permit application review summary - New Hampshire Department of ...

PERMIT APPLICATION
REVIEW SUMMARY
New Hampshire Department of Environmental Services
Air Resources Division
P.O. Box 95, 29 Hazen Drive
Concord, NH 03302-0095
Phone: 603-271-1370 Fax: 603-271-7053
Facility: Hypertherm, Inc./Centricut Engineer: Muriel Lajoie
Location: Two Technology Drive, West Lebanon, NH 03784
AFS #: 3300990304 Application #: FY07-0265 Date: DRAFT
APPLICATION & OTHER COMMUNICATION:
Date Description
12/12/2007 Application received
1/23/2008 Administrative Completeness Letter sent (Temporary Permit)
1/28/2008 Compliance Demonstration of Emissions from Plasma Arc Cutting Table 1 for 2003-2007.
PROJECT DESCRIPTION/PERMIT HISTORY
This application is for the installation of a second plasma arc cutting table at Hypertherm’s West Lebanon Facility called
Hypertherm, Inc./Centricut. Hypertherm (or its predecessor, Centricut, LLC) has operated a cutting table with a cartridgetype
dust collector at this location since approximately 1998. Historically this unit has been used intermittently for research
and development purposes. Recently, Hypertherm has expanded usage of the existing table and is in the process of
installing a second plasma arc cutting table. Hypertherm did not require a permit for the table in the past and they are able
to show compliance with the Env-A 1400 ambient air limits (AALs) using uncontrolled emissions. 1
The addition of a second table will require the installation of control technology to keep emissions below the 24-hour and
annual AALs for Regulated Toxic Air Pollutants (RTAPs). This engineering summary covers two plasma arc cutting tables
for the issuance of a Temporary Permit.
FACILITY DESCRIPTION
Hypertherm, Inc. has been in business for more than 30 years and manufactures mechanized, manual and hand-held plasma
cutting systems and torches. Plasma cutting is a process that is used to cut steel and other metals (or sometimes other
materials) using a plasma torch. In this process, an inert gas (in some units, compressed air) is blown at high speed out of a
nozzle; at the same time an electrical arc is formed through that gas from the nozzle to the surface being cut, turning some
of that gas to plasma. The plasma is sufficiently hot to melt the metal being cut and moves sufficiently fast to blow molten
metal away from the cut.
DEVICE DESCRIPTION
Process Device
Installation
Date
Plasma Arc
Cutting Table 1 1998
Plasma Arc
Cutting Table 2 2008
Manufacturer Model #/
Serial#
Maximum Daily
Cut Length (in)
Mazimum Annual
Cut Length
(in)
Hypertherm,
Inc. NA 86,400 5,616,000
Hypertherm,
Inc. NA 86,400 5,616,000
Material Type
Processed
mild steel,
aluminum and
stainless steel
mild steel,
aluminum and
stainless steel
1 Kenneth D. Boivin to Muriel Lajoie; Demonstration of Hypertherm, Inc. / Centricut historical Env-A 1400 compliance
2003 – 2007; January 28, 2008.

PERMIT APPLICATION
REVIEW SUMMARY
New Hampshire Department of Environmental Services
Air Resources Division
P.O. Box 95, 29 Hazen Drive
Concord, NH 03302-0095
Phone: 603-271-1370 Fax: 603-271-7053
Facility: Hypertherm, Inc./Centricut Engineer: Muriel Lajoie
Location: Two Technology Drive, West Lebanon, NH 03784
AFS #: 3300990304 Application #: FY07-0265 Date: DRAFT
PROCESS DESCRIPTION
Hypertherm’s plasma arc cutting torches utilize an ionized gas stream to vaporize metal. Hypertherm cuts mild steel,
stainless steel and aluminum ranging in thickness from 0.048 inches to 2 inches.
POLLUTION CONTROL EQUIPMENT
As discussed in Application FY07-0265, the two plasma arc cutting tables will be ducted in series to a cyclone and a
cartridge filter-type dust collector. The Facility is using the cyclone for large particle removal and is not taking credit for
this in the removal efficiency of RTAPs, NOx or PM. Only the cartridge collector will be considered as pollution control
equipment for RTAPs and PM from the Plasma Arc Cutting Tables. The cartridge collector will use the wide-spacing
PolyTech Filter Media in the HemiPleat Filter by Farr Air Pollution Control. Manufacturer’s literature specifies removal
efficiency of 99.99% on 0.5 ųm and larger particles by weight.
EMISSION CALCULATIONS
Emission testing for plasma arc cutting was conducted on 10/11/2001 at Hypertherm’s Hanover, NH Facility. These
emission rates are summarized in Table 1 Emissions Test Data for Plasma Arc Cutting in Application FY07-0265.
Emission rates for each type of metal cut (mild steel, aluminum and stainless steel) were averaged as pounds of pollutant
per inch of metal cut. The highest of the three rates was converted into lbs/day of pollutant based on the maximum inches
of metal expected to be cut per day (86,400 inches = 72 in/min * 60 min/hr * 20 hr/day). These values are considered the
daily and annual (using 5,616,000 inches) uncontrolled emission rates. Six of 17 Regulated Toxic Air Pollutants (RTAPs)
were below the 24-hour DeMinimis values for those pollutants. Ten of 17 RTAPs were below the Annual DeMinimis
values for those pollutants.
Post control emission rates in application FY07-0265 consider a filter efficiency rating of 99.99%. All 17 RTAPs passed
both the 24-hour Adjusted In-Stack Concentration and Annual Adjusted In-Stack Concentration at this filter efficiency.
Emissions testing conducted in Hanover showed that the efficiency of the collector cartridges used in that application did
not meet the 99% efficiency rating stated in Temporary Permit FP-T-0064. However, though included in the permit, the
99% efficiency value was not necessary to maintain compliance with Env-A 1400. “…DES also agrees with Hypertherm’s
conclustion that, although the dust collectors do not meet the 99% control efficiency required in Condition VI of the
Permit, emissions from the cutting tables have not caused exceedances of the AALs”. 2
In the case of the West Lebanon Hypertherm, Inc./Centricut Facility, compliance with the 24-hour and Annual AAL is
dependent upon a minimum performance of the cartridge filters. Adjusted In-Stack Concentrations for both the 24-hour
and Annual AAL for all 17 RTAPs can be met with a filter efficiency of 97%. Essentially the cartridge collector with the
PolyTech Filter Media is 300 times more effective than it needs to be to assure compliance with the AALs.
The criteria pollutants particulate matter (PM) and Oxides of Nitrogen (NOx) were evaluated to be below the major source
thresholds or 50 and 100 tons per year (tpy), respectively for these pollutants. Particulate matter was evaluated at the 97%
removal efficiency of the filter. NOx emitted was considered as 100% of the daily and annual uncontrolled emission rate as
the cartridge filter is not considered a pollution control device for NOx. The Facility is a True Minor source for these
pollutants.
See the emissions calculations summary at: Hyper_Review_of_GZACalcs.xls.
2 Pamela G. Monroe to Mr. John Blair, June 11, 2002.

