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HomeMy WebLinkAboutCorrespondence - 45 BEECHWOOD DRIVE 4/20/2007 COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY &, ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION UV NORTHEAST REGIONAL OFFICE 205B Lowell Street, Wilmington, MA 01887 • (978) 694-3200 DEVAL L. PATRICK IAN A. BOWLES Governor Secretary TIMOTHY P. MURRAY ARLEEN O'DONNELL Lieutenant Governor Commissioner APR 2 0 2007 Mr. James Roberts RE: Final Approval of LPA for L-corn Connectivity Products Non-Fuel Emissions 45 Beechwood Drive L-com Connectivity Products North Andover, Massachuse 1755 Osgood Street North Andover, MA 01845 Transmittal No. W 125509 AN:� 2 6 2007 Application No. MBR-07-IND-003 1 00�,l("JI 1,g)ro l'i ()\/1FR Dear Mr, Roberts: The Metropolitan Boston/Northeast Regional Office of the Department of Environmental Protection (MassDEP), Bureau of Waste Prevention has determined that the referenced Limited Plan Application ("LPA") is administratively complete and in conformance with current air pollution control engineering practices. MassDEP approves the referenced LPA authorizing the installation and operation of a Vertical Injection Molding Machine at the subject facility. Included as part of the LPA Approval are the following: Stamped approved BWP AQ 01-B Application form, General Conditions for Non-Fuel Emission LPAs, Special Conditions, and Appeal Rights. Please review the entire LPA Approval carefully as it stipulates the particular conditions to which the facility owner/operator must adhere for the facility to be constructed/reconstructed/altered and operated in compliance with the Regulations. MassDEP has determined that the filing of an Environniental Notification Form ("ENF") with the Secretary of Environmental Affairs, for air quality purposes, was not required prior to this action by MassDEP. Notwithstanding this determination, the Massachusetts Environmental Policy Act and Regulation 301 CMR 11,00, section 11.04, provide certain "Fail-Safe Provisions" which This information is available in alternate format.Call Donald M.Conics,ADA Coordinator at 617-536-1057.'I'DD Set-vice-1-800-298-2207. littp://Nvww.mass.gov/dep•Fax(978)694-3499 Printed on Recycled Paper L-cam Connectivity Products MBR-07-1ND-003 Transmittal No. W125509 Page 2 of 5 allow the Secretary to require the filing of an ENF and/or Environmental Impact Report at a later time. Should you have any questions concerning this Approval,please contact Mr. Dhiraj Desai at (978) 694-3282. Very truly yours, Dhiraj B. De 4i es E, Belsky Environmental Engineer ermit Chief Bureau of Waste Prevention ureau of Waste evention cc: Board of Health, Town Building,North Andover, MA 01845 Fire Headquarters, 124 Main Street,North Andover,MA 01845 DEP/BWP,E-Copy, Attn: Yi Tian DEP/NERO, T. Parks,M. Persky, D. Desai Attachment: BWP AQ 01-B LPA This information is available in alternate format by calling our ADA Coordinator at(617)574.6972. DEP on the World Wide Web: http:llwww.rnagnet.state.ma.usldep j Printed on Recycled Paper i i L-com Connectivity Products MBR-07-IND-003 Transmittal No. W125509 Page 3 of 5 GENERAL CONDITIONS FOR NON-FUEL EMISSION LPAs 1, Operation - No person shall operate a facility constructed, substantially reconstructed, or altered pursuant to 310 CMR 7.02 except in conformance with the requirements established therein and in conformance with the specific written plan approval requirements, 2. Record keeping - The facility owner/operator shall establish and continue an on-site recording system. All records shall be maintained up-to-date such that year-to-date information is readily available for MassDEP examination. Record keeping shall, at a minimum, include: a) The initiation and completion dates for the proposed construction /reconstruction/ alteration, b) Malfunctions. A record of all malfunctions including, at a minimum; the date and time the malfunction occurred; a description of the malfunction and the corrective action taken; the date and time corrective actions were initiated; and the date and time corrective actions were completed and the facility returned to compliance. C) Records shall be maintained documenting the air contaminant emission analysis supporting the response to B WP AQ 01-B Section-E items 1 a, 1 b and 2. d) All records shall be kept on site for five (5) years from date of record and shall be made available to the MassDEP upon request. 