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HomeMy WebLinkAboutBow Dipping - COM Engineering / Geo-Tech Reports - 11/20/2008 GviEG10N C NOTICE OF CONSTRUCTION FINAL DETERMINATION TO APPROVE s ORCAA Olympic Region Clean Air Agency *l0p•JEFFERSON•µ►Slla'��`\�`• Issued to: Steven Sims, Inc. Cnty: 45 Location: 0-1,i 1'W. Development Rd Srce: 202 Shelton, Washington 98584 RC: RC6 Application #: 08NOC635 File: 323 Prepared on: November 20, 2008 1. Project Description & Emissions This permitting action is granting approval to Steven Sims,Inc. (Steven Sims) to construct and operate a metal and composite materials coating facility at 151 W.Development Rd in Shelton,Washington. Steven Sims is a company that specializes in hunting products. One of the products sold by Steven Sims is the Deadzone®compound bow.The purpose of the new coating facility will be to coat the major components used to manufacture the Deadzone®bow. The Deadzone®bow consists of three main components.They are the riser(the aluminum main structure), the upper limb,and lower limb(the limbs are flexible composite structures attached to each end of the riser). It is these components that will be coated at the new facility. Upper limb Riser Lower limb Final Determination Page 1 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NCC635 Prepared January 7,2009 Steve Sims will receive the pre-manufactured,uncoated limbs and risers from vendors.They will use the equipment and facilities described in their NOC application to coat these parts prior to assembling the final product.The coating process to be used at the new coating facility is described below. Washing The aluminum bow risers and composite limbs received at the facility will require cleaning to remove residual oils and dirt before they can be successfully coated.This will be accomplished by rinsing the parts in a hot water rinse and dipping the parts in a detergent containing a mild phosphoric acid solution.The hot water rinse will be accomplished in a parts washer while the detergent"dip"will be done an open top basin or a drum. ORCAA considers the potential for air emission from washing at Steve Sims to be negligible. Spray Painting Next the components will be painted in the paint booth using a high volume low pressure (HVLP)paint gun. The paint is a colored two part base coat,and is referred to as HC Max 4 Basecoat.The paintbooth chosen by Steve Sims was originally designed to be an open face three sided spray booth;however,it will be retrofitted to be a fully enclosed booth. ORCAA calculated potential to emit(PTE) for air emission resulting from spray application of the base coat. Table 1.1 illustrates the results from this calculation. Table 1.1 Air Emissions Resulting from Spray Application of Basecoat Content Pollutant TMSDS' lassification' from PTE' PTE' SQER' SQER' Ib/yr Ib/hr Ib/yr Ib/hr Aliphatic petroleum Class B TAP, distillates VOC 10% 936.8 0.47 43748 5 Class B TAP, Meth a-am I ketone VOC 20% 1873.5 0.94 43748 5 Class B TAP, Methyl ethyl ketone VOC 20% 1873.5 0.94 43748 5 Class B TAP, n-butylacetate VOC 10% 936.8 0.47 43748 5 Class B TAP, TToluene VOC 10% 936.8 0.47 43748 5 'Bach pollutant contained in the I IC Max 4 Basecoat is classified in WAC 173-460. 2'Me amount of each compound contained in the HC Max 4 Basecoat is listed in the Material Safety Data Sheet for the coating. 3PTE(lb/yr)=Content from MSDS*Material Usage(b/yr) 4PTE(ib/hr)=Content from MSDS*Material Usage(lb/hr) 51he small quantity emission rate(SQER)for each compound is defined in WAC 173-460. Hydrographic Printing The next phase of the coating process is referred to as hydrographic printing. For this process,a piece of printed film is cut to size and laid on the surface of the water in a dip tank. Once the film base has dissolved, the camouflage film appears as an oil slick floating on the water in the dip tank.After a brief period,the item to be printed is dipped through the ink pattern laying on the surface of the water and then pulled back out again.As the part is plunged through the ink and then out again the ink coats all sides of the part. The coating is then cured.Initially the curing will take place at room temperature,and will require about a day to fully cure.Later,a dedicated curing room will be constructed in which the parts can be force cured thereby reducing the cure time of each part.The heated curing room will be an electrically heated room in which thee the inside temperature is maintained at approximately 100*F.A small fan will ventilate the curing room and will discharge to the atmosphere. Each part will be coated and cured a second time before the part is ready for the protective topcoat. Final Detertrtination Page 2 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 Table 1.2-Air Emissions Resulting from H dro ra hic Printing Content Pollutant Classification' from PTE' PTE4 SQER5 SQER5 MSDS' Ib/yr Ib/hr lb/yr lb/hr Butyl Cellosolve TAP,VOC 20% 401.9 0.2 43748 5 HAP,TAP, Iso ro anol VOC 1 10% 1 200.9 0.1 43748 5 'Each pollutant contained in the Hydro-graphic Activator is classified in WAC 173-460. rMe amount of each compound contained in the Hydro-graphic Activator is listed in the Material Safety Data Sheet for the coating. 3PTE(lb/yr)=Content from MSDS*Material Usage(Ib/yr) 4PT E(lb/hr)=Content from MSDS*Material Usage(lb/hr) 51he small quantity emission rate(SQER)for each compound is defined in WAC 173-4W. Application of the Topcoat Post cured bow risers and limbs will then inspected and any small areas void of the camouflage pattern may then be touched-up with a small airbrush paint gun or a permanent marking pen.The touched up and inspected bow risers and limbs will then be coated with a two part topcoat.This protective coating will be applied in the Spray Booth. Table 1.3-Air Emissions Resulting from Application of the Two-Part Topcoat Emissions from 1 JB HC Aliphatic Hardener Content Pollutant Classification from PTE' PTE2 SQER SQER MSDS Ib/ r lb/hr lb/ Ib/hr n-butyl acetate TAP,VOC 50% 689.7 0.34486 43748 5 Hexamethylene HAP,TAP, diisoc anate VOC 1% 13.8 0.0069 43748 5 Isobutyl acetate TAP,VOC 0.1% 1.4 0.00069 43748 5 Butanol TAP,VOC 10% 137.9 0.07 43748 5 Emissions from HC Low SH UV Res Vinyl T/C Content Pollutant Classification from PTE' PTE2 SQER SQER MSDS Ib/ r Ib/hr lb/ r Ib/hr Acetone TAP 1.0% 77.9 0.04 43748 5 Aliphatic