Purpose of Application:

Currently, The Goodyear Tire & Rubber Company (Goodyear) holds Title V Permit No. 00011T32 with an expiration date of November 30, 2008 for a tire manufacturing facility in Fayetteville, Cumberland County, North Carolina. The Division of Air Quality (DAQ) received Air Quality Permit Application No. 2600050.06C on May 25, 2006. The application seeks to authorize the replacement of twenty-one (21) existing 42-inch tire presses with new 52-inch tire presses (ID Nos. CP-161 through CP-181). A 52-inch tire press can hold a tire mold with a circumference as large as 52 inches, whereas a 42-inch tire press is limited to molds with a maximum circumference of 42 inches.

Mr. Robert Kennedy of the DAQ’s Fayetteville Regional Office reviewed the draft Permit No. 00011T33. Mr. Kennedy identified several corrections to the draft permit and draft permit review document which were corrected prior to permit issuance.

Regulatory Review:

Twenty-one (21) 52-inch tire presses (ID Nos. CP-161 through CP-181).

• 1. Description – Each curing press consists of two curing cavities and two tire/mold-release lube spray (i.e., green tire spray) operations. In the proposed modification, Goodyear will be replacing twenty-one (21) existing 42-inch diameter presses with twenty-one (21) 52-inch diameter presses (ID Nos. CP-161 through CP-181). The “press diameter” refers to the diameter of the tire being manufactured. Goodyear holds that there will be no emissions increases as a result of the tire press replacements (i.e., larger diameter tires do not require more rubber, green tire spray, or other emission-producing processing).
• 2. 15A NCAC 2D .0524 – 40 CFR 60, Subpart BBB, NSPS for the Rubber Tire Manufacturing Industry – This regulation is applicable to affected facilities in rubber tire manufacturing plants, including green tire spraying operations, that commenced construction, modification, or reconstruction after January 20, 1983. The green tire spray operations in each of the new/replacement presses shall be subject to the NSPS. Pursuant to the standard [40 CFR 60.542(a)(5)(i)] the Permittee shall discharge no more than 1.2 grams (0.0026 lbs) of VOC per tire sprayed with an inside green tire spray for each month.

Because Goodyear only uses water-based sprays with less than 1.0 percent VOC by weight, and in accordance with 40 CFR 60.543(b)(4), the facility is not required to conduct monthly performance tests. However, Goodyear is required to provide formulation data (or Method 24 analysis results) on the sprays used to the DAQ within 30 days of any formulation change OR at least once every 12 months.

Based on Goodyear’s history of compliance with this standard, the DAQ anticipates continued compliance. In addition, the DAQ is relaxing the quarterly monitoring report requirement in the existing permit to a semiannual reporting requirement.

Multiple Emissions Units (All Affected Sources):

