Statement of Basis-Pressleys Recycling
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7/28/2019 Statement of Basis-Pressleys Recycling
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STATEMENT OF BASIS Page 1 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
DATE APPLICATION RECEIVED
December 15, 2011 - Concrete CrusherMarch 1, 2012 - Tub GrinderSIC Code - 5093NAICS Code - 423930
INSPECTIONS
April 15, 2010: The following unpermitted sources were found at the site at the time of inspection: One 160 HP Concrete Crusher, One 480kW diesel generator, four electric conveyors, and one diesel screener. This facility was found to be operating in violation of air qualitregulations and was requested to submit a permit application within 30 days.
March 30, 2012: The Department conducted a site visit. The facility was found to be clean with a few fugitive dust emissions from tructraffic traveling within the site. Facility had a large C&D storage pile, mulch pile, unground wood pile, unground waste pallet pile and
waste metal pile. No fugitive emissions were observed from each storage pile.
FACILITY DESCRIPTION Pressley’s Recycling is a full service construction, demolition, metal, and e-waste processing and recycling yard. This facility has a concretcrusher system consisting on a concrete crusher, four(4) conveyors, associated diesel engines that are used for the recycling of concretfrom construction demolition activities. This facility also has an exempt tub grinder powered by a diesel engine which grinds green woowaste into mulch.
PROJ ECT DESCRIPTION Initial State Operating Permit. Because the crusher was already constructed and on site, it was directly incorporated into an operatingpermit.
FACILITY EXEMPT EQUIPMENT
Table 1 lists a description of the equipment at this facility that has been determined to be exempt.The mobile Horizontal Grinder isexempt because its uncontrolled PM emission rate is less than 1.0 lb/hr as specified bySC Regulation 61-62.5 Section II(B)(2)(h).
TABLE 1. FACILITY EXEM PT EQUIPMENT
Equip ID Source Description CapacityInstallDate
Exemption Basis
EX-EDGEmergency Diesel
Generator205 kW (215 Hp) 2007
SC Regulation 61-62.5 SectionII(B)(2)(f)(ii)
EX-DST-1Above Ground DieselFuel Storage Tank
1,000 gal 2007 Air Permitting Exemption List Item 9
EX-DST-2Above Ground DieselFuel Storage Tank
3,000 gal 2007 Air Permitting Exemption List Item 9
EX-UOT Above Ground Used OilStorage Tank
3,000 gal 2007 Air Permitting Exemption List Item 9
EX-TG Mobile Tub Grinder 200 tph 2007 Air Permitting Exemption List Item 2
EX-HGMobile
Horizontal Grinder
100 tph Asphalt Shingles
60 tph Wood Waste2012
SC Regulation 61-62.5 SectionII(B)(2)(h)
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STATEMENT OF BASIS Page 2 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
PERMIT EMISSION UNITS
The operating permit will include one emission unit consisting of Unit ID 01 (Concrete Crushing).
FACIL ITY NON-EXEMPT EQUIPMENTSince this is the initial operating permit a description of the non-exempt equipment for the emission unit is listed in Table 2.
TABLE 2. PROCESS EQUIPM ENT FOR EMISSION UNIT ID 01 – CONCRETE CRUSHING
EquipID
EquipmentDescription
CapacityInstallDate
Manufacture Date
40CFR60SubpartOOO
Applicable?
Control DeviceEmissionPoint ID
CR-1 Mobile Crusher 250 tph 2007 2007 Yes Wet Suppression CR-1
C-1 Conveyor No.1 250 tph 2007 2007 Yes Wet Suppression C-1
C-2 Conveyor No.2 250 tph 2007 2007 Yes Wet Suppression C-2
C-3 Conveyor No.3 250 tph 2007 2007 Yes Wet Suppression C-3
C-4 Conveyor No.4 250 tph 2007 2007 Yes Wet Suppression C-4
VS Vibratory Screen 250 tph 2007 2007 Yes Wet Suppression VS
SOURCE TEST REQUIREMENTS This facility has a concrete crusher, vibratory screen and 4 conveyors subject to 40CFR60 Subpart OOO opacity limits. The permit requirean opacity test no later than 60 calendar days after the effective date of this permit.
