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HomeMy WebLinkAboutSEP2008-00146 Re-Issue Determination - SEP Determinations - 1/26/2009 °N-STATE° MASON COUNTY �P C DEPARTMENT OF COMMUNITY DEVELOPMENT O Af U N N Planning Division ° Y C) P O Box 279, Shelton, WA 98584 (360)427-9670 1864 MITIGATED DETERMINATION OF NONSIGNIFICANCE (WAC 197-11-350) SEP2008-00146 Description of Proposal: RE-ISSUE OF EARLIER SEPA DETERMINATION of 10/30/2008 which was withdrawn based on City of Shelton and Port of Shelton need for additional information, which is now received and considered adequate. Manufacturing: Bow dipping and painting. Process consists of chemical pre-treatment, preparation, HVLP applied paint.base coating, chemically activated water transfer dip tank printing, rinse, HVLP applied finish top coating and hot air cure drying. Proponent: SIMS VIBRATION LAB Site Address (If Assigned): 301 W BUSINESS PARK LP SHELTON I, C�, I ''71"CT Directionsto,Site: 301 Business Park Loop, Port of Shelton facility, shelton 19�06C-T i S a 1 VJ,T)Evel-v P rnt1,A i RO A L Parcel Number: 420020062000 Legal Description: S1/2 W OF HY EX 10/147 S 10/144 8/117 PCL 2 OF BLA #94-77 AF#595248 DOR# 11374-001 Lead Agency: Mason County The Lead Agency for this proposal has determined that it does not have a probable significant adverse impact on the environment. An Environmental Impact Statement (EIS) is not required under RCW 43.21 C.030(2)(c). This decision was made after review of a completed Environmental Checklist and other information on file with the Lead Agency. This information is available to the public upon request. MITIGATED MEASURES ARE ATTACHED. Please contact Pam Bennett-Cumming at ext. 287 with any questions. This MDNS is issued under WAC197-11-340(2). There is no comment period for this re-issance. The original determination was withdrawn based on comments from the Port of Shelton, and City of Shelton requesting additional clarification about the project, which has since been provided by the applicant, and found adequate. Date Authorized Local Government Official J I SEPA Contact List MASON CO NTY DCp� ' Y' 00 7 <n<no Sent SEPA a o (check all that apply)on Skokomish Tribal Nation WA Department of Ecology Natural Resources Dept. Environmental Review Section ATTN: Randy Lumper PO BOX 47703 O N 541 Tribal Center Rd. Olympia,WA 98504-7703 Skokomish Nation,WA 98584 sepaunit@ecy.wa.gov rlumper@skokomish.org U.S.Army Corps of Engineers Tribal Historic Preservation Officer SEPA Reviewer-John Pell f m Attn: Kris Miller PO Box C-3755 80 N Tribal Center Rd Seattle,WA 98124 Skokomish Nation,WA 98584 shlanay1@skokomish.org WA Dept.of Fish and Wildlite z ATTN: Margie Schirato (saltwater) r r7 Quinault Indian Nation 2391 W Deegan Rd. rn ATTN: Mark Mobbs Shelton,WA 98584 rf� PO Box 189 schirmms@dfw.wa.gov Tahola, WA 98587 mmobbs@quinault.org ® WA Dept.of Fish&Wildlife ATTN: Gloria Rogers,Area Habitat Biologist Squaxin Tribal Nation 48 Devonshire Rd Natural Resources Dept. Montesano,WA 98563-9618 2952 SE Old Olympic Highway rogergsr@dfw.wa.gov Shelton, WA 98584 jdickison@squaxin.nsn.us Fa WA Dept.of Transportation Alana Hess, Development Review Engineer The Confederated Tribe of the Chehalis P.O. Box 47440 ATTN: SEPA Reviewer-Glen Connelly Olympia,WA 98504-7440 420 Howanut Rd. HESSA@wgdot.wa.gov Oakville, WA 98568 gconnelly@chehalistribe.org City of Shelton 525 West Cota St. Shannon Soto Shelton,WA 98584 WA DNR, South Puget Sound Region jasond@ci.shelton.wa.us 950 Farman Avenue North Enumclaw,WA 98022-9282 Q Port of Shelton shannon.soto@dnr.wa.gov Attn: Patti Miller-Crowley 21 West Sanderson Way Elizabeth Ellis Shelton,WA 98584 WA DNR,Aquatic Resources pattimc@portofshelton.com PO BOX 47027 Olympia,WA 98504-7027 Office of Archaeology& Historic Preservation elizabeth.ellis@dnr.wa.gov ATTN: Lance Wollwage P.O. Box 48343 Boyd Powers Olympia,WA 98504-8343 WA DNR, SEPA Center Lance.Wollwage@dahp.wa.gov PO BOX 47015 Olympia,WA 98504-7015 Tacoma Public Utilities boyd.powers@dnr.wa.gov Real Property Services Attn: Dave Letterman ® Olympic Region Clean Air Agency,John Kelly 3628 S 35th St 2940-B Limited Ln. NW Tacoma,WA 98409-3192 Olympia,WA 98502 john@orcaa.org Applicant: Mason County Transit School District: PO Box 1880 Mason Cty Public Works ATTN: Shelton,WA 98584 Mason Cty Env. Health ATTN: doconnell@masontransit.org Agent: MITIGATED DETERMINATION OF NONSIGNIFICANCE (WAC 197-11-350) SEP2008-00146 CONDITIONS OF THIS DETERMINATION 1) Site is on an area designated in Mason County Resource Ordinance Critical Aquifer Recharge Area Chapter 17.01.080 as a Class II (highly susceptible) Critical Aquifer Recharge Area. Applicants shall comply with all provisions of the CARA chapter including implementation of Best Management Practices identified in their BMP report prepared for Limbsaver by NorthWest Environmetrics Inc, dated October 23, 2008, and attached to this SEPA determination. x - 2) As provided for in the Mason County Resource ORdinance, proposal shall be compliant with and permitted by all other necessary reviewing agencies including Olympic Regional Clean Air Authority. X 3) Subject to all provisions and requirements of Olympic Region Clean Air Authority Notice of Construction 08NOC635. x 4) Subject to all provisions of Best Management Practices Report completed for Limbsaver/Sims on October 22, 2008 by Northwest Envirometrics Inc., and updated to include Respiratory Protection Program approved December 22, 2008. All painting processes have 100% secondary containment. No more than 10 gallons of paint to be kept on site at any time. x Sims Vibration Laboratory supplemental information for SEPA checklist SEP2008-00146 Note: the information below is based on applicant response to Mason County's request for additional information, to supplement the SEPA responses. 1. Project description: Please describe the project proposal, including the Water Transfer Painting process, so it is understandable to an outside reader. Provide information on quantities of materials to be stored on site at a given time, and quantities projected to be used over a specific time period. This project is aimed at streamlining processes at Sims Vibration Laboratory and bring more processes into our own control. Specifically we propose to bring all painting and coating processes for our several products in-house. The proposed Water Transfer Printing facility will operate as follows: Aluminum parts are machined and transferred to the coating facility; Parts are washed and etched to receive base-coat paint; Parts are taken to paint booth and sprayed with HVLP base-coat paint; Once dry,parts are taken to water transfer printing tank. Tank consists of a 500 gallon tank filled with hot water, a film with printed graphics is applied with a micro layer of chemical activator and laid out on surface of water,parts are lowered into the film and submerged in water,the pressure of the water wraps the film around the part coating it with the desired graphics, excess activator is collected in small trough on one side of the tank and recycled; Parts are washed in a hot water wash conveyor; Once dry parts are taken back to paint booth where they are coated with a Low-sheen clear top-coat. A maximum of 10 gallons of paint will be stored in the facility at any given time, for details see response to question 3 below. The proposed project annual usage is as follows: 60 gallons reducer,* 60 gallons activator,* 40 gallons paint hardener,* 250 gallons each Basecoat and Topcoat.