HomeMy WebLinkAbout20121408.tiff STATE OF COLORADO
John W.Hickenlooper,Governor WELD COUNTY
Christopher E. Urbina,MD, MPH 1-,iCIMMISSIONERS t,•coto,
Executive Director and Chief Medical Officer 9n c
Dedicated to protecting and improving the health and environment of the able gibloreao A II: 2b
4300 Cherry Creek Dr.S. Laboratory Services Division
Denver,Colorado 80246-1530 8100 Lowry Blvd. X876
Phone(303)692-2000 Denver,Colorado 80230-6928 RECEIVED Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
http://www.cdphe.state.co.us and Environment
June 4, 2012
Mr. Steve Moreno
Weld County Clerk
1402 N. 17th Ave.
Greeley, CO 80631
Dear Mr. Moreno:
The Air Pollution Control Division will publish a public notice for Vestas Blades America, Inc.. This
public notice will be published in the Greeley Tribune on June 10, 2012.
Thank you for assisting the Division by making the enclosed package (includes public notice,
preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review
and comment. It must be available for public inspection for a period of thirty (30) days from the date
the public notice is published.
Please forward any comment regarding this public notice to the address below.
Colorado Department of Public Health and Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Attention: Ellen Evans
Regards,
Ellen Evans
Public Notice Coordinator
Stationary Sources Program Air Pollution Control Division
r u,:\O`t C. mil✓\i l Cc- -. O1- , FL
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APPLICATION FOR ISSUANCE OF A MINOR SOURCE PERMIT
FOR THE OPERATION OF A WIND TURBINE BLADE MANUFACTURYING AND
PAINTING FACILITY.
BY
VESPAS BLADES AMERICA,
CONTENTS
1. PUBLIC NOTICE
2. PRELIMINARY ANALYSIS
3. APPLICATION FOR CONSTRUCTION PERMIT
4. AIR POLLUTANT EMISSION NOTICE
5. DRAFT PERMIT
PREPARED BY:
Sunday Fadeyi, P.E.
COLORADO DEPARTMENT OF PUBLIC HEALTH & ENVIRONMENT
4300 CHERRY CREEK DRIVE SOUTH, APCD-SS-Bl
GLENDALE CO 80246-1530
STATE OF COLORADO
Bill Ritter,Jr.,Governor
James B.Martin, Executive Director .0F.coZo�
Dedicated to protecting and improving the health and environment of the people of Colorado NT% , p
4300 Cherry Creek Dr.S. Laboratory Services Division '« 49 »`
Denver,Colorado 80246-1530 8100 Lowry Blvd. +tape+
Phone(303)692-2000 Denver,Colorado 80230-6928
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado of Public Health
http://www.cdphe.state.co.us and Environment
Released to: The Greeley Tribune on June 4, 2012, published June 10, 2012
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
The Colorado Air Pollution Control Division has declared that the following proposed construction activity
warrants public comment. Therefore, the Air Pollution Control Division of the Colorado Department of Public
Health and Environment hereby gives NOTICE, pursuant to Section 25-7-114.5(5), C.R.S. of the Colorado Air
Quality Control Act that an application to the Division has been received for an emission permit on the following
proposed project and activity:
Vestas Blades America, Inc. has requested a permit to construct and operate a Wind Turbine Blade manufacturing
facility located at Weld County Road 27 and Weld County Road 6, Brighton, in Weld County, CO. Particulate
emissions from paint overspray will be controlled by vent filters. Emissions will also be limited by various
process limits. Though a true minor source, public notice is required per the Division's policy, since the actual
controlled emissions are above 25 tons per year.
The Division hereby solicits and requests submission of public comment concerning the aforesaid proposed
project and activity for a period of thirty (30) days from and after the date of this publication. Any such comment
must be in writing and be submitted to the following addressee:
Sunday Fadeyi, P.E.
Colorado Department of Public Health and Environment
4300 Chen-y Creek Drive South, APCD-SS-BI
Glendale, Colorado 80246-1530
Within thirty(30)days following the said thirty(30)-day period for public comment, the Division shall consider
comments and, pursuant to Section 25-7-114.5(7)(a), either grant,deny, or grant with conditions,the emission
permit. Said public comment is solicited to enable consideration of approval of and objections to the proposed
construction of the subject project and activity by affected persons.
