POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two...

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Licensing Department EPA Headquarters PO Box 3000 Johnstown Castle Estate Co. Wexford 28-06-1 7 Licence Register No: POO21-02 Reference: Technical Amendment to IPC Licence to remove: Formaldehyde quarterly monitoring on emission point SOIC - Schedule C.1.2 Air flow limit from emission points S02A and S02B - Schedule 8. I Dear %/Madam, Masonites’ request the above two Technical Amendments to its IPC licence tu bring the licence in line with long standing letters of agreement between Masonite and EPA Office of Environmental Enforcement. B ac kn 1-0 u n d Over the years various changes have been agreed by EPA OEE to Masonites licence. These changes have been agreed through letters of approval. As part of a licence review in 2012 a large number of these changes were incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical Amendment to its’ IPC licence to amend Schedule C.1.2. This amendment is to remove the requirement for quarterly formaldehyde monitoring on emission point SO1 C. Approval to cease formaldehyde monitoring on emission point SO‘lC was obtained on IEith July 201 0. Masonite also requests a Technical Amendment to its licence to amend Schedule B.’l. This amendment is to remove the limits on air volume to be emitted for emissions points S02A and S02B. This change was approved by EPA on the 24th of August 2000. Masonite have not used the volumetric flow limit for compliance since 2000 and report air flow in the absence of the limit. A number of emission parameters for emission points S02A and SU2B do not have a mass emission limit. The proposal is to remove the air flow limit and to have mass emission limits for all parameters based on the original flow limit. Tables detailing the proposed changes are shown below. For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 10-04-2018:04:11:12

Transcript of POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two...

Page 1: POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical

Licensing Department EPA Headquarters PO Box 3000 Johnstown Castle Estate Co. Wexford 28-06-1 7

Licence Register No: POO21-02

Reference: Technical Amendment to IPC Licence to remove:

Formaldehyde quarterly monitoring on emission point SOIC - Schedule C.1.2 Air flow limit from emission points S02A and S02B - Schedule 8. I

Dear %/Madam,

Masonites’ request the above two Technical Amendments to its IPC licence tu bring the licence in line with long standing letters of agreement between Masonite and EPA Office of Environmental Enforcement.

B ac kn 1-0 u n d

Over the years various changes have been agreed by EPA OEE to Masonites licence. These changes have been agreed through letters of approval. As part of a licence review in 2012 a large number of these changes were incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence.

Proposal

Masonite request a Technical Amendment to its’ IPC licence to amend Schedule C.1.2. This amendment is to remove the requirement for quarterly formaldehyde monitoring on emission point SO1 C. Approval to cease formaldehyde monitoring on emission point SO‘lC was obtained on IEith July 201 0.

Masonite also requests a Technical Amendment to its licence to amend Schedule B.’l. This amendment is to remove the limits on air volume to be emitted for emissions points S02A and S02B. This change was approved by EPA on the 24th of August 2000. Masonite have not used the volumetric flow limit for compliance since 2000 and report air flow in the absence of the limit. A number of emission parameters for emission points S02A and SU2B do not have a mass emission limit. The proposal is to remove the air flow limit and to have mass emission limits for all parameters based on the original flow limit. Tables detailing the proposed changes are shown below.

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Schedule B.1 Revised Emission Limit Values

Remove air flow limit and include mass emission limits for the parameters that do not currently have a mass emission Limit

Emission Point Reference: S02A - First stage Fibre Drier - Line A

Parameter Particulates Condensable VOC as C Total Aldehydes as C CO NOx so2 Formaldehyde

Conc. (mg/m3) 20 100

20

I00 200 40 12

Kg/hr 2.1 6.7

2.0

0.8

Pro osed k /hr -1 0.8

Emission Point Reference: S02B - First stage Fibre Drier - Line B

Note: New mass emission limits rounded to one decimal place.

Justification

The justification for this request is contained in previous letters submitted to the EPA which we have included in Attachment A. The corresponding letters of approval from EPA are included in Appendix B. In addition mass emission limits will replace the air flow limits on emission points S02A and S02B as detailed above.

If you have any queries or if you require any additional information on any aspect of the enclosed, please do not hesitate to contact me.

