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Notice of Construction Application Zodiac Advanced Composites
and Engineered Materials
501 North Newport Avenue
Newport, Washington 99156
February 22, 2017
Terracon Project No. MP157289C
Prepared for:
Zodiac Advanced Composites and Engineered Materials
Prepared by:
Terracon Consultants, Inc.
Minneapolis, Minnesota
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lrerracan
February 22, 2017
Department of Ecology
Cashiering Unit
P.O. Box 47611
Olympia, WA 98504-7611
Re: Notice of Construction Application
Zodiac Advanced Composites and Engineered Materials
501 North Newport Avenue
Newport, Washington 99156
Dear Department of Ecology:
Terracon Consultants, Inc. was retained by Zodiac to assist with
the completion and submittal of this Notice of Construction
Application for their Newport, Washington facility.
Included in this submittal is the Notice of Construction
Application and permit application fee of $10,000.
A copy of the final stack test report for the testing on the
Panel Press will be submitted when the report has been
received.
If you have any questions please give me a call at (763)
489-3158.
Sincerely,
Liesch - A Terracon Company
~ \)~(Joshua Kurtz, PE David C. Reynol Staff Engineer Senior Air
Quality Eng
Attachment: Notice of Construction Application Notice of
Construction Application CD Permit Application Fee
Liesch - A Terracon Company 13400 15th Avenue North Minneapolis,
Minnesota 55441
P [7631489 3100 F [7631489 3101 terracon com
Environmental • Facilities • Geotechnical • Materials
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TABLE OF CONTENTS
APPENDIX A – NOC GENERAL INFORMATION (SECTIONS I-II)
APPENDIX B – NOC TECHNICAL INFORMATION (SECTIONS III, V-VII)
APPENDIX C – NOC SEPA CHECKLIST (SECTION IV)
APPENDIX D – NOC BACT ANALYSIS (SECTION VIII)
APPENDIX E – AMBIENT AIR IMPACTS ANALYSES (SECTION IX)
APPENDIX F – PTE CALCULATIONS
APPENDIX G – 2016 ACTUAL EMISSION CALCULATIONS
APPENDIX H – NOC SUPPORTING FIGURES
APPENDIX I – PANEL PRESS PRELIMINARY STACK TEST RESULTS
APPENDIX J – GEORGIA-PACIFIC POLYMERIZATION
INFORMATION/RESULTS
APPENDIX K – THERMAL OXIDIZER SPECIFICATIONS
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APPENDIX A NOTICE OF CONSTRUCTION APPLICATION
GENERAL INFORMATION
SECTIONS I-II
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Notice of Construction Application
This application applies statewide for facilities under the
Department of Ecology’s
jurisdiction. Submit this form for review of your project to
construct a new or modified
source of air emissions. Please refer to Ecology Forms ECY
070-410a-g, “Instructions for
NOC Application,” for general information about completing the
application.
Ecology offers up to two hours of free pre-application
assistance. We encourage you to
schedule a pre-application meeting with the contact person
specified for the location of your
proposal, below. If you use up your two hours of free
pre-application assistance, we will
continue to assist you after you submit Part 1 of the
application and the application fee. You
may schedule a meeting with us at any point in the process.
Upon completion of the application, please enclose a check for
the initial fee and mail to:
Department of Ecology For Fiscal Office Use Only:
Cashiering Unit 001-NSR-216-0299-000404 P.O. Box 47611
Olympia, WA 98504-7611
Check the box for the location of your proposal. For assistance,
call the contact listed below:
Ecology Permitting Office Contact
CRO
Chelan, Douglas, Kittitas, Klickitat, or Okanogan County
Ecology Central Regional Office – Air Quality Program
Lynnette Haller
(509) 457-7126
[email protected]
ERO
Adams, Asotin, Columbia, Ferry, Franklin,
Garfield, Grant, Lincoln, Pend Oreille, Stevens,
Walla Walla or Whitman County
Ecology Eastern Regional Office – Air Quality Program
Greg Flibbert
(509) 329-3452
[email protected]
NWRO
San Juan County
Ecology Northwest Regional Office – Air Quality Program
David Adler
(425) 649-7082
[email protected]
IND
For actions taken at
Kraft and Sulfite Paper Mills and Aluminum Smelters
Ecology Industrial Section – Waste 2 Resources Program
Permit manager: ____________________________________
Garin Schrieve
(360) 407-6916
[email protected]
NWP
For actions taken on the
US Department of Energy Hanford Reservation
Ecology Nuclear Waste Program
Philip Gent
(509) 372-7983
[email protected]
ECY 070-410 (Rev. 1/2013) Page 1 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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Notice of Construction Application Check the box below for the
fee that applies to your application.
New project or equipment:
$1,500: Basic project initial fee covers up to 16 hours of
review.
$10,000: Complex project initial fee covers up to 106 hours of
review.
Change to an existing permit or equipment:
$200: Administrative or simple change initial fee covers up to 3
hours of review
Ecology may determine your change is complex during completeness
review of your application. If
your project is complex, you must pay the additional $675 before
we will continue working on your
application.
$875: Complex change initial fee covers up to 10 hours of
review
$350 flat fee: Replace or alter control technology equipment
under WAC 173-400-114
Ecology will contact you if we determine your change belongs in
another fee category. You must
pay the fee associated with that category before we will
continue working on your application.
Read each statement, then check the box next to it to
acknowledge that you agree.
The initial fee you submitted may not cover the cost of
processing your application. Ecology will
track the number of hours spent on your project. If the number
of hours Ecology spends exceeds
the hours included in your initial fee, Ecology will bill you
$95 per hour for the extra time.
You must include all information requested by this application.
Ecology may not process your
application if it does not include all the information
requested.
Submittal of this application allows Ecology staff to visit and
inspect your facility.
ECY 070-410 (Rev. 1/2013) Page 2 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
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Notice of Construction Application Part 1: General
Information
I. Project, Facility, and Company Information 1. Project
Name
Zodiac - Total Facility NOC Application
2. Facility Name
Zodiac Cabin and Structures Support, LLC dba Engineered
Materials
3. Facility Street Address
501 North Newport Avenue, Newport, Washington 99156
4. Facility Legal Description
Manufacturer of Composite Materials
5. Company Legal Name (if different from Facility Name)
6. Company Mailing Address (street, city, state, zip)
501 North Newport Avenue, Newport, Washington 99156
II. Contact Information and Certification 1. Facility Contact
Name (who will be onsite)
Mark Harper
2. Facility Contact Mailing Address (if different than Company
Mailing Address)
501 North Newport Avenue, Newport, Washington 99156
3. Facility Contact Phone Number
509-447-4122
4. Facility Contact E-mail
[email protected]
5. Billing Contact Name (who should receive billing
information)
Ti Bertram
6. Billing Contact Mailing Address (if different than Company
Mailing Address)
12806 State Avenue, Marysville, WA 98271
7. Billing Contact Phone Number
360-653-2600
8. Billing Contact E-mail
[email protected]
9. Consultant Name (optional – if 3rd party hired to complete
application elements)
Dave Reynolds
10. Consultant Organization/Company
Terracon Consultants
11. Consultant Mailing Address (street, city, state, zip)
13400 15th Avenue North, Plymouth, MN 55441
12. Consultant Phone Number
763-489-3158
13.Consultant E-mail
[email protected]
14. Responsible Official Name and Title (who is responsible for
project policy or decision-making)
Mike Pound, Vice President
16. Responsible Official Phone
360-653-2600
17. Responsible Official E-mail
[email protected]
18. Responsible Official Certification and Signature
I certify, based on information and belief formed after
reasonable inquiry, the statements and information in
this application are true, accurate and complete.
Signature ________________________________________
Date____________________
ECY 070-410 (Rev. 1/2013) Page 3 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
mailto:[email protected]:[email protected]:[email protected]:[email protected]
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APPENDIX B NOTICE OF CONSTRUCTION APPLICATION
TECHNICAL INFORMATION
SECTIONS III, V-VII
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Notice of Construction Application Part 2: Technical
Information
The Technical Information may be sent with this application form
to the Cashiering Unit, or
may be sent directly to the Ecology regional office with
jurisdiction along with a copy of this
application form.
For all sections, check the box next to each item as you
complete it.
III. Project Description
Please attach the following to your application.
Written narrative describing your proposed project.
Projected construction start and completion dates.
Operating schedule and production rates.
List of all major process equipment with manufacturer and
maximum rated capacity.
Process flow diagram with all emission points identified.
Plan view site map.
Manufacturer specification sheets for major process equipment
components. Manufacturer specification sheets for pollution control
equipment. Fuel specifications, including type, consumption (per
hour & per year) and percent sulfur.
A. Written narrative describing your proposed project.
The Zodiac Aerospace facility located in Newport, Washington
specializes in the manufacture of composites used for structural
and cabin components in the aerospace industry.
