HomeMy WebLinkAbout20161767.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
May 25, 2016
Dear Sir or Madam:
RECEIVED
JUN 0 2 X16
WELD COUNTY
COMMISSIONERS
On May 25, 2016, the Air Pollution Control Division wilt begin a 30 -day public notice period for
Advanced Forming Technology - Longmont plant. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
yOL.; eu), 4/7
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cc
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
2016-1767
/c_/ .-1/
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Advanced Forming Technology - Firestone plant - Weld County
Notice Period Begins: May 25, 2016
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Advanced Forming Technology
Facility: Longmont plant
Manufacturer of metal injection molded products
7040 Weld County Rd 20, Longmont
Weld County
The proposed project or activity is as follows: Increase in VOC emissions
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the Division has determined that public comment is warranted because: Increase in permitted
emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy
in a non -attainment area and/or 50 tpy in an attainment area)
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 96WE428-2 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
KC Houlden
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLORdRO
1I t.„:
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NUMBER:
DATE ISSUED:
ISSUED TO:
96WE428-2
Advanced Forming Technology
Issuance 7
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Manufacturer of metal injection molded products located at 7040 Weld County Road 20,
Longmont, Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Electric
Sintering
Furnaces
and
Debind
units
002
Process: Solvent debinding and solvent recovery.
Equipment: Two (2) Serec, Model: 3638, S/Ns: 029, 030
Batch Cold Solvent Immersion Cleaning Units.
each equipped with a cold vapor recovery system
Solvent: Trichloroethylene (CAS # 79-01-6) (HAP)
004
Process: Solvent debinding and solvent recovery.
Equipment: One (1) Serec, Model: 3638, S/Ns: TBD,
Batch Cold Solvent Immersion Cleaning Units
equipped with a cold vapor recovery system
Solvent: 1- Bromopropane (CAS # 106-94-5)
(contains 1-5% 1,2-Epoxybutane) (CAS # 106-88-7)
(HAP)
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 issuance of this permit, compliance with the
conditions contained on this permit shall be demonstrated to the Division. It is the permittee's
AIRS ID: 123/0495
Page 1 of 14
Version 2009-1
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
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's website at https://www.colorado.gov/pacific/cdphe/air-permit-self-certification.
(Reference: Regulation Number 3, Part B, III.G.2).
2. Within one hundred and eighty days (180) after 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 Number 3,
Part B, 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 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. Note that the Division may modify the
monitoring requirements as part of the Title V Operating Permit if this facility is subject to Title V
permitting (Reference: Regulation Number 3, Part B, III.E.).
EMISSION LIMITATIONS AND RECORDS
4. Emissions of TCE and 1-bromopropane shall be determined by a mass balance approach. The
operator shall track and maintain records of the mass of TCE and 1- bromopropane added to the
solvent cleaning machines on a monthly basis. Such records shall be used to comply with the
emission limits contained in condition no. 10 below. Waste solvent shipped off site may be
quantified by appropriate sampling and analysis and subtracted from the calculated emissions.
Sampling and analysis of the waste solvent shall be conducted at a minimum of two times per
year. Records of the waste solvent volumes, and analytical results shall be maintained and made
available for inspection upon request.
5. Emissions of 1,2-Epoxybutane are assumed to be 5% of the 1-bromopropane emission. The
operator shall track and maintain records of the mass of 1,2-Epoxybutane added to the solvent
cleaning machine on a monthly basis, Such records shall be used to comply with the emission
limits contained in condition number 7 below. Waste solvent shipped off site may be quantified by
appropriate sampling and analysis and subtracted from the calculated emissions. Sampling and
analysis of the waste solvent shall be conducted at a minimum of two times per year. Records of
the waste solvent volumes, and analytical results shall be maintained and made available for
inspection upon request.
6. Emissions of Trichloroethylene (TCE) from all insignificant activities shall not exceed one ton per
year. The applicant shall track emissions from all insignificant activities on a yearly basis. This
information shall be made available to the Division for inspection upon request. For the purposes
of this condition, insignificant activities shall be defined as any activity or equipment which emits
any amount but does not require an Air Pollutant Emission Notice (APEN).
