The URL can be used to link to this page

Browse Search

Home My WebLink About20162331.tiff'COLORADO I Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 July 13, 2016 Dear Sir or Madam: On July 21, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for AFCO Steel, LLC. - Greeley 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. Regards, / Colorado Dept. of Public Health a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 7o'oIic KJLV iC- U.J 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Walk, MD, MSPH, Executive Director and Chief Medical Officer C.G* Pt_ GYI vm/-TP), HL.C PO), 1'L`-'C£.R/c Hl/7M� "7/go/ aoR, —►ias/ lc) 2016-2331 Air Pollution Control Division Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: AFCO Steel, LLC. - Greeley Plant - Weld County Notice Period Begins: July 21, 2016 NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: AFCO Steel, LLC. 31455 Weld County Road 39 1/2 Greeley, CO 8063 1-966 9 Facility: Greeley Plant AFCO Steel, LLC. 31455 Weld County Road 39 1/2 Greeley, CO 80631-9669 AFCO Steel, LLC. has applied to renew the Operating Permit for the Greeley Plant in Weld County, CO. The facility performs structural steel fabrication and coating. The only significant modifications include the addition of 40 CFR Part 63, Subpart XXXXXX and Colorado Regulation No. 7 requirements. There were no emission changes associated with this modification. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 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 has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Nick Dummer of the Division at 303-692-3125 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. Colorado Department of Public Health and Environment OPERATING PERMIT AFCO Steel, LLC Greeley Plant First Issued: February 1, 2000 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT F-ACILI-TY-NAME: - FACILITY ID: RENEWED: EXPIRATION DATE: MODIFICATIONS: - -Greeley Plant - 123/0488 October 1, 2008 October 30, 2013 See Appendix F of Permit OPERATING PERMIT NUMBER 99OPWE213 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et sec . and applicable rules and regulations. ISSUED TO: AFCO Steel, LLC PLANT SITE LOCATION: Greeley Plant 31455 Weld County Road 39 1/2 31455 Weld County Road 39'/2 Greeley, Colorado 80631-9669 Greeley, Colorado 80631-9669 INFORMATION RELIED UPON Operating Permit Renewal Application Received: And Additional Information Received: September 28, 2012 October 1, 2012, June 10, 2013, January 19-20, 2016 Nature of Business: Structural steel fabrication and coating Primary SIC: 3441 RESPONSIBLE OFFICIAL Name: Joe Honesto Title: Plant Manager FACILITY CONTACT PERSON Name: Joe Honesto Title: Plant Manager Phone: (970) 356-2326 Phone: (970) 356-2326 SUBMITTAL DEADLINES — First Semi -Annual Monitoring Period: Subsequent Semi -Annual Monitoring Periods: Semi -Annual Monitoring Reports: First Annual Compliance Period: Annual Compliance Certification: Note that the Semi -Annual Monitoring Reports and Annual Compliance report must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports. August 1 — January 31 February 1 — July 31 Due March 1, 2016 & September 1, 2016 & subsequent years February 1 —January 31 Due March 1, 2106 & subsequent years TABLE OF CONTENTS: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 2 3. Non -Attainment New Source Review and Prevention of Significant Deterioration 2 4. Accidental Release Prevention Program (112(r)) 2 5, Compliance Assurance Monitoring (CAM) 2 6. Summary of Emission Units 3 SECTION II - Specific Permit Terms 4 1. S001 — Protective Spray Coating of Structural Steel Components and Associated Cleaning Activities 4 2. S002 - Shot Blast System 8 3. 40 CFR Part 63, Subpart XXXXXX — National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source 14 SECTION III - Permit Shield 24 1. Specific Non -Applicable Requirements 74 2. General Conditions 24 3. Stream -lined Conditions "5 SECTION IV - General Permit Conditions (ver 5/22/2012) 26 1. Administrative Changes 16 2. Certification Requirements 26 3. Common Provisions �6 4. Compliance Requirements 30 5. Emergency Provisions 31 6. Emission Controls for Asbestos 3 I 7. Emissions Trading, Marketable Permits, Economic Incentives 3I 8. Fee Payment 31 9. Fugitive Particulate Emissions 32 10. Inspection and Entry 32 11. Minor Permit Modifications 32 12. New Source Review 32 13. No Property Rights Conveyed 32 14. Odor 32 15. Off -Permit Changes to the Source 33 16. Opacity 33 17. Open Burning 33 18. Ozone Depleting Compounds 33 19. Permit Expiration and Renewal 33 20. Portable Sources 33 21. Prompt Deviation Reporting 33 22. Record Keeping and Reporting Requirements 34 23. Reopenings for Cause 35 24. Section 502(b)(10) Changes 35 25. Severability Clause 36 26. Significant Permit Modifications 36 27. Special Provisions Concerning the Acid Rain Program 36 TABLE OF CONTENTS: 28. Transfer or Assignment of Ownership 36 29. Volatile Organic Compounds 36 30. Wood Stoves and Wood burning Appliances 37 APPENDIX A - Inspection Information 39 1. Directions to Plant 39 2. Safety Equipment Required: 39 3. Facility Plot Plan: 39 4. List of Insignificant Activities• 39 APPENDIX C Required Format for Annual Compliance Certification Reports 52 APPENDIX D 54 Notification Addresses 54 APPENDIX E 55 Permit Acronyms 55 APPENDIX F 57 Permit Modifications 57 APPENDIX G 58 Operating Plan 58 APPENDIX H 59 Compliance Assurance Monitoring Plan 59 Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 SECTION I - General Activities and Summary 1. Permitted Activities AFCO Steel, LLC Greeley Plant Page 1 AFCO Steel, LLC (Source) purchases rolled steel plate and shapes and fabricates them into components for bridges, buildings, and similar structures. The production operations involve sawing, shearing, flame cutting, hole -punching and drilling, and fitting and joining components together into a finished product by bolting or welding. The metal may be cleaned with steel shot blast and / or the application of a solvent. The shot blast cleaning unit is equipped with a particulate emissions control device. The Source also provides metal coating based on customer requests; these coatings may include a primer, paint, and other protective coatings. The coating operations are performed inside a large, open bay, primarily with spray devices. Due to the size of the steel components, traditional spray -paint booth style operations are prohibitively expensive. Coating overspray accumulates on the coating bay floor. Various solvents, primarily acetone, are used for cleaning the coating equipment. Thinning compounds may be used for the paint coatings. Large fans are used to provide ventilation. The facility is located in Weld County at 31455 Weld County Road 39 1/2, Greeley, Colorado 80631. This area is classified as non -attainment for ozone (O3) and is part of Colorado's 8 -hour Ozone Control Area as defined in Colorado Regulation No. 7, Section ff.A.1.b. The area is also classified as an attainment / maintenance area for carbon monoxide (CO). Under that classification, all State Implementation Plan (SIP) approved CO requirements will continue to apply to prevent backsliding under the provisions of Section 1100) of the Federal Clean Air Act (CAA); however, the Source emits a negligible amount of CO and there are no permitted conditions related to its emission. Wyoming is an affected state, located within 50 miles of the facility. Rocky Mountain National Park is a Federal Class I area within 100 kilometers of the facility. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 The Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Colorado Regulation No. 3, Part C. Thcse Part C procedures meet all applicable substantive New Source Review (NSR) requirements of Part B. Any revisions made using the provisions of Colorado Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the following construction permits: 95WE890. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section II - Condition 1.3, Section IV — Conditions 14 and 18. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 2 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios 2.1 No alternative operating scenarios have been specified thus any changes made to the methods of operation shall be reported to the Division for review. 3. Non -Attainment New Source Review and Prevention of Significant Deterioration 3.1 Based on the information provided by the applicant, the Source is categorized as a synthetic minor stationary source for the requirements of non -attainment new source review (NANSR) and prevention of significant deterioration (PSD) as of the date of the issuance of this permit. 3.2 For NANSR, any future modification at this facility which is major by itself (i.e. has a potential to emit (PTE) of 100 tons per year (tpy) or greater of either volatile organic compounds (VOC) or oxides of nitrogen (NOx)) may result in the application of NANSR review requirements. 3.3 For PSD, any future modification at this facility which is major by itself (i.e. has a PTE of 250 tpy or greater) for any pollutant listed in Colorado Regulation No. 3, Section D, II.A.44 for which the area in which the site is located is in attainment or attainment / maintenance may result in the application of PSD review requirements. 3.4 There are no other Operating Permits associated with this facility for purposes of determining applicability of PSD regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based upon the information received from the Source, this facility is not subject to the provisions of the Accidental Release Prevention Program — Section 112(r) of the Federal CAA. 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. The Source is therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: S002 — Shot blasting of structural steel components See Section 11, Condition 2.7 for compliance assurance monitoring requirements. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are as follows: AFCO Steel, LLC Greeley Plant Page 3 Facility ID I AIRS ID Description Pollution Control S001 001 Protective spray coating of structural steel components and associated cleaning, performed in a large, enclosed bay. N/A S002 002 Shot blast descaling of structural steel via stationary machinery: Wheelabrator with steel shot and 8 wheels, serial number: A140383 US Filter / Wheelabrator cyclone and size 45SH, model 36 cartridge filter system, serial number: A140533 Table 1 - AFCO Steel, LLC Title V Summary of Emission Units Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 4 SECTION 11 - Specific Permit Terms 1. S001 — Protective Spray Coating of Structural Steel Components and Associated Cleaning Activities 1.1 Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval TSP 1.1 6.1 tons per year Mass balance: 35% ffi f transer efficiency, Y, 90% control efficiency (see equation in Condition 1,1) Recordkeeping and calculation: 12- month rolling total Monthly, daily records of VOC and HAP content only PMiu 1.1 6.1 tpy Volatile Organic Compounds (VOC) P 1.1, 1.3 72.4 tpy Mass balance, spray- coating content restrictions Facility -wide Hazardous Air Pollutants (HAP) 1.1 8.0 tpy of a single HAP 20.0 tpy of facility - wide total HAP Opacity 1.2 Not to exceed 20% Material restriction Colorado Regulation 7 1.3 Sec Table 5 Spray -coating content restrictions (VOC) Recordkeeping and calculation Daily Table 2: S001 Emission Summary Total suspended particulate matter (TSP), particulate matter with diameter less than 10µm (PMio), VOC, and HAP emissions shall not exceed the limitations stated in Table 2 (95WE890, as modified under the provisions of Section 1, Condition 1.3 and Colorado Regulation No. 3, Part B, Section ii.A.6 and Part C, Section X. based on requested emissions identified on the APEN submitted on September 26, 2012). Monthly emissions of TSP, PM1o, VOC, and HAP shall be calculated at the end of the subsequent month using the following calculation. tons month lb gal 0.65 lb emitted 0.1. lb escaped = solids content (gal)* coating used r l * ( l * r lgal/ \month/ \ 1 lb sprayed / 11 lb captured 1 ton * (2000 lb) A twelve-month rolling total of emissions will be maintained to monitor compliance with the annual emission limitations. Each month, a new twelve-month total emission calculation shall be performed using the previous twelve months' data. Monthly records of the types and quantities of each material used (paint, thinner, solvent, etc.) and associated safety data sheets (SDS), emissions calculations, and compliance determinations shall be maintained and made available to the Division for review upon request. The records for each material must demonstrate the concentrations of HAP which shall be used to determine whether the material shall be defined as an applicable source under the following standards: "Materials that contain HAP" as Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 5 defined in 40 CFR Part 63, Subpart HHHHHH — National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, and for "Material containing MFHAP [metal fabrication HAP]" as defined in 40 CFR Part 63, Subpart XXXXXX — National Emission Standards for Hazardous Air Pollutants Area Source Standards for Ninc Metal Fabrication and Finishing Source Categories. Should an SDS contain a possible range,of concentrations, the highest given concentration (i.e. most conservative) shall be used for determining applicability, unless a more specific concentration can be proven by a manufacturer's formula or by an independent laboratory analysis of the 1-lAP content as described in Condition 1.1.4. 1.1.1 If the Source anticipates the use of any surface coating materials that would cause the Source to be classified as an affected source under Subparts IIITHHITH or XXXXXX, the Source shall be required to modify this permit to demonstrate compliance with the Subparts prior to the application of the surface coating. 1.1.2 The concentration limits, by percent (%) mass of target HAP containing compound contained in the surface coating, based on the definitions in Subpart HHHHHH to qualify as an applicable source under the Subpart are described in Table 3. Surface coating contains target HAP Percent (%) mass of compound Manganese (Mg) Cadmium (Cd), Chromium (Cr), Lead (Pb), Nickel (Ni) >1% >0.1% • All limits are for both HAP containing compounds and those in the elemental form with the exception of Pb as elemental lead is regulated as a criteria pollutant. • The concentration limits are based on the OSHA -defined carcinogenicity of Cd, Cr, Pb, and Ni as described in 29 CFR 1910.1200(d)(4)*. '[able 3 - Target HAP concentration requirements per Subpart HHHHHH *This reference, contained in Subpart HHHHHH has been deleted and no longer exists in the current 29 CFR 1910.1200. The original supporting reference from that version of the CFR follows: 59 FR 6170, February 9, 1994 as amended at 59 FR 17479, April 13, 1994; 59 FR 65948, December 22, 1994; 61 FR 9245, March 7, 1996. The updated reference is 29 CFR 1910.1200, Appendix A.6.4. 1.1.3 The concentration limits, by percent (%) weight of the MFHAP metal contained in the surface coating, based on the definitions in Subpart XXXXXX to qualify as an applicable source under the Subpart are described in Table 4. Surface coating contains target HAP Percent (%) weight of metal Manganese (Mg) >1% Cadmium (Cd), Chromium (Cr), Lead (Pb), Nickel (Ni) >0.1% • All limits are for both HAP containing compounds and those in the elemental form with the exception of Pb as elemental lead is regulated as a criteria pollutant. Table 4 -:Mth AP concentration requirements per Subpart XXXXXX Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 6 1.1.4 If a laboratory analysis is to be performed to determine the surface coating content, the procedure must first be approved by the Division. The protocol, analysis, and report must be in accordance with the requirements of the APCD Compliance Test Manual (https_//www.colorado.uov/pacific/cdphe/inspections-and-enforcement). In the absence of an approved test method for laboratory analysis, an alternative may be used with Division authorization. A protocol shall be submitted for Division approval at least thirty (30) calendar days prior to any laboratory analysis conducted pursuant to this condition. No laboratory analysis required herein shall be performed without prior Division approval. The analysis results shall be submitted to the Division within thirty (30) calendar days of the completion of the analysis. 1.2 No owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, 11.A.1.). 1.2.1 In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed provided that the Source only applies spray coatings that comply with the requirements described in Condition 1 and that are applied in a manner consistent with good air pollution control engineering practices. Should there be changes to the method of application of spray coatings, the Source shall inform the Division wherein this condition may be reviewed for modification as an additional demonstration of compliance with the opacity standard in Condition 1.2 may he necessary. 1.3 (State only enforceable) This unit is an affected source under Colorado Regulation No. 7 due to its location as described in Condition 1.1 and as defined by Colorado Regulation No. 7, Section LX.L.l.a.(viii). In addition to the General Permit Conditions described in Section IV, Condition 29 of this permit, the following conditions apply: 1.3.1 The Source shall not use surface coatings with VOC concentrations in excess of the limits in Table 5 (Colorado Regulation No. 7, IX.A.9.a.) wherein kg/lc is defined as kilograms of solvent VOC per liter of coating as applied (minus water and "exempt' solvents, as defined in Colorado Regulation No. 7, Section 11.B.). If more than one emission limitation applies to a coating, the least stringent emission limitation shall be applied (Colorado Regulation No. 7, TX.L.2.b.). Type of coating (Colorado Regulation No. 7, Section IX.L.1.c.) Maximum allowable VOC concentration in coating Clear Coatings 0.52 kg/lc Extreme Performance Coatings 0.42 kg/lc Air -Dried Coatings 0.42 kg/lc Other Coatings and Systems 0.36 kg/lc Table 5 - Regulation No. 7 surface coating Loncentration limitations 1.3.2 Control techniques and work practices shall be implemented at all times to reduce VOC emissions from fugitive sources (Colorado Regulation No. 7, IX.A.7.). Control techniques and work practices include, but are not limited to: Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 13.2.1 Tight -fitting covers for open tanks; and 1.3.2.2 Covered containers for solvent wiping cloths; and 1.3.2.3 Proper disposal of dirty cleanup solvent. AFC() Steel, LLC Greeley Plant Page 7 1.3.3 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 VOCs are collected and disposed of in a manner that prevents evaporation to the atmosphere (Colorado Regulation No. 7, TX.A.7.b.). 1.3.4 The Source shall demonstrate compliance with Condition 1.3 by maintaining records of the VOC content of all surface coatings used at the facility. Recordkeeping procedures shall follow the guidance as described in, "Recordkeeping Guidance Document for Surface Coating Operations and the Graphic Arts Industry," July 1989 (Colorado Regulation No. 7, IX.A.8.c.). These VOC data may originate from manufacturer provided SDS if they are certified by that manufacturer as being supported by the actual batch formulation records and as having been tested for VOC content using EPA Reference Method 24 — Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings (Colorado Regulation No. 7, IX.A.3.d.). 1.3.4.1 Alternatively, the Source may he permitted to use an alternative method of recordkeeping provided that it fulfills the requirements outlined in Condition 1.3.4. The Source shall prepare a report that demonstrates the equivalency of the recordkeeping methodologies and shall maintain it on site and make it available to the Division upon request for review. The Source shall update this report as necessary when changes to recordkeeping occur. At a minimum, the recordkeeping data must include: a. Coating formulation and analytical data; and b. Coating consumption data; and c. Spray applicator transfer efficiency data; and d. Process information. 1.3.5 Compliance with Condition 1.3 shall be determined on a daily basis and shall be calculated following the guidance as described in the following documents (Colorado Regulation No. 7, IX.A.10.): 1.3.5.1 EPA -450/3-84/019, "Procedure for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings"; 1.3.5.2 EPA -340/1-83-016, "A Guideline for Surface Coating Calculations" (Colorado Regulation No. 7, Appendix F). Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 2. S002 — Shot Blast System AFCO Steel, LLC Greeley Plant Page 8 Parameter Pennit Condition Number Limitation Compliance Emission Factor Monitoring Method- Interval Process Operating 2 I. 2,080 hours per year Hours Recordkeeping and calculation: 12- month rolling total Daily TSP 2.3 1.3 tpy1.2 pounds per hour Monthly PMio Permitted Abrasive Media 22 Steel shot only Recordkeeping Monthly Opacity 2.4 Not to exceed 20% Visible Inspections EPA Method 9 Daily, while operating As required 2.5 For certain operational activities — not to exceed 30% Control Equipment Operation 2.6 See Condi ion 2.6 Compliance Assurance Monitoring (CAM) 2.7 See Condition 2.7 NF.SHAP XXXXXX 2.2.1 See Condition 3 Table 6 - S002 Emission Summary 2.1 The use of the shot blast system shall not exceed the operating hours listed in 'fable 6 above(95WE890, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part B, Section II.A.6 and Part C, Section X. based on requested emissions identified on the APEN submitted on September 26, 2012). A log shall be maintained on -site that details the actual hours of operation per day; the log shall be made available to the Division upon request. Monthly hours of operation shall be calculated by the end of the subsequent month. A twelve-month rolling total of emissions shall be maintained to monitor compliance with the annual emission limitations. Each month, a new twelve- month total emission calculation shall be performed using the previous twelve months' data. 2.2 The abrasive media used in the shot blast system shall be limited to steel shot. The use of any other type of media shall be reported to the Division prior to use and may require a permit modification. SDS of the abrasive media content of the steel shot shall be maintained by the Source and be made available to the Division upon request. 2.2.1 Due to the material composition of the steel shot and the blasted steel, this unit is an affected source for dry abrasive blasting as defined 40 CFR Part 63, Subpart XXXXXX — National Emission Standards for hazardous Area Source Standards for Nine Metal Fabrication and Finishing Categories. See Condition 3 for Subpart XXXXXX applicable requirements. 2.3 Particulate emissions shall not exceed the limits listed in Table 6 (95WE890, as modified under the provisions of Section 1, Condition 1.3 and Colorado Regulation No. 3, Part B, Section I1.A.6 and Part C, Section X based on requested emissions identified on the APEN submitted on September 26, 2012). Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 9 Monthly emissions shall be calculated by the end of the subsequent month. A twelve-month rolling total of emissions shall be maintained to monitor compliance with the annual emission limitations. Each month, a new twelve-month total emissions calculation shall he performed using the previous twelve months' data. Records of the calculated emissions and compliance determinations shall be maintained and made available to the Division for review upon request. 2.4 Except as provided in Condition 2.5, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, II.A.1.). 2.4.1 The Source shall perform an EPA Reference Method 22, 6 -minute visible emissions observation of the shot blast system exhaust at least once daily while the unit is in operation. The results of these observations shall be logged on a daily observations sheet. Observations are not required for any day in which the shot blast system does not operate. If visible emissions arc observed from the stack, the permittee shall undertake the appropriate corrective process and / or maintenance actions as soon as practicable. When these actions are completed, that stack will be observed again during shot blast system operation. If visible emissions persist, the permittee shall perfonn an EPA Reference Method 9 opacity test. Subject to the provisions of C.R.S 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows and exceedance of the opacity limit, until a Method 9 reading is taken that shows the opacity is within the opacity limit. The corrective actions taken and the follow-up observations shall be noted on the daily observation sheet which shall be maintained and made available to the Division upon request. All Method 9 opacity observations shall be performed by an observer with a current and valid certification. A clear and readable copy of the observer's certificate shall be retained with the copies of the observations and made available to the Division upon request. Copies of any opacity observations made in accordance with the requirements of the permit that exceed the applicable standard shall be included with the net required report. 2.5 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4.). 2.6 The air pollution control equipment shall be operated in accordance with Item 1 of the Compliance Plan submitted (95WE890, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part B, Section ff.A.6 and Part C, Section X.). See Appendix G of this Operating Permit for information on the Construction Permit Operating Plan. The air pollution control equipment shall be maintained and renewed as per the manufacturer's recommendations, or more often if needed, Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 10 to ensure the continuing performance of the control devices. If the manufacturer's recommendations are no longer available, a written document detailing the procedures to be followed in controlling emissions shall be submitted for Division approval. Records shall be kept of the maintenance and renewals performed on the control devices. A copy of the manufacturer's recommendations or the Division approved operating procedure and copies of the maintenance and renewal records shall be maintained on -site and be made available to the Division upon request. 2.7 [Compliance Assurance Monitoring] The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply to the shot blast system with respect to the TSP and PM10 limitations identified in Condition 2.3 are as follows: 2.7.1 The permittee shall follow the CAM Plan provided in Appendix H of this permit. Excursions, for the purposes of reporting arc as follows: 2.7.1.1 Whenever visible emissions are detected from the exhaust stack; 2.7.1.2 Whenever there is a pressure drop reading outside of the following range: 1 to 6 inches of water (in. of H2O). Excursions shall be reported as required by the General Permit Conditions in Section IV, Conditions 21 and 22.d of this permit. 2.7.2 [Operation] The operation of approved monitoring are as follows: 2.7.2.1 At all times, the owner or operator shall maintain the monitoring system, which includes but is not limited to maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64, §64.7(b)). 2.7.2.2 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance and control (QA/QC) activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant -specific emissions unit (the shot blast system) is operating. Data recorded during monitoring malfunctions, associated repairs, and required QA/QC activities shall not be used for purpose of these CAM requirements; this includes data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all data collected during all other periods in assessing the operation of the control device and associated control systems. A monitoring malfunction is any sudden, infrequent, and not reasonably preventable failure of the monitoring system which has failed to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operations are not malfunctions (40 CFR Part 64 §64.7(c)). 2.7.2.3 The response to excursions or exceedances is as follows: a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant -specific cmissions unit (including the control device Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 11 and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any and all necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations have returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64, §67.4(d)(1)). b. Determination of whether the owner or operator has used acceptable procedures in response to an excursion or exceedance will be based upon information available, which may include bus is not limited to monitoring results, review of operation and maintenance (O&M) procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64, §64.7(d)(2)). 2.7.2.4 After approval of the monitoring required under the CAM requirements, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the Division and, if necessary, submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include but is not limited to reestablishing indication ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters (40 CFR Part 64, §64.7(e)). 2.7.3 [Quality Improvement Plan] The Quality Improvement Plan (QIP) requirements are as follows: 2.7.3.1 Based on the results of a determination made under the provisions of Condition 2.7.2.3.b., the Division may require the owner or operator to develop and implement a QTP (40 CFR Part 64, §64.8(a)). 2.7.3.2 If a QIP is required, the owner or operator shall maintain a written QIP and have it available for inspection by the Division (40 CFR Part 64, §64.8(b)(1)). 2.7.3.3 The QIP shall initially include procedures for evaluating control performance problems. Based upon the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64, §64.8(b)(2)(i)); b. Process operation changes (40 CFR Part 64, §64.8(b)(2)(ii)); Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 12 c. Appropriate improvements to control methods (40 CFR Part 64, §64.8(b)(2)(iii)); d. Other steps appropriate to correct control performance (40 CFR Part 64, §64.8(b)(2)(iv)). e. More I requent or improved monitoring (only in conjunction _ with one or more steps under Conditions 2.7.3.3.a. through d.) (40 CFR Part 64, §64.8(b)(2)(v)). 2.7.3.4 If a QIP is required, the owner or operator shall develop and implement a Q1P as expeditiously as practicable and shall notify the Division if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64, §64.8(c)). 2.7.3.5 Following the implementation of a QIP, upon any subsequent determination pursuant to Condition 2.7.3.32.7.2.3.b, the Division or the EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have either: a. Failed to address the cause of the control device performance problems (40 CFR Part 64, §64.8(d)(1)); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64, §64.8(d)(2)). 2.7.3.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting, or recordkeeping requirements that may apply under federal, state, or local law, or any other applicable requirements under the federal Clean Air Act (CAA) (40 CFR Part 64, §64.8(e)). 2.7.4 The reporting and recordkeeping requirements are as follows: 2.7.4.1 [Reporting requirements] The reports required by Section IV, Condition 22.d shall contain the information specified in Appendix B of the permit and the following information, as applicable: a. Summary information on the number, duration, and cause (including unknown cause, if applicable) for monitor downtime incidents (other than downtime associated with zero, span, or other daily calibration checks, if applicable) (40 CFR Part 64, §64.9(a)(2)(ii)); and b. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period, as specified in Condition 2.7.3 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring (40 CFR Part 64, §64.9(a)(2)(iii)). 2.7.4.2 [General recordkeeping requirements] In addition to the recordkeeping requirements in Section V, Condition 22.a.through c, the following apply: Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 13 a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 2.7.3 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records or monitoring maintenance or corrective actions) (40 CFR Part 64, §64.9(b)(1)); b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64, §64.9(b)(2)). 2.7.5 [Savings Provisions] The savings provisions are as follows: 2.7.5.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing remission limitations or standards, or any existing monitoring, testing, reporting or recordkeeping requirements that may apply under federal, state or local law, or any other applicable requirements under the federal CAA. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purpose of determining the monitoring to be imposed under separate authority under the federal CAA, including monitoring in permits issued pursuant to Title I of the federal CAA. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those missions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64, §64.10(a)(1)). 2.7.5.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the EPA or the Division to impose additional or more stringent monitoring, recordkeeping, testing, or reporting requirements on any owner or operator of a source under any provision of the federal CAA, including but not limited to sections 114(a)(l) and 504(b), or state, law, as applicable (40 CFR Part 64, §61.10(a)(2)). 2.7.5.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal CAA for any violation of an applicable requirement or of any person to take action under Section 304 of the federal CAA (40 CFR Part 64, §64.10(a)(2)). Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 14 3. 40 CFR Part 63, Subpart XXXXXX — National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source: Dry Abrasive Blasting, Machining, and Welding The Source is an affected source under Subpart XXXXXX due toits status as an existing facility primarily engaged in fabricated structural metal manufacturing, and performs dry abrasive blasting, machining, and welding which uses materials that contain or have the potential to emit metal fabrication or finishing metal HAP (MFHAP), defined to be the compounds of Cd, Cr, Pb, Mg, and Ni, or any of these metals in the elemental form with the exception of Pb. Materials that contain MFHAP are defined to be materials that contain greater that 0.1 percent (%) by weight of the elemental metal for carcinogens, as defined by 29 CFR 1910.1200(d)(4) (this reference has been replaced in the updated version in the rule as 29 CFR 1910.1200 Appendix A.6.4.), and greater than 1.0 % for noncarcinogens. For MFHAP, this corresponds to materials that contain Cd, Cr, Pb, or Ni in amounts greater than or equal to 0.1 % by weight of the elemental metal, and materials that contain Mg in amounts greater than or equal to 1.0% by weight of the elemental metal, as shown in the formulation data provided by the manufacturer or supplier, such as the SDS for the material (40 CFR Part 63, § 11514(a)&(b)). [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63, Subpart XXXXXX published in the Federal Register on July 23, 2008. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart XXXXXX] [These requirements have not been adopted into Colorado Regulation No. 8, Part E as of the date of this permit issuance, [DATE], and are therefore not state -enforceable. in the event that these requirements are adopted into Colorado Regulations, they will become state -enforceable.] 3.1.1 The compliance date for existing sourccs under Subpart XXXXXX is July 25, 2011 (40 CFR Part 63, §63.11515(a)). 3.1.2 [Dry abrasive blasting] The Source performs dry abrasive blasting with steel shot and sand on objects greater than eight (8) feet in any one dimension in a vented enclosure. The shot blast media and steel blasted contain MFHAP in excess of the thresholds described in Condition 3.1, therefore dry abrasive blasting is an affected unit and operations are subject to the following requirements. Note that the Source may elect to perform dry abrasive blasting according to the standards in §63.11516(a)(2) or (3) (Conditions 3.1.2.1 or 3.1.2.2), as applicable (40 CFR Part 63, §63.11516(a)). 3.1.2.1 The standards for dry abrasive blasting of objects in a vented enclosure are as follows; if the items to be blasted exceed 8 feet (2.4) meters in any dimension, the Source may perform the dry abrasive blasting according to §63.11516(a)(3) (Condition 3.1.2.2) (40 CFR Part 63, §63.11516(a)(2)): a. The Source shall capture emissions and vent them to a filtration control device. The Source shall operate the filtration control device according to manufacturer's instructions, and shall demonstrate compliance with this requirement by maintaining a record of the manufacturer's specifications for the filtration control Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 15 devices, as specified by the requirements in §63.11519(c)(4) (Condition 3.1.9.4) (40 CFR Part 63, §63.11516(a)(2)(i); and b. The Source shall take measures necessary to minimize excess dust in the surrounding area to reduce MFHAP emissions, as practicable (40 CFR Part 63, §63.11516(a)(2)(ii)(A)); and c. The Source shall enclose dust, abrasive material storage areas and holding bins, seal chutes, and conveyors that transport abrasive materials (40 CFR Part 63, §63.11516(a)(2)(ii)(B)); and d. The Source shall operate all equipment associated with dry abrasive blasting operations according to manufacturer's instructions (40 CFR Part 63, §63.11516(a)(2)(ii)(C)). 3.1.2.2 The standards for dry abrasive blasting of objects greater than eight (8) feet in any one dimension are as follows: a. The Source shall take measures necessary to minimize excess dust in the surround area to reduce MFHAP emissions, as practicable (40 CFR Part 63, §63.11516(a)(3)(i)(A)); and b. The Source shall enclose abrasive material storage areas and holding bins, seal chutes and conveyors that transport abrasive material (40 CFR Part 63, §63.11516(a)(3)(i)(B)); and c. The Source shall operate all equipment associated with dry abrasive blasting operations according to manufacturer's instructions (40 CFR Part 63, §63.11516(a)(3)(i)(C)); and d. The Source shall not re -use dry abrasive blasting media unless contaminants (i.e., any material other than the base metal such as paint residue) have been removed by filtration or screening, and the abrasive material conforms to its original size (40 CFR Part 63, §63.11516(a)(3)(i)(D)); and e. Whenever practicable, the Source shall switch from high particulate matter (PM) - emitting blast media (e.g., sand) to low PM emitting blast media (e.g., crushed glass, specular menatite, steel shot, aluminum oxide), where PM is a surrogate for MFHAP (40 CFR Part 63, §63.11516(a)(3)(i)(E). f. The Source shall perform visual determinations of fugitive emissions as specified in §63.11517(b) (Condition 3.1.5.3) (40 CFR Part 63, §63.11516(A)(ii)). (i) For abrasive blasting of objects greater than 8 feet (2.4 meters) in any one dimension that is performed outdoors, the Source shall perform visual determinations of fugitive emissions at the fenceline or property border nearest to the outdoor dry abrasive blasting operation (40 CFR Part 63, §63.11516(a)(3)(ii)(A)). (ii) For abrasive blasting of objects greater than 8 feet (2.4) meters in any one dimension that is performed indoors, the Source shall perform visual Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 16 determinations of fugitive emissions at the primary vent, stack, exit, or opening from the building containing the abrasive blasting operations (40 CFR Part 63, §63.11516(a)(3)(ii)(B)). g. The Source shall keep a record -of all visual determinations of fugitive emissions along with any corrective action taken in accordance with the requirements in §63.11519(c)(2) (Condition 3.1.9.2) 40 CFR Part 63, §63.11516(a)(3)(iii)). h. If visible fugitive emissions are detected, the Source shall perform corrective actions until the visible fugitive emissions are eliminated, at which time the Source shall comply with the requirements in §63.11516(a)(3)(iv)(A) and (B) (Conditions 3.1.2.2.h.Errorl Reference source not found. and (ii)) (40 CFR Part 63, §63.11516(a)(3)(iv)). (i) The Source shall perform a follow-up inspection for visible fugitive emissions in accordance with §63.11517(a) (Condition 3.1.5.1) (40 CFR Part 63, §63.11516(a)(3)(iv)(A)). (ii) The Source shall report all instances where visible emissions are detected, along with any corrective action taken and the results of subsequent follow- up inspections for visible emissions, with the Source's annual certification and compliance report as required by §63.11519(b)(5) (Condition 3.1.8.2) (40 CFR Part 63, §63.11516(a)(3)(iv)(B)). 3.1.3 [Machining] The Source performs machining on steel that contains MFHAP in excess of the thresholds described in Condition 3.1 and is subject to the following requirements (40 CFR Part 63, §63.11516(b)). 3.1.3.1 The Source shall take measures necessary to minimize excess dust in the surrounding area to reduce MFHAP emissions, as practicable (40 CFR Part 63, §63.11516(b)(1)); and 3.1.3.2 The Source shall operate all equipment associated with machining according to manufacturer's instructions (40 CFR Part 63, §63.11516(b)(2)). 3.1.4 [Welding] The Source performs welding with materials that contain MFHAP in excess of the thresholds described in Condition 3.1 and uses more than 2,000 pounds per year of welding rod containing MFHAP, and is subject to the following requirements (40 CFR Part 63, §63.11516(1)), 3.1.4.1 The Source shall operate all equipment, capture, and control devices associated with welding operations according to manufacturer's instructions and shall demonstrate compliance with this requirement by maintaining a record of the manufacturer's specifications for the capture and control devices, as specified by the requirements in Condition 3.1.9.4 (40 CFR Part 63, §63.11516(O(1)). 