The manufacturing of composite materials at the Zodiac facility
consists of several major
processes. These processes consist of the formulations room, the
treater process, the winder
process, and the panel press. Additional supporting processes
and sources of emissions include powder weighing and adding,
solvent cleaning, the core saw, the cleaning booth, the measuring
table, Thermwood trimming, and the thermal oxidizer. The potential
to emit (PTE) and limited PTE can be found in Appendix F. The 2016
actual emission calculations from the facility can be found in
Appendix G.
Formulation. The Formulations area consists of 7 mixing vessels
where the resins are produced. In addition to the mixing vessels
there is a powder weighing station and areas where the powder can
be added to the resins. Some of the resins are required to be
stored at
a slightly elevated temperature so there is an electric oven in
the room where some of the resins are stored. Some of the resins
that are produced are used on site in the Treater and
Winder processes, however some of the resins are also shipped to
other locations. Zodiac is
proposing a limit on the amount of certain higher emitting
resins that can be produced to
limit the potential to emit (PTE) from the process.
ECY 070-410 (Rev. 1/2013) Page 4 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
-
Notice of Construction Application
Treater. The Treater is an enclosed process that applies resins
to a glass substrate which is
essentially a thick sheet with a honeycomb structure. After the
resin is applied the prepreg
material passes through dryer sections to be cured before being
rolled and stored in plastic
bags until they are used in other processes. All of the
emissions from the Treater are
captured and vented to the thermal oxidizer. Zodiac tracks resin
usage and performs testing
that documents the amount of phenol and formaldehyde that
remains in the product after
being processed by the Treater.
Winders. The Winder room contains 5 Winder machines where resins
are applied to a
narrow fiber core strand and wound around a rotating barrel to
create layered sheets. The
prepreg product is removed from the barrel and either packaged
and sold or stored on racks
for a number of days until the prepreg meets the required
specifications for processing in the
Panel Press. Stack testing has shown that the majority of VOCs
from the resin are emitted in
the Winder room. There may be some minimal amounts of VOCs that
remain on the
prepreg material that are emitted during the storage period,
however the PTE calculations
for the Winder room assume that all VOCs (less formaldehyde and
phenol) are emitted in
the Winder room. Any emissions of VOCs (not including
formaldehyde and phenol) from
the product storing or Panel Press would result in a decrease in
the PTE from the Winder
room. Zodiac adds acetone to the low-VOC resins to maintain the
desired resin viscosity
and solvent is added to the high-VOC resins. Zodiac is proposing
to limit the VOC
emissions from the Winder processes to less than 22
tons/year.
Panel Press. Once the layered sheets (prepreg plies) produced by
the winders have reached
the desired specification they can be applied to a core material
and processed in the Panel
Press. The panels that are processed in the Panel Press can have
up to 8 total plies of
Winder or Treater prepreg material placed on the top and/or
bottom of the core and then
loaded into the Panel Press. The Panel Press can process up to
80 plies on 10 panels during
one cycle which takes a minimum of an hour to complete. During
the cycle the Panel Press
applies pressure and heat to adhere the prepreg to the panels to
create the final cured
product. Zodiac is proposing a limit on the amount of Winder and
Treater prepreg plies that
will be processed through the Panel Press to comply with the
acceptable source impact
levels (ASIL).
Supporting Processes. Supporting processes at Zodiac include
solvent cleaning, a core
saw, cleaning booth, and measuring table. The PTE calculation
methodology for all of these
processes were based on calculating an actual usage rate and
applying a safety factor.
The only combustion source at the Zodiac facility is the thermal
oxidizer which burns
propane fuel and controls the emissions from the treater
process. The combustion emissions
for the unit were calculated using the burner size and AP-42
emission factors.
ECY 070-410 (Rev. 1/2013) Page 5 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
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Notice of Construction Application
B. Projected construction start and completion dates.
The Zodiac Aerospace facility in Newport, Washington is
currently operating and no
construction is taking place as part of this permitting
action.
C. Operating schedule and production rates.
The current operating schedule of the facility is 24 hours/day
for Monday through Friday
and 12 hours/day on Saturday and Sunday.
D. List of all major process equipment with manufacturer and
maximum rated
capacity.
The following table includes the major process equipment for the
Zodiac Aerospace facility.
Table D.2: Treater Process Emission Unit
Emission
Unit ID
No.
Emission Unit
Description Make Model
Fan
Size
(scfm)
Rated
Capacity
(lbs/hr)
Amount
(pounds)
Associated
Stack(s)
EU001 Mixing Tote Custom Varies 3,143
Vented inside
room
EU002 Mixing Tote Custom Varies 3,143
EU003 Mixing Vat Custom Varies 5,000
EU004 Mixing Barrel Custom Varies 1,320
EU005 Mixing Barrel Custom Varies 1,320
EU006 Mixing Barrel Custom Varies 1,320
EU007 Mixing Barrel Custom Varies 1,320
Emission
Unit ID
No.
Emission Unit
Description
Make Model Fan
Size
(scfm)
Rated
Capacity
(tons/hr)
Associated
Stack(s)
EU008 Powder Weighing Custom Custom 1.40 Vented inside
room EU009 Powder Adding Custom Custom 1.40
Emission
Unit ID
No.
Emission Unit
Description Make Model
Fan
Size
(scfm)
Rated
Capacity
(sq.ft./hr)
Associated
Stack(s)
EU010
Treater: Resin
Application and
Curing
Custom Custom ~2000 6,100
Vented to
Thermal
Oxidizer
ECY 070-410 (Rev. 1/2013) Page 6 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
-
Notice of Construction Application Emission
Unit ID
No.
Emission Unit
Description Make Model
Fan
Size
(acfm)
Rated
Capacity
(sq.m./hr)
Associated
Stack(s)
EU011 Winder #1 McClean
Anderson Custom
5,080
35.7
SV004
EU012 Winder #2 McClean
Anderson Custom 35.7
EU013 Winder #3 McClean
Anderson Custom 35.7
EU014 Winder #4 McClean
Anderson Custom 35.7
EU015 Winder #5 McClean
Anderson Custom 35.7
Emission
Unit ID
No.
Emission Unit
Description Make Model
Fan
Size
(acfm)
Rated
Capacity
(plies/hr)
Associated
Stack(s)
EU016 Panel Press Fjeliman Custom 10,000 80 SV005
Emission
Unit ID
No.
Emission Unit
Description Make Model
Fan
Size
(scfm)
Rated
Capacity
(MMBtu/hr)
Associated
Stack(s)
EU022 Thermal Oxidizer Catalytic
Products
Quadrant
SR-3000 3,000 3.5 SV008
E. Process flow diagram with all emission points identified.
The process flow diagram is located in Appendix H.
F. Plan view site map.
The plan view site map is located in Appendix H.
G. Manufacturer specification sheets for major process equipment
components
All major process equipment components except for the thermal
oxidizer were custom-made for
Zodiac Aerospace therefore manufacturer’s specification sheets
are not available.
H. Manufacturer specification sheets for pollution control
equipment.
The specification sheets for the thermal oxidizer can be found
in Appendix K.
I. Fuel specifications, including type, consumption (per hour
& per year) and percent sulfur.
ECY 070-410 (Rev. 1/2013) Page 7 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
-
Notice of Construction Application The only fuel burning
stationary source at the facility is the thermal oxidizer. The
thermal oxidizer
combusts propane and the thermal oxidizer manufacturer has
indicated that maximum propane
consumption of propane is 1,500 cubic feet per hour. Actual
propane consumption for 2016 can be
found in the actual emission calculations in Appendix G.
ECY 070-410 (Rev. 1/2013) Page 8 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
-
______________________________________________
Notice of Construction Application IV. State Environmental
Policy Act (SEPA) Compliance
Check the appropriate box below.
SEPA review is complete:
Include a copy of the final SEPA checklist and SEPA
determination (e.g., DNS, MDNS,
EIS) with your application.
SEPA review has not been conducted:
If review will be conducted by another agency, list the agency.
You must
provide a copy of the final SEPA checklist and SEPA
determination before
Ecology will issue your permit.
Agency Reviewing SEPA:
If the review will be conducted by Ecology, fill out a SEPA
checklist and
submit it with your application. You can find a SEPA checklist
online at
www.ecy.wa.gov/programs/sea/sepa/docs/echecklist.doc
A copy of the SEPA checklist can be found in Appendix C.
ECY 070-410 (Rev. 1/2013) Page 9 of 17 If you need this document
in a format for the visually impaired, call the Air Quality Program
at 360-407-6800. Persons with hearing loss can call 711 for
Washington Relay Service. Persons with a speech disability can call
877-833-6341.
http://www.ecy.wa.gov/programs/sea/sepa/docs/echecklist.doc
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Notice of Construction Application
V. Emissions Estimations of Criteria Pollutants
Does your project generate criteria air pollutant emissions? Yes
No
If yes, please provide the following information regarding your
criteria emissions in your
application.
