Env-A 1400 Regulated Toxic Air Pollutants Compliance Demonstration Report. University of New Hampshire Durham, New Hampshire Campus

Env-A 1400 Regulated Toxic Air Pollutants Compliance Demonstration Report University of New Hampshire Durham, New Hampshire Campus Prepared for: Univ...
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Env-A 1400 Regulated Toxic Air Pollutants Compliance Demonstration Report University of New Hampshire Durham, New Hampshire Campus

Prepared for: University of New Hampshire 17 Leavitt Lane Durham, NH 03824-3522

December 2000

Env-A 1400 Regulated Toxic Air Pollutants Compliance Demonstration University of New Hampshire Durham, New Hampshire Campus Table of Contents Section I. Introduction A. Overview of Env-A 1400 B. Regulatory Applicability C. Procedures Used to Evaluate Compliance II. A. B. C. D. E. F. G. H. I.

Compliance Demonstration Mechanical/Electrical Maintenance Shop Carpentry Shop Printing Services Architectural Coating Memorial Union Building Copy Center Service Building Vehicle Maintenance Shop Grounds and Roads Garage Conclusion

Attachments A. Printing Services CY1999 RTAP Usage Summary B. Printing Services CY1999 Estimated RTAP Emission Rates C. Sample Adjusted In Stack Concentration Calculation: 1,2,4-Trimethyl Benzene D. Adjusted In Stack Concentration Analysis

Page 1 1 2 2 3 3 3 4 4 4 5 5

Env-A 1400 Regulated Toxic Air Pollutants Compliance Demonstration Report University of New Hampshire Durham, New Hampshire Campus I. Introduction A. Overview of Env-A 1400 The New Hampshire Department of Environmental Services, Air Resources Division (NHDES-ARD) is charged with administering Chapter Env-A 1400, Regulated Toxic Air Pollutants (RTAPs), of the New Hampshire Rules. Pursuant to Env-A 1400, new and existing sources that emit any of approximately 750 listed RTAPS must demonstrate compliance with established ambient air limits (AALs). The AALs are applicable at and beyond a source’s property boundary. If a source can demonstrate that uncontrolled RTAP emissions from a device or process comply with their 24-hour and annual AALs, a permit for the operation of the source is not required. Sources unable to show compliance with an AAL without the use of controls must submit an application to NHARD identifying how the device or process will come into compliance. The rule exempts certain emission units, such as combustion sources burning virgin fuel, from the requirements of Env-A 1400. For non-exempt emission units, three methods are provided in Env-A 1400 for demonstrating compliance with the AALs. They include: 1. Deminimus Emission Level Method – uncontrolled facility-wide RTAP emission levels are shown to be below established deminimus thresholds for 24-hour average and annual emission rates; 2. Adjusted In-Stack Concentration Method – uncontrolled RTAP in-stack exhaust concentrations from emission units at a facility are shown to be below 24-hour average and annual AALs by using a prescribed manual calculation, which includes the RTAP emission rate and process exhaust flow rate as input parameters; and, 3. Air Dispersion Modeling Analysis – uncontrolled RTAP impacts from a source at or beyond the property boundary are shown to be below 24-hour average and annual average AALs using a computer modeling analysis. B. Regulatory Applicability to the University of New Hampshire On May 18, 2000, NMC Environmental Group (NMC) conducted a campus wide Env-A 1400 applicability audit at the University of New Hampshire, Durham (UNH) to determine the activities and processes that may emit RTAPs into the ambient air. The following activities and/or processes were identified on campus as having the potential to release RTAPs into the ambient air:

Env-A 1400 Compliance Demonstration Report University of New Hampshire

     





December 12, 2000 Page 2

Mechanical/Electrical Maintenance Shop o Spray Paint Hood o Welding Hoods (2) Carpentry Shop Printing Services Architectural Coating Memorial Union Building Copy Center Service Building o Furniture Woodworking Devices o Natural Gas Fired Kiln o Electric Kilns (4) Vehicle Maintenance Shop o Vehicle Touch-up Painting o Waste Oil Burner o Solvent Degreaser Grounds and Road Garage o Solvent Degreaser