3.1.4.2 The Source shall implement one or more of the following management practices to minimize emissions of MFHAP, as practicable, while maintaining the required welding quality through the application of sound engineering judgment (40 CFR Part 63, Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 17 §63.11516(f)(2)): a. Use welding process with reduced fume generation capabilities (e.g., gas metal arc welding (GMAW) — also called metal inert gas welding (MIG)) (40 CFR Part 63, §63.11516(f)(2)(i)); b. Use welding process variations (e.g., pulsed current GMAW), which can reduce fume generation rates (40 CFR Part 63, §63.11516(f)(2)(ii)); c. Use welding filler metals, shielding gases, carrier gases, or other process materials which are capable of reduced welding fumc generation (40 CFR Part 63, §63.11516(f)(2)(iii)); d. Optimize welding process variables (e.g., electrode diameter, voltage, amperage, welding angle, shield gas flow rate, travel speed) to reduce the amount of welding fume generated (40 CFR Part 63, §63.11516(f)(2)(iv)); e. Use a welding fume capture and control system, operated according to the manufacturer's specifications (40 CFR Part 63, §63.11516(f)(2)(v)). 3.1.4.3 [Tier 1J The Source shall perform visual determinations of welding fugitive emissions as specified in Condition 3.1.5.3 at the primary vent, stack, exit, or opening from the building containing the welding operations. The Source shall keep a record of all visual determinations of fugitive emissions along with any corrective action taken in accordance with the requirements in Condition 3.1.9.2 (40 CFR Part 63, §63.11516([)(3)). 3.1.4.4 If visible fugitive emissions are detected during any visual determination required in Condition 3.1.4.3, the Source shall comply with the following requirements (40 CFR Part 63, §63.11516(1)(4)): a. Perform corrective actions that include, but are not limited to, inspection of welding fume sources and evaluation of the proper operation and effectiveness of the management practices or fume control measures implemented in accordance with Condition 3.1.4.2. After completing such corrective actions, the Source shall perform a follow-up inspection for visible fugitive emissions in accordance with Condition 3.1.5.1 at the primary vent, stack, exit, or opening from the building containing the welding operations (40 CFR Part 63, §63.11516(f)(4)(0). b. Report all instance where visible emission are detected, along with any corrective action taken and the results of subsequent follow-up inspections for visible emissions, and submit with the annual certification and compliance report as required by Condition 3.1.8.2 (40 CFR Part 63, §63.11516(f)(4)(ii)). 3.1.4.5 [Tier 2] If visible fugitive emissions are detected more than once during any consecutive 12 -month period (notwithstanding the results of any follow-up inspections), the Source shall comply with the following requirements (40 CFR Part 63, §63.11516(f)(5)): a. Within 24 hours of the end of the visual determination of fugitive emissions in which visible fugitive emissions were detected, the Source shall conduct a visual Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 18 determination of emissions opacity, as specified in Condition 3.1.5.4 at the primary vent, stack, exit, or opening from the building containing the welding operations (40 CFR Part 63, §63.11516(f)(5)(i)). b_ In -lieu -of -the -requirement of Condition-3L43-to-per-fo- -visual-determinations of fugitive emissions with EPA Method 22, the Source shall perform visual determinations of emissions opacity in accordance with Condition 3.1.5.5 using EPA Method 9, at the primary vent, stack, exit, or opening from the building containing the welding operations (40 CFR Part 63, §63.11516(f)(5)(ii)). c. The Source shall keep a record of each visual determination of emissions opacity performed in accordance with Condition 3.1.4.5.a. or b., along with any subsequent corrective action taken, in accordance with the requirements in Condition 3.1.9.3 (40 CFR Part 63, §63.11516(t)(5)(iii)). d. The Source shall report the results of all visual determinations of emissions opacity performed in accordance with Condition 3.1.4.5.a. or b., along with any subsequent corrective action taken, and submit with the annual certification and compliance report as required by Condition 3.1.8.3 (40 CFR Part 63, §63.11516(O(5)(iv)). 3.1.4.6 For each visual determination of emissions opacity performed in accordance with Condition 3.1.4.5 for which the average of the six -minute average opacities recorded is 20 percent (%) or less, but greater than zero, the Source shall perform corrective actions, including inspection of all welding fume sources, and evaluation of the proper operation and effectiveness of the management practices or fume control measures implemented in accordance with Condition 3.1.4.2 (40 CFR Part 63, §63.11516(O(6)). 3.1.4.7 [Tier 3] For each visual determination of emissions opacity performed in accordance with Condition 3.1.4.5 for which the average of the six -minute average opacities recorded exceeds 20 percent (%), the Source shall comply with the following requirements (40 CFR Part 63, §63.11516(O(7)). a. The Source shall submit a report of exceedance of 20 percent (%) opacity, along with the annual certification and compliance report, as specified in Condition 3.1.8.4 and according to the requirements of Condition 3.1.8 (40 CFR Part 63, §63.11516(O(7)(i)). b. Within 30 days of the opacity exceedance, the Source shall prepare and implement a Site -Specific Welding Emissions Management Plan (SSWEMP), as specified in Condition 3.1.4.8. If a SSWEMP has already been prepared in accordance with Condition 3.1.4.8, the Source shall prepare and implement a revised SSWEMP within thirty (30) days (40 CFR Part 63, §63.11516()(7)(ii)). c. During the preparation (or revision) of the SSWEMP, the Source shall continue to perform visual determinations of emissions opacity, beginning on a daily schedule as specified in CONDITION 3.1.5.5 using EPA Method 9, at the primary vent, stack, exit, or opening from the building containing the welding operations (40 CFR Part 63, §63.11516(f)(7)(iii)). Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT [ Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 19 d. The Source shall maintain records of daily visual determinations of emissions opacity performed in accordance with Condition 3.1.4.7.c., during preparation of the SSWEMP, in accordance with the requirements in CONDITION 3.1.8.5 (40 CFR Part 63, §63.11516(f)(7)(iv)). e. The Source shall include these records in the annual certification and compliance report, according to the requirements of Condition 3.1.8 (40 CFR Part 63, §63.11516(f)(7)(v)). 3.1.4.8 The Site -Specific Welding Emissions Management Plan (SS WEMP) must comply with the following requirements (40 CFR Part 63, §63.11516(f)(8)(i)). a. The SSWEMP must contain the following information (40 CFR Part 63, §63.11516(t)(8)(i)(A) through (F)): (i) Company name and address; (ii) A list and description of all welding operations which currently comprise the welding affected source, (iii) A description of all management practices and / or fume control methods in place at the time of the opacity exceedance; (iv) A list and description of all management practices and / or fume control methods currently employed for the welding affected source; (v) A description of additional management practices and / or fume control methods to be implemented pursuant to Condition 3.1.4.7.b. above, and the project date of implementation; and (vi) Any revisions to a SSWEMP must contain copies of all previous plan entries, pursuant to the requirements in Condition 3.1.4.8. b. The SS WEMP must be updated annual to contain the current information, as required by Condition 3.1.4.8.a.(i) through (iii), and submitted with the annual certification and compliance report, according to the requirements of Condition 3.1.8 (40 CFR Part 63, §63.11516(f)(8)(ii)). c. The Source shall maintain a copy of the current SSWEMP in a readily -accessible location for Division review, in accordance with the requirements in Condition 3.1.9.6 (40 CFR Part 63, §63.11516(f)(8)(iii)). 3.1.5 [Monitoring] The monitoring requirements for each affected unit under Subpart XXXXXX at the facility are as follows (40 CFR Part 63, §63.11517). 3.1.5.1 Visual determination of fugitive emissions must be performed according to the procedures of EPA Method, 22, of 40 CFR Part 60, Appendix A-7. The Source shall conduct the EPA Method 22 test while the affected source is operating under normal conditions. The duration of each EPA Method 22 test must be at least fifteen (15) minutes, and visible emissions will be considered to be present if they are detected for more than six (6) minutes of the fifteen minute period (40 CFR Part 63, §63.11517(a)). Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 0 3.1.5.2 Due to the nature of the operation of the Source, multiple affected sources under Subpart XXXXXX occur in the same area and have the same primary vent, stack, exit, or opening from the building in which they arc performed. For the purposes of the monitoring requirements in Condition 3.1.5, fugitive emissions identified during the required monitoring that cannot be reasonably identified as to which affected source is responsible shall require all affected sources in the operating area to comply with the requirements in Condition 3.1.5 as if they were responsible for those emissions. 3.1.5.3 Visual determinations of fugitive emissions must be performed in accordance with Condition 3.1.5.1 and according to the following schedule (40 CFR Part 63, §63.11517(b)). a. Perform visual determination of fugitive emissions once per day, one each day the process is in operation, during the operation of the process (40 CFR Part 63, §63.11517(b)(1)). b. If no visible fugitive emissions are detected in consecutive daily EPA Method 22 tests, performed in accordance with Condition 3.1.5.3.a., for ten (10) days of work day operation of the process, the Source may decrease the frequency of EPA Method 22 testing to once every five (5) days of operation of the process (one calendar week). If visible fugitive emissions are detected during these tests, the Source shall resume EPA Method 22 testing of that operation once per day during each day that the process is in operation, in accordance with Condition 3.1.5.3.a. (40 CFR Part 63, §63.11517(b)(2)). c. If no visible fugitive emissions are detected in four consecutive weekly EPA Method 22 tests performed in accordance with Condition 3.1.5.3.b., the Source may decrease the frequency of EPA Method 22 testing to once per 21 days of operation of the process (one calendar month). If visible fugitive emissions are detected during these tests, the Source shall resume weekly EPA Method 22 in accordance with Condition 3.1.5.3.b. (40 CFR Part 63, §63.11517(b)(3)). d. If no visible fugitive emissions are detected in three consecutive monthly EPA Method 22 tests performed in accordance with Condition 3.1.5.3.c., the Source may decrease the frequency of EPA Method 22 testing to once per 60 days of operation of the process (three (3) calendar months). If visible fugitive emission are detected during these tests, the Source shall resume monthly EPA Method 22 in accordance with Condition 3.1.5.3.c (40 CFR Part 63, §63.11517(b)(4)). 3.1.5.4 If the welding operation is subject to either Tier 2 or Tier 3 requirements as described in Conditions 3.1.4.5 or 3.1.4.7, visual determination of emissions opacity must be performed in accordance with the procedures of EPA Method 9, of 40 CFR Part 60, Appendix A-4, and while the affected source is operating under normal conditions. The durations of the EPA Method 9 test shall be thirty (30) minutes (40 CFR Part 63, §63.11517(c)). 3.1.5.5 If the welding operation is subject to either Tier 2 or Tier 3 requirements as described in Conditions 3.1.4.5 or 3.1.4.7, the Source shall perform visual determination of Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 21 emissions opacity in accordance with Condition 3.1.5.4 and according to the following schedule in Condition 3.1.5.5.a. through e. (40 CFR Part 63, §63.11517(d)). a. Perform visual determination of emissions opacity once per day during each day that the process is in operation (40 CFR Part 63, §63.11517(d)(1)). b. If the average of the six -minute opacities recorded during any of the daily consecutive EPA Method 9 tests performed in accordance with Condition 3.1.5.5.a. does not exceed 20 percent (%) for ten (10) days of operation of the process, the Source may decrease the frequency of EPA Method 9 testing to once per five (5) days of consecutive work day operation. If opacity greater than 20 percent is detected during any of these tests, the Source shall resume testing every day of operation of the process according to the requirements of Condition 3.1.5.5.a. (40 CFR Part 63, §63.11517(d)(2)). c. If the average of the six -minute opacities recorded during any of the consecutive weekly EPA Method 9 tests performed in accordance with Condition 3.1.5.5.b. does not exceed 20 percent for four consecutive weekly tests, the Source ma decrease the frequency of EPA Method 9 testing to once per every 21 days of operation of the process (one calendar month). If visible emissions opacity greater than 20 percent is detected during any monthly test, the Source shall resume testing every five days of operation of the process according to the requirements of Condition 3.1.5.5.b. (40 CFR Part 63, §63.11517(d)(3)). d. If the average of the six -minute opacities recorded during any of the consecutive weekly EPA Method 9 tests performed in accordance with Condition 3.1.5.5.c. dots not exceed 20 percent for three consecutive monthly tests, the Source may decrease the frequency of EPA Method 9 testing to once per every 120 days of operation of the process (three (3) calendar months). If visible emissions opacity greater than 20 percent is detected during any quarterly test, the Source shall resume testing every 21 days (calendar month) of operation of the process according to the requirements of Condition 3.1.5.5.c. (40 CFR Part 63, §63.11517(d)(4)). e. If, after two consecutive months of testing, the average of the six -minute opacities recorded during any of the monthly EPA Method 9 tests performed in accordance with Condition 3.1.5.5.c.does not exceed 20 percent, the Source may resume EPA Method 22 testing as in Condition 3.1.5.3.c. and d. In lieu of this, the Source may elect to continue performing EPA Method 9 tests in accordance with Condition 3.1.5.5.c.and d. (40 CFR Part 63, §63.11517(d)(5)). 3.1.6 [Initial notification] The Source shall submit an initial notification required by 40 CFR Part 63, §63.9(b), "General Provisions," no later than July 25, 2011. The Initial notification must provide the information specified in 40 CFR Part 63, §63.11519(a)(i) through (iv) (40 CFR Part 63, §6311519(a)). Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 22 3.1.7 [Compliance notification] The Source shall submit a notification of compliance status on or before November 22, 2011. The Source shall submit the information specified in 40 CFR Part 63, §63.11519(a)(2)(i) through (iv) (40 CFR Part 63, §63.11519(a)(2)). 3.1.8 [Reporting] The Source shall prepare and submit annual certification and compliance reports for each affected source according to the requirements in 40 CFR Part 63, §63.11519(b). These reports shall include the following information, as applicable: 3.1.8.1 General requirements (40 CFR Part 63, §63.11519(b)(4)); and 3.1.8.2 Visual determination of fugitive emissions requirements (40 CFR Part 63, §63.11519(b)(5)); and 3.1.8.3 Visual determination of emissions opacity requirements (40 CFR Part 63, §63.11519(b)(6)); and 3.1.8.4 Exceedances of 20 percent opacity for welding affected sources (40 CFR Part 63, §63.11519(b)(8)); and 3.1.8.5 Site -Specific Welding Emissions Management Plan reporting (40 CFR Part 63, §63.11519(b)(9)). 3.1.9 The Source shall keep records of the data and information specified in Conditions 3.1.9.1 through 3.1.9.7 according to the requirements in Condition 3.1.9.8 for each affected source (40 CFR Part 63, §63.11519(e)). 3.1.9.1 General compliance and applicability records (40 CFR Part 63, §63.11519(c)(1)). 3.1.9.2 Visual determination of fugitive emissions records (40 CFR Part 63, §63.11519(e)(2)). 3.1.9.3 Visual determination of emissions opacity records (40 CFR Part 63, §63.11519(c)(3)). 3.1.9.4 Maintain a record of the manufacturer's specifications for the control devices used to comply with 40 CFR Part 63, §63.11516 (40 CFR Part 63, §63.11519(c)(4)). 3.1.9.5 Visual determination of emissions opacity performed during the preparation (or revisions) of the Site -Specific Welding Emissions Management Plant (40 CFR Part 63, §63.11519(e)(11)). 3.1.9.6 Site -Specific Welding Emissions Management Plan (40 CFR Part 63, §63.11519(e)(12)). 3.1.9.7 Manufacturer's instructions (40 CFR Part 63, §63.11519(c)(13)). 3.1.9.8 The Source's records shall be maintained according to the requirements in Condition 3.1.9.7.a. through c. (40 CFR Part 63, §63.11519(c)(15)). a. The Source's records shall be in a form suitable and readily available for expeditious review, according to 40 CFR Part 63, §63.10(b)(1), "General Provisions." Where appropriate, the records may be maintained as electronic spreadsheets or as a database (40 CFR Part 63, §63.11519(c)(15)(i)). Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 23 b. As specified in 40 CFR Part 63, §63.10(b)(1), "General Provisions," the Source shall keep each record for five (5) years following the date of each occurrence, measurement, corrective action, report, or record (40 CFR Part 63, §63.11519(c)(15)(ii)). c. The Source shall keep each record on -site for at least two (2) ears after the date of each occurrence, measurement, corrective action, report, or record according to 40 CFR Part 63, §63.10(b)(1), " General Provisions." The Source may keep the records off -site for the remaining three (3) years (40 CFR Part 63, §63.11519(c)(15)(iii)). (c) (15) (iii)). Operating Permit 99OPWE213 First issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 SECTION III - Permit Shield AFCO Steel, LLC Greeley Plant Page 24 Colorado Regulation No. 3. 5 CCR 1001-5. Part C. §§ I.A.4, V.D. & XITT.B: § 25-7-114.4(3)(a), C.R.S. 1. Specific -Non -Applicable -Requirements — Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modifications or reconstruction on which construction commenced prior to permit issuance. Emission Unit Description & Number Applicable Requirement S001 — Protective Coating and Associated Cleaning Activities 40 CFR Part 63, Subpart MMMM — National Emission Standards for Hazardous Air pollutants: Surface Coating of Miscellaneous Metal Parts and Products Justification The source is not subject to Subpart MMMM as this Operating Permit is synthetic minor and contains federally -enforceable HAP limits below the major source threshold. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal CAA, concerning enforcement in cases of emergency; 2.2 1'he liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to §25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Colorado Regulation No. 3, Part C, § X111. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 3. Stream -lined Conditions AFC() Steel, LLC Greeley Plant Page 25 The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. No applicable requirements were streamlined out of this permit. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Pennit # 99OPWE213 AFCO Steel, TLC Greeley Plant Page 26 SECTION IV - General Permit Conditions (ver 5/22/2012) 1. Administrative Changes Regulation No. 3. 5 CCR 1001-5. Pan A. § III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No. 3, Part A, § 1.B.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.9., V.C.16.a.& e. and V.C.17. a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of such form, report or certification stating that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s) used for determining the compliance status of the source, currently and over the reporting period; and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation. 5 CCR 1001-2 §§ il.A.. 11.13.. II.C'.. II.E.. III .. 11.1. and I].J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving State. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 b. Emission Monitoring Requirements AFCO Steel, LLC Greeley Plant Page 27 The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined using the arithmetic mean of the results of the two other runs. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 28 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided, or planned for, and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 e. Circumvention Clause AFC() Steel, LLC Greeley Plant Page 29 A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications g. For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement, the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief Operating Permit 99OPWE213 First issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 30 The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess_ emissions_ have the potential_ to_cause_ an_exceedance.of_the_ambient -air _quality _ standards _orP_revention_of Significant Deterioration (PSD) increments. In making any determination whether a source established an affirmative defense, the Division shall consider the information within the notification required above and any other information the Division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. $. 5 CCR 1001-y, Part C. §§ Ill C.9. V,C 11. & 16.d. and 25-7-122.1(31. CRS. