Momentive Performance Materials

Posted on August 5, 2015

Client: Momentive Performance Materials
Location: Tarrytown, New York
Project Type: Westchester County and New York State Air Permitting and Registration

Project Description

Introductionlaboratory at the Tarrytown facility

Momentive Performance Materials (Momentive) leases space in a commercial building in Tarrytown, Westchester County, New York. Momentive manufactures silicone based chemicals, epoxies, resins and sealants that are used by other industries in producing consumer goods. The main operations conducted at Momentive’s Tarrytown facility include research and development (R&D) on the products manufactured by Momentive. As a result, Momentive operates numerous laboratories at the Tarrytown facility with exhaust hoods that are considered air contamination sources and potentially require air permitting from both the New York State Department of Environmental Conservation (NYSDEC) and the Westchester County Department of Health (WCDH). Dvirka and Bartilucci Consulting Engineers (D&B) was retained by Momentive to prepare and support the required permit applications necessary to obtain the air permits and registrations required by these regulatory agencies.

Emissions Inventory

D&B conducted a detailed site inspection of the facility to confirm the number of emission points at the facility and the number of laboratory hoods associated with each emission point. Using data provided by Momentive, D&B prepared a facility-wide emission inventory of regulated air pollutants for the facility. The facility-wide HAP emissions inventory was prepared and included the laboratory room number, fan number, design fan flow rate, actual fan flow rate, stack height, stack velocity and estimated emission rate for each HAP.laboratory hood

R&D activities and exhaust systems for laboratory operations are exempt from NYSDEC permitting as outlined by 6 NYCRR Part 201-3.2(c)(44) and (40), respectively. As a result, under the NYSDEC regulations, these sources only require permitting if facility-wide emissions exceed the NYSDEC Title V thresholds. Based upon D&B’s emissions estimates, the facility did not exceed Title V thresholds and, as a result, D&B determined that no NYSDEC air permit or registration was required for the facility. However, WCDH requires air permits for laboratory hoods emitting Hazardous Air Pollutants (HAPs), regardless of the total quantity of emissions. Based upon D&B’s emissions inventory, several laboratories at the Tarrytown facility were
determined to emit HAPS.

Emissions ScreeningView of roof top on building facility

In order to meet the WCDH air permitting requirements, D&B utilized the NYSDEC DAR-1 emission screening program to  determine whether the HAP emissions from the facility would cause any violations of the NYSDEC Short-term Guideline Concentrations (SGCs) or Annual Guideline Concentrations (AGCs) for the individual contaminants emitted from the facility. The type of emissions generated by the facility required D&B to setup of unique procedure for conducting the emissions screening effort. The DAR-1 screening program only allows inputs for hourly and actual annual emissions. Potential annual impacts are estimated by the screening program by multiplying the entered hourly emission rates by 8,760 hours per year. However,
for batch or intermittent operations such as laboratory hoods, where emissions occur during short time periods, this overestimates the actual potential impacts. As a result, D&B performed the DAR-1 screening analysis twice. The first run involved using the maximum calculated hourly emission rate and actual annual impacts. The second run involved using the average hourly emission rate to estimate potential annual impacts. This simulated the potential for the facility to emit HAPs if the existing, 5-day per week, 8-hour per day operating schedule was increased to 7 days per week, 24 hours per day at the same HAP usage rate, and more appropriately assessed potential annual impacts. As a result of this alternate screening procedure, which was accepted by WCDH, the calculated ambient impacts for all of the compounds were determined to be below the NYSDEC AGCs and SGCs on an actual and potential basis.

Permit to Construct

Based upon D&B’s evaluation, emissions inventory and screening effort, thirty six emission points required WCDH permitting due to the use of HAPs. D&B prepared the detailed application package required by the WCDH in order to obtain a Permit to Construct (PTC) for each emission point. The application included preparation of the required WCDH forms, an Engineer’s Report providing detailed descriptions of the emission sources and points operated at the facility, construction drawings for the emission sources and the above referenced screening analysis. D&B coordinated with WCDH to support their review of the application in order to facilitate issuance of the permits.

Permit to Operate

Subsequent to receiving the PTCs from the WCDH, D&B conducted a second inspection of the facility to ensure conformance with the PTC application package, and submitted a Permit to Operate (PTO) Application to the WCDH, including the required WCDH forms and as-built plans of the installation. D&B attended WCDH’s inspection of the facility to facilitate issuance of the final PTOs.

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