Each activity or process is discussed in further detail in Section II. C. Procedures Used to Evaluate Compliance Based on the aforementioned applicability audit and MSDS provided by UNH, NMC identified RTAPs potentially emitted from emission sources on campus. NMC determined that the majority of emission sources on campus were exempt pursuant to Env-A 609.03. NMC demonstrated compliance for Printing Services using the adjusted in-stack concentration method. Pursuant to the requirements of Env-A 1400, this compliance demonstration report will remain on file at the University of New Hampshire and, upon request, will be made available to the NHARD for inspection. If any modifications or additions are made to the processes or raw materials, the University of New Hampshire will review such changes for applicability to Env-A 1400 and will modify this compliance demonstration report as necessary. II. Compliance Demonstration A. Mechanical/Electrical Maintenance Shop Two activities were identified in the maintenance shop that have the potential to emit RTAPs into the ambient air: a spray paint hood and two welding hoods. NMC assessed the amount of spray paint used by this department and confirmed that the monthly amount of paint used is approximately 10 cans. It is NMC’s determination that the spraypainting activity is exempt under Env-A 609.03(c)(16) as a use of consumer products in a manner consistent with how the general public would use the product.

Env-A 1400 Compliance Demonstration Report University of New Hampshire

December 12, 2000 Page 3

The welding operation at the mechanical maintenance shop is classified as exempt pursuant to Env-A 609.03(c)(5), as a maintenance activity. B. Carpentry Shop Particulate matter (i.e., wood dust) emissions at UNH’s carpentry shop are controlled by an AGET Model 60N70-P Dust Collector and an AGET Model FH-58-D1 FILTERKOP baghouse. The dust control system re-circulates air into the carpentry shop and maintains a particulate removal efficiency of 100% above 0.5 microns. Based on the level of control and the fact that the system is vented internally, the carpentry shop at UNH is exempt under Env-A 609.03(c)(14). C. Printing Services UNH provided a summary of products currently used in the Printing Services at UNH. NMC reviewed the MSDS for each product to identify any RTAPs contained in the material. Attachment A lists the products, associated RTAPs, product usage rate for CY1999, product density and the product RTAP emission rate currently used in UNH’s Printing Services. Attachment B contains MSDS for each of the products currently used in Printing Services. Attachment C provides a summary of individual estimated RTAP emission rates based on actual material usage in CY1999. With the exception of carbon black, all the RTAPs are considered to completely volatilize during the printing process. Based on discussions with the ink manufacturer, the carbon black contained in the inks is completely transferred to the printing substrate, with no potential for volatilization or fugitive particulate emissions. For each volatile RTAP, NMC calculated the adjusted in-stack concentration as outlined in Env-A 1406.04 for the 24-hour average and annual average AALs. In order to calculate the 24-hour average AAL, NMC based its calculation on an operations schedule of 2,210 hours per year (8.5 hours/day, 5 days per week and 52 weeks/year). Because NMC calculated the adjusted in-stack concentrations using actual emissions rates, ARD policy requires compliance be demonstrated by comparing the concentrations to 50% of the respective AAL. Attachment D presents a sample calculation of the adjusted in stack concentration analysis for 1,2,4-Trimethyl Benzene. Attachment E, tables A-1 and A-2, demonstrates that the adjusted in-stack concentration for each RTAP emitted from UNH’s Printing Services is below 50% of the respective AAL. Thus, current operations at UNH Printing Services are in compliance with Env-A 1400. As new or reformulated products are brought into use, compliance with Env-A 1400 will be reassessed and findings updated. D. Architectural Coating Based on an assessment of exterior painting practices at the UNH campus and an inventory of product use for architectural coating purposes, NMC concludes that this activity is exempt from an RTAP compliance demonstration per Env-A 609.03(c)(16), as