• 1. 15A NCAC 2D .0958 – Work Practices for Sources of Volatile Organic Compounds – Goodyear is currently subject to this regulation, which will also be applicable to new equipment authorized for construction as part of this modification. On its latest inspection, conducted on July 7, 2005 by Mr. Kennedy and Mr. James Moser of the Fayetteville Regional Office (FRO), the facility was found to be in compliance with 15A NCAC 2D .0958.
• 2. 15A NCAC 2D .1100 – Control of Toxic Air Pollutants (TAP) – The DAQ administers a state-specific, health-based air toxics program. Goodyear provided an air dispersion analysis to the DAQ in September 2002 to demonstrate that the ambient concentration at the property line for any triggered TAP is less than the Acceptable Ambient Level (AAL) as listed in 2D .1100. Emissions limits are provided in Goodyear’s permit as a result of the emission rates modeled in this 2002 demonstration. To ensure compliance with the TAP limits, Goodyear shall not exceed 768 million pounds of rubber production per consecutive 12-month period. The Permittee shall maintain records demonstrating that this production limit has not been exceeded.
  The modifications authorized in this permit are not expected to increase actual rubber production to 768 million pounds or greater. Nor do the proposed modifications add any new emissions points to the previous air toxics compliance demonstration. The DAQ expects continued compliance with this regulation.
• 3. 15A NCAC 2D .1806 – Control and Prohibition of Odorous Emissions – Goodyear is currently subject to this regulation, which will also be applicable to new equipment authorized for construction as part of this modification. On its latest inspection, conducted on July 7, 2005 by Mr. Kennedy and Mr. James Moser of the Fayetteville Regional Office (FRO), the facility was found to be in compliance with 15A NCAC 2D .0958.
• 4. 15A NCAC 2Q .0711 – Toxic Air Pollutant Emissions Limitation Requirement – This regulation requires that, prior to causing actual emissions in exceedance of the limitations provided in 15A NCAC 2Q .0711, the Permittee shall obtain a permit as provided in 15A NCAC 2D .1100 (i.e., air dispersion modeling). Goodyear has indicated that actual TAP emissions shall not exceed the TAP limitations as a result of these modifications. The DAQ expects continued compliance with this regulation.
• 5. 40 CFR 63, Subpart XXXX – Rubber Tire Manufacturing MACT – Goodyear is an existing major source of hazardous air pollutants (HAPs), and a “tire manufacturing affected source” under 40 CFR 63, Subpart XXXX. The permit allows Goodyear to comply with the HAP Constituent emission limitation option (40 CFR 63.5984; Table 1, Option 1) –OR– the Monthly Average (without an add-on control device) compliance alternative option (40 CFR 63.5985). Goodyear is not currently planning to install any add-on control devices to comply with the regulation.

Prevention of Significant Deterioration:

Goodyear is located in Cumberland County, which is an ozone Early Action Compact (EAC) area; therefore Non-Attainment Area New Source Review (NAA NSR) review is not required. However, under the EAC, modifications with potential emissions increases must be evaluated under the Prevention of Significant Deterioration (PSD) program as provided in 15A NCAC 2D .0530. Goodyear is an existing major source under the PSD program (15A NCAC 2D .0530). Modifications to existing major sources are subject to review under PSD if the resulting emissions increase exceeds the significant emission rate.

Goodyear holds that there will be no actual emissions increases as a result of the tire press replacements because the facility is not planning to use larger tire molds in the replacement presses. However, because the presses could potentially manufacture a larger tire, there is a potential emissions increase of VOC emissions. DAQ evaluated total VOC emissions increases from the tire press replacements, including total VOC emissions from the rubber curing and green tire spray system at each press and VOC emissions from increased rubber production upstream from the presses.

VOC Emissions From . . . .	tpy
Rubber Curing (1)	5.33
Inside Green Tire Spray (2)	0.44
Rubber Mixing - Coupling Agent (3)	21.92
TOTAL VOC Emissions	27.69

NOTES:

• 1. Assumes a maximum hourly rubber throughput at the 21 replacement presses for 8,760 hours per year. Uses a VOC emission factor based on units of pounds VOC per pounds of rubber cured (lbs VOC/lb-rubber).
• 2. Assumes a maximum daily tire production rate at the 21 replacement presses for 365 days per year. Uses a maximum estimated green tire spray application rate (per tire) and actual VOC concentration of the spray. Assumes 100% of VOC is lost to the atmosphere.
• 3. Emissions based on emissions INCREASES associated with the potential to manufacture larger tires with the 52-inch presses. Assumes that the largest tire produced in the 52-inch press would require ten pounds more rubber that the average tire currently manufactured in the 42-inch presses. The calculation also assumes that 75% of the VOC emissions (i.e., loss of coupling agent) occurs during rubber mixing, with the remaining 25% of VOC emissions lost during rubber curing.

Based on the calculations provided below, the potential VOC emissions increase associated with the installation of the twenty-one (21) new 52-inch tire curing presses is less than the PSD significant emission rate of 40 tons per year. It is important to note that the estimation of VOC emissions provided above do NOT account for the emission decreases associated with the removal of twenty-one existing 42-inch presses.

The replacement of the twenty-one curing presses (ID Nos. CP-161 through 181) does not require PSD permitting pursuant to 15A NCAC 2D .0530.