### M EMORANDUM

TO: Toni Jones, Charlene Spells, Ketan Patel U.S. Environmental Protection Agency

FROM: Brian Shrager, U.S. Environmental Protection Agency, Kristen James and Jason

Huckaby, Eastern Research Group, Inc.

DATE: April 14, 2010

SUBJECT: Burn Off Oven Clarification Request Summary

1. 0 Introduction

T his memorandum summarizes the information collected in a follow up survey of Commercial and Industrial Solid Waste Incineration (CISWI) units classified as burn off ovens in the database. The purpose of this follow up survey was to obtain additional information in order to address concerns with testing these units. Attachment A provides a summary table of the facilities and their survey response. Attachment B includes the original response from each facility.

2.0 Information Collection

C ISWI facilities that identified themselves as the owner or operator of a burn off oven and received the EPA section 114 ICR letter requiring emissions testing by October 15, 2009 were asked to respond to questions in a follow up email. An email from Brian Shrager with the Environmental Protection Agency (EPA) was sent to facilities on June 25, 2009. Mr. Shrager requested that facilities answer the following questions for each oven for which the facility received a test request:

1) What is the cycle time of the unit for which testing has been requested? 2) Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time). 3) What size is the stack? 4) What types of stack/platform modifications (just those that you know about now) would be required to complete the testing? 5) Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is
it a natural draft? 6) Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)? 7) What are the estimated testing costs for your unit? 8) In the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs?

### 9) Do you know the composition of the materials that are "burned off" in the oven? If

yes, do the materials contain metals or chlorine?10) What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber? 11) Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means? 12) Please feel free to provide any other information that you believe may be pertinent to the feasibility of emission testing.

EPA received a follow up response from 11 facilities contacted for this survey.FacilityID UnitID Contact What is the cycle time of the unit for which testing has been requested? Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time). What size is the stack?

CNH - Burlington
IACNHAmerica INC-1 Audrey Van Dyke 7 hrs (+ ramp time @ max ramp) Max ramp to 450oF, "soak" for one hour; max ramp to 550oF, "soak" for two hours; max ramp to 650o, "soak" for two hours; max ramp to 750o, "soak" for two hours. Circular - 12 inches

CNH -
Grand Island
NECNHAmericaGrandIsland ID 7996 Audrey Van Dyke 3.25 hours Startup 0.75 hr, Bake 2 hr, Cool 0.5 hr 18 inches

CNH -
New Holland
PACNHAmericaNewHolland INC-1 Audrey Van Dyke varies - typically 6-9 hrs. Startup 0.75 hr; bake 2-4 hr; cool down
about 3-4 hr. 18 Inches

OHWhirlpoolClyde N001 Bob Karwowski 12 hour burn cycle typical. Only one cycle completed in a 24 hour period. Wet paint processes can have lower cycle time of around 8 hours. Start-up: 1 hour; full burn 2-4 hours; remainder of time polishing to complete pyrolysis. Circular - 14 inches ID, 18 inches OD; 2 inch ceramic lining

INWhirlpool Pyrolytic
Oven #1 Bob Karwowski 5 hours typical, 6 hours max. Only one cycle is completed per day. Start-up: 1 hour; full burn 1-2 hours; remainder of time polishing to complete pyrolysis. Circular - 14 inches ID, 18 inches OD; 2 inch ceramic lining

FLSolutia CP-L Roy Noble Varies - but typically operated overnight for about 14-16 hours, not including cool down. Heat up: 4 hours; max burn: 10-12 hours; cool down based on equipment being
reclaimed Two stacks approximately 25 ft above grade and 10-12 inch ID (16 inch OD with 2-3 inches of insulation)

Cooper Standard KYCooperStandard SN-17 Chris Massaro 8 hours Heat up: 90 minutes; 8 hours max burn;
60 minutes cool down 10 inch ID, 14 inch OD, top of stack is
93 inches above roof
Sealed Air Corporation SCCryovac FB01 Meredith Mangum The fluidized bed’s (FB-01) cycle time is dependant upon

the part being loaded and the level of assembly/disassembly. Traditional processing times for equipment loaded into FB-01 includes a two hour heating cycle. The temperature of the bed drops between 25 and 50 degrees Celsius immediately after the cage of parts is loaded into the unit. During the first 20 minutes after loading the parts cage, a natural gas burner is fired to raise the bed to optimum temperature (approximately 450oC) and stabilize bed conditions (air flow, temperature,). During the handling and cleaning of the metal parts, the sand bed is maintained at an elevated temperature for approximately 1 hour and 40 minutes. The fluidized bed enclosure is then opened and the parts removed. The fluidized bed is maintained at temperature awaiting the loading of the next set of parts. Some larger extruder dies may require up to 4
hours of immersion in the sand bed Once heated, the parts/cage is placed in a separate water quench bath for approximately 15 minutes to drop the temperature of the equipment and remove any residual sand. The cooled parts are then dipped in an oil quench tank to coat the parts with a light oil to protect the equipment and assist in the re-assembly process. A total of Four dies or batches may be processed each day (24 hour period). Once the fluidized bed has reached to operating temperature, the cycling time is dependant upon the level of metal parts assembly/disassembly and the
size of the die itself. Most die equipment at the Simpsonville plant take approximately 2 hours To clean, while a couple of large units may take up to 4 hours. In rare instances, the die is loaded into the fluidized bed intact (not disassembled). Since the sand does not directly contact all the parts, the die must
remain in the heated bath for approximately 6 to 8 hours. This event is limited to the cleaning of R&D dies which may include confidential or patented applications. From the roofline, a twenty-four (24)
inch stack extends 28 feet above the die maintenance shop roofline. The air
flow from two fans combine approximately 2 feet below the roofline.

VAQuadrantEPP Controlled Pyrolysis Cleaning
furnace
Model
SCTR-9 David K Bowles 16 hours Furnace: Heat up: 4 hours; Max burn: 4 hours; Cool down: 8 hours Afterburner: Heat up 4 hours; max burn 4 hours; cool down 8 hours 10 inch diameter with 17 ft straight duct through roof to rain shield

WabashNational
INWabashNational855 BO Andrew Frisbie 5 hours Heat up and completion of max burn cycle: 4 hours; Cool-down: 1 hour 30 inches

TXMadix Building C -
Burn-off
Oven Barry Robinson 2- 3 hours total. (Answered: 30 minutes to 1 hour, but this was for max burn portion of cycle only) Heat up: 1.5-2 hours; Max burn 30 minutes to 1 hour, depending on whether hanging from rack or placed in a tub. 20 inch Appendix A - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTSFacilityID UnitID Contact What types of stack/platform modifications (just those that you know about now) would be required to complete the testing? Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it a natural
draft? Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)?

CNH - Burlington
IACNHAmerica INC-1 Audrey Van Dyke Minor stack modifcations Natural draft The PM2.5 is a concern because of high stack temperatures (this is an in stack measurement using a filter that could be affected by high temperatures).

CNH -
Grand Island
NECNHAmericaGrandIsland ID 7996 Audrey Van Dyke Minor stack modifcations forced burner fan The PM2.5 is a concern because of high stack temperatures (this is an in stack measurement using a filter that could be affected by high temperatures).

