The Tennessee Department of Enironment and Conservationis is in the process of addressing citizen complaints regarding Superior Essex. Below is a Chronology of events. If you would still like to file a complaint with the City of Franklin, please contact the Building and Neighborhood Services Department at 615.794.7012. You can also contact The Department of Environment and Conservation at 615.532.0554.
Chronology of Events (TN Dept. Environment and Conservation)
Addressing Citizen Complaints in the Matter of Superior Essex
Status as of December 23, 2009
“Hard” Dates of Completed Actions
September 3, 2009 – Public Hearing/Town Meeting held at Franklin City Hall to process the Superior Essex Title V Major Source Operating Permit renewal application. Several citizens testified formally at the public hearing and informally at the town meeting to express concern about emissions from the Superior Essex plant.
Concerns registered were burning eyes, burning throats, headaches, odor and interference with the enjoyment of their property. Much concern was also expressed about exposure to children and persons that had other medical disorders that might be aggravated by the emissions. The emissions were described as sometimes you smell it, sometimes you don’t, but when you do smell it, it is overpowering. While the plant has been in operation at its current location for approximately 27 years, several persons commenting remarked that the odors had appeared or significantly increased during the last 1.5 to 2 years. The odor was described in various ways, including the smell of a magic marker, burning plastic, Lysol® or rubber.
The public hearing was held open to receive written comments to close of business, September 8, 2009, and almost 100 comments opposing the renewal of the permit and/or registering concern about the emissions were received.
September 14, 2009 – Superior Essex completed the modification of its exhaust vents to remove “mushroom” caps and replace them with louvers to provide unrestricted, upward flow of the exhaust. This was done in hopes of enhancing atmospheric dispersion and lowering ambient impact concentrations of the emissions. As evidenced by continued citizen complaints, this did not resolve citizen concerns about the emissions.
November 2, 2009 – In response to an earlier notice of violation issued by TDEC-APC on August 7, 2009, Superior Essex installed the last cover on the tanks containing the resin enamel mixture that coated the magnet wire prior to entering the oven. In a letter dated August 27, 2009, the company disagreed with the determination of the violation, but agreed to install the lids nonetheless. The requirement to have lids on these tanks is a work practice standard for magnet wire manufacturing operations as expressed in the federal hazardous air pollutant regulation 40 CFR 63 Subpart MMMM for magnet wire operations. TDEC-APC is evaluating the matter to determine whether additional enforcement action is needed.
In addition to federal hazardous air pollutant regulations imposed by the state of Tennessee on the company’s permit, the company is also subject to state rules for the control of volatile organic compounds. The volatile organic compound emissions from the facility are subject to the provisions of Division Rule 1200-3-18-.19 Coating of Magnet Wire and the Reasonably Available Control Technology Determination made by the Air Pollution Control Board on April 13, 1994 (Board Order 94-14).
General Description of Activity Occurring
During the Processing of the Permit Renewal Application
TDEC-APC has met with the company on a number of occasions in person and in conference calls in an effort to identify the cause of the citizen complaints. During plant visits, TDEC-APC inspectors have identified smoking emissions from hot wire exiting the oven as it cools prior to being wound on the take up spool for shipment. The federal rules for hazardous air pollutant control from magnet wire operations require that the oven be kept under negative pressure (This means that any opening in the oven would draw air from the outside of the oven to the inside of the oven.) to capture emissions and that a thermocouple (measures and records temperature) continuously show that the oven is kept hot enough to effectively destroy the emissions from the coating as it is dried and cured on the wire. Because the wire was seen smoking as it exited the oven and that suggested that the capture of emissions was compromised, TDEC-APC requested the company to design oven extensions to keep the hot, smoking wire under emission control long enough to address the concern. The company has designed the oven extensions and will prototype them in the first half of 2010 if TDEC-APC determines it is needed.
As the number of openings in the oven increase, the more difficult it becomes to keep the oven under an effective negative pressure. Due to thermally induced metallurgical fatigue, the ovens can develop cracks that are not outwardly visible because of insulation sheathing the oven. TDEC-APC instructed the company to perform an inspection of all of its ovens for these cracks and anything else that might be causing the oven to not perform as it was designed to perform with respect to the capture and destruction of coating emissions. All ovens have been inspected and repaired as of November 30, 2009. Inspections noted instances of metal wear and fatigue and some instances of loose metal joints and connections. The preventive maintenance program replaced metal components that showed excessive metal fatigue or wear, replaced and tightened metal joints and connections and conducted routine cleaning and adjustments.