The names of the criteria air pollutants emitted (i.e., NOx,
SO2, CO, PM2.5, PM10, TSP, VOC, and
Pb)
Zodiac currently emits NOx, SO2, CO, PM2.5, PM10, TSP, and
VOCs.
Potential emissions of criteria air pollutants in tons per hour,
tons per day, and tons per year
(include calculations)
The potential emission calculations can be found in Appendix F.
Zodiac is proposing the
following limits to be incorporated into the permit.
Emission Limits
Facility Wide Criteria Pollutants limited to
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Notice of Construction Application
If there will be any fugitive criteria pollutant emissions,
clearly identify the pollutant and
quantity
The facility does not have any fugitive emissions that are
generated outdoors, however there are
some processes that vent PM and VOC emissions fugitively within
the building. The emissions that
are vented fugitively within the building can be found in
Appendix F.
ECY 070-410 (Rev. 1/2013) Page 11 of 17 If you need this
document in a format for the visually impaired, call the Air
Quality Program at 360-407-6800. Persons with hearing loss can call
711 for Washington Relay Service. Persons with a speech disability
can call 877-833-6341.
-
Notice of Construction Application VI. Emissions Estimations of
Toxic Air Pollutants
Does your project generate toxic air pollutant emissions? Yes
No
If yes, please provide the following information regarding your
toxic air pollutant emissions in your
application.
The names of the toxic air pollutants emitted (specified in WAC
173-460-1501)
The specific toxic air pollutants that are emissions can be
found in the potential to emit
calculations in Appendix F.
Potential emissions of toxic air pollutants in pounds per hour,
pounds per day, and pounds per
year (include calculations)
The emission rates of specific toxic air pollutants that are
emitted at the facility can be found
in the potential emission calculations in Appendix F.
If there will be any fugitive toxic air pollutant emissions,
clearly identify the pollutant and
quantity
The facility does not have any fugitive emissions that are
generated outdoors, however the
facility does have some sources of emissions that will emit
toxic air pollutants fugitively within
the building.
1 http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150
ECY 070-410 (Rev. 1/2013) Page 12 of 17 If you need this
document in a format for the visually impaired, call the Air
Quality Program at 360-407-6800. Persons with hearing loss can call
711 for Washington Relay Service. Persons with a speech disability
can call 877-833-6341.
http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150
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Notice of Construction Application VII. Emission Standard
Compliance
Provide a list of all applicable new source performance
standards, national emission standards
for hazardous air pollutants, national emission standards for
hazardous air pollutants for source
categories, and emission standards adopted under Chapter 70.94
RCW.
Does your project comply with all applicable standards
identified? Yes No
New Source Performance Standards
The facility manufactures resin and epoxy impregnated
fiberglass/graphite products, primarily for
the aerospace industry. The New Source Performance Standards
(NSPS) that were reviewed include
Subpart HHH for Synthetic Fiber Production Facilities and
Subpart VVV for Polymeric Coating of
Supporting Substrates Facilities. The other NSPS do not appear
to be applicable to the operations.
It was determined that Subpart HHH was not applicable because an
affected facility is one that uses
a spinning process to produce synthetic fibers.
However it was determined that Subpart VVV does apply to the
facility. Since the facility
formulates resins that contain more than 130 Mg of VOCs and
there is no concurrent construction of
a control device, the facility is required to install, operate,
and maintain a cover on each piece of
affected equipment. Since the facility uses resins for coating
operations that contain less than 95 Mg
of VOCs the facility is required to monitor VOC use.
National Emission Standards for Hazardous Air Pollutants (40 CFR
61)
The operations at the facility do not include any of the
emission unit types that are listed in the
regulation.
National Emission Standards for Hazardous Air Pollutants (40 CFR
63)
The facility is not subject to any of the regulations written
for major source categories as the facility
is proposing synthetic minor limits to remain below the major
source threshold for hazardous air
pollutants (HAPs). A review of the area source categories did
not result in any regulations that
would appear to apply to the facility.
Emission standards adopted under Chapter 70.94 RCW
The facility is subject to the general standards of WAC
173-400-040 for visible emissions, particle
fallout, odors, emissions detrimental to persons or property,
sulfur dioxide, concealment and
masking, and fugitive dust. The thermal oxidizer is subject to
the emission standards included in
WAC 173-400-050(1) and (3). The process operations are also
subject to the particulate matter
emission requirements in WAC 173-400-060 and the federal HAP
regulations referenced in WAC
173-400-075.
This source is required to register with Ecology as a Plastics
and fiberglass product fabrication
facility (WAC 173-400-100(ff)). The facility is subject to New
Source Review of minor sources in a
limited way under WAC 173-400-111(8)(vi) for changes to permit
conditions. This section states
ECY 070-410 (Rev. 1/2013) Page 13 of 17 If you need this
document in a format for the visually impaired, call the Air
Quality Program at 360-407-6800. Persons with hearing loss can call
711 for Washington Relay Service. Persons with a speech disability
can call 877-833-6341.
-
Notice of Construction Application that “The revised order will
continue to require BACT, as defined at the time of the
original
approval. . .” Further the rule specifically states that the
revised order must meet “the requirements
of WAC 173-400-111, 173-400-112, 173-400-113, 173-400-720,
173-400-830, and 173-460-040, as
applicable”.
The facility is proposing synthetic minor limits in this
application that will allow the facility to
remain below major source thresholds for criteria pollutants and
HAPs.
VIII. Best Available Control Technology
Provide a complete evaluation of Best Available Control
Technology (BACT) for your
proposal.
As requested by Ecology, a Best Available Control Technology
(BACT) analysis has been
prepared for the emissions from the Winder processes and can be
found in Appendix DE.
IX. Ambient Air Impacts Analyses
Please provide the following:
Ambient air impacts analyses for Criteria Air Pollutants
(including fugitive emissions)
Zodiac had submitted draft PTE calculations to Ecology prior to
the stack testing of the panel
press and Ecology did not request a criteria pollutant Ambient
Air Impacts Analyses.
Ambient air impacts analyses for Toxic Air Pollutants (including
fugitive emissions)
Zodiac had submitted draft PTE calculations to Ecology prior to
the stack testing of the panel
press and Ecology indicated that they wanted the NOC application
to include an ambient air
toxics analyses for Toxic Air Pollutants. A copy of the ambient
air impacts analyses can be
found in Appendix E.
Discharge point data for each point included in air impacts
analyses (include only if modeling is
required)
Exhaust height
Exhaust inside dimensions (ex. diameter or length and width)
Exhaust gas velocity or volumetric flow rate
Exhaust gas exit temperature
ECY 070-410 (Rev. 1/2013) Page 14 of 17 If you need this
document in a format for the visually impaired, call the Air
Quality Program at 360-407-6800. Persons with hearing loss can call
711 for Washington Relay Service. Persons with a speech disability
can call 877-833-6341.
-
Notice of Construction Application The volumetric flow rate
Description of the discharges (i.e., vertically or horizontally)
and whether there are any
obstructions (ex., raincap)
Identification of the emission unit(s) discharging from the
point
The distance from the stack to the nearest property line
Emission unit building height, width, and length
Height of tallest building on-site or in the vicinity and the
nearest distance of that building to the
exhaust
Whether the facility is in an urban or rural location
Specific details on the exhaust parameters can be found in the
ambient air impacts analysis
located in Appendix E.
Does your project cause or contribute to a violation of any
ambient air quality standard
or acceptable source impact level? Yes No
ECY 070-410 (Rev. 1/2013) Page 15 of 17 If you need this
document in a format for the visually impaired, call the Air
Quality Program at 360-407-6800. Persons with hearing loss can call
711 for Washington Relay Service. Persons with a speech disability
can call 877-833-6341.
-
Notice of Construction Application
Appendix A – Figures
Figure III.1 Process Flow Diagram
Thermal
Oxidizer
(EU022)
Exhaust to
atmosphere
(SV008)
Winders
(EU011-EU015)
Panels Press
(EU017)
Exhaust to
atmosphere (SV004)
Exhaust to atmosphere (SV005)
Treater
(EU010)
Formulations
(EU001-EU009)
Raw Materials
Finished
Panels
Exhaust within room
(Fugitive)
Resin
Glass Product
Resin
Fiber Core
ECY 070-410 (Rev. 1/2013) Page 16 of 17 If you need this
document in a format for the visually impaired, call the Air
Quality Program at 360-407-6800. Persons with hearing loss can call
711 for Washington Relay Service. Persons with a speech disability
can call 877-833-6341.
-
Notice of Construction Application
Figure III.2 Site Plan View
ECY 070-410 (Rev. 1/2013) Page 17 of 17 If you need this
document in a format for the visually impaired, call the Air
Quality Program at 360-407-6800. Persons with hearing loss can call
711 for Washington Relay Service. Persons with a speech disability
can call 877-833-6341.