7. Emissions of air pollutants shall not exceed the following limitations. Monthly and Annual records
of the actual emission rates shall be maintained by the applicant and made available to the
Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4.)
Annual Limits:
AIRS ID: 123/0495 Page 2 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
pM
PM10
PM25
NO.
SO2
VOC
CO
Serec Debind
#1 & 2
002
-
-
-
-
-
6.9
-
Point
Serec Debind
#3
004
-
-
-
-
-
33.0
-
Point
TOTAL
Point
-
-
-
-
-
39.9
-
ee "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of Trichloroethylene (TCE) a hazardous air pollutant shall be less than9.0
tons per year. Compliance with the annual limits shall be determined by recording the facility's
annual emissions for all HAPs above the de minimus reporting level on a rolling twelve (12)
month total.
Facility -wide emissions of 1,2 epoxybutane a hazardous air pollutant shall be less than 8.0 tons
per year. Compliance with the annual limits shall be determined by recording the facility's annual
emissions for all HAPs above the de minimus reporting level on a rolling twelve (12) month total
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tons per year.
Compliance with the annual limits shall be determined by recording the facility's annual emissions
for all HAPs above the de minimus reporting level on a rolling twelve (12) month total.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
All emission calculations shall be made using the emission factors and format specified in Notes
to Permit Holder. The owner or operator shall petition the division, and receive division approval it
writing, prior to the use of any other method of calculating emissions.
8. The following control equipment shall be maintained and operated to ensure satisfactory
performance. The owner or operator shall monitor compliance with this condition through the
results of approved compliance tests (when required), compliance with the Operating and
Maintenance Plan, compliance records, and other methods as approved by the Division.
(Reference: Regulation Number 3, Part B, III.E.)
Facility
Equipment ID
AIRS Point
Control Device
Controlled
Pollutants
Debind units
1, 2 and 3
002 + 004
Vapor recovery system with cold condenser
for each debind unit
V OC
Hazardoudou s Air
Pollutants
PROCESS LIMITATIONS AND RECORDS
AIRS ID: 123/0495
Page 3 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
9. This source shall be limited to the following maximum consumption, processing and/or
operational rates as listed below. Monthly and Annual records of the actual process rate shall be
maintained by the applicant and made available to the Division for inspection upon request.
(Reference: Regulation Number 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Serec Debind
#1 & 2
002
Consumption of TCE
9 tons
Serec Debind
#3
004
Consumption of
1,bromopropane
50.8 tons
Compliance with the yearly process limits shall be determined on a rolling twelve (12) month total.
By the end of each month a new twelve-month total is calculated based on the previous twelve
months' data. The permit holder shall calculate monthly process rates and keep a compliance
record on site or at a local field office with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. 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. Opacity shall be determined using EPA Method 9. (Reference: Regulation Number 1,
II.A.1. & 4.)
11. The applicant shall maintain a major equipment list for AIRS Points 002 and 003 (see Attachment
A). The list shall be kept with this permit. This list shall be updated a minimum of once per
calendar year. Each time the equipment list is updated the operator shall mark the list with the
date on which the update was completed. If new equipment is added, the operator shall update
and denote on Attachment A the date on which the new equipment was installed. There shall be
no equipment additions that trigger additional permit requirements without receipt of written
approval from the Division prior to installation. The operator is responsible for determining if
additional permitting is required prior to installation of new equipment. Updated versions of the
equipment list will be maintained by the source and made available to the Division for inspection
upon request. (Reference: Regulation No 3, Part B,III.E.) (state only enforceable.)
12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
13. This source is subject to the requirements of Regulation No. 8, Part E, Subpart T - National
Emission Standards for Hazardous Air Pollutants for Halogenated Solvent Degreasers including,
but not limited to, the following
a. §63.460(a) The provisions of this subpart apply to each cleaning machine that uses
any solvent containing methylene chloride, perchloroethylene, trichloroethylene.
