Y- -~;YSWCAA Southwest Clean Air Agency

-~;YSWCAA Y-..."" , , Southwest Clean Air Agency

TECHNICAL SUPPORT DOCUMENT

CULLIGAN MACHINERY AND CONTRACTING, INC. SWCAA ID: 2508

Air Discharge Permit I Nonroad Engine Permit 17-3238

Air Discharge Permit I Nonroad Engine Application CL-3020

Prepared By: Clint Lamoreaux Air Quality Engineer Southwest Clean Air Agency

Issued: July 13, 2017

Technical Support Document Culligan Machinery and Contracting

Section

ADP I Nonroad Engine Permit Application CL-3020 SWCAA 17-3238

TABLE OF CONTENTS

1. Facility Identification 1

2. Facility Description 1

3. Current Permitting Action 1

4. Process Description 1

5. Equipment/Activity Identification 1

6. Emissions Determination 4

7. Regulations and Emission Standards 9

8. RACT/BACT/BART/LAER/PSD/CAM Determinations 10

9. Ambient Impact Analysis 11

10. Discussion of Approval Conditions 11

11. Start-up and Shutdown Provisions/ Alternative Operating Scenarios/Pollution 12 Prevention

12. Emission Monitoring and Testing 13

13. Facility History 13

14. Public Involvement 13



Abbreviations

ADP AP-42

BACT BART CFR co C02e EPA gal GWP HAP LAER lb/hp-hr lb/hr lb/yr MMBtu NOx PM

PM10

PM2.s

PSD psig PTE RACT RCW SQER S02 SOx SW CAA TAP T-BACT tpy voe WAC

Air Discharge Permit Compilation of Emission Factors. AP-42, Fifth Edition, Volume 1. Stationary Point and Area Sources -published by the US Environmental Protection Agency Best Available Control Technology Best Available Retrofit Technology Code of Federal Regulations Carbon monoxide Carbon dioxide equivalent as defined in 40 CFR 98 U.S. Environmental Protection Agency U.S. Gallon Global Warming Potential Hazardous Air Pollutant listed pursuant to Section 112 of the Federal Clean Air Act Lowest Achievable Emission Rate Pounds per horsepower per hour Pounds per hour Pounds per year Millions of British thermal units Nitrogen oxides Particulate matter with an aerodynamic diameter less than 100 micrometers (includes both filterable particulate matter measured by EPA Method 5 and condensable particulate matter measured by EPA Method202) Particulate matter with an aerodynamic diameter less than or equal to 10 micrometers (includes both filterable particulate matter measured by EPA Method 201 or 201 A and condensable particulate matter measured by EPA Method 202) Particulate matter with an aerodynamic diameter less than or equal to 2.5 micrometers (includes both filterable particulate matter measured by EPA Method 201 or 201 A and condensable particulate matter measured by EPA Method 202) Prevention of Significant Deterioration Pounds per square inch, gage Potential to Emit Reasonably Available Control Technology Revised Code of Washington Small Quantity Emission Rate listed in WAC 173-460 Sulfur dioxide Sulfur oxides Southwest Clean Air Agency Toxic Air Pollutant pursuant to Chapter 173-460 WAC Best Available Control Technology for toxic air pollutants Tons per year Volatile organic compound Washington Administrative Code


1. FACILITY IDENTIFICATION Applicant Name: Culligan Machinery and Contracting, Inc.


Applicant Address: 1075 Rustler Peak Street, Central Point, OR 97502

Facility Name: Facility Address: Contact Person: SWCAA Identification:

Primary Process: SIC/NAICS Code: Facility Designation:

Culligan Machinery and Contracting, Inc. Portable Kristopher Culligan 2508

Crushed and Broken Stone I Other Crushed and Broken Stone Mining and Quarrying 1429/212319 Natural minor

2. FACILITY DESCRIPTION The proposed equipment consists of a portable stone crushing facility consisting of one jaw crusher, one cone crusher, and one screen, each driven by separate diesel engines.

3. CURRENT PERMITTING ACTION This permitting action is in response to Air Discharge Permit I Nonroad Engine Permit application number CL-3020 (ADP Application CL-3020) received June 23, 2017. ADP application CL-3020 requests approval to operate a portable rock crushing facility powered by diesel engines.

