TCEQ REGULATORY GUIDANCE Small Business and Environmental Assistance Division RG-404 February 2011 Surface Coating Facilities A Guide for Obtaining

Unit VII Mini Project

As a continuation of our course project due in Unit VIII, A Permit By Rule (PBR) Application for an Interior Surface Coating Facility, complete the next section, “Heater and Oven Combustion Emissions,” of your proposal by following the instructions carefully, and then submit your continued draft for grading.

Instructions

1. Closely read the Required Reading assignment from your textbook, the TCEQ (2011) document, and the Unit Lesson in the Study Guide.

2. Open your proposal draft from Unit VI and make any improvements to your draft using your professor’s feedback from the Unit VI project assignment.

3. Open the Unit VII Study Guide, read the Unit VII Unit Lesson, then review the calculations demonstrated and explained regarding calculations for emissions of products of combustion from heaters and ovens for our scenario.

4. Make your Unit VII work your sixth level 1 heading titled “Heater and Oven Combustion Emissions.” Describe and demonstrate (illustrate) the calculations for the following for this section of your project: (a) nitrous oxides (NOx), (b) carbon monoxide (CO), (c) particulate matter (PM), (d) volatile organic compounds (VOC), and (e) sulfur dioxide (SO2) for BOTH hourly emissions (short-term) in lbs./hr. AND annual (long-term) emissions in tons/year.

Within the TCEQ’s (2011, Appendix I) guidance document, we select Examples: Calculations for Emissions of Products of Combustion from Heaters and Ovens: Hourly (Short-term) Emissions in Pounds per Hour and Annual (Long-term) Emissions in Tons per Year for our scenario work. Additionally, given that our Interior Lining Cure equipment (natural gas-fired heater) matches the TCEQ specifications, we are going to use the TCEQ’s natural gas unit emission factors tabulated for Firing Rate Between 0.3 MMBtu/hr (lb106 scf) and 100 MMBtu/hr (lab/106 scf) provided to us for our calculations. We will use the following referenced steps to calculate our air contaminant analytes generated from our natural gas-fired cure heater for our air permit application. We will be using the units in our calculations for million British thermal units/hr (MMBtu/hr), thousand British thermal units/hr (MBtu/hr), and standard cubic feet/hr (SCF/hr). For example, 1.0 lbs/MMscf would be 1.0 lbs of contaminant (pollutant) per one million standard cubic feet.

For our first set of calculations, we will be calculating the short-term (hourly) emissions generated from the heater. The following formula would apply:

lbs air contaminant/hr = lbs air contaminant x 1.0 scf x 2.1 MMBtu

MMscf 1,020Btu 1.0 hr

First, we reference our scenario for the technical information referenced for the Interior Liner Cure heater and see that our natural-gas fired cure heater has a firing rate of 2.1 MMBtu/hr, and that we anticipate firing liners in the curing process for a maximum of 2,500 hours/year. Further, we note that NOx content is tabulated as100 lbs/MMscf (lbs/million scf). Next, we multiply 100 lbs NOx/MMscf by 1 scf/1,020 Btu by 2.1 MMBtu/hr to derive 0.206 lbs NOx/hr.

Second, we note that CO content is tabulated as 84 lbs/MMscf. Next, we multiply 84 lbs CO/MMscf by 1 scf/1,020 Btu by 2.1 MMBtu/hr to derive 0.173 lbs CO/hr.

Third, we note that PM content is tabulated as 7.6 PM/MMscf. Next, we multiply 7.6 PM/MMscf by 1 scf/1,020 Btu by 2.1 MMBtu/hr to derive 0.016 lbs PM/hr.

Fourth, we note that VOC content is tabulated as 5.5 lbs/MMscf. Next, we multiply 5.5 lbs VOC/MMscf by 1 scf/1,020 Btu by 2.1 MMBtu/hr to derive 0.011 lbs VOC/hr.

Fifth, we note that SO2 content is tabulated as 0.6 lbs/MMscf. Next, we multiply 0.6 lbs SO2/MMscf by 1 scf/1,020 Btu by 2.1 MMBtu/hr to derive 0.001 lbs. SO2/hr.

For our second set of calculations, we will be calculating the long-term (annual) emissions generated from the heater. In order to accomplish this, we simply convert the hourly emissions (performed above) to annual emissions (2,500 hours/yr), and then to tons (2,000 lbs/ton) to derive an annual tons of air contaminant per year. The following formula would apply:

Tons air contaminant/hr = lbs air contaminant x 2,500 hr x 1.0 ton

1.0 hr 1.0 yr 2,000 lbs

For example, our first unit conversion would be for NOx. First, we note that our calculated hourly NOx is 0.206 lbs/hr. Second, we multiply 0.206 lbs NOx/hr by 2,500 hrs/yr by 1 ton/2,000 lbs to derive 0.258 tons NOx/yr (notice that the TCEQ Guidance document answer is not rounded correctly for this calculation). Perform the same conversion for the other four (CO, PM, VOC, and SO2) air contaminants.