OREGON DEPARTMENT OF ENVIRONMENTAL … DEPARTMENT OF ENVIRONMENTAL QUALITY ... Emission fee report ... although the casting method changed in the 1980s from a sand casting …

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Review Report/Permit No.: 22-0011-TV-01 Application No.: 27034, 28082, 28443

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OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY STANDARD AIR CONTAMINANT DISCHARGE PERMIT and

OREGON TITLE V OPERATING PERMIT Stala of Oregon Department of Environmental Qual!ly

Source Information:

3369

331529

REVIEW REPORT Western Region

I Source Categories (Part and code)

Compliance and Emissions Monitoring Requirements

Unassigned emissions COMS

Emission credits CEMS

Compliance schedule PEMS

Source test [date(s)] CB-PM; Ambient monitoring WX-CO,NOx;

AB-NOx. F

Reporting Requirements

Annual report (due date) 3115 Monthly report (due dates)

Emission fee report (due date) 3115 Excess emissions repmt

SACC (due date) 3115 and 8115 Other reports (type)

Quarterly report (due dates)

A" p If rograms

NSPS (list subparts) IIII Title V

NESHAP (list subparts) zzzz ACDP (SIP)

CAM Major HAP source

Regional Haze (RH) Federal major source

Synthetic Minor (SM) NSR

Part 68 Risk Management PSD

CFC Acid Rain

RACT

TACT

X

GHG

X

TABLE OF CONTENTS


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INTRODUCTION ......................................................................................................................................................... 4

RENEWAL AND PROPOSED CHANGES ................................................................................................................. 5

PERMITTEE IDENTIFICATION ................................................................................................................................ 5

FACILITY DESCRIPTION .......................................................................................................................................... 5

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION .................................................. 6

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING ....................... lO

PLANT SITE EMISSION LIMITS ............................................................................................................................... 5

SIGNIFICANT EMISSION RATE ............................................................................................................................... 5

HAZARDOUS AIR POLLUTANTS .......................................................................................................................... 13

GENERAL BACKGROUND INFORMATION ........................................................................................................ 14

COMPLIANCE HISTORY ......................................................................................................................................... 14

SOURCE TEST RESULTS ........................................................................................................................................ 14

PUBLIC NOTICE ....................................................................................................................................................... 14

ATTACHMENTS ....................................................................................................................................................... 15

LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT

AQMA Air Quality Management Area NzO ASTM American Society of Testing and NA

Materials NESHAP BDT bone dry ton CEMS continuous emissions monitoring NOx

system NSPS CFR Code of Federal Regulations NSR CH, methane (greenhouse gas) o, CMS continuous monitoring system OAR co carbon monoxide ORS co,e carbon dioxide equivalent O&M COMS continuous opacity monitoring Pb

system PCD DEQ Oregon DEQ of Environmental PEMS

Quality dscf dry standard cubic feet PM EF emission factor PMw EPA United State Enviromnental

Protection Agency PMz.s EU emissions unit FCAA Federal Clean Air Act PSD GHG greenhouse gas gr/dscf grains per dry standard cubic feet PSEL HAP hazardous air pollutant so, ID identification code ST I&M inspection and maintenance VE MB material balance VMT Mlb 1000 pounds voc MM million

Review Report/Pe1mit No.: 22-0011-TV-01 Application No.: 27034, 28082, 28443

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nitrous oxide (greenhouse gas) not applicable National Emission Standard for Hazardous Air Pollutants oxides of nitrogen New Source Performance Standard New Source Review oxygen Oregon Administrative Rules Oregon Revised Statutes operation and maintenance lead pollution control device predictive emissions monitoring system particulate matter particulate matter less than 10 microns in size particulate matter less than 2.5 microns in size Prevention of Significant Deterioration Plant Site Emission Limit sulfur dioxide source test visible emissions vehicle mile traveled volatile organic compound

INTRODUCTION

Review Report/Pe~mit No.: 22-00 II-TV -0 I Application No.: 27034, 28082, 28443

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I. DEQ proposes three simultaneous permitting actions for Pacific Cast Technologies- dba A TI Cast Products (PCT) as follows:

I.a. issuance of a new Standard ACDP to authorize a VOC and PMw PSEL increase to incorporate full production increases at the facility,

1 .b. issuance of an administrative amendment to incorporate the changed permit requirements as specified in Standard Air Contaminant Discharge Permit No. 22-00 !1-ST -0 I into the Oregon Title V Operating Permit in accordance with the enhanced review procedures in OAR 340-218-0 150(1 )(h).

I.e. renewal of the existing Title V operating permit and incorporation ofDEQ rule changes adopted on Aprill6, 2015.

The new Standard ACDP is required to authorize VOC and PM10 PSEL increases to incorporate full production of the new intermediate line. The intermediate line allows for more parts to be processed and results in an increase in VOC and PMw emissions. Construction and limited operation of the new intermediate line was authorized in the Notice of Approval No. 28141. The permittee submitted a timely Title V permit renewal application on 10/24/12 (Application No. 27034), a Standard Permit Application on 3/4115 (Application No. 28082), and Administrative Amendment application on 2/23/15 (Application No. 28443). The new Standard Permit and Title V renewal permit will be submitted for review to EPA, in addition to an administrative amendment to incorporate the new conditions in the ACDP into the Title V permit under the enhanced review process.

RENEWAL AND PROPOSED CHANGES

2. Pacific Cast Technologies dba ATI Cast Products (PCT) was issued their current Title V operating permit on January 2, 2009 which was originally scheduled to expire on November I, 2013. PCT submitted a timely Title V permit renewal application on October 24, 2012. Therefore, the current Title V permit remains in effect until the renewal permit is issued.

PCT is proposing to renew their Title V operating permit and to modify their facility to accommodate production increases. These changes will result in an increase in VOC and PM10 emissions and a request to increase the PSELs. No other PSEL increases are proposed, although PSELs for PM2.5 and GHGs are being added to the permit for the first time. Phase I, the first step in the process, was construction authorization for a new intermediate process Hne within the investment casting process. The intermediate line allows for more parts to be processed. Construction and limited operation ofthe intermediate line was authorized with approval of a Notice of Approval Application (NOA) No. 28141. DEQ approved the NOA on April 29,2015. Construction included installation of anew intermediate slurry pot, two additional 6 MMBtu!hr natural gas bumout ovens, a small 1.68 MMBtu/hr boiler and two new dust collectors. Phase II is operation ofthe intermediate line at full production. This requires a new Standard ACDP to authorize an increase in the VOC and PMw PSELs. The company is requesting the incorporation of the Standard ACDP conditions into the Title V operating permit through an administrative amendment to the renewed Title V Operating Permit under the enhanced review procedures in OAR 340-218-0150(1)(h). The proposed Title V permit renewal permit includes all DEQ mle updates and the VOC and PMw PSEL increases authorized by issuance of the Standard ACDP.

3. In accordance with OAR 340-218-0120(1)(t), this review report is intended to provide the legal and factual basis for tbe draft pe1mit conditions. In most cases, the legal basis for a permit condition is included in the permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the same as the legal basis. However, when the regulation is not specific and only provides general requirements, this review report is used to provide a more thorough explanation of the factual basis for the draft pe~mit conditions.


