1---- ,-, SWCAA Southwest Clean Air Agency

~SWCAA 1---"- ,-, Southwest Clean Air Agency

TECHNICAL SUPPORT DOCUMENT

FABRICATION PRODUCTS, INC.

SWCAA ID: 1329

Air Discharge Permit SWCAA 17-3231

ADP Application CL-3008

Issued: June 7, 2017

Prepared By: Clint Lamoreaux Air Quality Engineer Southwest Clean Air Agency

Technical Support Document Fabrication Products, Inc.

Section

TABLE OF CONTENTS

ADP Application CL-3008 ADP 17-3231

1. Facility Identification 1

2. Facility Description 1

3. Current Permitting Action 1

4. Process Description 1

5. Equipment/ Activity Identification 1

6. Emissions Determination 4

7. Regulations and Emission Standards 9

8. RACT/BACT/BART/LAERJPSD/CAM Determinations 10

9. Ambient Impact Analysis 11

10. Discussion of Approval Conditions 12

11. Start-up and Shutdown Provisions/ Alternative Operating Scenarios/Pollution 13 Prevention

12. Emission Monitoring and Testing 13

13. Facility History 14

14. Public Involvement 14



Abbreviations

ADP AP-42

ASIL BACT BART Btu CAM CAS# cfm CFR co C02e EPA gr/scf GWP HAP LAER lb/yr lbs MMBtu NOx PM

PM10

PSD RACT RCW SDS scfm SQER S02 SW CAA TAP T-BACT tpy voe WAC

Air Discharge Permit Compilation of Emission Factors, AP-42, Fifth Edition. Volume 1. Stationary Point and Area Sources -published by the US Environmental Protection Agency Acceptable Source Impact Level from WAC 173-460 Best Available Control Technology Best Available Retrofit Technology British thermal unit Compliance assurance monitoring (40 CFR 64) Chemical Abstract Service number Cubic feet per minute Code of Federal Regulations Carbon monoxide Carbon dioxide equivalent U.S. Environmental Protection Agency Grains per dry standard cubic foot (68 °F, 1 atmosphere) Global warming potential Hazardous air pollutant listed pursuant to Section 112 of the Federal Clean Air Act Lowest achievable emission rate Pounds per year Pounds Millions of British thermal units Nitrogen oxides Total particulate matter (includes both filterable particulate matter measured by EPA Method 5 and condensable particulate matter measured by EPA Method 202) Particulate matter with an aerodynamic diameter less than or equal to 10 micrometers (includes both filterable particulate matter measured by EPA Method 201 or 201 A and condensable particulate matter measured by EPA Method 202) Particulate matter with an aerodynamic diameter less than or equal to 2.5 micrometers (includes both filterable particulate matter measured by EPA Method 201 or 201 A and condensable particulate matter measured by EPA Method 202) Prevention of Significant Deterioration Reasonably Available Control Technology Revised Code of Washington Safety data sheet Standard (68°F, 1 atmosphere) cubic feet per minute Small Quantity Emission Rate listed in WAC 173-460 Sulfur dioxide Southwest Clean Air Agency Toxic Air Pollutant pursuant to Chapter 173-460 WAC Best Available Control Technology for toxic air pollutants Tons per year Volatile Organic Compound Washington Administrative Code


1. FACILITY IDENTIFICATION Applicant Name: Fabrication Products, Inc. Applicant Address: 4201 NE Minnehaha Street, Vancouver WA 98661

Facility Name: Fabrication Products Facility Address: 4201 NE Minnehaha Street, Vancouver WA 98661 SWCAA Identification: 1329 Contact Person:

Primary Process: SIC/NAICS:

Mr. Greg Sword - Vice President

Fabrication oflarge metal parts 3441I332312

Facility Classifications: BACT I natural minor

2. FACILITY DESCRIPTION


Fabrication Products, Inc. (FPI) is a machinery fabrication operation. The facility performs welding, cutting, shot blasting, abrasive blasting, and painting of various metal parts. Currently the main products are steel beams used for building construction and steel gates used in the hydroelectric industry.

3. CURRENT PERMITTING ACTION This permitting action is in response to Air Discharge Permit application number CL-3008 (ADP Application CL-3008) received March 10, 2017 and an amendment to ADP Application CL-3008 received May 1, 2017. ADP application CL-3008 (as amended) requests approval to:

a. Install a cartridge-style filter system to control emissions from existing abrasive blasting activities. In the past, emissions from abrasive blasting have been controlled by an exhaust filtration system shared with the painting operations.

b. Correct the basis for the abrasive blasting emissions potential from 200 hours per year to 2,000 hours per year. c. Install a new SteelPro robotic plasma beam line utilizing a Hypertherm XPR300 plasma cutter and associated

filtration system.