3. The Regional Bureau of Waste Prevention office must be notified by telephone or fax as soon as possible after the occurrence of any upsets or malfunctions to the facility equipment, air pollution control equipment, or monitoring equipment which result in an excess emission to the air and a condition of air pollution. d, The MassDEP must be notified in writing within 30 days of commencement of construction and completion of the approved installation. 5. The MassDEP may revoke, in accordance with 310 CMR 7.02(3)(k), any plan approval if the actual construction has not begun within two years from the date of issuance or if, during the construction,the construction is suspended for the period of one year or more. 6. Reporting - Any construction, substantial reconstruction or alteration, as described in 310 CMR 7.025 at a facility subject to the reporting requirements of 310 CMR 7.12, shall be reported to the MassDEP on the next required source registration. 7. This approval may be suspended, modified, or revoked by the MassDEP if, at any time, the MassDEP determines that the facility is violating.any condition or part of this LPA Approval. The MassDEP shall be notified in writing prior to any modification of the This information is available in alternate format by calling our AAA Coordinator at(617)574-6872. DEP on the World aWide Web: http:IIwww.magnet.state.ma.usldep C 7j Printed on Recycled Paper L-cam Connectivity Products MBR-07-IND-003 Transmittal No. W125509 Page 4 of 5 facility such as a change in raw materials or an increase in production capacity, which may increase emissions, 8. Noise from the facility during construction, initial start-up and routine operation, including start-ups and shutdowns, shall not exceed the MassDEP noise guidelines and shall not cause a condition of air pollution as defined in 310 CMR 7.01 and 7.10. 9. The facility shall be constructed and operated in a manner to prevent the occurrence of dust or odor conditions, which may cause or contribute to a condition of air pollution as defined in 310 CMR 7.01 and 7.09. 10, This Final Approval does not negate the responsibility of owner/operator of the referenced facility to comply with this or any other applicable federal, state, or local regulations now or in the future. Nor does this approval imply compliance with any other applicable federal, state or local regulation now or in the future. 11. Should asbestos removal and/or demolition be required, then said removal or demolition shall be done in full compliance with 310 CMR 7.15 and 310 CMR 7.09. The facility shall notify MassDEP, in writing, at least ten (10) working days in advance of removing any asbestos or performing any demolition." SPECIAL CONDITIONS 1. That L-corn Connectivity Products shall take immediate steps to abate any nuisance condition(s), including but not limited to visible emissions, noise, and odor, that may be generated by the operation of the subject facility. 2. That L-com Connectivity Products shall limit its facility-wide volatile organic compounds (VOC) emissions, hazardous air pollutants (HAP), and particulate matter (PM) emissions each to a total of no more than 1.0 ton per month and 4.5 tons per rolling 12 month period from the subject processes and shall maintain records on-site to demonstrate compliance with these emissions/limitations. 3. That L-corn Connectivity Products shall record the amount of solvent used to clean the machine parts, and the VOC/HAP content of each solvent used each month to calculate the resulting monthly and rolling 12-month facility-wide emissions of VOC/HAP. These records shall be maintained on-site for a minimum of five years and shall be made available for review by MassDEP personnel upon request. 4. That L-com Connectivity Products shall maintain an Environmental Logbook, or equivalent record keeping system, which shall record actions associated with environmental issues and overall emission changes at the facility. The facility shall record information such as the results of federal, state, or local environmental This information is available in alternate format by calling our ADA Coordinator at(617)574-6872. DEP on the World Wide Web: http://www.magnet.state,ma,usidep �� Printed on Recycled Paper L-cam Connectivity Products MB R-07-IND-003 Transmittal No. W1 25509 Page 5 of 5 inspections; and measures taken to Iower overall emissions to the environment (air, solvent waste, etc.). This logbook, or equivalent, shall be made available to MassDEP personnel upon request. 