petroleum distillates TAP,VOC 10% 779.3 0.39 43748 5 Butyl cellosolve TAP,VOC 10% 779.3 0.39 43748 5 HAP,TAP, Iso ro anol VOC 1% 77.9 0.04 43748 1 5 Methyl a-am I ketone TAP,VOC 30% 2337.8 1.17 43748 5 n-butyl acetate TAP,VOC 10% 779.3 0.39 43748 5 Toluene TAP,VOC 10% 779.3 0.39 43748 5 'Each pollutant contained in the two-part topcoat is classified in WAC 173-460. -Me amount of each compound contained in the two-part topcoat is fisted in the Material Safety Data Sheet for the coating. ;PTE(lb/yr)=Content from MSDS*Material Usage(Ib/yr) 4PTE(Ib/hr)=Content from MSDS*Material Usage(lb/hr) 5The small quantity emission rate(SQER)for each compound is defined in WAC 173-460. Final Determination Page 3 of 11 NOC_Steve Sims Inc-08NOC635.doc 08NOC635 Prepared January 7,2009 The finished products will then be used to assemble the Deadzone®bows.The figure shown below is a process flow diagram representing the coating process at Steve Sims. Raw Materials Parts Washer Spray Booth Water Transfer Printing (Dip Tank) Finished Products Curing Table 1.4 — Summary of New Emission Generating Processes New Emission Process Emission Process Description Spray Coating Base Coat Type: Spray application of HC Max 4 Basecoat Description:The HC Max Basecoat for the limbs and risers is applied using HVLP spray guns in the Spray Booth. Control Measures:HVLP spray guns used to apply basecoat,spray coating conducted in a filtered spray booth. Dip Coating Type: Water transfer printing Description:The decorative designs for the bow risers and limbs are applied using a water transfer printing technique. Control Measures:Water transfer printer as compared to spray coating results in relatively low air emissions.As such,the technique of water transfer printing is considered a control measure. Table 1.5 — Summary of New Emission Control Equipment New Emission Units Emission Unit Description Drying Room Manufacturer:Built on site Model:None Type:Electrically heated drying room Dimensions:5.5 ft.wide, 12.5 ft.high,and 22 ft.long Airflow: 10,000 CFM Exhaust Discharge:The exhaust from Prep Booth 2 will discharge into the interior of the building. Spray Booth Manufacturer:Standard Tools and Equipment Company Model: SMM PTB OFB-8 Type:Open Face Booth(retrofitted to be fully enclosed) Dimensions: 8 ft.wide, 13.67 ft.high,and 26.33 ft.long Filter Area:44.4 ft.'` Airflow: 5,484 acfm Section 1.3: Air Pollutant Emissions Final Determination Page 4 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 The amount of air pollution caused by manufacturing operations at Steve Simms is limited by the physical manufacturing limits of the facility.This production limitation will limit the amount of coatings,activators,reducers, and solvents used at the facility. Since air pollution emissions at Steve Sims will result from usage of coatings,activators,reducers, and solvents the volume of these materials used at the facility is the basis for the potential to emit (PTE) calculations shown in Table 1.3.The assumed volume of each material consumed at the facility for the PTE calculations is incorporated into enforceable conditions of approval.This ensures that the facility will not exceed the emission levels shown in this document. The emission rates shown in Table 1.3 assume that the emission rate for individual VOCs will be generally proportional to the rate of production. In other words,if the production rate remains unchanged the emission rates will remain unchanged. Table 1.6-Total Potential to Emit Emissions of Toxic Air Pollutants CAS Pollutant Name Pollutant SQER SQER Potential to Potential %of Class (lb/yr) (lb/hr) emit(lb/yr) to emit annual lb/hr SQER 67-64-1 Acetone B 43,748 5.0 8219 4 14% 64742-84- Aliphatic petroleum B 43,748 5.0 2034 1.02 4.6% 8 distillates 71-36-3 Butanol B 10,500 1.2 138 0.069 1.3% 822-06-0 Hexamethylene B 175 0.02 13.8 0.0069 7.9% diisoc anate 110-19-0 Isobutyl acetate B 43,748 5.0 1.38 0.00069 0.003% 67-63-0 1 Iso ro anol B 43,748 5.0 279 0.139 0.6% 110-43-0 1 Methyl a-amyl B 43,748 5.0 4211 2.11 9.6% ketone 78-93-3 Methyl ethyl ketone B 43,748 5.0 1874 0.94 4.3% 123-864 n-butyl acetate B 43,748 5.0 2406 1.20 5.5% 108-88-3 Toluene B 43,748 5.0 1875 0.94 4.2% 1330-20-7 X lene B 1 43,748 5.0 1 159 0.08 1 0.4% Fach Pollutant listed here is classified in W.%("173-460. ryhe amount of each compound contained in materials used at Steve Sims is listed in the respective Material Safety Data Sheet for the material. 3PTE(Ib/yr)=Content from MSDS*Material Usage(lb/yr) 4PTE(lb/hr)=Content from MSDS*Material Usage(lb/hr) 5The small quantity emission rate(SQER)for each compound is defined in WAC 173-460. Table 1.7-Total Potential to Emit for Volatile Organic Compounds and Particulate Matter Final Determination Page 5 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 Solids Controlled Material Material Material Material Material % VOC Emission Solids Usage" Usages Specific Useage' Usage VOC7 Solids' Emission as PM104 Emission Material al/ r al/hr gravity Ib/ r) (lb/hr) ((lb/gal) (by wt.) z Ib/ r) Ib/ r Ib/ r) L5/S Clear Hydro-Graphic Activator 240 0.12 1.01 2009 1.005 1 5.91 30% 1418 0 0.0 HC Max 4 Basecoat 1000 0.5 1.13 9368 4.684 5.37 43% 5370 4028 161.1 1 JB Aliphatic Harderer 160 0.08 1.04 1379 0.690 3.45 60% 552 828 33.1 HC Low SH UV Res Vinyl Topcoat 1000 0.5 0.94 7793 3.90 1 6.29 20% 6290 1559 62.3 Controlled Material Material Material % VOC Solids Solids Reducers and Usage Specific Usage VOC Solids Emission Emission Emission Solvents I ( al/ r) gravity (lb/ r) (lb/gal (by wt.) Ib/ r) (lb/ r) (Ib/yr) Acetone 1,000 0.45 0.79 6549 2.95 0% 0% 0 0 0 1-5/S HC Color Works Reducer 240 0.12 0.8 1592 0.796 1.78 0% 427 0 0 Material Usage(lb/yr)=Material Usage(gal/yr)*Specific gravity*8.29 Total VOC Emission 14058 (lb/yr) ZVOC Emission(gaI/yr)=Material Useage(gal/yr)*Material VOC(lb/gal) Or 7.0 (ton/yr) 3Controlled Solids Emission(lb/yr)=Solids Emiss ion(Ib/yr)*Uncontrolled Spraycoating Total Spraycoating Emission Rate PM Emissions 257 (lb/yr) °Solids Emission(lb/yr)=Material Useage(lb/yr)*%Solids(by wt.) Or 0.18 ton/ r) 5Material Usage(gal/hr)=(Material Usage(gal/yr))/Operating Schedule(hrs/yr) "Material Usage(Ib/hr)=(Material Usage(lb/yr))/Operating Schedule(hr/yr) 7VOC content(lb/gal)and%Solids(by wt.)was found on the MSDS for the material "Material Usage(gal/yr)is the maximum amount of coating and thinner that can be used at the facility without exceeding any single Small Quantity Emission Rate(SQER)as defined in WAC 173-460 2. Facility History and Background This is a new facility. 