4. PROCESS DESCRIPTION Rock is fed to the jaw crusher feeder via front end loader or backhoe. Transfer to the downstream crusher and screen is by conveyors. High pressure water spray will be used to control fugitive dust at the infeed of each crusher and at the screen, and wet suppression will be used as necessary at material transfer points. Each of the crushers and the screen are powered by diesel engines.

5. EQUIPMENT/ACTIVITY IDENTIFICATION

5.a Jaw Crusher. This unit is track mounted. Wet dust suppression will be provided at the inlet of the crusher and as necessary at associated material handling points.

Plant Make I Model: Plant Serial Number: Description: Year Built: Size/Capacity: Federal Regulations:

Metso Norberg I LT105 (uses the model C105 crusher) 72217 28" x 42" Jaw Crusher 2003 -350 tons per hour 40 CFR 60 Subpart 000

5.b Cone Crusher. This unit is track mounted. Wet dust suppression will be provided at the inlet of the crusher and as necessary at associated material handling points.

Plant Make I Model: Plant Serial Number: Year Built: Size/Capacity: Federal Regulations:

Metso Norberg I LT300 (uses the model HP300 crusher) 73179 2006 -350 tons per hour 40 CFR 60 Subpart 000



5 .c Screen. This unit is track mounted. Wet dust suppression will be provided at the screen decks and as necessary at associated material handling points.

Make I Model: Serial Number: Description: Year Built Estimated Capacity: Federal Regulations:

Metso Norberg I Locotrack ST620 (uses Norberg DS303 triple deck screen) 73487 5' 11" x 19' 8" 2007 660 tons per hour 40 CFR 60 Subpart 000

5 .d Haul Roads and Conveyors. Dump trucks or other equipment may be used to transport material to, from, or within a work area.

5.e Jaw Crusher Engine. This engine drives the Jaw Crusher plant. This engine drives the tracks on the jaw crushing plant and therefore is a non-road engine.

Engine Make I Model: Engine Serial Number: Fuel: Engine Power Rating: Engine Built Engine Certification: Stack Description: Federal Regulations:

Caterpillar I C-9 CLJ02219 Diesel 345 hp September 25, 2002 EPA Tier 2 Not provided. 40 CFR 89 (this is a non-road engine)

5.f Cone Crusher Engine. This engine drives the cone crushing plant. This engine drives the tracks on the cone crushing plant and therefore is a non-road engine.


Caterpillar I C 15 JRE00640 Diesel 540hp August 16, 2005 EPA Tier 3 Not provided. 4,145 acfm@ l,183.5°F. 40 CFR 89 (this is a non-road engine)

5.g Screen Engine. This engine drives the screen plant. This engine drives the tracks on the screen plant, and therefore is a non-road engine.


Caterpillar I C6.6 66601522 Diesel 174 hp August 26, 2006 EPA Tier 3 Not provided. 1,068 acfm at 920°F. 40 CFR 89 (this is a nonroad engine)

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5.h Equipment/Activity Summary.

.JD No. Generating Eq uipmentl Activity

I Jaw Crusher (Norberg model L Tl 05)

2 Cone Crusher (Norberg model LT300)

3 Screen (Norberg Locotrack model LT620)

4 Haul Roads and Conveyors

5 Jaw Crusher Engine (Caterpillar model C-9)

6 Cone Crusher Engine (Caterpillar model C 15)

7 Screen Engine (Caterpillar model C6.6)

#of Units

I

I

l

-

I

l

I

3

ADP I Nomoad Engine Permit Application CL-3020 SWCAA 17-3238

#of Control Measure/Equipment Units

High pressure wet suppression at crusher NIA entrance

High pressure wet suppression at crusher NIA entrance

High pressure wet suppression NIA

Wet suppression as necessary NIA

Ultra-low sulfur fuel, NIA EPA Tier 2 certification




6. EMISSIONS DETERMINATION


6.a Crushing and Screenin12: Ooerations. Potential emissions from crushing, screening, and material transfer are calculated from an aggregate throughput and emission factors from EPA AP-42, Table 11.19.2-2 (8/04). Emission factors for all stages except primary crushing are "controlled" factors from the 8/04 version of the table. Emission factors for primary crushing are taken from the 1/95 version of the table which only provided an "uncontrolled" PM factor for primary crushing. An 'uncontrolled' factor for PM10 was calculated using the 2.1: 1 ratio of PM to PM10 specified in the table footnotes. An "uncontrolled" factor for PM2.s was calculated using a PM to PM2.s ratio of 12:1 which is based on the tested PM to PM2.s ratio for tertiary crushing in the 8/04 version of the table. A control efficiency of 80% was applied to the primary crushing factors to account for the use of wet suppression. The blasting emission factors come from AP-42, Table 11.9 .1 assuming a blast area of 17 ,000 square feet, a blast depth of 20 feet, and a material density of 3,240 pounds per cubic yard.

