                            ENGINEERING EVALUATION
                                       
Date: 06/20/18				Project Number: 18-181
Facility Name: Meridian Manufacturing		Facility ID: 11-01-029
Engineer: Gary Smith				FO: 3
Permit Number(s): 
Project Description: 
Meridian Manufacturing (MM) is a company that makes agricultural bins, seeders, fuel tanks and other equipment. The processes are primarily metal cutting, welding and painting. The facility is currently major for Title V and HAPs. They are subject to NESHAP MMMM for surface coating.
Meridian wants to take limits to get out of Title V. This includes VOC and HAP limits for painting. When the facility becomes minor for HAPs they will no longer be subject to NESHAP MMMM. They will become subject to NESHAP 6X for area sources. This will require the 6X language to be in the permits for painting, machining and welding. MM wants to leave open the option to use paints and metals with the MFHAPs. 
SIC/NAICS: 3523, 3443/333111

Pollutant(s) Emitted: VOC, PM, HAP

Compliance Status: 14 entries in database. Two are open, this project will address those issues.


Applicability Determination:
 One Source Determination:
          Is there another operation that should be considered part of this facility? 	No
          Which facility(s)/facility ID(s)?:				NA
          Details of determination or reference to when determination was made: NA
         	
 NSR-PSD-NAA:
          Attainment?:						Yes
          Twenty-eight listed source?:				No, ag equipment maker 
          "Major" source?:						No
          "Major" pollutants:					NA
          Pollutants "major" for this project:			none
         
 Title V:
 "Major" source?:						No, this project makes them minor
 "Major" pollutants:					NA
         
 NSPS: This facility is not subject to NSPS because there are no applicable subparts.
      
 NESHAP:  This facility is subject to NESHAP subpart XXXXXX, National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. Before this project the facility was a major source of HAPs and subject to NESHAP MMMM for surface coating. MM is taking advantage of the new policy that allows them to take limits and get out of major source NESHAPS.
 Iowa Administrative Code (IAC):
          567 IAC 22.1(1)		Permit required for construction of any equipment
          567 IAC 23.3(2)"a"	0.1 gr/dscf
          567 IAC 23.4(13)		0.01 gr/dscf PM for paint booths
          567 IAC 23.4(6)		0.05 gr/dscf PM for metal processing

Dispersion Modeling: Checked with the dispersion modeling section and the changes should be a net positive for modeling. Therefore no modeling is required.

Compliance Demonstration: Modifications are to the material usage limits so no additional testing is required. 
Emission Limits: 
EP 1:	PM = 0.01 gr/dscf, 40% opacity
EP 2:	PM = 0.01 gr/dscf, 40% opacity 
EP 3:	PM = 0.01 gr/dscf, 40% opacity
EP 4:	PM = 0.01 gr/dscf, 40% opacity
EP 5:	PM = 0.01 gr/dscf, 40% opacity
EP 6:	PM = 0.01 gr/dscf, 40% opacity
EP 10:	PM = 0.01 gr/dscf, 40% opacity
EP 23:	PM = 0.05 gr/dscf, 0.514 lb/hr, 40% opacity
EP 30:	PM = 0.1 gr/dscf, 2.1 lb/hr
		PM10 = 2.1 lb/hr
EP 31:	PM = 0.1 gr/dscf, 2.1 lb/hr
		PM10 = 2.1 lb/hr
EP 32:	PM = 0.1 gr/dscf, 2.1 lb/hr
		PM10 = 2.1 lb/hr
EP 33:	PM = 0.1 gr/dscf, 2.1 lb/hr
		PM10 = 2.1 lb/hr
EP 34:	PM = 0.1 gr/dscf, 2.1 lb/hr
		PM10 = 2.1 lb/hr

EP
PM10 tpy
VOC tpy
SHAP tpy
 THAP tpy

1
3.38
90.4
3.8
4.8

2
3.38




3
3.38




4
3.38




5
3.38




6
3.38




10
1.5
1.1
1.1
1.1

23
2.25




30
8.0




31
8.0




32
4.0




33
4.0




34
4.0




Total
52.03
91.5
4.9
5.9



   

Operating Limits: 
Spray booths limited to 40,000 gallons/yr paint @ 4.52 lb/gal VOC, 0.19 lb/gal SHAP, 0.24 lb/gal THAP. Limited to 700 gal/yr solvent @ 7.5 lb/gal. NESHAP 6X monitoring and work practice requirements. 
Welding areas limited in the hours of operation due to previous modeling. NESHAP 6X work practices and opacity monitoring.
Plasma Table limited in the hours of operation due to previous modeling. NESHAP 6X work practices.


Emission Calculations:	
40,000(4.52)/2000 = 90.4 tpy VOC
40,000(0.19)/2000 = 3.8 tpy SHAP
40,000(0.24)/2000 = 4.8 tpy THAP
700(7.5)/2000 = 2.63 tpy VOC, SHAP, THAP
Total = 90.4 + 2.63 = 93.03 tpy VOC, 3.8 + 2.63 = 6.43 tpy SHAP, 4.8 + 2.63 = 7.43 tpy THAP
Welding (1, 2): 2.1 lb/hr(21 hr/day)(365)/2000 = 8.0 tpy x 2 = 16 tpy
Welding (3, 4, 5): 2.1 lb/hr(10.5 hr/day)(365)/2000 = 4.0 tpy x 3 = 12.1 tpy
Powder coat: 25 lb/hr(8760)/2000 = 109.5 tpy  assume 1% emitted as VOC: 109.5(0.01) = 1.1 tpy VOC



Facility-wide Emissions Inventory Completed?			No

Draft Permits:

Draft Permit(s) sent to Facility?	Yes, 7/9/18
Significant Comments: No comments


Attachments to Evaluation:
   	Emission Calculations
   	Facility Wide Emissions Calculations
   	Dispersion Modeling Memo
   	Correspondence (emails or letters)
   	Phone log(s)
   	Process Research
   	Timeline
   	Regulations
   	Stack Test(s)
   		Other Supporting Documentation
   	Compliance Work Request