3. Administrative Requirements ®Fees paid. ❑Application complete. 4. SEPA Review ❑The project is exempt from SEPA requirements per WAC 197-11-800(3) since it involves only repair, remodeling, maintenance or minor alteration of existing structures, equipment or facilities and will involve no material expansions or changes in use (describe basis): ❑SEPA is applicable and ORCAA is the lead agency. A copy of ORCAA's SEPA threshold determination and a list of any environmental documents used to support the determination are included in the attachments. ❑Existing environmental documents were either adopted,incorporated by reference by ORCAA, or an addendum to an existing environmental document was issued by ORCAA pursuant to WAC 197-11-600. Final Dctcrrnination Page 6 of 11 NOC_Stcvc Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 []No existing environmental documents were used to support ORCAA's SEPA threshold determination. ®SEPA is applicable and another agency is the lead agency. A copy of that agency's SEPA Threshold Determination and list of any support documents are included in the attachments. Lead AgencV Mason County Department of Corrununity Development Determination Mitigated Determination of Nonsignificance Date of Issuance of issued yej 5. Applicability and Compliance Evaluations ®The proposed new stationary source or modification will likely comply with all applicable state, federal and local air regulations and standards. The following table lists those air regulations and standards that required an applicability and/or compliance evaluation.A comprehensive list of applicable air regulations and standards is attached. Regulation/Standard Description Applicable? Compliance Evaluation Likely? Attached? General ORCAA and State General regulations and standards found in ties Yes No Air Requirements ORCAA Regulations 7 and 8,and WAC 173- 400-040. 40 CFR Part 63 Subpart National Emission Standard for Hazardous Air No Yes Yes HHHHHH Pollutants:Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources 6. BACT The proposed new stationary source or modification will employ BACT for all pollutants not previously emitted or whose emissions would increase as a result of the new stationary source or modification. Pollutant BACT Description:Describe BACT limits,and control technology or methods to meet - Applicable? BACT limits. NOx No CO No VOC Yes ORCAA has concluded that this proposal meets the requirement to employ BACT for VOC. so, No PM, Yes Toxics Yes ORCAA as concluded that this proposal meets the requirement to employ BACT for toxics. 7. Ambient Impact Analysis (Criteria Pollutants) Allowable emissions from the proposed new stationary source or modification will not delay the attainment date for an area not in attainment not cause or contribute to a violation of any ambient air quality standard: ®No criteria pollutant emissions increases expected. ❑Expected increases in criteria pollutant emission rates are below significant emission rate thresholds for all criteria pollutants (see Attachments). QAir Quality Impacts Analysis completed by ORCAA (see Attachments). Final Determination Page 7 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 ❑Air Quality Impacts Analysis provided by applicant (see NOC Application). 8. Ambient Impact Analysis (Toxic Air Pollutants) The requirements for approval of new sources of Toxic Air Pollutants (TAPs) in Chapter 173-460 WAC have been met. ❑No TAP emissions increases expected (see Attachments). ®Maximum TAP emission rate increases do not exceed the "small quantity emission rates" [specified in WAC 173-460-080(2)(e) (see Attachments). ]Analysis of TAP emission increases with respect to Acceptable Source Impact Levels (ASIL)in accordance with WAC 173-460-080 completed by ORCAA (see Attachments). ❑Analysis of TAP emission increases with respect to Acceptable Source Impact Levels (ASIL) in accordance with WAC 173-460-080 completed by Applicant (see NOC Application). 9. Title V Air Operating Permit (AOP) ® Minor Source.AOP not required since facility-wide potential to emit is minor for all pollutants (see Attachments). ❑Synthetic Minor Source.AOP not required since applicant requested voluntary limit on emissions (Describe voluntary limit and associated conditions): ❑New Major Source.AOP required since proposed new stationary source or modification results in a new major source under Title V. ❑Existing Major/Revision Not Required. New stationary source or modification proposed at an existing major source with an AOP. However,revision to the AOP not required as the proposed new stationary source or modification qualifies as a "change not requiring permit revisions"in accordance with WAC 173-401-722. ❑Existing Major/Off-Permit Change. New stationary source or modification proposed at an existing major source with an AOP. However,revision to the AOP not required as the proposed new stationary source or modification qualifies as an"off-permit change" according to WAC 173- 401-724. ❑Existing Major/AOP Revision Required. New stationary source or modification proposed at an existin major source with an AOP. Revision to the AOP required in accordance with: Administrative permit amendment procedures under WAC 173-401-720. ❑Minor permit modification procedures under WAC 173-401-725(2). []Procedures for group processing of minor permit modifications under WAC 173-401- 725(3). ❑Permit modification procedures under WAC 173-401-725(4). 