CNH -

New Holland
PACNHAmericaNewHolland INC-1 Audrey Van Dyke Minor stack modifcations forced burner fan w/ draft damper in

stack The PM2.5 is a concern because of high stack temperatures (this is an in stack measurement using a filter that could be affected by high temperatures).
OHWhirlpoolClyde N001 Bob Karwowski Install two 4 inch sampling ports - $500 No induced draft fan. Forced burner fan (but manufacturer claims natural draft) PM2.5 cyclone would not survive high stack temp (1400-1800 deg F). Glass probes may melt for metals test. High moisture levels of flue gas may affect methodology.
INWhirlpool Pyrolytic
Oven #1 Bob Karwowski Would need to install a platform 10 feet tall for testing. Also require stack extension and 4 inch port ($450). Would need cyclone for PM testing. No induced draft fan. Forced burner fan (but manufacturer claims natural draft) PM2.5 cyclone would not survive high stack temp (1400-1800 deg F). Glass probes may melt for

metals test.

FLSolutia CP-L Roy Noble Will likely need to significantly modify stack to provide ports, heat shield for sampler protection, support structure for stack, build a sample platform, and removal of rain cap during testing. No, natural draft. PM2.5 due to temperature limitations of method sampling apparatus.

Cooper Standard KYCooperStandard SN-17 Chris Massaro Add test ports No, natural draft. Stack temperature and flowrate are concerns. Process throughput measurements will be difficult since there are approximately 200-400 pounds per rack and less than 1 pound of material being burned off on each rack. It may take several

weeks to run all of the tests.

Sealed Air Corporation SCCryovac FB01 Meredith Mangum The roof for the fluidized bed building is

a modestly sloped sheet metal roof with

steel beam reinforcement. To facilitate stack testing, the facility has installed two sampling ports 90 degrees apart and more than 2 diameters of straight

section downstream from the last interruption. Stack hangers are present to hold/secure testing equipment approximately 12 feet above the

roofline. For a source tester to have adequate space and proper access to the sampling ports, at least four levels of scaffolding would be required. Yes. The system is designed with two cyclones in parallel to capture heated sand particles and protect the
induced draft fans from abrasion. As the air exists the cyclones, the exhaust temperature is reduced to approximately 225oF prior to exhaust. The requested testing would require 4 hour test runs, while the batch process only operates two hours at a time. To perform the required testing the bed would have to be opened during the sampling run to change out parts. This would cause periods of no emissions during each test run as well as periods of process stabilization. Due to the short notice for testing, Sealed Air would be unable to hold or accumulate parts for longer test runs. Only two large dies are scheduled for processing in the next two months. Several small batches or short cycle times may be performed each day. Current equipment loads may not allow for continuous testing of the unit.

VAQuadrantEPP Controlled Pyrolysis Cleaning

furnace
Model SCTR9 David K Bowles Install two test ports and extend stack height to meet Method 1 requirements. No, natural draft. Estimated flue gas

rate of 450 - 650 acfm at 1600 o F. P M, PM2.5 and any isokinetic sampling will be problematic. Cycle time modifications may be necessary to sample, especially Method 23.

WabashNational

INWabashNational855 BO Andrew Frisbie Add sampling ports and perform sampling using a boom lift. Natural draft To be determined

TXMadix Building C -

Burn-off
Oven Barry Robinson Unknown, possibly a staged product burning not realistic to plant operations. Natural draft Inaccurate or unable to get D/F readings, stack flow, a "less than" number for metals Appendix A (cont.) - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTSFacilityID UnitID Contact What are the estimated testing costs for your unit? In the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs? Do you know the composition of the materials that are "burned off" in the oven? If yes, do the materials contain metals or chlorine?

CNH - Burlington
IACNHAmerica INC-1 Audrey Van Dyke $50,000 - $55,000 The batch cycle time was taken into consideration by the consultant when they developed the cost. The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a review of environmental data sheets for 2008, the paint residue does not contain chlorine. Several low volume coatings contained HAP metals (cobalt, chromium and copper). Most of this would have been applied to our product and would not be on the hooks and racks that are
cleaned in the oven.

CNH -
Grand Island
NECNHAmericaGrandIsland ID 7996 Audrey Van Dyke $50,000 - $55,000 The batch cycle time was taken into consideration by the consultant when they developed the cost. The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a review of environmental data sheets for 2008, the paint residue does not contain any HAP
metals or chlorine.

CNH -
New Holland
PACNHAmericaNewHolland INC-1 Audrey Van Dyke $50,000 - $55,000 The batch cycle time was taken into consideration by the consultant when they developed the cost. The burnoff oven removes dried and cured paint from metal hooks and racks. Based on a review of environmental data sheets for 2008, the paint residue does not contain chlorine. One low volume coating contained a HAP metal (a total of 1.74 lb cobalt compounds based on 100 gallons of coating supplied to CNH). Most of this would have been applied to our product
and would not be on the hooks and racks that are cleaned in the oven.

OHWhirlpoolClyde N001 Bob Karwowski Unknown, using EPA estimate of $52,000 Unknown - short process runs may require several days worth of testing to test for all pollutants. Yes. No heavy metals or chlorine identified by paint and powder vendors. Facility is willing to run GCMS and ICPS analysis to verify these claims. Chlorine and fluorine present in small amounts in city water used in process. Two powder coatings contain <0.25% of fluorinated chemicals (PTFE).

INWhirlpool Pyrolytic
Oven #1 Bob Karwowski Unknown, using EPA estimate of $52,000 Unknown - short process runs may require several days worth of testing to test for all pollutants. Yes. No heavy metals or chlorine identified by paint and powder vendors. Facility is willing to run GCMS and ICPS analysis to verify these claims. Chlorine and fluorine present in small amounts in city water used in process. Two powder coatings contain <0.25% of fluorinated chemicals (PTFE).

FLSolutia CP-L Roy Noble $61,000 for one stack and $115,000 for two stacks if no sigificant issues with testing (this does not include stack/platform costs). Costs are assumed based on three days of sampling, since each test run will require on batch cycle. Yes, nylon 6,6. Some products contain phosphorous at 56 ppm. Manganese is added to one product at 8-14 ppm, but this product is less than 3% of annual production. Chromium may be present at less than 1ppm in the polymer. Sulfur, chlorine, and fluorine are not present at all in any nylon.

Cooper Standard KYCooperStandard SN-17 Chris Massaro $50,000 minimum (a month's worth of profit for this facility) N/A Unknown, but unlikely to contain chlorine or metals.

Sealed Air Corporation SCCryovac FB01 Meredith Mangum Analytical Testing Consultants, Inc. has

proposed testing on similar sized units as part of the EPA 114 requests. Of their proposed efforts, sampling costs have ranged between $35,000 and $50,000 dollars. Another company has estimated testing to cost around $28,000. Such an amendment should reduce costs slightly due to the overall time on-site being reduced, but the majority of the costs are fixed (equipment/prep). Yes. The company primarily manufactures food packaging, thus nearly all materials used are approved for food contact. Furthermore, the company only allows for the cleaning of Sealed Air/Cryovac parts in the unit. The material “burned off” or gasified includes residual resin that could not be removed from the parts by hand during the Die disassembly. These resins represent the raw materials or additives that are processed in the extruder to make a finished product or film. The fluidized bed itself is designed to accept a maximum of 30 pounds of resin per batch. The equipment could be damaged if
more resin was introduced.

Sealed Air does not allow any dies or die parts that contact a chlorine containing resin from being cleaned in the fluidized bed. Any such equipment is segregated and cleaned by hand or an alternate means. Other than trace contaminants not reported by the manufacturer, the only metals within the processed
resins include titanium and zinc.

