Download FEDERAL OPERATING PERMIT - TECHNICAL REVIEW SUMMARY

FEDERAL OPERATING PERMIT - TECHNICAL REVIEW SUMMARY
SITE OPERATING PERMIT (SOP) INITIAL ISSUANCE
Permit #:
Project #:
Account #:
Regulated Entity #:
Region:
SIC Code:
Permit Reviewer:
O3330
14356
HG-0465-O
RN100692219
12
2821
Camilla Widenhofer
SITE INFORMATION
Physical Location:
Nearest City:
Major Pollutants:
Additional FOPs:
Company:
Site:
Application Area:
Customer #:
County:
SIC Name:
Cook Composites and Polymers Co
Cook Composites and Polymers Co
Cook Composites and Polymers Co
CN601121742
Harris
Plastics Materials and Resins
2434 Holmes Rd
Houston
VOC, NOX
None
PROJECT SUMMARY
Cook Composites and Polymers Co (CCP) facility located within the Houston-Galveston-Brazoria (HGB)
nonattainment area is subject to the Title V major source threshold effective October 31, 2008 when the US
EPA reclassified the HGB as severe nonattainment under the 1997 ozone 8-hour standard which changed the
Title V major source threshold for NOx and VOC from 100tpy to 25tpy. A timely abbreviated application was
received by TCEQ on October 30, 2009.
PROCESS DESCRIPTION
1. Ester Resin Process Description
The ester resin process description includes the production of unsaturated polyester, saturated polyester, alkyd,
and modified alkyd resins.
Polyester resins are the starting point of all CCP resins and gel coats. They are the basis for all marble, casting,
laminating and molding resins. Polyester resins are used in a broad spectrum of applications. They are used in
buildings and construction; in corrugated and flat paneling; as reinforcement for acrylic sheet; in shower stalls,
tubs, and marble vanities. They are used in both interior and exterior autobody panels, and in polymer concrete
and mine bolts. They are used in electrical components, boat and other marine laminates.
Polyester resin production consists of raw materials stored in bulk tanks, tote tanks, drums, pails, and bags; one
or more reaction kettles; several process vessels for adjusting, blending and thinning the resins; intermediate
product storage tanks and containers; resin filtering equipment; and final product storage tanks and containers.
Polyester resins generally are produced by three types of compounds: dibasic acids, glycols, and
monomers/diluents. The acids and glycols join together under heat to form a long chain called a polymer. This
is an esterification reaction which results in a polymer called polyester. Some of the dibasic acids are
unsaturated and for this reason the polyester is said to be an unsaturated polyester. To form the polymer the
acids and glycols are “cooked” together in a reaction kettle. Cooking time can very from 14 to 24 hours at
temperatures up to 430ºF. When they are heated, water is generated. This water is decanted from the reactor to
shift the equilibrium of the esterification reaction.
The final properties of the polyester resin depend on the acids, glycols, and amount of unsaturated acid used in
making the polyester polymer. The most common unsaturated acid is maleic anhydride. Saturated acids
include phthalic anhydride, isophthalic acid, and adipic acid. Glycols include ethylene glycol, diethylene
glycol, propylene glycol, dipropylene glycol, and neoentyl glycol.
After the resin has achieved the desired end-point, it needs to be made readily useable for customer applications
by dissolving the resins in a solvent or monomer. It is typically transferred from the reaction kettle into a
thinning tank containing the desired solvent or monomer. Styrene monomer is nearly always used, but other
monomers include vinyl toluene, alpha-methyl styrene, and methyl methacrylate. The resin is adjusted in the
thinning tank to meet customer specifications. Resin can also be adjusted in blend tanks or adjusting tanks. The
adjusted resin is then transferred to a storage tank, tank wagon or into drums.
When a catalyst is added to the final polyester resin, the unsaturated portion of the monomer reacts with the
unsaturated portion of the polyester to form a hard solid that will not soften or melt even when heated to very
high temperatures. This resin is called an unsaturated thermosetting polyester resin.