10. Prevention of Significant Deterioration (PSD) Permitting ®PSD permit not required since the proposed new stationary source or modification will result in a minor source with respect to the State's PSD program in WAC 173-400-141 (emission calculations attached). ❑The existing source is a PSD major source. However, a PSD permit is not required since the proposed modification is not a major modification with respect to the State's PSD program in WAC 173-400-141 (emission calculations attached). Continuing ❑PSD permit issued by Ecology (PSD Permit Conditions Attached): 11. Public Involvement Final Determination Page 8 of 11 NOC—Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 ®Public notice of ORCAA's receipt of the NOC application,pursuant to ORCAA 6.1.3(a),was issued on October 9,2008. No comments were received during the comment period. ❑Public notice of ORCAA's Preliminary Determination,pursuant to ORCAA 6.1.3(c),was issued . No comments were received during the comment period. ❑Public notice of ORCAA's Preliminary Determination,pursuant to ORCAA 6.1.3(c),was issued . Comments were received during public comment period and were considered in making this Final Determination. Staff s Responsiveness Summary is provided in Attachments. ❑Public Hearing held pursuant to ORCAA 6.1.3(e) on .Comments received during public comment period and public hearing were considered in making this Final Determination. Staff s Responsiveness Summary and Hearings Examiner Ruling are provided in Attachments. 12. Conditions of Approval The following conditions of approval are necessary for assuring compliance with applicable air regulations and standards: 1. Technical Specifications: Pollution generating equipment,air pollution control devices and operations at the facility shall be in accordance with the information and specifications described in the associated NOC application unless otherwise specified by condition in this Approval Order. [Regulatory Basis: ORCAA 6.1.20)] 2. Stack Specifications:There shall be no flow obstructions at the point of discharge from the stack (i.e. cap). However,a weatherproof stack exhaust configuration that does not obstruct the air flow as it exits the stack is acceptable. [Regulatory Basis: WAC 173-460-060, ORCAA 6.1.4(a)(2)] 3. Spray Coating Requirements: The following requirements apply to spray coating activities conducted at the facility: a. The permittee shall confine all spray coating operations to a properly filtered spray booth,preparation station, or mobile enclosure; b. The booth or enclosure in which the spray coating is conducted shall be fitted with a type of filter technology that is demonstrated to achieve at least 98 percent capture of paint overspray (ASHRAE Method 52.1). Published filter efficiency data provided- by filter vendors may be used to demonstrate compliance with this requirement; c. Spray Application Methods: Only high-volume low-pressure (HVLP),electrostatic, airless, air-assisted airless equipment or an equivalent technology shall be used in the spray application of coatings;and, d. The permittee shall ensure that filters in the spray booth are properly seated and cover all openings of the exhaust plenum of the spray booth. [Regulatory Basis: WAC 173-400-113(2)(a), ORCAA 6.1.4(a)(2)] 4. Opacity Limit:The Spray Booth shall operate at a maximum of 5%opacity as measured by EPA 40CFR Part 60 Appendix A Method 9. [Regulatory Basis:WAC 173-400-113(2)(a), ORCAA 6.1.4(a)(2)] Final Determination Page 9 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 5. Material Use Limit: The permittee shall not use more than the amount specified for each corresponding product specified below,on a consecutive 12-month basis: a. Graphic Activator shall be less than 240 gallons per year; b. Basecoat shall be less than 1000 gallons per year; c. Aliphatic Hardener shall be less than 160 gallons per year; d. Vinyl Topcoat shall be less than 1000 gallons per year; e. Acetone shall be less than 1000 gallons per year;and, f. Color Works Reducer shall be less than 240 gallons per year. [Regulatory Basis:WAC 173-460-070, ORCAA 6.1.2(1)] 6. Operations and Maintenance Requirements: All reasonable measures and precautions shall be taken for minimizing emissions of VOCs and HAPs,including but not limited to: a. Cleaning spray guns in such a way that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects the used gun cleaning solvent. Examples include: i. Hand cleaning of gun parts in a solvent container by flushing solvent through the gun without atomizing the solvent and paint residue or; ii. Use of a fully enclosed spray gun washer. b. Keeping VOC or HAP-containing materials in closed containers when not being used. c. Storing all solvents or solvent-containing cloth or other material used for surface preparation in closed,airtight containers. d. Minimizing and promptly cleaning up all VOC or HAP-containing material spills and leaks. e. Ensuring that filters are properly seated and cover all openings of the exhaust plenum of the spray booth. f. Monitoring filters on a regular basis and replacing whenever damaged or loaded with particulate build-up to an extent that jeopardizes the effectiveness of the spray booth in capturing and controlling emissions. [Regulatory Basis:WAC 173-400-113(2)(a), ORCAA 6.1.4(a)(2)] 7. Operation Plan:The permittee shall develop,implement,and update when necessary an Operations and Maintenance (O&lam plan for operating and maintaining air pollution generating equipment and air pollution control equipment at the facility. [Basis: ORCAA Rule 4.3(g)] 8. Recordkeeping Requirements: Material use records shall be maintained and updated on a monthly basis. Records shall be sufficient to verify the actual,cumulative amount of VOC or HAP-containing materials used in terms of gallons per month and 12-consecutive month period. Records shall be maintained for at least five years,with copies kept on-site for at least two years.At a minimum,records shall include the following: Final Determination Page 10 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 a. Purchase invoices indicating the amount of VOC or HAP-containing materials purchased (paint,hardener,thinners,etc.), date of purchase, and corresponding product identification numbers. b. Record of the actual cumulative use of VOC or HAP-containing materials in terms of gallons per month. c. Material Safety Data Sheets (MSDS) for all VOC or HAP-containing materials used. d. Documentation of the filter efficiency of any spray booth exhaust filter material. e. Documentation from the spray gun manufacturer that each spray gun with a cup capacity equal to or greater than 3.0 fluid ounces(89 cc) that does not meet the definition of an HVLP, electrostatic,airless,or air-assisted airless spray gun,has been determined to achieve an equivalent transfer efficiency to one of these technologies. [Basis: ORCAA Rule 8.11] PREPARED BY: Gordon Lance Date REVIEWED BY: Mark V. Goodin, PE Date Final Determination Page 11 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 ATTACHMENTS ®APPLICABLE AIR REGULATIONS AND