In addition, a spreadsheet error in the emission factors for plasma cutting will be corrected in Section 6 of the Technical Support Document.

4. PROCESS DESCRIPTION All metal parts fabrication activities are conducted in the shop, including metal cutting (including plasma, oxy/fuel), welding and shot blasting. Shot blasting is conducted with a Wheelabrator-Frye shot blasting plant within the shop. Painting and abrasive blasting are conducted in a separate dedicated building that alternately acts as a paint booth or blast booth. Emissions from painting and blasting will be exhausted through separate emission control systems.

5. EQUIPMENT/ACTIVITY IDENTIFICATION

5.a Welding. Metal Fabrication. Welding and metal fabrication activities are not controlled. Welding is performed in the 32,340 square foot metal fabrication building and welding fumes are exhausted through multiple atmospheric roof vents.

5.b Painting. Painting is conducted in the following booth/building using high transfer efficiency guns (-65% or better). Specific equipment information is listed below:

Make I Model: Custom



5.b Painting. Painting is conducted in the following booth/building using high transfer efficiency guns (-65% or better). Specific equipment information is listed below:

Make I Model: Dimensions: Air Flow: Air Filters:

Stack Description:

Custom Inside a building measuring 75' long, 40' wide, 26' tall 54,000 acfm provided by (3) JBI model EFC-188 exhaust chambers 138 ft2 of Brinks Manufacturing "Paint Pockets" in a single layer rated at 99.84 % arrestance Each of the (3) exhaust chambers utilizes a stack measuring approximately 4' wide by 16" deep and exhausting - 20' above ground level (estimates based on a visual examination during an October 2009 visit)

5 .c Wheelabrator-Frye Shot Blasting Plant. Specific equipment information is listed below:

Make I Model:

Serial Number: Year of Manufacture:

Wheelabrator-Frye I 4-wheel (11.25 KW) plate and section steel shot blasting plant A-135493 Purchased used in -1994 by Fabrication Products

Emission Control Equipment - Baghouse Make I Model: Wheelabrator-Frye I 49-10 Serial Number: Unable to determine (requires ladder or manlift to access) Rated Airflow: 4,200 acfm Filter Description: ( 49) bags of 16 ounce per square yard polyester felt with a total fabric area of 577

square feet. Particulate removal efficiency is estimated at 99 .98% for particles with a diameter equal to or greater than one micron.

Stack Description: Exhausted at-45° from horizontal, -15' above ground level, through- 10" x 12" rectangular stack (estimates based on a visual examination during an October 2009 visit)

5.d Abrasive Blasting (Modified). Abrasive blasting is conducted in the same building as painting but will utilize a separate filtration system. Specific filtration system information is listed below:

Make I Model: Serial Number: Rated Airflow: Filter Description:

Stack Description:

Entech I Cyclone 20 DC 201520142 20,000 acfm, 2.85:1 air:cloth ratio (27) top loading filter cartridges with a total of 7,020 ft2 of total filter area. Standard Qx media by Nordic Air Filtration I TDC Filter. MERV 12 efficiency rating (99.8% at 0.5 µm particles). Exhausted vertically 29' above grade, -3' above the building roof, east side of the building through 22" diameter stack. The skid will be located with the fan end to the north, -73' from the southern property boundary. -45°40'0.90"N, 122°37'36.48"W

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5.e Plasma Table Torch Cutting (existing). Plasma cutting is currently conducted with air as a carrier gas in air (not in or above water). Specific equipment information is listed below:

Torch Make I Model: ALTRA-HPR-260 Hi

Plasma Torch Cutting Filter System. The plasma torch cutting occurs over a downdraft table that vents to the cartridge-style filter system. The downdraft table utilizes louvers that are closed except under the area where the torch is cutting. The frame on which the plasma torch is mounted mechanically opens the louvers as it moves. Specific equipment information is listed below:

Make I Model: Serial Number: Rated Airflow: Filter Description:

Stack Description:

Donaldson Torit I Downflo® Oval (DF03-24) 2261565-1 2,280 cfm-19,150 cfm (24) Ultra-web flame retardant cartridges with 190 square feet of filtration per cartridge, rated at MERV 13 as per ASHRAE Method 52.2. Oriented vertically at least 11' above grade.

