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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM November 23, 2004 TO: Dawson F. Lasseter, P.E., Chief Engineer, Air Quality Division THROUGH: John Howell, E.I., Existing Source Permits Section THROUGH: Herb Neumann, P.E., Tulsa Regional Office THROUGH: Peer Review FROM: David Schutz, P.E., New Source Permits Section SUBJECT: Evaluation of Permit Application No. 2004-226-C (PSD) Nomaco Incorporated Oklahoma City Polyethylene Foam Extrusion Plant Oklahoma City, Canadian County, Oklahoma Section 35 – T 12N – R 5W On Reno Avenue Between Sara Road and Morgan Road SECTION I. INTRODUCTION Nomaco Incorporated (Nomaco) has submitted a construction permit application for construction of a new polyethylene foam extrusion plant (SIC 3086). The proposed facility will be a new source under Prevention of Significant Deterioration (PSD) criteria. The project is subject to PSD because the added potential emissions of VOC are greater than the PSD major source threshold. Full PSD review is required for VOC. Full PSD review of emissions consists of the following: a determination of best available control technology (BACT); an evaluation of existing air quality and determination of monitoring requirements; an evaluation of PSD increment consumption; an analysis of compliance with National Ambient Air Quality Standards (NAAQS); an evaluation of source-related impacts on growth, soils, vegetation, visibility; and a Class I area impact evaluation. There will be a total of five extrusion lines installed. The first two will be installed initially upon construction, two more will be added in 2006, and the fifth line will be installed in 2007.
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PERMIT MEMORANDUM 2004-226-C (PSD) SECTION II. PROCESS DESCRIPTION The process will consist of expanding heated polyethylene resin using isobutane as a foaming agent. Pelleted resin will be received pneumatically into four raw materials silos. Pellets will be transferred to completely enclosed individual blending stations for mixing with other additives. The mix of pellets/additives will be heated electrically to form a homogeneous melt. Isobutane will then be injected into the melt, which is then moved by screw to a die to form the final product. The boiling point of isobutane is 11 o F, so it will change from liquid-phase to gas-phase in the process. Isobutane, as a liquid at 3,200 psi, will be injected into the melt, which is then moved by screw to a die to form the shape of the final product. The final products are then cooled using either air or water, printed with product specifications, then packaged and stored in a warehouse for shipment. The plant is designed to have up to five forming machines, each with a capacity of 200-300 kg/hr resin. Initially, two machines will be installed with a total capacity of 500 kg/hr resin, with the others added “as market conditions warrant.” The facility will include two resin grinders for reclamation of scrap resin, one for “hard purge” resin and one for foamed resin. Both will grind scrap resin for reflux to the process or use as packaging material.
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