HomeMy WebLinkAbout20092294.tiffSTATE OF COLORADO
Bill Ritter, Jr., Governor
James B. Martin, Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
TDD Line (303) 691-7700
Located in Glendale, Colorado
http://www.cdphe.state.co.us
July 28, 2009
Mr. Steve Moreno
Weld County Clerk
1402 N. 17th Ave.
Greeley, CO 80631
Dear Mr. Moreno:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
The Air Pollution Control Division will publish a public notice for the Bach Composite Colorado, Inc.
This public notice will be published in the Fort Lupton Press on August 1, 2009.
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-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Attention: Jacquie Barela
eline N. Barela
Public Notice Coordinator
Stationary Sources Program Air Pollution Control Division
Uetrc 7iieZ.c.)
(797/y47
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62009- (72_17./
PUBLIC NOTICE OF INTENT CONSTRUCT AND OPERATE A NEW FACILITY
FOR
REIFORCED COMPOSITE PARTS PRODUCTION
BY
Bach Composite Colorado, Inc.
Located In Weld County
Permit No.: 09WE0630
Table of Contents
1. PUBLIC NOTICE
2. PRELIMINARY ANALYSIS
3. APPLICATION FOR EMISSION PERMIT
4. AIR POLLUTANT EMISSIONS NOTICE
5. DRAFT CONSTRUCTION PERMIT
Prepared by
Sunday A. Fadeyi, P.E.
Construction Permit Section
Stationary Sources Program
Air Pollution Control Division
Colorado Department of Public Health and Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
STATE OF COLORADO
Bill Ritter, Jr., Governor
James B. Martin, Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
TDD Line (303) 691-7700
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Released to: Fort Lupton Press on July 28, 2009; published August 1, 2009
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
The Colorado Air Pollution Control Division has declared that the following proposed construction activity
warrants public comment. Therefore, the Division of Air Pollution Control of the Colorado Department of
Health, hereby gives NOTICE, pursuant to Section 25-7-114(4)(e), C.R.S. 1973, as amended, 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:
Bach Composite Colorado, Inc. has applied to construct and operate a reinforced plastic composite parts
production facility to be located at 1011 14th Street, Fort Lupton in Weld County, Colorado. The process at
this facility will include both open and closed mold with gelcoat spraying and resins infusion by vacuum
assisted resin transfer mold (VARTM) method. Particulate emissions from this facility will be controlled by
vent filters. In addition the source will apply both Reasonably Available Control Technology (RACT) and
Maximum Available Control Technology (MACT) to control criteria and hazardous air pollutants (1-lAP) from
this facility. Also emissions will be limited by process limits. This source has been classified as a major source
facility for Title V Operating Permit requirements. The source will be permitted to process gelcoat up to 443
tons per year and resins up to 2,322 ton per year.
The Division hereby solicits and requests submission of public comment concerning the aforesaid proposed
projects and activities for a period of thirty days from and after the date of this publication. Any such comment
must be in writing and be submitted to the following addresses:
Sunday A. Fadeyi, P.E.
Colorado Department of Public Health and Environment
APCD-SS-B I
4300 Cherry Creek Drive South
Construction Permit Unit
Denver, 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(4)(f)(11), either grant, deny, or grant with conditions,
the emission permits. Said public comment is solicited to enable consideration of approval of and objections to
the proposed construction of the subject projects and activity by affected persons.
A copy of the application for the emission permits, the Preliminary Analyses of said applications, and
accompanying data concerning the proposed projects and activity are available for inspection at the office of
the Clerk and recorder of Weld 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,
AIR POLLUTION CONTROL DIVISION
PRELIMINARY ANALYSIS
DATE:
July 28, 2009
PERMIT NUMBER: 09WE0630
APPLICANT: Bach Composite Colorado, 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 reinforced plastic composite parts production facility. Particulate
emissions from materials overspray will be controlled by vent filters. Air pollutant emissions from this facility's
operations are as follow:
SUMMARY OF EMISSIONS (tons/year)
AIR
POLLUTANT
CONTROLLED
EMISSIONS
UNCONTROLLED
EMISSIONS
POTENTIAL
TO EMIT
REMARKS
VOC
83.0
83.0
231.1
Synthetic minor for Title V
Operating Permit requirements and
minor for Prevention of Significant
Deterioration (PSD);
Public notice is required.
