HomeMy WebLinkAboutMiscellaneous - 351 HOLT ROAD 4/30/2018 (5)MassDEP
Charles D. Baker
Governor
Karyn E. Polito
Lieutenant. Governor
Commonwealth of Massachusetts
Executive Office of Energy & Environmental Affairs
Department of Environmental Protection
Northeast Regional Office • 205B Lowell Street, Wilmington MA 01887.978-694-3200
June 29, 2017
Mr. Lon Bartoli
Lifoam Industries, LLC
351 Holt Road
North Andover, MA 01845
Dear Mr. Bartoli:
RECEIVED
JUL 0'5 2017
TOWN OF NORTH ANDOVER
HEALTH DEPARTMENT
RE: NORTH ANDOVER
Transmittal No.: X273896
Application. No.: NE -17-002
Class: SM80-7
IMF No.: 581820
AIR QUALITY PLAN APPROVAL
Matthew A. Beaton
Secretary
Martin Suuberg
Commissioner
The Massachusetts Department of Environmental Protection ("MassDEP"), Bureau of Air and
Waste, has reviewed your Non -major Comprehensive Plan Application ("Application") listed
above. This application concerns the proposed installation and operation of fourteen new molding
machines, a new pre -expander, and a new bead storage room which will all be controlled with a
regenerative thermal oxidizer (RTO) at your new facility located at 351 Holt Road in North
Andover, Massachusetts ("Facility"). The submitted application bears the seal and signature of Ms.
Stacy Lynn Braga, Massachusetts P.E. No. 52938.
This Application was submitted in accordance with 310 CMR 7.02 Plan Approval and Emission
Limitations as contained in 310 CMR 7.00 "Air Pollution Control," regulations adopted by
MassDEP pursuant to the authority granted by Massachusetts General Laws, Chapter 111,
Section 142 A -O, Chapter 21C, Section 4 and 6, and Chapter 21E, Section 6. MassDEP's review
of your Application has been limited to air pollution control regulation compliance and does not
relieve you of the obligation to comply with any other regulatory requirements.
MassDEP has determined that the Application is administratively and technically complete and
that the Application is in conformance with the Air Pollution Control regulations and current air
pollution control engineering practice, and hereby grants this Plan Approval for said
Application, as submitted, subject to the conditions listed below.
Please review the entire Plan Approval, as it stipulates the conditions with which the Facility
owner/operator ("Permittee") must comply in order for the Facility to be operated in compliance
with this Plan Approval.
This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751.
TTY# MassRelay Service 1-800-439-2370
MassDEP Website: www.mass.gov/dep
Printed on Recycled Paper
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 2 of 21
1. DESCRIPTION OF FACILITY AND APPLICATION
Lifoam Industries, LLC (the "Permittee") proposes to manufacture expandable polystyrene
(EPS) foam products for various customers such as those engaged in the fishing and food
industries. The manufacturing operations at the new Facility will use an EPS bead that
contains pentane, a volatile organic compound (VOC). The pentane in the bead will be used
as a blowing agent to expand the polystyrene before and during product molding.
The proposed facility will consist of a pre -expander (EU-PREX1), aging and re -grind bags
located in a new aging room (EU -ARI), and up to fourteen EPS molding machines
(EU-MLD1, EU-MLD2, EU-MLD3, EU-MLD4, EU-MLD5, EU-MLD6, EU-MLD7,
EU-MLD8, EU-MLD9, EU -MLD 10, EU -MLD 11, EU -MLD 12, EU -MLD 13, EU -MLD 14).
The facility will also include a new Cleaver -Brooks process steam boiler (EU-CBB1), a
Cleaver -Brooks secondary process steam boiler (EU-CBB2), and an emergency generator
(EU -EG). None of the combustion equipment is subject to plan approval since they either
fall below MassDEP's Air Quality permitting thresholds or will be certified via the
Environmental Results Program (ERP); however, the potential emissions from this
equipment will be incorporated into the facility's potential emission limits found in Table 2
below.
Process steam will be provided to the pre -expander and the EPS molding machines
(e.g., manufacturing operations) by EU-CBB1 and EU-CBB2. EU-CBB2 will also
provide supplemental process steam for the manufacturing operations whenever needed.
These boilers will utilize natural gas as their sole fuel source.
The manufacturing process will begin with receiving the EPS beads, typically in 2,200
pound totes. The beads will be manually transferred to a holding tank or `.`bead bin". The
beads will then be pneumatically transferred to the pre -expander where the raw beads will
be heated with direct contact steam and expanded to 30 to 40 times their original size. The
expanded beads then will be pneumatically transferred to one of up to twenty five (25)
storage bags located in EU -ARI, where they will be aged for a period of 6 to 48 hours
("pre -puff stage").
As the EPS beads are transferred from EU-PREX1 to EU -ARI, they passively cool to
approximately ambient temperature. The aging bags will allow air to enter the bead cells
and equilibrate between the top and a small vent on the bottom so that air can pass over the
beads, but may be replaced with open mesh aging bags to allow for free flow of pentane out
of the silos (bags) into the permanent total enclosure (PTE) space of EU -ARI. Pentane
released from the aging bags account for approximately 20% of the total incoming pentane,
based on a compliance test performed from October 20 - 22, 2015 at Lifoam's former
manufacturing location. Since pentane is approximately 2.5 times heavier than air, pentane
released from the EPS beads during the bead aging process sinks to the bottom of the aging
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 3 of 21
rooms/bags. Captured pentane emissions from EU-PREX1 and EU-ARl are conveyed by
centrifugal blowers to a regenerative thermal oxidizer (RTO), specifically to a Ship and
Shore Model No. SSE -98X -7.5K RTO (PCD -RTO) for control.