5. That a copy of this Approval letter shall be affixed adjacent to the subject equipment. APPEAL OF APPROVAL This Approval is an action of MassDEP. If you are aggrieved by this action, you may request an adjudicatory hearing. A request for a hearing must be made in writing and postmarked within twenty-one (2 1) days of the date of issuance of this Approval. Under 310 CMR 1.01(6)(b), the request must state clearly and concisely the facts which are the grounds for the request, and the relief sought. Additionally, the request must state why the Approval is not consistent with applicable laws and regulations. The hearing request along with a valid check payable to Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00) must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The request will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described below. The filing fee is not required if the appellant is a city or town (or municipal agency) county, or district of the Commonwealth of Massachusetts, or a municipal housing authority. MassDEP may waive the adjudicatory hearing filing fee for a person who shows that paying the fee will create an undue financial hardship. A person seeking a waiver must file, together with the hearing request as provided above, an affidavit setting forth the facts believed to support the claim of undue financial hardship. This information is available in alternate format by calling our ADA Coordinator at(617)574-6872. DEP on the World Wide Web: http://www.magnet.state.ma.us/dep C*t Printed on Recycled Paper Massachusetts Department of Environmental Protection Bureau of Waste Prevention --Air Quality W125509 Transmittal Number BWP AQ 01 -B Limited Plan Approval • Application for Non-Fuel Emissions Date Received INSTRUCTION s A. Description of Project This form is for approval of 1. L-com Connectivity Products 1755 Osgood Street North Andover, MA. construction, substantial Facility Name Location reconstruction or alteration of any 2 General description of construction, substantial reconstruction, or alteration and exact location within facility which would p result in an the facility. increase in potential emissions greater than or Installation of a vertical Injection molding machine. equal to one ion and less than five tons per 12 month time period of: a. any single criteria contaminant Yuh-Dak _ (Sox,NOx,lead, Manufacturer of affected process equipment* Estimated Maximum Operating Schedule CO,Oione, Particulates or Y350C 8 vocs); Model number* HourlDay or any single non- April 6, 2007 5 criteria air Estimated Instillation Date Days/Week contaminant. 96 molding cycles 1 hour assuming 80%efficiency 48 This form is not to Normal Hourly Production Rate(as%Maximum Hourly Production Rate) WeeksNear be used for combustion sources(see form 3. is the proposed project modifying previously approved equipment? ❑ Yes ® No BWP AQ 01-A). If"Yes", list the previously issued air quality approval(s)for this equipment. Application Number Approval Date For DEP use only Application No Date Received Date Assigned B. Air Pollution Control Equipment None Date 1"Deficiency Type of Air Pollution Control Equipment Date 1"Response Make* Model Number* Reviewer Brief Description Permit: Approved Terminated Decision Date CPA Required: * If undetermined at time of application, indicate probable unit"or equlivianC. Specific make and Yes No model must be provided prior to final approval. ag0103a•rev.7103 AQ 01-B-Page 1 of 4 Massachusetts Department of Environmental Protection L11 Bureau of Waste Prevention —Air Quality W125509 BW P AQ 01 -B Transmittal Number Limited Plan Approval •Application for Non-Fuel Emissions Date Received C. Potential Annual Emissions POTENTIAL EMISSIONS are calculated from the maximum capacity of the equipment to emit pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the equipment to emit a pollutant, including air pollution control equipment, restriction on hours of operation, or on the type or amount of material combusted, stored or processed, shall be treated as part of its design only if the limitation is specifically stated in (a) plan approval(s)or if the facility