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4. Since the last Title V permit issuance, DEQ has issued the following construction authorizations or petmit modifications:

Date Pennit revision or notification Brief explanation 7/13/11 Administrative Amendment Name change to Pacific Cast Technologies, Inc. dba AT!

No.I Pacific Cast Technologies 9/5/13 NOA No. 27457 lostallation of grinding dust bagbouse DC-26 12118/13 NOA No. 27558 Replacement fan on caustic bath 4/29/15 NOANo.28141 lostallation of Phase I -lotermediate Process Line 9/15/15 NOA No. 28372 Installation of a new shot blaster and dust collector DC-29 6/13/16 NOA No. 28678 Move existing Heat Shield Sandblaster System DC-I 5 8/11/16 NOA No. 28747 Vent 10 existing finishing wet collectors to atmosphere 9/6116 Minor Permit Modification Changed PSEL compliance calculation procedure for EUs

KOandMM 10/28/16 NOA No. 288I8 Boilers I8 and 19 to replace Boiler I 0 11114/16 NOA No. 28847 Install5 new finishing grinders and wet collectors WC16-20

5. The following changes have been made to the permit:

• Construction authorizations as outlined above • Emission factor verification stack testing for NOx and F is being added to the permit for the acid

scrubbers (EU AB), for PM from the caustic baths (EU-CB), and for CO and NOx from the burnout ovens (OV 8 and 16) .

• Contact information is updated. • PSEL compliance calculation procedures for emission units which vent inside buildings are

updated to assume only 10% ofthe emissions escape the building. The permittee may vent some emission units to the atmosphere in the future in which case 100% of the emissions would be counted toward PSEL compliance.

• The emission unit inventmy has been updated to reflect the existing facility configuration and the construction authorizations as outlined above.

• The production rates and emission calculations have been updated to reflect proposed operations. • Excess emission reporting requirements have been updated. • Emission unit designations and names have been updated and revised. • Scrap Milling Tank (AI) in emission unit AB is renamed Acid Recovety Unit. • A proposed VOC PSEL increase from 198 tons to 248 tons and PM10 PSEL increase from 14 tons

to 15 tons due to projected production increases.

• Due to DEQ rule changes adopted on April 16, 2015 the following changes are also included: o A greenhouse gas (GHG) baseline emission rate, netting basis, and plant site emission

limit (PSEL) are being established for the first time. o PM,5 netting basis and PSEL are also being established in this permitting action. o The grain loading and opacity standards have been updated. o Categorically insignificant activities have been revised. o Nuisance and fugitive emission condition requirements are updated. o Rule references have been updated as needed.

PERMITTEE IDENTIFICATION

6. PCT operates a titanium casting facility located at 150 Queen Ave. SW, Albany, Oregon. The facility was built in 1968 by TiLine, Inc., and operated under that name untill986. At that time IMI Titanium, Inc. acquired the facility and operated it untill996 when TIMET Castings Corporation acquired the facility. Wyman-Gordon acquired the facility in 1998 and the facility operated under that name until January, 2000 when it was acquired by the Ladish Co. and the name changed to Pacific Cast Technologies, Joe. The

Review Report/Permit No.: 22-0011-TV -0 I Application No.: 27034, 28082, 28443

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facility became part of A TI in 2011, and is currently owned by Pacific Cast Technologies dba AT! Cast Products. The facility has continuously operated as a titanium casting facility under the various ownerships although the casting method changed in the 1980s from a sand casting process to the investment casting process used today.

FACILITY DESCRIPTION

7. The facility currently produces titanium aerospace components by investment casting. Raw materials used in the various processes at the facility include but are not limited to commercially pure and alloyed titanium metal, waxes, ceramic materials, and isopropanol. Additionally, scrap pieces of titanium are remelted after being cleaned in a chemical pickling process.

The investment casting process, also called the lost wax process, starts out with the creation of wax patterns in accurate metal dies in tbe wax department. As required, acid soluble wax fillers are incorporated into the pattern so a void will be left iu the wax pattern once the soluble filler is dissolved by a dilute hydrochloric acid solution. The wax patterns are touched up by hand before serving as the core for the creation of the shell molds. Smoke that is created by the use of hot tools in the wax touch-up area is controlled by filtration equipment which returns the cleaned air to the workplace.

The ceramic shell molds are bnilt up around the wax patterns in the investing department. A shell is built up around each pattern (or group of patterns which have been assembled onto a sprue) by alternately dipping a pattern into a slurry and rotating it under a rainfall sander. The sluny consists prhnarily of milled ceramic patticles and isopropanol, and the rainfall sanders dispense aluminum oxide sand. After the shell has set up, the wax is melted out ofthe shells using steam in the autoclave.

The shell molds are fired in kilns called bumout ovens. Any residual wax remaining in the shells is bumed out as the temperature is slowly ramped up to approximately 2,000 degrees op over a several hour period. The shells are then held in the ovens, or heat soaked, for a specific time period before they are ready for the casting operation.

Both the process of melting the titanium and the titanium pouring operation are conducted in a vacuum inside the casting furnaces. The vacuum is required to keep the titanium from reacting with oxygen. After the poured molds have been removed from the furnaces, the knockout depattment uses various methods to remove the shells and clean up the cast parts. These methods include the use of a heated caustic bath to soften the shell molds, water blasting, jack hammers, sand blasting, shot blasting, and abrasive grinding. Unwanted appendages such as sprues and risers are removed from the parts by torch cutting or abrasive cutoff wheels.

The oxygen-enriched layer on the surface ofthe castings is removed by mineral acid solution in the pickling department. The dhnensions of the castings are checked and modifications are made to bring them within specifications. The tools used to bring the castings within specified limits include a press, inert gas welding, and grinding. Final steps include both surface penetrant and x-ray inspections, as well as heat treating in an electrical vacuum heat treatment furnace.

The facility has a number of small natural gas combustion devices, including the burnout ovens, boilers to provide steam for the autoclave and HV AC heating, heaters for the acid and caustic baths, and small furnaces.

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

8. The emissions units at this facility are shown in the following table and described in more detail below:

Emission Unit Description Acid Baths (NO, & opacity)

Acid Recovery Unit (A I) Heated Acid Bath# I (A2) Cold Etch Bath (A4N) Heated Acid Bath #2 (AS)

Caustic Baths (PM/PMw/PM2.s & opacity) Caustic Bath (CBI) Caustic Bath (CB2)

Knockout Dust Collection Systems (PMIPMwiPMzs & opacity)

Torch Booth Sandblaster Sandblaster Sandblaster Sandblaster Sandblaster Stand Up Grinder

Mastermelt Dust Collection Systems (PMIPMwfPMz.s & opacity)

Torch Booth Welding Welding

Building H (PM/PMIO/PM,.s, & opacity) Finishing Grinding

Building C (PMIPMIOIPMz.s, & opacity) Grinding

Dewaxing Operations (CO, NO,, VOC, PMIPMw!PM,.s , & opacity)

Burnout Ovens 01, 04-08, 16, 17 (OVOI,04-08, 16, 17)

