### Nelco, Process Heater, A/N 371784

Rick Lee t

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.govSOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages 7 Page 1

STATIONARY SOURCE COMPLIANCE DI VISION 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 , THERM AL OIL HEATER, AMERICAN HYDROTHERM, MODEL
NO. 1200

- 4D

- 90, SERIAL NO. AM

- 2957, WITH ONE 19

- MMBTU/HR NATURAL

GAS LOW

- NOX BURNER, ALZETA, MODEL NO. CSB

- 22

- 250

- 3015.



# History

The company is a NO

x 

### RECLAIM and non

- Title V facility. The above application was s ubmitted 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 o 

### F hot oil provides the necessary heat used in lamination of different plastic panels. The lami nation 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 52SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages 7 Page 2

STATIONARY SOURCE COMPLIANCE DI VISION A/N 371784 Date

07

- 28

- 00

APPLICATION PROCESSING AND CALCULATIONS Processed by
RNL Checked by

________________________________ ________________________________ ________________________________ __________



# Emission Ca lculations

Combustion related emissions are emitted from the use of the

heater:

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 7 Page 3

STATIONARY SOURCE COMPLIANCE DI VISION A/N 371784 Date

07

- 28

- 00

APPLICATION PROCESSING AND CALCULATIONS Processed by
RNL Checked by

________________________________ ________________________________ ________________________________ __________



# 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 cl eanest 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 equipmen t will emit less than 12 ppm NO

x 

### and less than 50 ppm CO at 3% O 2 

### . 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 7 Page 4

STATIONARY SOURCE COMPLIANCE DI VISION 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 pub lic 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 NO x PM 10 SO 2 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 7 Page 5

STATIONARY SOURCE COMPLIANCE DI VISION A/N 371784 Date

07

- 28

- 00

APPLICATION PROCESSING AND CALCULATIONS Processed by
RNL Checked by

________________________________ ________________________________ ________________________________ __________



### Rule 212(g): This secti on 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 equipmen t:

Controlled Emissions (lb/dy)

ROG NO x PM 10 SO 2 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 expe cted 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 g rain/ft 3 

### is the most stringent

limit. The total PM concentration from the above equipment has been estimated to be 8.8E

- 9 grain/ft 3 

### , well below the limit. Therefore, compliance is expected.

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

em issions, 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 7 Page 6

STATIONARY SOURCE COMPLIANCE DI VISION 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

Va lue Compliance

Status



### CO (ppmv) 2000 50 Yes

SO 2 

### (ppmv) 500 0.33 Yes

Rule 409: Compliance is expected.

Rule 409

Limit Calculated

Value Compliance

Status


### PM (grain/ft 3 

### ) 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 H 2 

### S.

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

NO
x 

### and less than 50 ppm CO at 3% O 2 

### . Thus, compliance is expected.

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

NO
x 

### 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 ca lculated emissions from this project must be

less than limits below:

Rating (BTU/hr) NO x

(lb/hr)

Limit CO

(lb/hr)

Limit PM 10

(lb/hr)

Limit NO x

(lb/hr)

Calculated

(RULE 2005) CO

(lb/hr)

Calculated

(RULE 1303) PM 10

(lb/hr)

Calculated

(RULE 1303)

Non

comb ustion 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 0.22SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT Pages 7 Page 7

STATIONARY SOURCE COMPLIANCE DI VISION 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 estima ted emissions have been entered in the District NSR program:

30

- Day (lb/dy)

ROG NO x PM 10 SO 2 CO Pb

Oil Heater 1.9 5 4 .2 13 0



### NO
x 

### external offsets are not needed since the facility is a NO

x 

### RECLAIM.

ROG, CO, SO
x 

### and PM 10 

### external offsets are not

ne eded 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 applicabl e District Rules and Regulations. Approval of the draft Section H of the Facility Permit is recommended.