proposed to incorporate such a restriction into this current Plan.Approval. Fugitive emissions, to the extent quantifiable, are included in determining the potential emissions. Unless otherwise documented, potential emissions shall be based on 8,780 hours per year of source operation. Provide the potential emissions for each pollutant in this section and show calculations, assumptions and restrictions used in section D. Control Pounds Pounds per Pounds per Description of air Description of control Efficiency (after per year year(after year(after contamination source (percent control) control) equipment by weight) control) sox NOx Particulate 1. V.O.C.s NONE 9,000 2. Total HAP NONE 9,000 3. Total Particulate Matter NONE 91000 4. Total potential annual emissions after control Pounds per Stack or Pounds Pounds year(after Vent Pounds per per year per year control)other Number year(after (after (after pollutants control)VOC control) control) (give Circle new HOC Lead chemical (N)or name) Modified(M) 1. (continued) ❑ N ❑ M 2. (continued) ❑ N ❑ M 3. (continued) ❑ N ❑ M 4. (continued) El N [] M Total potential annual emissions after control ag0103a•rev.7103 AQ 01-B•Page 2 of 4 FROM :L.COM INC FAX N©. :9786856467 Apr. 18 2007 04:22PM P3 Massachusetts Department of'Environmental protection Bureau of Waste Prevention —Air Quality w12s�o9 i Transmittal Number BWP AQ 01 -B Limited Plan Approval •Application for Non-Fuel Emissions Date Received D.• Detailed Emission Calculations Use the space,provided below to show the assumptions and the arithmetic used to calculate the Potential Annual Emissions you have estimated for this facility, and.how the increase of less then five tons/year was calculated. (Attach separate sheets if necessary.) Assumptions regarding volume of emissions was determined through conversation with Mung Wong. It is believed that emissions will be much lower than stated on this form as the total weight of resin that will be processed in this facility would be less then 9,000 pounds.The company's plan Is to build odd length cable assemblies'and customs. The primary location for this type of production activity is in China. _ E. Miscellaneous 1. Is this project subject to; Yes No a. Appendix A--Nonattainment review 310 CMR 7.00? ❑ b. Prevention of significant Deterioration Permit(PSD), 40 CFR 52.21? 0 Note:PSD applications are filed with the U.S.Environmental Protection Agency(EPA). c. New Source Performance Standards,40 CFR 60? ❑ If yes,which part d, National Emissions Standards for Hazardous Air Pollutants (NESHAPS), 40 CFR 61? if yes,which subpart e, Maximum Achievable Control Technology(MACT),40 CFR 63? ❑ If yes,which subpart 2. Was netting used to avoid review under 31 O'CMR 7.00 Appendix A or CFR ❑ 52.21? Note:PSD questions Should be directed to EPA. 3. Does the proposed project meet the requirements of Best Available Control Technology(BACT), as required? 4J Brief description AQ 01.5•Page 3 of 4 ago103a•i ev,7103 Massachusetts Department of Environmental Protection Bureau of Waste Prevention —Air Quality W125509 Transmittal Number BWP AQ 01 -B Limited Plan Approval•Application for Non-Fuel Emissions Date Received F. Certification The signature below provides the affirmative demonstration pursuant to 310 GMR 7.02(3)that any facility(ies) in Massachusetts, owned or operated by the proponent for this project(or by an entity controlling, controlled by or under common control with such proponent)that is subject to 310 GMR 7.00, et seq., is in compliance with, or on a Department approved compliance schedule to meet, all provisions of 310 CMR 7.00, et seq., and any plan approval, order, notice of noncompliance or permit issued thereunder. This form must be signed by a.responsible official working at the location of the proposed new or modified facility. Even if an agent has been designated to fill out this form, the responsible official must sign it. (Refer to the definition given in 310 CMR 7.00.) I certify that have examined the responses provided herein and that to the best of my knowledge they are true and complete. James T. Roberts The space below is reserved for the placement Print name of the Department Approval Stamp T ed signature erin Lana �er r=. �_. -� -= ��r ..; � Position title L-com Connectivity Products Representing March 21, 2007 ` Date A-PLU zo V_7Z_ - ag0103a•rev.7103 AQ 01-B•Page 4 of 4