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The particulates have been identified as a potential pollutant <br />from the oil in the feed stocks and in the EPA document. Afterburners <br />will be used to convert the unburned UOCs and combustible particulates <br />to carbon dioxide and water. We therefore recommend that a particulate <br />test and opacity test be conducted once every five years. <br /> <br />COMPLIANCE WITH AIR QUALITY RULES <br /> <br /> The MPCA letter exempted the Permit Holder from obtaining an air <br />emission permit from the Minnesota Pollution Control Agency (MPCA). <br />This letter also stated that the Permit Holder must comply with the <br />following air quality rules: <br /> <br />1. Particulate Matter Air Standards (MN Rules 7005.0450- <br /> 7005.0520). <br /> <br />2. Fugitive Emissions (MN Rule 7005.0550). <br /> <br />3. Odorous Emissions (MN Rule 7005.0900-7005.0930). <br /> <br />4. visible Emissions (MN Rule 7005). <br /> <br />Particulate Matter (MN Rules 7005.0450-7005.0520) <br /> <br /> These rules set the maximum amount of particulates that can be <br />emitted based on the process weight rate of the facility and <br />determines the opacity levels that must be attained. <br /> <br /> The particulate emission rate is established by PR{ Rule 7005.05~0 <br />Table 1 which is based on the following equation for process weights <br />up to 60,000 lbs per hour: <br /> <br />E= 3.59 P exp 0.62 where <br /> <br />E= particulate emissions allowed per hour <br /> <br />P= process weight rate in tons per hour (total <br /> weight of all materials introduced into any <br /> industrial process equipment). <br /> <br />The particulate emissions for the Permit Holder under this rule is <br />calculated as follows: <br /> <br /> Process weight is 1000 lbs aluminum per hour plus steel. The <br />average aluminum composition is 50% and therefore the process weight <br />(P) is 2000 lbs or 1 ton per hour. Therefore, <br /> <br />E = 3.59 (1) exp 0.62 = 3.59 lbs per hour. <br /> <br /> The allowable particulate emission is 3.59 lbs per hour. The <br />potential particulate emissions from the EPA publication is 0.95 lbs <br />per hour. Therefore, the KN Rules allow approximate 4 times more than <br />the calculated potential emissions. <br /> <br /> <br />