SPECIAL CONDITIONS, MONITORING, LIM ITS This facility will be assigned the following operating hours limit: Concrete Crusher – 20 hr/week (20 hr/week)(52 week/yr) =1,040 hr/y
The Horizontal Grinder will be permitted to only grind asphalt shingles, untreated wood pallets, untreated kiln dried lumber and clean woodas defined by SC Regulation 61-62.1 Definition 17.
PUBLIC NOTICE This State Operating Permit will undergo a 30-day public notice period in accordance with SC Regulation 61-62.1, Section II(N). Thipermit was placed in the Carolina Gateway, Lancaster News, and The Herald on J uly 25, 2012. The comment period was open from July 252012 to August 23, 2012 and was placed on the BAQ website during that time period.
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STATEMENT OF BASIS Page 3 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
FACIL ITY-WIDE CRITERIA POLLUTANT EMISSIONS
Tables 3 through 5 lists the facility-wide criteria pollutant emissions.
• Potential controlled Concrete Crusher emissions calculated based on this facility operating a maximum of (20 hr/week)(52week/yr) =1,040 hr/yr
Sample CalculationFrom AP-42 5thed. Table 11.19.2-2, the PM emission factor for Tertiary Crushing is 0.0054 lb/ton. (250 ton/hr)(0.0054 lb/ton) =1.35lb/hr
TABLE 3. FACILITY -WIDE CRITERIA POLLUTANT EMISSIONS
Pollutant PM
EquipID
PotentialUncontrolled(lb/hr)
PotentialUncontrolled(tpy)
Basis PotentialControlled(lb/hr)
PotentialControlled(tpy)
Basis
CR-1 1.35 5.91
AP-42 5t Edition, Table11.19.2-2, TertiaryCrushing Factor, 250 tph of Concrete, 8,760 hr/yr
0.30 0.16
AP-42 5t Edition, Table11.19.2-2, Tertiary Crushing(Controlled) Factor, 250 tph oConcrete, 1,040 hr/yr
C-1C-2C-3C-4
3.0 13.14
AP-42 5t Edition, Table11.19.2-2, Conveyor
Transfer Point Factor, 250tph of Concrete, Total of all 4 conveyors, 8,760 hr/yr
0.140 0.07
AP-42 5t Edition, Table11.19.2-2, Conveyor TransfePoint (Controlled) Factor, 250tph of Concrete, Total of all 4conveyors, 1,040 hr/yr
VS 6.25 27.38
AP-42 5t Edition, Table
11.19.2-2, ScreeningFactor, 250 tph of Concrete, 8,760 hr/yr
0.550 0.29
AP-42 5t Edition, Table
11.19.2-2, Screening(Controlled) Factor, 250 tph oConcrete, 1,040 hr/yr
TOTAL 46.43 0.52
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STATEMENT OF BASIS Page 4 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
TABLE 4. FACILITY -WIDE CRITERIA POLLUTANT EMISSIONS
Pollutant PM10
EquipID
PotentialUncontrolled
(lb/hr)
PotentialUncontrolled
(tpy)Basis
PotentialControlled
(lb/hr)
PotentialControlled
(tpy) Basis
CR-1 0.60 2.63
AP-42 5t Edition, Table11.19.2-2, TertiaryCrushing Factor, 250 tph of Concrete, 8,760 hr/yr
0.135 0.07
AP-42 5t Edition, Table11.19.2-2, Tertiary Crushing(Controlled) Factor, 250 tph oConcrete, 1,040 hr/yr
C-1C-2C-3
C-4
1.10 4.82
AP-42 5t Edition, Table11.19.2-2, Conveyor
Transfer Point Factor, 250
tph of Concrete, Total of all 4 conveyors, 8,760 hr/yr
0.0460 0.02
AP-42 5t Edition, Table11.19.2-2, Conveyor TransfePoint (Controlled) Factor, 250
tph of Concrete, Total of all 4conveyors, 1,040 hr/yr
VS 2.18 9.53
AP-42 5t Edition, Table11.19.2-2, ScreeningFactor, 250 tph of Concrete, 8,760 hr/yr
0.185 0.10
AP-42 5t Edition, Table11.19.2-2, Screening(Controlled) Factor, 250 tph oConcrete, 1,040 hr/yr
TOTAL 16.98 0.19
• There are no uncontrolled AP-42 Table 11.19-2.2 Tertiary Crushing, Conveyor Transfer Point and Screening factors for PM2.
