMBtu per hour.

§5-251 (2) of the Regulations – Control of Nitrogen Oxides Emissions – Reasonably Available Control Technology for Large Stationary Sources..

This regulation is not applicable to the Facility, as the Facility does not have allowable NOx emissions of 100 tons per year or greater.

§5-252 of the Regulations – Control of Sulfur Dioxide Emissions

This regulation is not applicable to the Facility, as the steam generating equipment at the Facility has a heat input rating of less than 250 MMBtu per hour.

§5-253 (20) of the Regulations – Control of Volatile Organic Compound, Other Sources That Emit Volatile Organic Compounds

This regulation is not applicable to the Facility since it does not currently have the potential to have VOC emissions exceeding 50 tons/yr. Should the Facility’s VOC emission potential exceed 50 ton/yr in the future, this Permit Shield would no longer apply.

40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units. Applicable to all units of 10 MMBTU per hour or greater manufactured after June 9, 1989.

This regulation is not applicable to the Facility, as the affected units predate the June 9, 1989 applicability date.

5.0 CONTROL TECHNOLOGY REVIEW FOR MAJOR SOURCES AND MAJOR MODIFICATIONS

Pursuant to §5-502 of the Regulations each new major source and major modification must apply control technology adequate to achieve the Most Stringent Emission Rate ("MSER") with respect to those air contaminants for which there would be a major or significant emission increase, respectively. The Facility is not undergoing changes subject to new source review. Therefore, this section is not applicable.

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6.0. AMBIENT AIR QUALITY IMPACT EVALUATION

The Agency's implementation procedures concerning the need for an ambient air quality impact evaluation under §5-501 of the Regulations specifies that such analyses shall be performed when modifications result in an allowable emissions increase of 10 tpy or more of any air contaminant, excluding VOCs. Air quality impact evaluations are not required by the Agency for individual sources of VOCs. The changes at the Facility will not result in an allowable emissions increase of 10 tpy. Therefore, this section is not applicable.

7.0 HAZARDOUS AIR CONTAMINANTS

Pursuant to §5-261 of the Regulations, any stationary source whose current or proposed actual emission rate of a hazardous air contaminant (“HAC”) is equal to or greater than the respective Action Level (found in Appendix C of the Regulations) shall achieve the Hazardous Most Stringent Emission Rate ("HMSER") for the respective HAC.

Since fuel burning equipment which combusts only virgin liquid or gaseous fuel is not subject to §5-261, emissions from the two (2) Cleaver Brooks boilers are exempt from §5-261.

The Permittee is anticipated to have emissions of eighteen (18) hazardous air contaminants (HACs) from the manufacturing processes in excess of their respective Action Levels. Emissions from rubber manufacturing activities that were estimated using a combination of AP-42 emission factors and on-site testing previously conducted by the Permittee indicate that the following compounds may be emitted from the rubber mixing, milling, extruding, calendering and/or the post curing operations, and if present,, are likely to exceed the action levels.

1,2-Dichloroethane 1,3-Butadiene Acrolein Acrylonitrile Aniline Benzene Benzidine Biphenyl Carbon Tetrachloride Chloroform Hexachloroethane Hydroquinone Methylene Chloride Naphthalene Nickel (Ni) Compounds o-Toluidine Propylene Oxide Tetrachloroethylene

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The Permittee has previously indicated that Cadmium is not used as part of their manufacturing operations. Based on 2011 reported emissions data, emissions of Acrolein, Aniline, Biphenyl, Methylene chloride, Naphthalene, and Nickel compounds were exceeding their respective Action Level. The emissions estimates in this permit have been estimated using higher emission factors than were used in the emission estimates for previous permits.