VAQuadrantEPP Controlled Pyrolysis Cleaning
furnace
Model SCTR9 David K Bowles Expect to cost over $65,000, including stack modifications, which is more than unit's value. Unknown. Yes. No chlorine or metals are present in the products destroyed in this oven.

WabashNational
INWabashNational855 BO Andrew Frisbie To be determined To be determined Yes, based on the MSDS of the powder coating. No chlorine or metals known.

TXMadix Building C -
Burn-off
Oven Barry Robinson Verbal quote of $20,000, and written quote of $33,000 Unknown, but thinks it would reduce costs substantially. Yes. Powder coating hanging wires. Per 6/09 TCLP analytical results, ash from burn-off oven contains metals but not at hazardous levels. MSDS's of all coatings that might be removed via the burn-off oven can be provided. Appendix A (cont.) - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTSFacilityID UnitID Contact What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the maximum operating temperature of each chamber? Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is

heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means? Any additional information provided?

CNH - Burlington
IACNHAmerica INC-1 Audrey Van Dyke Main chamber (750 o F) and afterburner (1400 o F) No. No.

CNH -
Grand Island
NECNHAmericaGrandIsland ID 7996 Audrey Van Dyke 1000 o F (Main chamber) and afterburner (minimum 1400oF) No. No.

CNH -
New Holland
PACNHAmericaNewHolland INC-1 Audrey Van Dyke Main chamber (800 o F) and afterburner (1400 o F minimum) No. No.

OHWhirlpoolClyde N001 Bob Karwowski 800 o F in oven chamber, and 1400 o F to 1800 o F in afterburner. Can peak at 880 o F in oven and 2000 o F in afterburner Yes, but may not be true combustion. Heat is used in a moisture starved air atmosphere where material is decomposed into ash. The coating on the ware will smolder
and the smoke that evolves will enter the afterburner chamber for final destruction. Consider this a controlled air, pyrolytic oven.

INWhirlpool Pyrolytic
Oven #1 Bob Karwowski 800 o F in oven chamber, and 1500 o F in afterburner. Can peak

at 880 o F in oven and 2000 o F in afterburner Yes. All organics are pyrolyzed at the end of the cycle. Only the inorganic materials remain, which would be titanium dioxide powder residue on the racks and carriage. These are washed off in an enclosed spray booth with a pressurized water wand. Consider this a controlled air, pyrolytic oven. Adds comment to consider testing of materials being burned off instead of stack testing. Site is next to airport and may have limits on stack heights. If stack height must be increased to perform sampling, may need to clear with FAA beforehand. Suggest testing Clyde, OH unit instead of this one since processes are identical and OH site has higher throughput loading and no potential stack height concerns.

FLSolutia CP-L Roy Noble 900 o F in oven chamber, and 1550 o F or greater in afterburner. Materials are combusted. A small amount of ash may be present at end of cycle. The major use of this oven is during maintenance overhauls of continuous polymerization machines. Currently there are no overhauls planned within the testing window. Some minor use of the burn off oven does occur but is not representative of the primary use during overhauls.
Cooper Standard KYCooperStandard SN-17 Chris Massaro 800 o F in furnace chamber, and 1400-1600 o F in afterburner. Organic material is vaporized and then combusted in afterburner. Inorganic material falls to floor and is swept up for disposal. The process is very low volume running approx. 16-24 hours per week depending on customer volume. There may not be enough work to run all the tests needed, requiring multiple mobilizations of testers. The cost of this testing is prohibitive. This facility is an automotive OEM supplier, and the industry is in financial peril. Testing would be an enormous fiscal burden to this operation.

Sealed Air Corporation SCCryovac FB01 Meredith Mangum The fluidized bed system is a single-chamber unit that is heated

to 4500 C to heat and clean the metal die parts. The small quantities of residual resins that are not removed during the equipment disassembly process will gasify at the elevated temperatures. A flame which extends over the surface of the bed causes the gaseous
VOCs to be combusted. Since the fluidized bed operations schedule is dependant on equipment maintenance schedules, it is very difficult to plan source testing events for large parts (or longer cycling times). Some large equipment is scheduled for processing once every ten years, while smaller parts are cleaned much more frequently.

The batch cycling times and the EPA method run times may cause difficulties in achieving the prescribed test run durations. Furthermore, the limitation on the parts to process and the number of batches per day may cause testing firms to remain onsite for extended periods. Testing would necessarily include process startup/stabilization period. Normalized resin loading or approaching maximum capacity would be difficult based upon a tight maintenance
schedule.

VAQuadrantEPP Controlled Pyrolysis Cleaning
furnace
Model SCTR9 David K Bowles 1100 o F in furnace chamber, and 1400-1600 o F in afterburner. Range of furnace chamber is 900-1100 o F, and afterburner is

1400-1600 o F. The chamber pyrolyzes the plastics and the afterburner oxidizes the off gases. In this case, materials cleaned in this oven are not "burned off" as EPA believes. Traditional burning off causes hot spots that may cause damage to materials (internal cracks), leading to loss of quality. A pyrolysis oven is an improved version of the burnout oven because parts are heated up in a more controlled way. Pyrolysis ovens prevent uncontrolled combustion of binding agents, preventing crack formation. The amount of material coated on tools being cleaned is an average 5.3 pounds/batch and represents less than 1.5% on a BTU basis of input to process.

WabashNational
INWabashNational855 BO Andrew Frisbie 800 o F in main chamber, and 1500 o F in secondary chamber. The powder coating completely bakes off and turns into a very fine ash.

TXMadix Building C -
Burn-off
Oven Barry Robinson 815 o F in oven chamber, and afterburner is set to 1400 o F, with a high temperature setting for the stack at 1600 o F. Heat breaks the bond of the coating material from the hanging wires and oven ash is disposed of as class 2 material through a landfill. Appendix A (cont.) - SUMMARY OF INPUT FROM BURN-OFF OVEN RESPONDENTS