-
APPENDIX C NOTICE OF CONSTRUCTION APPLICATION
TECHNICAL INFORMATION
SECTION IV – STATE ENVIRONMENTAL POLICY ACT (SEPA) CHECKLIST
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Part 2: Technical Information
IV. State Environmental Policy Act (SEPA) Compliance
WAC 197-11-960 Environmental checklist.
ENVIRONMENTAL CHECKLIST
Purpose of checklist:
The State Environmental Policy Act (SEPA), chapter 43.21C RCW,
requires all governmental agencies to consider the
environmental impacts of a proposal before making decisions. An
environmental impact statement (EIS) must be prepared for
all proposals with probable significant adverse impacts on the
quality of the environment. The purpose of this checklist is to
provide information to help you and the agency identify impacts
from your proposal (and to reduce or avoid impacts from the
proposal, if it can be done) and to help the agency decide
whether an EIS is required.
Instructions for applicants:
This environmental checklist asks you to describe some basic
information about your proposal. Governmental
agencies use this checklist to determine whether the
environmental impacts of your proposal are significant,
requiring
preparation of an EIS. Answer the questions briefly, with the
most precise information known, or give the best description
you
can.
You must answer each question accurately and carefully, to the
best of your knowledge. In most cases, you should be
able to answer the questions from your own observations or
project plans without the need to hire experts. If you really do
not
know the answer, or if a question does not apply to your
proposal, write "do not know" or "does not apply." Complete
answers
to the questions now may avoid unnecessary delays later.
Some questions ask about governmental regulations, such as
zoning, shoreline, and landmark designations. Answer
these questions if you can. If you have problems, the
governmental agencies can assist you.
The checklist questions apply to all parts of your proposal,
even if you plan to do them over a period of time or on
different parcels of land. Attach any additional information
that will help describe your proposal or its environmental
effects.
The agency to which you submit this checklist may ask you to
explain your answers or provide additional information
reasonably related to determining if there may be significant
adverse impact.
Use of checklist for nonproject proposals:
Complete this checklist for nonproject proposals, even though
questions may be answered "does not apply." IN
ADDITION, complete the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS
(part D).
For nonproject actions, the references in the checklist to the
words "project," "applicant," and "property or site" should
be read as "proposal," "proposer," and "affected geographic
area," respectively.
A. BACKGROUND
1. Name of proposed project, if applicable: Notice of
Construction Application
2. Name of applicant: Zodiac Cabin and Structures Support, LLC
dba Engineered Materials
3. Address and phone number of applicant and contact person:
Facililty:Mark Harper HQ: Jennifer Shull
509-447-4122 360-653-2600
501 N. Newport Ave 12806 State Ave
Newport, WA 99156 Marysville WA 98271
4. Date checklist prepared: 2/19/2017
5. Agency requesting checklist: Washington Dept. of Ecology
6. Proposed timing or schedule (including phasing, if
applicable): Upon issuance of permit
7. Do you have any plans for future additions, expansion, or
further activity related to or connected with this proposal? If
yes,
explain.
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Zodiac Aerospace, Newport plant 2 of 12
There are no current plans for facility expansion.
8. List any environmental information you know about that has
been prepared, or will be prepared, directly related to this
proposal.
Stack testing has been performed at the request of Ecology on
the exhaust of the oxidizer and the Winder room stacks.
Additional stack testing has recently been performed on the
exhaust stacks associated with the panel press operations.
Potential to emit calculations, actual emission calculations, a
Best Available Control Technology (BACT) analysis, and
an Ambient Air Impacts Analyses for Toxic Air Pollutants are
included in the Notice of Construction application.
9. Do you know whether applications are pending for governmental
approvals of other proposals directly affecting the property
covered by your proposal? If yes, explain.
There are no pending permits
10. List any government approvals or permits that will be needed
for your proposal, if known.
N/A
11. Give brief, complete description of your proposal, including
the proposed uses and the size of the project and site. There
are
several questions later in this checklist that ask you to
describe certain aspects of your proposal. You do not need to
repeat those
answers on this page. (Lead agencies may modify this form to
include additional specific information on project
description.)
The Zodiac Aerospace facility located in Newport, Washington is
an existing facility that specializes in the manufacture
of composites used for structural and cabin components in the
aerospace industry. For a detailed description of the
operations see Section III of the Notice Of Construction (NOC)
application.
12. Location of the proposal. Give sufficient information for a
person to understand the precise location of your proposed
project, including a street address, if any, and section,
township, and range, if known. If a proposal would occur over a
range of
area, provide the range or boundaries of the site(s). Provide a
legal description, site plan, vicinity map, and topographic map,
if
reasonably available. While you should submit any plans required
by the agency, you are not required to duplicate maps or
detailed plans submitted with any permit applications related to
this checklist.
This facility is located at 501 N. Newport Ave, Newport, WA
99156
The legal description of the facility is Lot 3 Government Block;
Parcel 2, Section 18, Township 31N, Range 46E WM
See the attached figure showing the location of the Zodiac
facility. Additional figures can be found in Appendix H of the
NOC application.
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Zodiac Aerospace, Newport plant location
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B. ENVIRONMENTAL ELEMENTS
1. Earth
a. General description of the site (circle one): Flat, rolling,
hilly, steep slopes, mountainous, other . . . . . .
The site is generally flat however there is some sloping on the
east side of the property. See figure on
page 3.
b. What is the steepest slope on the site (approximate percent
slope)?
The site is basically flat in the area of the existing building.
However outside of the building and
parking area there is some sloping on the east side of the
property. No earthwork will be performed as
part of this project.
b. What general types of soils are found on the site (for
example, clay, sand, gravel, peat, muck)? If you know the
classification of agricultural soils, specify them and note any
prime farmland.
Not Applicable – this project will not involve construction
d. Are there surface indications or history of unstable soils in
the immediate vicinity? If so, describe.
No
e. Describe the purpose, type, and approximate quantities of any
filling or grading proposed. Indicate source of fill.
Not Applicable – this project will not involve construction
f. Could erosion occur as a result of clearing, construction, or
use? If so, generally describe.
Not Applicable – this project will not involve construction
g. About what percent of the site will be covered with
impervious surfaces after project
construction (for example, asphalt or buildings)?
Not Applicable – this project will not involve construction
h. Proposed measures to reduce or control erosion, or other
impacts to the earth, if any:
Not Applicable – this project will not involve construction
2. Air
a. What types of emissions to the air would result from the
proposal (i.e., dust, automobile, odors, industrial wood smoke)
during construction and when the project is completed? If
any, generally describe and give approximate quantities if
known.
There is no construction associated with this project so there
will not be any air emissions associated with construction
activities.
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Zodiac is an existing manufacturing facility located on the site
which does have air
emissions. The facility reported the following actual emissions
in 2016.
PM10: 0.433 tons SO2: 0.065 tons NOx: 0.566 tons VOC: 19.403
tons CO: 0.326 tons CO2e: 556.056 tons Total HAPs: 3.329 tons
b. Are there any off-site sources of emissions or odor that may
affect your proposal? If so, generally describe.
No
c. Proposed measures to reduce or control emissions or other
impacts to air, if any:
The facility has an existing thermal oxidizer that controls the
emissions from the Treater process.
3. Water
a. Surface:
1) Is there any surface water body on or in the immediate
vicinity of the site (including year-round and seasonal streams,
saltwater, lakes, ponds, wetlands)? If yes, describe type and
provide names. If appropriate, state what stream or river it flows
into.
The Pend Oreille River is near the property however it is
located several hundred yards east of the manufacturing building
(see map on page 3). Some surface water from the property may drain
into the river.
2) Will the project require any work over, in, or adjacent to
(within 200 feet) the described waters? If yes, please describe and
attach available plans.
No
3) Estimate the amount of fill and dredge material that would be
placed in or removed from surface water or wetlands and indicate
the area of the site that would be affected. Indicate the source of
fill material.
None
4) Will the proposal require surface water withdrawals or
diversions? Give general description, purpose, and approximate
quantities if known.
No
5) Does the proposal lie within a 100-year floodplain? If so,
note location on the site plan.
No
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6) Does the proposal involve any discharges of waste materials
to surface waters? If so, describe the type of waste and
anticipated volume of discharge.
No.
b. Ground:
1) Will ground water be withdrawn, or will water be discharged
to ground water? Give general description, purpose, and approximate
quantities if known.
No
2) Describe waste material that will be discharged into the
ground from septic tanks or other sources, if any (for example:
Domestic sewage; industrial, containing the following chemicals. .
. ; agricultural; etc.). Describe the general size of the system,
the number of such systems, the number of houses to be served (if
applicable), or the number of animals or humans the system(s) are
expected to serve.