Activity Primary crushing

(3" - 12")

Secondary crushing (l"-4")

Tertiary crushing (3/16" - 1 ")

Screening

Loading/conveying

Blasting

Throughput (tpy)

400,000

400,000

400,000

400,000

400,000

400,000

Pollutant PM

PM10

PM2.s PM

PM10 PM2.s PM

PM 10

PM2.s PM

PM10

PM2.s PM

PM 10

PM25 PM

PM 10

PM2.s

4

Emission Factor - Transfer Emissions Controlled (lb/ton) Points (lbs)

0.00014 56 0.000067 27 0.000012 5

0.0012 480 0.00054 216 0.0001 40 0.0012 480

0.00054 216 0.0001 40 0.0022 880

0.00074 296 0.00005 20 0.00014 10 560 0.000046 184 0.000013 52

0.0015 608 0.00079 316

0.000046 18



6.b Haul Roads. Emissions from haul roads were calculated using default emission calculations from EPA AP-42, Section 13.2.2 (12/03), an average load weight of 20 tons, an average silt content of 4.8%, and an average round trip distance of 0.5 miles. The use of wet suppression is expected to provide an overall control efficiency of 80% for haul road emissions.

Where: w = average truck weight in tons; s =road surface silt content(%); and

The constants k, a, and b are given in the table below:

Constant PM2.s PM10 PMJo (assumed to represent PM) k (lb/vehicle mile traveled) 0.23 1.5 4.9 a 0.9 0.9 0.7 b 0.45 0.45 0.45

Maximum haul road emissions are estimated in the table below.

Haul Road Emissions Average Truck Weight = Average Round Trip Distance = Amount of Aggregate per Load = Total# of Trips= Total Miles Traveled = Assumed Silt Content = Assumed Control (wet suppression)=

Pollutant PM

PM10

PM25

27 tons (assumes empty weight of 17 tons) 0.50 miles 20.0 tons

20,000 loads 10,000 miles

4.8% 80%

Uncontrolled Controlled Emission Emission

Factor Factor Emissions Emission Factor lb/mile lb/mile tpy Source

6.94 1.39 6.94 AP-42 13.2.2 (11/06)

1.77 0.35 1.77 AP-42 13.2.2 (11/06)

0.27 0.054 0.27 AP-42 13.2.2 (11/06)

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ADP I Nooroad Engine Permit Application_CL-3020 SWCAA 17-3238

6.c Jaw Crusher Engine. Potential annual emissions from the combustion of ultra-low sulfur diesel (<0.0015% sulfur by weight) were calculated with the assumption that the equipment will operate at full load for up to 1,000 hours per year. The engine is capable of producing an estimated 345 horsepower at full load.

Jaw Crusher Engine

Hours of Operation = 1,000 hours Power Output = 345 horsepower (estimated based on generator size) Diesel Density = 7 .206 pounds per gallon Fuel Sulfur Content = 0.0015 % by weight Fuel Consumption Rate = 17 .25 gallons per hour Fuel Heat Content = 0.138 MMBtu/gal (for use with GHG factors from 40 CFR 98) Annual Fuel Consumption = 17 ,250 gallons

Emission Emission Factor Factor Emissions Emission Factor

Pollutant lb/hp-hr lb/hr tov Source

NOx 0.0132 4.54 2.27 Caterpillar - Potential Site Variation co 0.0021 0.72 0.36 Caterpillar - Potential Site Variation voe 0.0005 0.17 0.09 Caterpillar - Potential Site Variation SOx as S02 0.000011 0.0037 0.002 Mass Balance

PMIPM10IPM2.s 0.0002 0.07 0.03 Caterpillar - Potential Site Variation

C02e C02e

Greenhouse Gases kg/MMBtu GWP lb/MMBtu lb/gallon tpy, C02e

C02 73.96 1 163.05 23 194 40CFR98 CH4 0.003 25 0.165 0.023 0.20 40CFR98

N20 0.0006 298 0.394 0.054 0.47 40CFR98 Total GHG - C02e 73.9636 163.613 23 195

Emissions must be calculated using the hourly emission factors identified above unless new emission factors are provided by the manufacturer or developed through source testing.