Yours sincerely,

Environmental Compliance Manager

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e

ATTACHMENT A

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EPA Regional Inspectorate J o h Moore Road Castlebar Co. Mayo

13th July 2010

P C Reg:' No. PROO21-01

Reference: Condition 1.2 -Request for approval to use alternative raw material.

Dear SirMadam,

h accordance with. PPC licence Condition 1.2 we are writing to request the Agencys approval to use a new raw material in the production process. This approval is requested following successful trials 2010. The new back sealer to be used is more cost effective than the back sealer ctmently k'ztse.

Process Desciiption:

. Masollite c'wently place two coats of primer to our d o o r s l ~ s in the CrxKoat process. One particular customer has had issues with our doorslhs in their, process and has requested that we improve the quality of the underside of our doorslcins so that they can be processed without any operational issues.

We have been able to resolve this issue in Qtrials, which were notified to the EPA, by adding a water-based back sealer to the doorskim and have received EPA approval €or om back sealer process in CdCoat (ref (P0021-01)10Ap19AR.docx).

Masonite has completed further successful. tr ials using an alternative back sealer material on the 8 ~ ' of April and the 7*" of July 201 0. This trial back sealer is similar to the current approved back sealer but is more cost effective to use.

The environmental implications ofthis process are as follows: Aj, - 8s pm3 o€this pmess which has been approved by the EPA, emission point SOlC cmcl its associatecl abatement technology is operated wlde applying back sealer to the doorslcicjs. I-listorkdly thee coating booths were vented though this stack, This process requires only one coating boo& to be vented through stack SOlC. Additiondly as the spray header Will only be operational when a doorskin passes above it, the loading of dust on the stack abatement system will be <2% of what it was when the three coating booths were operational. Air emissions from the new back sealer will be vented through ibis emission point as is currently the case when back sealing doorslbs.

* VOC and Formaldehyde - The back sealer does not cont& any formddehyde and only 2% VUCs and is a dean water-based sealer. (MSDS. included in Attih&ent A). Therefore there are no gaseous properties within the sealer that wa-l.rant my gaseous emission monitoring.

Masonite Ireland Drumsrra, Carrick on Shannon, Co. Leitrim, Republic of Ireland 0 Phone: +353 71 9659500 Fax: 5-353 71 9659508

Registered in Ireland No. 229654 /V.A.T. No. lE8229654U 4 Registered Office: 6th Floor, South Bank I-louse, Barrow Street, Dublin 4.

Directors: E. Chaples (U.S.A.); C. Kearns (Irish)

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Waste - The spray header: will only opaate when a doorslcin passes over it and therefore there will be no waste of any significance from this process. Any residual waste generated will be processes through the standard waste pakt process currently in use.

* Water - Any residual wastewater that may arise will be processed through the on-site wastewater tTeatment plait.

Ln surmnary, the bask sealer process itself has been approved by the Agency. We me requesting the Agencys approval to use an alternative back sealer which is water based and more cost effective than OUT cwcent back sealer.. Thus, we do not believe there will have any significant enviuoruneiitd implications for the site as a result of using this new raw material.

. .

Following y o u consideration of the above please revert back +th your decision as soon sts practicable as we are aaxious to proceed 'with this customer focused improv&ment. If you have queries on any aspect of the enclosed, please do not hesitate to contact me.

Yours sincerely,

fiA &LL&!+ Brian Mallon Environmental Compliance Manager

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Material Safety

3. Ca~~OSITIQMllldFOBUATlglN ON INGREDIENTS

Data Sheet

Ingredient Name Approx. EEC Hazard Notas: Weight % Classification CAS-NO.

12- 1 - 5 NE

34590-94-8

METHUXYMETWYLETH0XY)PRO PANOL

Product code: T-490JV11122B

Material Safety Data Sheet (ELI 'i 96'9/2006 REACH) Revision Date: 07/JuI/2010 Print Date: 07/J 1-11/20 1 0 I. IDENTIFICATION OF THE SUBSTANCEIPREPAWATION AND THE COWIFANYIUMDERTAKING

Product name: AQUADEX BV 122 El

EINECSl ELINCSI NLP: 252-1 04-2

Product code: Recommended use: Emergency telephone number: Manufacturer, importer, supplier:

T-490JVllI226 For coating metal containers and similar products. +33 (0) 1454 25959 The Valspar (France) Corporation 14 r u e Chanay 71 700 Tournus France Phone: j-33 (013 85 27 78 00 Fax: +33 (0)3 85 32 19 06 [email protected]

2. HAZARDS IDENTIFICATION c

Indication of danger: Not dangerous aGcarding to EC criteria.