None.
c. Water runoff (including stormwater):
1) Describe the source of runoff (including storm water) and
method of collection and disposal, if any (include quantities, if
known). Where will this water flow?
Will this water flow into other waters? If so, describe.
Runoff from grounds and parking lots flows into the municipal
stormwater system.
2) Could waste materials enter ground or surface waters? If so,
generally describe.
Only in the event of a transportation accident. All waste
chemicals are shipped out by truck under
manifest. Cleanup from such an event would be carried out under
standard WashDOT procedures.
d. Proposed measures to reduce or control surface, ground, and
runoff water impacts, if any:
Not applicable
4. Plants
a. Check or circle types of vegetation found on the site:
deciduous tree: alder, maple, aspen, other evergreen tree: fir,
cedar, pine, other shrubs grass
pasture
crop or grain
wet soil plants: cattail, buttercup, bullrush, skunk cabbage,
other
water plants: water lily, eelgrass, milfoil, other
other types of vegetation
b. What kind and amount of vegetation will be removed or
altered?
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None.
c. List threatened or endangered species of vegetation known to
be on or near the site.
None.
d. Proposed landscaping, use of native plants, or other measures
to preserve or enhance vegetation on the site, if any:
Not applicable
5. Animals
a. Circle any birds and animals which have been observed on or
near the site or are known to be on or near the site:
birds: hawk, heron, eagle, songbirds, other: Hawk, eagle, water
fowl on river
mammals: deer, bear, elk, beaver, other: Deer, muskrats, opossum
and voles
fish: bass, salmon, trout, herring, shellfish, other: Trout,
Bass in Pend Oreille River
b. List any threatened or endangered species known to be on or
near the site.
Wolves are under federal protection and have been reported in
Idaho. Wolves have not been seen on or
near the site.
c. Is the site part of a migration route? If so, explain.
No
d. Proposed measures to preserve or enhance wildlife, if
any:
Not applicable
6. Energy and natural resources
a. What kinds of energy (electric, natural gas, oil, wood stove,
solar) will be used to meet the completed project's energy needs?
Describe whether it will be used for heating,
manufacturing, etc.
Electricity from the local utility has been used for general
building heating/cooling.
b. Would your project affect the potential use of solar energy
by adjacent properties? If so, generally describe.
No.
c. What kinds of energy conservation features are included in
the plans of this proposal? List other proposed measures to reduce
or control energy impacts, if any:
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Zodiac has been careful to not propose the use of any equipment
that would consume additional energy.
7. Environmental health
a. Are there any environmental health hazards, including
exposure to toxic chemicals, risk of fire and explosion, spill, or
hazardous waste, that could occur as a result of this proposal?
If so, describe.
Manufacture of fiberglass/graphite sheets using epoxies and
resins involves the use of alcohol-based solvents and acetone which
are flammable which can present a fire and explosion risk. These
chemicals do evaporate in the process and can present a potential
inhalation hazard. Various toxic chemicals in the epoxies and
resins evaporate during the manufacturing process. These processes
also result in the generation of hazardous waste in the form of
spent alcohol related to laboratory and cleaning processes.
Industrial hygiene monitoring has found that worker exposure levels
are well below
any “action level”. All hazardous wastes are shipped offsite and
manifested as required by law and regulations.
1) Describe special emergency services that might be
required.
Arrangements have previously been made with the local fire
department. No new services will be required.
2) Proposed measures to reduce or control environmental health
hazards, if any:
The facility has an Illness and Accident Prevention Program
detailing the environmental health procedures and personal
protective equipment necessary to minimize occupational exposures.
Skilled professionals are on staff to ensure these procedures are
followed. Engineering controls are also used to reduce contaminant
airborne concentrations.
b. Noise
1) What types of noise exist in the area which may affect your
project (for example: traffic, equipment, operation, other)?
None.
2) What types and levels of noise would be created by or
associated with the project on a short-term or a long-term basis
(for example: traffic, construction, operation, other)? Indi-
cate what hours noise would come from the site.
None.
3) Proposed measures to reduce or control noise impacts, if
any:
There are no noise impacts that extend beyond the property.
Inside the building, PPE is required in certain
areas to limit occupational noise exposure.
8. Land and shoreline use
a. What is the current use of the site and adjacent
properties?
Zodiac operates an existing manufacturing facility on the site.
Adjacent properties to the site are
primarily commercial or vacant land.
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b. Has the site been used for agriculture? If so, describe.
Not to Zodiac’s knowledge.
c. Describe any structures on the site.
The existing structure is an approximately 70,000 sq. foot
concrete tilt up.
d. Will any structures be demolished? If so, what?
No.
e. What is the current zoning classification of the site?
Industrial
f. What is the current comprehensive plan designation of the
site?
Industrial
g. If applicable, what is the current shoreline master program
designation of the site?
Not applicable.
h. Has any part of the site been classified as an
"environmentally sensitive" area? If so, specify.
No.
i. Approximately how many people would reside or work in the
completed project?
Approximately 95 employees currently work at the site. No new
employees would be added as a direct result of this proposal.
j. Approximately how many people would the completed project
displace?
None.
k. Proposed measures to avoid or reduce displacement impacts, if
any:
Not applicable
l. Proposed measures to ensure the proposal is compatible with
existing and projected land
uses and plans, if any:
There are no planned changes to the existing property.
9. Housing
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a. Approximately how many units would be provided, if any?
Indicate whether high, mid-dle, or low-income housing.
None.
b. Approximately how many units, if any, would be eliminated?
Indicate whether high, middle, or low-income housing.
None.
c. Proposed measures to reduce or control housing impacts, if
any:
None.
10. Aesthetics
a. What is the tallest height of any proposed structure(s), not
including antennas; what is the principal exterior building
material(s) proposed?
There are no new structures planned for the existing
property.
b. What views in the immediate vicinity would be altered or
obstructed?
None.
c. Proposed measures to reduce or control aesthetic impacts, if
any:
Not applicable
11. Light and glare
a. What type of light or glare will the proposal produce? What
time of day would it mainly occur?
There are no lighting changes planned for the property.
b. Could light or glare from the finished project be a safety
hazard or interfere with views?
No.
c. What existing off-site sources of light or glare may affect
your proposal?
None.
d. Proposed measures to reduce or control light and glare
impacts, if any:
Not applicable.
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12. Recreation
a. What designated and informal recreational opportunities are
in the immediate vicinity?
There is a company-owned riverside park open to the public near
the site.
b. Would the proposed project displace any existing recreational
uses? If so, describe.
No.
c. Proposed measures to reduce or control impacts on recreation,
including recreation op-portunities to be provided by the project
or applicant, if any:
Not applicable.
13. Historic and cultural preservation
a. Are there any places or objects listed on, or proposed for,
national, state, or local preser-vation registers known to be on or
next to the site? If so, generally describe.
None known
b. Generally describe any landmarks or evidence of historic,
archaeological, scientific, or cultural importance known to be on
or next to the site.
None known
c. Proposed measures to reduce or control impacts, if any:
Not applicable.
14. Transportation
a. Identify public streets and highways serving the site, and
describe proposed access to the existing street system. Show on
site plans, if any.
No new access required.
b. Is site currently served by public transit? If not, what is
the approximate distance to the nearest transit stop?
No public transit nearby
c. How many parking spaces would the completed project have? How
many would the project eliminate?
There will be no changes to the existing parking lot.
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d. Will the proposal require any new roads or streets, or
improvements to existing roads or streets, not including driveways?
If so, generally describe (indicate whether public or
private).
No
e. Will the project use (or occur in the immediate vicinity of)
water, rail, or air transporta-tion? If so, generally describe.
No
f. How many vehicular trips per day would be generated by the
completed project? If known, indicate when peak volumes would
occur.
No impact on daily vehicle traffic
g. Proposed measures to reduce or control transportation
impacts, if any:
Not applicable
15. Public services
a. Would the project result in an increased need for public
services (for example: fire pro-tection, police protection, health
care, schools, other)? If so, generally describe.
No.
b. Proposed measures to reduce or control direct impacts on
public services, if any.
Not applicable
16. Utilities
a. Circle utilities currently available at the site:
electricity, natural gas, water, refuse serv-ice, telephone,
sanitary sewer, septic system, other.
Electricity, water, refuse service, telephone, cell phone and
sanitary sewer are currently used.
b. Describe the utilities that are proposed for the project, the
utility providing the service, and the general construction
activities on the site or in the immediate vicinity which might
be needed.
No new utilities are required.
C. SIGNATURE
The above answers are true and complete to the best of my
knowledge. I understand that the lead
agency is relying on them to make its decision.