Burnout Oven2 (OV02) Facility-Wide Use ofVOC-Containing Materials (VOC) Boilers 02,10,!2,13,14,16,17,18,19 and Natural Gas Burners 01-03,05-07 (NO,, CO, VOC, PMIPMw!PM,.s, &

opacity) Aggregate Insignificant Emissions (PMIPMwf PMz.s and VOC only)

EUID AB

CB

KO

MM

BLDGH

BLDGC

wx

FWVOC

NGBLR

AI


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Pollution Control Device Description PCDID

Wet Scrubber SCRB-05 Wet Scrubber SCRB-02 Wet Scrubber SCRB-04 Wet Scrubber SCRB-04

None NA None NA

Dust Collector DC-07 Dust Collector DC-12 Dust Collector DC-16 Dust Collector DC-19 Dust Collector DC-21 Dust Collector DC-29 Wet Collector WC-03

Dust Collector DC-04 Dust Collector DC-11 Dust Collector DC-17 Wet Collectors WC-10-15

WC-16-20 Wet Collectors WGRB-01-05

Afterburners NA

None NA None NA

None NA

8.a. EMISSIONS UNIT AB-Acid Baths [4 Baths- SCRB-02CA2l, SCRB-04(A5 & A4Nl, SCRB-05CA1ll

This emission unit includes emissions from both heated and cold acid baths emitting NO,, and HF. All acid baths have wet scrubbers rated at 99% removal for HF and 65% removal for NO, and have the potential to generate visible emissions.

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8.b. EMISSIONS UNIT CB-Caustic Baths (2- CB-01, CB-02)

This emissions unit without emission controls emits PMIPM10/PM2.s emissions from a heated caustic bath and a rinse tank and has the potential to generate visible emissions.

8.c. EMISSIONS UNIT MM-Mastennelt Dust Collection Systems

This emission unit includes welding and a torch booth which have all the PM!PMw /PM,.s emissions controlled by either dry dust collectors or a wet scrubber. Emissions are CUJTently vented inside a building but may be vented to the outside atUJosphere in the future.

8.d. EMISSIONS UNIT KO-Knockout Dust Collection Systems

a

Ibis emission unit includes sandblasters, standup grinder, and torch booth which have all the PM/PM10 !PM,_, emissions controlled by dry dust collectors. Emissions are cmTently vented inside

building but may be vented to the outside atmosphere in the future.

8.e. EMISSIONS UNIT WX-Dewaxing (Burnout Ovens 01, 02, 04-08, 16, 17)

This emissions unit consists of emissions from the 8 natural gas fired burnout ovens at the facility. The units have afterburner controls. OV02 is an electric heated burnout oven.

8.f. EMISSIONS UNIT FWVOC

This emission unit includes uncontrolled VOC emissions fl"om the facility-wide use ofVOC containing materials (primarily isopropanol) in the various processes (primarily investing) at the facility.

8.g. EMISSIONS UNIT NGBL

This emissions unit includes emissions from natural gas combustion in Boilers 02, I 0, 12, 13, 14, 15, 16, 17, 18, and 19 and six smaller natural gas burners. Aggregate NG combustion emissions ofNOx and CO are greater than de minimis and therefore all the boilers and natural gas bmners are included in the PSEL in accordance with DEQ rules changes in OAR-340-200-0020(23)(c).

8.h. EMISSIONS UNIT BLDG C

This emissions unit includes grinding operations in Building C which have all the PM/PMw!PM,.s emissions controlled by wet collectors. Emissions are currently vented inside a building but may be vented to the outside atUJosphere in the future.

8.i. EMISSIONS UNIT BLDG H

Ibis emissions unit includes finishing grinding operations in Building H which have all the PM!PM10 !PM,5 emissions controlled by wet collectors. Emissions are cuiTently vented inside a building but may be vented to the outside atUJosphere in the future.

8.j. AGGREGATE INSIGNIFICANT ACTIVITIES

The following activities which are present at the facility are insignificant in the aggregate:

8.j.i. VOC from autoclave (AC);

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8.j.ii. PM/PM10/PM,.s from various operations (see attached detail sheet).

9. Categorically insignificant activities include the following:

• Constituents of a chemical mixture present at less than I% by weigbt of any chemical or compound regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or less than 0.1% by weight of any carcinogen listed in the U.S. DEQ of Health and Human Service's Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year

• Evaporative and tail pipe emissions from on-site motor vehicle operation • Distillate oil, kerosene, gasoline, natural gas or propane burning equipment brought on site for six

months or less for maintenance, construction or similar purposes, such as but not limited to generators, pumps, hot water pressure washers and space heaters, provided that any such equipment that perfmms the same function as the permanent equipment, must be operated within the source's existing PSEL

• Office activities • Janitorial activities • Personal care activities • Groundskeeping activities including, but not limited to building painting and road and parking lot

maintenance • Insttument calibration • Maintenance and repair shop (DC-05) • Air cooling or ventilating equipment not designed to remove air contaminants generated by or

released from associated equipment • Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated

under Title VI, including pressure tanks used in refrigeration systems but excluding any combustion equipment associated with such systems

• Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical analysis, including associated vacuum producing devices but excluding research and development facilities

• Temporary construction activities • Warehouse activities • Accidental fn·es • Air vents from air compressors • Air purification systems • Electrical charging stations • Instrument air dryers and distribution • Process raw water filtration systems • Fire suppression • Routine maintenance, repair, and replacement such as anticipated activities most often associated

with and performed during regularly scheduled equipment outages to maintain a plant and its equipment in good operating condition, including but not limited to steam cleaning, abrasive use, and woodworking

• Electric motors • Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or

residual fuels, lubricants, and hydraulic fluids • Natural gas, propane, and liquefied petroleum gas (LPG) storage tanks and transfer equipment • Pressurized tanks containing gaseous compounds • Emissions from wastewater discharges to publicly owned treatment works (POTW) provided the

source is authorized to discharge to the POTW, not including on-site wastewater treatment and/or holding facilities

• Fire suppression and training


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• Paved roads and paved parking lots within an urban growth boundary • Health, safety, and emergency response activities • Emergency generators and pumps used only during loss of primary equipment or utility service

due to circumstances beyond the reasonable control of the owner or operator, or to address a power emergency, provided that the aggregate horsepower rating of all stationary emergency generator and pump engines is not more than 3,000 horsepower. If the aggregate horsepower rating of all stationary emergency generator and pump engines is more than 3,000 horsepower, then no emergency generators and pumps at the source may be considered categorically insignificant (DGEN-01 and DGEN-02)

• Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution systems

• Non-contact steam condensate flash tanks • Non-contact steam vents on condensate receivers, deaerators and simHar equipment • Boiler blowdown tanks • Uncontrolled oil/water separators in effluent treatment systems, excluding systems with a

throughput of more than 400,000 gallons per year of effluent located at the following sources: petroleum refineries, sources that perform petroleum refining andre-refining oflubricating oils and greases including asphalt production by distillation and the reprocessing of oils and/or solvents for fuels, or bulk gasoline plants, bulk gasoline terminals, and pipeline facilities

• Combustion source flame safety purging on stattup.

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING

Oregon Administrative Rules (OAR)

10. Facility-wide standards in Division 208 regarding fugitive emissions and nuisance conditions from odors or particle fallout apply to the facility. Monitoring for compliance with these standards will be done by the facility performing complaint investigations and maintenance of a complaint log and quarterly VE surveys at the property boundaries. These facility-wide standards are only enforceable by the state. No complaints have been received by tbe company or DEQ during the prior permit period.