TSP
2.4
47.0
80.9
Minor
PM10
2.4
47.0
80.9
Minor
HAPs
83.0
83.0
231.1
Major for Title V Operating Permit
Subject to MACT Subpart WWWW
of Part 63..
SOURCES' IMPACT
Impact modeling analysis is not required per the Division's policy.
SOURCE CLASSIFICATION
This is a major source for which emissions of reportable non -criteria air pollutant is above major source
threshold of 10 tons per year fo a single hazardous air pollutant for Title V Operating Permit requirements. But
the source is a synthetic minor for criteria pollutants, since the potential to emit VOC is greater than the major
source threshold of 100 tons per year but actual VOC emissions are below major source threshold. Public
notice is required.
Page 1 of 1
Air Pollution Control Division (APCD) - Construction Permit Application
PLEASE READ INSTRUCTIONS ON REVERSE SIDE.
1. Permit to be issued to: Bach Composite Colorado Inc.
2. Mailing Address: Erhvervsvej 9 r �thCEVbD`\
7760 Hurup Thy ASS
Denmark APett
tl
3. General Nature of Business: Reinforced Composites 4iwleib
Cr xP
SIC code (if known) 3261
4. Air Pollution Source Description: Reinforced Plastic Composites Production
(List permit numbers if existing source,
attach additional pages if needed) Is this a Portable Unit? No
5. Source Location Address (Include Location Map) If portable, include the initial location and home base location
1011 141, Street
Fort Lupton, Colorado 80621
6. Reason for Application: (Check all that apply)
11 New or Previously Unreported Source Administrative Permit Amendments
iii Modification of Existing Source ❑ Transfer of Ownership (Complete Section 9 & 10 below)
❑ Request for Synthetic Minor Permit ❑ Company Name Change (Complete Section 9 below)
❑ Other: ❑ Other:
7. Projected S te: September 1, 2009
02.07.2009
Si ure of Legally Authorized Person of Company listed in Section 1 Date Signed
Eric S. Knudsen, CTO Phone: +45-5137-6663
Type or Print Name and Official Title of Person Signing Above Fax: +45-9688-3201
8. Check appropriate box if you want:
' Copy of preliminary analysis conducted by Division
❑ To review a draf the permit prior to issuance
These sections are to be completed only if a company name change or transfer of ownership has occurred.
9. Permit previouslyed to:
10. Transfer of Ownership Information
Effective Date of Permit Transfer:
As responsible party for the emission source(s) listed above, I certify that the business associated with this source has been
sold, and agree to transfer the permit to said party.
Signature of Legally Authorized Person of Company listed in Section 9 Date Signed
Phone:
Type or Print Name and Official Title of Person Signing Above Fax:
Mail completed application, APENs, and filing fee to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
4300 Cherry Creek Drive South, APCD-SS-BI
Denver, Colorado 80246-1530
http://www.cdphestate_co.us/'ap/stationarv.lmnl
Phone: (303)692-3150
Revised August 2004
TO-£T-LO-6002-N3dY £00 -Soso -£z1
Colorado Department of Public Health and Environment k
Air Pollution Control Division
- PAINT SPRAY OPERATIONS -
$ na
Page 1 of4'
Air Pollutant Emission Notice (APEN) - and - Application for Construction Permit
Check all that apply:
® New Facility ❑ Transfer of Ownership * ❑ Change in VOC Usage
❑ No Change, APEN Update Only ❑ Request a Modification to Existing Permit
All sections of this APEN and application must be completed prior to submittal to the Division for both new and existing
facilities. An application with missing information may be determined incomplete and may result in longer engineer
processing times,
Note: For transfer of ownership or company name change of a permit, you must also submit a Construction Permit
Application form.
Permit Number �, li 0(5 18
a
AIRS Number
11-3i Cc5c8i 003
Company Name: Bach Composite Colorado, Inc.