5.f SteelPro Plasma Beam Line (new). A new articulated robotic plasma torch will be installed in the fabrication building to cut carbon steel (carbon steels include "mild steel"). No stainless steel or aluminum will be cut with this unit. The plasma torch will be used with a SteelPro 600 robotic beam line. Fume and particulate matter generated from plasma cutting will be captured and vented to a cartridge-style dust collector. Specific equipment information is listed below:

Beam Line Make I Model: Torch Make I Model:

Inovatech Engineering Corp. I SteelPro 600 Hypertherm/ XPR3 00

SteelPro Beam Line Filter System. The plasma torch cutting occurs within the robot enclosure and all fume and particulate matter is vented to the filter system. Specific equipment information is listed below:

Make I Model: Serial Number: Rated Airflow:

Cleaning Method: Filter Description:

Stack Description:

Other Equipment

Inovatech Engineering Corp. I 12 cartridge dust collector To be determined 4,000 cfm at 12" w.c. using a Cincinnati Fan model HDAF-180 60% width fan operated at 3,530 rpm. Pulsed Jet (12) Nonwoven flame retardant cartridges manufactured by Fab-Tex Filtration with a total of 4,840 ft2 filter area, rated at MERV 15 as per ASHRAE Method 52.2. Manufactured from 4.3 oz/yd2 80% cellulose, 20% polyester material. 14" diameter vertical exhaust stack terminating -37' above ground level, -3' above the roof peak of the fabrication building at -45°40'2.08"N, 122°37'40.3 l "W.

5.g Shop Heater. This unit provides hot air to the shop for comfort heating. Specific equipment information is listed below:

Make I Model: Heat Input Capacity: Fuel: Year of Manufacture: Year of Installation: Stack Description:

Tu Go, ICE, model OHV 500LP/NG 0.45 MMBtu/hr propane -2005 -2005 6" round stack exhausting horizontally approximately 5' above grade

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5 .h Equipment/ Activity Summary.

ID No. Generating Equipment/ Activity

1 Welding I Metal Fabrication

2 Painting

3 Abrasive Blasting

4 Wheelabrator-Frye Shot Blasting Plant

5 Plasma Table Torch Cutting

6 SteelPro Beam Line

6. EMISSIONS DETERMINATION

#of Units

NIA

1

1

1

1

1


#of Control Equipment Units

None NIA

Fabric filtration 1

Cartridge-style dust collector 1

Baghouse 1

Cartridge-style filter system 1

Cartridge-style filter system 1

6.a Welding I Metal Fabrication. Emissions from metal fabrication activities (drilling, grinding, etc.) in the shop are not expected to be significant. Potential emissions from welding were calculated by doubling the reported weld/rod usage from 2008 and applying emission factors from AP-42 Section 12.19 (1/95).

Welding Emissions

Wire/Rod Amount Emission Factors (lb/1,000 lb) Type lbs/yr Cr Cr(VI) Co Mn Ni Pb PM10 PM2.s E70S 1,386 0.001 0 0.001 0.318 0.001 0 5.2 5.2 E70T* 8,306 0.004 0 0 0.891 0.005 0.001 15.1 15.1 E71T 57,690 0.002 0 0 0.662 0.004 0 12.2 12.2 E309LT 9,228 0.393 0.015 0.001 0.252 0.043 0 10.8 10.8 E316L (GMA W) 12,150 0.528 0.01 0 0.245 0.226 0 3.2 3.2

Emissions (lbs/year) Type Cr Cr(VI) Co Mn Ni Pb PM10 PM2.s E70S 0.0 0.0 0.0 0.4 0.0 0.0 7.2 7.2 E70T* 0.0 0.0 0.0 7.4 0.0 0.0 125.4 125.4 E71T 0.1 0.0 0.0 38.2 0.2 0.0 703.8 703.8 E309LT 3.6 0.1 0.0 2.3 0.4 0.0 99.7 99.7 E316L(GMAW) 6.4 0.1 0.0 3.0 2.7 0.0 38.9 38.9

Totals= 10.19 0.26 0.01 51.33 3.42 0.01 975 975

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6.b Painting. Emissions ofVOe, TAPs and HAPs from painting operations were calculated using MSDS/SDS and/or technical data sheet information for individual coating products, and a basis of 177% of the material consumption reported for calendar year 2008 (resulting in 10.0 tpy VOe facilitywide). PM10 emissions were determined using the mass of coating sprayed, 30% solids content, an assumed 98% filter arrestance and 65% transfer efficiency.