II. Visible emissions (opacity) from all emission sources at the facility must meet the 20% opacity standard in OAR 340-208-0 II 0( 4). Compliance with the standard will be monitored by quarterly visible emissions (VE) surveys using EPA Method 22 (or EPA Method 9 if VE are noted). No VE or minimal VE emissions have been noted by company staff in the past or by prior DEQ inspections.

12. Particulate emissions from all non-fugitive emission sources at the facility must meet either the 0.14 gr/dscf or 0.10 gr/dscf grain loading standards in OAR 340-226-021 0(2)(h) or (c). in lieu oftesting, the quarterly VE surveys will be used as the SUJTogate monitoring method for compliance with the grain loading standard. The baghouses and wet scrubbers will also have monthly inspections performed externally for structural integrity, corrosion, and air leaks and repairs made if necessary. No problems with control equipment have ever been noted in prior DEQ inspections.

13. The process weight standards in OAR 340-226-0310 and -8-lOapply to emission units CB, KO, MM, BLDG C, BLDG H, and WX at this facility. Since the process weight standard is usually less stringent than tbe grain loading limits, monitoring by VE tests and inspection and maintenance ofthe control devices will be used as the surrogate monitoring method for compliance.

14. Plant Site Emission Limits (PSELs) are required for the facility by OAR 340 Division 222. Projected maximum emissions have been calculated using anticipated production values and emission factors updated to the most current standards. Monitoring for compliance with the PSELs will be done by calculating monthly and rolling annual emissions using production data and emission factors. Because some emission sources in emission units which currently vent inside buildings may be vented to the outside in the future, the PSEL compliance determination for PM will be made with emission factors which account for whether


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the unit is venting inside or outside. Based on an engineering estimate, a 10% emission factor for PM is used if the emission units are venting inside a building to account for possible dust escaping the building. If the unit is venting outside, a 100% emission factor is used for PM. The calculations are performed on a monthly basis because this is the shortest reasonable time period that is compatible with source operations and will give reliable data for all operations.

15. The facility is required to submit reports semi-annually to DEQ. The frrst semi-annual report will include only the semi-annual compliance certification. The annual report will include the second semiannual compliance certification as well as the excess emission upset log, the emission fee report, and the calendar year and rolling 12-month actual emission calculations.

16. The facility is required by OAR 340-214-0300 through -0360 to report excess emissions immediately. For this source immediately will be no later than by 9:00 am the following business day. A written report is due within 15 days.

Federal Requirements

17. Federal rules applicability deteJminations for the facility are described below:

17.a. The accidental release provisions of 40 CFR Part 68 do not apply to the facility as it does not store, use, or have quantities in excess of any of the specified chemicals subject to this regulation.

17.b. Subpart De of the New Source Performance Standards does not apply to any ofthe natural-gas fired boilers at the facility because they are all smaller than the Subpart De applicability criteria (>10 MM Btulhr) as shown in the table below.

Boiler No. Rating (MMBtulhr)

02 4.9 10 1.6 12 0.4 13 2.2 14 1.5 15 1.5 16 1.5 17 1.68 18 0.5 19 0.5

17.c. The facility is not subject to the Compliance Assurance Monitming (CAM) requirements of 40 CFR Part 64 because no emission units at the facility meet the applicability requirements. The CAM applicability analysis table is included in the detail sheets attached to this report.

17.d. The facility is not subject to any major source National Emission Standards for Hazardous Air Pollutants (NESHAP) standards as the facility is not a major somce of HAP. The boilers are not subject to the Area Source Boiler GACT rules in 40 CFR, Part 63, Subpart JJJJJJ as the boilers are exclusively natural gas frred. The source does not have gasoline dispensing facilities or other sources that trigger Area Source NESHAP requirements. The two emergency generators at the facility are subject to 40 CFR Part 63, Subpart ZZZZ requirements and one ofthe emergency generators is also subject to 40 CFR Part 60, Subpart IIIJ requirements. The appropriate conditions have been added to the permit in this renewal.

18. Insignificant activities


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As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include categorically insignificant activities and aggregate insignificant emissions, as defined in OAR 340-200-0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter (grain loading). DEQ does not consider it likely that IEUs could exceed an applicable emissions limit or standard because IEUs are generally equipment or activities that do not have any emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions. Since there are no controls, no visible emissions, and the emissions are less than one ton per year, DEQ does not believe monitoring, recordkeeping, or reporting is necessary for assuring compliance with the standards

PLANT SITE EMISSION LIMITS

19. Provided below is a summary of the baseline emission rates, netting basis, and the plant site emission limits.

Baseline Plant Site Emission Limit (PSEL) Emission Netting Basis Previous Proposed PSEL

Rate Previous Proposed PSEL PSEL Increase Pollutant (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)

PM 2 2 2 24 24 0 PMw 2 2 2 14 15 +1 PM,,, NA NA 6 NA 15 NA co 1 1 1 99 99 0 NO, 1 1 1 39 39 0 so, 0 0 0 NA NA NA voc 15 193 193 198 248 +50

F 0 0 0 NA NA NA GHG (CO,e) 3200 NA 3200 NA 74,000 NA

19.a. In accordance with OAR 340-222-0048 the 1978 baseline emission rates were "frozen" in a previous permitting action.

19.b. The netting basis is equal to the baseline emission rate for all pollutants except VOC and PM,, since the facility has not had any Prevention of Significant Deterioration approvals under OAR 340-224-0070 and no rule reductions have been required since baseline for those pollutants. The netting basis for VOC was increased in a II /12/97 PSD approval permitting action. The netting basis for VOC was reduced 711/07 from 234 tons to 193 tons due to unassigned emissions reduction of 41 tons. The initial netting basis for PM,,, is being established for the first time in this permitting action and is equal to the PM10 netting basis since all emissions are less than 2.5 microns in size. The PM,, netting basis is being adjusted with a one-time "true-up" of 4 tons in accordance with OAR-340-222-0046(2)(b ). The baseline and netting basis are being established for GHGs for the first time in this permitting action. The baseline and netting basis for GHGs is derived from 2005 actual emissions as requested by the company.

19.c. The proposed PSELs for VOC, PMw, and PM,, have been set at the facility's potential to emit in accordance with OAR 340-222-0041(3)(a). The PM,.s PSEL has been set equal to the PMw PSEL as all emissions are less than 2.5 micron in size.

19.d. The proposed PSELs for PM, CO, NO,, and GHG have been set at the DEQ's Generic PSEL levels in accordance with OAR 340-222-0041 (1) since the projected emission levels are less than the Generic PSEL levels but greater than the de minimis level.

19.e. No PSELs are being established for S02 or Fluorides since the projected emission levels are less than the de minimis levels in OAR 340-222-0020(3)(a).

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19.£ The PSEL is a federally enforceable limit on the potential to emit.

SIGNIFICANT EMISSION RATE

20. The proposed PSELs are less than the significant emission rate (SER) over the netting basis for all pollutants except VOC as shown below and no further air quality analysis is required for those pollutants.