### Appendix B – Original Survey ResponsesBurlingtonGrand IslandNew HollandINC-1ID 7996INC-1What is the cycle time of the unit for which testinghas been requested?7 hrs (+ ramp time @ max ramp)3.25 hoursvaries - typically 6-9 hrs.Please provide a breakdown of the cycle time(e.g., start-up time (hours), maximum heat time,cool-down time).Max ramp to 450oF, "soak" for one hour; maxramp to 550oF, "soak" for two hours; max rampto 650o, "soak" for two hours; max ramp to 750o,"soak" for two hours.Startup 0.75 hr, Bake 2 hr, Cool 0.5 hr Startup 0.75 hr; bake 2-4 hr; cool down about3-4 hr.What size is the stack?Circular - 12 inches18 inches18 InchesWhat types of stack/platform modifications (justthose that you know about now) would be requiredto complete the testing?Minor stack modifcationsMinor stack modifcationsMinor stack modifcationsIs the stack equipped with an induced draft fan? Ifnot, is the draft forced by a fan or is it a naturaldraft?Natural draftforced burner fanforced burner fan w/ draft damper in stackWhich test methods, if any, have emission testcontractors expressed concerns about (regardingfeasibility of testing, ability to sample isokinetically,other)?The PM2.5 is a concern because of high stacktemperatures (this is an in stack measurementusing a filter that could be affected by hightemperatures).The PM2.5 is a concern because of high stacktemperatures (this is an in stack measurementusing a filter that could be affected by hightemperatures).The PM2.5 is a concern because of high stacktemperatures (this is an in stack measurementusing a filter that could be affected by hightemperatures).What are the estimated testing costs for your unit? $50,000 - $55,000$50,000 - $55,000$50,000 - $55,000In the Webinar, EPA indicated that for batchprocesses with short cycle times, the individualtest runs do not need to span more than one batchcycle. How would that change the estimatedtesting costs?The batch cycle time was taken intoconsideration by the consultant when theydeveloped the cost.The batch cycle time was taken intoconsideration by the consultant when theydeveloped the cost.The batch cycle time was taken intoconsideration by the consultant when theydeveloped the cost.Do you know the composition of the materials thatare "burned off" in the oven? If yes, do thematerials contain metals or chlorine?The burnoff oven removes dried and cured paintfrom metal hooks and racks. Based on a reviewof environmental data sheets for 2008, the paintresidue does not contain chlorine. Several lowvolume coatings contained HAP metals (cobalt,chromium and copper). Most of this would havebeen applied to our product and would not be onthe hooks and racks that are cleaned in theoven.The burnoff oven removes dried and curedpaint from metal hooks and racks. Based on areview of environmental data sheets for 2008,the paint residue does not contain any HAPmetals or chlorine.The burnoff oven removes dried and curedpaint from metal hooks and racks. Based on areview of environmental data sheets for 2008,the paint residue does not contain chlorine.One low volume coating contained a HAPmetal (a total of 1.74 lb cobalt compoundsbased on 100 gallons of coating supplied toCNH). Most of this would have been appliedto our product and would not be on the hooksand racks that are cleaned in the oven.What is the maximum operating temperature ofthe unit, or, in the case of multi-chamber units, themaximum operating temperature of eachchamber?Main chamber (750oF) and afterburner (1400oF) 1000oF (Main chamber) and afterburner(minimum 1400oF)Main chamber (800oF) and afterburner(1400oF minimum)Are the materials that are removed from theparts/hooks/racks in the oven combusted? If not,is heat used to melt or break material bonds sothat the materials fall off of the parts/hooks/racksand are collected and disposed of through anothermeans?No. No.No. No.No. No.Burn off oven questionsUnit requested to be testedBurlingtonGrand IslandNew HollandINC-1ID 7996What is the cycle time of the unit for which testinghas been requested?7 hrs (+ ramp time @ max ramp)3.25 hoursPlease provide a breakdown of the cycle time(e.g., start-up time (hours), maximum heat time,cool-down time).Max ramp to 450oF, "soak" for one hour; maxramp to 550oF, "soak" for two hours; max rampto 650o, "soak" for two hours; max ramp to 750o,"soak" for two hours.Startup 0.75 hr, Bake 2 hr, Cool 0.5 hrWhat size is the stack?Circular - 12 inches18 inchesWhat types of stack/platform modifications (justthose that you know about now) would be requiredto complete the testing?Minor stack modifcationsMinor stack modifcationsMinor stack modifcationsIs the stack equipped with an induced draft fan? Ifnot, is the draft forced by a fan or is it a naturaldraft?Natural draftforced burner fanWhich test methods, if any, have emission testcontractors expressed concerns about (regardingfeasibility of testing, ability to sample isokinetically,other)?The PM2.5 is a concern because of high stacktemperatures (this is an in stack measurementusing a filter that could be affected by hightemperatures).The PM2.5 is a concern because of high stacktemperatures (this is an in stack measurementusing a filter that could be affected by hightemperatures).The PM2.5 is a concern because of high stacktemperatures (this is an in stack measurementusing a filter that could be affected by hightemperatures).What are the estimated testing costs for your unit? $50,000 - $55,000$50,000 - $55,000$50,000 - $55,000In the Webinar, EPA indicated that for batchprocesses with short cycle times, the individualtest runs do not need to span more than one batchcycle. How would that change the estimatedtesting costs?The batch cycle time was taken intoconsideration by the consultant when theydeveloped the cost.The batch cycle time was taken intoconsideration by the consultant when theydeveloped the cost.The batch cycle time was taken intoconsideration by the consultant when theydeveloped the cost.Do you know the composition of the materials thatare "burned off" in the oven? If yes, do thematerials contain metals or chlorine?The burnoff oven removes dried and cured paintfrom metal hooks and racks. Based on a reviewof environmental data sheets for 2008, the paintresidue does not contain chlorine. Several lowvolume coatings contained HAP metals (cobalt,chromium and copper). Most of this would havebeen applied to our product and would not be onthe hooks and racks that are cleaned in theoven.The burnoff oven removes dried and curedpaint from metal hooks and racks. Based on areview of environmental data sheets for 2008,the paint residue does not contain any HAPmetals or chlorine.The burnoff oven removes dried and curedpaint from metal hooks and racks. Based on areview of environmental data sheets for 2008,the paint residue does not contain chlorine.One low volume coating contained a HAPmetal (a total of 1.74 lb cobalt compoundsbased on 100 gallons of coating supplied toCNH). Most of this would have been appliedto our product and would not be on the hooksand racks that are cleaned in the oven.What is the maximum operating temperature ofthe unit, or, in the case of multi-chamber units, themaximum operating temperature of eachchamber?Main chamber (750oF) and afterburner (1400oF) 1000oF (Main chamber) and afterburner(minimum 1400oF)Are the materials that are removed from theparts/hooks/racks in the oven combusted? If not,is heat used to melt or break material bonds sothat the materials fall off of the parts/hooks/racksand are collected and disposed of through anothermeans?No. No.No. No.No. No.Burn off oven questionsUnit requested to be tested

### See the following for the answers to the questions presented in your email of June 25,

2009. These answers concern Unit CP-L at the Ascend Performance Materials LLC (formerly Solutia Inc.) Pensacola Plant.

What is the cycle time of the unit for which testing has been requested? The cycle time varies depending on amount of equipment being reclaimed and amount of polymer. As there are no methods to determine a true “end of cycle” the burn off oven is typically operated overnight to ensure complete removal of nylon 6, 6. The estimated burn off rate is 60 pounds per hour. See following question for additional details.

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time). The typical cycle time consists of a 4 hour heat up period, 10 –12 hours maximum heat time to ensure complete burn off of the nylon 6, 6 and the cool down time varies based on the equipment being reclaimed.

What size is the stack? Two (2) stacks approximately 25 feet above grade and 10 - 12 inch ID (16 inch OD with 2 – 3 inches of insulation)

What types of stack/platform modifications (just those that you know about now) would be required to complete the testing?

The stacks are self supporting and constructed of insulation surrounded sheet metal, guyed to the roof of the shed and are not equipped for stack sampling. The stacks would need to be reconstructed to add sampling ports and additional support. A heat shield would also need to be installed to protect the stack samplers. The rain cap would need to be cut off to reduce positive pressure in stack during sampling and re-welded in place after testing. The shed roof is slanted and not rated to support personnel. A sampling platform(s) would need to be constructed to support personnel and equipment.

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it
a natural draft?
Natural draft

Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)? There are concerns over the temperature of the gases in the stack and potential blockage of flow due to the small stack diameter. They believe that ports would need to installed at different planes. The testing firm specifically expressed concern over PM2.5 sampling due to the stack temperatures. While stack exhaust temperature profiles in the stacks are not known, the exit afterburner temperature is typically above 1500o F and with the relatively short stacks it is reasonable to assume that exit temperatures are above 500o F.
OTM 27 section 1.6 states: "1.6 Limitations. You cannot use this method to measure emissions following a wet scrubber because this method is not applicable for in-stack

### gases containing water droplets. To measure PM10 and PM2.5 in emissions where water

droplets are known to exist, we recommend that you use Method 5. This method may not be suitable for sources with stack gas temperatures exceeding 260°C (500°F). You may need to take extraordinary measures—including the use of specialty metals (e.g., Inconel) to achieve reliable particulate mass since the threads of the cyclones may gall or seize, thus preventing the recovery of the collected particulate matter and rendering the cyclone unusable for subsequent use."