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination, revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and Xi. of Regulation No. 3, Part C. d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e, Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division, progress reports which contain the following: (i) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities, milestones, or compliance were achieved; and i) an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 g. AFC() Steel, LLC Greeley Plant Page 3I The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No. 3. 5 CCR 1001-5. Part C. 5 VILE: An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s) of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10, Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No, 8, Part B, "asbestos control." 7. Emissions Trading, Marketable Permits, Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C. V.CJ3. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S 88 25-7-I I4. i(6) and 25-7-1 14.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 32 c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. I. 5 CCR 1001-3. *' 111.D.I, The penmittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. I, § 111.D.1. 10. Inspection and Entry Rem:Wien No. 3. 5 CCR 1001-5. Part C. V.C.IG.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C. 4S X. & XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 C'CR 1001-5, Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No. 3, Part B, without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3. 5 CClt 1001-5. Pan C. $ V.C. I I.d. This permit does not convey any property rights of any sort, or any exclusive privilege. 14. Odor Regulation No. 2. 5 CCR 1001-4, Pan A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 15. Off -Permit Changes to the Source AFC() Steel, LLC Greeley Plant Page 33 Rcetdation No. 3. 5 CCR 1001-5, Pan C, . XI].B. The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- H. 17. Open Burning Regulation No. 9.5 CCR 1001-I1 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15. 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections 1., 11.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No. 3. 5 CCR 1001-5, Part C. §§ BIB 6.. fV.C.. V.C.2. a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No. 3. 5 CCR 1001-5, Part C, S I I.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No. 3. 5 CCR 1001-5, Part C. S V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 34 a. Any definition of"prompt" or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit; or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall he made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements, the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone (303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must specify that this notification is a deviation report for an Operating Permit.] A written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6 - month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No. 3.5 CCR 1001-5. Part A. 6 II.; Part C. 66 V.C.6.. V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following information: (1) date, place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s) on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis; and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application. Support information, for this purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 35 d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering any facility, process, activity which constitutes a stationary source from which air pollutants are or arc to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, § II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a request for permit revision. APENs for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No. 3. s CCR 1001-5. Part C. § XIII. a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § ITT., except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years, unless the effective date of the requirements is later than the date on which the permit expires, or unless a general permit is obtained to address the new requirements; whenever additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program; whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(b)(10) Changes Regulation No_ 3 5 CCR 1001-5, Part C, § XII.A. The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 25. Severability Clause AFC() Steel, LLC Greeley Plant Page 36 Regulation No. 3, 5 CCR 1001-5. Part C. $ V.C'.10. In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, - -record-keeping-and-reporting requirements-ofthe-permit-except those being -challenged; -remain -valid -and -enforceable _ - 26. Significant Permit Modifications Regulation No. 3. 5 CCR 1001-5, Part C. y 111.13.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements) without first receiving a construction permit. the permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation, to the address listed in Item I in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No. 3, 5 CUR 1001-5, Part C. 11 V.C. I -b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3, 5 CUR 1001-5, Part C. §1l.(7. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7. 5 CCR 1001-9.1.1$ Ill & V. The requirements in paragraphs a, h and e apply to sources located in an ozone non -attainment area or the Denver 1 -hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated, or used for necessary and proper activities (e.g. maintenance). Such opening, actuation, or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section VTII.C.3. b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 37 transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology (RACT) is utilized. d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored in open containers, or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No 4.5 CCR r00i-6 The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 38 OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - REPORTING REQUIREMENTS AND DEFINITIONS C - COMPLIANCE CERTIFICATION REPORTS D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - OPERATING PLAN H - COMPLIANCE ASSURANCE MONITORING PLAN *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise provided in the permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page: 39 APPENDIX A - Inspection Information 1. Directions to Plant: From Denver, follow the Highway 85 by-pass around the east side of Greeley. Immediately after Highway 85 by-pass rejoins Highway 85 business route, turn right on "O Street East." Go —0.25 miles on O Street East and turn left on County road 39 'h. The plant is at the end of County Road 39 'z on the left. 2. Safety Equipment Required: Eye Protection; Safety Shoes; Hearing Protection; Hard Hat 3. Facility Plot Plan: Figure 1 and Figure 2 (following pages) show the facility location and plot plan as submitted with the Title V Operating Permit renewal application. 4. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. Insignificant activities and/or sources of emissions as submitted in the application are as follows: The asterisk (V denotes an insignificant activity source category based on the size of the activity, emissions levels from the activity or the production rate of the activity. The owner or operator of individual emission points in insignificant activity source categories marked with an asterisk (*) must maintain sufficient record keeping verging that the exemption applies. Such records shall be made available for Division review upon request (Colorado Regulation No. 3, Part C, Section HE). • *Sand blasting of steel components using Starblast media. Note that this exemption only applies to emissions requirements and does not exempt the Source from the requirements in Section II, Condition 3. • *Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). • Welding activities that use lead (Pb) compounds. Note that this exemption only applies to emissions requirements and does not exempt the Source from the requirements in Section II, Condition 3. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 40 • *Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). • *Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. • *Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). • *Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. • Storage of butane, propane, or liquefied petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. • Storage tanks of capacity < 40,000 gallons of lubricating oils. • *Fuel storage and dispensing equipment in ozone attainment areas operated solely for company - owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. • *Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1D, 2D, or 4 D; (B) fuel oils #1 through #6; (C) gas turbine fuels 1GT through 4GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA). • Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. • Stationary Internal Combustion Engines which: Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit /1 99OPWE213 AFC() Steel, LLC Greeley Plant Page 41 (i) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii) have actual emissions less than five tons per year or rated horsepower of less than 50. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 42 • • • FIGURE 1 COLORADO Quw WrGL( LOCATIONII! Greeley Quadrangle USGS 7.5 Minute Series (Topographic), 1980 II'rn; ≤�i(:+_ ;his. Scale: 1:24,000 (1" = 2,000') Site Location Map Platte River Steel Company, Inc. Greeley, Colorado SORENSEN Prepared by: Date: ENVIRONMENTAL PCS 6-22-95 Project No. S002-01 2 Figure 1 — Site Location Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 43 Figure 2 — Plot Plan Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 Appendix B Reporting Requirements and Definitions with codes ver 8/20/14 AFCO Steel, LLC Greeley Plant Page 44 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report #2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 45 permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern; for example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred (only if the emission point is subject to CAM). For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8 = CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 46 Report #3: Compliance Certification (annually, as defined in the permit) -Submission of compliance -certifications with terms andconditionsin the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred (only for emission points subject to CAM). Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification may be referenced in the compliance certification. For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 Startup, Shutdown, Malfunctions and Emergencies, AFCO Steel, LLC Greeley Plant Page 47 Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. With regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they arc properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology -based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit 99OPWE213 First Tssued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 APPENDIX B: Monitoring and Permit Deviation Report - Part I AFCO Steel, LLC Greeley Plant Page 48 1: -Following is the required -format for the Monitoring and Permit Deviation report to be submitted -to -the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part 11 Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: AFCO Steel LLC. OPERATING PERMIT NO: 99OPWE312 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Operating Permit Unit TD Unit Description Deviations noted During Period?i Deviation Code 2 MalfunetiuwJEmer geney Condition Reported During Period? YES NO YES NO 5001 Protective coating and associated cleaning activities. S002 Structural steel descaling system — Wheelabrator, steel shot, 8 wheels, serial number A140383 General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries, as appropriate 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8=CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 APPENDIX B: Monitoring and Permit Deviation Report - Part II FACILITY NAME: AFCO Steel LLC. OPERATING PERMIT NO: 99OPWE312 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup _ Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/i:mergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE AFCO Steel, LLC Greeley Plant Page 49 Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 50 EXAMPLE FACILITY NAME: U.S.S. Enterprise OPERATING PERMIT NO: 64OPZZXXX REPORTING PERIOD: 1/1/2369 - 6/30/2369 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown _ Malfunction X Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Holodeck generator with nanobot-repaired filtration system — Unit TNG Operatinz Permit Condition Number Citation Section 11, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Tribbles in the console Duration START- 1730 4/10/2369 END- 1 800 4/10/2369 Action Taken to Correct the Problem Transported Tribbles to Klingon vessel. Measures Taken to Prevent Reoccurrence of the Problem Permanent ban of Tribbles as pets. Increased structural integrity of console. Dates of Malfunction/Emergencies Reported (if applicable) 5/30/2369 to J.L. Picard, APCD Deviation Code Division Code QA: Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit /4 99OPWE213 AFCO Steel, LLC Greeley Plant Page 51 APPENDIX B: Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: AFCO Steel LLC. FACILITY IDENTIFICATION NUMBER: 123-0488 PERMIT NUMBER: 99OPWE213 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section LB. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 APPENDIX C Required Format for Annual Compliance Certification Reports AFCO Steel, LLC Greeley Plant Page 52 Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: AFCO Steel LLC. OPERATING PERMIT NO: 99OPWE213 REPORTING PERIOD: 1. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. _ With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating p g Permit Unit ID Unit Description Deviations Reported I Monitoring Method per Permit?2 Was compliance continuous or intermittent?3 Previous Current YES NO Continuous Intermittent S001 Protective coating and associated cleaning activities. S002 Structural steel descaling system — Wheelabrator, steel shot, 8 wheels, serial number A140383 General Conditions Insignificant Activities If deviations were noted in a previous deviation report , put an "X" under "previous.' if deviations were noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current." Mark both columns if both apply. 2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional information/explanation. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 53 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non-compliance, then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. Compliance status for these sources shall be based on a reasonable inquiry using readily available information. 11. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). I . A Risk Management Plan _ will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix ID of this Permit. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 502(b)(10) Changes, Off Permit Changes: Office of Partnerships and Regulatory Assistance Mail Code 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 AFC() Steel, LLC Greeley Plant Page 54 Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 55 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP -42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act (CAAA = Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet (SCF = Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate in MMBtu/hr FR - Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP -HR - Horsepower Hour (G/HP-HR = Grams per Horsepower Hour) LAER - Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf - Million Standard Cubic Feet MMscfd - Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter PMlo - Particulate Matter Under 10 Microns Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 56 PSD - PTE - RACT - SCC - SCF - SIC - SO2 - TPY - TSP - VOC- Prevention of Significant Deterioration Potential To Emit Reasonably Available Control Technology Source Classification Code Standard Cubic Feet Standard Industrial Classification Sulfur Dioxide Tons Per Year Total Suspended Particulate Volatile Organic Compounds Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFC() Steel, LLC Greeley Plant Page 57 APPENDIX F Permit Modifications DATE OF REVISION TYPE OF REVISION SECTION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 58 APPENDIX G Operating Plan The following methods are proposed to demonstrate compliance with the permit conditions, included in Platte River Steel Company's (now AFCO Steel, LLC) permit application for March 1999. These methods are required under Colorado Regulation No. 3, Part IV.B.2. (I) The requirement for proper operation and maintenance will apply to the Wheelabrator Blast Unit. AFCO Steel, LLC will operate the Blast Unit only if the dust collection system is fully operational. If a plume is observed from this unit, AFCO Steel, LLC will cease operations of the unit and make repairs or provide maintenance prior to restarting the Unit. (2) Recordkeeping will include collecting data for all paints and solvents used at the facility. Records will include data sheets showing the fraction of VOCs in each item, the HAP content of each item, and the amount used on a monthly basis. The Safety Data Sheets supplied by vendors will be used to obtain these data. A spreadsheet system will be used to calculate emissions of VOCs and HAPs from the use of these materials. Records will be tabulated on a monthly basis and will be available for inspection on site. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 APPENDIX H Compliance Assurance Monitoring Plan Background a. Emission Unit Description: Shot Blast System b. Applicable Regulation. Emission Limit. Monitorin_ Requirements: Regulations: Emission Limitations: c. Control Technolony: Operating Permit Section 11, Condition 2 PM & PMio: 1.3 tons/yr Opacity: 20% Cyclone and cartridge filter system with 99% control efficiency. Uncontrolled emissions = 130 tons/yr. II. Monitoring Approach AFCO Steel, LLC Greeley Plant Page 59 Indicator No. 1 Indicator No. 2 1. Indicator Measurement Approach Visible Emissions (VE) from the Control Device Exhaust Stack Pressure Drop Across the Control Device Trained observer using Visual Emissions (VE) observation per EPA Reference Method 22 requirements. Observation shall be taken during routine operating conditions using a 6 -minute VE — no VE check. Differential pressure gauges or manometers. Readings shall be taken during routine operating conditions. Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 99OPWE213 AFCO Steel, LLC Greeley Plant Page 60 Indicator No. 1 Indicator No. 2 IT. Indicator Range An excursion is defined as the presence of visible emissions. Excursions trigger the permittee to investigate the shot blast system and control equipment performance within 24 hours of discovery and make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded in a log, to be made available to the Division upon request. The indicator range is a pressure drop between 1 and 6 inches 142O. An excursion is defined as any measurement outside the range specified above. Excursions trigger the permittee to investigate the shot blast system and control equipment performance within 24 hours of discovery and make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded in a log, to be made available to the Division upon request. QIP Threshold Five excursions in a 6 -month reporting period. None selected. TH. Performance Criteria a. Data Representativeness Visual observation taken at the control device exhaust stack per EPA Reference Method 22. Gauges shall be installed to measure pressure at the control device inlet and outlet. The gauge shall have a minimum accuracy of 0.25 in. 142O. b. Verification of Operational Status N/A. Gauge shall be installed and calibrated per manufacturer's recommendations. c. QA/QC Practices/Criteria Initial training of observer(s) on Reference Method 22, visible emissions, and control device operation. Calibrate, maintain and operate instrumentation using procedures that take into account the manufacturer's recommendations. d. Monitoring Frequency 6 -minute VE observation daily when in operation. Pressure drop measurement taken weekly when in operation and manually recorded. 1. Data Collection Procedures Record the time and date of each visible emission observation, and whether or not any visible emissions were observed. Pressure drop noted in log -book, and whether the reading was within the indicator range specified above. c. Averaging Time N/A N/A Operating Permit 99OPWE213 First Issued: February 1, 2000 Renewed: DRAFT TECHNICAL REVIEW DOCUMENT For RENEWAL OF OPERATING PERMIT 99OPWE213 AFCO Steel, LLC — Greeley Plant Weld County Source ID 123/0488 January 2016 — Date Operating Permit Engineer: Operating Permit Supervisor review: Field Services Unit review: I. Purpose Nicholas Dummer Matt Burgett Jeffery Bishop This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan, and compliance status of emission units covered by the renewed Operating Permit for the AFCO Steel LLC. Greeley Plant facility (herein referred to as the Source). The original Operating Permit for the Source was issued on February 1, 2000; it was renewed on October 1, 2008; it was last revised on June 10, 2013; it expired on October 30, 2013. However, since a timely and complete renewal application was submitted, under Colorado Regulation 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield shall continue in full force and operation. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the original construction permit (95WE890), previously issued operating permits, comments on the draft permit submitted on [date], previous inspection reports and various email correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at www.colorado.aov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Colorado Regulation 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction and operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit provided no change in operations occur as described in this permit. 123/0488 Page 1 of 9 AFCO Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document — Revision 2 II. Description of Source AFCO Steel, LLC (Source) purchases rolled steel plate and shapes and fabricates them into components for bridges, buildings, and similar structures. The production operations involve sawing, shearing, flame cutting, hole -punching and drilling, and fitting and joining components together into a finished product by bolting or welding. The metal may be cleaned with steel shot blast and / or the application of a solvent. The shot blast cleaning unit is equipped with a particulate emissions control device. The Source also provides metal coating based on customer requests; these coatings may include a primer, paint, and other protective coatings. The coating operations are performed inside a large, open bay, primarily with spray devices. Due to the size of the steel components, traditional spray -paint booth style operations are prohibitively expensive. Coating overspray accumulates on the coating bay floor. Various solvents, primarily acetone, are used for cleaning the coating equipment. Thinning compounds may be used for the paint coatings. Large fans are used to provide ventilation. The facility is located in Weld County at 31455 Weld County Road 39 1/2, Greeley, Colorado 80631. This area is classified as non -attainment for ozone (O3) and is part of Colorado's 8 -hour Ozone Control Area as defined in Colorado Regulation No. 7, Section II.A.1.b. The area is also classified as an attainment / maintenance area for carbon monoxide (CO). Under that classification, all State Implementation Plan (SIP) approved CO requirements will continue to apply to prevent backsliding under the provisions of Section 110(1) of the Federal Clean Air Act (CAA); however, the Source emits a negligible amount of CO and there are no permitted conditions related to its emission. The Source has pre -controlled emissions of TSP and PM10 above the major source threshold, but uses a control device to reduce emissions below the threshold. The Source also employs a federally -enforceable restriction on material throughput in the facility to remain below major source thresholds for VOC and HAP; therefore the Source is classified as a synthetic minor stationary source for both non -attainment new source review (NANSR) and prevention of significant deterioration (PSD) as of the date of the issuance of this permit. The Source has elected to operate with an Operating Permit to ensure that they are working under a federally enforceable HAP limit to avoid classification as a major source of HAP. The cancellation of this permit and the issuance of a new construction permit was discussed with the Source, but they have elected to continue to retain a Title V permit for the facility. 123/0488 Page 2 of 9 AFCO Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document — Revision 2 The emission units at the facility are as follows (from Construction Permit 95WE890) Facility ID AIRS ID Description Pollution Control S001 001 Protective spray coating of structural steel components and associated cleaning, performed in a large, enclosed bay. N/A S002 002 Shot blast descaling of structural steel via stationary machinery: Wheelabrator with steel shot and 8 wheels, serial number: A140383 US Filter / Wheelabrator cyclone and size 45Sys model 36 cartridge filter system, serial number: A140533 Emissions in tons per year at the facility are as follows: Parameter Permit Condition (Section II) Yearly Limitation in Tons per Year (tpy) — S001, S002 Actual Emissions (tpy) — S00I, S002 TSP 1.1, 2.2 6.1, 1.3 3.12, 0.99 PIV110 1.1, 2.2 6.1, 1.3 3.12, 0.99 VOC 1.1 72.4, N/A 11.5, N/A HAP 1.1 N/A 8.0 (single HAP) & 20.0 (total facility HAP), 3.94 (single) & 7.20 (total), N/A Opacity 1.2, 2.4, 2.5 20%, 20% (30% in specific circumstances) No exceedances Actual emissions are based on the most recent inspection, performed on January 19, 2016 Note: There are no PM2.5 limits associated with the Operating Permit as the initial issuance of the permit pre -dates the EPA's designation of PM2.5 as a criteria pollutant. Ill. Applicable Requirements Accidental Release Program — 112(r) Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical accidents. Sources subject to these provisions must develop and implement risk management programs that include hazard assessment, a prevention program, and an emergency response program. They must prepare and implement a Risk Management Plan (RMP) as specified in the Rule Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). Compliance Assurance Monitoring (CAM) The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control 123/0488 Page 3 of 9 AFCO Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document — Revision 2 emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV: Shot blast descaling of steel components and associated particulate control device; AIRS point 002 (emission unit S002) for TSP and PMio. Hazardous Air Pollutants (HAPs) This facility is designated as a synthetic minor for HAP emissions. HAP emissions originate from the surface coating operation and are accounted for by a rolling total 12 - month calculation based on the HAP content of the coating. 40 CFR Part 63, Subpart XXXXXX — National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source The Source is subject to 40 CFR Part 63, Subpart XXXXXX requirements due to metal fabrication hazardous air pollutant (MFHAP) emissions. Subpart XXXXXX has applicable requirements for dry abrasive blasting, spray painting, machining, welding, and dry grinding and polishing with machines; these categories are analyzed as follows to determine whether operations at the Source are applicable sources under the Subpart: 1. Dry abrasive blasting is an affected unit under Subpart XXXXXX due to: a. Steel shot used in the blasting process contains manganese (Mn) and Chromium (Cr) in excess of MFHAP material containing thresholds; b. The blasted steel contains Cr, Mn, and Nickel (Ni) in concentrations in excess of material containing MFHAP thresholds; c. Abrasive sand used in the blasting process does not contain MFHAP; however, since it is used on the blasted steel as outlined in 1.b. above, sand blasting is an affected unit. 2. Spray painting is not an affected unit under Subpart XXXXXX because the coatings do not contain target MFHAP compounds above the MFHAP containing compound limits as defined in the Subpart. Recordkeeping requirements to prove compliance with these limits and those in Subpart HHHHHH are outlined in the Operating Permit, Section II, Condition 1.1. 3. Machining is an affected unit as described in Subpart XXXXXX as the steel machined at the facility contains Cr, Mn, and Ni in concentrations exceeding the material containing MFHAP threshold. 4. Welding is an affected unit as described in Subpart XXXXXX as the welding wires frequently used at the facility contain Cadmium (Cd), Cr, Mn, and Ni in concentrations in excess of the material containing MFHAP thresholds. 5. Dry grinding and polishing with machines is not an affected unit under Subpart XXXXXX as dry grinding and polishing are only performed using hand-held machines and not stationary machines. 123/0488 Page 4 of 9 AFCO Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document — Revision 2 Section II, Condition 3 was added to address the applicable requirements related to 40 CFR Part 63, Subpart XXXXXX. Requirements were added for dry abrasive blasting which include work practices to reduce MFHAP, operating the control devices per manufacturer's instructions, and visibility monitoring. Note that the Source may elect to comply with Conditions 3.1.2.1 or 3.1.2.2 as appropriate. Standards for machining include work practices to reduce MFHAP, operating all equipment associated with machining per manufacturer's instructions, and visibility monitoring. Standards for welding include operating all associated equipment per manufacturer's instructions, the implementation of work practices, and visibility monitoring. A site specific welding emissions management plan is also required. Requisite recordkeeping and reporting is also included in Condition 3. 40 CFR Part 63, Subpart MMMM — National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products The Source is not subject to Subpart MMMM as this Subpart only applies to stationary sources that are major sources of HAP. 40 CFR Part 63, Subpart HHHHHH — National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources The Source is not subject to Subpart HHHHHH as this subpart only applies to sources which use spray coatings with target HAP containing compounds above specified limits. However, despite the Source not being subject to Subpart HHHHHH, the Source has requested that they be allowed to use coatings containing target HAP compounds below the limits described in the Subpart. Recordkeeping requirements that prove compliance with these limits are discussed in the Operating Permit, Section II, Condition 1.1. There is a narrow band in the calculation of applicability between NESHAP XXXXXX and HHHHHH that would include the Source in HHHHHH but not XXXXXX; however, if the Source were to trigger the requirements of XXXXXX, compliance with those requirements would satisfy the requirements of HHHHHH per 40 CFR Part 63, §63.11514(b)(4). Greenhouse Gases The potential -to -emit of greenhouse gas (GHG) emissions from this facility is less than 100,000 TPY CO2e. Future modifications greater than 100,000 TPY CO2e may be subject to regulation (Colorado Regulation No. 3, Part A, l.B.44). IV. Modifications Requested by the Source Following the receipt of the renewal application, based on discussions with facility contacts on January 19-20, 2016, it was requested that the permit be modified to allow for the use of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), and cadmium (Cd) — collectively referred to as "target HAP compounds" in 40 CFR Part 63, Subpart HHHHHH, and "metal fabrication HAP [MFHAP] containing compounds" in 40 CFR Part 63, Subpart XXXXXX — in surface coating operations; however, the use of these surface coatings would be below the definition of "HAP -containing materials" as described in the 123/0488 Page 5 of 9 AFCO Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document — Revision 2 Subparts so the Source would not be classified as an affected source under Subpart HHHHHH or the spray painting conditions of Subpart XXXXXX (the Source has other affected units under Subpart XXXXXX). It was discussed with the Source that the State of Colorado Department of Public Health and the Environment (CDPHE) Air Pollution Control Division (APCD) would require sufficient proof that surface coatings contained target HAP compounds below Subpart HHHHHH and XXXXXX thresholds. These details are outlined in Section II, Condition 1.1 of the Operating Permit. In the renewal application, received by the Division on September 28, 2012, the Source requested that sand blasting and welding be added as insignificant activities in the Operating Permit. This request was accepted based on the list of allowable insignificant activities in Colorado Regulation No. 3, Section C, H.E; however, both sand blasting and welding are affected units under Subpart XXXXXX and thus are subject to the requirements in the Operating Permit Section II, Condition 3. The insignificant designation only applies to the sand blasting and welding units as it relates to their contribution to facility -wide emissions limitations. These units were added to the insignificant activities list in Appendix A of the Operating Permit. In the renewal application, the Source also requested that Subpart XXXXXX applicable requirements be added to the Operating Permit. The Source has submitted notices of startup and of compliance status to the EPA as required under the Subpart. Section II, Condition 3 of the Operating Permit addresses Subpart XXXXXX. The source's requested modifications were addressed as follows: Section II — Specific Permit Terms • Condition 1: S001 — Cd, Cr, Ni, Mg, and Pb to be allowed for use in spray - coatings under the thresholds in Subparts HHHHHH & XXXXXX. • Condition 2: S002 - Subpart XXXXXX applicability added. • Condition 3 was added to address applicable requirements related to Subpart XXXXXX affected units at the facility. Appendices • Appendix A insignificant activities list was updated to include welding and sand blasting. V. Other Modifications In addition to the source requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. These changes are as follows: Page Following Cover Page 123/0488 Page 6 of 9 AFC() Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document —Revision 2 • It should be noted that the monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the source may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I — General Activities and Summary • Revised the language in Condition 1.4 include current conditions that are state - only enforceable. • Updated the Source description in Condition 1.1. The Source description was updated after discussions with the Source and a tour of the facility. There are no major changes to the operations; however, solvents were erroneously listed for cleaning metal components when the main use of solvents is for paint thinning and for spray -gun cleaning. Section I I — Specific Permit Terms • Condition 1: S001 — Protecting Spray Coating of Structural Steel Components and Associated Cleaning Activities o Requirements for the allowable use of Cr, Cd, Pb, Ni, and Mg in surface coatings added to Condition 1.1. • It was determined that the modification to the permit by allowing the use of Target HAP as described in Subparts HHHHHH and XXXXXX constituted a minor modification. As such, it was investigated whether RACT was triggered as a result. It was determined that since there was no increase in total VOC emissions, the change would not trigger RACT requirements in Regulation No. 3, Part B, Section III.D.2. o Condition 1.2 and the table entry were updated to clarify the opacity requirements, per Source comment. So long as material coatings that are permitted for use under the rest of the condition are used, the Source is assumed to be in compliance with the opacity standard. This was originally discussed in the 1999 TRD for the first issuance of the permit wherein it was assumed that spray -coatings from this facility would not require ongoing opacity monitoring, but compliance would be assumed provided that the appropriate materials were used for the coating operation. o Regulation No. 7 requirements added in Condition 1.3. • The Source is an affected source under Regulation No. 7, IX.L due to its location in the 8 -hour ozone non -attainment area and its 123/0488 Page 7 of 9 AFCO Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document — Revision 2 use of surface coatings for metal components. Condition 1.3 was added to the permit to reflect the applicable requirements associated with this Regulation. • The Source is exempt from RACT requirements under Regulation No. 7, II.C.1.a.(iii) as it is not major for VOC emissions due to the federally enforceable permit conditions contained in the operating permit which limit the VOC emissions below 100 tpy. • The Source requested that they be permitted to use their own recordkeeping as an alternative to the recordkeeping requirements in Condition 1.3.4. This request was granted on the condition that they prove that their recordkeeping system sufficiently demonstrates that the requirements in Condition 1.3.4 are satisfied. • Condition 2: S002 - Shot Blast System o The shot blast system is an affected source under Subpart XXXXXX because the Source is primarily engaged in fabricated structural manufacturing and performs dry abrasive blasting with steel shot that contains Mn and Cr in concentrations that classify the media as metal fabrication HAP (MFHAP) containing as defined in the rule. Additionally, the steel being blasted contains Cd, Pb, and Ni. Condition 2.2 has been updated to address compliance with the Subpart. Requirements include capturing emissions and venting them to a control device operated according to manufacturer's recommendations, work practices associated with minimizing MFHAP emissions, and visibility monitoring. o Fixed a reference error from C.R.S. 15-7-123 to 25-7-123.1 in Section 2.4 • Condition 3: Subpart XXXXXX applicable requirements added due to machining, welding, and dry abrasive blasting being affected sources under this Subpart. o Monitoring requirements for Subpart XXXXXX are stricter for welding than for other affected units. The Source performs multiple operations that are affected units under the Subpart in the same bay. This makes the EPA Method 22 and 9 testing challenging for purposes of determining which affected unit was responsible for the emissions. It was determined that in the absence of evidence, all affected units would be considered to be the cause of the emission since cumulative effects from multiple units are more impactful than from any single unit. Condition 3.1.5.2 addresses this concern. Appendices 123/0488 Page 8 of 9 AFCO Steel, LLC. Operating Permit No. 99OPWE213 Technical Review Document — Revision 2 • Sand blasting was added to the insignificant activities list. Approximately twelve (12) tons per year of sand blasting media are used adding —650 lb of fugitive PM, based on emissions factors from AP -42, Table 13.2.6-1. 123/0488 Page 9 of 9 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 99OPWE213 APPLICANT: AFCO Steel, LLC. REVIEW ENGINEER: Nicholas Dummer AIRS ID #: 123/0488 DATE: July 12, 2016 SOURCE DESCRIPTION AFCO Steel, LLC. has applied for renewal of their Operating Permit issued for the Greeley Plant located at 31455 Weld County Road 39 1/2, Greeley, Weld County, Colorado. The facility consists of structural steel fabrication and surface coating operations which includes various machining, welding, abrasive blasting, cutting, punching, and fitting and joining steel components together; this operation falls under SIC 3441. The area in which the plant operates is designated as non -attainment for ozone and attainment/maintenance for carbon monoxide. This source is categorized as a synthetic minor stationary source with respect to Prevention of Significant Deterioration (PSD) requirements. Wyoming is an affected state within 50 miles of this facility. Rocky Mountain National Park and is a Federal Class I designated area within 100 km of this facility. The emission units covered under this permit are not subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. The shot blasting of steel components is equipped with a dust collection system for total suspended particulates and particulate matter less than 10 microns in diameter and is subject to the Compliance Assurance Monitoring (CAM) requirements under 40 CFR Part 64. FACILITY EMISSION SUMMARY TSP PM10 Potential to Emit (tons/year) VOC Single HAP Total I-lAP Surface coating and associated cleaning activities — S001 6.1 6.1 72.4 8 20 Shot blasting of steel components — S002 1.3 1.3 N/A N/A N/A Total Facility Emissions 7.4 7.4 72.4 8 20 EMISSION SOURCES The following discussion identifies the changes that were made in the renewal permit. 