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6.d Cone Crusher Engine. Potential annual emissions from the combustion of ultra-low sulfur diesel (<0.0015% sulfur by weight) were calculated with the assumption that the equipment will operate at full load for up to 1,000 hours per year. The engine is capable of producing 540 horsepower at full load.

Cone Crusher Engine

Hours of Operation = 1,000 hours Power Output = 540 horsepower Diesel Density = 7 .206 pounds per gallon Fuel Sulfur Content = 0.0015 % by weight Fuel Consumption Rate = 28.7 gallons per hour (Caterpillar) Fuel Heat Content = 0.138 MMBtu/gal (for use with GHG factors from 40 CFR 98) Annual Fuel Consumption = 28,700 gallons


Pollutant lb/hp-hr lb/hr tpy Source

NOx 4.01 2.01 Caterpillar - Potential Site Variation co 3.92 1.96 Caterpillar - Potential Site Variation voe 0.11 0.055 Caterpillar - Potential Site Variation SOx as S02 0.000011 0.0062 0.003 Mass Balance

PMIPM10IPM2.s 0.40 0.200 Caterpillar - Potential Site Variation

C02e C02e


C02 73 .96 1 163.05 23 323 40CFR98

CH4 0.003 25 0.165 0.023 0.33 40 CFR98

IN20 0.0006 298 0.394 0.054 0.78 40 CFR98 Total GHG - C02e 73.9636 163.613 23 324


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6.e Screen Engine. Potential annual emissions from the combustion of ultra-low sulfur diesel (<0.0015% sulfur by weight) were calculated with the assumption that the equipment will operate at full load for up to 1,000 hours per year. The engine is capable of producing 174 horsepower at full load.

Screen Engin

Hours of Operation = 1,000 hours Power Output = 17 4 horsepower Diesel Density = 7 .206 pounds per gallon Fuel Sulfur Content = 0.0015 % by weight Fuel Consumption Rate = 10.22 gallons per hour Fuel Heat Content = 0.138 MMBtu/gal (for use with GHG factors from 40 CFR 98) Annual Fuel Consumption = 10,220 gallons


Pollutant lb/hp-hr lb/hr tpy Source

NOx 0.0057 0.99 0.50 EPA Family Cert. Data co 0.0030 0.52 0.26 EPA Family Cert. Data voe 0.00015 0.026 0.013 EPA Family Cert. Data SOx as S02 0.000013 0.0022 0.0011 Mass Balance

PM/PM HIPM2.s 0.00024 0.043 0.021 EPA Family Cert. Data

C02e C02e


C02 73.96 1 163.05 23 115 40 CFR 98

CRi 0.003 25 0.165 0.023 0.12 40 CFR98

N 20 0.0006 298 0.394 0.054 0.28 40 CFR98 Total GHG - C02e 73 .9636 163.613 23 115


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6.f Facilitywide Potential Emissions (PIE) Summary.

Stationary PTE Pollutant tons er ear Nitrogen oxides 0 Carbon monoxide 0 Volatile organic compounds 0 Sulfur oxides as sulfur dioxide 0 Particulate matter 8.47 PM10 2.40 PM2.s 0.36 Toxic Air Pollutants 0 Hazardous Air Pollutants 0 C02e 0

7. REGULATIONS AND EMISSION STANDARDS


NonroadPTE TotalPTE tons er ear tons er ear

4.77 4.77 2.58 2.58 0.15 0.15

0.006 0.006 0.26 8.72 0.26 2.65 0.26 0.61

0 0 0 0

634 634

Regulations that have been used to evaluate the acceptability of the proposed facility and establish emission limits and control requirements include, but are not limited to, the regulations, codes, or requirements listed below.

7.a Title 40 Code of Federal Regulations (40 CFR) Part 60.670 et seq. (Subpart 000) "Standards of Performance for Nonmetallic Mineral Processing Plants" establishes opacity and particulate matter emission limits for stationary (fixed) plants with capacities greater than 25 tons per hour and portable plants greater than 150 tons per hour that were constructed, reconstructed or modified after August 31, 1983. More stringent requirements apply to affected facilities constructed, reconstructed or modified on or after April 22, 2008.