A copy of the application for the emission permit,the Preliminary Analysis of said application, and
accompanying data concerning the proposed project and activity are available for inspection at the office of the
Clerk and Recorder of Mesa County during regular business hours and at the office of the Air Pollution Control
Division, Colorado Department of Public Health and Environment, 4300 Cherry Creek Drive South, Glendale,
Colorado and on the Division website at www.cdphe.state.co.us/ap/airpublicnotices.html.
AIR POLLUTION CONTROL DIVISION
PRELIMINARY ANALYSIS
PERMIT NUMBER: 0BWE1007 DATE: June 4, 2012
APPLICANT: Vestas Blades America, Inc.
REVIEW ENGINEER: Sunday A. Fadeyi, P. E. CONTROL ENGINEER: R K Hancock III, P.E.
PROJECT DESCRIPTION
This project is to construct and operate a new wind turbine blade manufacturing facility. Operations
at the facility will include volatile materials usage. Particulate emissions from paint overspray will
be controlled by vent filters. Emissions will also be limited by various process limits. Air pollutant
emissions from this facility's operations are as follows:.
SUMMARY OF EMISSIONS (tons/year}
AIR CONTROLLED UNCONTROLLED POTENTIAL REMARKS
POLLUTANT EMISSIONS EMISSIONS TO EMIT
VOC 90.00 90.00 90.0 Minor source. Public notice is
required.
HAPs 5.8 5.8 5.8 Reportable
Source Impact:
Impact modeling analysis is not required per the Division's policy.
SOURCE CLASSIFICATION
This source is considered a minor source according to the Air Quality Control Commission
regulations. The source is located within the Denver 8 hour ozone non-attainment area.
Emissions of VOC could exceed 50 tons per year. Therefore, this source is considered a minor
source and this permit action is subject to public review by Regulation Number 3, Part B, Section
III.C.3. The Division has determined that this source will meet all applicable regulations.
Page 1 of 1
[Ft , /3/o& /1
II
Colorado Department of Public Health and Environment %� in`v
Air Pollution Control Division w
COATING,PAINTING AND VOLATILE MATERIALS USAGE OPERATIONS
Air Pollutant Emission Notice (APEN)— and —Application for Construction Permit
Permit Number(if known) AIRS Number(if known): 123/7282/001
ACTION REQUIRED: ❑ New Facility ❑APEN Update Only ® Modification:
Modification Type: ❑ Ownership Transfer ❑ Change in Material Use ® Change in Equipment.
Complete all applicable sections of this form prior to submittal to the Division. Incomplete information may
result in longer engineer processing times. You must submit the application fee with your APEN submittal.
* Note: For transfer of ownership or company name change on a permit, you must submit a proof of ownership
transfer(e.g. Transfer of Ownership Form signed by the previous owner or a copy of a Bill of Sale).
Company Name: Vestas Blades America, Inc.
Facility Location: 1500 B East Crown Prince Boulevard
Brighton, CO 80603-5875 County: Weld
Contact Person: Kevin Cory
Phone: 970.674.6201 Fax: 970.686.1103
Mailing Address: Vestas Blades America, Inc.
1500 B East Crown Prince Boulevard
Brighton, CO 80603-5875
E-mail Address: kecorc vestas.com
Date Facility Began or Will Begin Operation: 8/15/2011
Normal Operation of this Source: 24 Hours per day, 7 Days per week, 50 Weeks per year
1. Type of Tasks (J): ❑Automobile Coating, ❑ Metal Parts Coating ❑ Plastic Parts Coating
® Others (Explain): Painting of carbon/glass fiber wind blades in a computer operated, robot applied,
paint tunnel.
2. Type of Equipment Located at this Facility (attach additional sheets as needed)
N (Paint booths, dip-tanks, powder coating units,etc.)
co UniYear of Control Device
No.t Make Model Serial No. Installation Type
RTO
1 Anguil Anguil 200 AES 15339 2011 (20,000 SCFM)
N 90%VOC Reduction
o -
2 DanRob/Wagner Vestas Specific 2011 Robotic Painting
3
869664
Page 1 of 3
RECEIVED
1 AP` 2012
3. Paints and Volatile Materials Usage Information: «,n
a. Coating Materials Application Method:
❑ Dip, Brush, or Roller(DBR): TE*= 95%; ❑ Electrostatic, How Voltage(HLV): TE=90%
❑ High Volume Low Pressure Gun (HVLP): TE =65% ❑ Electrostatic, Low Voltage(ELV):TE = 65%
❑Air-Assisted Airless/Airless (AAA/A):TE =40% ® Conventional Air Atomizing (CAA): TE = 25%
E Others(Describe):Robotic application wl high transfer efficiency spray nozzle in paint tunnel. 75%TE
with 25%overspray.