40 CFR Part 63, Subpart XXXXXX — National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source requirements were added to the permit. These requirements include monitoring and recordkeeping requirements for shot blasting, welding, and machining of steel parts. Colorado Regulation No. 7 requirements were added to the surface coating activities at the facility. This includes limitations on the VOC content of surface coatings and additional recordkeeping requirements. INSIGNIFICANT ACTIVITIES No changes were made to the list of insignificant activities. PERMIT SHIELD No changes were made to the permit shield. A=COM Environment Prepared for: AFCO Steel, Inc. Greeley, Colorado AFCO Steel, LLC Title V Operating Permit Renewal Application Prepared By Christopher Driscoll riF yiez ,ei ty Reviewed By Loni Gaudet Submitted by: AECOM Fort Collins, Colorado September 2012 2047 AECOM Environment Contents 1.0 Introduction 1 2.0 General Applicant Information1 3.0 Proposed Changes Included in this Application2 4.0 Emission Calculation Basis 2 4.1 Protective Coating Activities 2 4.2 Structural Steel Descaling 3 4.2.1 Wheelabrator 3 4.2.2 Indoor Abrasive Blasting 3 4.3 Welding Activities 3 5.0 Regulatory Review of National Emissions Standards for Hazardous Air Pollutants 3 5.1 Subpart MMMM 3 5.2 Subpart HHHHHH 4 5.3 Subpart XXXXXX 4 5.3.1 Dry Abrasive Blasting 4 5.3.2 Spray Painting 5 5.3.3 Machining 5 5.3.4 Welding 5 5.3.5 Dry Grinding and Dry Polishing with Machines 6 6.0 Other Attachments 6 List of Attachments Attachment A - CDPHE Air Pollution Emission Notice Forms Attachment B - CDPHE Application Forms Attachment C - Emission Calculations SEP26' iia September 2012 AECOM 1.0 Introduction Environment 1 AFCO Steel, LLC (AFCO) purchases rolled steel plate and shapes, and fabricates bridges, buildings, and other structures (SICC 3441). The Greeley, Colorado, facility purchases steel plate which is fabricated and primed or coated according to customer specification. Prior to coating, the metal may be prepared by cleaning with a steel shot blast, application of a solvent, or both. Coating is performed primarily indoors in large open bays. The large size of the components prohibits the use of a conventional spray booth. Coating overspray accumulates on the floor of the coating building. Large fans are used to provide ventilation during the cleaning and coating operations. Acetone is the primary solvent used to prepare the steel prior to coating and to clean the coating application equipment. Abrasive cleaning/descaling of steel is mainly performed in an enclosed "Wheelabrator," which uses steel shot/grit. The shot/grit is recovered and reused, and emissions from this operation are controlled using a cartridge filter. Occasionally, an imperfection in the descaling or coating operation requires a section of steel to be reworked. In these cases, abrasive blasting with Starblast is performed indoors. AFCO operates under Colorado Operating Permit 99OPWE213 issued by the Colorado Department of Public Health and Environment (CDPHE) on February 1, 2000, and renewed on October 1, 2008. Under Regulation No. 3, 5 CCR 1001-5, Part C, § Ill B. 6., IV.C., V.C.2., the permit remains valid for 5 years from its issuance or renewal data and expires at the end of its term. All renewal applications must be submitted to the CDPHE at least 12 months prior to the expiration of the Operating Permit. The contents of this document address all those portions of the permit requiring revision and supplementation for permit renewal. This document also includes updated Air Pollution Emission Notice (APEN) forms for both emission unit S001 and 5002. While the APENs for these units are valid until April 18, 2013, updated APENs are included in this submittal. 2.0 General Applicant Information Listed below are the applicant's points of contact for this project, and the addresses and telephone numbers where they may be reached. Project Site: Applicant Contacts: AFCO Steel, LLC 31455 Weld County Road 39 V2 Greeley, Colorado 80631 Weld County Joe Honesto AFCO Steel, LLC, Plant Manager 31455 Weld County Road 39 1/4 Greeley, Colorado 80631 (970) 356-2326 Christopher Driscoll AECOM 1601 Prospect Parkway Fort Collins, Colorado 80525 (970) 530-3463 FAX: (970) 493-0213 September 2012 AECOM Environment 2 3.0 Proposed Changes Included in this Application Operations at the AFCO facility have experienced only minimal changes since the 2008 renewal of Colorado Operating Permit 99OPWE213. Therefore, this application is for a minor modification and renewal of the Title V permit. In addition to the existing Descaling/Wheelabrator and Coating/Cleaning Operations, AFCO requests the addition of two insignificant emission units (IEUs): 1) indoor abrasive blasting; and 2) welding activities. These operations are exempt from the requirement to file for an APEN because annual emissions do not meet the threshold emission standards listed in Regulation 3, II.B.3.a. In addition, welding activities are not required to have an APEN filed per Regulation 3, II.D.1.r. AFCO requests to add these emission units to the Title V permit because they are affected facilities under 40 Code of Federal Regulations (CFR), Part 63, Subpart XXXXXX — Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. This National Emission Standard for Hazardous Air Pollutants (NESHAP) regulates hazardous air pollutant (HAP) emissions from metal fabrication and finishing source categories (as defined in the Rule) located at area sources of HAP emissions such as AFCO. Applicable emission sources under Subpart XXXXXX are described in detail in Section 5.3. 4.0 Emission Calculation Basis General operations at AFCO consist of four distinct emission units, two of which are insignificant based on the emission thresholds listed in Regulation 3, II.B.3.a. These four emission units are described below and consist of protective coating activities, structural steel descaling, indoor abrasive blasting, and welding. 4.1 Protective Coating Activities Paint, thinner, and solvent emissions were calculated using material balances on each product, utilizing the manufacturer's data from the Material Safety Data Sheets (MSDS). One hundred percent of the volatile components of the paints, thinners, and solvents are assumed to evaporate, contributing to emissions of volatile organic compounds (VOC). Particulate emissions due to spray application of coatings were calculated based on the transfer efficiency of the spray guns (35 percent) and the control efficiency (90 percent) due to enclosure. Potential to emit (PTE) of each non -criteria reportable pollutant (in pounds per year) was evaluated for APEN reporting requirements against Scenario 1 de minimis levels according to Regulation No. 3, Appendix B (see Attachment C for calculation details). After conducting this analysis, there are three non -criteria reportable pollutants that exceeded their respective de minimis levels (xylene, ethyl benzene, and toluene). These pollutants are included on the non -criteria reportable pollutant APEN form located in Attachment A. Coatings applied by AFCO are dictated by client specification, therefore, paints, thinners, and solvents used at the site are subject to change with each contract. Historical records of usage were utilized to calculate actual emission estimates; however, due to the fact that that paints (and therefore thinners and cleaning solvents) used may change, and to allow for maximum operational flexibility, AFCO requests federally enforceable facility -wide emission limits of HAPs to designate the facility as a synthetic minor source pursuant to 40 CFR 63.2. AFCO proposes the following limits for emissions due to the use of paints and solvents in order to meet client specifications, September 2012 AECOM Environment 3 • Facility -wide HAP emissions shall not exceed 20.0 tons per year (tpy); and • Facility -wide emissions from any individual HAP will not exceed 8.0 tpy HAP indicates any non -criteria reportable pollutant regulated under Section 112(g) of the Clean Air Act or listed in Colorado Regulation 3, Part A, Appendix B. In order to demonstrate compliance with these limits, AFCO will maintain records of monthly coating, thinner, and solvent usage and will calculate rolling 12 -month emissions by the end of the new calendar month. This request does NOT represent a change from the existing permit conditions and limits. 4.2 Structural Steel Descaling All of the rolled steel plate AFCO receives must be descaled (cleaned) prior to the application of coatings. This descaling process is accomplished through dry abrasive blasting of the new metal surfaces using steel shot/grit in an enclosed Wheelabrator unit. Abrasive blasting using Starblast is performed on the occasion when a coating must be reapplied. 4.2.1 Wheelabrator The Wheelabrator uses steel shot/grit to descale new metal surfaces. The Wheelabrator is enclosed and uses a cartridge filter to control particulate matter emissions. Emissions from this unit are calculated based on the exhaust flow rate and the exhaust particulate loading of 0.02 gr/dscf, which is typical for cartridge filters. 4.2.2 Indoor Abrasive Blasting Indoor abrasive blasting is performed when corrective re -blasting of objects is required or when a client requires an object greater than 8 feet in any dimension to be descaled (objects of this size do not fit into the Wheelabrator). Indoor abrasive blasting is performed infrequently, and is classified as an IEU due to not exceeding the emission threshold under Regulation 3, ll.B.3.a. Emissions from this unit are estimated using AP -42 emission factors from Table 13.2.6-1 and a containment efficiency of 90% since blasting occurs indoors. 4.3 Welding Activities AFCO joins all descaled and coated components into a finished product by bolting or welding. Welding activities are classified as an IEU due to not exceeding threshold emissions under Regulation 3, II.B.3.a and are not required to have an APEN filed per Regulation 3, II.D.1.r. Emissions due to welding are estimated using emission factors from AP -42 Section 12.19. 5.0 Regulatory Review of National Emissions Standards for Hazardous Air Pollutants Three subparts of the 40 CFR, Pad 63, NESHAP are potentially applicable to operations at AFCO. These are Subpart MMMM— Surface Coating of Miscellaneous Metal Parts and Products, Subpart HHHHHH — Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, and Subpart XXXXXX— Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. 5.1 Subpart MMMM Subpart MMMM applies to metal coating operations of components and products using 250 gallons per year or more of coatings that contain HAPs and are located at a major source of HAPs. By designating AFCO a synthetic minor source of HAPs, Subpart MMMM is not applicable. September 2012 AECOM Environment 4 5.2 Subpart HHHHHH Subpart HHHHHH applies to area sources involved in any of the following activities: Paint stripping operations that involve the use of chemical strippers that contain methylene chloride (MeCI), Chemical Abstract Service number 75092, in paint removal processes; Autobody refinishing operations that encompass motor vehicle and mobile equipment spray - applied surface coating operations; and • Spray application of coatings containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd), collectively referred to as the target HAP to any part or product made of metal or plastic, or combinations of metal and plastic that are not motor vehicles or mobile equipment. AFCO fabricates structural steel components from new metal and does not have paint stripping operations that use McCI. Additionally, AFCO does not refinish auto bodies. A review of coatings used in the previous 3 years shows that none of the coatings contain Cr, Pb, Mn, Ni or Cd, and the use of coatings containing these compounds is not anticipated. AFCO will not use any coating containing Cr, Pb, Mn, Ni or Cd and proposes to review the MSDS of any customer -requested coating to ensure these contaminants of concern are not present. AFCO will maintain copies of all MSDS for coating products used for a minimum of 5 years. 5.3 Subpart XXXXXX Subpart XXXXXX applies to area sources that are primarily engaged (as defined in the Rule) in one of nine source categories listed in §63.11514(a) and which operate one of five affected sources listed in §63.11514(b), which uses materials that contain or have the potential to emit metal fabrication or finishing metal HAP (MFHAP), as defined in the Rule. Based on the source categories and affected sources listed in §63.11514(a) and §63.11614(b), respectively, the following operations were analyzed to determine whether they are affected sources under Subpart XXXXXX. 5.3.1 Dry Abrasive Blasting Dry abrasive blasting is the collection of all equipment and activities necessary to perform dry abrasive blasting operations, which use materials that contain MFHAP or that have the potential to emit MFHAP. Dry abrasive blasting is defined as: "Cleaning, polishing, conditioning, removing or preparing a surface by propelling a stream of abrasive material with compressed air against the surface. Hydroblasting, wet abrasive blasting, or other abrasive blasting operations which employ liquids to reduce emissions are not dry abrasive blasting." AFCO performs dry abrasive blasting of new metal surfaces using steel shot/grit and sand. A review of the MSDS for these abrasive materials and the new steel indicate that: 1. The steel shot/grit contain MN, Cr and Zinc (Zn) in amounts exceeding the material containing MFHAP threshold'; I Material containing MFHAP means a material containing one or more MFHAP. Any material that contains Cd, Cr, Pb, or Ni in amounts greater than or equal to 0.1 percent by weight (as the metal), and contains Mn in amounts greater than or equal to September2012 AECOM Environment 5 2. The new steel used at the stationary sources contain Cr, Mn and Ni in amounts exceeding the material containing MFHAP threshold; and 3. The abrasive sand does not contain any MFHAP; however, because it is used to blast the new steel, which does contain MFHAP, abrasive blasting with sand has the potential to emit MFHAP. Therefore, dry abrasive blasting performed by AFCO is an affected source subiect to Subpart XXXXXX. 5.3.2 Spray Painting Spray painting is the collection of all equipment and activities necessary to perform spray -applied painting operations using paints which contain MFHAP. A spray painting affected source includes all equipment used to apply cleaning materials to a substrate to prepare it for paint application (surface preparation) or to remove dried paint; to apply a paint to a substrate (paint application) and to dry or cure the paint after application; or to clean paint operation equipment (equipment cleaning). Affected source(s) subject to the requirements of Subpart XXXXXX are not subject to the miscellaneous surface coating provisions of 40 C.F.R. 63 Subpart HHHHHH, NESHAP: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. In Operating Permit 99OPWE213, AFCO is specifically prohibited from using coatings containing Pb, Cr, Ni, Mn, or Cd. Cleaning solvents do not have the potential to emit MFHAP. As long as AFCO complies with the prohibitions of permit 99OPWE213, spray painting performed by AFCO is NOT an affected source subject to Subpart XXXXXX. 5.3.3 Machining Machining is the collection of all equipment and activities necessary to perform machining operations, which use materials that contain MFHAP or that have the potential to emit MFHAP. Machining operations are defined as: "dry metal turning, milling, drilling, boring, tapping, planing, broaching, sawing, cutting, shaving, shearing, threading, reaming, shaping, slotting, hobbing, and chamfering with machines. Shearing operations cut materials into a desired shape and size, while forming operations bend or conform materials into specific shapes. Cutting and shearing operations include punching, piercing, blanking, cutoff, parting, shearing and trimming. Forming operations include bending, forming, extruding, drawing, rolling, spinning, coining, and forging the metal. Processes specifically excluded are hand-held devices and any process employing fluids for lubrication or cooling." AFCO performs machining of new steel using saws, punches, and other processes. As determined for the category of abrasive blasting, the new steel used at AFCO contains Cr, Mn, and Ni in amounts exceeding the material containing MFHAP threshold. Therefore, machining performed by AFCO is an affected source subject to Subpart XXXXXX2. 5.3.4 Welding Welding is the collection of all equipment and activities necessary to perform welding operations, which use materials that contain MFHAP or have the potential to emit MFHAP. 1.0 percent by weight (as the metal), as shown in formulation data provided by the manufacturer or supplier, such as the MSOS for the material, is considered to be a material containing MFHAP. ' While Machining may be an affected source, AFCO only performs dry grinding and dry polishing by hand, and there are no monitoring, recordkeeping, or reporting requirements for these processes. AFCO reviews operations regularly to ensure that machine dry grinding and dry polishing do not commence without a thorough review of 40 C.F.R. 11516(c), and communicates to staff that these operations are not allowed at the AFCO Greeley facility. September 2012 AECOM Environment 6 AFCO performs welding operations, and a review of the MSDS of a several welding wires commonly used by AFCO indicates that these wires contain Cd, Cr, Mn, and/or Ni in amounts exceeding the material containing MFHAP threshold. Therefore, welding performed by AFCO is an affected source subject to Subpart XXXXXX. 5.3.5 Dry Grinding and Dry Polishing with Machines Dry grinding and dry polishing with machines is the collection of all equipment and activities necessary to perform dry grinding and dry polishing with machines operations which use materials that contain MFHAP or have the potential to emit MFHAP. Dry grinding and dry polishing with machines is defined as: "grinding or polishing without the use of lubricating oils or fluids in fixed or stationary machines. Hand grinding, hand polishing, and bench top dry grinding and dry polishing are not included under this definition." AFCO only performs dry grinding and dry ootishinq by hand, and does not employ machines for these processes. Therefore, dry grinding and dry polishing performed by AFCO is NOT an affected source subject to Subpart XXXXXX. 6.0 Other Attachments This submittal includes the following CDPHE Air Pollution Emission Notice forms in Attachment A: • General Air Pollution Emission Notices (APENs) for Sources S001 and 5002 • Non -criteria Reportable APEN Addendum; and • APEN — Paint Spray Operations. This submittal also includes the following CDPHE application forms in Attachment B: • Form 2000-100, Facility Identification; • Form 2000-101, Facility Plot Plan; • Form 2000-102, 102A, and 102B, Source and Site Description; • Form 2000-200, Stack Identification; • Form 2000-305, Painting and Coating Operations; • Form 2000-306, Miscellaneous Processes; • Form 2000-407, Baghouses/Fabric Filters; • Form 2000-500, Compliance Certification — Monitoring and Reporting; • Form 2000-503, Control System Parameters or Operation Parameters of a Process; • Form 2000-504, Monitoring Maintenance Procedures; • Form 2000-507, Compliance Demonstration by Recordkeeping; • Form 2000-600, Emission Unit Hazardous Air Pollutants; • Form 2000-601, Emission Unit Criteria Air Pollutants • Form 2000-602, Plant -wide Hazardous Air Pollutants; • Form 2000-603, Facility Criteria Air Pollutants; • Form 2000-604, Applicable Requirements and Status of Emissions Unit; September 2012 AECOM Environment 7 • Form 2000-605, Permit Shield Protection Identification; • Form 2000-606, Emission Unit Compliance Plan — Commitments and Schedule; • Form 2000-700, Supplemental Information; and • Form 2000-800, Tabulation of Permit Application Forms. Supporting emission calculations including examples are included in Attachment C. Also included with this letter is the associated $305.80 APEN filing fee for the permit renewal. September 2012 AECOM Environment Attachment A CDPHE Air Pollution Emission Notice Forms General APENs for Sources S001 and S002 Non -criteria Reportable APEN Addendum APEN - Paint Spray Operations September 2012 A Application for Construction Permit — General AIR POLLUTANT EMISSION NOTICE (APE. co O Emission Source AIRS ID: 123 'o C a eth 3 ^-U V EE L C O- O. LL. C 7 F O 99OPWE213 uested Action (check applicable request boxes) Section 02 — R Section 01 — Administrative Information Request for NEW permit or newly reported emission source Request PORTABLE source permit Change company name V t s Transfer of ownership ❑ ❑ Request to limit HAPs with a Federally enforceable limit on PTE T y "a Cra 0 cI E a o a r R r E L ' G o ,a a e � a ,o S j E 5 v u L.05 T. C. HI y Q o e 5 n -0 0 v Cidp } z C b C4 .C N Ti U i. S L G Y Z ❑ N ❑ ❑ ❑ ❑EI en en O y U < i r O V v C7 U G N Fax Number: b 5o z Section 03 — General Information Va 0. b ti '-,, a -O y L. o 4 U L e LI Ca O 0 L 9 Y V Co r F y_ 0J N J 0 a Y a N S• i y S S "0 ., e N NI9 P e F V -0 e L L a G N N a 0 0, e E 0 c. LI O V ti F O _-a -r - -18 co 7 �,a== a a= CJ ^ N N •-• .11 -- en Q u y 4 4 4 47 V v u T a -^ .�' a o 0 0 r c L F `° c c °� W L. V Vi j N 69 L a <J Li _ Sq ;r. Ti Q u ., ii a6 ,.eau m E o, F P E 2 L u C J ,, o o a s- a co .. e U . .'= u. E. d c c ,, c a- m m E -y Si L 0 .'• co e o' a- a •Id �. ern Y❑ gi L r - 0..zup..-,. O F i G `S L Q I C., %4 Ca e ' v o,_ U m o U" - d a •y o° v°Gm y0 g o S E c c c N y9f=U .' 5 y ,� (..7 `` .. V q V V ❑ O m o r e `, 0> CO L— 7 u:.a a .a o. 0 F a. P, It-i v!- CU QK t u. Q:n Q a. d 3 oe Y O O 0 ment Information & Material Use J Nianufacturin2 E Section 04 — Processin Serial No.: unk 3 0 L a N C V v a 0 Q 0 C a z not a manufacturing u a z m ' Y � of L V y Other Process: 0 a a oo a a c € a a a G v` -a 0 0 C. a 0 0 V Y a v 0 B F U ®® L 0 .2j L a 3 L o a 2 C — J S O E LC L e J 6. :4 a x v .c 0 U PI E a a c E U a - 3 y ' o 0 E 9 Check box to r AFCO 2012 APEN Ge 0 LI a FORM APCD-200 Emission Source AIRS ID: 99OPWE213 Permit Number: th relevant information in the event of multiple releases; provide datum & either Lat/Long or UTM) Section (IS — Emission Release Information (Attach a separate sheet e 247 ae �— u 0 O F 2 o 2 8 V s 3 0 C C 7736 en cm cm N y 2 b- 6 O ▪ Nry ti O J i a 0 on 2 CC] E a In r N S ^ 0 Vertical with obstructing raincap a II v C L F ❑ C A ci t ❑ 0 L • N Y • ai v R. r .114 .. 