7.b 40 CFR 89 includes requirements for nonroad engines. The definition of nonroad engines in 40 CFR 89.2 includes any internal combustion engine described in (1 )(i) "In or on a piece of equipment that is self-propelled or serves a dual purpose by both propelling itself and performing another function (such as garden tractors, offhighway mobile cranes and bulldozers)." The diesel engines on both crushers and the screen power the tracks on the respective units and therefore are nonroad engines. In accordance with Part 89, nonroad engines must meet the appropriate EPA Tier certification standards based on engine size and year of manufacture. In accordance with Appendix A of Subpart 89, states are precluded from requiring retrofitting of nonroad engines except that states are permitted to adopt and enforce any such retrofitting requirements identical to California requirements which have been authorized by EPA under section 209 of the Clean Air Act. States may enforce limitations on hours of usage, daily mass emission limits, and sulfur limits on fuel as necessary.

7.c Revised Code of Washington (RCW) 70.94.141 empowers any activated air pollution control authority to prepare and develop a comprehensive plan or plans for the prevention, abatement and control of air pollution within its jurisdiction. An air pollution control authority may issue such orders as may be necessary to effectuate the purposes of the Washington Clean Air Act [RCW 70.94] and enforce the same by all appropriate administrative and judicial proceedings subject to the rights of appeal as provided in Chapter 62, Laws of 1970 ex. sess.

7.d RCW 70.94.152 provides for the inclusion of conditions of operation as are reasonably necessary to assure the maintenance of compliance with the applicable ordinances, resolutions, rules and regulations when issuing an Air Discharge Permit for installation and establishment of an air contaminant source.

7.e Washington Administrative Code (WAC) 173-460 "Controls for New Sources of Toxic Air Pollutants" (as in effect August 21, 1998) requires Best Available Control Technology for toxic air pollutants (T-BACT), identification and quantification of emissions of toxic air pollutants and demonstration of protection of human health and safety.

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7 .f WAC 173-476 "Ambient Air Quality Standards" establishes ambient air quality standards for PM10, PM2.s, lead, sulfur dioxide, nitrogen dioxide, ozone, and carbon monoxide in the ambient air, which shall not be exceeded.

7 .g SW CAA 400-040 "General Standards for Maximum Emissions" requires all new and existing sources and emission units to meet certain performance standards with respect to Reasonably Available Control Technology (RACT), visible emissions, fallout, fugitive emissions, odors, emissions detrimental to persons or property, sulfur dioxide, concealment and masking, and fugitive dust.

7.h SWCAA 400-040(1) "Visible Emissions" requires that no emission of an air contaminant from any emissions unit shall exceed twenty percent opacity for more than three minutes in any one hour at the emission point, or within a reasonable distance of the emission point.

7.i SW CAA 400-040(2) "Fallout" requires that no emission of particulate matter from any source shall be deposited beyond the property under direct control of the owner(s) or operator(s) of the source in sufficient quantity to interfere unreasonably with the use and enjoyment of the property upon which the material is deposited.

7 .j SW CAA 400-040(3) "Fugitive Emissions" requires that reasonable precautions be taken to prevent the fugitive release of air contaminants to the atmosphere. ·

7.k SWCAA 400-040(4) "Odors" requires any source which generates odors that may unreasonably interfere with any other property owner's use and enjoyment of their property to use recognized good practice and procedures to reduce these odors to a reasonable minimum.

7.1 SWCAA 400-040(8) "Fugitive Dust Sources" requires that reasonable precautions be taken to prevent fugitive dust from becoming airborne, and minimize emissions.

7.m SWCAA 400-050 "Emission Standards for Combustion and Incineration Units" requires that all provisions of SWCAA 400-040 be met and that no person shall cause or permit the emission of particulate matter from any combustion or incineration unit in excess of 0.23 grams per dry cubic meter (0.1 grains per dry standard cubic foot) of exhaust gas at standard conditions.

7.n SWCAA 400-060 "Emission Standards for General Process Units" requires that all new and existing sources not emit particulate matter in excess of 0.1 grains per dry standard cubic foot of exhaust gas.

7.o SWCAA 400-110 "New Source Review" requires that an Air Discharge Permit Application be filed with SW CAA, and an Air Discharge Permit be issued by SWCAA, prior to establishment of the new source, emission unit, or modification.