For the full text of the R phrases mentioned in this Section, see Section 16.

Product code: T-490JVIIlZ2B Page 114

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i

4. FIRST AID MEASURES 1 General If symptoms persist, call a physician. Never give anything by mouth to an unconscious person. Inhalation: Move to fresh air. If victim is unconscious but breathing: Victim to lie down in the recovery position, cover and keep him warm. If not breathing, give artificial respiration. Obtain medical attention. Skin: Take off all contaminated clothing immediately. Wash off immediately with soap and plenty of water. Do NOT use solvents or thinners. Eyes: Remove contact lenses. In the case of contact with eyes, rinse immediately with plenty of water and seek medical advice.' Keep eye wide open while rinsing. Irigestion: Keep at rest. If swallowed, seek medical advice immediately and show this container or label. Do NUT induce vomiting.

5. FIE-FIGHTING MEASURES 1 The following actions are recommended Collect contaminated fire extinguishing water separately. This must not be discharged into drains. Fire will produce dense ,~ black smoke containing hazardous combustion products (see heading I O ) . Wear self contained breathing apparatus for ) fire fighting if necessary. Cool containers / tanks with water spray.

Suitable extinguishing media Suitable extinguishing media Alco hol-resistant foam Carbon dioxide (C02) Dry powder Extinguishing media which must not be used for safety reasons High volume water jet

6. ACCIDENTAL RELEASE MEASURES I Personal precautions: Exclude non essential personnel. Remove ail sources of ignition. Ensure adequate ventilation. D.0 not breathe vapoursldust. Environmental precautions: Local authorities should be advised if significant spillages cannot be contained. Methods for cleaning up: Contain spillage, and then collect with non-combustible absorbent material, (e.g. sand, earth, diatomaceous earth, vermiculite) and place in container for disposal according to local / national regulations. Soak up with inert absorbent material (e.g. sand, silica gel, acid binder, universal binder, sawdust). Glean with detergents. Avoid solvents.

7 . HANDLING AND STQMGE Handling: Operators should wear anti-static footwear and clothing. Use only non-sparking tools, Good housekeeping standards and regular safe removal of waste materials will minimise the risks of spontaneous combustion and other fire hazards. Vapours are heavier than air and may spread along floors. Prevent the creation of flammable or explosive concentrations of vapour in air and avoid vapour concentration higher than the occupational exposure limits. Provide adequate ventilation. The product should only be used in areas from which alI naked tights and other sources of ignition have been excluded. Electrical equipment should be protected to the appropriate standard. Preparation may charge electrostatically: always use earthing leads when transferring from one container to another, Keep container tightly closed. Keep away from open flames, hot surfaces and sources of ignition. Avoid contact with skin and eyes. Do not breathe vapours or spray mist. When using, do not eat, drink or smoke. Do not use pressure to empty drums. Store in original container. Storage: Containers which are opened must be carefully resealed and kept upright to prevent leakage. Take notice of the directions of use on the label. I<eep in a dry, cool and well-ventilated piace. Keep away from heat and sources of ignition. Keep away from direct sunlight. Store in a place accessible by authorized persons only. Do not smoke. Storage temperature: I O - 3 0 C

8. EXPOSURE CONTROLS I PERSONAL PRBTE%;TION Exposure h i t s :

I I

Product code: T-49OJVlll228 Page ,2 / 4

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8. EXPOSURE CONTROLS I PERSONAL PROTECTION

Ingredient Name UK Workplace Exposure Limit CAS-NO. WEL LTEL

(2- 308 mg/m3 METHOXYMETHYLETH0XY)PRUPANOL 50 PPm

34590-94-8

UK Workplace Exposure Limit Comments WEL STEL

150 pprn ' 924 malm3

Can be absorbed through skin.