1,1,1, trichloroethane, carbon tetrachloride or chloroform.
b. §63.460(b) General Provisions Applicability to Subpart T of this subpart, the
provisions of subpart A of this part (General Provisions) apply to owners or operators
AIRS ID: 123/0495 Page 4 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
of any solvent cleaning machine meeting the applicability criteria of paragraph (a) of
this section.
c. §63.462 Batch Cold Cleaning Machine Standards - In lieu of the requirements
contained under §63.462(a) the source shall comply with the following alternative as
authorized in a November 24, 2003 letter issued by the Colorado APCD:
i. A tightly fitting cover shall be closed at all times on the solvent cleaning chamber
except during part entry and removal, and
ii. No detectable solvent will remain in the cleaning chamber under normal
conditions when the door is open.
iii. §63.462 (c)(1) All waste solvent shall be collected and stored in closed
containers. The closed container may contain a device that allows pressure
relief, but does not allow liquid solvent to drain from the container.
iv. §63.462 (c)(2) If a flexible hose or flushing device is used, flushing shall be
performed only within the freeboard area of the solvent cleaning machine.
v. §63.462 (c)(3) The owner or operator shall drain solvent cleaned parts for 15
seconds or until dripping has stopped, whichever is longer. Parts having cavities
or blind holes shall be tipped or rotated while draining.
vi. §63.462 (c)(4) The owner or operator shall ensure that the solvent level does not
exceed the fill line.
vii. §63.462 (c)(5) Spills during solvent transfer shall be wiped up immediately. The
wipe rags shall be stored in covered containers meeting the requirements of
paragraph (c)(1) of this section.
viii. §63.462 (c)(6) When an air- or pump -agitated solvent bath is used, the owner or
operator shall ensure that the agitator is operated to produce a rolling motion of
the solvent but not observable splashing against tank walls or parts being
cleaned.
ix. §63.462 (c)(7) The owner or operator shall ensure that, when the cover is open,
the cold cleaning machine is not exposed to drafts greater than 40 meters per
minute (132 feet per minute), as measured between 1 and 2 meters (3.3 and 6.6
feet) upwind and at the same elevation as the tank lip.
x. §63.462 (c)(8) Except as provided in paragraph (c)(9) of this section, sponges,
fabric, wood, and paper products shall not be cleaned.
xi. §63.462 (c)(9) The prohibition of paragraph (c)(8) of this section does not apply
to the cleaning of porous materials that are part of polychlorinated biphenyl
(PCB) laden transformers if those transformers are handled throughout the
cleaning process and disposed of in compliance with an approved PCB disposal
permit issued in accordance with the Toxic Substances Control Act.
xii. §63.462(d) Each owner or operator of a batch cold cleaning machine shall
AIRS ID: 123/0495 Page 5 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
submit an initial notification report as described in § 63.468 (a) and (b) and a
compliance report as described in § 63.468(c).
d. §63.465(e) Test Methods - shall determine their potential to emit from all solvent
cleaning operations, using the procedures described in paragraphs (e)(1) through
(e)(3) of this section. A facility's total potential to emit is the sum of the HAP
emissions from all solvent cleaning operations, plus all HAP emissions from other
sources within the facility.
xiii. §63.465(e)(2) Cleaning machines that do not have a solvent/air interface shall
calculate a solvent/air interface area using equation 7.
SAI=2.20 x (Vol)0'6 (Equation 7)
Where:
SAI = the solvent/air interface area (square meters).
Vol = the cleaning capacity of the solvent cleaning machine (cubic meters).
xiv. §63.465(e)(3) Sum the PTE; for all solvent cleaning operations to obtain the total
potential to emit for solvent cleaning operations at the facility.
e. §63.468(b) - Reporting Requirements - Each owner or operator of a new solvent
cleaning machine subject to the provisions of this subpart shall submit an initial
notification report to the Administrator. New sources for which construction or
reconstruction had commenced and initial startup had not occurred before December
2, 1994, shall submit this report as soon as practicable before startup but no later
than January 31, 1995. New sources for which the construction or reconstruction
commenced after December 2, 1994, shall submit this report as soon as practicable
before the construction or reconstruction is planned to commence. This report shall
include all of the information required in § 63.5(d)(1) of subpart A (General
Provisions), with the revisions and additions in paragraphs (b)(1) through (b)(3) of
this section.