After aging in the bead storage bags, the beads are pneumatically transferred to enclosed
hoppers, which are attached to the molding machines. The beads are then transferred into
the mold where steam is added to form the molded products. The molding machines have
been modified so that they exhaust to a vacuum capture system during molding. The
steam/air mixture is drawn off the molds, and passed through an air/water separator. The
steam condenses to water, leaving the press through a drain line and gravity fed to the
cooling water system reservoir. Water from the cooling water system is pumped back to the
molding machines where it is used for cooling the parts after they are molded as well as for
condensing exhaust steam and cooling hydraulics and equipment.
During the molding process, the EPS material is enclosed within the press. The Permittee
estimates that 95 percent, by weight (based on emissions testing and mass balance
measurements), of the process pentane emissions from the pre -expander, the aging room,
and the fourteen molding machines will be captured and sent PCD -RTO for control.
The molded EPS products are then stored within the facility's warehouse prior to shipment
to the customer. Approximately half of the VOC emissions released from the stored product
occur during the first four weeks of storage. Assuming if all of the residual pentane in the*
life of the finished EPS product was to be emitted, this amount would equate to up to
28.2 tons per year (TPY) of VOC emissions based on the maximum consumption of
5,130,000 pounds per year of raw EPS beads with a rolling twelve month average pentane
content of 5.5 percent by weight. This is a conservative estimate of these fugitive pentane
emissions since there still is a significant amount remaining pentane in the shipped product.
Two new centrifugal blowers with a combined rated capacity of at least 7,500 standard
cubic feet per minute (scfin) will collect VOC laden gases from the collection header which
will maintain a negative pressure in the emission unit capture headers serving, each of the
following emission units: EU-PREXI, EU -ARI, and EU-MLD1 through EU -MLD 14.
PCD -RTO will have a rated air flow capacity of at least 7,500 scfin. PCD -RTO will be
equipped with a burner which will burn natural gas as the only fuel of use at a designed
energy input capacity of at least 3.1 million. British thermal units per hour (MMBtu/hr).
Under normal operating conditions, the set point of PCD -RTO operating temperature will be
approximately 1515 degrees Fahrenheit (°F), in order to maintain the minimum operating
temperature of 1,500 OF, or such other temperature as may be established pursuant to
satisfactory compliance testing results as determined by MassDEP. The effective volume of
each combustion chamber within PCD -RTO is approximately 508 cubic feet which is
designed to provide a minimum retention time of greater than 0.5 second at an operating
temperature of 1,500 OF. Thermocouples will be located within each of the two combustion
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 4 of 21
chambers. A temperature chart recorder and a data logger will continuously monitor and
record the actual operating temperature of PCD -RTO as one (1) minute averages.
PCD-RTO's VOC destruction efficiency will be 99 percent of the process air captured or a
maximum outlet VOC emission rate of 0.30 pounds per hour, whichever is less stringent.
This will be demonstrated through future compliance testing as specified in Table No. 3,
Paragraph No. 7. In the event of an emergency shutdown of PCD -RTO, the molding
machines will stop production and the process air in the aging room will be re -circulated
until such time that PCD -RTO is operating properly again.
During nonproduction periods such as weekends when PCD -RTO and EPS bead processes
are not in operation or whenever PCD -RTO is down for maintenance, pentane emissions
will be re -circulated within EU -ARI until bead processing resumes. Each aging room is
equipped with Lower Explosive Level (LEL) monitors with an emergency set point of up to
25 percent of the LEL or 3,750 parts per million (ppm) pentane, and two TRI Model CV9-
36 axial fan systems for emergency ventilation. Should this upset condition take place, an
audible alarm shall sound and notify Lifoam personnel via electronic notification. In
addition, a data logger shall automatically record the date, time, and the length of time the
emergency system had been activated.
The Permittee also will be installing and operating up to four (4) American World Trade
Group AWT Cameo 18 -CB screen printing machines, or equivalent, to apply printing to
some molded EPS products. These four screen printing machines will generate less than
0.3 ton per year of VOC emissions.
The Permittee has indicated that the Project may be subject to the Federal New Source
Performance Standards (HSPS) for Small Industrial -Commercial -Institutional Steam
Generating Units (40 CFR Part 60 Subpart Dc).
The Permittee has indicated that the Project may be subject to 40 CFR Part 63, Subpart
ZZZZ, National Emission Standards for Hazardous Air Pollutants (NESHAPs) for
Stationary Reciprocating Internal Combustion Engines. Since the Permittee's Facility is an
area source for HAPs and is defined as an institution, compliance with 40.CFR Part 63,
Subpart ZZZZ shall be met by complying with the requirements of 40 CFR Part 60,
Subpart JJJJ, "Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines".
MassDEP is not the delegated authority for these federal regulations since this facility will
be a non -major Air Quality source and not subject to MassDEP's Operating Permit
Program.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 5 of 21
2. EMISSION UNIT (EU) IDENTIFICATION
Each Emission Unit (EU) identified in Table 1 is subject to and regulated by this Plan Approval:
Table 1
Maximum Design
Pollution Control
EU#
Description
Capacity
Device (PCD)
EU-PREX1
Hirsch Model No.
1,097 lbs/hr
PREEX6000XXL new pre -
expander, or equivalent
EU -ARI
Aging room with aging bags and
649 lbs/hr
re -grind bags
EU -MLD 1
EU-MLD2
EU-MLD3
Ship and Shore Model No.
EU-MLD4
SSE -98X -7.5K RTO
EU-MLD5
(PCD -RTO)
EU-MLD6
EU-MLD7
14 new Hirsch Model No. HSI 400
43 lbs/hr per molding
EU-MLD8
molding machines, or equivalent
machine
EU-MLD9
EU -MLD 10
EU -MLD 11
EU -MLD 12
EU -MLD 13
EU -MLD 14
EU -SPI
4 American World Trade Group
N/A
EU-SP2
AWT Cameo 18 -CB screen printing
None
EU-SP3
machines, or equivalent
EU-SP4
EU-CBB 1
Cleaver -Brooks Model No.