STANDARDS ❑APPLICABILITY DETERMINATIONS ®LIST OF ABBREVIATIONS AND ACRONYMS ®SEPA DOCUMENTS ❑EMISSION CALCULATIONS ❑AMBIENT AIR QUALITY ANALYSIS ®AIR TOXICS ANALYSIS ❑OTHER SUPPORTING INFORMATION Final Determination Attachments NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 Attachment 1 Applicable Regulations and Standards Final Determination Attachments NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 APPLICABLE AIR REQUIREMENTS AND PERFORMANCE STANDARDS FOR 08NOC635 TITLE CITATION BRIEF DESCRIPTION Generall A licable Requirements and Performance Standards: Annual Registration WAC 173-400-101 Requires annual registration and reporting of annual emissions. Program ORCAA 4.1 Registration Category:RC4 Annual Registration WAC 173-400-104 Provides local air pollution agencies the authority to assess an annual fee to Fees ORCAA 3.1 registered air pollutant sources. New Source Review ORCAA Rule 6 Approval by ORCAA through a NOC application is required prior to (NSR) WAC 173-400-110; establishing or constructing any new source of emissions,or modifying an Requirements WAC 173-400-114 existing source.This includes removal of a control device or substantial modification of an existing control device. Concealment and WAC 173-400-040(7) Prohibits the installation or use of any means that conceals or masks an Masking ORCAA 7.5 emission of an air contaminant that would otherwise violate any provisions of this cha ter. Control Equipment ORCAA 8.8 Requires air contaminant sources to keep any process and/or air pollution Maintenance and control equipment in good operation and repair. Repair Emission Inventory WAC 173-400-105(1) Requires maintenance of records relating to air pollutant emissions and ORCAA 4.3 submittal of an annual emissions inventory if required. Emissions WAC 173-400-040(5) 1'n)hibits emissions of any air contaminant from any source that are Detrimental to ORCAA 7.6 detrimental to persons or property. Persons or Property Excess Emissions WAC 173-400-107 Requires source operators to demonstrate that excess emissions were ORCAA 8.7 unavoidable in order to obtain relief in an enforcement action. Fallout Prohibition WAC 173-400-040(2), Prohibits particulate emissions from any source to be deposited,beyond the ORCAA 8.3(e) property under direct control of the owner or operator of the source,in sufficient quantity to interfere unreasonably with the use and enjoyment of the property upon which the material was deposited. Fugitive Dust WAC 173-400-040(8) Requires reasonable precautions be taken to prevent fugitive dust from Sources ORCAA 8.3 c becoming airborne. Fugitive Emissions WAC 173-400-040(3), Requires that reasonable precautions be taken for controlling fugitive emissions. Odors WAC 173-400-040(4) Requires use of"recognized good practices and procedures"for control of State Regulation any odor which may unreasonably interfere with the use or enjoyment of another erson's property. Odors ORCAA 8.5 Requires that reasonably available control techniques and measures be used to ORCAA Regulation control odor-bearing gases. Prohibits emissions of any odor that unreasonably interferes with another erson's use and enjoyment of their property. Record Keeping and ORCAA 8.11 Requires the following: Reporting 1.Maintenance of records on the nature and amounts of emissions and other related information as deemed necessary by ORCAA; 2.Reporting of emissions to ORCAA upon request. Sulfur Dioxide WAC 173-400-040(6) Prohibits emissions of sulfur dioxide from any emissions unit in excess of 1000 ppm of sulfur dioxide on a dry basis,corrected to 7%oxygen for combustion sources,and based on the average of any period of sixty consecutive minutes. Equipment-Specific Applicable Requirements and Performance Standards: General Standards WAC 173400-040(1) Prohibits emissions with an opacity of greater than 20%for more than three for Maximum ORCAA Rule 8.2(a) (3)minutes in any one hour. Visual Emissions Particulate WAC 173-400-060 Prohibits emissions from any process unit in excess of 0.1 grain/dscf. EPA Standards for ORCAA Rule 8.3(a) test methods from 40 CFR Appendix A shall be used should demonstration Process units I of compliance be required. I I Final Determination Attachments NOC_Steve Sims lnc_08NOC635.doc 08NOC635 Prepared January 7,2009 Attachment 2 Applicability Determinations Applicability Determination for National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (40 CFR Part 63, Subpart HHHHHH) The requirements of 40 CFR Part 63 Subpart HHHHHH apply to an operator of an area source of hazardous air pollutants (HAPs) that perform one or more of the following activities listed in§63.11170(a)(1) through (3).They are: 1. Paint stripping using McCI for the removal of dried paint(including,but not limited to,paint,enamel, varnish,shellac,and lacquer from wood,metal,plastic,and other substrates; 2.Spray application of coatings,as defined in§63.11180,to motor vehicles and mobile equipment;and/or 3. Spray application of coatings that contain the target HAP,as defined in§63.11180,to a plastic and/or metal substrate on a part or product. The proposed Steve Sims,Inc. (Steve Sims) bow manufacturing facility will be an area source of HAPs since the facility will emit several HAPs while conducting manufacturing activities,but has a potential-to-emit of less than 10 tons per year of any single HAP and less than 25 tons per year of total combined HAPs. However,Steve Sims,Inc. does not propose to use McCI to strip paint nor does Steve Sims propose to conduct surface coating of motor vehicles or mobile equipment(as defined in§63.11180). Steve Sims does proposes to spray coat metal and composite parts;however,an examination of material data safety sheets (MSDS) for all proposed coatings to be used at Steve Sims revealed that the single target HAP conatained in the coatings is reported by the coating manufacturer to be less than 0.1%by mass.Pursuant to the definition of"Target HAP"founding in§63.11180,this amount is insufficient to qualify the coating as a "Target HAP containing coating". As a result of this finding,ORCAA has concluded that the requirements of 40 CFR Part 63 Subpart HHHHH will not apply to activities at Steve Sims since Steve Sims is not proposing to conduct any of activities listed in§63.11170(a)(1) through(3). I Final Determination attachments NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 i i i I i Attachment 3 Abbreviations and Acronyms Final Determination Attachments NOC_Steve Sims Inc_ O 08NC635.doc 08NCC635 Prepared January 7,2009 ABBREVIATIONS AND ACRONYMS WAC Washington Administrative Code AOP Air Operating Permit AP-42 Compilation of Emission Factors,AP-42, UNITS OF MEASUREMENT Fifth Edition,Volume I,Stationary Point minute(measurement of angle) and Area Sources—Published by EPA second(measurement of angle) ASIL Acceptable Source Impact Level pursuant ° degree to Chapter 173-460 WAC acfin actual cubic feet per minute BACT Best Available Control Technology atm atmosphere FCAA Federal Clean Air Act Bhp Brake horse power CAM Compliance assurance monitoring(40 Btu British thermal units CFR 64) cfin cubic feet per minute CFR Code of Federal Regulations dscfin dry standard cubic feet per minute CO Carbon monoxide OF degree Fahrenheit EPA United States Environmental Protection ft feet Agency g grams HAP Hazardous air pollutant listed pursuant to g/s grams per second Section 112 FCAA gal gallon MACT Maximum Achievable Control gr grain Technology hr hour NESHAPs National Emission Standards for hp horsepower Hazardous Air Pollutants in inches NAAQS National Ambient Air Quality Standard K degree Kelvin NOx Nitrogen oxides kg kilograms NOC Notice of Construction application km kilometers NSPS New Source Performance Standards kW kilowatt NSR New Source Review L liter PM Total particulate matter(includes both lb pounds filterable particulate matter measured by In meters EPA Method 5 and condensable M thousand particulate matter measured by EPA min minute Method 202) Mbf thousand board feet PM10 Particulate matter with an aerodynamic MMbf million board feet diameter less than or equal to 10 MM million micrometers(includes both filterable ❑g micrograms particulate matter measured by EPA MMBtu million British thermal units Method 201 or 201A and condensable mmHg millimeters of mercury particulate matter measured by EPA mph miles per hour Method 202) MW megawatts PM2.5 Particulate matter with an aerodynamic ppm parts per million diameter less than or equal to 2.5 ppmvd parts per million,dry volume micrometers(includes both filterable ppb parts per billion particulate matter measured by EPA psi pounds per square inch Method 201 or 201A and condensable s second particulate matter measured by EPA scfm standard cubic feet per minute Method 202) tpy tons per year PSD Prevention of Significant Deterioration RACT Reasonably Available Control Technology RBLC RACT/BACT/LEAK Clearinghouse RCW Revised Code of Washington S02 Sulfur Dioxide SQER Small Quantity Emission Rate listed in Chapter 173-460 WAC ORCAA Olympic Region Clean Air Agency TAP Toxic Air Pollutant pursuant to Chapter 173-460 WAC T-BACT Best Available Control Technology for toxic air pollutants VOC Volatile Organic Compound Final Duemvnation Attachments NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 Attachment 4 Emission Calculations Air pollution emission at the proposed Steve Sims bow manufacturing facility will result from application of coatings to the bow components and also from solvents used to clean the coating equipment. ORCAA staff calculated the potential-to-emit at Steve Sims using a mass balance calculation. The mass balance calculation assumes that all of the volatile constituents in the coatings and solvents become airborne pollution.The amount of volatile ingredients in the coatings is obtained from the material data safety sheet for each coating or solvent. For volatile organic compound (VOC) emission calculations, the physical and chemical properties of the coating are used to quantify the amount of VOC emitted by using a certain quantity of coating. An example calculation is shown below.The coating in this example is the HC Max 4 Basecoat and the following assumptions are made: Maximum annual product usage = 1000 gallons (this is based on production limitations at the plant) VOC content (lb/gal) = 5.38 lb/gal (from Section 9 of the MSDS) VOC Emissions =5.38 lb*1000 gal gal yr VOC Emissions =5380 lb yr The amount of each toxic air pollutant (TAP) emitted is also calculated. For TAPs,a mass balance calculation technique is used. An example calculation is shown below.The coating in this example is the HC Max 4 Basecoat and the TAP is methyl ethyl ketone.The following assumptions are made: Maximum annual product usage = 1000 gallons per year Specific Gravity of the product = 1.13 (from Section 9 of the MSDS) The percent methyl ethyl ketone in the product = 20% (from Section 3 of the MSDS) MEK Emissions =1000 gal *1.13*8.29 lb*20% yr gal MEK Emissions = 1873.5 lb yr The total amount of air pollution caused by manufacturing operations at Steve Simms is limited by the physical manufacturing limits of the facility.This limitation will limit the amount of coatings, activators,reducers,and solvents used at the facility. Since air pollution emissions at Steve Sims will result from usage of coatings, activators,reducers,and solvents the volume of these materials used Final Determination Attachments N(X:_Stcve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 at the facility is the basis for the potential to emit (PTE) calculations and resulting emission levels shown in Tables A4.1 and A4.2. The assumed volume of each material consumed at the facility for the PTE calculations is incorporated into enforceable conditions of approval. This ensures that the facility will not exceed the emission levels calculated in this document. Table A4.1—Total Facility Wide VOC Emissions Solids Controlled Material Material Material Material Material % VOC Emission Solids Usage Usages Specific Useage' Usages VOC' Solids' Emission as PM104 Emission Material al/ r al/hrgravity Ib/ r Ib/hr (lb/gal) (by wt. z Ib/ r Ib/ r Ib/ r) L5/S Clear Hydro-Graphic Activator 240 0.12 1.01 2009 1.005 5.91 1 30% 1418 0 0.0 HC Max 4 Basecoat 1000 0.5 1.13 9368 4.684 5.37 43% 5370 4028 161.1 1 JB Aliphatic Harderer 160 0.08 1.04 1379 0.690 3.45 60% 552 828 33.1 HC Low SH UV Res Vinyl Topcoat 1000 0.5 0.94 7793 3.90 6.29 20% 6290 1559 62.3 Controlled Material Material Material % VOC Solids Solids Reducer/Thinne Usage Specific Usage VOC Solids Emission Emission Emission r/Solvent al/ r) gravity (lb/yr) (lb/gal) (by wt. Ib/ r) (lb! r) (Ib/ r) Acetone 1,000 0.45 0.79 6549 2.95 0% 0% 0 0 0 L5/S HC Color