7.p SWCAA 400-113 "Requirements for New Sources in Attainment or Nonclassifiable Areas" requires that no approval to construct or modify an air contaminant source shall be granted unless it is evidenced that: (1) The equipment or technology will comply with all applicable New Source Performance Standards (NSPS),

emission standards adopted under RCW 70.94 and the applicable emission standards of SWCAA; (2) Best Available Control Technology (BACT) will be employed for all air contaminants to be emitted by the

proposed source; (3) The proposed equipment will not cause any ambient air quality standard to be exceeded; and (4) If the proposed equipment or facility will emit any toxic air pollutants regulated under WAC 173-460 the

proposed equipment and control measures will meet all the requirements of that Chapter.

8. RACT/BACT/BART/LAER/PSD/CAM DETERMINATIONS The proposed equipment and control systems incorporate Best Available Control Technology (BACT) for the types and amounts of air contaminants emitted by the processes as described below:

10


BACT Determinations

ADP I Nonroad Engine Permit Application Clr3020 SWCAA 17-3238

8.a BACT Determinations- Crushing and Screening. The use of high pressure wet suppression systems, including spray or fog nozzles operating at a minimum pressure of 80 psig, has been determined to meet the requirements of BACT for the proposed crushing and screening equipment. Because there are other wet suppression systems (e.g. sonic fogging systems) that utilize a lower water pressure but provide equivalent or superior levels of emission control, the permit will allow for wet suppression systems reviewed and approved by SWCAA that provide equivalent or superior control of particulate matter emissions.

8.b BACT Determination-Fugitive Dust. The use of wet suppression has been determined to meet the requirements of BACT for fugitive dust emissions from storage piles, material transfer points, and haul roads for this source.

PDS/CAM Determinations

8.c Prevention of Significant Deterioration (PSD) AP.Plicability Determination. This permitting action will not result in a potential increase in emissions equal to or greater than the PSD thresholds. Therefore, PSD review is not applicable to this action.

8.d Compliance Assurance Monitoring (CAM) AP.Plicability Determination. CAM is not applicable to any emission unit at this facility because it is not a major source and is not required to obtain a Part 70 permit.

9. AMBIENT IMPACT ANALYSIS Incremental increases in toxic air pollutant emissions will not exceed the applicable Small Quantity Emission Rates (SQER) listed in WAC 173-460 (in effect August 21, 1998); therefore, toxic impacts are presumed to be below regulatory significance. Potential emissions of criteria air pollutants (nitrogen oxides, carbon monoxide, sulfur dioxide, PM10) and volatile organic compounds are all at or below 4.8 tons per year each from the facility. At these emission rates, no adverse ambient air quality impact is anticipated.

Conclusions

9.a Operation of the crushing equipment as proposed in ADP I Nonroad Engine Permit Application CL-3020 and in accordance with Air Discharge Permit 17-3238 will not cause the ambient air quality standards established by Title 40 Code of Federal Regulations Part 50 ( 40 CFR 50), "National Primary and Secondary Ambient Air Quality Standards" to be violated.

9.b The crushing plant proposed in ADP I Nonroad Engine Permit Application CL-3020, if properly installed and maintained, can be operated without causing a violation of the applicable emission standards, which include the limits established under SWCAA 400-040 "General Standards for Maximum Emissions."

9.c Operation of the crushing plant as proposed in ADP I Nonroad Engine Permit Application CL-3020 and in accordance with Air Discharge Permit 17-3238 will not cause the requirements of WAC 173-460 "Controls for New Sources of Toxic Air Pollutants," (in effect August 21, 1998) or WAC 173-476 "Ambient Air Quality Standards" to be violated.

10. DISCUSSION OF APPROVAL CONDITIONS SWCAA has made a determination to issue Air Discharge Permit I Nonroad Engine Permit 17-3238 in response to application CL-3020. Air Discharge Permit I Nonroad Engine Permit 17-3238 contains approval requirements deemed necessary to assure compliance with applicable regulations and emission standards as discussed below.

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10.a General Basis. Approval conditions for equipment affected by this permitting action incorporate the operating schemes proposed by the permittee in the Air Discharge Permit application.

1 O.b Emission Limits. Annual emission limitations for the equipment addressed in this permitting action were established equal to the potential to emit identified in Section 6. As discussed in Section 8, these emission limits meet the requirements of BACT. Based on information available to SWCAA, it is SWCAA's understanding that the emission limits established in the permit will not constrain future operation.