16.75 MMBtu/hr
CBLE700-400-150 boiler, or
equivalent
None
EU-CBB2
Cleaver -Brooks Model No.
8.375 MMBtu/hr
CB40-300 boiler, or equivalent
EU -EG
[,
Existing Kohler Model No.
50 kW output
20RESA emergency generator
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 6 of 21
Table 1 Key:
RTO = regenerative thermal oxidizer
EU# = Emission Unit Number
PCD = Pollution Control Device
lbs/hr = pounds per hour
MMBtu/hr = million British thermal units per hour
N/A = not applicable
No. = number
kW =kilowatt
3. ' APPLICABLE REQUIREMENTS
A. OPERATIONAL, PRODUCTION and EMISSION LIMITS
The Permittee is subject to, and shall not exceed the Operational, Production, and
Emission Limits as contained in Table 2 below:
Table 2
EU#
Operational /
Air Contaminant
Emission Limit
Production Limit
Maximum pentane content
of EPS beads shall not
exceed 5.7 percent by
EU-PREX1
weight.
EU -ARI
EU-MLD1
Twelve month rolling
EU-MLD2
average pentane content of
EU-MLD3
EPS beads shall not exceed
EU-MLD4
5.5 percent by weight.
Minimum VOC destruction efficiency
EU-MLD5
of 99 percent by weight or a maximum
EU-MLD6
Maximum throughput of
outlet VOC emission rate of 0.30
EU-MLD9
EPS beads shall not exceed:
pounds per hour, whichever is less
EU-MLD10
• 1,068,750 pounds of
VOC
stringent
EU -MLD 11
pentane beads per
EU-MLD7
month and
EU-MLD8
• 5,130,000 pounds of
EU-MLD12
pentane beads over
EU -MLD 13
any consecutive
EU-MLD14
twelve month rolling
period.
Air handling systems shall
provide a capture efficiency
> 95%
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 7 of 21
Table 2
EU#
Operational /
Production Limit
Air Contaminant
Emission Limit
EU -SPI
EU-SP2
EU-SP3
EU-SP4
N/A
VOC
0.06 TPM; 0.27 TPY
EU-CBB 1 a
Natural gas is sole fuel of
use.
NO,,
0.22 TPM; 2.57 TPY
CO
0.49 TPM; 5.87 TPY
VOC
0.19 TPM; 2.20 TPY
PM/PMI0/PM2.5
0.06 TPM; 0.73 TPY
Opacity
<5%, except 5 to <10% for <2 minutes
during any one hour
EU-CBB2
Natural gas is sole fuel of
use.
NO,,
0.11 TPM; 1.28 TPY
CO
0.25 TPM; 2.93 TPY
VOC
0.10 TPM; 1.10 TPY
PM/PM10/PM2.5
0.03 TPM; 0.37 TPY
Opacity
<5%, except 5 to <10% for <2 minutes
during any one hour
EU -EG
Natural gas is sole fuel of
use.
NO,,
0.10 TPM; 0.20 TPY
CO
0.16 TPM; 0.32 TPY
VOC
0.005 TPM; 0.01 TPY
PM/PMI0/PM2.5
0.005 TPM; 0.01 TPY
Opacity
<5%, except 5 to <10% for <2 minutes
during any one hour
Facility-
wide
N/A
NO,,
0.43 TPM; 5.0 TPY
CO
0.9 TPM; 11.2 TPY
VOC
7.5 TPM; 47.1 TPY
PM/PM10/PM2.5
0.2 TPM; 1.2 TPY
SO2
0.05TPM; 0.1 TPY
Total HAPS
0.4 TPM; 3.0 TPY
Table 2 Key:
N/A = Not Applicable
EU# = Emission Unit Number
EPS = Expandable Polystyrene
NO,., = Nitrogen Oxides
CO Carbon Monoxide
SO2 = Sulfur Dioxide
PM = Total Particulate Matter
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 8 of 21
PM10 = Particulate Matter less than or equal to 10 microns in diameter
PM2.5 = Particulate Matter less than or equal to 2.5 microns in diameter
VOC = Volatile Organic Compounds
Total HAPs = total Hazardous Air Pollutants.
TPM = tons per month
TPY = tons per consecutive 12 -month period
< = less than
< = less than or equal to
> = greater than or equal to
% = percent
Table 2 Note:
a = emission limits are established at 310 CMR 7.26(30) for these emission units
B. COMPLIANCE DEMONSTRATION
The Permittee is subject to, and shall comply with, the monitoring, testing, record
keeping, and reporting requirements as contained in Tables 3, 4, and 5 below:
Table 3
EU#
Monitoring and Testing Requirements
1. The Permittee shall conduct compliance testing for VOC on these EUs within one hundred twenty
(120) days of the commencement of continuous operation of said EUs. All compliance testing shall
be conducted in accordance with the test methods and procedures set forth in 40 CFR 60,
EU-PREX1
Appendix A. All compliance testing shall be witnessed by MassDEP personnel at a mutually
EU -ARI
agreeable date and time.
EU -MIDI
2 The Permittee shall monitor the weekly, calendar month, and twelve month rolling consumption of
EU-MLD2
EPS beads processed by the facility in these EUs to document compliance status with the limitations
EU-MLD2
EU-MLD4
contained in Table 2 above. The average monthly pentane content of the EPS beads consumed and
EU-MLD5
the total monthly EPS bead consumption shall be used to determine the actual monthly emission
EU-MLD6
rates.