*Note: "TE" means"Transfer Efficiency percent(%)." It is used to estimate particulate
emissions.
b. Volatile Materials Usage (you may attach additional sheets as needed)*:
S/N: Name of Product Annual Usage MSDS ID or Name
(Specify Units)
1 Paint Thinner 425 lbs N-Butyl acetate
2 Paint- Part A 1,600 lbs N-Butyl acetate
3 Paint Hardener-Part B 525 lbs Aliphatic
polyisocyanate
4
5
6
7
8
9
10
Note:
* Materials usage will not be made part of permit conditions. Material usage is required to establish valid
basis for the facility's emissions and to make accurate determination of the facility's status. If there are
more than ten (10) products, you may attach extra sheets.
Actual data should be supplied. Calculations for the total VOC and HAPs emissions must correlate with
actual material usage listed above. Annual air emissions fees are based on actual emissions.
For new sources and existing sources requesting a modification, requested annual VOC emission
limit should be supplied (see section 5 below).
a
c. Actual Time Spent for Materials Application : 24 hours/day
a Actual hours of materials application will be used in conjunction with actual or requested VOC and HAPs
emissions to establish the facility's status. (i.e. Potential To Emit).
4. Powder Coatings Usage: Not Applicable
a. Actual Usage: tons per year; b. Requested Usage: tons per year
c. Application Method: ; Transfer Efficiency (TE):
d. Control Device: • Control Efficiency (CE):
Page 2 of 3
RECEIVED
Pro
5. Air Pollutant Emissions from Coating and Volatile Materials Usage
(Should be based on products usages listed above):
a. Actual VOC:0.1 tons/year, Data Year: 2011
b. Requested VOC: 24 tons/year
c. List individual hazardous air pollutants (HAP) on the Non-Criteria Reportable Pollutants Addendum form and
submit it with this APEN form.
*For new sources and existing sources requesting a modification requested annual VOC emission limit
should be supplied. Allow for growth when estimating your requested annual VOC emission limit. The requested
total emissions below will become a permit limit.
6. Check the appropriate box below if you want:
❑ I want The Division to help calculate my source's air pollutant emissions based on the products usage
supplied in this application.
® A copy of the Preliminary Analysis conducted by the Division; ® To review a draft of the permit prior
to issuance
7. Person Legally Authorized to Supply Data:
Name: /%✓�WS c7 f5 AZ SAN Title: 6
Signature: C// �PO�i/PfiC _ Date: O,v/e)r://-e
♦ •
Please Note:
• This APEN is valid for five (5)years unless a significant change is made that causes significant increase in
air pollutant emissions. A revised APEN shall be filed no less than 30 days prior to the expiration date of this
APEN form.
o Send this form along with $152.90 (or the current)filing fee to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver,CO 80246-1530
• Businesses that emit air pollutants above certain thresholds may trigger the need to submit an APEN
or obtain an Air Permit. The air permitting process begins with submission of a Construction Permit
Application form and APEN (one for each emission source)to the APCD. APEN and permit emission
thresholds are based on uncontrolled actual emission rates. All permits will be issued based on the
level of production/operation requested on the APEN. If you have questions about"Actual"and
Requested"emissions, please contact the Division.
• The Division requires notification of start up of your operations. You must submit a Notice of Start-up
form to the Division at least 15 days after commencing operation of the source.
o Once the source begins operations, the Division may inspect the source to ensure compliance with all
applicable permit conditions.
o Air Pollutant Emission Notice(APEN), Construction Permit Applications forms, and other application
forms are downloadable at www.cdphe.state.co.us/ap/downloadforms.asp.
• Guidance documents are available to help you understand the air permitting process and
environmental regulations specific to your business. These documents are available at
www.cdphe.state.co.us/ap/stationarvlibrant html.
• Any Abrasive blasting may need separate APEN.
