Nelco, Process Heater, A/N 371784

Rick Lee 

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o

:

Shaheerah Kelly 02/16/2010 10:51 AM

History: This message has been replied to and forwarded.

Hi Kelly,

Per your request, please find the attached pdf file of my engineering evaluation.  In a separate email, I

will attach a pdf file of the actual permit.

Please let me know if you have any other questions.

Rick Lee

Air Quality Engineer

South Coast AQMD

Team B

909-396-2629

909-396-3350 (fax)

rlee@aqmd.gov 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages

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STATIONARY SOURCE COMPLIANCE DIVISION A/N

371784

Date

07-28-00

APPLICATION PROCESSING AND CALCULATIONS Processed by

RNL

Checked by

__________________________________________________________________________________________________________

Permit to Construct

THERMAL OIL HEATER

Legal Owner ID: 40483

or Operator: NELCO PROD. INC

1411 E. ORANGETHORPE AVE

FULLERTON, CA 92631-5297

Equipment

Location: SAME AS ABOVE

Equipment Description:

A/N 371784 (New Construction)

DEVICE NO. D6 , THERMAL OIL HEATER, AMERICAN HYDROTHERM, MODEL 

NO. 1200-4D-90, SERIAL NO. AM-2957, WITH ONE 19-MMBTU/HR NATURALGAS LOW-NOX BURNER, ALZETA, MODEL NO. CSB-22-250-3015.

History

The company is a NOx RECLAIM and non-Title V facility. The above 

application was submitted as Class I and deemed complete on 6/23/00. 

The project is subject to Rule 1401, as amended March 17, 2000.

Process Description

The company manufactures plastic panels that are used in the 

manufacturing of printed circuit boards (PCB). However, PCBs are not 

manufactured on site. The above equipment will be used to heat hot 

oil which is re-circulating inside lamination presses. Hot oil at 

about 550 oF hot oil provides the necessary heat used in lamination of 

different plastic panels. The lamination presses are exempted 

equipment pursuant to Rule 219(j)(1) since no VOC or chlorinated 

blowing agent is present.

The above heater will be operated according to the following 

schedule:

Hr/dy dy/wk wk/yr

Normal 24 7 52

Maximum 24 7 52
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages

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STATIONARY SOURCE COMPLIANCE DIVISION A/N

371784

Date

07-28-00

APPLICATION PROCESSING AND CALCULATIONS Processed by

RNL

Checked by

__________________________________________________________________________________________________________

Emission Calculations

Combustion related emissions are emitted from the use of the 

heater:

Thermal Oil Heater @

(A/N 371784)

maximum normal

hr/dy 24 24 max heat input 1.90E+07 (BTU/hr)

dy/wk 7 7 gross heating value 1050 (BTU/scf)

wk/yr 52 52

load 100% 60%

Emission MAX AVE MAX 30-DAY MAX MAX

Factors (lb/hr) (lb/hr) (lb/dy) (lb/dy) (lb/yr) (ton/yr)