EU-MLD7
EU-MLD8
3. Within thirty (30) days of the continuous operation of the PCD -RTO, the Permittee shall balance the
EU-MLD9
air handling system and measure the air flow within the air handling system to ensure that all
EU-MLDI O
VOC-laden process air is vented to the PCD -RTO. Permittee shall allow MassDEP personnel to
EU -MLD 11
witness the documentation of the capture effectiveness of the air handling system.
EU 12
-MLD
EU -MLD 13
4. For compliance testing purposes, the PCD -RTO and its associated pentane capture system shall be
EU -MLD 14
constructed so as to accommodate the emissions testing requirements as stipulated in 40 CFR Part
60, Appendix A. The two (2) inlet and two (2) outlet sampling ports should ideally be located at two
duct diameters upstream and eight duct diameters downstream of any flow disturbance. The
corresponding sampling ports should be 90 degrees apart from each other.
Lifoam Industries, -LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 9 of 21 1 .
Table 3
EU#
Monitoring and Testing Requirements
5. The Permittee shall monitor operations so that a minimum PCD -RTO combustionchamber
temperature of 1,500 degrees Fahrenheit, or other such temperature as may be established pursuant
to satisfactory compliance testing results as determined by MassDEP, is achieved prior to ducting of
VOC laden air to PCD -RTO, or introduction of pentane beads to any pre -expander or molding
EU-PREX1
machine. This minimum temperature shall be maintained at all times (in one -minute averages)
EU -ARI
while any associated emission unit(s) is/are producing VOC laden air that can't be re -circulated.
EU -MLD 1
Temperature monitoring shall include date and time and any necessary description of operational
EU-MLD2
changes that may occur.
EU-MLD3
EU-MLD4
6. The Permittee shall monitor operations so that in the event of a PCD -RTO malfunction, an interlock
EU-MLD5
system shall be installed and maintained to prevent the uncontrolled operation of EU-PREX1 and
EU-MLD6
EU-MLD1 through EU-MLD14. The Permittee shall cease feeding EPS beads to these emission
EU-MLD7
units until PCD -RTO is operating properly, and consistent with the requirements of the plan
EU-MLD8
approval.
EU-MLD9
EU -MLD 10
7. Compliance testing shall be conducted on PCD -RTO and the associated PTEs every three (3) years,
EU -MLD 11
or as determined by MassDEP, with the first compliance test commencing within one hundred
EU -MLD 12
twenty days (120 days) of commencement of continuous operation of PCD -RTO. The compliance
EU -MLD 13
testing of PCD -RTO must demonstrate, at minimum, that: a) each applicable enclosure complies
EU -MLD 14
with the United States Environmental Protection Agency's (USEPA) Method 204 which outlines
criteria for Permanent Total Enclosures; b) the actual pentane capture system complies with the
required overall, minimum VOC capture efficiency of 95% (by mass balance justification); and c)
the VOC destruction efficiency of PCD -RTO is a minimum of 99.0 percent by weight or a
maximum outlet VOC emission rate of 0.30 pound per hour or less, whichever is less stringent. The
compliance testing procedures must follow USEPA and MassDEP methods and guidelines.
8. The Permittee shall monitor maintenance activities associated with PCD -RTO.
EU -SPI
9. The Permittee shall monitor the monthly and twelve month rolling consumption of VOC containing
EU-SP2
materials for these EUs to document compliance status with the limitations contained in Table 2
EU-SP3
above.
EU-SP4
EU-CBB 1
10. The Permittee shall monitor the monthly and twelve month rolling consumption of natural gas to
EU-CBB2
document compliance status with the emission limitations contained in Table 2 above.
EU -EG
11. The Permittee shall monitor to ensure that all VOC or HAPS-containing materials such as coatings,
solvents, and cleanup solutions, shall be transported and stored in tightly covered containers.
Facility-
12. The Permittee shall monitor that all cleaning rags used in conjunction with the VOC containing
wide
cleaning solutions shall be placed in tightly covered containers when not in use, and shall be
collected for proper recycling or disposal.
13. The Permittee shall monitor Facility operations so that deviations from Plan Approval requirements
can be reported to MassDEP.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 10 of 21
Table 3
EU#
Monitoring and Testing Requirements
14. The Permittee shall monitor raw material usage each month in order to determine the actual
Facility-
emissions of VOC and HAPs for the month as well as for the prior 11 months for the entire Facility.
wide
15. The Permittee shall monitor Facility operations such that emissions may be calculated as required
for compliance with 310 CMR 7.12.
Table 3 Key:
EU# = Emission .Unit Number
PCD -RTO = Pollution Control Device — Regenerative Thermal Oxidizer
VOC = volatile organic compounds
PTE = Permanent Total Enclosure
HAPS = hazardous air pollutants
% = percent
CFR = Code of Federal Regulations
EPS = Expandable Polystyrene
EU#
EU -ARI
EU -MLD 1
EU-MLD2
EU-MLD3
EU-MLD4
EU-MLD5
EU-MLD6
EU-MLD7
EU-MLD8
EU-MLD9
EU -MLD 10
EU -MLD 11
EU -MLD 12
EU -MLD 13
EU -MLD 14
Table 4
Record Keeping Requirements
1. The Permittee shall quantify all periods of excess emissions, even if attributable to an
emergency/malfunction, startup/shutdown or equipment cleaning in the determination of annual
emissions and compliance with the emission limits as stated in Table 2.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page I 1 of 21
Table 4
EU#
Record Keeping Requirements
2. The Permittee shall maintain a record keeping system for these EUs to be established on-site. All such
records shall be maintained up-to-date such that year-to-date information is readily available for
MassDEP examination upon request and shall be kept on site for a minimum of five (5) years.
