notice of construction application - ecology.wa.gov€¦ · department of ecology cashiering unit ....

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

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

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

APPENDIX A NOTICE OF CONSTRUCTION APPLICATION

GENERAL INFORMATION

SECTIONS I-II

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]

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.


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)


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)


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____________________


mailto:[email protected]:[email protected]:[email protected]:[email protected]

APPENDIX B NOTICE OF CONSTRUCTION APPLICATION

TECHNICAL INFORMATION

SECTIONS III, V-VII

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.



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.



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




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


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


Notice of Construction Application Emission

Unit ID

No.

Emission Unit


Fan

Size

(acfm)

Rated

Capacity

(sq.m./hr)

Associated

Stack(s)

EU011 Winder #1 McClean

Anderson Custom

5,080

35.7

SV004


Anderson Custom 35.7







Emission

Unit ID

No.

Emission Unit


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


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.


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.


______________________________________________

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.


http://www.ecy.wa.gov/programs/sea/sepa/docs/echecklist.doc


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


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.


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


http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150

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


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


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



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



Figure III.2 Site Plan View


APPENDIX C NOTICE OF CONSTRUCTION APPLICATION


SECTION IV – STATE ENVIRONMENTAL POLICY ACT (SEPA) CHECKLIST

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 1 of 12

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.

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.

3 of 12

Zodiac Aerospace, Newport plant location


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.


f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe.


g. About what percent of the site will be covered with impervious surfaces after project

construction (for example, asphalt or buildings)?


h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any:


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.


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


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?


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:


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.


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


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.


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.


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 __________________________

APPENDIX D NOTICE OF CONSTRUCTION APPLICATION


SECTION VIII – BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS

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.

Responsive ■ Resourceful ■ Reliable


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),



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



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



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.


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


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


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:


Facility County: OKLAHOMA

Facility State: OK


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 NAME: CHEMICAL DEPAINTING/AIRCRAFT PAINT STRIPPING/AIRCRAFT PARTS PAINT STRIPPING


Primary Fuel: NA

Throughput: 0

Process Notes:


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


Facility County: KING

Facility State: WA


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 NAME: Floor Activities


Primary Fuel:

Throughput: 504.00 airplanes per year

Process Notes: Floor activities include but are not limited to spar, wing, and aircraft assembly.


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 NAME: New Vertical Wing Booth (PB5)


Primary Fuel:

Throughput: 0

Process Notes:


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






Primary Fuel:

Throughput: 0

Throughput: 0

Process Notes:









Primary Fuel:

Throughput: 0

Process Notes:


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





PROCESS NAME: New Corrosion Inhibitor Compound Booth (CB1)


Primary Fuel:

Throughput: 0

Process Notes:


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




PROCESS NAME: New Corrosion Inhibitor Compound Booth (CB2)


Primary Fuel:

Throughput: 0

Process Notes:




Aerospace Manufacturing and Rewo

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