Plant Location: 1011 14th Street County:
Fort Lupton, Colorado Zip: 80621
Billing Address: Erhvervsvej 9
Hurup Thy, Denmark Zip: 7760
Person to Contact: Jeffrey Pfost Phone Number: 016-928-9129
E-mail Address: Jeff.pfost@enviro-partners.com Fax Number: 616-928-9126
Is this facility owned or managed by another company or corporation? No
If YES, provide name of company and mailing address:
Please describe the operations at this facility (body shop, manufacturing or refurbishing of select items, etc.):
Reinforced Plastics Composites Manufacturer
Normal Operation of this Source:
16 Hours per day
Section 1: ABRASIVE BLASTING
5 Days per week
Is abrasive blasting performed at this location?
If yes list material used: _ (e.g. sand, plasti } t-
on
Amount consumed? Tons per Year �`r'
No
52 Weeks per year
SCANNED
Abrasive Blasting Control Measures (this will serve as the fugitive dust control pl4A%I LD - P
❑ Wet Blasting
O Enclosure
❑ Other (specify):
(may be required by the Division)
Type: Complete or Partial, describe:
Please provide description of the blasting material cleanup and disposal at the site:
Revised September 2004
cclph,.state.co.us ap'stationarv.htmla so
Colorado Department of Public Health and Environment
Air Pollution Control Division
- PAINT SPRAY OPERATIONS -
Section 2: PAINT BOOTH INFORMATION
Percent of painting done indoors:
Number of indoor spray booths?
100%
Page 2 of 4 m
t. RECEWL:
Ant
Stationaw
R
ns
List any air pollution controls (i.e. overspray filters, VOC controls) associated with the indoor spray booths. Please
indicate control and capture efficiency.
Dry overspray filters
Percent of painting done outdoors:
0%
Please describe any air pollution controls associated with outdoor painting operations (if applicable):
NA
Application Method of Surface Coating
Air Atomization
Pressure Atomization
Hot Airless Spray
HVLP*
Electrostatic: Air
Electrostatic: Disc
Constitutes what % of Transfer Efficiency (%)
operations:
Other (Specify):Nonatomized 100% TBD
Required for Automotive Refinishing Booths Located in the Denver Metro Area.
Section 3: VOLATILE MATERIAL USAGE
The VOC emission limit included in the permit will be based on the requested emission limit provided in this section.
Sources are encouraged to provide a requested emission limit that allows room for growth over the next five years
(APENs must be resubmitted every five years). The source will be required to show compliance with the VOC
permit limit by calculating emissions based on actual material consumption. Sources may use VOC and HAP
reports provided by their solvent supplier to demonstrate compliance. Annual emission fees will be based on the
actual VOC usage provided in this section.
Actual VOC Usage:
Requested VOC Limit:
Year For Which The Actual Data Applies:
83
Tons per year
Tons per year
(e.g. 2003)
Revised September 2004 Into:'%www.cdphe.state.co.us-ap-stationary.htsnlasp
Colorado Department of Public Health and Environment Page 3 of 4
Air Pollution Control Division
- PAINT SPRAY OPERATIONS -
The applicant must provide the following information with this APEN:
For previously permitted facilities:
• Submit the previous year's VOC and HAP report, and
• Submit a completed Non -Criteria Reportable Pollutant Addendum.
Or
nary
9' Q
• Submit a table or spreadsheet containing the previous year's emission estimates for VOC and HAPs based on
the actual amounts of solvent purchased by the facility,
• Submit a completed Non -Criteria Reportable Pollutant Addendum, and
• Submit MSDS or Product Data Sheets" for at least the ten highest consumed solvents at the facility.
For new or previously unpermitted facilities:
• Submit a table containing the anticipated annual usage (quantity) of each solvent to be used at the facility,
• Submit a completed Non -Criteria Reportable Pollutant Addendum, and
• Submit MSDS or Product Data Sheets' for at least the ten highest consumed solvents at the facility.
Please make sure the MSDS or the Product Data Sheets contain the VOC & HAP contents in the solvent.