SO2 (R1) 0.6 0.011 0.007 0.261 NA 95 0.047

SO2 (R2) 0.6 0.011 0.007 0.261 0.200 95 0.047

NO2 (R1) 140 2.533 1.520 60.800 NA 22,131 11.066

NO2 (R2) 15 0.271 0.163 6.514 4.994 2,371 1.186

CO (R1) 35 0.633 0.380 15.200 NA 5,533 2.766

CO (R2) 40 0.724 0.434 17.371 13.318 6,323 3.162

N2O (R1) 2.2 0.040 0.024 0.955 NA 348 0.174

N20 (R2) 2.2 0.040 0.024 0.955 0.732 348 0.174

PM, PM10 (R1=R2) 11.9 0.215 0.129 5.168 3.962 1,881 0.941

CO2(R1=R2) 1.20E-05 0.000 0.000 0.000 0.000 0 0.000

TOC(R1=R2) 5.8 0.105 0.063 2.519 1.931 917 0.458

acetaldchyde 0.0043 7.8E-05 4.7E-05 1.9E-03 NA 6.80E-1 3.40E-4

acrolein 0.0027 4.9E-05 2.9E-05 1.2E-03 NA 4.27E-1 2.13E-4

benzene 0.008 1.4E-04 8.7E-05 3.5E-03 NA 1.26E+0 6.32E-4

formaldehyde 0.017 3.1E-04 1.8E-04 7.4E-03 NA 2.69E+0 1.34E-3

napthalene 0.0003 5.4E-06 3.3E-06 1.3E-04 NA 4.74E-2 2.37E-5

PAH's 0.0001 1.8E-06 1.1E-06 4.3E-05 NA 1.58E-2 7.90E-6

toluene 0.0366 6.6E-04 4.0E-04 1.6E-02 NA 5.79E+0 2.89E-3

xylenes 0.0272 4.9E-04 3.0E-04 1.2E-02 NA 4.30E+0 2.15E-3

NO2 @ 3% excess O2------>>> 11.56 (ppmv) SO2 @ 3% excess O2------>>> 0.33 (ppmv)

CO @ 3% excess O2------>>> 50.62 (ppmv) PM @ 12% CO2------>>> 8.8E-09 (grain/ft3

)

Ver. 1.3

I have assumed that the gross heating value of natural gas is 

1050 BTU/hr. Emission factors are taken from AP-42, section 1.4, 

revised 10/96, and from AB2588 program, revised 9/95. The following 

equation is used to compute the hourly emissions:
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages

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STATIONARY SOURCE COMPLIANCE DIVISION A/N

371784

Date

07-28-00

APPLICATION PROCESSING AND CALCULATIONS Processed by

RNL

Checked by

__________________________________________________________________________________________________________

( )

)

10

. (10 ) (

( / )

3

6 3

6

ft

BTU Gross Heating Value

ft

lb Emission Factor of i compound

hr

BTU Max Heat Input Rating

Emissions of i compound from the combustion of natural gas lb hr

th

th





Toxic Evaluation

This project is subject to Rule 1401, as amended March 17, 2000. 

The calculated emissions of TACs are less than the Tier-1 screening 

emission levels found in Table 1A of Risk Assessment Procedures for 

Rules 1401 and 212, Version 5.0, September 1999. Tier II analysis is 

not needed for these types of equipment based on past experience and 

T-BACT is the use of the cleanest fuel such as natural gas.

Based on the above finding, Rule 212(c)(3) public notification is 

not required prior to the granting of a Permit to Construct the above 

equipment.

BACT Evaluation

The burner manufacturer has guaranteed that the equipment will 

emit less than 12 ppm NOx and less than 50 ppm CO at 3% O2. The 

proposed Permit to Construct will require a source test to confirm 

these emission levels. Thus, the equipment meets BACT.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages

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STATIONARY SOURCE COMPLIANCE DIVISION A/N

371784

Date

07-28-00

APPLICATION PROCESSING AND CALCULATIONS Processed by

RNL

Checked by

__________________________________________________________________________________________________________

Rule Evaluation

Rule 212(c)(1): This section requires a public notice for all new or modified permit units 

that may emit air contaminants located within 1,000 feet from the outer 

boundary of a school.

Since no school is located within 1,000 ft from 

the emission source, a public notice will not be 

required.

Rule 212(c)(2): This section requires a public notice for all new or modified facilities 

that have on-site emission increases exceeding any of the daily maximums as

specified by Rule 212(g).

Controlled Emissions (lb/dy)

ROG NOx PM10 SO2 CO Pb

Entire Project 3 7 5 0.3 17 0

MAX Limit 30 40 30 60 220 3

Required Public Notice No No No No No No

The above table summarizes the emission limits and 

increases. Since emission increases are less than

the limits, a public notice will not be required.

Rule 212(c)(3): There will be increases in TACs, but MICR should 

be less than 1E-6 since the TAC emission levels 

comply with the Tier-1 screening emission level. 

Thus, a public notice will not be required. 

Please see Toxic Evaluation section.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages

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STATIONARY SOURCE COMPLIANCE DIVISION A/N

371784

Date

07-28-00

APPLICATION PROCESSING AND CALCULATIONS Processed by

RNL

Checked by

__________________________________________________________________________________________________________

Rule 212(g): This section requires a public notice for all new or modified sources that 

have equipment emission increases exceeding any of the daily maximums as 

specified by Rule 212(g).