Alky resins are saturated polyesters modified with monobasic fatty acids. There are widely used in equipment
and implement enamels, industrial baking finishes, and can coatings due to their flexibility and durability
characteristics.
2. Acrylic Resin Process Description
The acrylic resin process description includes the production of acrylic co-polymers and homo-polymers, epoxy
acryliate, and urethane acrylate resins.
Acrylic acid and its esters are primarily used to prepare polymers and co-polymers. The polymeric products can
be made to vary widely in physical properties through control of the nature and ratio of monomers employed in
the preparation, and the control of the degree of cross-linking and molecular weight.
Solution polymerization of acrylic esters is usually conducted at a controlled rate to maintain a reaction
temperature in the range of 270ºF to 285ºF. Inhibitors and peroxide catalysts are also used to control the
molecular weight.
Urethane acrylate resin are formed when the hydroxyl groups in the acrylate or methacrylate alkyl group
undergo the typical reactions of alcohols and are reacted with aliphatic or aromatic diisocyanates. These resins
are further reacted with polyether or polyester polyols for additional flexibility. The reaction with the acrylate
or methacrylate monomer is controlled below 120ºF to reduce the viscosity and cross-linking. Additional
acrylate and methacrylate monomers are used to reduce the viscosity and cross-link with the oligomer during
curing. Therefore, urethane acrylate resins are 100 percent reactive. Both urethane acrylate and epoxy acrylate
resins can be formulated for cure by ultra-violet (UV) or electron-beam (EB) mechanisms.
Epoxy acrylate resins can also be used in adhesives. An epoxy resin is reacted with 1:1 to 1:1.5 equivalents of
acrylic or methacrylic acid to increase the molecular weight and to form acid functional groups which improve
the adhesive properties of this resin family. This reaction is completed in the presence of air at temperatures
below 210ºF. The reaction is controlled by the use of oxygen-activated inhibitors and the addition rate of the
acrylic or methacrylic acid.
Acrylic-based polymers are noted for their outstanding water-clear color and the stability of their properties
upon aging under severe service conditions. The properties of the polymers can be made to vary from those
extremely tacky adhesives, to rubber, through plastics and even hard powders.
TECHNICAL REVIEW
Working Draft Permit (WDP) Preparation
1. Was Periodic Monitoring (PM) required and included in the WDP? ................................................. Yes
2. Was Compliance Assurance Monitoring (CAM) required and included in the WDP? ........................No
3. Was PM or CAM included in the permit customized for site operations? ...........................................No
4. Were Special Terms and Conditions pertaining to the mass emissions cap and trade
Program (for Houston/Galveston area only) included in the WDP? .......................................... Yes
5. Was a permit shield requested?........................................................................................................... Yes
6. If permit shield was requested, was any permit shield request denied? ...............................................No
7. Identify if the following are applicable for this project:
(a) Manually-built applicable requirements ..................................................................................No
(b) Customized Special Terms and Conditions ............................................................................No
(c) Manual changes to the IMS-generated applicable requirements .............................................No
(d) Alternate means of compliance for any emission unit/source at the site ................................No
8. Is the site subject to the requirements of 40 CFR Part 72 (Acid Rain Permit)? ...................................No
Permit reviewer notes:
An abbreviated initial application was received by TCEQ on October 30, 2009. A request for the full
application was mailed on November 19, 2009, and the full application was received on December 21, 2009.
Changes were made to the permit during the public notice period since it was discovered that 30 TAC Chapter
115 requirements had not been included in the permit for units E6513, E6514, and S-6215.
Working Draft Permit Review
1. Did the applicant’s review/comments on the working draft permit result in changes
to the permit content?................................................................................................................ Yes
2. Will the draft permit be sent to public notice with unresolved issues
(i.e., disagreements with applicant)?.......................................................................................... No
Permit reviewer notes:
Applicant comments include but are not limited to revised negative applicability reasons in the permit
shield, addition of low level 30 TAC Chapter 117 requirements, company name change from TOTAL
Composites Two, Inc. to Cook Composites and Polymers Co, and typos. See application file for details.