PM2.5 testing, even on a single stack, would require extraordinary measures. No alternate test methods are provided for this analyte. Additionally, as the unit is natural draft, the low variable flow rates and high exhaust temperatures may preclude valid flow

measurements.

What are the estimated testing costs for your unit? Estimated costs (based on one preliminary quote) were $61,000 for testing one stack and $115,000 for testing two stacks assuming no issues with the testing. This does not include any costs associated with redesigning, constructing and installing modified stacks and sampling platform(s).

In the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs?

The above cost estimate is based on 3 days of testing. Each test run would be for one batch cycle.

Do you know the composition of the materials that are "burned off" in the oven? If yes,
do the materials contain metals or chlorine?

The burn off oven burns off nylon 6, 6. The nylon is not known to contain any of the constituents being sampled for with the following exceptions. Phosphorous may be added to the nylon at a target concentration of 56 ppm depending on the product. Manganese is added to one product at between 8 – 14 ppm. This product represents less than 3% of a typical year’s production. Chromium may be present at less than 1 ppm in the polymer. Sulfur, chlorine and fluorine are not present in any of the nylon 6, 6 placed
into the burn off ovens.

What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the maximum operating temperature of each chamber?

The main chamber pyrolyzes the nylon 6, 6 at approximately 900 F and the off gases are passed through afterburners operating at greater than or equal to 1550 F.

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means?

### In general the materials are combusted. A small amount of ash may be present at end of

cycle.

Please feel free to provide any other information that you believe may be pertinent to the feasibility of emission testing.

The major use of this burn off oven is during maintenance overhauls of continuous polymerization machines. Currently there are no overhauls planned within the testing window. Some minor use of the burn off oven does occur but is not representative of the primary use during overhauls.

Should testing be conducted during the initial heat-up cycle of the main chamber?

Should you have any additional questions, please contact me at (850) 968-98721 or Roy.W.Noble@AscendMaterials.com

.

Roy NoblePlease see below for answers to the requested information. Please let me know if you need additional

information.

What is the cycle time of the unit for which testing has been requested? The cycle time of the oven is 4 hours from start up till the time all material has been baked off.

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time). It may take an hour or less for it to cool down to where you can open the door. The materials are still hot for probably another hour.

What size is the stack? Approximately 30 inches

What types of stack/platform modifications (just those that you know about now) would be required to complete the testing ? We would need to add sampling ports and access ports via a boom lift.

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it a natural draft?
Natural Draft

Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)?
To be determined

What are the estimated testing costs for your unit?
To be determined

In the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs?
To be determined

Do you know the composition of the materials that are "burned off" in the oven? If yes, do the materials
contain metals or chlorine? We do know the composition based on the MSDS for the powder coating, none known. What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the maximum operating temperature of each chamber? 800 F for the main chamber, 1500 for the secondary chamber

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means? The powder coating completely bakes off and turns into a very fine ash.

Thanks, Andrew Frisbie, Ph.D., CHMM ISO14001 EMS Management Representative Senior Environmental, Health and Safety Engineer Wabash National Corporation Phone (765) 771-5443 Cell (765) 532-9985

### KYCooperStandard

What is the cycle time of the unit for which testing has been requested? 8 hrs

p rocess time.

P lease provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time ). Warm up is 90 minutes, processing time of 8 hrs. and a

c ool down time of 60 minutes.

Wh at size is the stack? Stack has an OD of 14” and an ID of 10” The top of the

s tack is 93” above the roof surface.

Wh at types of stack/platform modifications (just those that you know about now) would be required to complete the testing ? Test ports would need to be added.

I s the stack equipped with an induced draft fan? If not, is the draft forced by a fan
or is it a natural draft? Natural Draft

Wh ich test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)? Stack

t emperature and Flow, Will also have difficulty measuring the process throughput due to the large weight of the racks and the small quantity of removable material. (Approximately 200-400 pounds for each of the racks, and less than a pound of material on each rack) There is a potential for the testers to have to remobilize for an additional week(s) to run all of the tests.

Wh at are the estimated testing costs for your unit? $50,000 minimum, this is a

m onth’s worth of profit for the facility.
I n the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs? N/A.

D o you know the composition of the materials that are "burned off" in the oven? If yes, do the materials contain metals or chlorine? Contents are not directly known
b ut are unlikely to contain metals or Cl 2



### Wh at is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber? Furnace is

800 ° F the Afterburner is 1400 ° -1600 ° F

A re the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through
another means? Organic material is vaporized and then combusted in the
af terburner. Any Inorganic material falls to the floor of the unit and is swept up for disposal.

### Please feel free to provide any other information that you believe may be pertinent

to the feasibility of emission testing. The process is very low volume running

ap proximately 16 to 24 hrs per week dependant on customer volume. There may not be enough work to run all the tests needed. This would result in multiple mobilizations by the testers.

P lease feel free to provide any other information that you believe may be pertinent to the feasibility of emission testing. 

### The cost of this testing is very prohibitive. This facility
i s an automotive OEM supplier. The entire industry is in financial peril. Testing of this process would be an enormous fiscal burden to the operation.

Wh en EPA concludes consideration of this issue, we will consider extension requests for units that are required to perform testing.

### What is the cycle time of the unit for which testing has been requested?

The fluidized bed’s (FB-01) cycle time is dependant upon the part being loaded and the level of assembly/disassembly. Traditional processing times for equipment loaded into FB-01 includes a two hour heating cycle. The temperature of the bed drops between 25 and 50 degrees Celsius immediately after the cage of parts is loaded into the unit. During the first 20 minutes after loading the parts cage, a natural gas burner is fired to raise the bed to optimum temperature (approximately 450oC) and stabilize bed conditions (air flow, temperature,). During the handling and cleaning of the metal parts, the sand bed is maintained at an elevated temperature for approximately 1 hour and 40 minutes. The fluidized bed enclosure is then opened and the parts removed. The fluidized bed is maintained at temperature awaiting the loading of the next set of parts. Some larger extruder dies may require up to 4 hours of immersion in the sand bed

Once heated, the parts/cage is placed in a separate water quench bath for approximately 15 minutes to drop the temperature of the equipment and remove any residual sand. The cooled parts are then dipped in an oil quench tank to coat the parts with a light oil to protect the equipment and assist in the re-assembly process. A total of Four dies or batches may be processed each day (24 hour period).

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time).

Once the fluidized bed has reached to operating tempe rature, the cycling time is dependant upon the level of metal parts assembly/disassembly and the size of the die itself. Most die equipment at the Simpsonville plant take approximately 2 hours To clean, while a couple of large units may take up to 4 hours. In rare instances, the die is loaded into the fluidized bed intact (not disassembled). Since the sand does not directly contact all the parts, the die must remain in the heated bath for approximately 6 to 8 hours. This event is limited to the cleaning of R&D dies which may include confidential or patented applications.

What size is the stack?

F rom the roofline, a twenty-four (24) inch stack extends 28 feet above the die maintenance shop roofline. The air flow from two fans combine approximately 2 feet
below the roofline.

What types of stack/platform modifications (just those that you know about now) would be required to complete the testing ?