Record keeping shall, at a minimum, include:
a) Compliance records sufficient to document the actual monthly and twelve month rolling emission
rates of VOC from these EUs, so as to determine compliance status with the emission limitations
contained in Table 2 above: Such records shall include, but are not limited to, the daily, monthly,
and twelve month rolling emission rates, emissions test results, monitoring equipment data and .
reports, and hours of operation.
b) Maintenance: A record of routine maintenance activities performed on these EUs and their
monitoring equipment including, at a minimum, the type or a description of the maintenance
performed and the date and time the work was completed.
EU-PREX 1
EU -RE
c) Malfunctions: A record of all malfunctions of these EUs and their monitoring equipment
EU -MLD 1
including, at a minimum: the date and time the malfunction occurred; a description of the
EU-MLD2
malfunction and the corrective action taken; the date and time corrective actions were initiated;
EU-MLD3
and the date and time corrective actions were completed and the equipment was returned to
EU-MLD4
compliance.
EU-MLD5
3. The Permittee shall maintain records on-site of the weekly, calendar month, and twelve month rolling
EU-MLD6
EPS bead consumption to document compliance status with the emission limitations contained in Table 2
EU-MLD7
above.
EU-MLD8
EU-MLD9
4. The Permittee shall maintain records documenting actual PCD -RTO combustion chamber temperature
EU -MLD 10
in degrees Fahrenheit. Temperature monitoring shall include the date and any necessary description of
EU -MLD 11
operational changes that may occur. The combustion chamber temperature of the PCD -RTO shall be
EU -MLD 12
EU -MLD 13
recorded with temperature monitoring and recording equipment using a digital readout and stored on a
EU -MLD 14
computerized hard drive, flash card, disc, or other media. Permittee shall have on-site a temperature data
back up to the flash card, disc, or other backup data capture media. These records shall be maintained
on-site, and shall be made available to MassDEP personnel upon request.
5. The Permittee shall maintain records of all malfunctions as defined in the SOMP as well as historical
activation of the interlock system associated with PCD -RTO, including corrective actions taken and
steps to prevent similar malfunctions from reoccurring in the future.
6. The Permittee shall maintain records of all emission testing for PCD -RTO.
7. The Permittee shall maintain a maintenance log for PCD -RTO which shall record all routine and
emergency maintenance work and repairs performed on it, as specified in the SOMP. Said log shall
indicate all malfunctions and down time.
8. The Permittee shall maintain all records of PCD -RTO operation/malfunction resulting in any associated
uncontrolled excess VOC emissions.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 12 of 21
Table 4
EU#
Record Keeping Requirements
9. The Permittee shall quantify all periods of excess emissions, even if attributable to an
EU -SP1
emergency/malfunction, startup/shutdown or equipment cleaning in the determination of annual
EU-SP2
emissions and compliance with the emission limits as stated in Table 2.
EU-SP3
EU-SP4
10. The Permittee shall maintain records on-site of the monthly and twelve month rolling VOC emissions to
document compliance status with the emission limitations contained in Table 2 above.
EU-CBB 1
11. The Permittee shall maintain records of monthly and twelve month rolling natural gas consumption rates
EU-CBB2
and the corresponding actual emissions from these emission units.
EU -EG
12. The Permittee shall maintain adequate records on-site to demonstrate compliance status with all
operational, production, and emission limits contained in Table 2 above. Records shall also include
the actual emissions of air contaminant(s) emitted for each calendar month and for each consecutive
twelve month period (current month plus prior eleven months). These records shall be compiled no
later than the 156 day following each month. An electronic version of the MassDEP approved record
keeping form, in Microsoft Excel format, can be downloaded at
http://www mass .ov/eea/a,gencies/massdep/air//gprovals/limited-emissions-record-keepin,g-and-
reporting.html.
13. The Permittee shall maintain records of monitoring and testing as required by Table 3.
14. In accordance with 310 CMR 7.71(6)b. and c. retain at the facility for five years and make available to
the Department upon request copies of the documentation of the methodology and data used to quantify
Facility-
greenhouse gas emissions.
wide
15. The Permittee shall maintain a copy of this Plan Approval, underlying Application and the most up-
to-date SOMP for the EUs and PCDs approved.herein on-site.
16. The Permittee shall maintain a record of routine maintenance activities performed on the approved
EU(s), PCD, and monitoring equipment. The records shall include, at a minimum, the type or a
description of the maintenance performed and the date and time the work was completed. ,
17. The Permittee shall maintain a record of all malfunctions affecting air contaminant emission rates on
the approved EU(s), PCD, and monitoring equipment. At a minimum, the records shall include:. date
and time the malfunction occurred; description of the malfunction; corrective actions taken; the date
and time corrective actions were initiated and completed; and the date and time emission rates and
monitoring equipment returned to compliant operation.
18: The Permittee shall maintain records of facility operations such that information may be reported as
required for compliance with 310 CMR 7.12.
19. The Permittee shall maintain records required by this Plan Approval on-site for a minimum of five (5)
years.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 13 of 21
Table 4
EU#
Record Keeping Requirements
Facility-
20. The Permittee shall make records required by this Plan Approval available to MassDEP and USEPA
wide
personnel upon request.
Table 4 Key:
EU# = Emission Unit Number
PCD = Pollution Control Device
EPS = Expandable Polystyrene
PCD -RTO = Pollution Control Device — Regenerative Thermal Oxidizer
VOC =_ volatile organic compounds
SOMP = Standard Operating and Maintenance Procedures
USEPA = United States Environmental Protection Agency
CMR = Code of Massachusetts Regulations
Table 5
EU#-
Reporting Requirements
1. The Permittee shall submit a compliance test protocol on the required initial compliance test to
MassDEP's Northeast Regional Office (HERO), Bureau of Air and Waste (BAW) Permit Chief, for
review and approval at least sixty (60) days prior to the scheduled commencement of said testing. Test
EU-PREX 1
protocols for any subsequent required emissions testing shall be submitted for review and approval at
EU -ARI
least forty-five (45) days prior to the scheduled commencement of said testing.