For more information or assistance contact: Main Office:(303)692-3150
Small Business Assistance Program: (303)692-3175 or(303)692-3148
Revised October 2010 http://www.cdphe.state.co.us/ap/downloadforms.asp
Page 3 of 3
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT oe•coo
AIR POLLUTION CONTROL DIVISION r �
TELEPHONE: (303) 692-3150D c,
‘,4
CONSTRUCTION PERMIT
PERMIT NUMBER: 08WE1007
INITIAL APPROVAL
DATE ISSUED: Modification No.1
ISSUED TO: Vestas Blade's America, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Wind turbine blade manufacturing facility located at 1500 B E. Crown Prince Boulevard, Brighton
Brighton in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
N/A 001 One (1) DanRob/Wagner, wind turbine blade robotic painting system, model:
Custom, SN: N/A, equipped with an Anguil regenerative thermal oxidizer (RTO),
model: Anguil 200, SN: AES 15339 to control emissions of volatile organic
compounds (VOC) and hazarduous air pollutants (NAPS) from operations of this
unit; vents are equipped with overspray filters to control particulate emissions.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL
ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS
DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL APPROVAL
1. Within one hundred and eighty days (180) after the issuance of this permit, compliance with the conditions
contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self
certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in
revocation of the permit or enforcement action by the Division. Information on how to certify compliance
was mailed with the permit or can be obtained from the Division. (Reference: Regulation No. 3, Part B,
II.G.2)
2. Within one hundred and eighty days (180) after the issuance of this permit, the operator shall complete all
initial compliance testing and sampling as required in this permit and submit the results to the Division as
part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.)
3. The owner or operator shall develop an operating and maintenance (O&M) plan, along with a
recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with
the requirements of this permit. Compliance with the O&M plan shall commence at startup. Within one
hundred and eighty days (180) after the issuance of this permit, the owner or operator shall submit the
O&M plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in
revocation of the permit. (Reference: Regulation No. 3, Part B, III.E.)
AIRS ID: 123/7282/001 Page 1 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Vestas Blades America, Inc. Er iff[i
Permit No. 08WE1007
INITIAL APPROVAL
4. Within one hundred and eighty days (180) after commencement of operation, the permit number shall be
marked on the subject equipment for ease of identification. (Reference: Regulation No. 3, Part B, Ill,E.)
(State only enforceable)
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations (as calculated using the emission
factors included in the Notes to Permit Holder section of this permit). Monthly records of the actual
emission rates shall be maintained by the applicant and made available to the Division for inspection upon
request. (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Emission (Tons per Year)
Equipment Point Emission Type
ID PM PM10 PM2.5 NO„ SO2 VOC CO
5.1 5.1 5.1 24.0 Point
N/A 001
Fugitive
See "Notes to Permit Holder#4" for information on emission factors and methods used to calculate limits.
The above emission rate is based on consumption rates, and on all other activities, operational rates and
numbers of equipment as stated in the application. Annual records of the actual consumption rate shall
be maintained by the applicant and made available to the Division for inspection upon request:
(Reference: Regulation No. 3, Part B, III.E.)
Compliance with the annual emission limits listed above shall be demonstrated by adequate
recordkeeping. The permit holder shall keep a compliance record on site for Division review, See
Attachment A for an example of recordkeeping format. (Reference: Regulation 3, Part B.III.E)
Compliance with the annual VOC limit shall be determined by recording the facility's annual criteria
pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on
a rolling (12) month total. By the end of each month a new twelve-month total shall be calculated based
on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a
compliance record on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all emission units, requiring an APEN, at this facility.
6. The emission points in the table below shall be maintained and operated with the control equipment as
listed. The uncontrolled emissions shall be reduced by at least the control efficiencies listed. Operating
parameters of the control equipment shall be identified in the operating and maintenance plan. The
identified operating parameters will replace the control efficiency requirement on the final permit.
(Reference: Regulation No. 3, Part B, Section III.E.)
Facility AIRS Control Device Pollutants Control
Equipment ID Point Controlled Efficiency*
Vent Filters PM 90.0 %
N/A 001 Regenerative thermal oxidizer VOC 90.0
(RTO)
NOTE: *Overall collection and destruction efficiency.
AIRS ID: 123/7282/001 Page 2 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Vestas Blades America, Inc. Er �
Permit No.08WE1007
INITIAL APPROVAL
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum consumption, processing and/or operational rates as
listed below. Monthly records of the actual process rate shall be maintained by the applicant and made
available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
N/A 001 Volatile materials usage Shall be limited by the VOC limit above.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source.
During periods of startup, process modification, or adjustment of control equipment visible emissions shall
not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference:
Regulation No. 1, Section II.A.1. &4.