TAP HAP Emissions Emissions

Pollutant eAS# (lb/yr) (lb/yr) Acetone 67-64-1 1,584 ---n-Butyl acetate 123-86-4 8 ---Ethyl benzene 100-41-4 1,134 1,134 2-Ethoxyethyl acetate 111-15-9 8 8 Isopropyl alcohol 67-63-0 1,126 ---Methyl alcohol 67-56-1 211 211 Methyl ethyl ketone (MEK) 78-93-3 4,173 4,173 Methyl isobutyl ketone (MIBK) 108-10-1 273 273 Toluene 108-88-3 2,136 2,136 Triethylamine 121-44-8 7 7 Xylenes (m-,o-,p-isomers) 108-38-3 4,582 4,582 (represents all xylenes 1330-20-7)

Totals= 15,242 12,525 PMIPM10 Emissions = 68 lb/yr

SQER (lb/period)

43,748 43,748 43,748 10,500 43,748 43,748 43,748 43,748 43,748

175 43,748

Avg. Period

yr yr yr yr yr yr yr yr yr yr yr

ASIL (µglm3) 5,900 2,400 1,000

90 3,300 870

1,000 680 400

7 1,500

PM2.s Emissions= 53 lb/yr (SWeAA assumed that 78% of the PMIPM10 emissions are PM2.s voe Emissions= 19,961 lb/yr

Actual annual emissions must be calculated using annual material purchases, material composition data, filter efficiencies and transfer efficiency for spray applied coatings.

6.c Abrasive Blasting. Emissions from this activity consist of particulate matter. Potential annual emissions were calculated with the assumption that this activity is conducted with the exhaust system operating at full rated capacity for 2,000 hours per year and an exhaust concentration of 0.005 gr/scf (assumes all filters are in good repair).

Abrasive Blasting

Source Abrasive Blasting

flow scfm

20,000 gr/dscf 0.005

Hours of Operation

2,000 lb/hr 0.86

PM/PM 10IPM2.s lb/yr tpy 1,714 0.86

6.d Wheelabrator-Fiye Shot Blasting Plant. Emissions from this unit consist of particulate matter exhausted out of the baghouse stack. Potential annual emissions were calculated with the assumption that the equipment will operate at full rated capacity for 8,760 hours per year and the baghouse is in good repair.

Wheelabrator Abrasive Blasting Unit

Source Wheelabrator

flow scfm 4,200

gr/dscf 0.005

5

Hours of Operation

8,760 lb/hr 0.18

PM/PM 10IPM2.s lb/yr tpy 1,577 0.79



6.e Plasma Table Torch Cutting. Plasma torch cutting will generate fume (particulate matter) emissions and small amounts of nitrogen oxides. Based on emission factors from "Emissions of Fume, Nitrogen Oxides and Noise in Plasma Cutting of Stainless and Mild Steel" Bromeen B. et al March 1994", uncontrolled emissions were calculated as indicated below:

Plasma Cutting Uncontrolled #of Hours Fume NOx Fume NOx

min Hours of mild steel cutting = 23 10.2 13.33 5.89 Hours of stainless steel (-8 mm) = 35 9.7 20.28 5.65 Hours of stainless steel (-35 mm)= 3 15.2 1.51 8.80

NOx emissions are not controlled. Because potential fume generation is greater than the estimated baghouse discharge concentration, particulate matter emissions were calculated from an allowable baghouse discharge concentration of 0.005 gr/dscf, the baghouse flow rate and the annual hours of baghouse operation. This will likely be conservative because fume may not be generated during all of the time that the baghouse will be on.

Torch Cutting (estimated from dust collector discharge) (PM11/PM2.s Emissions) Rated

flow(cfm Plama Cutting Filter System 19,150

Emissions lb/hr 0.82 3.59

In the future, emissions must be calculated using the emission factors identified above unless new emission factors are provided by the manufacturer or developed through source testing.

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6.f SteelPro Beam Line. Plasma torch cutting will generate fume (particulate matter) emissions and small amounts of nitrogen oxides. Based on emission factors from "Emissions of Fume, Nitrogen Oxides and Noise in Plasma Cutting of Stainless and Mild Steel" Bromeen B. et al March 1994", uncontrolled emissions were calculated as indicated below:

Plasma Cutting Uncontrolled #of Hours Fume NOx Fume NOx Operated g/min g/min tpy tpy

Hours of mild steel cutting = 8,760 I 23 10.2 13.33 5.89

NOx emissions will not be controlled. Because potential fume generation is greater than the estimated baghouse discharge concentration, particulate matter emissions were calculated from an allowable baghouse discharge concentration of 0.005 gr/dscf, the baghouse flow rate and the annual hours of baghouse operation. This will likely be conservative because fume may not be generated during all of the time that the baghouse will be on.

Torch Cutting (estimated from dust collector discharge) (PM11/PM2.s Emissions) Rated Hours

flow ( cfm) of Op. I gr/dscf SteelPro Plama Cuttin~ Filter System 4,000 8,760 I 0.005

Emissions lb/hr 0.17

tov 0.75

Mild steel contains less than 1 % manganese, therefore SWCAA conservatively assumed that no more than 1 % of the fume was manganese. This does not account for the fact that much of the fume will be in the form of metal oxides.