TABLE 5. FACILITY -WIDE CRITERIA POLLUTANT EMISSIONS
Pollutant PM2.5
EquipID
PotentialUncontrolled
(lb/hr)
PotentialUncontrolled
(tpy)Basis
PotentialControlled
(lb/hr)
PotentialControlled
(tpy) Basis
CR-1 0.60 2.63
AP-42 5t Edition, Table11.19.2-2, TertiaryCrushing PM10 Factor, 250tph of Concrete, 8,760hr/yr, Assumed all PM10 isPM2.5
0.0250 0.01
AP-42 5th Edition, Table11.19.2-2, Tertiary Crushing(Controlled) Factor, 250 tph oConcrete, 1,040 hr/yr
C-1
C-2C-3C-4
1.10 4.82
AP-42 5t Edition, Table11.19.2-2, Conveyor
Transfer Point Factor 250tph of Concrete, 8,760hr/yr, Total of all 4conveyors, Assumed allPM10 is PM2.5
0.0130 0.01
AP-42 5th Edition, Table11.19.2-2, Conveyor TransfePoint (Controlled) Factor, 25tph of Concrete, Total of all 4conveyors, 1,040 hr/yr
VS 2.18 9.53
AP-42 5t Edition, Table11.19.2-2, ScreeningFactor, 250 tph of Concrete,8,760 hr/yr, Assumed allPM10 is PM2.5
0.0125 0.01
AP-42 5th Edition, Table11.19.2-2, Screening(Controlled) Factor, 250 tph oConcrete, 1,040 hr/yr
TOTAL 16.98 0.03
TABLE 6. FACI LITY WIDE EMISSIONS SUMM ARY
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STATEMENT OF BASIS Page 5 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
Pollutant
Potential Uncontrolled Emissions Potential Controlled
tpy tpy
PM 46.43 0.52
PM10 16.98 0.19
PM2.5 16.98 0.03
REGULATORY APPLICABLILTY REVIEW
FACILITY REGULATORY APPLICABIL ITY REVIEW
RegulationApplicable
Comments Yes No
South Carolina Regulation 61-62.1 through 62.99: Air Pollution Regulations
Section II(E):Synthetic Minor
X This facility emits PM, PM2.5
and PM10which are PSD pollutants. Facility-wide emissions of eachare less than 250 tpy and so no PSD avoidance limits are needed.
Section II(G):Conditional Major
X This facility emits PM2.5 and PM10 which are Title V pollutants The uncontrolled facility-wideemission rate of each of these pollutants is less than 100 tpy.
Standard 1: FuelBurning Operations
X This facility has diesel engines that burn a fuel. Each engine does not meet the definition of a fueburning operation as specified in SC Regulation 61.62.1.
Standard 2: Ambient
Air Quality Standards
X This facility was not required to demonstrate compliance with this standard using air dispersion
modeling. See modeling summary dated June 12, 2012.Standard 3: WasteCombustion/Reduction(state only)
X This regulation applies to sources that combust anything other than virgin fuels for any purpose This facility will only combust diesel fuel in its engines which is virgin fuel.
Standard 3.1: HMIWaste Incinerators
X This facility does not incinerate medical waste.
Standard 4: Emissionsfrom Process Industries X
PM limits for this facility’s processes are not specified elsewhere in the state regulations and soSection VIII is applicable. This facility determined it would have the process as specified in Table8. This section specifies that the following equation be used to determine the process PM limit (E(lb/hr)) for process weight rates greater than 30 tph: E (lb/hr) =((55.0) (P0.11)) - 40) and is listedin Table 7.
Opacity limits for this facility’s process equipment are not specified elsewhere in the state
regulations and so Section IX is applicable. All of this facility’s process equipment was installedafter 1985 and so each is assigned a 20% opacity limit as specified by Section IX(B).