9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
10. Point 001: This source is located in an ozone non-attainment or attainment-maintenance area and subject
to the Reasonably Available Control Technology (RACT) requirements-of Regulation Number 3, Part B,
III.D.2.b. The application of RTO as required by the condition no. 6 and the requirements of condition no.
13 have been determined to be RACT for this source.
11. This source is subject to the requirements of Regulation No. 7.V. regarding Disposal of Volatile Organic
Compounds as follows:
No person shall dispose of volatile organic compounds by evaporation, or spillage unless RACT
is utilized. (Regulation No. 7.V A)
12. Fugitive emissions shall be controlled by the following practices: (Reference: Reg.7,IX.A.7.)
IX.A.7.a. Control techniques and work practices shall be implemented at all times to reduce volatile
organic compound (VOC) emissions from fugitive sources. Control techniques and work
practices include, but are not limited to:
IX.A.7.a.(1) tight-fitting covers for open tanks;
IX.A.7.a.(2) covered containers for solvent wiping cloths;
IX.A.7.a.(3) proper disposal of dirty clean-up solvent.
IX.A.7.b. Emissions of organic material released during clean-up operations, disposal, and other fugitive
emissions shall be included when determining total emissions, unless the source owner or
operator documents that the VOC's are collected and disposed of in a manner that prevents
evaporation to the atmosphere.
13. This source is subject to the control of Volatile Organic Compounds emission requirements of Regulation
No. 7, Part IX, Subpart L. Manufactured Metal Parts and Metal Products, Control of paints VOC content
as follows:
IX.L.2. Provisions for Specific Processes
IX.L.2.a. No owner or operator of a facility or operation engaging in the surface coating of
manufactured metal parts or metal products may operate a coating application system
subject to this regulation that emits VOC in excess of:
AIRS ID: 123/7282/001 Page 3 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Vestas Blades America, Inc.
Permit No. 08WE1007
INITIAL APPROVAL
(1)
IX.L.2.a (1) Clear Coatings: 0.52 Kg/1c (4.3 1b/90)
IX.L.2.a (2) Extreme Performance Coatings: 0.42 Kg/1c (3.5 Ib/9c)
IX.L.2.a (3) Air-Dried Coatings: 0.42 Kg/1c (3.5 lb/9c)
IX.L.2.a (4) Other Coatings and Systems: 0.36 Kg/1c (3.0 lb/90) delivered to a
coating applicator for all other coatings and coating application systems.
(1) Note: Kg/Ic means kilograms per liter of coating as applied
lb/
gc means pounds per gallon of coating as applied.
OPERATING & MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and
record keeping format submitted to the Division for' review and approval, in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are
subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section
III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. Initial testing is not required for this source.
Periodic Testing Requirements
16. Periodic testing is not required for this source.
ADDITIONAL REQUIREMENTS
17. All previous versions of this permit are cancelled upon issuance of this permit.
18. The permit number shall be marked on the subject equipment for ease of identification. (Reference:
Regulation No. 3, Part B, III.E.) (State only enforceable)..'
19. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A,
Section II.C.)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five tons per
year or more, above the level reported on the last APEN submitted; or
For volatile organic compounds (VOC) and nitrogen oxide (NOx) sources in an ozone non-
attainment area emitting less than 100 tons of VOC or nitrogen oxide per year, a change in
actual emissions of one ton per year or more or five percent, whichever is greater, above the level
reported on the last APEN submitted; or
AIRS ID: 123/7282/001 Page 4 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Vestas Blades America, Inc. D
Permit No. 08WE1007 1 r
INITIAL APPROVAL
For sources emitting 100 tons per year or more of a criteria pollutant, a change in actual
emissions of five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
For sources emitting any amount of lead, a change in actual emissions, above the level reported
on the last APEN submitted, of fifty (50) pounds of lead
For any non-criteria reportable pollutant: •
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level
reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or activity; or
c. Whenever new control equipment is installed, or whenever a different type of control equipment
replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN'expires.
20. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide
potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equals
or exceeds the major source level a Title V operating permit application shall be submitted in accordance
with the requirements in Regulation No. 3, Part C
21. Non-attainment New Source Review requirements shall apply to this source at any such time that this
source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that
increases the potential to emit above the applicable NSR threshold will require a full NSR review of the
source as though construction had not yet commenced on the source. The source shall not exceed the
NSR threshold until a NSR permit is granted. (Regulation No. 3, Part D, V.A.7)
GENERAL TERMS AND CONDITIONS:
22. This permit and any attachments must be retained and made available for inspection upon request. The
permit may be reissued to a new owner by the Division as provided in Regulation No. 3, Part B, Section
II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required
fee.This source is located in an ozone non-attainment or attainment-maintenance area and subject to the
Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B,
III.D.2.b. RACT for this source is determined to be "no control" due to the excessive cost per ton of
emission removed.