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6.g Shop Heater. Potential annual emissions from the combustion of propane were calculated with the assumption that the equipment will operate at full rated capacity (0.45 MMBtu/hr) for 8,760 hours per year.

Shop Heater

Heat Input Rating = 0.45 MMBtu/hr Propane Heat Content = 91.5 MMBtu/1,000 gal (for AP-42 Emission Factors) Propane Heat Content = 92.0 MMBtu/1,000 gal (for 40 CFR 98 Emission Factors) Operating Hours = 8,760 hours per year Propane Consumption = 4.92 gal/hr Propane Consumption = 43,082 gal/yr Propane Sulfur Content = 185 ppmw Propane Weight = 4.24 lbs/gallon

propane Emissions Emissions Emissions Emission Factor Pollutant lb/1,000 gal lb/hr lb/yr tpy Source NOx 13.0 0.064 560 0.28 AP-42 Section 1.5 (07 /08) co 7.5 0.037 323 0.16 AP-42 Section 1.5 (07 /08) voe 0.8 0.004 34 0.02 AP-42 Section 1.5 (07 /08)

SOx as S02 1.57 0.008 68 0.03 Mass Balance

PM 0.7 0.003 30 0.02 AP-42 Section 1.5 (07 /08)

PM10 0.7 0.003 30 0.02 AP-42 Section 1.5 (07 /08)

PM2.s 0.7 0.003 30 0.02 AP-42 Section 1.5 (07 /08)

C02e C02e Emission Factor

Greenhouse Gases kg/MMBtu GWP lb/gallon tpy Source

C02 61.71 1 12.52 270 40 CFR98

CH4 0.003 25 0.02 0.3 40CFR98

N20 0.0006 298 0.04 0.8 40 CFR98

Total GHG - C02e 61.7136 12.568 271


6.h Facilitywide Potential Emissions Summary.

Pollutant Potential Annual Emissions (tpy) Nitrogen oxides 14.96 Carbon monoxide 0.16 Volatile organic compounds 10.00 Sulfur oxides as sulfur dioxide 0.03 Particulate matter 6.53 PM10 6.53 PM2.s 6.52 Toxic Air Pollutants 7.65 Hazardous Air Pollutants 6.29 C02e 271

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7. REGULATIONS AND EMISSION STANDARDS


Regulations that have been used to evaluate the acceptability of the proposed facility and establish emission limits and control requirements include, but are not limited to, the regulations, codes, or requirements listed below.

7.a Title 40 Code of Federal Regulations (40 CFR) 63.11514 et seq. (Subpart :XXXXXX) "National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories" establishes standards and work practices for nine metal fabrication and finishing sources engaged in operations that use materials that contain or have the potential to emit chromium, lead, manganese, nickel, or cadmium. The source categories listed in the Subpart include: electrical and electronic equipment finishing operations, fabricated metal products, fabricated plate work (boiler shops), fabricated structural metal manufacturing, heating equipment, except electric, industrial machinery and equipment finishing operations, iron and steel forging, primary metal products manufacturing, and valves and pipe fittings. The Permittee's facility is an existing area source that manufactures a variety of custom structural steel projects (NAICS code 332312) and is subject to this regulation. Existing facilities must provide an Initial Notification to the Administrator and be in compliance with the applicable provisions of the subpart no later than July 25, 2011. Because SWCAA is not administering this regulation, the requirements related to this regulation have not been included in the Air Discharge Permit.

7.b 40 CFR 63.11169 et seq. (Subpart HHHHHH) "National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources" establishes standards and work practices for all area sources engaged in paint stripping operations using methylene chloride, autobody refinishing operations, or spray coating of metal or plastic parts with coatings that contain chromium, lead, manganese, nickel, or cadmium (target HAPs). This rule does not apply to surface coating or paint stripping activities covered under another area sources NESHAP. This facility is subject to 40 CFR 63.11514 et seq. Subpart :XXXXXX, therefore this facility is not subject to Subpart HHHHHH.

7.c Revised Code of Washington (RCW) 70.94.141 empowers any activated air pollution control authority to prepare and develop a comprehensive plan or plans for the prevention, abatement and control of air pollution within its jurisdiction. An air pollution control authority may issue such orders as may be necessary to effectuate the purposes of the Washington Clean Air Act [RCW 70.94] and enforce the same by all appropriate administrative and judicial proceedings subject to the rights of appeal as provided in Chapter 62, Laws of 1970 ex. sess.

7.d RCW 70.94.152 provides for the inclusion of conditions of operation as are reasonably necessary to assure the maintenance of compliance with the applicable ordinances, resolutions, rules and regulations when issuing an Order of Approval (Air Discharge Permit) for installation and establishment of an air contaminant source.