Pollutant

PM PMw PM,.s co NOx voc GHG

Netting Requested Requested increase Increase due to physical Increase due to use SER Basis PSEL over netting basis or operational changes of Generic PSEL

25 2 24 22 15 7 15 2 15 13 13 0 10 6 15 9 9 0

100 I 99 98 16 82 40 1 39 38 31 7 40 193 248 55 55 -0-

75,000 3200 74,000 70,800 21,500 49,300

Because the VOC emission rate over the netting basis for VOC is greater than the SER the following ozone precursor analysis required by OAR 340-224-0520(2)(a) is provided.

Sources with emission greater than the significant emission rate over the netting basis for ozone precursor pollutants (NOx and VOC) and are located less than 100 km from the Portland Ozone Air Quality Maintenance Area (AQMA) must demonstrate they are not a significant contributor of ozone precursors. The source has the potential to emit 55 tons/year ofVOC over the netting basis and is located 83 km fi·om the Portland AQMA boundary. Proposed PSEL is 248 and Netting Basis is 193. 248-193~55 tons proposed over netting basis.

D~(Q/40) * 30 km

D=ozone precursor distance in km Q~is VOC emission increase being requested above netting basis

D~(55/40) * 30 km

D~41 km < 83 km from the Portland AQMA

For the proposed emissions, the formula demonstrates that the source is located at a sufficient distance relative to the boundary ofthe Portland AQMA that the emissions do not have a potential to effect the designated maintenance area. The source would have to be located 41 km or less from the AQMA to have a potential effect. Therefore, no further air quality analysis is required for VOCs.

HAZARDOUS AIR POLLUTANTS

21. The facility is not a major source for HAPs. Estimated annual emissions of HAPs for the proposed operating period are as follows:

Pollutant Tons/year Hydrogen fluoride 0.02 Methanol 1.13 Methyl isobutyl ketone 0.24 Toluene 1.2 Organic HAPs from NG combustion 0.33

Metal HAPs from NG combustion Metal HAPs fi·om metal processing

TOTAL

GENERAL BACKGROUND INFORMATION

0.001 0.0013 2.92

Review Repori!Permit No.: 22-00 II-TV -0 I Application No.: 27034, 28082, 28443

Page 14 of29

22. A Land Use Compatibility Statement was signed by the City of Albany on 5/31/97.

23. Other permits issued or required by DEQ for this facility include a General Storm water Permit.

COMPLIANCE HISTORY

24. The facility was inspected on 6/7/10, 6/20/12, 7/21/14, and 8/30/16 and found to be in compliance with all existing permit conditions.

25. No complaints have been received concerning the facility during the prior permit period.

26. No formal enforcement actions have been taken against the source since the original Title V issuance. A warning letter was issued on 8/22/13 for a late semi-annual compliance report and a warning letter with opportunity to conect was issued on 4/4/16 for missed visible emissions surveys in the last two quarters of 2015. This violation was discovered in their 2nd half Semi-Annual Compliance Certification Report for 2015 and has been conected. Another warning letter was issued on I 1/22/16 for exceeding the PMw 12-month rolling PSEL in July 2016. The exceedance was 0.01 T/Y and was due to a flawed calculation procedure in the permit. The company submitted a minor permit modification application to conect the calculational procedure which was issued on 9/6/16 and conected the violation.

SOURCE TEST RESULTS

27. No source tests have been conducted at the facility in the past. DEQ is adding emissions factor verification testing requirements for NOx and F from the acid scrubbers, PM from the caustic baths, and CO and NOx from the burnout ovens in this permitting action.

PUBLIC NOTICE

28. This permit was put on public notice from December 28, 2016, to February 1, 2017. During the comment period, two citizen comments were received. The comments are included below in their entirety along with the DEQ response.

Comment 1: The costs associated with increased output of pollutants is poor health for the community. It is unconscionable for companies to not consider their waste as a problem. Pacific Cast Technologies must install equipment to be sure the air they emit into the community is clean enough to breathe safely. We cannot continue to add poison to the air, increased cancer cases is the outcome. Solution is no longer the answer to pollution.

DEQ Response: The facility uses state-of-the-art baghouses and wet scrubbers to control particulate and NOx emissions from the facility which reduce emissions to low levels and no better controls are necessary or feasible. Although VOC emissions from the facility are not controlled, VOC is a precursor to ozone. However, ozone concentrations in the ambient air in the Albany area and the Willamette Valley are well under health-based levels of concem and the facility's emissions ofVOC are quite small in comparison to the total VOC emission from all sources in the Albany and Willamette Valley area.


Page 15 of29

Comment 2: I'm writing about tbe permit for more emissions from the Pacific Cast Technologies Company plant in Albany. I don't think the permit should be granted. We have too many emissions already in our air in Albany. I live in North Albany and I smell Wah Chang some nights, or ATI, or whatever its name is now. It smells like a smelly kitty litter box, or something like that. It's hard to describe. Definitely a chemical smell. I don't think these Titanium companies should be emitting as much pollutants as they are already. I imagine they'll most likely get approval, but ifDEQ could stop them that would be terrific. I appreciate DEQ being around and trying to monitor these companies. My Uncle worked at Wah Chang for 28 years and died at 51 from colon cancer. His step daughter later got money from the government for his exposure to dangerous metals that he was exposed to there. My Uncle was in waste management at Wah Chang. I know these Titanium companies in Albany are safer than they used to be, but they are sometimes still irresponsible, as I see it. I'm not concerned about climate change, but strictly the negative impact their emission have on human health. Some of these emissions are carcinogenic, I'm quite positive. I definitely oppose Pacific Cast Tech. getting a petmit to emit more pollutants. They should install scrubbers and advanced technology to capture all these pollutants. I appreciate your time. Thank you very much.

DEQ Response: See response to Comment I above conceming emission controls. Some of this comment is concerned with emissions and odors from another A TI facility but not Pacific Cast Technologies. DEQ will continue to investigate odors or other issues with that facility. The Pacific Cast facility has met all the legal requirements for issuance of a renewal permit and, therefore, DEQ must issue the permit. DEQ will continue to monitor the facility through inspections and reports the facility must submit.

29. Based on the comments received and DEQ's responses above, DEQ will not be modifying the draft pennit. A proposed permit was sent to EPA for a45 day review period on Febtuary 9, 2017. EPA had no objection to the issuance ofthis permit.

If EPA does not object in writing, any person may petition the EPA within 60 days after the expiration of EPA's 45-day review period to make such objection. Any such petition must be based only on objections to the permit that were raised with reasonable specificity during the public comment period provided for in OAR 340-2I8-0210, unless the petitioner demonstrates it was hnpracticahle to raise such objections within such period, or unless the grounds for such objection arose after such period.