Statement of Basis
A Statement of Basis sets forth the legal and factual basis for the applicable requirements that are
included in the FOP.
The Statement of Basis was prepared on 03/26/2010 .
The Statement of Basis GroupWise Document # (OPDP Database) is 56938 .
Compliance History Review
In accordance with 30 TAC Chapter 60, the compliance history was reviewed on 03/19/2010 .
The compliance history review evaluated the period from 10/30/2009 to 10/30/2004 .
Site rating: 0.38
Company rating: 3.85
(High < 0.10; Average > 0.10 and < 45; Poor > 45)
Site/Permit Area Compliance Status Review
1. Were there any out-of-compliance units listed on Form OP-ACPS? ................................................ No
2. Is a compliance plan and schedule included in the permit? ............................................................... No
Public Notice Information
1. Were comments received from the applicant after the draft permit was mailed and
before Public Notice was published? ......................................................................................... No
2. Was a revised draft permit or public notice authorization package (PN-Errata) sent
for any reason? ........................................................................................................................... No
3. Publication date: 05/07/2010
Newspaper name: Houston Chronicle
4. Was bilingual public notice published? ............................................................................................. No
(a) Publication date: 05/09/2010
Newspaper name: Houston Chronicle dba La Voz
5. Were comments received during Public Notice period?.................................................................... No
(a) Was a public hearing requested? .......................................................................................... No
(b) Was a public hearing held? .................................................................................................. No
(c) Was the public hearing request withdrawn? ......................................................................... No
(d) Was permit content changed as a result of any public comments? ...................................... No
6. Was re-publication necessary? ........................................................................................................... No
EPA Review
1. Did EPA comment on the draft permit? ............................................................................................ No
2. Was a separate NOPP - Notice of Proposed Permit sent to the EPA? ............................................... No
(a) If yes, did the EPA comment on the proposed permit? ........................................................ No
3. Were any changes made to the permit after the EPA Review Period? .............................................. No
(a) If yes, were these changes made within the 60 day Public Petition Period? ........................ No
IMPORTANT MILESTONES
Milestone (Standard)
Start Date
End Date
Date Application Received by TCEQ
10/30/2009
Date Project Received by Engineer
11/04/2009
Technical Review Period
01/12/2010
03/18/2010
Working Draft Permit Reviewed by Applicant
01/13/2010
03/18/201
Date PNAP/Draft Permit Mailed
04/09/2010
Public Notice Comment Period
05/09/2010
06/10/2010
EPA Review Period
05/18/2010
06/30/2010
Date Sign Posting Certification Received
06/24/2010
EFFECTIVE PERMIT ISSUANCE DATE:
Camilla Widenhofer
Permit Reviewer
Operating Permits Section
Air Permits Division
Date
Kim D. Strong, P.E.
Team Leader
Operating Permits Section
Air Permit Division
Date
ATTACHMENTS
Administrative Data
Communication Log
ADMINISTRATIVE DATA
Responsible Official:
Jon Schuckman
Director - HSEQ Compliance Assurance
Cook Composites and Polymers Co.
PO Box 419389
Kansas City, MO 64141-6389
Technical Contact:
Jon Schuckman
Director - HSEQ Compliance Assurance
Cook Composites and Polymers Co.
PO Box 419389
Kansas City, MO 64141-6389
Phone:
Email: [email protected]
COMMUNICATION LOG
Company Name
Application Area
Air Account
Number
Regulated Entity
Number
IMS Project
Number
Cook Composites and
Ploymers Co
Cook Composites And
Polymers Co
HG-0465-O
RN100692219
14356
Contact
Phone/E-mail
Date
Jon Schuckman
[email protected] 02/24/2010 Intro email
Notes