PERMIT APPLICATION
REVIEW SUMMARY
New Hampshire Department of Environmental Services
Air Resources Division
P.O. Box 95, 29 Hazen Drive
Concord, NH 03302-0095
Phone: 603-271-1370 Fax: 603-271-7053
Facility: Hypertherm, Inc./Centricut Engineer: Muriel Lajoie
Location: Two Technology Drive, West Lebanon, NH 03784
AFS #: 3300990304 Application #: FY07-0265 Date: DRAFT
STACK INFORMATION
The following table details the stack parameters for the permitted devices:
Stack
Inside
Diameter
(ft)
Exhaust Flow
(acfm)
Exhaust
Temp.
( o F)
Plasma Arc Cutting
Tables 1& 2
Height Above
Ground (ft)
Stack
Configuration
1.08 2,000 70 22.83 Vertical and
Unobstructed
MODELING
Modeling is not necessary as the source has demonstrated compliance with Env-A 1405.05 Adjusted In-Stack
Concentration Method and the air flow exiting the stack is unobstructed.
EMISSION TESTING
No emissions testing will be required at this time.
SITE VISITS/INSPECTIONS
As of the date of this engineering summary, there have been no site visits or inspections of the Hypertherm, Inc./Centricut
Facility in West Lebanon.
REPORTS/FEES
Annual Emission Reports/Fees
This is a new permit subject to permit fees under Env-A 702.02(a) and (b). The Facility submitted the fee required under
Env-A 702.02(a) with the permit application. An invoice was sent to the Facility for the fee due under Env-A 702.02(b) on
1/23/2008 in accordance with Env-A 702.02(c).
CHANGES FROM PREVIOUS PERMIT
Not applicable.
REVIEW OF REGULATIONS
State Regulations
Env-A 600 – Permitting
• 607.01(g) – Not Applicable – The Facility does not have any volatile organic compound (VOC) emissions.
607.01(n) – Not Applicable - The Facility is a true minor source of all criteria pollutants (PM & NOx).
• 607.01 (v) – Applicable – The source has a control device to reduce pollutants subject to Env-A 1400 and requires
a permit.
Env-A 1200 – Prevention, Abatement and Control of Stationary Source Air Pollution
• 1204 – There is no source at the Facility subject to any VOC RACT requirements.
• 1211.01(m) – Not Applicable – The Facility TPE for NOx is < 50 tpy.

PERMIT APPLICATION
REVIEW SUMMARY
New Hampshire Department of Environmental Services
Air Resources Division
P.O. Box 95, 29 Hazen Drive
Concord, NH 03302-0095
Phone: 603-271-1370 Fax: 603-271-7053
Facility: Hypertherm, Inc./Centricut Engineer: Muriel Lajoie
Location: Two Technology Drive, West Lebanon, NH 03784
AFS #: 3300990304 Application #: FY07-0265 Date: DRAFT
Env-A 1400 – Regulated Toxic Air Pollutants
• 1402.01(c) – Applicable/Not Applicable – The exemption applies to only six of 17 Regulated Toxic Air Pollutants
(RTAPs) which are below the 24-hour deminimis values for those pollutants and ten of 17 RTAPs which are below
the annual deminimis values for those pollutants.
• 1403.01(a) – Applicable – The Facility emits eleven of 17 RTAPs above the 24-hour de-mimimis values for those
pollutants and seven of 17 RTAPs above the annual de-minimis values for those pollutants.
• 1405.05 – Applicable – The Facility has chosen to demonstrate compliance with Env-A 1400 by using the
Adjusted In-Stack Concentration.
Env-A 2100 – Particulate Matter and Visible Emissions Standards
• 2103.01 – Applicable – The Plasma Arc Cutting Tables are a source of visible emissions.
• 2103.02 – Applicable – Average opacity from all stationary devices shall not exceed 20% opacity for any
continuous 6-minute period in any 60 minute period during startup, shutdown or malfunction.
Federal Regulations
• No federal regulations are applicable to the Facility.
SUMMARY AND CONCLUSIONS
The operations, as applied for, will be capable of meeting all regulations and standards for air quality. A Temporary Permit
shall be drafted.
H:\Permitting\Source Files\Hypertherm\07-0265_TP\Hyper_Summary.doc