On the other side of the oven – the inlet, TDEC-APC has been working with the company to identify potential capture improvement opportunities. One theory under review is that the number of product changeovers has increased significantly in the last couple of years. In the past, customers ordered “long runs” of wire. Now, with the advent of “just in time delivery” accounting practices, customers order just enough wire for their current needs and keep little to none in inventory. The practical effect of this with respect to emission control is that the ovens have to be opened up more for cleaning up the previous coating and replacing it with the next coating. This means a potential loss of capture efficiency and an increase in the use of clean-up solvent. The company estimates that it loses about 50% of its vapor capture efficiency during these periods and the solvent itself has the potential to be odoriferous as it is about 50% phenol and cresylic acid. To use less of this solvent, the company is looking at felt wiper applicators as opposed to spray applications and the use of drip pans to contain what formerly dripped and required clean up with solvent on the lower sheaves of the oven system.
Another possibility is that increase in the price of copper has lead to a need to produce aluminum magnet wire for certain applications. Aluminum forms a hard, abrasive oxide on the surface of the wire that can abrade the dies used in the process and requires additional coating solvent to sufficiently lubricate the die. That may also be a source of additional emissions of late. In a letter dated December 1, 2009, the company agreed to work on ways to minimize these product changeover emissions. TDEC-APC is working with the company to establish an expeditious schedule to get that done.
TDEC-APC was at the plant on the week of December 14, 2009 to pre-survey the operations at the plant in preparation for a sampling sweep to measure progress made as a result of having the required lids in place on the coating tanks, the improvements made as part of the oven preventative maintenance campaign and to see what effect having the ovens opened up for product changeovers have on emission concentrations on the production floor. This sampling sweep will occur in January 2010, and we hope to have it done in conjunction with an ambient air sample from the Moore Elementary School.
When TDEC-APC is satisfied that the ovens are effectively capturing emissions, and that the ovens are effectively destroying the captured emissions, the last opportunity for making the plant more compatible with the community is to look at dispersion. TDEC will look at the citizen complaints and the observations of its inspectors before making this decision. One possibility is to collect all the vents from the roof into a common manifold and route that to an elevated stack with additional mechanical plume loft to disperse or otherwise dilute the post controlled emissions to lower levels before the plume would touch down in the community.
Ambient Air Sampling
There have been citizen requests to site a number of ambient air stations in the community. TDEC-APC believes that using emission monitoring in a combination of direct and parametric techniques better serves the community in that the activities of the plant are monitored no matter what the meteorological conditions would be. As stated by a number of citizens in the public hearing, sometimes you smell it, sometimes you don’t. Ambient monitors would only “see” a plume if the wind were in that direction and then only if the plume touched down in the vicinity of the ambient monitor.
Because a number of parents expressed concern about their children at Moore Elementary School and Winstead Elementary School, TDEC-APC will install an ambient air monitoring station first at Moore Elementary for a sampling period of approximately two months and then move the monitor to Winstead Elementary for a sampling period of approximately two months. These ambient monitors are being operated for parent “peace of mind” and are not expected to record excessive ambient concentrations of phenol or cresol emissions. TDEC-APC will continue to rely upon direct and parametric emission monitoring at the plant as the primary indicator of community conditions. The sampling and analytical costs for the ambient study should run about $9,000 per school.
Status of the Permit Renewal Application
The permit review by TDEC-APC is complete, and the package was forwarded to the USEPA for its mandatory review of the action on December 21, 2009. TDEC-APC is responsible for summarizing and responding to public comment registered in the formal public hearing process conducted as part of the permit renewal application and making any final edits to the draft permit that originally appeared in the public depository. The USEPA must make its review of the TDEC-APC submittal in accordance with the provisions of 40 CFR 70. During this period, citizens that commented at the public hearing have an opportunity to discuss those comments with the USEPA and ask for relief at the federal level if they do not feel that TDEC-APC adequately addressed their registered concern.
The complete elimination of odor may not be possible. Referring to the EPA publication: Reference Guide to Odor Thresholds for Hazardous Air Pollutants Listed in the Clean Air Act Amendments of 1990 Link: http://www.epa.gov/ttn/atw/odorguide1992.pdf, cresols have an odor threshold of much less than one part per million and phenol has an odor threshold of less than one part per million. That means that persons can still smell them even at very low concentrations.
TDEC-APC will make certain that the facility is in compliance with all environmental regulations, but even at that, the community may still smell a phenol or cresol odor, though it is hoped that it will be at a tolerable level. TDEC-APC informed the community that it would make an announcement of when it had done all it could do in terms of reducing emissions. As described above, many steps have been taken to reduce emissions through improved capture efficiency and others showing promise are being evaluated for implementation. Enhancing dispersion is also an option, though it is an option of last resort.
End of Chronology