The roof for the fluidized bed building is a modestly sloped sheet metal roof with steel beam reinforcement. To facilitate stack testing, the facility has installed two sampling ports 90 degrees apart and more than 2 diameters of straight section downstream from the last interruption. Stack hangers are present to hold/secure testing equipment approximately 12 feet above the roofline. For a source tester to have adequate space and proper access to the sampling ports, at least four levels of scaffolding would be required.

### Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan

or is it a natural draft?

Y es. The system is designed with two cyclones in parallel to capture heated sand particles and protect the induced draft fans from abrasion. As the air exists the cyclones, the exhaust temperature is reduced to approximately 225oF prior to exhaust.

Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)?

The requested testing would require 4 hour test runs, while the batch process only operates two hours at a time. To perform the required testing the bed would have to be opened during the sampling run to change out parts. This would cause periods of no emissions during each test run as well as periods of process stabilization. Due to the short notice for testing, Sealed Air would be unable to hold or accumulate parts for longer test runs. Only two large dies are scheduled for processing in the next two months. Several small batches or short cycle times may be performed each day. Current equipment loads may not allow for continuous testing of the unit.

What are the estimated testing costs for your unit?

A nalytical Testing Consultants, Inc. has proposed testing on similar sized units as part of the EPA 114 requests. Of their proposed efforts, sampling costs have ranged between $35,000 and $50,000 dollars. Another company has estimated testing to cost around $28,000.

In the Webinar, EPA indicated that for batch processes wit h short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs?

Such an amendment should reduce costs slightly due to the overall time on-site being reduced, but the majority of the costs are fixed (equipment/prep).

Do you know the composition of the materials that are "burned off" in the oven? If yes, do the materials contain metals or chlorine?

Yes. The company primarily manufactures food packaging, thus nearly all materials used are approved for food contact. Furthermore, the company only allows for the cleaning of Sealed Air/Cryovac parts in the unit. The material “burned off” or gasified includes residual resin that could not be removed from the parts by hand during the Die disassembly. These resins represent the raw materials or additives that are processed in the extruder to make a finished product or film. The fluidized bed itself is designed to accept a maximum of 30 pounds of resin per batch. The equipment could be damaged if more resin was introduced.

### Sealed Air does not allow any dies or die parts that contact a chlorine containing

resin from being cleaned in the fluidized bed. Any such equipment is segregated and cleaned by hand or an alternate means. Other than trace contaminants not reported by the manufacturer, the only metals within the processed resins include titanium and zinc.

What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber?

T he fluidized bed system is a single-chamber unit that is heated to 4500 C to heat and clean the metal die parts.

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through
another means?

The small quantities of residual resins that are not removed during the equipment disassembly process will gasify at the elevated temperatures. A flame which extends over the surface of the bed causes the gaseous VOCs to be combusted.

Please feel free to provide any other information that you bel ieve may be pertinent to the feasibility of emission testing.

S ince the fluidized bed operations schedule is dependant on equipment maintenance schedules, it is very difficult to plan source testing events for large parts (or longer cycling times). Some large equipment is scheduled for processing once every ten years, while smaller parts are cleaned much more frequently.

The batch cycling times and the EPA method run times may cause difficulties in achieving the prescribed test run durations. Furthermore, the limitation on the parts to process and the number of batches per day may cause testing firms to remain onsite for extended periods. Testing would necessarily include process startup/stabilization period. Normalized resin loading or approaching maximum capacity would be difficult based upon a tight maintenance schedule.

If you have any questions or comments, please feel free to contact me as indicated below, or Meredith Mangum at (864) 967-1376.

Bobby Cullom Global Environmental Engineer Sealed Air Corporation 100 Rogers Bridge Road, Building A Duncan, South Carolina 29334 Direct: (864) 433-2334 Fax: (864) 433-2723

### TXMadix

From: Shrager.Brian@epamail.epa.gov [ mailto:Shrager.Brian@epamail.epa.gov] Sent: Thursday, June 25, 2009 1:09 PM

To: shrager.brian@epa.gov Subject: Burn off oven follow-up questions

Please respond to this e-mail if you are the owner/operator of a burn off oven and received the EPA section 114 ICR letter requiring emissions testing by October 15, 2009. In order to address concerns with testing these units, we require additional information on the units. Your prompt response will facilitate EPA's consideration of these units.

Burn off oven questions (please answer separately for each oven for which you received a test request)

What is the cycle time of the unit for which testing has been requested? 30 minutes to 1 hour depending upon placement of material to be burned. If hanging wires are on a rack, it will be 30 minutes. If placed in a tub it is extended to 1 hour.

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time). 1.5-2 hour warm up time then cycle starts and runs for 30 minutes
or 1 hour.

What size is the stack?
20”

What types of stack/platform modifications (just those that you know about now) would be required to complete the testing ? unknown, possibly a staged product burning not realistic to plant operations

Is the stack equipped with an induced draft fan? If not, is the draft forced by a fan or is it
a natural draft?
Natural draft

Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)? Inaccurate or unable to get D/F readings, stack flow, a “less than” number on metals

What are the estimated testing costs for your unit? One verbal quote of $20,000 and one written quote of $33,000

In the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs? Unknown. I would think it would reduce costs substantially Do you know the composition of the materials that are "burned off" in

### the oven? If yes, do the materials contain metals or chlorine?

Yes. Powder coated hanging wires. Per 6/09 TCLP analytical results, ash from burn-off oven contains metals but not at hazardous levels. MSDS’s of all coatings that might be removed via the burn off oven can be provided.

What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the maximum operating temperature of each chamber? It’s a one chamber over set to operate at 915 degrees. Afterburner is set at 1400 degrees F and stack high temp setting is 1600 degrees F.

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means? Heat breaks the bond of the coating material from the hanging wires and oven ash is disposed of as class 2 material through a landfill.

Please feel free to provide any other information that you believe may be pertinent to the feasibility of emission testing.

When EPA concludes consideration of this issue, we will consider extension requests for units that are required to perform testing.

Thanks!

Brian Shrager Environmental Engineer U.S. EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/Energy Strategies Group
D243-01 Research Triangle Park, NC 27711 (919) 541-7689 Fax: (919) 541-5450Quadrant EPP USA, Inc. Page 1 of 4 

### 2530 N. Fourth Street • Wytheville, VA 24382 Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com July 1, 2009

BY EMAIL ONLY

Mr. Brian Shrager Environmental Engineer U.S. EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/Energy Strategies Group D243-01 Research Triangle Park, North Carolina 27711

RE: Initial response to Section 114 Email questionnaire regarding Pyrolysis Ovens CISWI Standards

Dear Brian,

Attached is Quadrant Engineering Plastic Products, Wytheville, Virginia facility’s response to the Follow up survey in you email June 26, 2009. If we need to provide further clarification please let me know.

We would appreciate the opportunity to discuss our process with you so that USEPA has a clearer understanding of the operation and the severity of the impact of such an increase in the CISWI standards
would cause to our business.

Please contact me should you have any questions.

David K. Bowles Quadrant EPP
2530 N 4 th St Wytheville, Va. 24382

cc. Alan Freeman Rick FreyQuadrant EPP USA, Inc. Page 2 of 4 

### 2530 N. Fourth Street • Wytheville, VA 24382 Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com 

### Response to Section 114 Questionnaire regarding CISWI potentially regulated facilities June 25, 2009

Burn off oven questions (please answer separately for each oven for which you received a test request):

Initial Comments:



### The unit in question is our Controlled Pyrolysis Cleaning furnace Model SCTR-9. This small furnace is used to remove small amounts of Nylon and Polyacetal resins that accumulate on screws and Extrusion dies. The unit has been in operation for more than 10 years and represents an integral part of the cleaning process of various equipment. Without this equipment, significant cost increases and increases in solid waste generation will be expected.