Works Reducer 240 0.12 0.8 1592 0.796 1.78 0% 427 0 0 Material Usage(lb/yr)=Material Usage(gal/yr)*Specific gravity*8.29 Total VOC Emission 14058 (lb/yr) 2VOC Emission(gal/yr)=Mated al Useage(gal/yr)*Material VOC(lb/gal) Or 7.0 (ton/ r) 3Controlled Solids Emission(lb/yr)=Solids Emission(lb/yr)*Uncontrolled Spraycoating Total Spraycoating Emission Rate PM Emissions 257 (lb/yr) °SOIids Emission(lb/yr)=Material Useage(Ib/yr)*%Sol ids(by wt.) Or 0.18 ton/ r 5Material Usage(gal/hr)=(Material Usage(gal/yr))/Operating Schedule(hrs/yr) 6Material Usage(lb/hr)=(Material Usage(lb/yr))/Operating Schedule(hr/yr) 7VOC content(lb/gal)and%Solids(by wt.)was found on the MSDS for the material 8Material Usage(gal/yr)is the maximum amount of coating and thinner that can be used at the facility without exceeding any single Small Quantity Emission Rate(SQER)as defined in WAC 173-460 Final Determination .Attachments NOC Stew Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 r Table A4.2—Facili -Wide Emission of Toxic Air Pollutants Modeling Pollutant Classification CAS# PTE' PTE2 SQER3 SQER3 Required?° (lb/ r) (lb/hr) (lb/ r) (lb/hr) ( es/no) Acetone TAP 67-64-1 8219 4 43748 5 no Aliphatic petroleum distillates TAP,VOC 64742-89-8 2034 1.02 43748 5 no Butanol TAP,VOC 71-36-3 138 0.069 10500 1.2 no Hexamethylene diisoc anate HAP,TAP,VOC 822-06-0 13.8 0.0069 175 0.02 no Isobutyl acetate TAP,VOC 110-19-0 1.38 0.00069 43748 5 no Iso ro anol HAP,TAP,VOC 67-63-0 278.9 0.139 43748 5 no Methyl a-am I ketone TAP,VOC 110-43-0 4211 2.11 43748 5 no Methyl ethyl ketone TAP,VOC 78-93-3 1874 0.94 43748 5 no n-butyl acetate TAP,VOC 123-86-4 2406 1.20 43748 5 no Toluene TAP,VOC 108-88-3 1875 0.94 43748 5 no X lene HAP,TAP,VOC 1330-20-7 159 0.080 43748 5 no Total HAPs= 452 Ibs/ r = 0.23 tons/ r Total TAPs= 19335 Ibs/ r = 9.7 tons/ r 'PTE(lb/yr)=Content from MSDS;Material Usage(lb/yr) 2PTE(lb/hr)=Content from MSDS'Material Usage(lb/hr) 'The small quanity emission rate for each pollutant is defined in Chapter 173-460 of the Washington Administrative Code "If the calculated emission rate is greater than the Small Quanity Emission Rate,then modeling is required I I I I I I I I Final Determination Attachments NOC_Steee Sims]nc_08NOC635.doc 08NOC635 Prepared January 7,2009 Attachment 5 Air Toxics Analysis I� i i Final Determination :Attachments NOC_Steve Sims Inc_08NOC635.doc O8NOC635 I Prepared January 7,2009 Air Toxics Analysis WAC 173-400-113(2)(e)requires new sources and modifications,that emit toxic air pollutants (TAPS),to comply with the requirements of Chapter 173-460 WAC,also known as the Washington Air Toxics Regulation. The requirements of WAC 173-460 are applicable to projects that result in an increase in emissions of TAPS and to replacement units that will emit TAPs. In this case,the new coating activities at Steve Sims constitute a new source that will result in emissions of TAPs.Therefore,a demonstration of compliance with WAC 173-460 is required. Essentially,WAC 173-460 allows for a multi-tiered approach to assessment of the potential impacts caused by emission of TAPs.The first tier involves comparing the calculated emission rates to the small quantity emission rates (SQER).The SQER is described in WAC 173-460-080(2)(e)as a threshold below which emissions are sufficiently low to ensure compliance without further analysis. For pollutants with emission rates greater than the SQER,a more complex analysis is needed.This analysis typically involves the use of a screening tool used to predict fence line concentrations of the pollutant followed by a comparison of this concentration to the acceptable source impact level(ASM).For pollutants with a fence line concentration greater than the ASH,a second tier risk analysis is required. In this case,there are no pollutants with a projected emission rate greater than their respective SQER. In fact, there are no TAPs emitted at more than 19%of the SQER,and most are 5%or less of their respective SQER.Table A5.1 shows the calculated emission rate as well as the corresponding SQER.The emission rates represent the maximum allowable emissions given the plant-wide material usage limits. Table A5.1- Emission of Toxic Air Pollutants Modeling Pollutant Classification CAS# PTE' PTE' SQER3 SQER3 Required?° (Ib/ r) (lb/hr) Ib/ Ib/hr ( es/no Acetone TAP 67-64-1 8219 4 43748 5 no Aliphatic petroleum distillates TAP,VOC 64742-89-8 2034 1.02 43748 1 5 no Butanol TAP,VOC 71-36-3 138 0.069 10500 1.2 no Hexamethylene diisocyanate HAP,TAP,VOC 822-06-0 13.8 0.0069 175 0.02 no lsobutyl acetate TAP,VOC 110-19-0 1.38 0.00069 43748 5 no Iso ro anol HAP,TAP,VOC 67-63-0 278.9 0.139 43748 5 no Methyl a-am I ketone TAP,VOC 110-43-0 4211 2.11 43748 5 no Methyl ethyl ketone TAP,VOC 78-93-3 1874 0.94 43748 5 no n-butyl acetate TAP,VOC 123-86-4 2406 1.20 43748 5 no Toluene TAP,VOC 108-88-3 1875 0.94 43748 5 no X lene HAP,TAP,VOC 1330-20-7 159 0.080 43748 5 no Total HAPs= 452 Ibs/ r = 0.23 tons/ r Total TAPs= 19335 Ibs/ r = 9.7 tons/ r 'PTE(lb/yr)=Content from MSDS*Material Usage(lb/yr) 2PTE(lb/hr)=Content from MSDS*Material Usage(lb/hr) 3The small quanity emission rate for each pollutant is defined in Chapter 173-460 of the Washington Administrative Code `If the calculated emission rate is greater than the Small Quanity Emission Rate,then modeling is required III I I Final Detemvnation Attachments NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 Air Toxics Analysis Conclusion After quantifying potential-to-emit for emissions of TAPs at the proposed bow manufacturing facility, ORCAA has concluded that emissions will likely comply with the requirements found in WAC 173-460.This conclusion is based in part on the finding that the potential to emit for each TAP was quantified,and it was found that the emission rate for each TAP is below the corresponding pollutant SQER. In addition to this, there is a substantial margin between potential to emit for each TAP and the corresponding SQER.This means that it can be safely assumed that pollutant concentrations at the fence line will be well below their corresponding ASH s. rinal Determination Attachments NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 ORDER OF APPROVAL NOTICE OF CONSTRUCTION NOC #: 08NOC635 Date Issued:January 12,2009 This Order of Approval (Order) is issued in accordance with Olympic Region Clean Air Agency's (ORCAA) Regulations