§63.468(b)(1) The report shall include a brief description of each solvent cleaning
machine including machine type (batch vapor, batch cold, vapor in -line, or cold -
line), solvent/air interface area, and existing controls.
ii. §63.468(b)(2) The report shall include the anticipated compliance approach for
each solvent cleaning machine.
iii. §63.468(b)(3) In lieu of § 63.5(d)(1)(ii)(H) of subpart A of this part, the owner or
operator must report an estimate of annual halogenated HAP solvent
consumption for each solvent cleaning machine.
f. §63.468(c) Each owner or operator of a batch cold solvent cleaning machine subject
to the provisions of this subpart shall submit a compliance report to the Administrator.
For existing sources, this report shall be submitted to the Administrator no later than
150 days after the compliance date specified in §63.460(d). For new sources, this
report shall be submitted to the Administrator no later than 150 days after startup or
AIRS ID: 123/0495 Page 6 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
g.
Public Health and Environment
Air Pollution Control Division
May 1, 1995, whichever is later. This report shall include the requirements specified
in paragraphs (c)(1) through (c)(4) of this section.
i. §63.468(c)(1) The name and address of the owner or operator.
ii. §63.468(c)(2) The address (i.e., physical location) of the solvent cleaning
machine(s).
iii. §63.468(c)(3) A statement, signed by the owner or operator of the solvent
cleaning machine, stating that the solvent cleaning machine for which the report
is being submitted is in compliance with the provisions of this subpart.
iv. §63.468(c)(4) The compliance approach for each solvent cleaning machine.
§63.468(j) The Administrator has determined, pursuant to section 502(a) of the Act,
that if you are an owner or operator of any batch cold solvent cleaning machine that
is not a major source and is not located at a major source, as defined under 40 CFR
63.2, 70.2, or 71.2, you are exempt from title V permitting requirements under 40
CFR parts 70 or 71, as applicable, for that source, provided you are not otherwise
required to obtain a title V permit.
h. §63.469 Equivalent methods of control - Upon written application, the
Administrator may approve the use of equipment or procedures after they have been
satisfactorily demonstrated to be equivalent, in terms of reducing emissions of
methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane,
carbon tetrachloride or chloroform to the atmosphere, to those prescribed for
compliance within a specified paragraph of this subpart. The application must contain
a complete description of the equipment or procedure and the proposed equivalency
testing procedure and the date, time, and location scheduled for the equivalency
demonstration
14. Fugitive VOC emissions shall be controlled by the following practices: (Reference: Regulation
No.7, Section 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:
(I) tight -fitting covers for open tanks;
(II) covered containers for solvent wiping cloths
(III) proper disposal of dirty clean-up solvent.
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.
15. This source is subject to the requirements of Regulation No. 7.V.A. - Disposal of Volatile Organic
Compounds as follows:
No person shall dispose of volatile organic compounds by evaporation or spillage
AIRS ID: 123/0495 Page 7 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
unless RACT is utilized.
16. 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 numbers 8 and 13 above were determined to be
RACT for this source.
OPERATING & MAINTENANCE REQUIREMENTS
17. 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 commencement of operation, 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. Note that the Division may modify
the monitoring requirements as part of the Title V Operating Permit if this facility is subject to Title
V permitting (Reference: Regulation Number 3, Part B, III.E.).
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. A source initial compliance test shall be conducted on the vapor recovery to measure the
emission rate(s) for the pollutants listed below in order to demonstrate compliance with the VOC
and HAP emission limits listed in condition 10 above. The test protocol must be in accordance
with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be
submitted to the Division for review and approval at least thirty (30) days prior to testing. No
compliance test shall be conducted without prior approval from the Division. Any compliance test
conducted to show compliance with a monthly or annual emission limitation shall have the results
projected up to the monthly or annual averaging time by multiplying the test results by the
allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part
B., Section III.G.3)
• Volatile Organic Compounds using EPA approved methods.
• Trichloroethylene (TCE) (HAP)
• 1,2 Epoxybutane (HAP)
Periodic Testing Requirements
19. Semiannual sampling and analysis of the waste solvents shipped off site shall be carried out to
determine the amounts of waste reagents (TCE, 1-bromopropane and 1,2-epoxybutane) to be
deducted from the emissions totals. Records of the sampling and analytical results shall be
maintained and made available for review upon request. (Reference: Regulation Number 3, Part
B, III.E.)