Env-A 1400 Compliance Demonstration Report University of New Hampshire

December 12, 2000 Page 4

a use of consumer products in a manner consistent with how the general public would use the product. UNH estimates that for CY1999 architectural coating activities utilized approximately 125 gallons water-based paint and 20 tubes of latex caulking. E. Memorial Union Building Copy Center All activity at the MUB Copy Center is exempt from an RTAP compliance demonstration under Env-A 609.03(c)(2). There are no printing or gluing operations at the MUB copy center. F. Service Building UNH’s service building houses a furniture woodworking operation that is used by students and faculty for various projects. All woodworking equipment, including saws, sanders, and shapers, have vacuum hoses at the device which are ducted through a cyclone behind the building. In addition, approximately 10 gallons of varnish are purchased and used for wood finishing purposes. The varnish is applied manually. Based on the amount of varnish used, the method of application, and the infrequent schedule, NMC has determined that the woodworking operation housed in the Service Building is exempt from an RTAP compliance demonstration per Env-A 609.03(c)(16), as a use of consumer products in a manner consistent with how the general public would use the product. In addition to the woodworking facility, the UNH Service Building also houses art studios for various medias, including painting, sculpture, and pottery/ceramics. During the on-campus air toxics compliance inspection, a natural gas fired kiln and four electric kilns were noted. These kilns are used to dry pieces of clay pottery and ceramics. Based on information provided by UNH Art Department personnel, the various water-based glazes, which are applied to clay objects prior to being kiln dried, are mixed on campus and contain no metallic component. As a result, NMC concludes that this activity does not release any RTAPs. G. Vehicle Maintenance Shop Based on an inventory of spray painting practices at the Vehicle Maintenance Shop, NMC concludes that this activity is exempt from an RTAP compliance demonstration per Env-A 609.03(c)(16), as a use of consumer products in a manner consistent with how the general public would use the product. Specifically, UNH estimates the use of spray paint to be less than one can per week and two cases of twelve-ounce spray paint per year. UNH operates a waste oil combustor to provide space heat in the Vehicle Maintenance Building. The waste oil burner is a Fornax model FX-210 with a maximum heat input capacity of 210,000 btu/hr. The waste oil combustor burns used crankcase oil only and has a maximum firing rate of 1.5 gallons per hour. The inside diameter of the exhaust stack is 7 inches. The exhaust stack outlet is 25 feet above ground level and does not have a cap. The waste oil combustor receives regular maintenance and is operated according to manufacturers specifications.

Env-A 1400 Compliance Demonstration Report University of New Hampshire

December 12, 2000 Page 5

Typically, the waste oil combustion unit at the UNH maintenance garage operates from November through April. Personnel from the maintenance garage estimate that approximately 500 gallons of waste oil was burned during the 1999/2000 heating season. Because the emissions from the combustion of waste oil are directly related to the constituents of the oil, UNH had an analysis of the waste oil performed by an independent laboratory (results are in Attachment F). Based on the analysis, the waste oil meets the definition of specification waste oil. NHARD has informed NMC that the owner of a waste oil combustor can demonstrate compliance with Env-A 1400 if a waste oil combustion unit meets all of the criteria listed below. This policy will be issued in a forthcoming letter from the NHARD (refer to Attachment G).       

Heat input capacity of 500,000 Btu/hr or less; Maximum fuel use of 3.6 gallons/hour or less; Annual waste oil consumption of 8,640 gallons or less; Inside diameter of the exhaust stack of 8 inches or less; Vertical exhaust stack with no cap or other obstruction; Stack outlet 20 feet AGL or higher; Emission unit operated according to manufacturer’s specifications.