ATTACHMENTS

Emission Detail Sheets Baseline Emissions Proposed Emissions Aggregate Insignificant Activities Emissions HAP Emissions NG Emissions CAM Analysis

Review Report/Pe1mit No.: 22-0011-TV-01 Application No.: 27034, 28082, 28443

Page 16 of29

Pacific Cast Technologies 1978 Baseline Emissions

Process or Annual Rate Pollutant Emission Factor Reference Annual Activity Emissions

(tons/yr)

Core making and 78.35 ton/yr PM/PM10 1.1 lb/ton AP-42 Table 12.10-7 0.04 baking

Shakeout 78.35 ton/yr PM/PM1o 3.2 lb/ton AP-42 Table 12.10-7 0.13

Cleaning and 78.35 ton/yr PM/PM10 17 lb/ton AP-42 Table 12.10-7 0.67 finishing

Graphite handling 448. 1 ton/yr PM/PM10 3.6 lb/ton AP-42 Table 12.10-7 0.81

Mold baking furnace

Natural gas 16.54 MM ft3/yr PM/PM10 2.5 lb/MM ft3 DEQ Factor 0.021 combustion

NOx 100 lb/MM ft' DEQ Factor 0.827

802 2.6 lb/MM ft3 DEQ Factor 0.022

co 84 lb/MM ft' DEQ Factor 0.695

voc 5.5 lb/MM ft3 DEQ Factor 0.045

Wood combustion 5.06 ton/yr PM/PM10 30.6 lb/ton AP-42 Table 1.10-1 0.077

NOx 2.8 lblton AP-42 Table 1.10-1 0.007

802 0.4 lblton AP-42 Table 1.10-1 0.001

co 230.8 lb/ton AP-42 Table 1.10-1 0.584 VOC 53.0 lb/ton AP-42 Table 1.10-1 0.134

Mold baking 7.17 ton/yr voc 95% Engineering Judgment 6.81

Facility-wide use VariousVOC voc Varies by product Material Balance 8.02 ofVOC containing use

containing materials materials

Baseline Summary

PM/PM10 1.739

NOx 0.834

802 0.023

co 1.279 voc 15.011

NG Cornbusted (MM ft3

)

52.5

Review Report/Pem1it No.: 22-001 1-TV-01 Application No.: 27034, 28082, 28443

Page 17 of29

Pacific Cast Technologies 2005 Greenhouse Gas Baseline Emissions

Emission Factor Reference Emissions (tons/year CO,e)

120,14llb/MM ft3 40 CFR Part 98 3154

The GHG baseline and netting basis will be rounded to 3200 tons/year

Eu ID

CB

wx

KO

Bldg H


Page IS of29

Pacific Cast Technologies Projected Emissions

PM/PM10/PM, s

Emission Factor Annual EU Description

Annual Emissions

Production Rate Rate Reference (tons/yr)

CB-01 - Caustic 6,600 dscfm 0.01 gr/dscf Eng. Est.• 2.48 bath tank

CB-02- Caustic 6,600 dscfm 0.01 gr/dscf Eng. Est.• 2.48 rinse tank

OV01 16.32 MMcf 2.5 lb/MMcf DEQAQ- 0.02 (1.9 MMBtu) NG EF05






OV16 51.53 MMcf 2.5 lb/MMcf DEQAQ- 0.06 (6 MMBtu) NG EF05

OV17 51.53 MMcf 2.5 lb/MMcf DEQAQ- 0.06 (6 MMBtu) NG EF05

DC-07 511 ton 5.48E-04 lb/lb Eng. Est.b 0.28 castings castings

DC-12 511 ton 3.66E-04 lb/lb Eng. Est.c 0.19 castings castings

DC-16 511 ton 7.31 E-04 lb/lb Eng. Est.c 0.37 castings castings

DC-19 511 ton 7.31E-04 lb/lb Eng. Est.' 0.37 castings castings

DC-21 511 ton 7.31 E-04 lb/lb Eng. Est.' 0.37 castings castings

DC-29 511 ton 7.31 E-04 lb/lb Eng. Est.' 0.37 castings castings

WC-03 511 ton 7.46E-03 lb/lb Eng. Est.e 3.81 castings castings

WC-10-15 8,760 hr/yr 7.00E-02 lb/hr Manufacturer 0.31 WC-16-20 8,760 hr/yr 5.26E-02 lb/hr Eng. Est. 0.23

(2016 IH study)

Bldg C WGRB-01-05 8,760 hr/yr (4 x 12,500 elm, 1 x 10,000 elm)

MM DC-04 511 ton castings

DC-11 511 ton castings

DC-17 511 ton castings

NGBL BOIL-02 41.8 MMcl

BOIL-10 13.74 MMcl

BOIL-12 3.44 MMcf

BOIL-13 18.89 MMcl

BOIL-14 12.88 MMcl

BOIL-15 12.88 MMcl

BOIL-16 12.88 MMcf

BOIL-17 14.43 MMcl

BOIL-18 4.29 MMcl

BOIL-19 4.29 MMcl

NG-01 1.50 MMcf

NG-02 4.29 MMcl

NG-03 3.44 MMcl

NG-05 4.29 MMcf

NG-06 2.15 MMcl

NG-07 2.15 MMcl

AI


Page 19 of29

0.105 lb/hr Eng. Est. 0.46 (2016 IH study)

5.48E-04 lb/lb Eng. Estd 0.28 castings

1.38E-03 lb/lb Eng. Est.• 0.71 castings

1.38E-03 lb/lb Eng. Est." 0.71 castings

2.5 lb/MMcl DEQAQ- 0.05 EF05


2.5 lb/MMcl DEQAQ- 4.29E-03 EF05








2.5 lb/MMcf DEQAQ- 1.88E-03 EF05






1.0

Total 14.86

a Estimated em1ss1ons based on the 1997 annual mr em1ss1ons mventory and September 1997 PM em1ss1ons study.

b Estimated emissions based on the September 1997 PM emissions study, 2009 ACDP application, and comparison to similar emission units.

c Estimated emissions based on the September 1997 PM emissions study, 2001 Title V permit, and comparison to similar emission units.

d Estimated emissions based on the September 1997 PM emissions study and comparison to similar

emission units.

Review Report/Permit No.: 22-0011-TV -OJ Application No.: 27034, 28082, 28443

Page20 of29

• Estimated emissions based on the September 1997 PM emissions study and 2009 ACDP application.

NOx

Emission Factor Annual Eu ID EU Description Annual Emissions

Production Rate Rate I Reference (tons/yr)

NGBL BOIL-02 41.8 MM ft' 100 lbs/MM ft' DEQ Factor 2.09 NG

BOIL-10 13.7 MM It' 100 lb/MM It' DEQ Factor 0.69 NG

BOIL-12 3.4 MM It' 100 lb/MM ft3 DEQ Factor 0.17 NG

BOIL-13 18.9 MM ft3 100 lb/MM It' DEQ Factor 0.94 NG

BOIL-14 12.9 MM ft3 100 lb/MM II" DEQ Factor 0.64 NG

BOIL-15 12.9 MM ft3 100 lb/MM ft3 DEQ Factor 0.64 NG

BOIL-16 12.9 MM ft3 100 lb/MM fP DEQ Factor 0.64 NG

BOIL-17 14.4 MM It' 100 lb/MM It' DEQ Factor 0.72 NG

BOIL-18 4.3 MM ft3 100 lb/MM ft3 DEQ Factor 0.21 NG

BOIL-19 4.3 MM It' 100 lb/MM fP DEQ Factor 0.21 NG

NG-01-03,05-07 17.8 MM fP 100 lbs/MM ft3 DEQ Factor 0.89 NG

SCRB-02 Heated Acid Bath 10,512 MM sci 0.392 lbs/MM 10 ppm 2.06 #1 set measured in