* *See attached MSDS sheets I 2. Methods to reduce or control emissions or other impacts to air: Please describe both the process and the equipment that will control emissions. Emissions are initially reduced by the choice of Low VOC coatings. SVL has determined the best possible coatings with minimal environmental impact. ORCAA or the Olympic Region Clean Air Agency will review proposed materials and make final determination on air quality. ORCAA will also conduct semi-annual inspections to ensure compliance to applicable permits and regulations. In addition SVL has contracted NorthWest Envirometrics, Inc. to conduct additional air quality testing on an as needed basis or when a process change needs to occur. The paint booth is the main source of emissions from the facility and will be equipped with standard approved painting particulate(HEPA) filters to eliminate paint release into the air. VOCs will be at a controlled level as stated in ORCAA permits (see attached draft ORCAA permit). The Respiratory Protection Plan is in compliance with 29 CFR 1910-134 as required for Employees who will wear an air purifying respirator more than 30 days a year(painter working inside a spray paint booth) and workers who may be exposed to materials exceeding Permissible 1 Exposure Limits(PELs) as set by OSHA or Recommended Exposure Limits(RELs) as set by the American Congress of Governmental Industrial Hygienists(ACGIH). 3. Could waste materials enter ground or surface waters? if so, generally describe: No,there is full primary and secondary containment. SVL will store only 10 gallons of paint in the facility at a given time,which will be contained by a manufactured Spill Pallet which is designed to hold 50 gallons of liquid. Each water tank(i.e. dip tank,wash conveyor tank)will have a spill containment area constructed to contain 100%of overflow liquid in a urethane barrier. In addition SVL will determine the best possible containment in the case of failure to the overflow area which will include super-absorbent spill mats and containment socks. Spill response kits (pads,booms, etc.)will be stored on-site and readily available for deployment in the event of a spill or release. See also BMP Plan. Waste materials will be removed by American Petroleum Environmental Services employing HAZWOPER trained personnel, in compliance with D.O.T. Regulations (49 CFR,parts 100— 177)using a vacuum truck and utilizing on-site spill response kits, as necessary during transfer operations. In addition, American Petroleum Environmental Services maintains one million dollars in environmental insurance for cleanup in the event of a spill or release. Per the attached Best Management Practices Plan, spill control and containment kits will be located on-site in the event of a catastrophic spill or release. Risk is further limited by the small amount of materials stored and used on-site(10 gallons), open at a given time(far less), and secondary containment for all processes and material storage equipment. In the event of a spill, subsequent remedial actions would be guided by the Best Management Plan, and would require such actions absorption, retention in plastic tarps, over-packs, and the immediate removal of any contaminated material. The building is designed without floor drain,to preclude release to the outside. Any initial actions would be done by trained SVL employees with any additional work being done by American Petroleum Environmental Services, at the direction of the Port of Shelton, and the Washington State Department of Ecology SWRO. All SVL employees will be trained to implement emergency response operations in compliance with WAC 296-62-824, and NFPA 472 (2008) edition. 4. Threatened or endangered species: Shelton Pocket Gopher(State candidate and local species of importance). Streaked horned lark. Habitat is managed through Port Habitat Management Plan. This project will have no effect on the species,who are not present in the built area. There will be no changes to the existing environment in relation to flora, ground water, or soil features. There is no plan to change any external features of the facility as it exists today. Currently, the Port Habitat Management Plan covers a total of 787 acres. The proposed plan for indoor operations, will not affect any existing habitat for these or any other species of wildlife. 5. Hazardous materials stored/used on site: All documents have been revised to state that a total of 10 gallons of hazardous material (paint) will be stored on-site. (As noted in the revised BMP and SEPA documents rev. 12/4/2008) 2 6. What will be the frequency of monitoring of the site by Northwest Envirometrics, ORCAA, DOE, other agencies? NWEI will conduct on-site and off-site air monitoring during startup operations to measure any air emissions inside the work area during paint operations. This is to protect the workers inside the facility and to assure no toxic emissions are released from the facility. NWEI will also conduct monitoring any time there is a change in the operations process in terms of the amount of paint products being used or the duration of operations. NWEI maintains one million dollars in liability insurance for errors or omissions. ORCAA will conduct semi annual inspections to determine if the facility is in compliance with their permit requirements. DOE will inspect the site as a regulated Hazardous Waste Generator. Frequency will depend on the amount of wastes generated on an annual basis. If there is a spill or release of regulated materials,the site will be subject to inspection and subject to administrative action. Mason Co. Fire Marshal will also conduct annual inspections for fire or other industrial hazards on an annual basis. Port of Shelton has the authority to inspect the facility as a leased facility. This can be done any time the Port deems necessary as part of their lease agreement. Labor and Industries will also make inspections any time there is a complaint filed regarding unsafe work conditions or any time an employee files a L&I claim for any work related injuries. I 7. Please clarify why the BMP Plan is written as though the project is completed, rather than under review, so this is not confusing to readers of the SEPA. *Olympic Region Clean Air Agency will provide a copy of their permit document to the County for inclusion in the updated SEPA documents. The ORCAA application was submitted and tentative verbal approval was indicated at the time the BMP was written. II 3 I f I Y 1 3' ffa �., uti- cony 10'-,, a i3 veer Co un,t Fine.Gondain.nanfi i `\ 18' 2° 4 /vl �56' Ng/�Perma»e.nt-irle¢'41/ahin ,,� ' . ' N�Ctbh�Rins� `yam` SQS nlJ � n \` MAXIM L,ENGM..1`0t 1 PATN5 Floor flan W6 Proposed Charges /16'-1-0' IP3PAi10N -POW PIPPING FACILITY DEVELoPMENt RO �c. � z MASON CO. ENVIROMENTAL CHECKLIST A. BACKGROUND 1. Name of proposed project, if applicable: Sims - LIMBSAVER, Water Transfer Paint Facility 2. Name of applicant: li ant: Steven Sims Inc. 3. Address and phone number of applicant and contact person: Mr. Drew Stephens 301 W. Business Park Loop Shelton Wa. 98584 Phone # 427-6031 4. Date checklist prepared: 12/5/2008 5. Agency requesting checklist: Olympic Clean Air Agency, Mason County Community Development, PAC 6. Proposed timing or schedule (including phasing, if applicable): Within 90 days (following approval ) 7. Do you have any plans for future expansion, or further activity related to or connected with this proposal: If yes, explain. No 8. List an environmental information you know about that has been prepared, or will be � y y P P prepared, directly related to this proposal. Best Management Practices, NorthWest Envirometrics 10/22/2008 Respiratory Protection Plan, NorthWest Envirometrics 10/28/2008 *Attached. 