Signature: _____________________________
Name, title: Mike Pound, Vice President
Date Submitted __________________________
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APPENDIX D NOTICE OF CONSTRUCTION APPLICATION
TECHNICAL INFORMATION
SECTION VIII – BEST AVAILABLE CONTROL TECHNOLOGY (BACT)
ANALYSIS
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VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington
February 19, 2017 ■ Terracon Project No. MP157289C
VOC BACT Analysis –Winder Operations Zodiac Aerospace –
Engineered Materials
Newport, Washington Terracon Project No.
February 19, 2017
INTRODUCTION
Zodiac Aerospace – Engineered Materials (Zodiac) in Newport,
Washington had submitted a Best Available Control Technology (BACT)
analysis for the VOC emissions from the facility
previously and it was determined that it would be cost effective
to control the winder processes.
However based on revisions to the potential to emit calculations
and the recent stack testing
that was requested by the Washington Department of Ecology
(Ecology), the BACT analysis
has been updated to reflect these changes.
EPA’s steps for a top-down BACT analysis for the winder
operations are detailed below.
1. Identify all control technologies. 2. Eliminate technically
infeasible options. 3. Rank remaining control technologies by
effectiveness. 4. Evaluate most effective controls and document
results. 5. Select BACT.
The potential VOC emissions from winder operations have been
updated based on a mass
balance approach and the calculations were provided to Ecology
on April 1, 2015. The potential
to emit (PTE) calculations have been calculated based on all 5
winders using high VOC resins,
however the facility only uses 3 of the winders with high VOC
resins and the other 2 winders
produce product using low VOC resins. The stack testing that was
performed on the Winder
room exhaust stacks showed that the phenol and formaldehyde
emissions were below detection
limits which supported Georgia-Pacific’s believe that the phenol
and formaldehyde would not be
emitted at ambient temperatures. The VOC emissions from the
stack testing were in
reasonable correlation with the expected emissions using a mass
balance methodology. Zodiac
is proposing to limit the VOC emissions from the winder
operations to 22 tons/year.
The VOC BACT analysis has been completed and is documented in
this report. This analysis
concludes the following:
It is proposed that add-on controls are not required for the
winder operations because all
of the control technology is either technically infeasible or
not economically feasible
based on the proposed emission limit for the winder
operations.
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VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington
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A thorough review of the RACT/BACT/LAER Clearinghouse (RBLC) was
performed to try and
match a process contained in the RBLC to the winder processes at
Zodiac. The following types
of sources were searched on the RBLC for previous VOC BACT
determinations.
41.001 Aerospace Surface Coating – See attached 41.017 Polymeric
Coating of Fabrics – No results 41.999 Other Surface
Coating/Printing/Graphics Arts Sources – See attached
The search results for these three source categories did not
produce a similar process to the
winder process at the Zodiac facility. A copy of the search
results from the RBLC database can
be found in Appendix B of this BACT analysis.
Below is the top-down approach for identifying BACT for VOCs
from the winder operations at
the facility.
STEP 1 – IDENTIFY CONTROL TECHNOLOGIES
Zodiac has identified the following VOC control technologies to
potentially consider as BACT for
the primary processes at the facility.
Oxidation
o Regenerative Thermal Oxidation o Recuperative Thermal
Oxidation o Thermal Oxidation o Catalytic Oxidation
Condensation
Carbon Adsorption
Biofilter
STEP 2 – ELIMINATE TECHNICALLY INFEASIBLE OPTIONS
2.1 Oxidation
Oxidation refers to the combustion of organic compounds at a
sufficiently high temperature and
adequate residence time. Oxidation systems are either thermal or
catalytic. These categories
can be further divided based on the type of heat recovery used.
If a shell-and-tube or plate-type
heat exchanger is used, then the system is generally classified
as recuperative. If a high
efficiency bed of ceramic material is used, then the system is
generally classified as
regenerative. With all types of systems, most hydrocarbons are
oxidized to carbon dioxide and
water. Capital and operating cost estimates for regenerative
thermal oxidation (Appendix C),
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VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington
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recuperative thermal oxidation (Appendix D), and catalytic
oxidation (Appendix E) were
prepared for the BACT analysis.
A 10-year life of the oxidizers was used in the calculations for
converting the capital cost to an
annualized cost.
2.2 Condensation
Condensation systems utilize a refrigeration source to cool an
exhaust stream until the partial
pressure of the pollutant in the gas stream equals its vapor
pressure as a pure substance. This
allows the condenser to convert VOCs from the gaseous phase to a
liquid phase. Any gas can
be reduced to a liquid by sufficiently lowering its temperature
and/or increasing its pressure.
Based on the stack test results, the gaseous emissions from the
winder operations are primarily
made up of acetone, ethanol, methanol, and isopropanol. Based on
a mass balance, the
maximum VOC emission rate from the winder operations is 11.86
lbs/hour. The concentration of
the VOCs in the measured exhaust stream of 4,680 scfm would be
low (approximately 500
ppmv based on the stack test results). The vapor pressures of
the individual compounds, even
at 32˚F, are too high to enable condensation at these
concentrations. Therefore, due to the relatively high volume of air
stream, low concentration of VOCs, and the variety of different
components that would be included in the exhaust stream,
condensation is not a technically
feasible method to control VOCs from the winder operations.
2.3 Carbon Adsorption
Adsorption is the process by which molecules collect on and
adhere to the surface of an
adsorbent solid (usually carbon). This adsorption is due to
physical and/or chemical forces.
Physical adsorption, the most common in this type of
application, is due to van der Waals
forces. These forces are common to all matter and result from
the motion of electrons.
Activated carbon is typically used as an adsorbent because of
its large surface area, a critical
factor in the adsorption process since the adsorption capacity
is proportional to surface area.
Activated carbon has significant surface area due to its
internal pore structure. The adsorption
capacity of carbon is proportional to the vapor pressure of the
compounds being adsorbed. Due
to the high vapor pressure of these compounds, the compounds
would be poorly adsorbed on
carbon. Also as discussed previously, the concentration of VOCs
in the exhaust stream is low.
Because of the low concentration of VOCs and the variety of
components in the exhaust
stream, it would take an infeasible amount of carbon to remove
the VOCs in the exhaust
stream. For the reasons indicated above, carbon adsorption is
not a technically feasible option
for controlling VOCs from the winder operations.
2.3 Biofiltration
Biofiltration is a pollution control technique that uses living
material to capture and biologically
degrade pollutants. Common uses include processing waste water
and microbiotic oxidation of
contaminants in air. Zodiac performed a trial with a biofilter
that resulted in poor results. The
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poor results were likely the result of the cold weather. The
size requirements of a full scale
biofiltration system make it impractical to locate the system
indoors and an outdoor system
would be subject to the cold weather in Newport, Washington. In
addition, the intermittent
operations provide a poor food supply for the organisms. Because
of these reasons it was
determined that biofiltration is not a technically feasible
option.
STEP 3 – RANK REMAINING CONTROL TECHNOLOGIES BY
EFFECTIVENESS
Oxidation control technologies are the only remaining control
technologies identified as
technically feasible. The effectiveness of each oxidation
control technology is approximately the
same and thus economic factors will drive the decision for the
BACT analysis.
STEP 4 – EVALUATE MOST EFFECTIVE CONTROLS AND DOCUMENT
RESULTS
4.1 Cost Estimate
Preliminary budget-level cost data was developed for the
installation and operation of the
control technologies listed below. Estimated oxidizer costs have
been provided by Catalytic
Products, Inc. and can be found in Appendix F of the BACT
analysis.
Regenerative Thermal Oxidation
Recuperative Thermal Oxidation
Catalytic Oxidation
These cost estimates were based on cost estimation guidance
adapted from the USEPA Office
of Air Quality Planning and Standards (OAQPS) Air Pollution
Control Cost Manual (EPA/452/B-
02-001, Sixth Edition, January 2002) and recent equipment
quotes.
The table below summarizes the cost and cost-effectiveness
estimates developed by Terracon
for the control of VOC emissions from the winder operations.
Please see Appendix C through
Appendix E for the cost estimate calculations. The estimated
costs were provided by Catalytic
Products, Inc. and have been included in Appendix F.
Control Method Total Capital
Investment
Total Annualized
Cost Cost per Ton
Regenerative Thermal Oxidizer $676,216 $244,644 $11,326
Recuperative Thermal Oxidizer $956,490 $375,299 $17,375
Responsive ■ Resourceful ■ Reliable
-
VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington
February 19, 2017 ■ Terracon Project No. MP157289C
Control Method Total Capital
Investment
Total Annualized
Cost Cost per Ton
Catalytic Oxidizer $751,101 $277,265 $12,836
STEP 5 – SELECT BACT
Based on the analysis above, oxidation control technologies are
not economically feasible and
condensation, carbon adsorption, and biofiltration control
technologies are not technically
feasible.
Zodiac has evaluated alternative resins and to produce
acceptable products for customers
Zodiac is required to use the resins that are currently in
use.
Since all of the control options are either technically or
economically infeasible and there is no
option for resin substitution, Zodiac is proposing that BACT for
the Winders to be operated
without controls.