(2- 308 mgh3 METHOXYMETHYlETH0XY)PROPANOL 50 PPm

34590-94-8

Engineering measures: During curing, decomposition products may be formed, which should be extracted safely from the work area. Provide adequate ventiiafion. Where reasonably practicable this should be achieved by the use of local exhaust ventilation and ' good general extraction, If these are not sufficient to maintain concentrations of particulates and solvent vapour below the OEL, suitable respiratory protection must be worn. Basic Personal Protection Respiration When workers are facing concentrations above the exposure limit they must use appropriate certifjed respirators. Hand protection: Wear suitable gloves and eyelface protection. Use protective skin cream before handling the product. Skin: Wear as appropriate: Flame retardant antistatic protective clothing Wear shoes with conductive soles.

Wear as appropriate: Safety glasses with side-shields Goggles Hygiene measures: Do not use solvents or thinners to clean skin. When ushg, do not eat, drink or smoke. Wash hands before breaks and at the end of workday. It is good practice in industrial hygiene to avoid contact with solvents by using appropriate protective measures whenever possible. The OES for nuisance dust is - IO m g h 3 (total dust), 4 m g h 3 (respirable dust). Check local regulations in case difFerent limits apply, .

Eyes:

Can be absorbed through skln.

9. PI-IYSICAL AND CHEMICAL PROPERTIES Physical state: liquid Specific Gravity .I '04 Boiling pointkange 3 00°C Flash point: 97% c,c. Sustains combustion: IlO

Ingredient Name Ireland OEL 8h TWA CAS-NO.

Stability: Stable under normal conditions. Conditions to avoid: Stable under recommended storage conditions. Materials to avoid: Keep away from oxidising agents, strongly alkatine and strongly acid materials in order to avoid exothermic reactions. Hazardous decomposition products: H'azardaus decomposition products, may be produced when the recommended processing temperatures or times are exceeded. Carbon monoxide Carbon dioxide (CO2) Smoke nitrogen oxides (NOx)

Ireland OEL 15 mtn STEL Ireland OEL Notes

i 1 d TOXICOLOGICAL INFORMATION General No data is available on the product itself.

Product code: T-49OJVlIf22B Page 3 t 4

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I ,

'i ',

\

1 14.T0XICUtOQICAL INFORMATION 1

1% REGULATORY 1NFORMATION

Skin Repeated or prolooged contact with the preparation may cause removal of natural fat from the skin resulting in non- allergic contact dermatitis and absorption through the skin. Repeated or prolonged skin contact may cause skin irritation and/or dermatitis and sensitization of susceptible persons. In h aiatio n Exposure to component S Q I V ~ R ~ vapour concentrations in excess of the stated occupational exposure limit may result in adverse health effect, such as mucous membrane and respiratory system irritation and adverse effect on kidney, liver and central nervous system. Inhalation of high vapour concentrations may cause symptoms like headache, dizziness, tiredness, nausea and vomiting. Ingestion not determined Eyes The liquid splashed in the eyes may cause irritation and reversible damage.

16. OTHER INFORUATlBN

I 12. ECOLOGICAL INFORMATION Product Information No data is available on the product itself. Local pollution requirements may apply to the use of this product. Do not let product enter drains. Do not contaminate ,

] surface water.

q3, DISPOSAL CONSIDERATIONS Waste disposal methods: Do not let product enter drains. Do not contaminate ponds, waterways or ditches with chemical or used container. Where possible recycling is preferred to djsposal or incineration. Dispose of as special waste in cornpiiance with local and national regulations. European Waste Catalogue 0801 42

14, TRANSPORT INFORMATION ADR

Proper shipping name: NOT REGULATED

IMDG-Code Proper shipping name: NOT REGULATED Marine pollutant I30

IATA-DGR Proper shipping name: NOT REGULATED

S-phrase(s) S23 - Do not breathe gas/fumes/vapour/spray. 551 - Use only in well-ventilated areas.