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. No 10. List any government approvals or permits that will be needed for your proposal, if known. ORCAA - Notice of Construction Permit 11. Give a 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.) This project is to renovate an old building, pre- viously used for manufacturing, into a modern, State-of-the-art Water Transfer Paint Facility. This will include a parts washing maching, a paint transfer dipping station, a small spray paint booth, and an area for hot air drying painted parts. This will include engineering controls for air ventilation/filtration, secondary containment for all wet operations, and energey effic- ient appliances/applications . 12. What i the location of the proposal? Give sufficient information for person to understand the a s e a p p 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. 121 West Development Rd. Shelton Wa. This is an existing 2000 Sq Ft building di g located on the Port of Shelton Property, adjacent to the Sims LIMBSAVER building at 301 Business Park Loop Rd. Both facilities are located in Mason County. B. ENVIRONMENTAL ELEMENTS: 1. EARTH: a. General description of the site (circle one):0 rolling, hilly, steep slopes, mountainous, other b. What is the steepest slope on the site (approximate percent slope)? None C. 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. Glacial till, 2"minus rock d. Are there surface indications or history of unstable soils in the immediate vicinity: If so, describe. None Mason Countv Environmental Checklist Pace 2 e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. Indicate source of fill. None f. Could erosion occur as a result of clearing, construction, or use: If so, generally describe. No g. About what percent of the site will be covered with impervious surfaces after project constructions (for example, asphalt or buildings)? Exisitin building covers 2000 Sq.Ft. No additional coverings will be part of this project. h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: None 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. Ventilation: Paint dipping area filtered air at 200 cfm Spray paint booth 24" filtered system at 5 ,500 cfm. No VOCs will be discharged into the atmosphere b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe. No Mason Countv Environmental Checklist Page 3 I C. Proposed measures to reduce or control emissions or other impacts to air, if any: Ventilation: Paint Dipping Area, filtered 200 cfm system Sprat Paint Area 24" filtered 5, 500 cfm system *Respitory Protection Plan Attached Air monitoring for VOC emissions by NorthWest Envirometrics 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. None Does not apply 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, Does not apply 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. None Mason Countv Environmental Checklist Page 4 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. None 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. None 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 - The closest Septic Stsyem is located in a seperate building located 100 feet west of this existing structure. There are no existing storm drains or sanitary sewers on this site. C. Water runoff (including storm water): 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 flow into other waters? If so, describe. None - Does not apply 2) Could waste materials enter ground or surface waters: If so, generally describe. None Mason Countv Environmental Checklist Pane 5 d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any: None 4. PLANTS: a. Check or circle types of vegetation found on the site: deciduous tree: alder, maple, aspen, other evergreen tree: fir ,edar, 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 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: None I Mason Countv Environmental Checklist Page 6 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: yes hawk, heron, eagle so other Mammals: eer ,bear, elk, beaver, other Fish:no bass, salmon, trout, herring, shellfish, other b. List any threatened or endangered species known to be on or near the site. None C. Is the site part of a migration route? If so, explain. No d. Proposed measures to preserve or enhance wildlife, if any: None 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: Heating, ligh+'ing, painting equipment. 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: it Use of energy efficient, lighting, heating, and appliances. Mason Countv Environmental Checklist Page 7 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. Qt,ct eel-t_ Yes 1 gallon paint cans ( 10 ) containing VOCs and metal cleaner containing <5% Hydroflouric acid. Employes will be train- ed to handle small spills on site. 1) Describe special emergency services that might be required. Normal firefighting response operations . 2) Proposed measures to reduce or control environmental health hazards, if any: Engineering controls: Ventelation, secondary contaiment (all pro- cesses. use of absorbent pads/pillows, explosion proof electrical applications, and employee training. * See RPP attached 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)? Indicate what hour's noise would come from the site. None 3) Proposed measures to reduce or control noise impacts, if any: None - Does not apply B. LAND AND SHORELINE USE: a. What is the current use of the site and adjacent properties? J P P This site will be used for light manufacturing, consistent with all of the surrounding sites in the AREA. Mason Countv Environmental Checklist Paee 8 b. Has the site been used for agriculture? If so, describe. No C. Describe any structures on the site. The existing structure is an old ( 1940s ) steel building with concrete floors . The building is 100 feet long and 20 feet wide. Thete are no existing septic systems, storm drains or sewers . d. Will any structures be demolished? If so, what? No e. What is the current zoning classification of the site? Commercial Business f. What is the current comprehensive plan designation of the site? Mason County Urban Growth Area (UGA) g. If applicable, what is the current Shoreline Master Program designation of the site? Does not apply h. Has any part of the site been classified as an "environmentally sensitive" area? If so, specify. Yes Class II Critical Aquifer Recharge area (CARA) i. Approximately how many people would reside or work in the completed project? ( 4 ) j. Approximately how many people would the completed project displace? ( 0 ) None k. Proposed measures to avoid or reduce displacement impacts, if any: None Mason Countv Environmental Checklist Pare 9 i I. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any: None - This is a pre-existing facility. 