ADDITIONAL REQUIREMENTS
20. All previous versions of this permit are cancelled upon issuance of this permit.
21. The permit number shall be marked on the subject equipment for ease of identification.
(Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
AIRS ID: 123/0495 Page 8 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
22. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation Number
3, Part A, I I.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
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.
GENERAL TERMS AND CONDITIONS:
23. 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
Number 3, Part B, II.B upon a request for transfer of ownership and the submittal of a revised
APEN and the required fee.
24. 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 is considered initial
approval and does not provide "final" approval 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 Number 3, Part B, III.G. Final
approval cannot be granted until the operation or activity commences and has been verified by
AIRS ID: 123/0495 Page 9 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
the APCD 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. The operator shall
retain the permit final approval letter issued by the Division after completion of self -certification
with the most current construction permit.
25. 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. (Reference: Regulation Number 3, Part B III.E.)
By: By:
R K Hancock III, P.E.
Construction Permits Unit Supervisor
K.C. Houlden
Permit Engineer
isto
Issuance
Date
Description
Issuance 7
This Issuance
Lowering throughput of point 004 from 79 tons per
year. Reducing control efficiency of condensers on
points 002 and 004
Issuance 4
September 16,
2014
Added equipment: 1 sintering furnace, 1 debind unit
(bromopropane), 3 cold trap vapor recovery units.
Adjust VOC emissions from 10.52 to 35.18 tpy.
Final Approval
modification #4
October 7, 2013
Allow source to create and maintain an equipment list
as part of the permit (Attachment A) to allow for
additional electric sintering furnaces without requiring
a permit modification
Final Approval
modification #3
November 20,
2012
Name change from PCC- Advanced Forming
Technology to Advanced Forming Technology,
updated general conditions
Initial Approval
modification #2
November 19,
2004
Request for increase in TCE emission limit on permit;
Addition of sintering furnaces previously covered by
permit 96WE428-1 to account for facility wide mass
balance approach for tracking TCE emissions;
Reclassification of solvent cleaning units from "Batch
vapor degreasers" to "Batch Cold Cleaners" for MACT
requirements.
Initial Approval
modification #1
February 5, 1999
Addition solvent cleaning unit relocated to this facility
Initial Approval
October 24, 1996
Issued to PCC- Advanced Forming Technology
AIRS ID: 123/0495
Page 10 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Notes to Permit Holder (as of date of permit issuance):
Public Health and Environment
Air Pollution Control Division
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 pollutant emission
notice (APEN) and application form must be submitted with a request for a permit revision.
(Reference: Regulation Number 3, Part B II.A.4.)
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: https://www.colorado.gov/pacific/cdphe/aqcc-regs.
3) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate' (Ib/yr)
002
Trichloroethylene (TCE)
108883
18,000
YES
11,673
004
1,2 Epoxybutane2
106887
5,080
YES
3,295
(1) Assumes overall capture of 95% and vapor recovery unit control efficiency of 63.9%
overall = 60.7%
(2) Per the MSDS information 1-bromopropane is assumed to contain five percent (5%)
1,2- epoxybutane
4) The emission levels contained in this permit are based on the following emission factors:
The uncontrolled emission levels contained in this permit are based on mass balance
calculations. The operator tracks the mass of make-up solvent added to the cleaning machines
and subtracts the amount of waste solvent shipped offsite. The remaining portion of solvent is
considered uncontrolled emissions. VOC emissions are calculated by multiplying the total TCE
solvent emission by a factor of 1.17 and adding the make amount of 1-bromopropane added.