AIR QUALITY IMPACTS
For any pollutant exceeding its PSD significant emission level
as part of a new construction, a
PSD air quality impact analysis is required to demonstrate
compliance with any applicable
ambient air quality standards established for that pollutant.
However, PSD thresholds have not
been exceeded by the PTE for the Zodiac Facility. As such, an
impacts analysis was not
performed.
Responsive ■ Resourceful ■ Reliable
-
APPENDIX A
Potential To Emit Calculations
-
Table 10: Winder Room Potential to Emit
Zodiac Aerospace Engineered Materials
Newport, WA
Emission Unit Identification No.: EU011-EU015
Emission Unit Description: Winder Process
Stack/Vent Designation No.: SV004
Control Equipment No.: N/A
Hours of Operation: 8760
No. of Winders 5
VOCs, HAPS, and TAPs Applied
Product ID (Resin ID/Fiberglass Part #) Resin ID
Fiber Core + Dried
Resin Weight1
(g/m^2)
Fiber Core
Weight1
(g/m^2)
Dried Resin
(Solids) Weight
(g/m^2)
Resin-Specific
Solids Content
(%)
Total Resin
Applied
(g/m^2)
Fiber Core +
Applied Resin
(g/m^2)
Volatiles
Applied
(lb/m^2)
VOCs Applied
(lb/m^2)
Formaldehyde
Applied2
(lb/m^2)
Methanol
Applied
(lb/m^2)
MIBK
Applied
(lbs/m^2)
Phenol
Applied2
(lb/m^2)
Total HAPs
Applied
(lb/m^2)
Isopropanol
Applied
(lb/m^2)
APG 1102/12K AR1102 219.0 140.0 79.0 50% 158.0 298.0 0.174 0.104
0.002 0.028 0.003 0.031 0.064 0.014
APG 1114/12K AR1114 219.0 140.0 79.0 50% 158.0 298.0 0.174 0.102
0.002 0.021 0.003 0.024 0.051 0.017
APG 1114/12K-300 AR1114 305.0 202.0 103.0 50% 206.0 408.0 0.227
0.133 0.002 0.027 0.005 0.032 0.066 0.023
AEG 1502/12K AR1502 252.0 150.0 102.0 50% 204.0 354.0 0.225
0.024 0.000 0.000 0.000 0.000 0.000 0.000
AEG 1510/12K AR1510 330.0 208.0 122.0 60% 203.3 411.3 0.179
0.001 0.000 0.000 0.000 0.000 0.000 0.000
AEF 1510/750 AR1510 480.0 290.0 190.0 60% 316.7 606.7 0.279
0.001 0.000 0.000 0.000 0.000 0.000 0.000
AEG1510/18K AR1510 173.0 103.0 70.0 60% 116.7 219.7 0.103 0.000
0.000 0.000 0.000 0.000 0.000 0.000
PTE From Resin Usage2
Product ID (Resin ID/Fiberglass Part #) Resin ID
Max Production
Rate Per Winder1
(m^2/hr)
Number of
Winders
Max
Production
Rate for All
Winders
(m^2/hr)
VOC
PTE3
(TPY)
Methanol PTE3
(TPY)
MIBK
PTE3
(TPY)
Total HAPs
PTE2,3,4
(TPY)
Isopropanol
PTE3
(TPY)
APG 1102/12K AR1102 30.1 5 150.5 68.89 18.37 2.30 20.67 9.18
APG 1114/12K AR1114 22.7 5 113.5 50.74 10.39 1.73 12.12 8.66
APG 1114/12K-300 AR1114 11.9 5 59.5 34.68 7.10 1.18 8.29
5.92
AEG 1502/12K AR1502 26.0 5 130.0 13.73 0.00 0.00 0.00 0.00
AEG 1510/12K AR1510 19.4 5 97.0 0.36 0.00 0.00 0.00 0.00
AEF 1510/750 AR1510 14.0 5 70.0 0.41 0.00 0.00 0.00 0.00
AEG1510/18K AR1510 35.7 5 178.5 0.38 0.00 0.00 0.00 0.00
Worst Case 68.89 18.37 2.30 20.67 9.18
PTE From Thinner Added
Product ID (Resin ID/Fiberglass Part #) Resin ID
Total Resin
Applied
(g/m^2)
Thinner
Addition Rate1,4
(% by weight)
Thinner Added
(g/m^2)
Max
Production
Rate for All
Winders
(m^2/hr)
VOC PTE
(TPY)
Methanol PTE
(TPY)
MIBK PTE
(TPY)
Total HAPs PTE
(TPY)
APG 1102/12K AR1102 158.0 2.80% 4.424 150.5 6.423 0.321 0.193
0.514
APG 1114/12K AR1114 158.0 4.90% 7.742 113.5 8.477 0.424 0.254
0.678
APG 1114/12K-300 AR1114 206.0 4.90% 10.094 59.5 5.794 0.290
0.174 0.464
Worst Case 8.477 0.424 0.254 0.678
PTE Summary
Pollutant
PTE
(tons/year)
Limited PTE5
(tons/year)
VOCs 77.363 22.0
Methanol 18.793 5.34
MIBK 2.550 0.73
Total HAPs 21.344 6.07
IPA 9.185 2.61
1 Information provided by Zodiac.
2 Georgia Pacific has indicated that the phenol and formaldehyde
will not be released in the winder process based on operating
temperatures. Previous stack testing supports this conclusion.
3 Georgia Pacific has indicated that all other VOCs in the
resins should be emitted in the Winder Room. Although small amounts
of other VOCs may remain on the prepreg, they are included in the
Winder calculations to
be conservative. 4
Acetone is added to the AR1502 and AR1510 resins, Tarsol added
to AR1102 and AR1114 resins 5
Zodiac is proposing to take a limit of 22 tons/year on VOC
emissions from the Winder Process calculated on a 12-month rolling
basis. Limited HAP emissions have been ratioed to the 22 ton/year
limit based on the PTE calculations.
-
APPENDIX B
RACT/BACT/LAER Clearinghouse Search Results
-
COMPREHENSIVE REPORTReport Date:02/19/2017
Facility Information RBLC ID: OK-0172 (final) Date
Determination Last Updated: 07/06/2016
Corporate/Company TINKER AFB LOGISTICS CTR Permit
2009-394-C(M-4)PSD Name: Number: Facility Name: MIDWEST CITY AIR
DEPOT Permit Date: 11/19/2015 (actual)
Facility Contact: COL STEPHANIE WILSON 405-734-2102
[email protected] FRS Number: 109-00090
Facility Description: Tinker AFB is a
multi-mission/multi-faceted installation that serves the U.S. Air
Force, U.S. Navy, and SIC Code: 9711 other Department of Defense
(DoD) organizations. The primary Standard Industrial Classification
(SIC) code is 9711, National Security. It is home to the Oklahoma
City Air Logistics Center (OC-ALC) and a number of associated
organizations.
Permit Type: C: Modify process at existing facility NAICS Code:
928110
Permit URL:
EPA Region: 6 COUNTRY: USA
Facility County: OKLAHOMA
Facility State: OK
Facility ZIP Code: 73145
Permit Issued By: OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
(Agency Name) MR. LEE WARDEN(Agency Contact) (405)702-4182
[email protected]
Permit Notes: The applicant requests an increase in emissions
associated with facilities needed to support the KC-46A program.
The applicant discovered discrepancies in the stripper materials
initially proposed in Permit No. 2009-394-C (M-2) PSD. As a result
the applicant is requesting a re-opening of the prior permit and
relaxation of the existing VOC emission limits from the previous
PSD permit.
Affected Boundaries: Boundary Type: Class 1 Area State:
Boundary: Distance: CLASS1 OK Wichita Mountains 100km - 50km
Facility-wide Pollutant Name: Facility-wide Emissions Increase:
Emissions: Volatile Organic Compounds (VOC) 319.0000
(Tons/Year)
Process/Pollutant Information
PROCESS CHEMICAL DEPAINTING/AIRCRAFT PAINT STRIPPING/AIRCRAFT
PARTS PAINT STRIPPING NAME: Process Type: 41.001 (Aerospace Surface
Coating)
-
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel: NA
Throughput: 0
Process Notes: Tinker AFB will perform surface coating and
depainting/stripping for the KC-46A aircraft. The chemical
strippers used to remove the residual paint from the surface of the
aircraft as well as the new paint applied to the aircraft will be
formulations that meet Aerospace Manufacturing and Rework
Facilities (Aerospace) National Emission Standards for Hazardous
Air Pollutants (NESHAP) VOC limits. No VOC controls will be
installed at the new paint hangars.