This facility has non-enclosed operations and so the all of the requirements specified by Section Xapply.
All other sections of this regulation do not apply because they apply to types of equipment that thifacility does not have.
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STATEMENT OF BASIS Page 6 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
TABLE 7. SC REGULATION 61-62.5, STANDARD NO.4 PROCESSES
IDOpacity
(%)PM Allowable
(lb/hr)Process WeightRate tph)
Potential PMEmissions
(lb/hr)
Actual PMEmissions
(lb/hr)Monitoring
ConcreteCrushing
20% 60.96 250 10.60 0.99Proper operation of the wet suppressionsystem
FACILITY REGULATORY APPLICABIL ITY REVIEW
RegulationApplicable
Comments Yes No
South Carolina Regulation 61-62.1 through 62.99: Air Pollution Regulations
Standard 5: VolatileOrganic Compounds
X This standard is specific to certain processes. This facility does nor have any of the processoperations that are specified by this regulation and therefore this standard does not apply.
Standard 5.1:BACT/LAER For VOC(state only)
X This facility was initially constructed after J uly 1, 1979. Because this facility wasconstructed after July 1, 1979, it is assigned a LAER baseline VOC limit of zero(0) tpy
This facility will not have any process VOC emissions.
Standard 5.2: Control of Oxides of Nitrogen
The Crusher Engine, Conveyor Engine and Tub Grinder Engine were each constructed in2007and the Horizontal Grinder Engine was constructed in 2012. Each engine meets theexemption specified in Section I(b)(12) for portable engines.
Standard 7: Prevention of
Significant Deterioration X
This facility is not specified as one of the 28 specific industry types and is in the otherindustry type category so the PSD applicability trigger is 250 tpy.
This facility emits PM, PM2.5and PM10which are PSD pollutants. Facility-wide emissionsof each of these pollutants is less than 250 tpy.
Standard 7(c): AmbientAir Increments
X This facility was not required to demonstrate compliance with this standard using airdispersion modeling. See modeling summary dated June 12, 2012.
Standard 7.1: Standardsfor Non Attainment Areas
X This facility is not located in a non-attainment area.
Standard 8: Toxic AirPollutants(state only)
X
In accordance with this standard, the TAP’s emitted from fuel combustion in the dieselengines were not required to be included in the air dispersion modeling used todemonstrate compliance with this standard.
TAP emissions from the grinding process were determined to be de minimis and were notrequired to be included in the air dispersion modeling used to demonstrate compliancewith this standard.
Regulation 61-62.6:Control of FugitiveParticulate Matter
X This facility is a non-enclosed operation which is capable of fugitive PM emissions. Afugitive emission plan required.
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STATEMENT OF BASIS Page 7 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
FACILITY REGULATORY APPLICABIL ITY REVIEW
RegulationApplicable
Comments Yes No
South Carolina Regulation 61-62.1 through 62.99: Air Pollution Regulations
40CFR60- NSPSand Regulation61-62.60: SCDesignated
Facility Plan andNSPS SubpartOOO
X
It was determined that the Concrete Crusher and its associated equipment is subject to 40CFR60Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants).
From 60.671(Definitions) nonmetallic mineral processing plant means any combination of equipment that is used to crush or grind any nonmetallic mineral wherever located, including limeplants, power plants, steel mills, asphalt concrete plants, portland cement plants, or any other facilityprocessing nonmetallic minerals except as provided in 60.670(b) and 60.670(c). 60.670(b) and
60.670(c) do not apply to this facility. Concrete contains some of the non-metallic minerals specifiedin 60.671(Definitions) so this facility’s Concrete Crusher, 4 Concrete Conveyors and VibratoryScreen meet the definition of a non-metallic mineral processing plant.
This equipment was installed in 2007. A summary of the applicable requirements from thisregulation as it applies to this facility’s affected facilities is listed in Table 8.