•
23. If this permit specifically states that final approval has been granted, then the remainder of this condition
is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for
this activity or operation of this source. Final approval of the permit must be secured from the Division in
writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and Regulation No. 3, Part B,
Section III.G. Final approval cannot be granted until the operation or activity commences and has been
verified by the Division as conforming in all respects with the conditions of the permit. Once self-
certification of all points has been reviewed and approved by the Division, it will provide written
documentation of such final approval. Details for obtaining final approval to operate are located in
the Requirements to Self-Certify for Final Approval section of this permit.
AIRS ID: 123/7282/001 Page 5 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Vestas Blades America, Inc. I )�
Permit No. 08WE1007
INITIAL APPROVAL —�
24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the
applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the
source, in accordance with this information and with representations made by the applicant or applicant's
agents. It is valid only for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have
been determined by the Division to be necessary to assure compliance with the provisions of Section 25-
7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or
appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,
this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-
certification and final authorization by the Division on grounds set forth in the Colorado Air Pollution
Prevention and Control Act and regulations of the AQCC including failure to meet any express term or
condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested
by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice
(APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or
activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the
permit. Upon notification, annual fee billing will terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control
Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions
under Sections 25-7-115 (enforcement), -121 (injunctions), -122. (civil penalties), -122.1 (criminal
penalties), C.R.S.
By: By:
Sunday A. Fadeyi, P.E. R K Hancock III, P.E.
Permit Engineer, Unit Leader
Permit History:
Issuance Date Description
Initial Approval November 3, 2008
IA Modification No. 1 This Issuance Installation of new pieces of equipment including an RTO;
reduction of VOC emission from 90.0 to 24.0 tons per year, and
permit conversion from a true minor to a synthetic minor.
•
AIRS ID: 123/7282/001 Page 6 of 8
Colorado Department of Public Health and Environment
Air Pollution Control Division
Vestas Blades America, Inc.
P
Permit No. 08WE1007 o
INITIAL APPROVAL
Notes to Permit Holder:
1) The production or raw material processing limits and emission limits contained in this permit are based on
the production/processing rates requested in the permit application. These limits may be revised upon
request of the permittee providing there is no exceedence of any specific emission control regulation or
any ambient air quality standard. A revised air pollution emission notice (APEN) and application form
must be submitted with a request for a permit revision.
2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See:
http://www.cd phe.state.co.us/req ulations/ai rregs/5CC R1001-2.pdf.
3) The emission levels contained in this permit are based on the following emission factors:
Point 001 jVolatile Materials Usage):
VOC/HAP Emissions: Mass balance assuming that the entire solvent contents in the products are
emitted.
VOCemissions = (Pr0dUCtoonsumption)*(VOO )*(1-CE)
TSP/PMto/PM2.5emissions = (Product consumption)*(Particulate %)*(1-TE)*(1-CE),
Where: Productoonsumption = Beginning Inventory + New Purchases— End Inventory
VOC 1/4/ HAP% is in weight percent(i.e. VOC/HAP's weight percent in the product),
Particulate %is the weight percent(i.e. particulate's weight percent in the product)
TE = Transfer Efficiency in weight percent; the TE used in the analysis is 75.0% and it
should be used for compliance purposes.
CE = Control efficiency percent; the CE used in the analysis is 90.0% for each of the PM,
VOC and HAP control efficiencies and it should be used for compliance purposes.
If volatile materials consumption is in tons, then emissions are in tons per year.
If volatile materials consumption is in Ibs, then emissions are in lbs per year.
4) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notices (APENs) associated with this
permit are valid for a term of five years. As of the issuance of this permit, the five-year term for these
APENs expires per the table below. A revised APEN shall be submitted no later than 30 days before the
five-year term expires.
AIRS Date of Expiration
Point
001 5/7/2016
5) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic minor source for VOC
PSD Minor
NANSR Synthetic minor source for VOC
AIRS ID: 123/7282/001 Page 7 of 8
•
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