45 O ▪ "t. • C C) C W meat & Fuel Consumption Information Section 06 — Combustion Eaui Manufacturer: Company equipment Identification No.: Seasonal Fuel Use (% of Annual Use) zI Q Y V) 0 a 5 so .0 v Percent by Weight H a 7 'n a ,11 L 00 -O G C G a C C yv c z 0 c O C s y a Section 07 — Emissions inventory information & Emission Control Information r` 2 cv i c 2 Ei a A n A Cs O 2 O C so s • A E A c 9 A ▪ 9 c - ✓ C 8 a O 6 4 E 7 o u c m in • l e v 1 0 a t a Estimation Method or Emission Factor Source Outlet grain loading/exhaust flow rate Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 9 C..? s. f C 0 Lo o n2 Controlled (Tons/Yearl 0 0 0 = � o e } ev c •G Actual Calendar Year Emissions3 Controlled (Tons/Year) 0 QS. M M CC Uncontrolled (Tons/Year) VI's! z z Emission Factor ce C u a a u a 40 a en Li di t Uncontrolled Basis ri 0 0 a 0 o 0 Control Efficiency (s/ Reduction) ' 0 Q a ON T a es 0 — O J 7V d C GLC V W Control Device Description i. 0 Primary Venturi with Cartridge Filer C a p a y E.' 2 0. g 1 O V` 'ON V i C ZJ O E y C • C • o 4 .2 c 2 a 01 C eG o C 2'e W i '{ CE :Lin 7 • k e leant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Section 08-A sal Form - S002.doc AFCO 2012 APEN G Plant Mana 0 0 0 0 ti a AFC() 2012 APEN General Form - 5002.doc en O Cp Cu 2 C z w C C w 0 I- 0 z z CD O yC t w= I— a a ° U O 7 J J a 0 g EL CL 1!' �L 4L c0 O M N AIRS ID Number: 99OPWE213 Permit Number: Arco Steel, LLC Company Name: CO (0 0 CO o U 0 N C C O U 0 U T a) a) 2 C7 M m 0 C 0 U a) U) V M Plant Location: (970) 356-2326 Phone Number: Joe Honesto Person to Contact: (970) 351-6743 Fax Number: AFCOSteel.corn 0 N a) O i E-mail Address: Controlled Actual Emissions (lbs/year) VN VN YN Uncontrolled Actual Emissions (lbs/year) co O r co 0 N a7 8,737.50 Emission Factor Source (/) O co MSDS GO a ci) Emission Factor (Include Units) Mass Balance Mass Balance Mass Balance Control Equipment I Reduction (%) VN VN YN Reporting BIN O O O Chemical Name Ethylbenzene Xylene a) C a) 7 I-- Chemical Abstract Service (CAS) Number 1- o O r 1330-20-7 M co co c0 O r O Calendar Year for which Actual Data Applies: r Reporting Scenario (1, 2 or 3): w N O ea co O T ca -o Q O N 0 L 7 Q (a a) J C O a) m a 0 2 7 ((00 C 0) Plant Manager Joe Honesto Title of Person Legally Authorized to Supply Data Name of Person Legally Authorized to Supply Data (Please print) Form Revision Date: December 4, 2006 Colorado Department of Public Health and Environment Air Pollution Control Division - COATING, PAINTING AND VOLATILE MATERIALS USAGE OPERATIONS - Air Pollutant Emission Notice (APEN) — and — Application for Construction Permit ❑ New Facility ❑ Transfer of Ownership ° ❑ Change in Throughputs ® No Change, APEN Update Only ❑ Change in Equipment ❑ 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 detetnthted incomplete and may result in longer engineer processing times. * Note: For transfer of ownership or company name change on a permit, you must submit proof of ownership transfer (e.g. Transfer of Ownership Form signed by the previous owner or a copy of a Bill of Sale). Permit Number 99OPWF213 AIRS Number 001 Company Name: AFCO Steel, LLC City: Greeley Plant Location: 31455 Weld County Rd. 39 1/2, Greely, CO County: Weld Billing Address: Person to Contact: E-mail Address: 31455 Weld County Rd. 39 1/2, Greely, CO Zip Code: 80631-9669 Greeley, CO Joe Honesto IIIonestii, A!coSicel.coal Phone Number: 970-365-2326 Fax Number: Date Facility Began or Will Begin Operation: Normal Operation of this Source: 12 Hours per day, 7 Days per week, 52 Weeks per year 1. Facility Function: ❑ Automobile Coating ® Metal Parts Coating O Plastic Parts Coating ❑ Others (Explain): Current Project: 2. Type of Equipment Located at this Facility (attach additional sheets as needed) (Paint booths, dip -tanks, powder coating units, etc.) Unit No. Make Model Serial No. Year of Installation Control Device Type 1 Indoor, open bay paint areas NA NA NA 3 4 5 Page 1 of 3 3. Paints and Volatile Materials Usage Information: a. Coating Materials Application Method: ❑ Dip, Brush, or Roller (DBR): TE• = 95% ❑ High Volume Low Pressure Gun (HVLP): TE = 65% ® Air -Assisted Airless/Airless (AAA/A): TE = 40% ❑ Electrostatic, How Voltage (EHV): TE = 90% ❑ Electrostatic, Low Voltage (ELV): TE = 65% ❑ Conventional Air Atomizing (CAA): TE = 25% ❑ Others (Describe): *Note: "TE" means "Transfer Efficiency percent (%)." It is used to estimate particulate emissions. b. Volatile Materials Usage (you may attach additional sheets as needed)*: SIN: Name of Product Annual Usage (Specify Units) MSDS ID or Name 1 Various Coatings, Thinners and Solvents (see emission calculations for specifics) Permit allows emissions up to 72.4 tpy VOC and 20 tpy HAP (synthetic minor source) Varies 2 3 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). 4. Actual Time Spent for Materials Application: typically 12. up to 24 hours/day 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). 5. Powder Coatings Usage: a. Actual Usage: 0 tons per year b. Requested Usage: 0 tons per year Page 2 of 3 c. Application Method: Transfer Efficiency (TE): d. Control Device: Control Efficiency (CE): 6. Air Pollutant Emissions from Coating and Volatile Materials Usage (Should be based on products usages listed above) a. Actual VOC: 25 tons/year* Data Year: 2011 (e.g. 2010). The Data Year must be given b. Requested VOC: up to 72.4 tnns,vear (synthetic minor per existing permit) tons/year* c. List individual hazardous air pollutants (HAP) on the Non -Criteria Reportable Pollutants Addendum form and submit it with this APEN form. * The Division will calculate annual emission fees based on the Actual VOC level reported above. Allow for growth when estimating Requested YOU emission limit. The Requested VOC emissions listed above will become a permit limit. 7. Check the appropriate box below if you want: D The Division to help calculate my source's air pollutant emissions based on the products usage supplied in this application. Z A copy of the Preliminary Analysis conducted by the Division. ® To review a draft of the permit prior to issuance. 8. Person Legally Authorized to Supply Data: Name: Joe Honesto Title: Plant Manager Signature: Date: 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. 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 fonn and APEN (one for each emission source) to the APCD. APEN and permit emission thresholds are based on uncontrolled actual emission rates. All pemfts 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. Once the source begins operations, the Division may inspect the source to ensure compliance with all applicable pemit conditions. Air Pollutant Emission Notice (APEN), Construction Permit Applications forms. and other application forms are downloadable at www.cdphe.state.co_u,-a Pidutwiluadlornus.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 \YVV W, ud plte state_cn_ns/np'si atiunacy library_hum 1. Any Abrasive blasting may need separate APEN. Revised August 2011 http://www.cdphe.slate.co.us/ap/downloadforms.asp • Page 3 of 3 Colorado Department of Public Health and Environment Air Pollution Control Division Stationary Sources Program - FUGITIVE PARTICULATE EMISSIONS CONTROL PLAN FOR SAND BLASTING OPERATIONS - Permit Number 99OPWE213 AIRS Number Not Yet Assigned Company Name: AFCO Steel, LLC Source Location: 31455 Weld County Rd. 39 12, Greely, CO County: Weld Billing Address: Person to Contact: E -Mail Address: 31455 Weld County Rd. 39 1/2 Zip Code: 80631-9669 Greeley, CO Joe Honesto Phone Number: 970-365-2326 JHoncsto(�AfcoSteel.com Fax Number: Please provide description of the activity: Minor amounts of abrasive blasting using Starblast are performed indoors to correct mistakes in the coating of structural metal parts. The Colorado Air Quality Control Commission's Regulation No. 1 requires that a fugitive emissions control plan be submitted by applicants whose source/activity results in titgitive particulate emissions. Die control plan must ratable the source to minimize l itgitive emissions to a level that is technologically feasible and economically reasonable. If the control plan is not adequate in minimizing emissions, a revised control plan will be required unless it is determined that no technologically feasible and economically reasonable abatement measures exist. The control plan (if acceptable to the Division) will be used for enforcement inspection purposes. Please check the control measures that you propose for your activity. A separate sheet may be attached explaining your specific control measures or activities if they differ from those fisted in this lbnn or if more space is needed. The Division will contact you if it feels that additional control measures are needed. The control measures you and the Division agree to be applied will be enforced. Control Measures: 0 Wet Blasting El Enclosure ❑ Other (specify) (Likely to be required by the Division) Type: Complete or Partial Blasting occurs inside a warehouse (complete enclosure) Additional Comments Type of Material Used: Starblast Amount of Material Used: 12 Tons Per Year Please provide description of the cleanup and disposal at the site: Abrasive material is removed for disposal by Waste Management annually Signature of a Responsible Official (not a vendor or consultant) Joe Honesto Name (please print) Revised July 2001 Date Plant Manager Title hitpfiwww.cdphe.state.co.usiap/slationary.htnil AECOM Environment Attachment B CDPHE Application Forms Form 2000-100, Facility Identification Form 2000-101, Facility Plot Plan Form 2000-102, 102A, and 102B, Source and Site Description Form 2000-200, Stack Identification Form 2000-305, Painting and Coating Operations Form 2000-306, Miscellaneous Processes Form 2000407, Baghouses/Fabric Filters Form 2000-500, Compliance Certification — Monitoring and Reporting Form 2000-503, Control System Parameters or Operation Parameters of a Process Form 2000-504, Monitoring Maintenance Procedures Form 2000-507, Compliance Demonstration by Recordkeeping Form 2000-600, Emission Unit Hazardous Air Pollutants Form 2000-601, Emission Unit Criteria Air Pollutants Form 2000-602, Plant -Wide Hazardous Air Pollutants Form 2000-603, Facility Criteria Air Pollutants Form 2000-604, Applicable Requirements and Status of Emissions Unit Form 2000-605, Permit Shield Protection Identification Form 2000-606, Emission Unit Compliance Plan — Commitments and Schedule Form 2000-700, Supplemental Information Form 2000-800, Tabulation of Permit Application Forms September 2012 Operating Penult Application FACILITY IDENTIFICATION Colorado Department of Public Health and Eneironmem Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 Facility name and Name mailing address Street or Route City, State, Zip Code AFCO Steel, LLC 31455 Weld County Rd. 39 1/2 Greeley, Colorado 80631-9669 2. Facility location Street Address 31455 Weld County Rd. 39 1/2 (No P.O. Box) City,County, Zip Code Greeley, Colorado 80631-9669 3. Parent corporation Name AFCO Steel, LLC Street or Route 1423 East 6- St. City, State, Zip Code Little Rock, AR 72202-2715 County (if not U.S.) 4. Responsible official Naine Title Telephone Joe Honesto Plant Manager 970-356-2326 5. Permit contact person Name Title (If Different than 4) Telephone 6. Facility SIC code: 3441 7. Facility identification code: CO / 123/0488 8. Federal Tax I. D. Number: 7 1 0 5 5 8 7 4 1 9. Primary activity of the operating establishment: 10. Type of operating permit ❑New Modified Renewal 11. Is the facility located in a "nonattainment" area: m Yes ❑Vo If "Yes", check the designated "non -attainment" pollutant(s): ❑ Carbon Monoxide Ozone ❑ PM10 ❑ Other (specify)_ 12. I,i.st all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. 82WE099, 95WE890, 99OPWE213 Operating Permit Application Colorado Department of Public Health and Envixomnent Air Pollution Control Division FACILITY PLOT PLAN FORM 2000-101 Rev 06-95 Facility Name: AI CO Sled, 1.LC Facility Identification Code: CO CO/123.04g8 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. In order for a comprehensive air quality analysis to be accomplished, a facility plot plan MUST be included with the permit application. Drawings provided must fit on generic paper sizes of 8 1/2" X 11", 8 1/2" X 14" or 11" X 15", as appropriate to display the information being provided. Include the facility name and facility identification code on all sheets. For facilities with large areas, sketches of individual buildings, on separate drawings, may be needed to allow easy identification of stacks or vents. Insignificant activities do not need to be shown. • 1. A plant layout (plan view) including all buildings occupied by or located on the site of the facility and any outdoor process layout. • 2. The maximum height of each building (excluding stack height). • 3. The location and coded designation of each stack. Please ensure these designations correspond to the appropriate stacks listed on the other permit forms in this application. The drawings need not be to scale if pertinent dimensions are annotated, including positional distances of structures, outdoor processes and free standing stacks to each other and the property boundaries. • 4. The location of property boundary lines. • 5. Identify direction "North" on all submittals. Are there any outdoor storage piles on the facility site with air pollution emissions that need to be reported? [Yes • No If "Yes", what is the material in the storage pile(s)? Are there any unpaved roads or unpaved parking lots on the facility site? ■ Yes ❑ No List the name(s) of any neighboring state(s) within a 50 mile radius of your facility: Wyoming 2 ( 4480000 iu m co M • 4479000 • 4478000 z • 4477000 F - N4 . eeler 4476000 4475000 522000 523000 524000 525000 526000 527000 528000 529000 530000 UTM Easting (UTM Zone 13, NAD 83, meters) AFCO Steel I Greeley, CO Facility P A S I V. A L L AFCO STEEL, LLC GREELEY. CO FACILITY FACILITY LOCATION AND AREA TOPOGRAPHY Elevation Contour Interval = 10 feet Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division Facility Name: AFCO Steel, LLC SOURCE AND SITE DESCRIPTIONS FORM 2000-102 Rev 06-95 Facility Identification Code: CO — /121/0488 lie operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. 1.Briefly describe the existing Unit(s) to be permitted. Attach copies of Form 2000-700 as needed to provide the information. Process flowsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in showing the location and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very helpful when developing an understanding of the processes involved. Coating and solvent use — structural steel surface coating operations and cleanup solvent use. Performed indoors. Wheelabrator shot -blast unit — one wheelabrater steel shot blasting unit with a cartridge filter to control particulate emissions Welding — insignificant emission unit by emission rate. Performed indoors. Abrasive blasting using Starblast — peformed indoors rarely as needed when surface coating needs to be reworked. 2.Site Location and Description (Include instructions needed to drive to remote sites not identifed by street addresses) 31455 Weld County Road 39 1/2 North of Greely, Colorado, east of US Highway 85 Safety Equipment Identify safety equipment required for performing an inspection of the facility: ' Eye Protection • Hard Hat • Safety shoes • Hearing Protection ❑ Gloves ❑ Other, specify 3 Operating Permit Application Colorado Department of Public Health and Enviromnent Air Pollution Control Division SOURCE DESCRIPTION - APENS FORM 2009-102A Rev 06.95 Facility Name AFC° Steel, TLC Facility Identification Code: CO /123/0488 _ MOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of $100 per APEN. 1. For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice (APEN) on file with the Division. If the most current APEN was not completely and correctly filled out, a revised APEN is required. List an APEN number, date, and a brief description of the unit/process covered by the APEN. (No filing fees are needed for these copies) 2. No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN with a construction permit application. New APEN and permit application submitted pvith this application OR pander separate cover to Construction Permits Section APENs are not required for indoor blasting or welding operations due to not exceeding threshold emissions of Regulation 3, II.B.3.a. Welding is also exempt from the requirement to submit an APEN per Regulation 3, II.D.1.r. 3. A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information here. A revised APEN is needed where a significant increase in emissions has occurred, or is planned; or a major modification of the unit has occurred or is planned; or the existing information needs correction or completion. A construction permit application may need to be submitted. Revised APEN submitted as part of this application: • Yes aio ! Filing Fee Enclosed New permit application enclosed: ['Yes ' No Permit modification application enclosed: • Yes QJo APEN Number 1: Permit 990PWE213 — P001, Unit ID 5001, Protective coating and associated cleaning activities. (Renewal) APEN Number 2: Permit 990PWE213 — P002, Unit ID S002, Structural steel descaling system (Wheelabrator) (Renewal) 4 Berating Permit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES Colorado Department of Public Health and Environment Air Pollution Control Division FORM 2000-102B Rev 06-95 Facility Name: AITO Steel, I.I.C Facility Identification Code: CO 123/0488 _.JTE: The operating permit must be prepared and submitted on forms supplied by the Division. [his is a supplemental form for use only when necessary to provide complete information in the operating permit application. The Division will not consider or act upon your application unless each form used has been entirely completed. Certain categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A source solely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, unless the source's emissions trigger the major source threshold as defined in Part A, Section I.B.58 of Regulation 3. For the facility, mark all insignificant existing or proposed air pollution emission units, operations, and activities listed below. ❑ (a) noncommercial (in-house) experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories, environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non -criteria reportable pollutant. • Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). • Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). [Petroleum industry flares, not associated with refineries, combusting natural gas containing no H2S except in trace (less than 10 ppmw) amounts, approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any illutant of less than five tons per year. • Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. • Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). ❑crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. • Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. ❑Oil production wastewater (produced water tanks), containing less than 1% by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. • Storage of butane, propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. • Storage tanks of capacity < 40,000 gallons of lubricating oils. [Venting of compressed natural gas, butane or propane gas cylinders, with a capacity of 1 gallon or less. ❑ Fuel storage and dispensing equipment in ozone attainment areas operated solely for company -owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. ❑Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. 5 • Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils #1 through #6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA). • Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. • Stationary Internal Combustion Engines which: (i) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii)have actual emissions less than five tons per year or rated horsepower of less than 50. [Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. ■ Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level. NOTE: Material Data Safety Sheets (MSDS) do not have to be submitted for any insignificant activities. USE FORM 2000-700 TO PROVIDE AN ITEMIZED LIST OF THE SOURCES OR ACTIVITIES BEING IDENTIFIED AS INSIGNIFICANT ACTIVITIES. DO NOT ITEMIZE INDIVIDUAL PIECES OF LANDSCAPING EQUIPMENT. THE LIST IS NEEDED TO ACCURATELY ACCOUNT FOR ALL ACTIVITIES AT THE FACILITY 6 Operating Permit Application Colorado Department of Publio IIeaah and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE STACK IDENTIFICATION FORM 2000-200 Rev 06-95 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ 123/0488 3. Stack identification code: S001 (Coating and Cleaning) 3a. Construction Permit Number: 95EW890 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 30L 302.303- 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 X 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 6. Indicate by checking: ❑ This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. [When stack height Good Engineering Practice ( GF1') exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for hem 7. 