TABLE 8. SUMM ARY OF APPLICABLE SUBPART OOO AND SUBPART A REQUIREMENTS
EquipID
EmissionLimit
Emission LimitBasis
Emission L imitCompliance
DemonstrationRequirement
ComplianceDemonstration
Basis
Recordkeepingand
Reporting
Recordkeepingand
ReportingBasis
CR-1 15% Opacity60.672(b) and
Table 3 to SubpartOOO
Initial Performance Test for OpacityOnly
60.860.7(a)(6)60.11(b)60.11(e)60.675
Record SSM 60.7(b)
Report results of initial performancetest
60.860.676(f)
Report any like forlike replacements
60.670(d)60.676(a)
C-1C-2C-3C-4
10% Opacityfrom each
transfer point
60.672(b) and Table 3 to SubpartOOO
Initial Performance Test for OpacityOnly
60.860.7(a)(6)60.11(b)60.11(e)60.675
Record SSM 60.7(b)
Report results of initial performancetest
60.860.676(f)
Report any like for
like replacements
60.670(d)
60.676(a)
VS 10% Opacity60.672(b) and
Table 3 to SubpartOOO
Initial Performance Test for OpacityOnly
60.860.7(a)(6)60.11(b)60.11(e)60.675
Record SSM 60.7(b)
Report results of initial performancetest
60.860.676(f)
Report any like forlike replacements
60.670(d)60.676(a)
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STATEMENT OF BASIS Page 8 of 8
BAQ Engineering Services Division2600 Bull Street, Columbia, SC 29201
Phone: 803-898-4123 Fax: 803-898-4079
Company Name:Permit Number:
Pressley’s Recycling1460-0068
Permit Writer: Date:
Kirk SchneiderDRAFT
FACILITY REGULATORY APPLICABIL ITY REVIEW
RegulationApplicable
Comments Yes No
South Carolina Regulation 61-62.1 through 62.99: Air Pollution Regulations
40CFR60 - NSPS andRegulation 61-62.60: SCDesignated Facility Planand NSPS Subpart IIII
X
This facility has 6 diesel engines.60.4200( a) states that the provisions of this subpart areapplicable to manufacturers, owners, and operators of stationary compression ignition (CI)internal combustion engines (ICE). Each of this facility’s engines is a non road engine asdefined in 40 CFR 89 and does not meet the definition of a stationary internal combustionengine as defined in 60.4219 (Definitions).
40CFR61 - NESHAP and Regulation 61-62.61:
NESHAP
X This facility does not have any sources that meet any of the applicability requirements of
all the subparts contained in this regulation.40CFR63 – MACT andArea Source Standards andRegulation 61-62.63: NESHAP For SourceCategories Subpart ZZZZ
X
63.6585 states that an engine is subject to this subpart if the owner/operator owns oroperates a stationary RICE at a major or area source of HAP emissions. Each of thisfacility’s engines is a non road engine as defined in 40CFR89 and does not meet thedefinition of a stationary RICE as defined in 63.6675 (Definitions).
40CFR63 – MACT andArea Source Standards andRegulation 61-62.63: NESHAP For SourceCategories All OtherSubparts
XAll other subparts of this regulation do not apply because this facility does not havesources that meet their applicability requirements.
Regulation 61-62.68:Chemical AccidentPrevention
X This facility will not store any chemicals specified by this regulation above the thresholdquantities required to trigger applicability to this regulation.
Regulation 61-62.70:TitleV
X This facility emits PM2.5and PM10which are Title V pollutants The uncontrolled facility-wide emission rate of each of these pollutants is less than 100 tpy.
Regulation 61-62.72:AcidRain
X This facility does not have any affected sources subject to this regulation.
Regulation 61-62.96: Nitrogen Oxides (NOX) andSulfur Dioxide (SO2)Budget Trading Program
X This facility does not have any affected sources subject to this regulation.
Regulation 61-62.99: Nitrogen Oxides (NOX)
Budget ProgramRequirements forStationary Sources Not Inthe Trading Program
X This facility does not have any affected sources subject to this regulation.
40CFR64 - ComplianceAssurance Monitoring(CAM)
XCAM applies to facilities required to obtain a Title V permit and this facility is notrequired to obtain a Title V operating permit.
SUMMARY AND CONCLUSIONS It has been determined that this source, if operated in accordance with the submitted application, will meet all applicable requirements andemission standards.