Product code: T490JVII122B Page 4 14

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6 MASONITE IRELAND CARRICK-ON-SHANNON CO. LEITRIM REPUBLIC OF IRELAND PHONE: t.353 78 59500 FAX: +353 78 w i o a DIRECT LINE: 59521

Mr. Dara Lynott Licensing and Control EPA Headquarters PO BOX 3000 Joh town Castle Estate Wexford

l2th June 2000

Reference: Request fox Testing with Plume Suppression On for Campfiance Testing

Doar M, Lynott,

Following on fiom our meeting with EPA officials on March Bth, 2000, and with respect to subsequent reports submitfed to EPA on March 3Oth, 2000, I now present below an

. assessment of particdates when operating the plume suppression system. Please inform us by Jme 20,2000, if you concur or disagree With our assessment.

.

Backprou ad: At om meeting in March2000, .and in our letter dated March 30th 2000, an explanation was provided on the apparent bias noted in the probe wash Saction of particulate due to cualescing/condensation on the probe which occurs without plume suppression in opqration.

Rmdy Young of International Paper's Technology organisation discussed aspects of this

on the €allowing points: ' issue with Nick Kenny of your organisation, at the March meeting,. who agreed with Randy

' 9) The use of plume suppression has no impact on our ability to accurately determhe. compliance with the oxygen corrected concenbation standards for the dryers. b) The use of plume suppression does not &ect ow ability to determine compliance with the mass emission standard from the dryers. (While it islpossible that some regulated material is present in plume suppression air, my introductioqof a contaminant would effectively reduce the allowable emission fkom the dryer, and would not increase the dowable emission to fie enviranmg?.) .. L _

. I. . .2G(,+:sJi .Ahsdlwre.-is a massstandard md EL oaneentration limit at 1.7% ~ ~ ~ ~ ~ n . ~ s ~ ~ ~ ~ ~ ~ ~ r ~ ~ ~ ~ :- .., .-: :<**' *.

&yers,'a fiow (volhmetric flow rate) standard i s not ~eani r igM.

Based on item c.) above, we request your concurreme that no volumetric flow standard should be applicable for the dryers. We also in€omed you at this meeting that OUT existing flows, especially when corrected to 17% wet oxygen, exceed the license value and that we

Registered in Ireland No. 229654 / V.A.T. No. 1E8229B54U. Registered Office: Arthur Cox Bldg. Earlsfart Tce. Dublin 2. Direotors: J. Morrison (USA); C. Butler (USA); P. Heist (USA); V. Lane (USA); J. Hoey (Irel).

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P MASONITE IRELAND CARRICK-ON-SHANNON CO. LEITRIM REPUIBLIC OF IRELAND PHONE +353 78 59500 FAX: +353 78 59508 DIRECT LINE: 59521

desire relief from my compliance consideration with respect to volumeEric flow rate of the dryers, so long as .the mass emissions and concentrations are consistent with the license terns.

Randy's recollection is that Mi. Kenny agreed Eo review this discussion with Mr. Lynott, and further that he would review it with Mr. Ken Macken to verify his understanding ofthe issue.

We interpret these discussions as "conceptual agreement" with ow points and look forward to your consideration of tho points noted in th is letter. We request your endorsement on the use of plume suppression for compliance sampling for mass emission rate and concentration for dl parameters on the dryers.

Particulate Update: In agreement with BPA we have undertaken a number of particulate tests when operating the plume suppression system. Testing with the plume suppression system on was performed to minimise the bias observed in the particulate resulh which i s caused by the testing artEact. These tests were conducted €or trial purposes only, and have not been used for regular compliance determinations.

The test data for coxnpliance and trial data ate provided in aftachment 1 afthis document.

Line 1: Plume suppression OF@ (standard test conditions): Nine valid sets of compliance data have been obtained since Janucuy 5,2000. Emission results from sewn test events exceeded the licence limit. For this process line the average for 9 compliance test events i s equivalent to 120% of the 1sC limit, which means on average we exceed the limit, The primary reason for these €ailures is the high level of inorganic salts being captured in the sample probe wash itaction of the sample. This is 'directly associated ~ t h the testing artifact. Plume suppression system ON: There have been eleven events where data have been obtained with the plume suppression system in the ON position, since Febiuary 4,2000, Only five test events exceeded the licence limit. For this process line the average for 11 phme suppression test events is equivalent to 90% of the IPC Emit, which means on average we are in compliance with the limit.