In addition to these criteria, the facility must keep records of annual waste oil usage. NMC has determined that the waste oil combustor maintained and operated by the UNH maintenance garage meets all of the listed criteria and is, therefore, in compliance with Env-A 1400. UNH operates a cold cleaning solvent degreaser in the Vehicle Maintenance Building for cleaning small parts and tools that is maintained by an outside contractor. In January 2000 UNH switched from an RTAP containing solvent to an aliphatic petroleum distillate based solvent bath for parts cleaning which does not contain a listed RTAP and, therefore, is in compliance with Env-A 1400. H. Grounds and Roads Garage UNH also operates a cold cleaning solvent degreaser in the Grounds and Roads Garage for cleaning small parts and tools. The solvent degreaser is maintained by an outside contractor. The degreaser is equipped with a cover and uses an aliphatic petroleum distillate based solvent bath for parts cleaning which does not contain a listed RTAP and, therefore, is in compliance with Env-A 1400. I. Conclusion Based on the information presented above, it is UNH’s contention that the audit for applicability and compliance with Env-A 1400 has been extensive and complete. In addition, UNH maintains that the use of laboratory ventilation hoods is an exempt activity under Env-A 609.03(c)(15) and has thus not been considered in this Env-A 1400 audit. UNH will maintain this summary report as on file documentation of the compliance demonstration with Env-A 1400 ambient air limits. Attachment H contains a

Env-A 1400 Compliance Demonstration Report University of New Hampshire

December 12, 2000 Page 6

letter from NHARD, which states that the findings of this Env-A 1400 compliance demonstration of campus activities and processes are satisfactory.

University of New Hampshire Attachment A

December 2000 Page 1

University of New Hampshire Printing Services CY1999 RTAP Usage Summary Product/RTAP

CAS

Press Wash PWM Special Aliphatic Hydrocarbon Xylene Cumeme 1,2,4-Trimethyl Benzene

8052-41-3 1330-20-7 98-82-8 95-63-6

Tame E.C. 2-Butoxyethanol Isopropyl Alchohol

111-76-2 67-63-0

ARS-JP 2-Butoxyethanol

111-76-2

Emerald JRZ 2-Butoxyethanol Acetic Acid

111-76-2 64-19-7

Rapid One Step Glaze Remover Dipropylene Glycol Methyl Ether Propylene Glycol Monoethanol Amine Color Wash #1 (two step) Naphthalene Diethanolamine

CY1999 Usage Rate (gallons)

Density (lbs/gal)

220

6.87

4

20

12

2

95.0% 3.0% 2.0% 10.0%

1,435.8 45.3 30.2 151.1

2.8% 5.0%

1.0 1.8

54.15%

85.6

5% 7.66%

5.3 8.2

38% 38% 38%

5.2 5.2 5.2

1.3% 3%

1.8 4.2

2%

0.36

30%

63.0

20%

13.8

5% 5% 3% 55% 3% 10% 5%

0.34 0.34 0.20 3.76 0.20 0.68 0.34

7.9

8.9

6.9

6.98

91-20-3 111-42-2

Color Wash #2 (two step)

CY1999 Emission Rate (lbs/yr)

9.2

34590-94-3 107-98-2 141-43-6 20

Composition (% RTAP)

20

6.42

2

9.08

No RTAPs Padding Compound Ethylene Glycol

107-21-1

Quickson Special Intense Black Carbon Black

1333-86-4

23.9

Quickson Special Colors

8.78

50.3

8.85

7.52

9.16

No RTAPs TK Hyplus Process Series Carbon Black

1333-86-4

Blanket Hardener JK-162 Methyl Alchohol Hexylene Glycol Toluene Xylene Ethylbenzene n-Butyl Acetate Methyl Isobutyl Ketone

67-56-1 107-41-5 108-88-3 1330-20-7 100-41-4 123-86-4 108-10-1

1

6.83

NMC Environmental Group

University of New Hampshire Attachment B

December 2000 Page 2

University of New Hampshire Printing Services CY1999 Estimated RTAP Emission Rate RTAP 1,2,4-Trimethyl Benzene 2-Butoxyethanol Acetic Acid Aliphatic Hydrocarbon Carbon Black Cumeme Diethanolamine Dipropylene Glycol Methyl Ether Ethylbenzene Ethylene Glycol Hexylene Glycol Isopropyl Alchohol Methyl Alchohol Methyl Isobutyl Ketone Monoethanol Amine Naphthalene n-Butyl Acetate Propylene Glycol Toluene Xylene