Visible emissions from the diesel engines were limited to 5% opacity. Visible emissions should not exceed this level if the engines are operating properly. For nonroad engines, visible emissions can be used as a surrogate indicator that the engine is in good repair (rather than a tailpipe emission standard otherwise precluded by 40 CFR 89). For the nonroad engines, this restriction is appropriate because if the engines are not maintained in good repair, emissions are likely to greatly exceed the expected emission level and could cause an exceedance of a state or federal ambient air quality standard.

1 O.c Operating Limits and Requirements. A visible emission limit (not to exceed 0% opacity for more than three minutes in any one hour) for the crushing and conveying equipment has been established consistent with proper operation of the proposed wet suppression systems and the requirements of 40 CFR 60, Subpart 000. High pressure spray systems ~ 80 psig) or equivalent have been determined to be a minimum BACT requirement for individual pieces of rock crushing and aggregate screening equipment.

10.d Monitoring and Recordkeeping. Sufficient monitoring and recordkeeping was established to document compliance with the annual emission limits and provide for general requirements (e.g. excess emission reporting, annual emission inventory submission). In addition, upset conditions must be recorded for each occurrence. For the purposes of this requirement, an upset condition is a failure, breakdown, or malfunction of any piece of process equipment or pollution control equipment that causes, or has the potential to cause, excess emissions. This log can be useful to plant operators and SW CAA staff when evaluating whether equipment is being properly operated and maintained.

10.e Emission Monitoring and Testing Requirements. See Section 12.

1 O.f Reporting. The permit requires reporting of the annual air emissions inventory, and reporting of the data necessary to develop the inventory. Excess emissions must be reported immediately in order to qualify for relief from monetary penalty in accordance with SWCAA 400-107. In addition, prompt reporting was required because it allows for accurate investigation into the cause of the event and prevention of similar future incidents.

11. START-UP AND SHUTDOWN/ALTERNATIVE OPERATING SCENARIOS/POLLUTION PREVENTION

11.a Start-up and Shutdown Provisions. Pursuant to SWCAA 400-081 "Start-up and Shutdown," technology based emission standards and control technology determinations shall take into consideration the physical and operational ability of a source to comply with the applicable standards during start-up or shutdown. Where it is determined that a source is not capable of achieving continuous compliance with an emission standard during start-up or shutdown, SWCAA shall include appropriate emission limitations, operating parameters, or other criteria to regulate performance of the source during start-up or shutdown.

The nonroad diesel engines may exhibit excess opacity upon startup even if the units are in proper working order. Accordingly, the visual emissions limits listed in the permit for the diesel engines does not apply during the startup period defined in the permit. The general opacity standard from SWCAA 400-040 of 20% continues to apply during startup.

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11.b Alternate Operating Scenarios. SWCAA conducted a review of alternate operating scenarios applicable to equipment affected by this permitting action. The permittee did not propose or identify any applicable alternate operating scenarios. Therefore, none were included in the approval conditions.

11.c Pollution Prevention Measures. SWCAA conducted a review of possible pollution prevention measures for the facility. No pollution prevention measures other than the control measures identified in the permit were identified by either the permittee or SWCAA. Therefore, none were included in the approval conditions.

12. EMISSION MONITORING AND TESTING Initial opacity observations are required by 40 CFR 60 Subpart 000 for affected crushers and any associated screening equipment and belt conveyors. All of the crushing and screening equipment addressed by this permitting action is subject to the initial testing requirements of 40 CFR 60 Subpart 000.

13. FACILITY IDSTORY This facility is new to SWCAA's jurisdiction.

14. PUBLIC INVOLVEMENT

14.a Public Notice for Air Discharge Permit Application CL-3020. Public notice for Air Discharge Permit Application CL-3020 was published on the SWCAA internet website for a minimum of 15 days beginning on June 23, 2017.

14.b Public/Applicant Comment for Air Discharge Permit Application CL-3020. SWCAA did not receive formal comments, a comment period request, or any other inquiry from the public or the applicant regarding this Air Discharge Permit application. Therefore, no public comment period was provided for this permitting action.

14.c State Environmental Policy Act. SWCAA issued Determination of Non-Significance 17-025 on July 13, 2017 for this permitting action.

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