7.e Washington Administrative Code (WAC) 173-460 "Controls for New Sources of Toxic Air Pollutants" (as in effect August 21, 1998) requires Best Available Control Technology for toxic air pollutants (T-BACT), identification and quantification of emissions of toxic air pollutants and demonstration of protection of human health and safety.

7.f WAC 173-476 "Ambient Air Quality Standards" establishes ambient air quality standards for PM10, PM2.s, lead, sulfur dioxide, nitrogen dioxide, ozone, and carbon monoxide in the ambient air, which shall not be exceeded.

7 .g SW CAA 400-040 "General Standards for Maximum Emissions" requires all new and existing sources and emission units to meet certain performance standards with respect to Reasonably Available Control Technology (RACT), visible emissions, fallout, fugitive emissions, odors, emissions detrimental to persons or property, sulfur dioxide, concealment and masking, and fugitive dust.

9



7.h SWCAA 400-040(1) "Visible Emissions" requires that no emission of an air contaminant from any emissions unit shall exceed twenty percent opacity for more than three minutes in any one hour at the emission point, or within a reasonable distance of the emission point.

7.i SWCAA 400-040(4) "Odors" requires any source which generates odors that may unreasonably interfere with any other property owner's use and enjoyment of their property to use recognized good practice and procedures to reduce these odors to a reasonable minimum.

7.j SWCAA 400-050 "Emission Standards for Combustion and Incineration Units" requires that all provisions of SWCAA 400-040 be met and that no person shall cause or permit the emission of particulate matter from any combustion or incineration unit in excess of 0.23 grams per dry cubic meter (0.1 grains per dry standard cubic foot) of exhaust gas at standard conditions.

7 .k SW CAA 400-110 "New Source Review" requires that an Air Discharge Permit application be filed with SW CAA prior to the establishment of any new source, emission unit, or modification and that an Air Discharge Permit be issued prior to establishment of the new source, emission unit, or modification.

7.1 SWCAA 400-111 "Requirements for Sources in a Maintenance Plan Area" requires that no approval to construct or alter an air contaminant source shall be granted unless it is evidenced that: (1) The equipment or technology is designed and will be installed to operate without causing a violation of the

applicable emission standards; (2) Emissions will be minimized to the extent that the new source will not exceed emission levels or other

requirements provided in the maintenance plan; (3) Best Available Control Technology will be employed for all air contaminants to be emitted by the proposed

equipment; ( 4) The proposed equipment will not cause any ambient air quality standard to be exceeded; and (5) If the proposed equipment or facility will emit any toxic air pollutant regulated under WAC 173-460, the

proposed equipment and control measures will meet all the requirements of that Chapter.

The Permittee's facilities is within the Portland/Vancouver Maintenance Plan Area, therefore this regulation is applicable to the Permittee's facilities.

7.m SWCAA 490-205 "Surface Coating of Miscellaneous Metal Parts and Products" requires specified sources ofVOCs located within designated ozone nonattainment and maintenance plan areas comply with emission standards of that Chapter if potential VOC emissions are greater than 10 tons per year. The Permittee's potential VOC emissions will not exceed 10 tons per year therefore this regulation does not apply to the applicant's facility.

7.n SWCAA 493-300 "Architectural Coatings" establishes VOC content limits for all architectural coatings manufactured, distributed, sold, or commercially applied within the boundaries of the Vancouver Air Quality Maintenance Area. The Permittee's facility is located within the Vancouver Air Quality Maintenance Area and may apply architectural coatings, therefore this regulation can apply to the Permittee's facility.

8. RACT/BACT/BART/LAEWPSD/CAM DETERMINATIONS The proposed equipment and control systems have been evaluated to determine if they meet the requirements of Best Available Control Technology (BACT) and Best Available Control Technology for toxics (T-BACT) for the types and amounts of air contaminants emitted by the processes and equipment as described below:

10


New BACT Determination


8.a BACT Determination - Abrasive Blasting. The proposed use of cartridge-style filters would be the top choice in a "top-down" BACT analysis. The level of filtration proposed (MERV 12) meets the requirements of BACT for the size and type of particulate matter generated from the abrasive blasting activities.

8.b BACT Determination - SteelPro Beam Line. The proposed use of cartridge-style filters would be the top choice in a "top-down" BACT analysis. The level of filtration proposed (MERV 15 cartridge-style filters) meets the requirements of BACT for the size and type of particulate matter generated from the plasma cutting activities. No cost-effective means of minimizing NOx emissions have been identified and the quantity of NOx emissions are highly uncertain, therefore SWCAA had determined that no additional controls are appropriate to address potential NOx emissions.