CAS

CY1999 Emission Rate (lbs/yr)

95-63-6 111-76-2 64-19-7 8052-41-3 1333-86-4 98-82-8 111-42-2 34590-94-8 100-41-4 107-21-1 107-41-5 67-63-0 67-56-1 108-10-1 141-43-6 91-20-3 123-86-4 107-98-2 108-88-3 1330-20-7

151.1 91.9 8.2 1,435.8 76.8 30.2 4.2 80.3 0.20 0.36 0.34 1.84 0.34 0.34 5.20 1.81 0.68 5.20 0.20 49.10

NMC Environmental Group

University of New Hampshire Attachment C

December 2000 Page 1

Sample Adjusted In Stack Concentration Calculation 1,2,4-Trimethyl Benzene (1) Based on Env-A 1406.04, the equations to calculate the annual adjusted in-stack concentration are as follows: Equation 1. Y = X/7.94 X is the emissions rate in lbs/hr Y is the emissions rate in grams/sec Annual Emissions: Based on use of Press Wash PWM Special Annual Emission = 151.1 lbs/year of 1,2,4-Trimethyl Benzene Based on 365 days/year (8,760 hrs/year), the actual annual average emission rate (X) for 1,2,4-Trimethyl Benzene is as follows: =(151.1 lbs/year) / (8,760 hrs/year) =1.73e-02 lbs/hr. Equation 2. Z = Y * 106 Z is the emissions rate in ug/s Z for the annual AAL for 1,2,4-Trimethyl Benzene: Z = (1.73e-02/7.94) * 106 = 2,178 ug/s Equation 3. B= A/2,119 A is the stack volume flow in actual cubic feet per minute B is the stack volume flow in actual cubic meters per second B = 1,800 acfm/2,119 = 0.85 m3/s Equation 4. In-stack concentration = Z/B = (2,178 ug/s) / (0.85 m3/s) = 2,562 ug/m3 Equation 5. Adjusted in-stack concentration = (In-stack concentration /100) Adjusted in-stack concentration = (2,562 ug/m3)/100 = 25.62 ug/m3 The equation used to calculate the 24-hr adjusted in-stack concentration is as follows: Equation 6. 24-hr Adjusted in-stack concentration = (Annual adjusted in-stack concentration) x (8,760/2,210) = (25.58 x (8,760 hrs/year / 2,210 hrs/year)) = 101 ug/m3 (1) Note that any discrepancies between the sample calculation and the calculation in the spreadsheet in Attachment E occurs as a result of round off error. NMC Environmental Group

University of New Hampshire Env-A 1400

December 2000

Printing Services University of New Hampshire, Durham, NH Adjusted In-stack Concentration Calculations 24-Hr Average Exhaust System Air Flow (acfm) "A"

1,800

Exhaust System Air Flow (m3/s) "B" (1)

0.85

RTAP

1,2,4-Trimethyl Benzene 2-Butoxyethanol Acetic Acid Aliphatic Hydrocarbon Cumene Dipropylene Glycol Methyl Ether Ethylene Glycol Isopropanol Monoethanol Amine Propylene Glycol Xylene

CAS #

95-63-6 111-76-2 64-19-7 8052-41-3 98-82-8 34590-94-8 107-21-1 67-63-0 141-43-5 107-98-2 1330-20-7

24-Hr AAL μg/m3

619 432 126 2,641 1,237 3,048 503 4,945 27 2,000 1,550

RTAP Emissions lb/year

9.60E+00 5.25E+01 7.10E+00 5.63E+01 7.00E-01 2.98E+01 1.50E-01 1.84E+00 1.00E-02 1.00E-02 6.90E-01

"X" (2) RTAP Emissions

"Z" (3) RTAP Emissions

"ISC"