Section 4: POWDER COATINGS USAGE
Actual usage of powder coatings:
Requested limit of powder coatings:
Year For Which The Actual Data Applies:
NA
Tons per year
Tons per year
(e.g. 2003)
Application method:
Transfer efficiency:
Please list any powder coating control or capture devices and their efficiencies:
Section 5: DRYING OVENS
For natural gas fired drying ovens rated above 5.0 million Btu per hour, provide the following information:
Manufacturer
NA
Model No.
NA
Requested amount of natural gas consumed by all ovens
rated over 5.0 million Btu per hour:
Serial No.
NA
scf per year
_ July 8, 2009 _
y Authoriz• • Person (not a vendor or consultant) Date
CTO
Heat Rating
(MMBtu/hr)
NA
Name (please print) Title
Revised September 2004
hu2i_www.cdphe.state.co.uslap/stationarv.htmlasp e.state.co.us/ap/stationarv.htmlasp
Colorado Department of Public Health and Environment
Air Pollution Control Division
- PAINT SPRAY OPERATIONS -
4,9
wyy .
Page4of4
Check the appropriate box if you want:
❑ Copy of the Preliminary Analysis conducted by the Division
® To review a draft of the permit prior to issuance
(Checking any of these boxes may result in an increased fee and/or processing time)
This notice is valid for five (5) years unless a significant change is made, such as an increased production, new equipment,
change in fuel type, etc. A revised APEN shall be filed no less than 30 days prior to the expiration date of this APEN form.
Send this form along with $152.90 to:
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3148 and (303) 692-3175
Small Business Ombudsman
(303) 692-2135
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Revised September 2004 hnp://www.cdphestate.co.uu'ap!stationarv.iitrnlasp
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Section 02 — Re
Section 01— Administrative Information
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Name of Person Legally Authorized to Supply Data (Please print)
December 4, 2006
Form Revision Oat
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
r
CONSTRUCTION PERMIT
PERMIT NUMBER: 09WE0630
DATE ISSUED:
ISSUED TO: Bach Composite Colorado, Inc.
INITIAL APPROVAL
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Reinforced plastic composite parts production facility located at 1011 14th Street, Fort Lupton in
Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Reinforced plastic composite parts production involving closed and open molding processes and
usage of volatile materials for cleaning. Specific processes include: open molding, with gelcoat
application, closed molding with resins infusion by vacuum assisted resin transfer mold (VARTM)
technique, de -molding and parts trimming. Equipped with vent 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:
1. 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 1, Section II.A.1.& 4.)
2. 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)
3. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's
preliminary analysis): (Reference: Regulation No. 3, Part B, II.A.4)
Volatile Organic Compounds: 14,099 pounds per month and 83.0 tons per year.
Particulate Matter (TSP): 2.4 tons per year
Particulate Matter <10 pm (PM10) 2.4 tons per year
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.)
During the first twelve (12) months of operation, compliance with both the monthly and yearly
emission limitations shall be required. After the first twelve (12) months of operation, compliance
with only the yearly limitation shall be required. Compliance with the yearly emission limits shall
be determined on a rolling twelve (12) month total.
123/0508/002
Page 1 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Bach Compo
Permit No. 09WE0630
INITIAL APPROVAL
The permit holder shall calculate emissions monthly and keep a compliance record on site in
order to demonstrate compliance with the above emission limitations. After the first twelve (12)
months of operation, the permit holder shall calculate annual emissions by the end of each
month. Annual emissions shall be calculated based on the previous twelve (12) months' emission
data. These calculated annual emissions shall be used to demonstrate compliance with the yearly
emission limit listed above.
This source shall be limited to a maximum materials process rates as listed below and all other
activities, operational rates and numbers of equipment as stated in the application. Monthly
Annual records of the actual production rate 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.)
Gel Coat process rate shall not exceed 37.6 tons per month and 443.0 tons per year.
Resin process rate shall not exceed 197.2 tons per month and 2,322.0 tons per year
During the first twelve (12) months of operation, compliance with both the monthly and yearly
production limitations shall be required. After the first twelve (12) months of operation, compliance
with only the yearly limitation shall be required. Compliance with the yearly process limits shall be
determined on a rolling twelve (12) month total
5. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part
A, 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; or
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.
6. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
123/0508/002
Page 2 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Bach Compo
Permit No. 09WE0630
INITIAL APPROVAL
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. The requirements of condition number 8 below and the following were determined
to be RACT for this source.:
a. No person shall dispose of volatile organic compounds by evaporation or spillage unless
RACT is utilized. (Regulation No. 7.V A)
b. 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:
i. tight -fitting covers for open tanks;
H. covered containers for solvent wiping cloths;
proper disposal of dirty clean-up solvent.
iv. All cleaning materials and used towels shall be kept in closed containers at all
times, and in addition limit VOC emission by either:
c. 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
8. This source is a Title V Operating Permit major HAP source, and it is subject to the requirements
of Regulation No. 8, Part E, Subpart RRR - National Emission Standards for Hazardous Air
Pollutants (HAP) for Reinforced Plastic Composites Production, 40 C.F.R. Part 63, Subpart
WWWW (July 1, 2007) and shall apply maximum achievable control technology (MACT) as but
not limited to the following:
a. During the open molding process emission of organic hazardous air pollutant (HAP) shall
not exceed the following MACT standards of Paragraph 6, Table 3 to Subpart WWWW of
Part 63,:
Process
Process Used
Organic HAP Emissions Limit
Open Molding
Process
a. tooling gel coat
440 pound per ton of resin
b. white/off white pigmented gel coat
267 pound per ton of resin
c. all other pigmented gel coat
337 pound per ton of resin
d. CR/HS or high performance gel coat
605 pound per ton of resin
e. fire retardant gel coat
854 pound per ton of resin
f. clear production gel coat
522 pound per ton of resin
Note: CR/HS = corrosion -resistant and/or high strength.
123/0508/002
Page 3 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Bach Compo
Permit No. 09WE0630
INITIAL APPROVAL
I'
b. The source shall comply with the work practice standards of MACT WWWW, Paragraphs
2 and 3, Table 4 to Subpart )/W/WW of Part 63 at all times as follows:
i. Only cleanup solvents that do not contain any HAP may be used and shall not
use and solvents that contain HAP except that styrene may be used to cleaner in
closed systems, and organic HAP containing cleaners may be used to clean
cured resin from application equipment. Application equipment includes any
equipment that directly contacts resin.
ii. Keep containers that store HAP containing material closed or covered except
during the addition or removal of materials. Bulk HAP containing materials
storage tank may be vented as necessary for safety
Hi. During the open molding process, Gelcoat or other materials application shall be
done manually or by robot spraying. Atomizer may not be used during this
process.
iv. During the closed molding process, Resin infusion shall utilize vacuum assisted
resin transfer mold (VARTM) technique.
c. The source must demonstrate continuous compliance with each standard in §63.5805 that applies
to this facility according to the methods specified in paragraphs (a)(1) through (3) of section
§ 63.5900.
d. The source must keep the records listed in paragraphs (a)(1) through (3) of section § 63.5915
9. The paint spray booth(s) shall be equipped with exhaust filters or paint arresters to control
particulate emissions.
10. Within one hundred and eighty days (180) after commencement of operation, the applicant shall
submit to the Division for approval an operating and maintenance plan for all control equipment
and control practices, and a proposed record keeping format that will outline how the applicant
will maintain compliance on an ongoing basis with the requirements of condition nos.: 3, 4 and 7
listed above. The operating and maintenance plan shall commence at startup. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
11. This source is subject to the provisions of Regulation No. 3, Part C, Operating Permits (Title V of
the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be
incorporated into the operating permit associated with this facility. The application for the
Operating Permit is due within one year of commencing operation of the equipment covered by
this permit. (Reference Reg. 3, Part C, 11.8.2)
12. The manufacturer, model number and serial number of the subject equipment shall be provided
to the Division within one hundred and eighty days (180) after commencement of operation.
(Reference: Regulation No. 3, Part B, Section III.E.)
13. Within one hundred and eighty days (180) after commencement of operation, 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. (Information on how to certify compliance
was mailed with the permit.)