9. HOUSING: a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing. Does not apply b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing. Does not apply C. Proposed measures to reduce or control housing impacts, if any: Does not apply 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? pre-existing metal siding consistent with adjacent buildings . b. What views in the immediate vicinity would be altered or obstructed? None C. Proposed measures to reduce or control aesthetic impacts, if any: None - pre-existing structure Mason County Environmental Checklist Page 10 11. LIGHT AND GLARE a. What type of light or glare will the proposal produce? What time of day would it mainly occur? None 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: None - does not apply 12. RECREATION: a. What designated and informal recreational opportunities are in the immediate vicinity? Regional Airport activities , State Patrol training Academy Bus Driver Training area, Skydiving, walking & jogging. b. Would the proposed project displace any existing recreational uses? If so, describe. None C. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any: None - will be no impact III i Mason Countv Environmental Checklist Paize 11 i i Washington, United States, North America �102 W Dayton Airport Rd Q Sims Paint Facility IV101 w Sanderson way / .0^ �...., Sanderson N Field ro 0 mi 0.2 0.4 0.6 Copyright 0 1988-2005 Microsoft Corp.and/or its suppliers.All rights reserved.http:/Avww.microsoft.com/streets/ 0 2004 NAVTEQ.All rights reserved.This data includes Information taken with permission from Canadian authorities 0 Her Majesty the Queen in Right of Canada.0 Copyright 2004 by TeleAtlas North America,Inc.All rights reserved. 13. HISTORIC AND CULTURAL PRESERVATION: a. Are there any places or objects listed on, or proposed for, national, state, or local preservation registers known to be on or next to the site? If so, generally describe. None b. Generally describe any landmarks or evidence of historic, archaeological, scientific, or cultural importance known to be on or next to the site. None C. Proposed measures to reduce or control impacts, if any: None 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. See attached map. b. Is site currently served by public transit? If not, what is the approximate distance to the existing street system? Show on site plans, if any. Yes - 0 .3 miles to transit stop. C. How many parking spaces would the completed project have? How many would the project eliminate? ten ( 10 ) None eliminated. Will be utilizing existing parking area 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 Mason Countv Environmental Checklist Page 12 e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe. Yes . Within 1 mile of the Shelton Airport f. How many vehicular trips per day would be generated by the completed project: If known, indicate when peak volumes would occur. Peak operation will be 4 vehicles at 7 :00 am leaving at 4 :00 pm monday through friday. g. Proposed measures to reduce or control transportation impacts, if any: No significant traffic impact 15. PUBLIC SERVICES: a. Would the project result in an increased need for public service (for example: fire protection, 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: None Mason Countv Environmental Checklist Nee 13 16. UTILITIES: a. Circle utilities currently available at the site: (-electricity,-natural gas, elepheAg,�sanitary sewer, septic system, other: 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. The general construction activities include the wiring and con- nection of the equipment relating to the proposed project to include Hot Air Drying enclosure, Spray Paint Booth, Air filters and ventilation system. 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: Date submitted: �Z�O�S ZP20S Mason Countv Environmental Checklist Paee 14 When answering these questions,be aware of the extent of the proposal, or the types of activities likely to result from the proposal, would affect the item at a greater intensity or at a faster rate than if the proposal were not implemented. Respond briefly and in general terms. 1. How would the proposal be likely to increase discharge to water; emissions to the air; production,storage,or release of toxic or hazardous substances; or production of noise. There should be no increased emissions resulting from this project. a. Proposed measures to avoid or reduce such increases are: There will be no off site air emissions due to the painting process. All painting will be done in ventilated areas with a high efficiency VOC filtration system to eliminate vapors. Liquids are all contained in areas that have secondary containment using urethane walls to catch>100%of any process liquids. Wastes will be contained in self cleaning paint and washing appliances until removed on a quarterly basis by American Petroleum Environmental Services. Paint products containing VOCs will be shipped and stored in one (1) gallon containers and used as necessary. These containers will be stored on a chem.-pallet that has secondary containment for up to 60 gallons of product built into the pallet. No more than ten(10) gallons of paint will be stored on-site at any time. There should be no increase in noise outside the work area due to the nature of the paint activities. NorthWest Envirometrics Inc. will monitor for air and noise emissions to insure compliance when the facility becomes operational. 2. How would the proposal be likely to affect plants,animals,fish,or marine life? There will be no affect on plants, animals, fish,or marine life. a. Proposed measures to conserve plants, animals,fish, or marine life are: None 3. How will the project likely deplete energy or natural resources ? 1 There will be no impact on energy or natural resources. a. Proposed measures to conserve energy and natural resources ? This project will conserve energy by implement energy efficient lighting,heating, and energy efficient appliances. This will be an upgrade from the facility's former use. 4. How would the proposal be likely to use or affect environmentally sensitive areas or areas designated (or eligible or under studyaaaaaa0 for governmental protection; such as parks,wilderness,wild and scenic rivers,threatened or endangered species habitat, historic or cultural sites,wetlands,floodplains,or prime farmlands ? There will be no affect or impact on the listed areas. a. Proposed measures to protect such resources or to avoid or reduce the impacts are: None 5. How would the proposal be likely to affect land and shoreline use, including whether it would allow or encourage land or shoreline uses incompatible with existing plans.? There will be no affect on land, shorelines, or existing plans. a. Proposed measures to reduce shoreline and land use impacts are: None 6. How would the proposal be likely to increase demands on transportation or public services and utilities ? There will be no impact. a. Proposed measures to respond to such demand(s) are: None 7. Identify, if possible,whether the proposal may conflict with local, state, or federal laws, or requirements for the protection of the environment: II There are no conflicts *See Best Management Practices Report(*attached) 2 E. SIGINATURE I,the undersigned, swear under the penalty of perjury that the above responses are made truthfully and to the best of my knowledge. I also understand that, should there be any willful misrepresentation or willful lack of full disclosure on my part,the agency may withdraw any Determination of Nonsignificance that it might issue in r 'ance u this check list. Date:—I Z jou �LCx0g Signature: �' Please print or type: Proponent: Steven Sims Inc. Address 50 Rose Nye Way, Shelton Wa. 