EU -MLD 1
2. The Permittee shall submit the initial emission test results report to this Office, attention BAW Permit
EU-MLD2
Chief, for review within sixty (60) days of the completion of any required compliance stack testing.
EU-MLD3
EU-MLD4
3. In the event of any PCD -RTO malfunction which results in any uncontrolled excess VOC emissions, the
EU-MLDS
permittee shall notify MassDEP by telephone within three (3) business day and subsequently in writing
EU-MLD6
within ten (10) days of said occurrence. This written notification shall describe the reason(s) for and the
EU-MLD
EU-MLD8
extent of down time of the equipment and all steps that have been or will be taken to prevent similar
EU-MLD9
malfunctions from occurring in the future.
EU-MLD10
4. The Permittee shall notify NERO, in writing, within fourteen (14) days of commencement of operation of
EU -MLD 11
EU -MLD 12
these EUs. These EUs shall not be operated without control by PCD -RTO.
EU -MLD 13
EU-MLD14
5. The Permittee shall submit the Final Standard Operating and Maintenance Procedures (SOMP) for
these EUs and PCD -RTO to NERO within sixty (60) days of completion of their required initial
compliance testing. Any subsequent changes to the SOW shall be submitted within fifteen (15) days of
said revision(s).
Lifoam Industries, LLC
Plan. Approval
Transmittal No. X273896
Application No. NE -17-002
Page 14 of 21
Table 5
EU#
Reporting Requirements
6. The Permittee shall notify MassDEP's NERO by telephone, fax, or email as soon as possible, but in
any case no later than three (3) business days, and subsequently in writing within ten (10) business
days, after the occurrence of any upsets or malfunctions to these EUs and related equipment which
results in an excess emission to the air and/or a condition of air pollution.
7. All notifications and reporting required and not specified by this Approval shall be made to:
BAW Permit Chief
MassDEP - NERO
205B Lowell Street
Wilmington, Massachusetts 01887
Phone: 978-694-3200
Fax: 978-694-3499
8. A semi-annual report of the VOC and HAPs emissions data for the period of January 1 through June
30 inclusive and for the period of July 1 through December 31 inclusive must be submitted to the
MassDEP, attention BAW Permit Chief, by no later than the following July 30th and January 30th,
Facility-
respectively.
wide
9. Accurately report the Facility's air emissions on Source Registration/Emission Statement Forms as
required by Regulation 310 CMR 7.12.
10. The Permittee shall submit to MassDEP all information required by this Plan Approval over the
signature of a "Responsible Official" as defined in 310 CMR 7.00 and shall include the. Certification
statement as provided in 310 CMR 7.01(2)(c).
11. The Permittee shall notify the Northeast Regional Office of MassDEP, BAW Permit Chief, by
telephone (9787-694-3200), email, nero.air@state.ma.us, or fax (978-694-3499), as soon as possible,
but no later than three (3) business days after discovery of an exceedance(s) of Table 2 requirements.
A written report shall be submitted to BAW Permit Chief at MassDEP within ten (10) business days
and shall include: identification of exceedance(s), duration of exceedance(s), reason for the
exceedance(s), corrective actions taken, and action plan to prevent future exceedance(s).
12. In accordance with 310 CMR 7.71(5), by April 15th of each year report emissions of greenhouse gases
from stationary emissions sources including, but not limited to, emissions from factory stacks,
manufacturing processes and vents, fugitive emissions, and other process emissions; and owned or
leased motor vehicles when stationary source greenhouse gas emissions are greater than 5,000 short ton
CO2e. Report greenhouse gas emissions electronically in a format that can be accommodated by the.
registry.
13. In accordance with 310 CMR 7.71(6), certify greenhouse gas emissions reports using a formprovided
by the Department or the registry.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 15 of 21
Table 5
EU#
Reporting Requirements
Facility-
wide
14. In accordance with 310 CMR 7.71(7), by December 31s` of the applicable year submit to the Department
documentation of triennial verification of the greenhouse gas emissions reports.
Table 5 Key:
EU# = Emission Unit Number
BAW = Bureau of Air and Waste
VOC = volatile organic compounds
HAPS = hazardous air pollutants
CO2e = carbon dioxide equivalents
PCD -RTO = Pollution Control Device — Regenerative Thermal Oxidizer
CMR = Code of Massachusetts Regulations
4. SPECIAL TERMS AND CONDITIONS
The Permittee is subject to, and shall comply with, the following special terms and conditions:
A. The Permittee shall comply with the Special Terms and Conditions as contained in Table 6
below:
Table 6
EU#
Special Terms and Conditions
1. The Permittee shall establish and maintain documentation and adhere to the criteria for VOC capture
efficiency -U.S. EPA Method 204 for permanent total enclosures (PTEs) for these emission units. The
criteria for a PTE are the following:
a) All access doors and windows are closed during normal operation.
b) The interior of the PTE is under negative pressure to the outside environment.
EU-PREX 1
EU -ARI
c) The average velocity through the natural draft openings (NDOs) must be greater than 200 feet
per minute.
d) Sources of VOC in the PTE must be at least four (4) equivalent diameters from each NDO.
e) The total area of all NDOs must be less than five (5) percent of the total area of the enclosure.