What is the cycle time of the unit for which testing has been requested?

The total Cycle time typically is 16 Hours

.

Please provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, cool-down time).

Furnace chamber Afterburner

4 Hour Heat- up from Ambient to 1000 o F 4 Hours from Ambient to 1600 F
4 Hour Cleaning Cycle @ 1000 o F 4 Hours @ 1600 F
8 Hour Cool down to Ambient 8 Hours 1600 o F to Ambient

What size is the stack?

The stack is 10 Inch Diameter with a total of 17 Ft Straight ducting thru the roof to a
Chinese Hat covered vent.

What types of stack/platform modifications (just those that you know about now) would be required to complete the testing?

The stack would require the installation of 2 test ports at 90 degrees to each other, either below the roof-line, or above the roof. It would be considerable expense to establish the required stack height in order to meet EPA Method 1. In addition, the diameter of the stack may preclude any compliance with stack testing protocols due
to its ten inch diameter.Quadrant EPP USA, Inc. Page 3 of 4 

### 2530 N. Fourth Street • Wytheville, VA 24382 Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com 

### Is the stack equipped with an induced draft fan? No

. If not, is the draft forced by a fan or
is it a natural draft?

The stack has only induced draft

. The maximum exit gas volume is estimated at 450 to 650 ACFM at 1600 degrees F.

Which test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)?

PM10, PM2.5 and any of the isokinetic sampling protocols are expected to be problematic for measuring emissions from this system. Further with the large number of potential facility locations which stack testing may be required we have been advised that testing may not be able to be achieved by the October 2009 deadline. Particulate emissions have not been seen nor expected due to the lack of forced velocity. Monitoring for either PM10 or PM2.5 would be not be expected to yield significant results. Sample time required for these tests are a minimum of 4 hours, which would impact the entire cycle of cleaning which this unit is currently programmed. The Method 23 protocol would have to be modified, and possible extrapolated for a 4 hour burn time. Excess O2 may also be a problem since this is a pyrolysis oven which is naturally operated in a low O2 environment.

What are the estimated testing costs for your unit? With the modifications to the stack height (if diameter is acceptable), we expect testing to cost over $65,000 which may
exceed the value of the oven.

In the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs? Unknown.

Do you know the composition of the materials that are "burned off" in the oven? Yes

. If yes, do the materials contain metals or chlorine? NO. In this case, materials cleaned in this oven are not” burned off” as EPA believes. In the process of traditional burning-out of materials, the binding agents (e.g. varnish, resin, paint and plastic) will combust (due to the high oxygen content), so that the heating of the materials will not be equal. This unequal heating (hot spots) may cause damage to materials(internal cracks), leading to loss of quality. This tended to be a problem with 'burnoff' ovens. A Pyrolysis Oven can be said to be the improved version of a standard “burnout” oven. The degree of control is much better as the parts are heated up in a more controlled way. Pyrolysis Ovens are capable of decomposing larger amounts of binding agents in comparison with the traditional burnout ovens, since no combustion can take place in a low-oxygen environment, allowing the temperature control to remain optimal. A review of all raw materials and final products do notQuadrant EPP USA, Inc. Page 4 of 4 

### 2530 N. Fourth Street • Wytheville, VA 24382 Telephone 276.228.0100 • Fax 276.228.0119 • www.quadrantepp.com 

### indicate that metals or chlorine containing precursors are present in the products destroyed in this oven. Further, the amount of material coated on the tools being cleaned is an average 5.3 pounds per batch, and represents an estimate less than 1.5% on a BTU basis of the amount of BTUs utilized in the process.

What is the maximum operating temperature of the unit, or, in the case of multi-chamber units, the maximum operating temperature of each chamber?

The furnace Chamber maximum temperature is 1100 F. with a range 900 to 1100o f The afterburner Maximum temperature is 1600 o F with a range from 1400 o F to
1600o F.

Are the materials that are removed from the parts/hooks/racks in the oven combusted? If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means?

The Primary chamber is a low oxygen environment pyrolyzes the plastics and the Afterburner Oxidizes the off gasses

.

### Dear Mr. Shrager:

RE: CISWI Whirlpool Corp

The Whirlpool Clyde & Evansville facilities received EPA’s request on providing stack sampling information for the NSPS Commercial, Industrial Solid Waste Incinerators (CISWI). Whirlpool is always willing to assist EPA in their requests for data. However, per our earlier discussion on Whirlpool’s stack sampling, please consider the elimination of one of Whirlpool’s sites for testing.

As explained during our call, both of Whirlpool’s “burn-off oven” processes are identical (See equipment manufacture’s letter attached) and testing for both systems would not be productive. Whirlpool is requesting that the Evansville IN site be removed from the list. We feel the Clyde OH facility would represent a more suitable data point in that its hook loading rates are higher that Evansville’s.

Further, the Evansville facility is adjacent to an airport, and stack heights are restricted. If a stack height increase is needed to reduce temperatures for PM2.5 sampling, it may not be allowed by FAA rules.

If you need anymore information or have any questions, please give me a
call at 269/923-3614.

A "hard copy" of this request will also be submitted.

Thank You.,

Robert J. Karwowski Director, NAR Environmental, Health & Safety
Phone - 269-923-3614
Fax - 269-923-5768Please respond to this e-mail if you are the owner/operator of a burn off oven and

received the EPA section 114 ICR letter requiring emissions testing by October 15, 2009. In order to address concerns with testing these units, we require additional information on the units. Your prompt response will facilitate EPA's consideration

of these units.

Burn off oven questions (please answer separately for each oven for which you received a test request)

Location: Whirlpool Corporation 119 Birdseye St. Clyde, OH 43410

Contact: Gary Jaeger, Environmental Engineer

Corporate Contact: Bob Karwowski

W hat is the cycle time of the unit for which testing has been requested?

Typically, we have a twelve hour burn cycle followed by a cool-down period, unloading, oven cleaning, and a reloading process. Normally only one cycle is completed in a 24 hour period during each work day. Most often, the unloading, cleaning and reloading is done the following day.

P lease provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, and cool-down time).

The total burn cycle is typically a twelve hour proc ess for powdered paint tooling. Tooling from the wet paint processes normal have a much lower coating build-up and the full burn cycle can be less (Possibly as low as eight hours). Start-up time and temperature ramp-up takes approximately 1 hour. Maximum heat (strong burn) cycle time is between two to four hours dependent on the loading. The remaining polishing cycle time is utilized to complete the pyrolysis process.

W hat size is the stack?

The stack is circular in shape with a measured inner diameter of 14 inches, outer diameter of 18 inches, with a two inch ceramic fiber lining.

W hat types of stack/platform modifications (just those that you know about now) would be required to complete the testing?

If the sampling train can be set-up similar to a pre vious test sequence we ran back in Dec 2002 for PM, we would merely set up the sample train at approximately 4.5 foot above the roof level. Stack modifications with two four inch sampling ports will cost approximately $ 500.00.Is the stack equipped with an induced draft fan?

N o

I f not, is the draft forced by a fan or is it a natural draft?

A natural draft is created by the lower chamber burn er and the after-burner. Each burner has an integral forced air feed blower for combustion air. The Manufacturer refers to this as a natural draft system. The pyrolytic ovens are designed to operate under starved air (pyrolytic) conditions

W hich test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)?

