INSPECTION SUMMARY:
On 19 May 2006 Robert Hayden of the Fayetteville Regional Office met with Mr. John Grant (Production Manager) and Mr Anthony Bullard (Maintenance Manager) for an unannounced air quality compliance inspection. Mr Thompson, the facility contact, was on vacation. Mr Thompson’s monitoring and maintenance records were not readily available; however, all required record keeping, with the exception of the SSM plan(s), is submitted to DAQ semiannually. The SSM plan for the Friction Products MACT requires an additional paragraph regarding condenser contingencies. The October 2005 MACT compliance demonstration report appears correct and complete. The previous semiannual report appeared complete and valid, with no deviations noted. All emission sources were inspected, including the roof emission points. Hayden returned on 21 June 2006 to complete the records review portion of the inspection with Mr. Thompson. The air quality consultant, Mr Ken Hausle, was also present. At the time of the inspection, the facility appeared to be operating in compliance.
This facility is subject to the MACT for Friction Materials Manufacturing Facilities, 40 CFR Part 63 Subpart QQQQQ. The final rule was published on October 18, 2002 and applies to any owner of a friction materials manufacturing facility that is, or is part of, a major source of HAP emissions. The affected source is each existing and new solvent mixer at a friction materials manufacturing facility, that is a major source of HAPs, that uses a solvent that contains one or more HAPs as ingredients of the friction material composition. Railroad Friction is one of only four subject sources in the country.
RFPC operates a friction materials mixer, and this mixer – Sigma Mixer (ES-10) is subject to the Friction Products MACT. Older mixers (Ross) were disconnected and removed, mainly due to their failure to meet the MACT. As it applies to RFPC, the Friction Products MACT requires reduction of HAP solvent (hexane) emissions from the mixer by at least 70%. This reduction can be achieved by hexane recovery or solvent substitution. A significant fraction of RFPC’s formulations have been changed to “hexane-free;” however, hexane-free batches in the mixer do not yet account for 70% of the total batches. Thus in order to achieve the 70% emissions reduction, hexane usage and recovery is tracked and recorded. A 7-day block average is used to determine the emissions reduction. The compliance formula takes into account solvent content and solvent recovered by batch, as well as zero solvent batches. The compliance level is anything less than 30%.
The initial MACT compliance demonstration was performed Sunday October 16th 7:00 am through Sunday October 23rd 6:59am. The final report was provided to DAQ on 8 November 2005. The compliance percentage (P7 in the formula) was 12.6%, demonstrating initial compliance with the MACT.
The Start-up, Shut-down and Malfunction (SSM) plan for the Friction Products MACT appears adequate; however, Hayden requested some amplification on several areas regarding early detection and remedies for condenser failure. That information was provided to DAQ by email (edited SSM plan) on 23 June 2006.
RFPC’s goal is to produce 100% hexane free products. They are still in the process of converting one product to hexane-free, the locomotive brake shoes. Since July/August of 2002, 60% of the products are now hexane-free. The new product contains phenolic resins. Therefore an increase in phenol, ammonia, and formaldehyde emissions are anticipated. The modeling analysis, submitted to DAQ on December 13, 2002, indicated compliance for these pollutants. NOTE: a start-up/shut-down plan is required per CFR 63.9505.
The facility is also subject to the Surface Coating of Miscellaneous Metal Parts and Products MACT, 40 CFR Part 63 Subpart MMMM, Rail Transportation Category in Table 1. The final rule was published on January 2, 2004, with a compliance date of 2 January 2007. Affected sources are the Backing Plate Spray Application process (ID No. ES17) and the Wedge Casting Hand Spray Application process (ID No. ES-18). The backing plate operation bonds the friction materials (mixture containing rubber) to the metal brake shoes, and falls under the Rubber-to-Metal Coatings standard, with an emission limit of 37.7 lbs HAP/gallon of solids applied. The facility is currently in the process of identifying the appropriate coating type (for existing affected sources General Use Coatings,). The Wedge Casting Hand Spray Application process is subject to the General Use Coatings, with an emission limit of 2.6 lbs HAP/gallon of solids applied. Based on trials and input from the coating and adhesives manufacturer, the MACT-compliant version of the product will be ready well before the compliance date.
As MMMM is the last applicable MACT, there is also due by the compliance date a facility-wide toxics review, per 15A NCAC 2Q .0705, “Existing Facilities and SIC Calls.” A permit application shall be submitted which includes an evaluation for all toxic air pollutants covered under 15A NCAC 2D .1104, unless the actual rate of emission from all sources are not greater than the toxic permitting emission rates listed in 2Q .0711.
PSD issues. This facility is an pre-existing major stationary source for PSD, with actual and potential VOC emissions greater than 250 TPY. Any modification would be evaluated for PSD significance levels. The PSD – VOC bottleneck is the adhesive spray operations.
MACT Subpart QQQQQ, Friction Materials Manufacturing MACT. The sole sources are the mixer (ES-10) and Granulator (F-01), controlled by two condensers, CD-05A and CD-05B.
CONDENSERS, CD-05A and CD-05B. The facility is required to:
1. Inspect and maintain the structural integrity of the condenser (inspecting for leakage of coolant, leakage of the contaminated gas stream (if system is under positive pressure), inspection of the condensate for the presence of coolant.
2. Inspect and maintain the structural integrity of duct work and piping leading to and coming from condensers.
3. Maintain records of inspections and any measures taken to repair leaks or other possible sites of fugitive emissions.
4. Monitoring/Record keeping – to ensure proper performance of the condenser, the total solvent used in the mixer and the total solvent recovered from the mixer shall be recorded once per week. These records shall indicate if the batch was “solvent-based,” by what amount, or “solvent-free.” Data is used to calculate the 7-day recovery average to show compliance with the 70% reduction (of what otherwise would have been emitted from a solvent-based, uncontrolled process) requirement in the MACT. A solvent-free batch equates to a 0% in the calculations.
IN COMPLIANCE. All maintenance and usage data is readily available and indicates compliance. A tracking and calculation program calculates daily and weekly recovery rates and averages. The lowest recorded “equivalent reduction” percentage yet recorded is 78% This number should continue to rise (farther into the compliance comfort zone) as n-hexane is replaced through solvent reformulation.