The above procedures shall be incorporated into Permittee's Standard Operating and Maintenance
Procedure (SOMP) for these emission units.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 16 of 21
Table 6
EU#
Special Terms and Conditions
2. The Permittee shall establish and maintain a copy of the full PTE site-specific test plan on-site. The test
plan should contain the following:
a) A description of how Permittee will demonstrate that, within the PTE, the VOC concentrations
shall. be maintained and not rise or exceed safe Occupational Safety & Health Administration
(OSHA) levels. Method 204 lists the requirements for such levels;
EU-PREX1
EU-AR1
b) A full explanation of any possible natural draft openings (NDOs) and how they might affect the
overall certification of the PTE;
c) A description of how Permittee will monitor to verify that the PTE will meet either inward flow to
the PTE or negative pressure in the PTE; and
d) A calculation of the PTE area ratios as required in Method 204.
This plan shall be made available to MassDEP personnel upon request.
3. The Permittee shall maintain documentation of the actual VOC capture efficiency of the pentane capture
system based on the most recently performed compliance test.
4. The Permittee shall operate the subject EUs consistent with the Final SOW and the conditions/parameters
established from each compliance test.
EU-PREX 1
EU -RE AR1
5. PCD -RTO shall provide a minimum control efficiency of 99.0 weight percent for VOC or a maximum
EU- I
outlet VOC emission rate of less than 0.30 pound per hour, whichever is less stringent. All associated
EU-MLD2.
permanent total enclosures (PTEs) shall provide 100 percent capture efficiency based on conformance
EU-MLD3
to Method 204.
EU-MLD4
6. There are five (5) upset conditions for which the associated emission units being controlled by
EU-MLD5
PCD -RTO shall immediately be shut down. These conditions are as follows:
EU-MLD6
EU-MLD7
a) RTO fan failure;
EU-MLD8
b) RTO combustion chamber exceeding 1950 OF or manufacturer's specification;
EU-MLD9
c) hydraulic system (i.e. pumps, etc.) pressure loss;
EU -MLD 10
d) loss of bumer gas pressure, gas service interruption, or flame out; and/or
EU -MLD 11
e) general system or PCD -RTO power failure.
EU -MLD 12
EU-MLD13
7. A copy of the Standard Operating and Maintenance Procedure (SOW) for PCD -RTO shall be located
EU -MLD 14
at or nearby the system's control panel.
8. The start-up specifications and maintenance procedures for PCD -RTO as well as the emergency
shutdown procedures for EUs and PCD -RTO shall be established and incorporated into its SOMP.
The SOMP shall address the spare parts inventory and back-up equipment systems for the PCD -RTO
to prevent or reduce any downtime PCD -RTO. In addition, a copy of any subsequent revisions made
to the SOW must be submitted to this office within fifteen (15) days of the documented
modification(s).
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 17 of 21
Table 6
EU#
Special Terms and Conditions
EU-PREX1
EU-ARl
9. An electronic interlock system shall prevent or interrupt the introduction of EPS bead to any emission
EU-MLD1
unit requiring control by PCD -RTO until the PCD -RTO achieves and maintains the minimum
EU-MLD2
operating temperature of 1,500°F (or such other temperature as may be established pursuant to
EU-MLD3
satisfactory compliance testing results as determined by MassDEP). In the event the interlock is
EU-MLD4
activated to prevent processing, all bead processing emission units will be allowed to complete any
EU-MLD5
cycle already in progress prior to interruption from further EPS processing.
EU-MLD6
EU-MLD7
EU-MLD8
EU-MLD9
EU -MLD 10
10. In the event of an emergency shutdown of PCD -RTO, the molding machines shall stop production and the
EU-MLD11
process air in the aging room shall be re -circulated until such time that PCD -RTO is operating properly
EU -MLD 12
again.
EU -MLD 13
EU -MLD 14
11. This Facility may be subject to the Federal New Source Performance Standards (NSPS) for Small
Industrial -Commercial -Institutional Steam Generating Units (40 CFR Part 60 Subpart Dc). Since
MassDEP has not accepted delegation for Subpart Dc, you are advised to consult with the EPA for
additional information. There may be additional notification, record keeping and reporting
requirements. Their address is US EPA Region 1, 5 Post Office Square — Suite 100, Boston, MA
02109-3912.
12. The Permittee shall evaluate the feasibility of capturing and controlling the pentane emissions from
both the raw material storage area and the finished product storage area to further minimize VOC
emissions. The results of this evaluation shall be completed and submitted by no later than December.
Facility-
31, 2018, to MassDEP for review and approval.
wide
13. The feasibility study report shall include at a minimum:
a) the measured pentane concentrations at both areas of the new facility during manufacturing
and non -manufacturing operations as well as the aging room (EU -ARI);
b) the estimation of additional, pentane emissions that could be captured and controlled by the
existing PCD -RTO; and
c) the reasons why the additional capture and control would be feasible or infeasible.
14. Should the feasibility study indicate that it would be feasible to capture and control pentane emissions
from one or both of the storage areas, then the Permittee shall submit plans, specifications, and a
timeline for the installation and operation of the new capture system(s) to MassDEP by no later than
January 31, 2019.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 18 of 21
Table 6
EU#
Special Terms and Conditions
Stack Inside Exit
Dimensions
(feet)
15. This Facility may be subject to subject to 40 CFR Part 63, Subpart ZZZZ, National Emission Standards
Stack Gas Exit
Temperature (Ofl
for Hazardous Air Pollutants (NESHAPs) for Stationary Reciprocating Internal Combustion Engines.
35
Since the Permittee's Facility is an area source for HAPS and is defined as an institution, compliance with
Facility-
40 CFR Part 63, Subpart ZZZZ shall be met by complying with the requirements of 40 CFR Part 60,
wide
Subpart JJJJ, "Standards of Performance for Stationary Spark Ignition Internal Combustion Engines".