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Unspecified Pollutant Group(s): (
Volatile Organic Compounds (VOC) ) Emission Limit 1: 333.3800 TONS
YEAR Emission Limit 2: Standard Emission: Did factors, other then
air pollution technology considerations influence the BACT
decisions: Y
Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NSPS
, NESHAP , MACT Control Method: (P) 1.Low VOC vapor press. cleaning
solvents and strippers( Est. % Efficiency: Cost Effectiveness: 0
$/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified:
No Pollutant/Compliance Notes:
Facility Information RBLC ID: OK-0171 (final) Date
Determination Last Updated: 07/06/2016
Corporate/Company TINKER AFB LOGISTICS CTR Permit
2009-394-C(M-3)PSD Name: Number: Facility Name: MIDWEST CITY AIR
DEPOT Permit Date: 11/18/2015 (actual)
Facility Contact: COL STEPHANIE WILSON 405-734-2102
[email protected] FRS Number: 109-00090
-
Facility Description: Tinker AFB is a
multi-mission/multi-faceted installation that serves the U.S. Air
Force, U.S. Navy, and SIC Code: 9711 other Department of Defense
(DoD) organizations. The primary Standard Industrial Classification
(SIC) code is 9711, National Security. It is home to the Oklahoma
City Air Logistics Center (OC-ALC) and a number of associated
organizations.
Permit Type: C: Modify process at existing facility NAICS Code:
928110
Permit URL:
EPA Region: 6 COUNTRY: USA
Facility County: OKLAHOMA
Facility State: OK
Facility ZIP Code: 73145
Permit Issued By: OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
(Agency Name) MR. LEE WARDEN(Agency Contact) (405)702-4182
[email protected]
Permit Notes: The applicant discovered discrepancies in the
stripper materials initially included in Permit No. 2009-394-TVR.
This is a relaxation of VOC usage/emission limitation of chemical
depainting.
Affected Boundaries: Boundary Type: Class 1 Area State:
Boundary: Distance: CLASS1 OK Wichita Mountains 100km - 50km
Facility-wide Pollutant Name: Facility-wide Emissions Increase:
Emissions: Volatile Organic Compounds (VOC) 400.0000
(Tons/Year)
Process/Pollutant Information
PROCESS NAME: CHEMICAL DEPAINTING/AIRCRAFT PAINT
STRIPPING/AIRCRAFT PARTS PAINT STRIPPING
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel: NA
Throughput: 0
Process Notes:
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Unspecified Pollutant Group(s): (
Volatile Organic Compounds (VOC) ) Emission Limit 1: 1605.5600 TONS
YEAR Emission Limit 2: Standard Emission: Did factors, other then
air pollution technology considerations influence the BACT
decisions: Y
-
Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NSPS
, NESHAP , MACT Control Method: (P) 1.Low VOC vapor pressure
cleaning solvents and strippers ( Est. % Efficiency: Cost
Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: No Pollutant/Compliance Notes:
Facility Information RBLC ID:
Corporate/Company
WA-0347 (draft)
THE BOEING COMPANY
Date Determination Last Updated: Permit
03/14/2013 PSD-12-01
Name: Facility Name:
Facility Contact:
BOEING RENTON
MICHAEL VERHAAR (425) 965-1567 [email protected]
Number: Permit Date:
FRS Number:
02/19/2013 (actual)
Facility Description:
Permit Type:
The Boeing Renton facility is located in the city of Renton in
King County, Washington, and began operation in 1942. It occupies
339 acres, and currently manufactures parts for and assembles the
737 series airplane model. The facility is located in the south
half of Section 18, Township 23N, Range 5, Willamette Meridian. It
is bounded to the north by Lake Washington, to the south by Airport
Way, to the east by Logan Avenue, and to the west by the Renton
Airport D: Both B (Add new process to existing facility) &C
(Modify process at existing facility)
SIC Code:
NAICS Code:
3721
336411
Permit URL:
http://www.ecy.wa.gov/programs/air/psd/psd_existingpermits.html
EPA Region: 10 COUNTRY: USA
Facility County: KING
Facility State: WA
Facility ZIP Code: 98124
Permit Issued By:
Permit Notes:
WASHINGTON STATE DEPARTMENT OF ECOLOGY (ECY); AIR QUALITY
PROGRAM (Agency Name) MR. MARC CROOKS(Agency Contact) (360)407-6803
[email protected]
Affected Boundaries: Boundary Type: CLASS1 CLASS1 CLASS1
Class 1 Area State: WA WA WA
Boundary: Alpine Lakes Glacier Peak Goat Rocks
Distance: < 100 km < 100 km 100km - 50km
-
CLASS1 WA Mount Adams 100km - 50km CLASS1 WA Mount Rainier NP
< 100 km CLASS1 WA North Cascades NP 100km - 50km CLASS1 WA
Olympic NP < 100 km
INTL BORDER US/Canada Border 100km - 50km Facility-wide
Emissions:
Pollutant Name: Facility-wide Emissions Increase: Volatile
Organic Compounds (VOC) 750.0000 (Tons/Year)
Process/Pollutant Information
PROCESS NAME: Floor Activities
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel:
Throughput: 504.00 airplanes per year
Process Notes: Floor activities include but are not limited to
spar, wing, and aircraft assembly.
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Other Other Test Method: mass
ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 458.0000 TONS YEAR Emission Limit 2: Standard
Emission: Did factors, other then air pollution technology
considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
NESHAP Control Method: (P) Boeing must comply with all applicable
VOC emission standards of the National Emission Standards for
Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part
63, Subpart GG (Aerospace NESHAP), as in effect on February 19,
2013
Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost
Effectiveness: 0 $/ton Compliance Verified: Unknown
Pollutant/Compliance Notes:
-
Process/Pollutant Information
PROCESS NAME: New Vertical Wing Booth (PB5)
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel:
Throughput: 0
Process Notes:
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Other Other Test Method: mass
ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 65.0000 LB PER WING 12-MONTH ROLLING Emission
Limit 2: Standard Emission: Did factors, other then air pollution
technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD Other Applicable
Requirements:NESHAP Control Method: (P) Boeing must comply with all
applicable VOC emission standards of the National Emission
Standards for
Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part
63, Subpart GG (Aerospace NESHAP), as in effect on February 19,
2013
Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost
Effectiveness: 0 $/ton Compliance Verified: Unknown
Pollutant/Compliance Notes:
Process/Pollutant Information
PROCESS NAME: New Vertical Wing Booth (PB6)
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel:
Throughput: 0
-
Throughput: 0
Process Notes:
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Other Other Test Method: mass
ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 65.0000 LB PER WING 12-MONTH ROLLING Emission
Limit 2: Standard Emission: Did factors, other then air pollution
technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD Other Applicable
Requirements:NESHAP Control Method: (P) Boeing must comply with all
applicable VOC emission standards of the National Emission
Standards for
Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part
63, Subpart GG (Aerospace NESHAP), as in effect on February 19,
2013
Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost
Effectiveness: 0 $/ton Compliance Verified: Unknown
Pollutant/Compliance Notes:
Process/Pollutant Information
PROCESS NAME: New Vertical Wing Booth (PB7)
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel:
Throughput: 0
Process Notes:
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Other Other Test Method: mass
ballance
-
Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 65.0000 LB PER WING 12-MONTH ROLLING Emission
Limit 2: Standard Emission: Did factors, other then air pollution
technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD Other Applicable
Requirements:NESHAP Control Method: (P) Boeing must comply with all
applicable VOC emission standards of the National Emission
Standards for
Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part
63, Subpart GG (Aerospace NESHAP), as in effect on February 19,
2013
Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost
Effectiveness: 0 $/ton Compliance Verified: Unknown
Pollutant/Compliance Notes:
Process/Pollutant Information
PROCESS NAME: New Corrosion Inhibitor Compound Booth (CB1)
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel:
Throughput: 0
Process Notes:
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Other Other Test Method: mass
ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 7.7000 LB/WING 12-MONTH ROLLING Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology
considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
NESHAP
-
Other Applicable Requirements:NESHAP Control Method: (P) Boeing
must comply with all applicable VOC emission standards of the
National Emission Standards for
Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part
63, Subpart GG (Aerospace NESHAP), as in effect on February 19,
2013
Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost
Effectiveness: 0 $/ton Compliance Verified: Unknown
Pollutant/Compliance Notes:
Process/Pollutant Information
PROCESS NAME: New Corrosion Inhibitor Compound Booth (CB2)
Process Type: 41.001 (Aerospace Surface Coating)
Primary Fuel:
Throughput: 0
Process Notes:
POLLUTANT NAME: Volatile Organic Compounds (VOC)
CAS Number: VOC Test Method: Other Other Test Method: mass
ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 7.7000 LB PER WING 12-MONTH ROLLING Emission
Limit 2: Standard Emission: Did factors, other then air pollution
technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD Other Applicable
Requirements:NESHAP Control Method: (P) Boeing must comply with all
applicable VOC emission standards of the National Emission
Standards for
Aerospace Manufacturing and Rewo