These HAC emissions are predominantly from additives, cements, solvent tackifiers, and release agents used in the manufacture of the rubber. These compounds may gradually be emitted to the ambient air as part of the production process. Emissions may occur as particulate matter, or in the case of organic HAP/HAC, as a vapor phase. Heated operations such as extruding and curing likely would be processes with largest vapor emissions. Most of these emissions are fugitive in nature making capture and control infeasible. These pollutants are naturally occurring emissions from the manufacturing of rubber compounds. According to the Permittee, product reformulation may reduce emissions of these chemicals, but may not eliminate them altogether. The Permittee is currently not aware of a rubber product substitute that would eliminate or reduce emissions of these pollutants. As information becomes available, the Permittee intends to research rubber compounds and additives in an effort to lower its potential emissions of these compounds. In the meantime, where possible, the Permittee intends to use best management practices to limit the emissions of these HACs.

Best management practices would include control of particulate and vapor phase emissions. To control particulate emissions, the rubber processing operations are equipped with high efficiency Torit cartridge dust collectors, many of which do not discharge to the ambient air. The three dust collectors that do discharge to ambient air are D/C-4, D/C-6 and D/C-11, which are limited to 0.002 gr/dscf, 0.001 gr/dscf, and 0.01 gr/dscf respectively

A permit condition will be established to restrict emissions of the eighteen (18) HAC compounds identified above based on the emission factors identified in AP-42 for each of the various rubber manufacturing processes. This will serve to restrict HAC emissions to those typically encountered in the rubber manufacturing industry.

The best management practices to control vapor phase emissions will include minimizing the operating temperatures at which heated operations such as extruding and curing are performed, covering process vessels when in use except to add materials or to sample, periodic inspections for leak detection, prompt repair of leaks, and transferring liquids or materials in a manner that will minimize fugitive emissions.

The operation of the dust collectors at or below the permitted discharge limits, restriction of HAC emissions to less than the emission factors presented in AP-42 for rubber manufacturing, and implementation of the best management practices described above are considered by the Agency to achieve HMSER.

8.0 PERMIT CONDITION DISCUSSION

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For purposes of clarity, discuss any unique permit conditions and explain what was considered in the development of the condition

(2) The Permittee shall control particulate matter emissions from each of the processes listed below by installing and operating the respective emission control device, or a similar device capable of achieving equivalent emission reductions if approved in writing by the Agency.

This condition lists the various dust collectors and their specifications as given in the application for #AOP-12-036. Even though the only operations that vent externally are Extruding and Milling, Menzel #1 Hood and Floor Pits and the Banbury mixer, other operations with emissions controls are listed here to ensure proper control of dust that could eventually make its way to the ambient air.

(4) Dust collectors D/C-5, D/C-7, D/C-8, D/C-9, and DC-13.shall be vented internal to the building whenever operating and shall not be vented directly to the outside air, unless prior approval has been granted by the Agency.

The Permittee proposed limiting the discharge from these units to exclusively indoor discharge. Discharge from the remaining three units (D/C-4, D/C-6, and D/C-11) was permitted for discharge to the ambient air without limitations on the total hours of discharge. These units may still be vented back inside the building during colder months to conserve heat.

(7) The Permittee shall operate only one of its two boilers listed in Finding of Fact (A) at any given time. [10 V.S.A. §§556(c) and 556a(d)] [application for #AP-89-003b]

AND(8) The annual fuel consumption in the two boilers listed in Finding of Fact (A) shall

not exceed a combined 260,000 gallons, based upon any rolling twelve (12) consecutive calendar month period. [10 V.S.A. §§556(c) and 556a(d)] [application for #AP-89-003b]

These conditions stem from an earlier permit that limited the boilers to operating one at a time and 260,000 gallons per year of fuel for both boilers combined. Based on actual fuel usage the 260,000 gallon limit is not expected to be an issue. Should the Permittee wish to operate both boilers simultaneously in the future a permit amendment would be required and it would need to be verified that there are no short term ambient impact issues such as for SO2. Such SO2

impacts could likely be remedied by agreeing to use lower sulfur fuel oil.

(14) Particulate Matter: Emissions of particulate matter from the sources listed below shall not exceed the following limits:

These are all high efficiency Torit dust collectors and not expected to have difficulty meeting the required emission limits. Limits were not established for dust collectors that vented exclusively indoors.

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