and Chapter 173-400 of the Washington Administrative Code. Conditional approval is hereby granted to Steve Sims,Inc. to construct a new bow manufacturing facility at 121 W. Development Rd in Shelton,Washington.The special conditions established in this Order are enforceable requirements and are in addition to applicable state,local and federal regulations and standards. Compliance with the conditions of this Order does not relieve the owner or operator from compliance with ORCAA Regulations,RCW 70.94, or any other emissions control requirements,nor from the resulting liabilities and/or legal remedies for failure to comply.The owner or applicant may appeal this Order to the Pollution Control Hearings Board (PCHB) by filing a written appeal with the PCHB and serving a copy upon ORCAA within thirty (30) days from receipt of the Order. THIS ORDER OF APPROVAL IS ISSUED SUBJECT TO THE FOLLOWING CONDITIONS: 1. Technical Specifications:Pollution generating equipment,air pollution control devices and operations at the facility shall be in accordance with the information and specifications described in the associated NOC application unless otherwise specified by condition in this Approval Order. [Regulatory Basis: ORCAA 6.1.20)] 2. Stack Specifications:There shall be no flow obstructions at the point of discharge from the stack(i.e. cap). However,a weatherproof stack exhaust configuration that does not obstruct the air flow as it exits the stack is acceptable. [Regulatory Basis:WAC 173-460-060,ORCAA 6.1.4(a)(2)] 3. Spray Coating Requirements:The following requirements apply to spray coating activities conducted at the facility: a. The permittee shall confine all spray coating operations to a properly filtered spray booth, preparation station,or mobile enclosure; b. The booth or enclosure in which the spray coating is conducted shall be fitted with a type of filter technology that is demonstrated to achieve at least 98 percent capture of paint overspray (ASHRAE Method 52.1).Published filter efficiency data provided by filter vendors may be used to demonstrate compliance with this requirement; c. Spray Application Methods: Only high-volume low-pressure(HVLP),electrostatic,airless,air- assisted airless equipment or an equivalent technology shall be used in the spray application of coatings;and, d. The permittee shall ensure that filters in the spray booth are properly seated and cover all openings of the exhaust plenum of the spray booth. [Regulatory Basis:WAC 173-400-113(2)(a),ORCAA 6.1.4(a)(2)] Order of Approval Page 1 of 3 NOC_Steve Sims lnc_08NOC635.doc 08NOC635 Approved January 12,2009 4. Opacity Limit:The Spray Booth shall operate at a maximum of 5%opacity as measured by EPA 40CFR Part 60 Appendix A Method 9. [Regulatory Basis:WAC 173-400-113(2)(a),ORCAA 6.1.4(a)(2)] 5. Material Use Limit:The perm ittee shall not use more than the amount specified for each corresponding product specified below,on a consecutive 12-month basis: a. Graphic Activator shall be less than 240 gallons per year; b. Basecoat shall be less than 1000 gallons per year; c. Aliphatic Hardener shall be less than 160 gallons per year; d. Vinyl Topcoat shall be less than 1000 gallons per year; e. Acetone shall be less than 1000 gallons per year;and, f. Color Works Reducer shall be less than 240 gallons per year. [Regulatory Basis:WAC 173-460-070,ORCAA 6.1.2(1)] 6. Operations and Maintenance Requirements:All reasonable measures and precautions shall be taken for minimizing emissions of VOCs and HAPs,including but not limited to: a. Cleaning spray guns in such a way that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects the used gun cleaning solvent.Examples include: i. Hand cleaning of gun parts in a solvent container by flushing solvent through the gun without atomizing the solvent and paint residue or; I Use of a fully enclosed spray gun washer. b. Keeping VOC or HAP-containing materials in closed containers when not being used. c. Storing all solvents or solvent-containing cloth or other material used for surface preparation in closed,airtight containers. d. Minimizing and promptly cleaning up all VOC or HAP-containing material spills and leaks. e. Ensuring that filters are properly seated and cover all openings of the exhaust plenum of the spray booth. f. Monitoring filters on a regular basis and replacing whenever damaged or loaded with particulate build-up to an extent that jeopardizes the effectiveness of the spray booth in capturing and controlling emissions. [Regulatory Basis:WAC 173-400-113(2)(a),ORCAA 6.1.4(a)(2)] 7. Operation Plan:The permittee shall develop,implement,and update when necessary an Operations and Maintenance (OW plan for operating and maintaining air pollution generating equipment and air pollution control equipment at the facility. [Basis: ORCAA Rule 4.3(g)] Order of Approval Page 2 of 3 NOC_Steve Sims Inc_08NO(:635.doc 08NOC635 Approved January 12,2(X)9 I I I I 8. Recordkeeping Requirements: Material use records shall be maintained and updated on a monthly basis. Records shall be sufficient to verify the actual,cumulative amount of VOC or HAP-containing materials used in terms of gallons per month and 12-consecutive month period. Records shall be maintained for at � p least five years,with copies kept on-site for at least two years.At a minimum,records shall include the following: a. Purchase invoices indicating the amount of VOC or HAP-containing materials purchased(paint, hardener,thinners,etc.),date of purchase,and corresponding product identification numbers. b. Record of the actual cumulative use of VOC or HAP-containing materials in terms of gallons per month. c. Material Safety Data Sheets (MSDS) for all VOC or HAP-containing materials used. d. Documentation of the filter efficiency of any spray booth exhaust filter material. e. Documentation from the spray gun manufacturer that each spray gun with a cup capacity equal to or greater than 3.0 fluid ounces(89 cc)that does not meet the definition of an HVLP,electrostatic,airless,or air- assisted airless spray gun,has been determined to achieve an equivalent transfer efficiency to one of these technologies. [Basis: ORCAA Rule 8.11] i I PREPARED BY: Gordon D. Lance Date REVIEWED BY: Mark V. Goodin, PE Date Order of Approval Page 3 of 3 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Approved January 12,2009