1997 and 65% control

from manufacturer specifications

SCRB-04 Heated Acid Bath 14,454 lbs inlet 65% removal Manufacturer 2.53 (A5) #2

SCRB-04 Cold Etch Bath 23,827 lbs inlet 65% removal Manufacturer 4.17 (A4N)

SCRB-05 Scrap Milling 4,126 MM set 1.567 lb/MM set 40 ppm 3.23 Tank measured in

1997 and 65% control

from manufacturer specifications

OV01,04- Burnout ovens 195.8 MM ft3

08,16-17 01,04-08, 16-17 NG

AI

co

Eu ID EU Description Annual Production Rate

NGBL BOIL-02 41.8 MM ft3

NG

BOIL-10 13.7 MM ft3

NG

BOIL-12 3.4 MM ft3 NG

BOIL-13 18.9 MM ft3

NG

BOIL-14 12.9 MM ft3

NG

BOIL-15 12.9 MMfP NG

BOIL-16 12.9 MM fP NG

BOIL-17 14.4 MM ft3

NG

BOIL-18 4.3 MM fP NG

BOIL-19 4.3 MM ft3

NG

NG-01-03,05-07 17.8 MM fP NG


08,16-17 01' 04-08, 16-17 NG

AI

Review Report/Permit No.: 22-00 II-TV -01 Application No.: 27034, 28082, 28443

Page 21 of29

100 lbs/MM ft3 DEQ Factor 9.79

0.0

Total 29.65

Emission Factor Annual Emissions

Rate I Reference (tons/yr)

84 lbs/MM fP DEQ Factor 1.76












0.0

Total 14.83

voc

EuiD EU Description Annual Production Rate

OV01,04- Burnout ovens 511 tons 08,16-17 01,04-08, 16-17 casting

FWVOC Facility-wide use 511 tons containing casting compounds

NGBL BOIL-02 41.8 MMfP NG

BOIL-10 13.7 MM ft3

NG

BOIL-12 3.4 MMfP NG

BOIL-13 18.9 MM ft3

NG

BOIL-14 12.9 MM ft3

NG

BOIL-15 12.9 MMfP NG

BOIL-16 12.9 MM ft3

NG

BOIL-17 14.4 MM ft3

NG

BOIL-18 4.3 MM ft3

NG

BOIL-19 4.3 MM ft3

NG

NG-01-03,05-07 17.8 MMfP NG

AI

Review Report/Permit No.: 22-00 II-TV -0 I Application No.: 27034, 28082,28443

Page22 of29



2.7 lb/ton Precision castings Cast Parts

Permit No. 0.69 26-1867-ST-01' 9/2012

0.48 lb/lb Projected castings usage based

245.3 on historical data

5.5 lbs/MM fP DEQ Factor 0.11

5.5 lbs/MM ft3 DEQ Factor 0.04






5.5 lbs/MM ft' DEQ Factor 0.04


5.5 lbs/MM ft' DEQ Factor 0.01


1.0

Total 247.4

EuiD EU Description Annual Production Rate

NGBL BOIL-02 41.8 MM ft' NG

BOJL-10 13.7 MM ft' NG

BOIL-12 3.4 MM ft3

NG

BOIL-13 18.9 MM ft' NG

BOIL-14 12.9 MM ft3

NG

BOIL-15 12.9 MM ft3

NG

BOIL-16 12.9 MM ft3

NG

BOIL-17 14.4 MM ft3

NG

BOIL-18 4.3 MM ft3

NG

BOIL-19 4.3 MM ft3

NG

NG-01-03,05-07 17.8 MM ft3

NG


08,16-17 01,04-08, 16-17 NG

AI

Review Report/Penni! No.: 22-0011-TV-01 Application No.: 27034, 28082, 28443

Page 23 of29















0.0

Total 0.30

1 The annual emissions for S02 are below the de minimis level of 1 tpy, therefore is no PSEL requested.

Greenhouse Gases (C02e)

Emission Factor Annual Eu ID EU Description Annual Emissions

Production Rate Rate I Reference (tons/yr)

NGBL BOIL-02 41.8 MM ft' 120,141 lbs/MM ft3 DEQ Factor NG 2,511

BOIL-10 13.7 MM ft3 120,141 lbs/MM ft' DEQ Factor NG 825

BOIL-12 3.4 MM ft3 120,141 lbs/MM ft' DEQ Factor NG 206

BOIL-13

BOIL-14

BOIL-15

BOIL-16

BOIL-17

BOIL-18

BOIL-19

NG-01-03,05-07

OV01,04- Burnout ovens 08,16-17 01,04-08, 16-17

AI

EuiD EU Description

SCRB-02 Heated Acid Bath #1

SCRB-04 Heated Acid Bath (A5) #2

SCRB-04 Cold Etch Bath (A4N)

SCRB-05 Scrap Milling Tank

18.9 MM ft' NG

12.9 MM ft' NG

12.9 MM ft3 NG

12.9 MM ft' NG

14.4 MM ft' NG

4.3 MM ft3 NG

4.3 MM ft' NG

17.8 MM ft' NG

195.8 MM ft3 NG


Page 24 of29

120,141 lbs/MM ft' DEQ Factor 1,135

120,141 lbs/MM ft' DEQ Factor 774


120,141 lbs/MM ft3 DEQ Factor 774

120,141 lbs/MM ft3 DEQ Factor 867



120,141 lbs/MM ft3 DEQ Factor 1,070

120,141 lbs/MM ft3 DEQ Factor 11,763

0

Total 21,215

Fluorides'

Emission Factor Annual Annual Emissions Production

Rate Rate Reference (tons/yr)

0.06 lb/hr 99 % Manufacturer 0.003 inlet removal



99 % Manufacturer Neg!. Neg!. Inlet removal

Total 0.02 ..

'The annual em1ss1ons for Fluondes are below the de m1n1m1s level of 0.3 tpy, therefore 1s no PSEL requested.

EuiD

DC-01

DC-02

DC-03

DC-08

DC-10

DC-15

DC-26

DC-27

DC-28

CF-01

CF-02

CF-03

CF-04

EF-36

WC-04,05,08, 09


Page 25 of29

Pacific Cast Technologies Aggregate Insignificant Emissions

PM/PM10/PM2 s

Annual Emission Factor Annual

EU Description Production Emission

Rate Rate Reference s (tons/yr)

Investing prime 1,215 lbs dust 99.9% removal Manufactur 6.1 E-04 cell rainfall er sander 5

Investing back- 608 lbs dust 99.9% removal Manufactur 3.0E-04 up cell rainfall er sander1

Sandblaster, 511 tons 9.05E- lb/lb Eng. Est.a 0.046 Knockout castings 05 castings

Invest back-up 1,299 lbs dust 99.9% removal Manufactur 6.5E-04 cell grinding er room Grinding dust 94 lbs dust 99.9% removal Manufactur 4.7E-05 collector 10, er Knockout

Sandblaster 31 lbs dust 98.0% removal Eng. Estb 3.1E-04

Grinding wet 94 lbs dust 99.9% removal Manufactur 4.7E-05 collector 1 er

Burnoff dust 1,215 lbs dust 99.9% removal Manufactur 6.1E-04 collector 27 er

Investing 1,299 lbs dust 99.9% removal Manufactur 6.5E-04 intermediate line er sander, Knockout Casting furnace 511 tons 0.21 lb/ton Eng. Est.c 0.013 1 castings castings