123/0508/002
Page 4 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Bach Compos
Permit No. 09WE0630
INITIAL APPROVAL
14. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)
does not commence construction/modification or operation of this source within 18 months after
either the date of issuance of this initial approval permit or the date on which such construction or
activity was scheduled to commence as set forth in the permit application associated with this
permit; (ii) discontinues construction for a period of eighteen months or more; or (Hi) does not
complete construction within a reasonable time of the estimated completion date (See General
Condition No. 6., Item 1.). Upon a showing of good cause by the permittee, the Division may
grant extensions of the permit. (Reference: Regulation No. 3, Part B, Section III.F.4.)
By: By:
Sunday A. Fadeyi, P.E. R K Hancock III, P.E.
Permit Engineer Unit Leader
123/0508/002
Page 5 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Bach Compo.
Permit No. 09WE0630
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.
http://www. cd phe. state. co. us/regulations/airregs/100102agcccommon provisio n sreg. pdf
3). This source is classified as a: Major source for Operating Permit (HAPs)
At a: Major source for Operating permit facility.
4). The following emissions of non -criteria reportable air pollutants are estimated based upon the
material consumption as stated in the application. This information is listed to inform the operator of
the Division's analysis of the specific compounds. This information is listed on the Division's emission
inventory system
C.A.S. # SUBSTANCE EMISSIONS (Pounds per year)
100-42-5 Styrene
166,000
5) The emission levels contained in this permit are based on the following emission factors (EF):
Open Mold (Gelcoat Application):
Material Type
Applicable VOC/HAP EF Equation*
Material with less than 33% HAP content
EF = 0.185 x % HAP x 2000
Material with equal to or greater than 33%
HAP content
EF = ((0.4506 x %HAP) -0.0505) x 2000
Note: For VOC emissions the same equation shall be used substituting %VOC for %HAP
Particulate Matter (TSP) EF** = 0.0025 x (1 -%Volatile) pounds per ton of Gelcoat
Particulate Matter<10 pm (PM10) EF** = 0.0025 x (1 -%Volatile) pounds per ton of Gelcoat.
** Based on transfer efficiency (TE) of 95% and filter control efficiency (ContrEFF) of 95%
Closed Mold (Resin Infusion):
VOC EF = 20.01 lb per ton of Resin
HAP EF = 20.01 lb per ton of Resin
Mold Release and Cleaning:
VOC/HAP EF is by mass balance assuming that total VOC/HAP content of the cleaning material
is emitted.
Parts Grinding:
Particulate Matter (TSP):
Particulate Matter<10 pm (PM1°):
0.00107125 pounds per ton of raw materials
0.00107125 pounds per ton of raw materials.
123/0508/002
Page 6 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
Bach Compo
Permit No. 09WE0630
INITIAL APPROVAL
J
J
7
GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8)
1. 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.
2. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been
determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-
114.5(7)(a), C.R.S.
3. 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 final approval by
the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (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.
4. This permit and any required attachments must be retained and made available for inspection upon request
at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of
the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is
relocated) should be attached to this permit. The permit may be reissued to a new owner by the APCD as
provided in AQCC 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.
5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or operation
of this source. Final approval of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC 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 APCD as
conforming in all respects with the conditions of the permit. If the APCD so determines, it will provide written
documentation of such final approval, which does constitute "final" authority to operate. Compliance with
the permit conditions must be demonstrated within 180 days after commencement of operation.
6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within
18 months after either the date of issuance of this permit or the date on which such construction or activity
was scheduled to commence as set forth in the permit, whichever is later; (2) discontinue construction for a
period of 18 months or more; or (3) do not complete construction within a reasonable time of the estimated
completion date. Extensions of the expiration date may be granted by the APCD upon a showing of good
cause by the permittee prior to the expiration date.
7. YOU MUST notify the APCD at least thirty days (fifteen days for portable sources) prior to
commencement of the permitted operation or activity. Failure to do so is a violation of Section 25-7-
114.5(12)(a), C.R.S. and AQCC Regulation No. 3, Part B, Section III.G.1., and can result in the revocation of
the permit. You must demonstrate compliance with the permit conditions within 180 days after
commencement of operation as stated in condition 5.
8. 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.
9. 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.
123/0508/002
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