. 4 . ,_ ':- .., ,: 11. . . . . . _. a . -. . . .,. L.i'n&,:-:,f:. ' . * . . . . . ~ ~ , ~ ~ . ' . . ~ ~ t ~ ~ ~ ~ ~ ~ ~ , ~ ~ !:;;..!?. - _. I.. . * :. -; " .+.

_111 : .a<*.

Plume suppressio;' OFF (stan'kard test conditions): Thirteen valid sets of Gompliance data-have been obtained since January 12,2000. S k events exceeded the licence limit. FOK this process line the average €or 13 compliance test events is equklent to I 10% of the P C limit, which means on average we exceed the limit. The primary reason for these failwes-is

Registered in ireland No. 229654 I V.A.T. No. IE8229654U. Registered Office: Arthur Cox Bldg. Earlsfoh Tce. Dublin 2. Directors: J. Morrison (USA); C. Butler (USA); P. Heist (USA); V. Lane (USA); J. Hoey (trel).

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cI1 MASONITE IRELAND CARRICK-ON-SHANNON CO. LEITRIM REPUBLIC OF IRELAND PHONE: +353 78 59600 FAX: +353 78 59508 DIRECT LINE: 59521

the h& level of inorganic salts being captured in the sample probe wash fiaction of f&e sample. This is directly associated with the testing artifact. Plume suppression system UN: There have been seven events where data have been obtained with the plume suppression system in the ON position, since February 16,2000. For this process line the average for 7 plume suppression test events is equivalent to 62% of thhe IPC h i t , The result for each event onthis line is in 100% compXance with the licence limit.

Interim Summary: The use of the plume suppression system has reduced the average teest results for particulates on the direr emission points from 120% of the IPC limit to 90% of the P C h i t on Primary Line I, and fiom 1 10% of the IPC limit to 62% of the IPC 1 s t on. Primary Line 2. In addition, since the bagifining of the year, the average compliance run. results for each line, 2.5 kg/hr for line 1 and 2.3 k g h for line 2, have exceeded the maximum result of any given plume suppression result, 2.4 k g h for line 1 and 1.8 l@hr for line 2. The data indicate that compliant results were primarily achieved by reducing the probe rinse (artifact) fraction, which was the intent of testing with the plume suppression in thhe on position.

Particulates - Plan Porward: The action plan as we progress with this study is as follows: ,

We request your written approval on the following points, as agreed between Randy Young of International Paper and Nick Kenny of the EPA back on Mach 28,2000: 0 The use of plume suppression has no impact on our' ability to accurately determine

compliance with the oxygen corrected concentration standards for the dryers. 0 As there is both a mass standard and a concentration limit at 17% Oxygen standard

for the dryers, a flow (volumetric flow rate) standard is not meanhgfd. 0 The use of plume suppression does not aEect ow ability to determhe.compliance

witb. the mass emission standard fiorn the dyers. We addifionally request your written approval on the following: @ To operate with glume suppression on for all futctre particulate compliance testing

0 That the flow (volumetric flow rate) not be used to deterkine compliance. e. To resolve the highe! levels of particulate contadnation in both the probe wash and

- *

on edssion points SOZA and S02R

,&j@&y&&e s.eples .taken @om k i m q Line I emission poht ~ q p g g t ~ ~ g ~ $ g ~ ted'frd& Prim&-y Line' 2, because it is ow god tomaintain 100% complianck with

the P C licence limits.

Registered in Ireland No. 229654 1 V.A.T. No, lE8229654U. Registered Office: Arthur Cox Bldg. Earlsfott Tce. Dublin 2. Directors: J. Morrison (USA); G. Butler (USA); P. H d s t (USA); V. Lane (USA); J. Hoey (lrel),

A subsidiary of

INTERNATIONAL @ PAPER

, r .- ....,

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Page 14: POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical

8 M A ~ N I T E IRELAND CARRICK-UN-SHANNON CO. LEITRIM REPUBLIC OF IRELAND PHONE: +353 76 59500 FAX: +353 38 59508 DIRECT LINE 5952 1

Please inform us at your earliest: convenience, but by no later than June 20,2000, if you concm with &e above rEport;.