98584 Phone: (360)427-6031 Person completing this form (if different than the proponent): Name: Roy. C. Glass, CHMM, President/CEO NorthWest Envirometrics Inc. Address: 170 Wildwood Dr. SE, Shelton Wa. 98584 Phone: (360) 427-3288 3� �D I 3 BEST MANAGEMENT PRACTICES REPORT October 22, 2008 Prepared For: LIMBSAVERj/� Steven C. Sims, President/C.E.O. - 301 W Business Park Loop Shelton, Wa. 98584 �© (360)427-6031 o CU �o A. (Qualifications: NorthWest Envirometrics Inc. (est. 1999) is a fully certified environmental consulting firm consisting of eight environmental professionals who each, have over 25 years of field experience in Environmental Health and Safety. (see attachments) Mr. Roy C. Glass, President/C.E.O. holds a B.A. Degree in Political Science from Washington State University, and is a Certified Hazardous Materials Manager(CHMM#6825)by the Academy of Hazardous Materials Managers, and the Institute of Hazardous Materials Management(IHMM). These credentials are internationally recognized and accepted by;the World Safety Organization, and f the State of Washington(Department of Ecology). B. On Site Inspection: On October 20, 2008, an on-site assessment was done at the LIMBSAVER "Bow Dipping Facility"adjacent to 301 W. Business Park Loop. Mr. Drew Stephens represented LIMBSAVER. �CARD �vT ( �1 t"1 _r'DrUE:�'Zp M ei'4T Facili 7F'04a::> The building is an old(1940s) steel building with concrete floors. The building is 100 feet long and 20 feet wide(2,000 sq/ft). There are no existing, exterior storm drains or interior, sanitary drains. The building has been divided into two sections: 1)containing a self contained spray paint booth with a filtered 24 inch exhaust fan/vent,and a paint drying room. 2) The second half of the facility contains a self contained washer/conveyor, and a 500 gallon water transfer printing tank. Note* floor plan attached 1 I The spray paint booth was in full compliance of the Clean Air Act(40-CFR 126 f) and approved by the Department of Ecology, Olympic Region Clean Air Agency, and the Mason County Fire Marshal. The washer/conveyor is a stainless steel, self contained unit that utilizes hot water and a< 5 %phosphoric acid solution to wash parts prior to painting. It holds a maximum of 200 gallons of water that is captured, filtered and re-used during the wash process. There is no floor drain or discharge from this equipment. In the event of a spill or release of process water,the washer/conveyor is fully enclosed in a urethane enclosure that will provide secondary containment for 100% of the process water. Note* Material Safety Data Sheets attached cleaner/etcher(Chem Cote 3406) Not regulated under SARA 313 CERCLA RQ. =5,000 pounds Total process water= 1,600 pounds The water transfer printing tank is a stainless steel tank that holds a maximum of 500 gallons of process water. The water is used to float a transfer film that is bonded to the parts being treated. The tank has a stainless steel collection tray and filter, to catch water as the parts are removed from the tank. In addition,this tank is also fully enclosed in a 4ft. x 8 ft.x 12 in. urethane tub to provide for 100% secondary containment. The CHEM-COTE products used in this process are painting products (flammable liquids)contained under hooded 10 inch ventilation system. Construction and application are in compliance with article 80 of the Uniform Fire Code as approved by the Mason County Fire Marshal. Paint products will be stored in I gallon containers on a spill containment pallet with a maximum amount of 10 gallons/containers on site at any time. Note* MSDS Sheets attached(painting products) All process water, for both systems is scheduled to be removed for, treatment, and disposal at 90 day intervals by: American Petroleum Environmental Services 2117 River St. Tacoma, Wa. 98421 (253) 538-5252 2 In the event of a spill or release, American Petroleum Environmental Services would be called to remove the process water from the secondary containment systems. Note* Both of the above processes are exempt from additional Spill Prevention Countermeasures and Control Planning(40 CFR 112)SPCC Oil Spill Response Plans. This facility was designed and constructed to meet those requirements. Training: LIMBSAVER is compliant with 29CFR 1910-1200 "Hazard Communication Standard"and has provided initial and recurrent training for all employees. LIMBSAVER has developed a Facility Response Plan(FRP as required under(29 CFR 1910— 120) Prior to operating the Bow Dipping Paint Facility, LIMBSAVER will provide additional training for employees (4)assigned to that process that will include spill response protocols, application of absorbent materials(spill kits), and personal protective equipment. (respirators, eye protection, splash protection). LIMBSAVERS has retained NorthWest Envirometrics Inc.to provide them with a written Respiratory Protection Plan as required under 29 CFR 1910— 134. (This plan was completed November 1, 2008.) * Note plan attached C. WAC 173-303 Compliance: LIMBSAVERS has agreed to comply with WAC 173-3-303-145 "Spills and Discharges into the Environment". Protocols will include immediate notification to: local authorities(911), immediate notification to the Department of Ecology Northwest Regional Office 407-6300, and The Port of Shelton(Al Frey)493- 4005. LIMBSAVER employees will provide spill control countermeasures per their protocols and training. American Petroleum Environmental Services will provide personnel and equipment for cleanup and post emergency response (WAC 296-62- 824) Engineering controls(secondary containment, absorbent pads/booms and ventilation)will confine all releases to the interior of the facility. D. Findings: LIMBSAVER is utilizing a new"state of the art"process in the application, design and construction in painting in the"Bow Dipping Facility". This process is more 3 environmentally friendly and generates less hazardous wastes,than traditional methodologies. They have implemented additional safety measures by integrating additional engineering controls, and have addressed worker health and safety issues. It is the opinion of NorthWest Envirometrics Inc. that LIMBSAVER has employed the best possible current site management practices in: planning, constructing,training, and operations for this facility. Sincerely; Mr. Roy HMM#6825 President/CEO,NorthWest Envirometrics Inc. 170 Wildwood Dr. SE Shelton, Wa. 98584 426-7949 4 I RESPIRATORY PROTECTION PROGRAM LIMBSAVER Sims Vibration Laboratory PREPARED BY: NorthWest Envirometrics Inc. October 28 2008 Approved By: Approval Date: I Z W6 {CSC � � I�� LIMBSAVER Sims Vibration Laboratory TABLE OF CONTENTS 1.0 SCOPE................................................................................................................... 1 2.0 APPLICABILITY..................................................................................................... 1 3.0 REQUIREMENTS.................................................................................................. 