TOWN OF CICERO - THERMAL FOAMS INC

Notice of Complete Application

Applicant:

THERMAL FOAMS/SYRACUSE INC
6173 S BAY RD
PO BOX 1396
CICERO, NY 13039

Facility:

THERMAL FOAMS INC
6173 SOUTH BAY RD
CICERO, NY 13039

Application ID:

7-3122-00095/00010

Permit(s) Applied for:

Article 19 Air State Facility

Project is Located:

CICERO, ONONDAGA COUNTY

Project Description:

The Department of Environmental Conservation (DEC) has prepared draft permits and has made a tentative determination to issue an Air State Facility (ASF) operating permit for Thermal Foams, Inc. This facility is located at 6173 South Bay Road, Cicero, NY 13039. The facility is engaged in the manufacturing of eps plastic blocks. Primary activities at the facility include material manufacturing; this process involves the use of expandable polystyrene (EPS) resin. The facility's expanded polystyrene (EPS) foam manufacturing operations also include pre-expansion, pre-puff aging, molding, block aging, fabrication, and storage.

The pentane is emitted to the atmosphere through six different emission points identified as follows: EP #01 - Block Mold Roof Vent; EP #02 - Molder Exhaust Stack; EP #03 - Pre-Expander Roof Vent; EP #04 - Molding Room Wall Vent; EP #05 - Warehouse Wall Vent and EP #06 - Pre-Expander Exhaust Stack. There are also several non-regulated emissions sources in operation at the facility including a natural gas-fired boiler, six natural gas-fired unit heaters, one roof-mounted natural gas-fired HVAC system and block cutting operations. All of these sources are classified as being either exempt or trivial according to 6 NYCRR Part 201-3.2 & 3.3.

This application is for an updated Air State Facility (ASF) Permit for Thermal Foams/Syracuse, Inc. This facility is a manufacturer of expanded polystyrene foam products and has been operating under old Certificates to Operate since 1995. The existing certificates authorize operation of five emission points which are used for venting/removal of pentane vapors generated during the expansion, aging and molding of expandable polystyrene resin. The ASF permit would provide for continued operation of these five points as well as one additional emission point associated with a new pre-expansion system.

The permit would also allow the facility to continue operating under the current VOC emission cap of 49.9 tons per year in order to avoid having to comply with Title V permitting requirements established under 6 NYCRR Part 201-6. The draft permit includes limits, set forth in the above referenced regulations, that the facility has currently confirmed compliance with and shall continue to operate as such. Actual emissions and facility operating parameters are required to be determined on a monthly basis and recorded to show that the facility cannot operate as a major source.

The facility is subject to 212-2.3(b) requirements for the C-rating, for the contaminant Pentane. Facility pentane emissions were modeled and found to be acceptable. As per from 212-2.3(b), Table 4, this requires a 75% control requirement of the pentane emissions due to the pentane emission rate potential (ERP) of greater than or equal to 10 lbs./hr. but less than 25 lbs./hr.

The facility submitted a T-BACT analysis, which was accepted by the DEC as appropriate. This analysis confirmed that no control is acceptable for this process, due to the high cost (in US dollars) per ton associated with the application of control technology (a regenerative thermal oxidizer (RTO)) to reduce about 30 tons/year actual VOC emissions at the facility at 95+ %). No other control options were considered technically feasible. This permitting variance will be submitted to the Environmental Protection Agency (EPA) for approval, as a State Implementation Plan (SIP) revision, for this facility. The facility will not limit this process but will still maintain compliance with their VOC limit (cap).

Persons wishing to inspect the ASF permit subject files; including the application with all relevant supporting materials, the draft permit, and all other materials available to DEC (the "permitting authority") that are relevant to this permitting decision should contact the DEC representative listed below. The Draft Permit and Permit Review Report may be viewed and printed from the DEC web site at: https://dec.ny.gov/environmental-protection/air-quality/controlling-pol….

DEC will evaluate the application and the comments received on it to determine whether to hold a public hearing. Comments and requests for a public hearing should be in writing and addressed to DEC representative listed below. A copy of DEC's permit hearing procedures is available upon request or on the DEC web site at: https://dec.ny.gov/regulatory/permits-licenses/environmental-permits/gu….

Availability of Application Documents:

Filed application documents, and Department draft permits where applicable, are available for inspection during normal business hours at the address of the contact person. To ensure timely service at the time of inspection, it is recommended that an appointment be made with the contact person.

State Environmental Quality Review (SEQR) Determination:

Project is not subject to SEQR because it is a Type II action.

SEQR Lead Agency: None Designated

State Historic Preservation Act (SHPA) Determination:

The proposed activity is not subject to review in accordance with SHPA. The application type is exempt and/or the project involves the continuation of an existing operational activity.

Coastal Management:

This project is not located in a Coastal Management area and is not subject to the Waterfront Revitalization and Coastal Resources Act.

DEC Commissioner Policy 29, Environmental Justice and Permitting (CP-29)

It has been determined that the proposed action is not subject to CP-29.

Opportunity for Public Comment:

Comments on this project must be submitted in writing to the Contact Person no later than Jul 26, 2024.

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