If you have queries on my aspect of the enclosed, please do not hesitate to contact me.

Registered .in Ireland No. 229654 I V.A.T. NO. lE8229654U. Registered Office: Arthur Cox Bldg. Earlsfort Tm. Dublin 2. Directors: J. Morrison (USA); C. Butler (USA); P. Heist (USA); V. Lane (USA); J, Hoey (Irel).

A subsidiary of INTERNATIONAL @ PAPER

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Page 15: POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical

ATTACHMENT I

.__l. .. . - . . ~ .\ .. 1 c . . . . ' . . _. ..,.-._. ,. . .* - -- - .'. . . * . r _ L .. . ....+-..~..".. - . . :. .. . .

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Page 16: POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical

1. - .. . ’.

4

3

4 d s 1. I l

0

Pnrdcdrfe a s s Emtden Liue 2 Scrubbnr 6023: MalResult8Pluole Supprdon On

- ... . , ... . .., - ... I- ... i. -_

M h X m 2.4 MINE 1.i AVO=. l .0

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Page 17: POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical

ATTACHMENT B

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Page 18: POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical

i

Mr Brian Mallon Environmental Compliance Manager Masonite Ireland Dmrnsna Carri ck-on-S hannon Co. Leitrim

Office of Environmental EnForcement

Environmental Protection Agency Regional Inspeaorale, John Moore Road Castlebar, County Mayo, Ireland

CigiEacht Reigiiinach, Bbthar Shedn de Mbrdha Cairldn an Bhatraigh, Contae Mhaigh Eo, $ire

T: 4-3353 94 904 8400 F: +353 94 904 8499 E: inf&epa.ie W: w . e p a . i e

LoCall: 1890 33 55 99

.

1 Sfh July 20 IO Our Ref: (P0021-01)1 OAP2lAR.docx

Reference: Condition 1.2 - Request for approval to use alternative raw material in the Cut/Coat Process.

Dear Mr Mallon

I deer to your proposal of 13fh July 2010 received by the Agency an 14/07/2010 requesting approval in accordance with Condition I .2 of your IPPC licence PO021 -0 1. I am to advise you that the proposal submitted is to the satisfaction of the Agency subject to the following:

Full documentation on the monitoring trials carried out on 07/07/2010 for the back sealer evaluation shall be retained on-site and shall be available for inspection by authorised persons of the Agency. Emission point SOlC and its associated abatement technology is fully operational and continuously monitored while applying the back sealer to the doorskins. The conditions of the IPPC licence POO21-01 must be complied with at all times. The Agency reserves the right to revoke Illis agreeinelit at any stage ia the future.

a

Please quote the above reference in future correspondence in relation to this matter.

Yours sincerely

Office-of Environmental Enforcement

\\OWL\OEE\OS. Licence Enforcemetit\lPC Licence Enforcement\lPC D3 Documents\P021-03O\POOZ 1-0 l\(POO 01)10AP21AR,docx

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Page 19: POO21-02 · incorporated into licence POO2‘l-02. Not all changes were made and the above two changes now need to be included in the licence. Proposal Masonite request a Technical

W. Tam QUinn Er~~komental Manager Mason& Corporation DlumsJlZ

Carrick-on-Shannon Co. Leitrim

Date

24 August 2000

, Ourref.

rn 1/AP

PO Box 3000 Johnstawn Castle &tat0 County Wexford fieland

Tel.: -1-353 53 60600 Fax: +353 53 60699 Website: ww w.epa.ie

Your ref.

Dear Mi. Quinn

X refer t6 you proposal dated 12 June 2000 received by the Agency on 16 June 2000 in relation to Plume Suppression,

I an to advise you that the proposal submitted i s to the satisfaction of the Agency subject to the following:

That permission to use plume suppression w h k sampling may be withdrawn in h e f-hxe. CompLiance mouh-ing is for 30 minuEe averages. +

Having plume suppression on does not invalidate lest procedures. That more accurate (representative) data may be collected with plme suppression On.

If you have any Eurther questions please do not hesitate to contact the Agency.

Yours sincerely

/ / Licensing and Control

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