The following table summarizes the limit and 

Potential-to-Emit (PTE) emissions per equipment:

Controlled Emissions (lb/dy)

ROG NOx PM10 SO2 CO Pb

Entire Project 3 7 5 0.3 17 0

MAX Limit 30 40 30 60 220 3

Required Public Notice No No No No No No

Thus, this section does not require a public 

notice.

Rule 401: Visible emissions are not expected with the proper 

operation of the equipment.

Rule 402: Nuisance is not expected with the proper operation 

of the equipment.

Rule 404: Table 404(a) specifies limits of PM concentrations 

in an effluent gas stream at standard conditions, 

of which 0.01 grain/ft3 is the most stringent 

limit. The total PM concentration from the above 

equipment has been estimated to be 8.8E-9 

grain/ft3, well below the limit. Therefore, 

compliance is expected.

Rule 405: Table 405(a) specifies limits of maximum hourly PM 

emissions, of which 0.99 lb/hr is the most 

stringent limit. The total maximum hourly PM 

emission has been estimated to be 0.13 lb/hr, well

below the limit. Therefore, compliance is 

expected.
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages

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STATIONARY SOURCE COMPLIANCE DIVISION A/N

371784

Date

07-28-00

APPLICATION PROCESSING AND CALCULATIONS Processed by

RNL

Checked by

__________________________________________________________________________________________________________

Rule 407: Compliance is expected.

Rule 407 

Limit

Calculated 

Value

Compliance 

Status

CO (ppmv) 2000 50 Yes

SO2 (ppmv) 500 0.33 Yes

Rule 409: Compliance is expected.

Rule 409 

Limit

Calculated 

Value

Compliance 

Status

PM (grain/ft3) 0.1 8.8E-9 Yes

Rule 431.1: Compliance is met by the use of natural gas. Rule 

431.1(c)(1) requires the Gas Company to supply 

only the low-sulfur content natural gas, 

containing no more than 16 ppmv of H2S.

Rule 1146: The equipment is expected to emit less than 12 ppm 

NOx and less than 50 ppm CO at 3% O2. Thus, 

compliance is expected.

Rule 1303(a): The equipment is expected to emit less than 12 ppm 

NOx and less than 50 ppm CO at 3% O2. Thus, 

compliance is expected (See BACT Evaluation for 

more details).

Rule 1303(b)(1)& 2005:

In order to be exempted from modeling requirement,

the calculated emissions from this project must be

less than limits below:

Rating

(BTU/hr)

NOx

(lb/hr)

Limit

CO

(lb/hr)

Limit

PM10

(lb/hr)

Limit

NOx

(lb/hr)

Calculated

(RULE 2005)

CO

(lb/hr)

Calculated

(RULE 1303)

PM10

(lb/hr)

Calculated

(RULE 1303)

Non

combustion

0.068 3.7 0.41

<2 0.2 11.0 1.2

>2 <5 0.31 17.1 1.9

>5 <10 0.47 25.9 2.8

>10 <20 0.86 47.3 5.2

>20 <30 1.26 69.3 7.6 0.3 0.7 0.22
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages

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STATIONARY SOURCE COMPLIANCE DIVISION A/N

371784

Date

07-28-00

APPLICATION PROCESSING AND CALCULATIONS Processed by

RNL

Checked by

__________________________________________________________________________________________________________

Further air quality modeling analysis is not 

needed.

Rule 1303(b)(2) & 2005:

The following estimated emissions have been 

entered in the District NSR program:

30-Day (lb/dy) 

ROG NOx PM10 SO2 CO Pb

Oil Heater 1.9 5 4 .2 13 0

NOx external offsets are not needed since the 

facility is a NOx RECLAIM.

ROG, CO, SOx and PM10 external offsets are not 

needed since the estimated emissions of these 

pollutants are less than 4 tons per year.

Rule 1401: Compliance is expected. Please see Toxic 

Evaluation section for more details.

Recommendation

The proposed project is expected to comply with all applicable 

District Rules and Regulations. Approval of the draft Section H of 

the Facility Permit is recommended.