1 3.1 Access to Information................................................................................2 3.2 Responsibilities.........................................................................................2 3.3 Types of Respirators.................................................................................3 3.4 Selection....................................................................................................3 3.5 Fit Testing and Medical Evaluation...........................................................4 3.6 Training......................................................................................................4 3.7 Inspection..................................................................................................5 3.8 Respirator Use ..........................................................................................5 3.9 Cleaning ....................................................................................................6 3.10 Storage......................................................................................................6 4.0 PROGRAM EVALUATION.....................................................................................6 i ilk LIMBSAVER Sims Vibration Laboratory 1.0 SCOPE This Respiratory Protection Program (RPP) establishes the LIMBSAVER requirements for all employees who will be required to wear respirators. The RPP supplements the existing Emergency Response Plan, and establishes policy for respiratory protection. Contractors, vendors, and suppliers will also be required to comply with this program or their own program, whichever is more restrictive. This program applies to all activities that require respirators at any LIMBSAVER facility, and for emergency response operations. 2.0 APPLICABILITY This guideline is applicable to all LIMBSAVER employees who are required to wear respirators during their on-the-job work activities. It provides instructions for the proper selection, training, fitting, use, and care of respiratory protection devices. This RPP complies with the federally mandated requirements cited at 29 CFR 1910.134(c) Respiratory Protection Program. 3.0 REQUIREMENTS LIMBSAVER, (the employer) shall develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. NorthWest Envirometrics Inc. (NWEI) being, fully qualified, has the appropriate training and experience, acting as the environmental compliance consultant for LIMBSAVER, shall perform services as necessary to assure compliance. Mr. Steven Sims, President/CEO will be the designated RPP Administrator. Additionally, certain program elements may be required for voluntary use of respiratory protective devices in order to prevent potential hazards with the use of; painting, washing, and bow dipping equipment. Respiratory protective equipment shall be used only when effective engineering controls are either not feasible or are insufficient to eliminate or reduce exposure to known respiratory hazards. Acceptable engineering controls to eliminate the need for respiratory protection include: • Operation enclosure • General ventilation • Local exhaust ventilation, or • Material substitution If not already available, air monitoring shall be performed to determine air contaminant concentrations upon the issuance of a respirator. Only NIOSH (or appropriate regulatory agency) certified respirators, deemed appropriate based on the respiratory hazard(s) and workplace and user factors that affect respirator performance and reliability will be used. Each respirator shall be used in compliance with the conditions of its certification. Respirators shall be equipped with the proper and appropriate filtering cartridges as determined by the potential hazardous atmospheres. Personnel shall be not assigned tight-sealing respirators if they wear a beard or other facial hair that inhibits proper seal of the respirator. Additionally, personnel shall not be assigned tight-sealing respirators if the wearer's anatomical facial features preclude the effective use of the respirator. The fitness and ability to wear a respirator shall be ascertained for each employee prior to respirator assignment and donning. Contact lenses shall not be allowed with the use of full-face respirators. When a respirator is found to be defective, the RPP Administrator shall be contacted to assist in obtaining a new respirator or to assist in replacing defective respirator parts. All respirator and cartridge selections shall be reviewed and authorized by the RPP Administrator. Respirators shall be only used for work practices or conditions for which they were assigned. 1 LIMBSAVER Sims Vibration Laboratory 3.1 Access to Information and Training Materials Affected personnel shall have access to a copy of this written program and to the specific requirements of the Respiratory Protection regulation cited at 29 CFR 1910.134. (Appendix A) 3.2 Responsibilities The following persons shall be responsible, at a minimum, for actions as indicated below: Personnel assigned respirators shall: • Complete medical questionnaires and any other medical clearance activity as required. • Be properly fit-tested (Qualitative&Quantitative) and trained prior to using any respirator. • Inspect respirators on a quarterly basis, and before and after each use. • Clean respirators as often as necessary to be maintained in a sanitary condition. • Use respirators only for intended applications and only when necessary to reduce exposure to potentially harmful levels of airborne contaminants. • Not use a respirator that is malfunctioning, defective, or is missing parts. • Report any malfunctioning, defective, or missing parts to their supervisor. • Perform positive and negative fit tests prior to each respirator use. Management/Supervisors shall: • Ensure personnel under their supervision wear respirators when required. • Ensure personnel enrolled in the respiratory program follow the requirements outlined in this procedure. • Ensure that all personnel using respiratory protection have received training and a medical respirator evaluation. RPP Administrator(Mr. Steven Sims)shall: • Function as the RPP Administrator, (or) shall assign a suitable designee. • Provide professional compliance services to facilitate and implement the RPP. • Provide industrial hygiene services adequate to ensure proper application and selection of respiratory equipment. • Provide guidance in determining appropriate engineering controls to be implemented in lieu of respiratory protection. • Provide annual personnel training and fit-testing. Health Services/Medical/Healthcare Provider shall: • Conduct initial and annual medical evaluations on all personnel prior to issuing a respirator to ascertain their fitness for using such protection. 2 LIMBSAVER Sims Vibration Laboratory 3.3 Types of Respirators The LIMBSAVER respirator of choice shall be the: MSA(or similar)'/z face masks. Approved cartridges used in LIMBSAVER facilities and emergency operations shall be the following: Volatile Organic Vapor Cartridges designed and approved for these air purifying respirators. • Are not approved for atmospheres immediately dangerous to life or health (IDLH). • Do not supply oxygen. They must not be used in oxygen-deficient atmospheres (<19.5% oxygen), in poorly ventilated areas, or in enclosed spaces where the concentration of a contaminant is unknown and/or unstable. • Are approved for low concentrations of the specified contaminant. If employees smell or taste the contaminant, sense irritation, or breathing becomes difficult over a short period of time while wearing any respirator, they shall leave the contaminated area immediately. • A change schedule shall be implemented for canisters or cartridges, that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. Similar respiratory protective devices (facepieces and cartridges) from other manufacturers may be approved and used as needed. Alternative respiratory protective devices must by evaluated and approved for use by the RPP Administrator. 