Casting furnace 511 tons 0.21 lb/ton Eng. Est.c 0.013 2 castings castings



Exhaust fan, 511 ton 0.14 lb/ton Precision 0.04 autoclave castings casting Cast Parts

Permit No. 26-1867-ST-01, . 9/2012 '

Wet collectors, 8,760 hr/yr 0.05 lb/hr Manufactur 0.219 Building D er, 2016 IH

study


Page 26 of29

WC-07 Finishing 3,650 hr/yr 0.0158 lb/hr Manufactur 0.029 operations er

EF-27 Exhaust fan, wax 512,1 lbs wax 0 lb/lb wax Eng. Estd Neg I. leach tanks 39

EF-28 Exhaust fan, wax 512,1 lbs wax 0 lb/lb wax Eng. Est.' Neg I. leach tanks 39

SMKC- Wax stations 1-5 512,1 lbs wax 0 lb/lb wax Eng. Est.' Neg I. 01-03,05 39

Total 0.39

a Estimated em1ss1ons based on the September 1997 PM emiSSions study, 2009 ACDP application, and comparison to similar emission units.

b Estimated emissions based on 2013-2016 sand usage and operating time.

c Estimated emissions based on the 1997 annual air emissions inventory and September 1997 PM emissions stud .

' Estimated emissions based on process knowledge and historical wax usage.

NOx There are no emission units considered Aggregate Insignificant for NOx.

co There are no emission units considered Aggregate Insignificant for CO.

voc

Annual Emission Factor

Eu ID EU Description Production Rate Rate

EF-36 Exhaust fan, 511 ton 0.09 lb/ton autoclave castings casting

so2 There are no emission units considered Aggregate Insignificant for S02.

Greenhouse Gases (C02e) There are no emission units considered Aggregate Insignificant for C02e.

Reference

Precision Cast Parts Permit No. 26-1867-

ST-01, 9/2012 Total

Annual Emission

s jtonslyr) 2.30E-02

2.30E-02

Review Report/Permit No.: 22-0011-TV-01 Application No.: 27034,28082,28443

Page27 of29

Pacific Cast Technologies Process HAP Emissions

Methanol

EuiD EU Description Annual Production Emission Factor Annual Rate Emissions

(tons/yr) Rate Reference

FWVOC Facility-wide use of 511 tons castings 0.0022 lb/lb casting 2013 data 1.13 VOC containing

compounds

Total 1.13

MIBK




compounds

Total 0.24

Toluene

Eu ID EU Description Annual Production Emission Factor Annual Rate Emissions



compounds

Total 1.23

Hydrogen Fluoride



SCRB-02 Heated Acid Bath #1 0.06 lb/hr inlet 99% removal Manufactur 0.003 er data

SCRB-04 Heated Acid Bath #2 0.14 lb/hr inlet 99% removal Eng. Est. 0.006 (A5) SCRB-04 Cold Etch Bath 0.24 lb/hr inlet 99% removal Eng. Est. 0.010 (A4N) SCRB-05 Scrap Milling Tank Negl. Inlet 99% removal Eng. Est. Neg I.

Total 0.02

Pollutant

Organic HAPs

Benzene

Dichlorobenzene Formaldehyde

Hexane

Naphthalene Toluene

POM

Metallic HAPs Lead

Arsenic

Beryllium Cadmium

Chromium Cobalt

Manganese

Mercury Nickel

Selenium

Other Organics Butane

Ethane

Pentane

Methane Propane

Other Metals Barium

Copper

Molybdenum Vanadium

Zinc

Review Report/Pennit No.: 22-00 II-TV -0 I Application No.: 27034, 28082, 28443

Page28 of29

Pacific Cast Technologies Natural Gas Combustion Emissions

Emission Factor Emissions (lb/MMft3 NG)* (lb/yr)**

2.1E-03 0.74

1.2E-03 0.42

7.5E-02 26.48

1.8 635.58

6.1E-04 0.22

3.4E-03 1.20 3.2E-05 0.01

Sum 664.65

5.0E-04 0.18 2.0E-04 0.07

1.2E-05 0.004

1.1E-03 0.39

1.4E-03 0.49

8.4E-05 0.03

3.8E-04 0.13 2.6E-04 0.09

2.1E-03 0.74

2.4E-05 0.008

Sum 2.132

2.1 741.51

3.1 1094.61

2.6 918.06

2.3 812.13

1.6 564.96

Sum 4131.27

4.4E-03 1.55

8.5E-04 0.30

1.1E-03 0.39 2.3E-03 0.81

2.9E-02 10.24

Sum 13.29

Grand Total 4811.342 lbs/yr or 2.41 tons/yr

*Em1ss1on factors from AP-42 Chapter 1.4 (7 /98) **Based on 353.1 MMft3 NG combusted annually

Review Report/Permit No.: 22-0011-TV-0 I Application No.: 27034, 28082, 28443

Page 29 of29

Pacific Cast Technologies CAM Applicability Analysis 2016*

EUID Emission Pollutant Control Limit or Point Device Standard

Used? ?

AB SCRB2 NO, y N

SCRB4 NO, y N

SCRBS NO, y N

KO DC7 PM y y

DC12 PM y y

DC16 PM y y

DC19 PM y y

DC21 PM y y

DC29 PM y y

WC3 PM y y

MM DC4 PM y y

DC11 PM y y

DC17 PM y y

wx OV1 voc y N

PM y y

OV4 voc y N PM y y

ovs voc y N

PM y y

OV6 voc y N

PM y y

OV7 voc y N PM y y

Pacific Cast Technologies CAM Applicability Analysis 2016*

Exempt PTE >100 CAM from T/Y Pre- Required CAM? control ?

?

N N N N N N

N N N

N N N

N N N N N N N N N N N N

N N N N N N

N N N N N N N N N

N N N N N N

N N N N N N N N N N N N

N N N

N N N N N N

N N N

PTE Post CAM Periodic Existing control Unit Monitoring Monitoring

>100 T/Y Size Required?

N Source test

N Source test

N Source test

N Quarterly VE

N Quarterly VE N Quarterly VE


N Quarterly VE

N Quarterly VE


N Quarterly VE

N Quarterly VE

N Quarterly VE

N Quarterly VE

N Quarterly VE



N Quarterly VE

N Quarterly VE

ovs VOC y N N N N N Quarterly VE

PM y y N N N N Source Test

OV16 voc y N N N N N Quarterly VE

PM y y N N N N Source Test

OV17 VOC y N N N N N Quarterly VE

PM y y N N N N Quarterly VE

BLDGC WGRBl PM y y N N N N Quarterly VE

WGRB2 PM y y N N N N Quarterly VE



WGRBS PM y y N N N N Quarterly VE

BLDGH WClO PM y y N N N N Quarterly VE

WCll PM y y N N N N Quarterly VE

WC12 PM y y N N N N Quarterly VE



WC15 PM y y N N N N QuarterlyVE






*Other emission units not shown or pollutants not shown in the emission units above do not have controls and cannot be subject to CAM.

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