Uncontrolled emissions
VOC (tons) = (Tons of TCE added * 1.17) + (tons of 1,bromopropane added) — (tons of waste
solvent)
TCE = (tons of TCE — tons of waste TCE)
AIRS ID: 123/0495 Page 11 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
1,2 epoxybutane (EB)=( (Tons of 1,bromopropane) — (tons of waste 1,bromopropane)) * 5%
Note: mass of 1,2 epoxybutane is 5% of the mass of 1, bromopropane
Controlled emissions are based on uncontrolled emissions modified by 1) the overall capture
(95%) and 2) the control efficiency of the vapor recovery unit (37.0 %)
VOC emissions (tons) = (Tons of VOC) * (95%) * (1-.37) + (tons of VOC * 5%)
TCE = (Tons of TCE) * (95%) * (1-.37) + (tons of TCE * 5%)
1,2 epoxybutane (EB) = (Tons of 1,2 EB ) * (95%) * (1-.37) + (tons of 1,2 EB * 5%)
5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated
with this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
6) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source HAPs
PSD
Minor Source
NANSR
Minor Source
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.460
Subpart T — National Emission Standards for Halogenated
Solvent Cleaning
8) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. Failure to pay the invoice will result in
revocation of this permit. The permit holder shall pay the invoice within 30 days of receipt of the
invoice (Reference: Regulation Number 3, Part A, VI.B.).
9) 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.
10) 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
AIRS ID: 123/0495
Page 12 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
permit, the applicant or owner or operator of a source may request a hearing before the AQCC for
review of the Division's action. (Reference: Regulation Number 3, Part B III.F.)
11) Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollutant
Emission Notice (APEN) must pay an annual emission fee. 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.
12) 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.
AIRS ID: 123/0495 Page 13 of 14
Advanced Forming Technology
Permit Number 92WE428-2
Issuance 7
Public Health and Environment
Air Pollution Control Division
ATTACHMENT A
MAJOR EQUIPMENT LIST (AIRS ID 002 AND 004)
(AS OF THE DATE OF PERMIT ISSUANCE)
AFT ID
MANUFACTURER
MODEL
SERIAL
NUMBER
ELNIK
ELNIK
MIM 3009-T-115
P-368
FURNACE 2
VFS
HL34 X 48
2186
FURNACE 3
VFS
HL50 BH
2230
FURNACE 4
VFS
HL34 X 48
2265
FURNACE 5
VFS
L50EQ11
2328
FURNACE 6
GM
301-XXLB
2743
FURNACE 7
VFS
HL54X84VDP
2369
FURNACE 8
GM
HVF-201-B
1702
FURNACE 9
GM
HVF-301-B
1703
FURNACE 10
GM
HVF-301-XB
1899
FURNACE 11
GM
HVF301-XXLB
2766
TWO (2) BATCH COLD SOLVENT
(TCE) IMMERSION CLEANING
UNITS; EACH EQUIPPED WITH
VAPOR RECOVERY SYSTEM
(DEBIND UNITS)
SEREC
MODEL 3638
029
030
ONE (1) BATCH COLD SOLVENT
(BROMOPROPANE) IMMERSION
CLEANING UNITS; EQUIPPED WITH
VAPOR RECOVERY SYSTEM
(DEBIND UNITS)
SEREC
MODEL 3638
133
AIRS ID: 123/0495
Page 14 of 14
AIR POLLUTION CONTROL DIVISION PRELIMINARY ANALYSIS
PERMIT NUMBER: 96WE428-2 DATE: May 6, 2016
APPLICANT: Advanced Forming Technology
ENGINEER: K.C. Houlden
CP SUPERVISOR: R K Hancock III, PE
PROJECT DESCRIPTION
The company listed above has applied for a modification to an existing air emission permit to
increase emissions and decreasing emission control efficiency of the condensers at the facility
located at 7040 Weld County Road 20, Longmont, in Weld County, Colorado.
SUMMARY OF EMISSIONS
Pollutant
Controlled Emissions
(Tons per Year)
Potential to Emit
(Tons per Year)
VOC
39.9
98.13
The Division has determined that the above emission source will comply with all applicable
regulations and standards, and plans to issue an emission permit. A copy of the draft permit is
included in the public comment packet.
SOURCE CLASSIFICATION
This metal injection mold manufacturing plant has the potential to emit (PTE) a total of 98.13
tons of volatile organic compounds (VOC) per year. After operational limitations were applied,
the VOC emissions will not exceed 39.9 tons per year. Because this source is requesting an
increase in permit limit of VOC over 25 tons per year in an ozone non -attainment area, this
source is required to undergo a public comment process.
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — General
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Section 01— Administrative Information
Request for NEW permit or newly reported emission source
Request PORTABLE source permit
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