3.4 Selection Respirator selection shall be governed by the following factors: • The type and nature of the respiratory hazard • The extent of the respiratory hazard • Characteristics and limitations of available respirators • Work requirements and conditions Personnel shall be allowed to select the most comfortable respirator from various sizes and manufacturers. Employees will use their own equipment and will not share their respirators with other employees. Prior to the selection process, the employee shall be shown how to don a respirator, position it on the face, set strap tension, and assess a "comfortable fit." Unless inappropriate for the identified hazard, selection will begin with half-mask respirators. If an employee cannot be fitted with a half-mask respirator, he/she will either be fitted with a full-face or removed from the respiratory protection program and reassigned to an activity that does not require respirator use. If the employee is not familiar with using a particular respirator, he/she shall be directed to don the mask several times and to adjust the straps each time, so that they become adept at setting proper tension on the straps. Assessment of comfort shall include reviewing the following points with the employee: • Positioning of mask on the nose or face • Strap tension • Fit and seal across nose bridge and face • Tendency to slip • Adequate time for assessment 3 LIMBSAVER Sims Vibration Laboratory Personnel shall then conduct the conventional negative and positive pressure fit checks to determine the proper seal. See the Respirator Use section (3.8)of this document for instruction on positive and negative face fit tests. After successfully completing the fit checks, the employee shall be questioned again regarding the comfort of the respirator. If it has become uncomfortable, another model of respirator shall be evaluated. 3.5 Fit Testing and Medical Evaluation A medical evaluation shall be conducted to determine the employee's ability to use a respirator, before they are fit tested or allowed to use the respirator in the workplace. After receiving medical approval, personnel shall be properly fitted by qualified personnel and taught how to wear, adjust, and fit the respirator. Personnel shall also receive an explanation as to why a particular type of respirator has been selected. Personnel using a tight-fitting facepiece respirator must pass an appropriate qualitative fit test(QLFT) or quantitative fit test(QNFT). All personnel must be fit tested with the same make, model, style, and size of respirator that will be used. The RPP Administrator will determine the fit test methodology. A fit test should be conducted prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model, or make) is used, and at least annually thereafter or whenever visual observations are made with changes in the employee's physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight. A record of the qualitative and quantitative fit tests administered should be maintained and shall include: • The name or identification of the employee tested • Type of fit test performed • Specific make, model, style, and size of respirator tested • Date of test • The pass/fail results for QLFTs or the fit factor and strip chart recording or other recording of the test results for QNFTs. Medical monitoring may be discontinued when the employee is no longer required to use a respirator. 3.6 Training Prior to issuance of any respiratory device for use, personnel shall undergo a training program designed to provide the following information: • Discussion of engineering and administrative controls in use and why respirators are needed. • Selection of respiratory protection, including: manufacturers' conditions, hazardous substances(s) for which that respirator is provided, cartridge or filter type(s), and consequences of not wearing the respirator properly. • Proper use, including fit checks and cartridge changing. • Storage, cleaning, inspection, and maintenance of respiratory devices. • Capabilities and limitations of respiratory devices. • Lung anatomy and defense mechanisms. • Contaminant(s) route of entry. 4 I LIMBSAVER Sims Vibration Laboratory • Conditions to avoid, symptoms of exposure, Permissible Exposure Limits(PELs) /Threshold Limit Values (TLVs). • Odor threshold versus TLVs. • Particle size. Training shall occur annually for all respiratory program participants. The RPP Administrator shall ensure that training is comprehensive and understandable. 3.7 Inspection All respirators shall be inspected by the user for the following conditions prior to each use: • Excessive dirt. • Cracks, tears, holes, or distortion. • Inflexibility. • Cracked or broken cartridge holders; missing gaskets. • Torn or cracked inhalation and/or exhalation cartridges. • Malfunctioning buckles or head straps and/or head harness; breaks in straps. • Incorrect cartridge for respirator hazard. • Cracks or dents in outside case of cartridge. 3.8 Respirator Use The seal of the respirator on the face shall be fit-checked prior to each use by performing positive and negative pressure face fit checks as follows: • Place the cartridge filter in the retainer and rotate clockwise until tight. Twisting too tightly can result in distortion and may cause leakage. • Place the respirator over the mouth and nose, and then pull the head harness over the crown of the head. • Take the bottom straps in both hands, place them in back of the neck, and hook them together. • Pull the ends of the head harness and bottom straps to adjust the tightness. Positive Pressure fit check Employees shall place the palms of their hands over exhalation cover and exhale gently. If the facepiece bulges slightly and no air leaks between the face and the facepiece are detected, a proper fit has been obtained. If air leakage is detected, they shall reposition the respirator on the face and/or readjust the tension of the elastic straps to eliminate the leakage. If they cannot achieve a proper fit, employees shall not enter the work area with potential exposure. In these cases, employees shall contact their supervisor. Negative Pressure fit check Employees shall place the palms of their hands (alternatively, pieces of cardboard or surgical gloves can be used to cover the openings) over the open area of the cartridge cap, inhale gently and hold their breath for five (5)to ten (10) seconds. If the facepiece collapses slightly, a proper fit has been obtained. If air leakage is detected, reposition the respirator on the face and/or readjust the tension of the elastic straps 5 LIMBSAVER Sims Vibration Laboratory to eliminate the leakage. If they cannot achieve a proper fit, employees shall not enter the work area with potential exposure. In these cases, employees shall contact their supervisor. If odors of vapors or gases become noticeable or breathing resistance becomes excessive, the cartridges have served their useful life and need replacement. 3.9 Cleaning All respirators shall be cleaned by the personnel assigned to use them. The respirator shall be cleaned as often as necessary to be maintained in a sanitary condition. Alcohol-free cleaning wipes and a dry cloth shall be used to clean all face pieces. A solution of disinfecting soap and water may also be used. Face pieces shall be thoroughly dried after cleaning. 