We do not have a contractor on board at this time. The contractor we used back in 2002 indicated the in-stream PM 2.5 cyclone would not survive the stack temperature. Typical stack temperatures are between 1400 F and 1800 F. Temperatures can peak above 2000°F under a full load, but this is not a normal operational practice. Various testing contractors have also mentioned concerns with probes used for the metals test. Glass sample probes may melt. Air cooled or water cool probes may suffice. Water moisture levels do run higher in these ovens by design and can have an effect on test methodology.

W hat are the estimated testing costs for your unit?

The cost is unknown at this time. We are in the pro cess of learning what the scope of work entails and preparing the RFQ for the contractors. EPA estimates for sampling and analysis was $52,000.

I n the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs?

Unknown - Due to short process runs, it may take sev eral days to perform all the required testing. This would have a tendency to increase costs.

D o you know the composition of the materials that are "burned off" in the oven?

Yes

I f yes, do the materials contain metals or chlorine?

No heavy metals or chorine have been identified by t he paint & powder vendors. Whirlpool is willing to run GCMS and ICPS analysis on the paint and powder fragment to verify the case. Chlorine and fluorine can be found present in low levels in the city water which is used in the process. Two powder coating products contain <0.25% concentration of fluorinated chemicals (PTFE).What is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber?

The oven chamber normally is held at 800°F once it r eaches its standard operating temperature. It can peak to 880°F. The afterburner is normally set to operate from 1400°F to 1800°F, but can peak above 2000°F.

Are the materials that are removed from the parts/ho oks/racks in the oven combusted?

Yes, but this may not be considered a true combustio n process. Heat is used in a moisture starved air atmosphere where the material is decomposed into an ash. The coating on the ware will smolder and the smoke that evolves will enter the
afterburner chamber for final destruction.

Please note that this type of process may not be actually considered as “incinerators”, but are rather controlled air, pyrolytic ovens. They are a unique breed. The primary oven has minimal turbulence and maximum temperature control. Any organics that volatilize continue into the afterburner and are consumed at temperatures above 1,400°F.

I f not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means?

Please feel free to provide any other information that you believe may be pertinent to the feasibility of emission testing.

When EPA concludes consideration of this issue, we will consider extension requests for units that are required to perform testing.

Thanks!

Brian Shrager Environmental Engineer U.S. EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/Energy Strategies Group

D243-01 Research Triangle Park, NC 27711
(919) 541-7689
Fax: (919) 541-5450Please respond to this e-mail if you are the owner/operator of a burn off oven and

received the EPA section 114 ICR letter requiring emissions testing by October 15, 2009. In order to address concerns with testing these units, we require additional information on the units. Your prompt response will facilitate EPA's consideration

of these units.

Burn off oven questions (please answer separately for each oven for which you received a test request)

Location: Whirlpool Corporation 5401 U.S. Highway 41 North Evansville, IN 47727

Contact: Greg Kissel, Environmental Engineer

Corporate Contact: Bob Karwowski

What is the cycle time of the unit for which testing has been requested?

A five hour burn cycle is typical (longest cycle time would be 6 hours). Upon the completion of the cycle, the oven cools overnight, followed by unload, cleaning, and reload process. Since this is a one shift operation, only one batch is completed in a work day.

P lease provide a breakdown of the cycle time (e.g., start-up time (hours), maximum heat time, and cool-down time).

The total burn cycle is typically a five hour process. Start-up time and temperature ramp-up takes approximately 1 hour. Maximum heat (strong burn) cycle time is between one to two hours. The remaining cycle time is utilized to complete the pyrolysis process.

W hat size is the stack?

The stack is circular in shape with a measured inner diamete r of 14 inches and an outer diameter of 18 inch. The annulus
contains two inches ceramic fiber insulation.

W hat types of stack/platform modifications (just those that you know about now) would be required to complete the testing?

A platform approximately ten feet tall would be required for stack testing. A stack extension with four inch ports would be necessary for stack testing (cost approximately $450). A cyclone for PM testing would also be required.

I s the stack equipped with an induced draft fan?

N oIf not, is the draft forced by a fan or is it a natural draft?

A natural draft is created by the lower chamber burner and the after-burner. Each burner has an integral forced air feed blower for combustion air. The Manufacturer refers to this as a natural draft system. The pyrolytic ovens are designed to operate under starved air (pyrolytic) conditions

W hich test methods, if any, have emission test contractors expressed concerns about (regarding feasibility of testing, ability to sample isokinetically, other)?

We do not have a contractor on board at this time. There is a concern regarding the in-stream PM 2.5 cyclone would not survive the stack temperature. The stack operates at 1500 F at full load. There are also concerns with probes used for the metals test. Air jacketed or water jacketed probes may have to be considered.

W hat are the estimated testing costs for your unit?

This is unknown at this time. Clyde, Ohio facility is in the process of learning what the scope of work entails and preparing the RFQ for a contractor. EPA estimates for sampling and analysis indicated approximately $51,000. (Original purchase price of the Evansville oven was approximately $20,000)

I n the Webinar, EPA indicated that for batch processes with short cycle times, the individual test runs do not need to span more than one batch cycle. How would that change the estimated testing costs?

Due to short process runs, it may take several days to perform all the required testing. This would have the tendency to
increase overall costs.

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D o you know the composition of the materials that are "burned off" in the oven?

Yes

I f yes, do the materials contain metals or chlorine?

No heavy metals or chorine have been identified by the pain t vendor. Whirlpool is willing to run GCMS and ICP analysis on the paint to verify the case. It is noted that potable water is utilized in the process to help control the temperature in the primary chamber (sprayed onto the ware). The potable water may have small levels of chlorine and fluorine that is added at the drinking (potable) water plant. It is not well understood if this would have any impact on the
stack constituents.

W hat is the maximum operating temperature of the unit, or, in the case of multichamber units, the maximum operating temperature of each chamber?

The oven primary chamber normally is held at 800 F once it reaches its standard operating temperature. The afterburner is normally set to operate from 1500 F. Due to the limited loading of paint on the hooks, temperatures are fairly stable.Are the materials that are removed from the parts/hooks/racks in the oven combusted?

Yes. All organics are pyrolyzed at the end of the cycle. Only the inorganic materials remain, which would be titanium dioxide powder residue on the racks and carriage. These are washed off in an enclosed spray booth with a pressurized
water wand.

Please note that this type of process may not be act ually considered as “incinerators”, but are rather controlled air, pyrolytic ovens. They are a unique breed. The primary oven has minimal turbulence and maximum temperature control. Any organics that volatilize continue into the afterburner and are consumed at high temperatures (1,500 F). These are generally converted to water vapor and carbon dioxide prior to exiting the stack.

Also, as mentioned earlier, it would be in our best interest to determine if metals and halogens are in the materials being consumed by testing of the materials versus the high cost and effort involved in stack testing. Other federal regulations allow knowledge or testing of the materials to preclude regulation. Please consider this option.

If not, is heat used to melt or break material bonds so that the materials fall off of the parts/hooks/racks and are collected and disposed of through another means?

Please feel free to provide any other information that you believe may be pertinent to the feasibility of emission testing.

When EPA concludes consideration of this issue, we will consider extension requests for units that are required to perform testing.

Thanks!

Brian Shrager Environmental Engineer U.S. EPA Office of Air Quality Planning and Standards Sector Policies and Programs Division/Energy Strategies Group

D243-01 Research Triangle Park, NC 27711
(919) 541-7689
Fax: (919) 541-5450