1.67
Since MassDEP has not accepted delegation for area sources, you are advised to consult with the
360
United States Environmental Protection Agency (USEPA) for additional information. There may be
35
additional notification, record keeping and reporting requirements. Their address is US EPA Region 1,
18
5 Post Office Square — Suite 100, Boston, MA 02109-3912.
Table 6 Key:
EU# = Emission Unit Number
EUs = emission units
EPA = Environmental Protection Agency
VOC= Volatile Organic. Compounds
PCD -RTO = Pollution Control Device — Regenerative Thermal Oxidizer
RTO = Regenerative Thermal Oxidizer
EPS = Expandable Polystyrene (Bead)
°F = degrees Fahrenheit
CFR = Code offederal Regulations
B. The Permittee shall install and use an exhaust stack, as required in Table 7, on each of the
Emission Units that is consistent with good air pollution control engineering practice and that
discharges so as to not cause or contribute to a condition of air pollution. Each exhaust stack
shall be configured to discharge the gases vertically and shall not be equipped with any part
or device that restricts the vertical exhaust flow of the emitted gases, including but not
limited to rain protection devices known as "shanty caps" and "egg beaters." The Permittee
shall install and utilize exhaust stacks with the following parameters, as contained in Table 7
below, for the Emission Units that are regulated by this Plan Approval:
Table 7
EU#/PCD
Stack Height
Above Ground
(feet)
Stack Inside Exit
Dimensions
(feet)
Minimum Stack. Gas
Exit Velocity
(feet per second)
Stack Gas Exit
Temperature (Ofl
EU-CBB 1
35
2.0
27
360
EU-CBB2
35
1.67
19
360
PCD -RTO
35
2.2 x 4.6
18
360
EU -EG
19
0.25
1 443
1200
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 19 of 21
Table 7 Key:
EU# = Emission Unit Number
OF = degrees Fahrenheit
PCD = Pollution Control Device
PCD -RTO = Pollution Control Device — Regenerative Thermal Oxidizer
5. GENERAL CONDITIONS
The Permittee is subject to, and shall comply with, the following general conditions:
A. Pursuant to 310 CMR 7.01, 7.02, 7.09 and 7.10, should any nuisance condition(s), including
but not limited to smoke, dust, odor or noise; occur as the result of the operation of the
Facility, then the Permittee shall immediately take appropriate steps including shutdown, if
necessary, to abate said nuisance condition(s).
B. If asbestos remediation/removal will occur as a result of the approved construction,
reconstruction, or alteration of this Facility, the Permittee shall ensure that all
removal/remediation of asbestos shall be done in accordance with 310 CMR 7.15 in its
entirety and 310 CMR 4.00.
C. If construction or demolition of an industrial, commercial or institutional building will occur
as a result of the approved construction, reconstruction, or alteration of this Facility, the
Permittee shall ensure that said construction or demolition shall be done in accordance with
310 CMR 7.09(2) and 310 CMR 4.00.
D. Pursuant to 310 CMR 7.01(2)(b) and 7.02(7)(b), the Permittee shall allow MassDEP and / or
USEPA personnel access to the Facility, buildings, and all pertinent records for the purpose
of making inspections and surveys, collecting samples, obtaining data, and reviewing
records.
E. This Plan Approval does not negate the responsibility of the Permittee to comply with any
other applicable Federal, State, or local regulations now or in the future.
F. Should there be any differences between the Application and this Plan Approval, the Plan
Approval shall govern.
G. Pursuant to 310 CMR 7.02(3)(k), MassDEP may revoke this Plan Approval if the
construction work is not commenced within two years from the date of issuance of this Plan
Approval, or if the construction work is suspended for one year or more.
H. This Plan Approval may be suspended, modified, or revoked by MassDEP if MassDEP
determines. that any condition or part of this Plan Approval is being violated.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 20 of 21
I. This Plan Approval may be modified or amended when in the opinion of MassDEP such is
necessary or appropriate to clarify the Plan Approval conditions or after consideration of a
written request by the Permittee to amend the Plan Approval conditions.
J. Pursuant to 310 CMR 7.01(3),and 7.02(3)(f), the Permittee shall comply with all conditions
contained in this Plan Approval. Should there be any differences between provisions
contained in the General Conditions and provisions contained elsewhere in the Plan
Approval, the latter shall govern.
6. MASSACHUSETTS ENVIRONMENTAL POLICY ACT
MassDEP has determined that the filing of an Environmental Notification Form (ENF) with the
Secretary of Energy & Environmental Affairs, for air quality control purposes, was not required
prior to this action by MassDEP. Notwithstanding this determination, the Massachusetts
Environmental Policy Act (MEPA) and 301 CMR 11.00, Section 11.04, provide certain "Fail -
Safe Provisions," which allow the Secretary to require the filing of an ENF and/or an
Environmental Impact Report (EIR) at a later time.
7. APPEAL PROCESS
This Plan 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 (21) days of the date of issuance of this Plan 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 Plan
Approval is not consistent with applicable laws and regulations.
The hearing request along with a valid check payable to the 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
This 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.
Lifoam Industries, LLC
Plan Approval
Transmittal No. X273896
Application No. NE -17-002
Page 21 of 21
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.
Should you have any questions concerning this Plan Approval, please contact Mr. Mun Wong by
telephone at 978-694-3286, or in writing at the letterhead address.
Sincerely,
Permit Chief`
of Air and Waste
l
Mun S. Wong
Environmental Engineer
cc: . Board of Health, 120 Main Street, North Andover, MA 01845
Fire Headquarters, 795 Chickering Road, North Andover, MA 01845
DEP, Boston, Yi Tian (e -copy)
DEP, NERO, Attn: E. Braczyk, M. Bolis, M. Persky
Environmental Resources Management, OneBeacon Street, Boston, MA 02108
ATTN: Mr. Bob Fraser
Susan Ruch, Deputy Regional Director, MassDEP NEROBAW
Email: susan.ruch@state.ma.us