Pre-Existing BACT Determinations

8.c BACT Determination - Plasma Torch Cutting (ADP 09-2900). Plasma torch cutting is primarily a source of particulate phase fume. The Permittee's cartridge-style filtration system would be the top choice in a top-down BACT analysis, therefore no other control options were evaluated.

8.d BACT Determination - Increased Painting Activity (ADP 09-2900). The Permittee requested that the VOC emission limit be increased significantly from 6.0 tons per year to account for anticipated business growth. The voe emission limit was raised to 10.0 tons per year, almost all from painting. voe emissions from painting (some of which are also TAPs and HAPs) are captured and vented vertically at a rate of approximately 54,000 cfm. Potential control measures include the use of a regenerative thermal oxidizer and carbon adsorption. Neither option would be cost-effective at the emission rates proposed, therefore SWCAA accepts the use of adequate vertical dispersion as BACT at this facility.

BACT for the control of particulate matter from paint overspray requires at least 98% capture consistent with 40 CFR 63 Subpart XXXXXX.

8.e Prevention of Significant Deterioration (PSD) AP.Plicability Determination. This permitting action will not result in a potential emissions increase equal to or greater than the applicable PSD thresholds. Therefore, requirements of the PSD program are not applicable to this action.

8.f Compliance Assurance Monitoring (CAM). CAM is not applicable to any emission unit at this facility because this facility is not a major source required to obtain a Part 70 or 71 permit.

9. AMBIENT IMP ACT ANALYSIS This permitting action is not associated with an increase in any type of air emissions. Emissions of criteria air pollutants (nitrogen oxides, carbon monoxide, sulfur dioxide, particulate matter, and volatile organic compounds) are all at or below 15 tons per year each. At these emission rates, no adverse ambient air quality impact is anticipated.

Conclusions

9.a Operation of the metal fabricating facility as proposed in ADP Application CL-3008 will not cause the ambient air quality standards established by Title 40 Code of Federal Regulations Part 50 (40 CFR 50), "National Primary and Secondary Ambient Air Quality Standards" to be violated.

9.b The metal fabricating facility proposed in ADP Application CL-3008, if properly installed and maintained, can be operated without causing a violation of the applicable emission standards, which include the limits established under SW CAA 400-040 "General Standards for Maximum Emissions."

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9.c Operation of the metal fabricating facility as proposed in ADP Application CL-3008 will not cause the requirements of WAC 173-460 "Controls for New Sources of Toxic Air Pollutants,'' (in effect August 21, 1998) or WAC 173-476 "Ambient Air Quality Standards" to be violated.

10. DISCUSSION OF APPROVAL CONDITIONS SWCAA has made a determination to issue Air Discharge Permit 17-3231 in response to ADP Application CL-3008. Air Discharge Permit 17-3231 contains approval requirements deemed necessary to assure compliance with applicable regulations and emission standards as discussed below.

10.a General Basis. Approval conditions for equipment affected by this permitting action incorporate the operating schemes proposed by the permittee in the Air Discharge Permit application.

10.b Emission Limits. The annual facilitywide VOC emission limit was increased to 10.0 tons per year in Air Discharge Permit 09-2900 at the request of the permittee to accommodate increased production.

In Air Discharge Permit 09-2900 the annual emission limit for the Wheelabrator-Frye Shot Blasting baghouse was reduced from 0.9 tons per year to 0.79 tons per year consistent with the maximum potential emissions from that unit identified in Section 6 of this Technical Support Document.

PM emissions from both plasma torch cutting exhausts were limited to 0.005 gr/dscf consistent with BACT.

A zero percent opacity limit was established for all equipment at the facility because any visible emissions from any of these emission units would indicate that the unit or control equipment was malfunctioning and producing excess emissions.

10.c Operating Limits and Requirements. To minimize the impact of emissions on ambient air quality, the exhausts from painting, abrasive blasting, and plasma torch cutting were required to be exhausted vertically. Any device that obstructs or prevents vertical discharge is prohibited. This is good engineering practice and is required by SW CAA 400-200(1) for all new equipment.

Installation of differential pressure gages to monitor pressure drops across the fabric filtration systems was required to assist in evaluating whether the dust collectors are operating properly. Large changes in differential pressure can indicate operational problems.

Consistent with the requirements of 40 CPR 63 Subpart :XXXXXX and BACT, the paint enclosure filters must be capable of capturing at least 98% of the particulate matter from paint overspray.

1 O.d Monitoring and Recordkeeping. Sufficient monitoring and recordkeeping was established to document compliance with the annual emission limits and provide for general requirements (e.g. excess emission reporting, annual emission inventory submission). Logging of differential pressure reading across filtration systems were required weekly to monitor for operational problems.

10.e Emission Monitoring and Testing Requirements. See Section 12.