3.10 Storage All respirators and cartridges shall be stored in an area free of dirt, debris, or other forms of contaminants. They shall be not exposed to chemicals during storage. All respirators shall be stored in such a way as to prevent kinking, distortion, or other damage. Storage areas shall not be subject to extreme heat or cold. All respirators shall be stored in a clean, dry, and sanitary location. Clean, sealed bags shall be used to store respirators. All respirators shall be stored in area(s)that provide easy access to the user. 4.0 PROGRAM EVALUATION The Respiratory Protection Program shall be evaluated on an annual basis in order to monitor the effectiveness of the program elements and regulatory requirements. The RPP Administrator shall be responsible for performing this annual program evaluation. The program evaluation shall encompass the following elements: - selection of respirators - medical evaluation of program participants - fit testing procedures - use of respirators (required and voluntary) - maintenance and care of respirators - identification of filters, cartridges, or canisters - training and information - recordkeeping 6 J GItEGION CLE NOTICE OF CONSTRUCTION FINAL DETERMINATION TO APPROVE 2 r Olympic Region Clean Air Agency (p�' o RCAA ��aAB�A•16(ERSON•M��� Issued to: Steven Sims, Inc. Cnty: 45 Location: 151 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_OSNOC635.doc 08NOC635 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 (F V P)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 Classification' from PTE' PTE4 SQER' SQER' MSDS' 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, Methyl a-am I ketone VOC 20% 1873.5 0.94 43748 5 Class B TAP, Methyl ethyl ketone VOC 20% 1 1873.5 0.94 43748 5 Class B TAP, n-butylacetate VOC 10% 936.8 0.47 43748 5 Class B TAP, Toluene VOC 10% 936.8 0.47 43748 5 'Each pollutant contained in the HC Max 4 Basecoat is classified in WAC 173-460. ZThe amount of each compound contained in the HC Max 4 Basecoat is listed in the Material Safety Data Sheet for the coating. 3PTE0b/yr)=Content from MSDS*Material Usage(lb/yr) 4PTE(lb/hr)=Content from MSDS*Material Usage(lb/hr) 3The 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 Determination Page 2 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 l Table 1.2-Air Emissions Resulting from Hydro ra hic Printing Content Pollutant Classification' from PTE3 PTE4 SQER' SQER' MSDS' Ib/yr Ib/hr lb/yr Ib/hr Butyl Cellosolve TAP,VOC 20% 401.9 0.2 43748 5 HAP,TAP, Iso ro anol VOC 1 10% 200.9 0.1 43748 5 Each pollutant contained in the Hydro-graphic Activator is classified in WAC 173-460. 2The 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(lb/yr) 4PTE(lb/hr)=Content from MSDS*Material Usage(lb/hr) 51he small quantity emission rate(SQER)for each compound is defined in WAC 173-460, 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/yr Ib/hr lb/yr 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 Elb/ ER SQER MSDS lb/ r Ib/hr 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 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. rMe amount of each compound contained in the two-part topcoat is fisted in the Material Safety Data Sheet for the coating. 3PTE(lb/yr)=Content from MSDS*Material Usage(lb/yr) 4PTE(Ib/hr)=Content from MSDS*Material Usage(lb/hr) sThe 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.dcc 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 E ui ment 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.Z Airflow:5,484 acfm Section 1.3:Air Pollutant Emissions Final Determination Page 4 of 11 NOC_Steve Sims lnc_08NOC635.doc 08NOC635 Prepared January 7,2009 L 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. I 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 Iso ro anol B 1 43,748 5.0 279 0.139 0.6% 11043-0 Methyl a-amyl B 43,748 5.0 4211 2.11 9.6% ketone 78-93-3 ethyl ethyl ketone B 43,748 5.0 1874 0.94 4.3% 123-86-4 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 43,748 1 5.0 159 1 0.08 0.4% 'Each pollutant fisted here is classified in WAC 173-460. rMe amount of each compound contained in materials used at Steve Sims is fisted in the respective Material Safety Data Sheet for the material. 3PTE(lb/yr)=Content from MSDS*Material Usage(lb/yr) 4PTE(lb/hr)=Content from MSDS*Material Usage(lb/hr) 31he 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 I Final Determination Page 5 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 I Solids Controlled Material Material Material Material Material % VOC Emission Solids Usage8 Usages Specific Useage' Usage VOC' Solids' Emission as PM,o' Emission' Material al/ r) al/hr) gravity Ib/ r (lb/hr) (lb/gal) (by wt.) Z(lb/ r) Ib/ r (lb/ r L5/S Clear Hydro-Graphic Activator 240 0.12 1.01 2009 1.005 5.91 1 30% 1418 0 1 0.0 HC Max 4 Basecoat 1000 0.5 1.13 r9368 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 Reducers and Usage Specific Usage VOC Solids Emission Emission Emission Solvents ( al/ r) gravity (lb/ r) (lb/gal) (by wt.) Ib/ r) Ib/ r (lb/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 1 427 0 0 Material Usage(lb/yr)=Material Usage(gal/yr)*Specific gravity*8.29 Total VOC Emission 14058 (lb/yr) 2VOC Emission(gal/yr)=Material Useage(gal/yr)*Material VOC(lb/gal) or 7.0 (ton/yr) 'Controlled Solids Emission(lb/yr)=Solids Emission(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) 6Material Usage(Ib/hr)=(Material Usage(lb/yr))/Operating Schedule(hr/yr) i 'VOC 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 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 Determination Page 6 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared January 7,2009 i [:]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 Agency Mason County Department of Community Development Determination Mitigated Determination of Nonsignificance Date of Issuance of issued vet 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. i Regulation/Standard Description Applicable? Compliance Evaluation Like1 ? Attached? General ORCAA and State General regulations and standards found in Ycs Ycs 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 i CO No VOC Yes ORCAA has concluded that this proposal meets the requirement to employ BACT for VOC. S02 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 nor 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). ❑Air Quality Impacts Analysis completed by ORCAA (see Attachments). Final Determination Page 7 of 11 NOC_Steve Sims Inc_08NOC635.doc 08NOC635 Prepared lanuary 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). NMaximum 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) N 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 existing 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 NPSD 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_08NOCG35.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 Determuiation,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. Staffs 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 6.1.2(1)] 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 L 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 (0&M) 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: I Final Determination Page 10 of 11 NOC_Steve Sims Inc_08NOC635Ac 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 8.111 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 - - J