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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