10.f Reporting. The permit requires reporting of the annual air emissions inventory, and reporting of the data necessary to develop the inventory. Excess emissions must be reported as soon as possible in order to qualify for relief from monetary penalty in accordance with SWCAA 400-107. In addition, deviations from permit conditions must be rei>orted within 30 days of discovery in accordance with the SW CAA 400-107 requirement for excess emissions.

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11. START-UP AND SHUTDOWN/ALTERNATIVE OPERATING SCENARIOS/POLLUTION PREVENTION

11.a Startup and Shutdown Provisions. Pursuant to SWCAA 400-081 "Startup and Shutdown," technology based emission standards and control technology determinations shall take into consideration the physical and operational ability of a source to comply with the applicable standards during startup or shutdown. Where it is determined that a source is not capable of achieving continuous compliance with an emission standard during startup or shutdown, SWCAA shall include appropriate emission limitations, operating parameters, or other criteria to regulate performance of the source during startup or shutdown.

The permittee did not identify any startup and shutdown periods during which the proposed equipment is not capable of achieving continuous compliance with any applicable emission standard or approval condition. Therefore, specific startup and shutdown provisions were not included in the permit.

11.b Alternate Operating Scenarios. SWCAA conducted a review of alternate operating scenarios applicable to equipment affected by this permitting action. The applicant did not propose or identify any applicable alternate operating scenarios. Therefore, none were accommodated by the approval conditions.

11.c Pollution Prevention Measures. SWCAA conducted a review of possible pollution prevention measures for the facility. No pollution prevention measures other than the control measures identified in the permit were identified by either the permittee or SWCAA. Therefore, no additional measures were included in the approval conditions.

12. EMISSION MONITORING AND TESTING Initial and periodic (once every 10 years) source emissions testing of the Abrasive Blasting dust collector was required to demonstrate initial and on-going compliance with BACT and permitted emission limits. It is expected that the ten-year testing frequency is appropriate based on the size of the equipment (up to 20,000 cfm), the cartridge-style design, the type of service (ambient temperature dust) and the fact that emissions are limited to 0.86 tons per year (which limits the number of hours the unit can be operated each year based on measured emissions).

No source emission tests were required for the SteelPro Beam line because the inlet particulate matter concentration is expected to be relatively low (much lower than the abrasive blasting dust collector inlet for example), and the cartridgestyle filter design is expected to provide a reliable level of emission control.

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13. FACILITY IDSTORY


13 .a Previous Approvals. The following permits have been issued for this facility:

Permit Number Annlication # Date Issued Descriotion 09-2900 CL-2097 11/10/2009 Approval for cartridge-style fabric filter to control emissions

from plasma cutting, increase in voe emission limits to 10 tov. 01-2398 CL-1539 11129/2001 Relocation of the facility from 6131NE63rd Street, Vancouver,

WA to its new location at 4201 NE Minnehaha Street, Vancouver, WA. Installation of a custom designed painting and abrasive blasting building at the new location. Superseded 95-1730 and 89-1057.

95-1730 CL-948 3/23/1995 Installation of Wheelabrator-Frye steel shot blasting plant and paint spray booth.

89-1057 CL-778 5/18/1990 Installation and operation of metal fabrication facility. This permit was issued after SWCAA found the facility operating without a permit.

Bold font indicates that the Air Discharge Permit was superceded or will no longer be in effect upon issuance of Air Discharge Permit 17-3231.

14. PUBLIC INVOLVEMENT

14.a Public Notice for Air Discharge Permit Application CL-3008. Public notice for Air Discharge Permit Application CL-3008 was published on the SWCAA internet website for a minimum of 15 days beginning on March 21, 2017.

14.b Public/Applicant Comment for Air Discharge Permit Application CL-3008. SWCAA did not receive formal comments, a comment period request, or any other inquiry from the public or the applicant regarding this Air Discharge Permit application. Therefore, no public comment period was provided for this permitting action.

14.c State Environmental Policy Act (SEPA). SWCAA issued Determination of Non-Significance 17-020 on June 7, 2017 for this project. The most relevant non-air quality impact was the potential for noise from the new fan for the Abrasive Blasting dust collector. Sound measurements by the manufacturer for this machine indicated a sound level of 70 dB 50' to the south end of the machine, and that "beyond 50' distance decibel readings dropped off quickly to less than 50 decibels." The southern property boundary (the nearest boundary and the only nearby boundary that may have residential buildings in the future) is approximately 73' from the north (fan end) of the machine. It appears that the equipment will meet the 60 dB (daytime) and 50 dB (nighttime) sound level requirements for impact on residential property found in WAC 173-60. Noise impacts within potential future housing are expected to be much less than 45 dB, which is the level below which mitigation is not typically required.

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