"AISC" ISC/100 Adjusted In-stack Conc. μg/m3

lb/hr

μg/sec

Z/B In-stack Conc. μg/m3

(24-Hr)

(24-Hr)

(24-Hr)

(24-Hr)

4.34E-03 2.38E-02 3.21E-03 2.55E-02 3.17E-04 1.35E-02 6.79E-05 8.33E-04 4.52E-06 4.52E-06 3.12E-04

5.47E+02 2.99E+03 4.05E+02 3.21E+03 3.99E+01 1.70E+03 8.55E+00 1.05E+02 5.70E-01 5.70E-01 3.93E+01

6.44E+02 3.52E+03 4.76E+02 3.78E+03 4.70E+01 2.00E+03 1.01E+01 1.23E+02 6.71E-01 6.71E-01 4.63E+01

6 35.2 4.8 38 0.5 20.0 0.101 1.23 0.01 0.01 0.5

1

B = actual cubic feet per minute / 2,119.

2

Based on 2,210 hours per year of operation: 52 weeks @ 5 days/week @ 8.5 hours/day

3

Z = X/(7.94*1,000,000).

4

Per NHARD policy, comparison is with 50% of AAL since RTAP emission rate is calculated as an actual rate.

24-Hr AAL (4)

Compliance Demonstated (yes/no)

310 216 63 1,321 619 1,524 252 2,473 14 1,000 775

yes yes yes yes yes yes yes yes yes yes yes

50% of

University of New Hampshire Env-A 1400

December 2000

Printing Services University of New Hampshire, Durham, NH Adjusted In-stack Concentration Calculations Annual Average Exhaust System Air Flow (acfm) "A"

1,800

Exhaust System Air Flow (m3/s) "B" (1)

0.85

RTAP

1,2,4-Trimethylbenzene 2-Butoxyethanol Acetic Acid Aliphatic Hydrocarbon Cumene Dipropylene Glycol Methyl Ether Ethylene Glycol Isopropanol Monoethanol Amine Propylene Glycol Xylene

CAS #

95-63-6 111-76-2 64-19-7 8052-41-3 98-82-8 34590-94-8 107-21-1 67-63-0 141-43-5 107-98-2 1330-20-7

"ISC" Annual AAL μg/m3

412 288 84 1,761 400 2,032 335 3,296 18 2,000 1,033

RTAP Emissions lb/year

9.60E+00 5.25E+01 7.10E+00 5.63E+01 7.00E-01 2.98E+01 1.50E-01 1.84E+00 1.00E-02 1.00E-02 6.90E-01

"X" (2) RTAP Emissions

"Z" (3) RTAP Emissions

"AISC"

lb/hr

μg/sec

Z/B In-stack Conc. μg/m3

(Annual)

(Annual)

(Annual)

(Annual)

1.10E-03 5.99E-03 8.11E-04 6.43E-03 7.99E-05 3.40E-03 1.71E-05 2.10E-04 1.14E-06 1.14E-06 7.88E-05

1.38E+02 7.55E+02 1.02E+02 8.09E+02 1.01E+01 4.28E+02 2.16E+00 2.65E+01 1.44E-01 1.44E-01 9.92E+00

162 889 120 953 12 504 2.5 31.1 0 0 12

1.62 9 1.2 10 0.12 5.04 0.025 0.311 0.00 0.00 0.12

1

B = actual cubic feet per minute / 2,119.

2

X is calculated using 8,760 hours per year of continuous operation.

3

Z = X/(7.94*1,000,000).

4

Per NHARD policy, comparison is with 50% of AAL since RTAP emission rate is calculated as an actual rate.

ISC/100 Adjusted Compliance In-stack Conc. 50% of Demonstated Annual AAL (4) (yes/no) μg/m3

206 144 42 881 200 1,016 168 1,648 9 1,000 517

yes yes yes yes yes yes yes yes yes yes yes