7. Discharge height above ground level: (feet) 8. Inside dimensions at outlet (check one and complete): circular (feet) Q(ectangular length (feet) width (feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity (FPS) ❑Calculated [Mack Test 10. Exhaust gas temperature (normal): (EF) 11. Does process modify ambient air moisture content? ❑ Yes ❑ No If "Yes", exhaust gas moisture content: Normal percent Maximum - percent 12. Exhaust gas discharge direction: EILTP [Down ['Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? [tires [No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, 305. 306. or 307 for each Unit exhausting through this stack. ***** 7 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC STACK IDENTIFICATION FORM 2000-20(1 Rev 06-95 Facility identification code: CO _.123,0488 _ 3. Stack identification code: 5002 (Descaling, Wheelabrator) 3a. Construction Permit Number: 95EW890 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 X 2000-307 5. Stuck identified on the plot plan required on Form 2000-101 ❑ 6. Indicate by checking: � This stack has an actual exhaust point. The parameters are entered in Items 7-13. ❑This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. [When stack height Good Engineering Practice (CEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 3.5 (feet) 8. Inside dimensions at outlet (check one and complete): ['Circular (feet) Rectangular 5 length (feet) 8 width (feet) 9. Exhaust flow rate: (ACFM) Velocity 5.0 (FPS) U Calculated Quack Test Normal 8000 (ACFM) Maximum 8000 10. Exhaust gas temperature (normal): ambient (EF) I I. Does process modify ambient air moisture content? ❑ Yes No If "Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: OUP [Down • Horizontal l3. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ❑Yes No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, 305. 306. or 307 for each Unit exhausting through this stack. ***** 3 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division EE INSTRUCTIONS ON REVERSE SIDE STACK IDENTIFICATION FORM 2000-200 Rev 06-95 Facility name: AFC° Steel, LTC Facility identification code: CO _ 123'0488 3- Stack identification code: S003 (Indoor Abrasive Blasting) 3a. Construction Permit Number: 95EW890 890 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 X 2000-307 5. Stack identified on the plot plan required on Form 2000-101 6. Indicate by checking: ❑ This stack has an actual exhaust point. The parameters are entered in Items 7-13. ▪ This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑PVhcn stack height Good Engineering Practice (GEM exceeds 65 meters (Colorado Air Quality Reg 3.A.V111D) data entry is required for Item 7. 7. Discharge height above ground level: (feet) 8. Inside dimensions at outlet (check one and complete): circular (feet) ['Rectangular length (feet) width (feet) 9. Exhaust flow rate: Normal (ACFM) Velocity (FPS) ['Calculated OStack Test Maximum (ACFM) 10. Exhaust gas temperature (normal): (EF) 11. Does process modify ambient air moisture content? ❑ Yes ❑ No If "Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: Dup [Down ['Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ❑Yes [No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, 305, 306, or 307 for each Unit exhausting through this stack. ***** 9 STACK IDENTIFICATION FORM 2000-200 Rev 06-95 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRI ICIiONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ 123/04X8 3. Stack identification code: S004 (Welding) 3a. Construction Permit Number: 95EW890 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 X 2000-307 5. Stack identified on the plot plan required on Form 2000-101 6. Indicate by checking: ❑ This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑When stack height Good Engineering Practice f GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VTII.D) data entry is required for Item 7. 7. Discharge height above ground level: (feet) 8. Inside dimensions at outlet (check one and complete): circular (feet) [Rectangular length (feet) width (feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity (FPS) [Calculated [Stack Test 10. Exhaust gas temperature (normal): (EF) 11. Does process modify ambient air moisture content? ❑ Yes 0 No If "Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: OUP [/)own [Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ['Yes aro *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, 305, 306, or 307 for each Unit exhausting through this stack. ***** 10 Operating Permit Application Colorado Department of Public Health and Snironment Air Pollution Control Division EE INSTRUCTIONS ON REVERSE SIDE PAINTING AND COATING OPERATIONS FORM 2000-305 Rev 06-95 L Facility name: AFCO Steel, LLC 2. Facility identification code: CO / 123/0488 Stack identification code: S001 4. Process (Unit) code: P002 Unit description (with serial number): Coating and Cleaning 6. Indicate the control technology status. Uncontrolled ❑Controlled If the process is controlled, enter the control device code(s) from the appropriate fonn(s): 2000-400 2000-401 2000-402 2000-404 2000-405 2000-406 2000-403 2000-407 7. Application technique and transfer efficiency: Airless Assisted Gun, 40%: 8. Date placed in service: 1982 Date of last modification: 05/13/99 9. Normal operating schedule: 12 hrs/day 7 days/wk 4380 hours/yr 10. Oven curing (complete if applicable): Number of ovens I Specify oven fuels Electric Total Maximum Energy input to each oven: rnmBTU/Hr, total fuel usage for 19 million cubic feet 11. Describe all of the coatings' and solvents' composition (as applied) that are used by this unit. Data entry in the shaded columns of the table is optional; however, if NSPS or Regulation 7 requirements apply to the unit, the applicable information must be provided. Name of coating a. '* b. T e. Maximum usage d. Actual usage 19 e. Solids Ts 1'. VOC a g. Wale r o lv Exempt solvent % i. Coating or VOC Density i. VOC less H2O k. EF gal/hr gal/yr gal/yr Wt Wi Wt Wt lbs/gal lbs./gal Paints — Varies 1 70 6 75,245 Varies Varies Varies List the thinning solvents used with the coatings identified above. Thinners — Varies 0.5 2000 Varies Varies Clean-up solvents Solvents — Varies 0.9 4000 Varies Varies Other (specify) *** For this emissions unit, identi y the method of compliance demon (ration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attaclunent(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** Use the following codes in this column: 1 - for air dried coatings; 2 - for clear coatings; 3 - for cured coatings; 4 - for extreme performance coatings; 5 - for other (specify) 11 Operating Permit Application Colorado Uepartmenl of Public Health and Environment Pollution Control Division E INSTRUCTIONS ON REVERSE SIDE MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06-95 1. Facility name: AFCO Steel, LTC 2. Facility identification code: CO 123/0488 3. Stack identification code: 5002 4. Process (Unit) code: P001 5. Unit description: Descaling. Wheelabrator 6. Indicate the control technology statu -. ['Uncontrolled l. Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 C001 7. Actual annual process rates for 19 98 8. Date first placed in service: 1982 Date of last modification: 05/13/99 9. Normal operating schedule: 12 hrs./day 7 days/wk. 4380 hours/yr. 10. Describe this process (please attach a flow diagram of the process). Attached'? ❑ Steel shot/grit is used in an enclosed unit to remove scale from steel components prior to assembly and coating. Emissions are controlled using a cartridge filter. Shot/grit is recovered and reused until spent. 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process Actual usage Units Maxinnun Units usage Steel shot/grit Manufacturer's containers 16,000 Lbs/nun Other (specify) 12. List the types and amounts of finished products: Material Storage/material handling process Actual amount Units produced Maximum Units amount produced NA 13. Process luel usage: Type of filet Maximum heat input to process million BTU/hr. Actual usage Units Maximum usage Units NA 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: NA ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500,***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 12 Operating Permit Application Colorado Department of Public Health and Environment ir Patton on Control Division :E INSTRUCTIONS ON REVERSE SIDE MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06-95 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO / /23/0488 Stack identification code: S003 4. Process (Unit) code: P003 Unit description: Indoor Abrasive Blasting 6. Indicate the control technology status. a IJncontrolled ['Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 7. Actual annual process rates for 2011 8. Date first placed in service: 1982 Date of last modification: 05/13/99 9. Normal operating schedule: t hrs./day 2 days/wk. 104 hours/yr. 10. Describe this process (please attach a tlow diagram of the process). Attached'? ❑ Starblast is used indoors to blast steel that either requires recoating or that is too large to blast in the Wheelabrator. Emissions are controlled by blasting indoors. 11. List the types and amounts of raw materials used in this process: Material Storage/material handling process Actual usage Units Maximum usage Units Starblast (abrasive) Manufacturer's containers (totes) 12 TPY IS TPY Other (specify) 12. List the types and amounts of finished products: Material Storage/material handling process Actual amount Units produced Maximum Units amount produced NA 13. Process fuel usage: Type of fuel Maximum heat input to process million BTU/hr. Actual usage Units Maximum usage Units NA 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles unpaved roads, open conveyors, etc.: NA ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500,***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. 13 ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** Operating Permit Application alorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE. MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06-95 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO J 123/0488 Stack identification code: S004 4. Process (Unit) code: P004 5. Unit description: Welding 6. Indicate the control technology status. • Uncontrolled ['Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 7. Actual annual process rates for 2011 8. Date first placed in service: 1982 Date of last modification: NA 9. Normal operating schedule: 24 hrs./day 7 days/wk. 8760 hours/vr. 10. Describe this process (please attach a flow diagram of the process). Attached? ❑ Welding of structural steel parts. List the types and amounts of raw materials used in this process: Material Storage/material handling process Actual usage Units Maxinnim usage Units Welding Rods Warehouse 87, 000 lbs/ yr 134,000 lbs/ yr Other (specify) 12. List the types and amounts of finished products: Material Storage/material handling process Actual amount produced Units Maximum amount produced Units NA — not a manufacturing process 13. Process fuel usage: Type of fuel Maximum heat input to process million BTIJ/hr. Actual usage Units Maximum usage Units Electric 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500,***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Air Pollution Control Permit Application Foams 2000-600 and 2000-601 for this Unit. ***** 14 Operating Permit Application CONTROL EQUIPMENT - BAGHOUSES/FABRIC FILTERS Colorado Department of Public Health and Environment kir Pollution Control Division FE INSTRUCTIONS ON REVERSE SIDE FORM 2000-407 Rev 06-95 Section A I. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ / 123/0488 Stack identification code: 8002 4. Unit identification code: P001 5. Control device code: O001 6. Manufacturer and model number: US Filter/Wheelabrator cyclone and Size 45SH, Model 36 cartridge filter system 7. Date first placed in service: 1982 8. Describe the filtering system used. Attach a diagram of the system. Cyclone and cartridge filter Date last modified: NA 9. In the table below list the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant. [Documentation attached EITHER the outlet pMiniunt concentration OR the control efficiency must be provided. Pollutant Inlet pollutant concentrati on Outlet pollutant concentration Efficiency (%) gr/acf griaef Emission Capture Pollutant Removal Particulate 0.02 99% PM -10 0.02 99% 10. Range of pressure drop across the filter clean and dirty) (inches of H2O): l 1. Discuss how the collected material will be handled for reuse or disposal. 12. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not he limited to the following: a. Identification of the individuals(s), by title, responsible for inspecting, maintaining and repairing this device. h. Bag cleaning techniques and frequency of cleaning or replacement schedule for filters. c. Operation variables that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. d. An inspection schedule and items or conditions that will be inspected. e. Where is this plan available for review? Section B The following questions must he answered by sources installing new equipment or existing Units which cannot document control efficiency of this device by other means. 13. Filter medium or type of fabric material (if fabric, indicate whether felt or woven; if coated, frequency of coating): 14. Maximum inlet gas flow rate ACFM): 16. Number of bags if applicable: 18. Air to cloth ratio (actin/111)' 15. Maximum inlet gas temperature (EF): l7. Dimensions ofhags/filters: 15 Operating Permit Application COMPLIANCE CERTIFICATION - MONITORING AND REPORTING Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED it Pollution Control Division FOR DETERMINING COMPLIANCE FORM 2000-500 Rev 06-95 All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, rccordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit tem. These submittals must he no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name AFCO Steel, LLC 2. Facility identification code: CO _/ 123/0488 3. Stack identification code: 5002 Unit identification code: P001 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): [Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): ▪ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): PM and PM 0 ▪ Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): PM and PM 0 ❑'tack Testing - Form 2000-505 Pollutant(s): Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): • Recordkeeping - Form 2000-507 Pollutant(s): PM and PMI0 ❑Dther (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: and even/ The first March 31 occurring after the permit issue dale 12 months thereafter. (12 month maximum interval) Compliance monitorine reports will be submitted to the Division according to the following schedule: Start date: and every months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 16 Opening Permit Application COMPLIANCE CERTIFICATION - MONITORING AND REPORTING FORM 2000500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE ..11 applicants are required to certify compliance with all applicable air pollution permit requirements by inchiding a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit tenn. These submittals must be no less frequent than annually, and may need to he more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE L Facility name AFCO Steel, LLC 7. Facility identification code: CO _/ 123/0488 Stack identification code: S001 Unit identification code: P002 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate fom(s) to this torn). ❑ Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): [Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): ▪ Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): VOC/HAPs [Monitoring Maintenance Procedures - Fotm 2000-504 Pollutant(s): ;Stack Testing - Form 2000-505 Pollutant(s): and Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): ▪ Recordkeeping - Form 2000-507 Pollutant(s): VOC/HAPs ❑Other (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: and every The first March 31 occurnne after the permit issue date 12 months thereafter. (12 month maximum interval) Compliance monitorine reports will be submitted to the Division according to the following schedule: Start date: and every months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 17 Operating Permit Application COMPLIANCE CERTIFICATION - MONITORING AND REPORTING Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Air Pollution Control Division FOR DETERMINING COMPLIANCE FORM 2000-500 Rev 06-95 nll applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name AFC() Steel, Li.C Facility identification code: CO _/ 123/0488 3. Stack identification code: S003 4. Unit identification code: P003 5. For this Unit the following method(s) for determining compliance with die requirements of the permit will be used (check all that apply and attach the appropriate tom(s) to this form). ['Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): Eperiodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): MI Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): PM and PMI0 Monitoring Maintenance Procedures - balm 2000-504 Pollutant(s): ILStack Testing - Form 2000-505 Pollutant(s): [Fuel Sampling and Analysis (ESA) - Form 2000-506 Pollutant(s): • Recordkeeping - Form 2000-507 Pollutant(s): PM and I'M I0 Other (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: The first March 31 occulting alter the permit issue date and every 12 months thereafter. (12 month maximmn interval) Compliance monitorinu reports will be submitted to the Division according to the following schedule: Start date: and every months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 18 Operating Permit Application COMPLIANCE CERTIFICATION - MONITORLNG AND REPORTING Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Air Pollution Control Division FOR DETERMINING COMPLIANCE FORM 2000-599 Rev 06-95 .11 applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkecping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit tenn. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name AFCO Steel, LLC 2. Facility identification code: CO _/ 123/0488 3. Stack identification code: S004 4. Unit identification code: P004 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). IliCoutinuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): Eperiodic Emission Monitoring Using Portable Monitors - Foam 2000-502 Pollutant(s): Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): [Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): ,Iitack Testing - Form 2000-505 Pollutant(s): duel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Recordkeeping - Form 2000-507 Pollutant(s): PM and I'M 10 [Other (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: The first March 31 occurring after the permit issue date and every 12 months thereafter. (12 nionth maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: and every months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 19 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-503 Colorado Department of Public Health and Environment MONITORING CONTROL SYSTEM PARAMETERS OR Rev 06-95 Air Pollution Control Division OPERATING PARAMETERS OF A PROCESS to monitoring of a control system parameter or a process may be acceptable as a compliance demonstration method provided that a correlation .,ctween the parameter value and the emission rate of a particular pollutant is established in the form of a curve of emission rate versus parameter values. Ideally stack test data that bracket the emission limit, if possible, could be used to define the emission curve. This correlation shall constitute the certification of the system. It should be attached for Division approval. If it is not attached, please submit it within. 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO / 123/0488 3. Stack identification code: S001 4. Unit identification code: P002 5. Pollutant(s) being monitored: VOC/HAPs 6. Name of manufacturer: Various paint/coating manufacturers (including Carboline, Ameron, SW and TNEMEC) Model number: Various paint/coating types 8. Is this an existing system? Yes Q4o 9. Reserved for future use 10. Describe the method of monitoring: Monitoring will include math:mina data for ail paints and solvents used at the facility. Records will include data sheets showing the fraction of VOCs in each item, the HAP content of each item, and the amount used on a monthly basis. The MSDS supplied by vendors will he used to obtain these data. A spreadsheet system will be used to calculate emissions of VOCs and HAPs from the use of these materials. Monthly emissions shall be calculated by the end of the subsequent month. A twelve-month rolling total of emissions will he maintained in order to monitor compliance with the annual VOC and HAP emission limitations. Each month. a new twelve month total shall he calculated using the previous twelve months data. Records of the calculated emissions and compliance determinations shall be maintained and made available to the Division for review upon request. No coatings used at this facility shall contain chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni). Of cadmium (Cd). New or reformulated coatings will be reviewed for HAP content prior to purchase and use 11. Backup system: The amount of paints and solvents used at the facility will always be available. However, if art MSDS is unavailable for any reason, engineering estimates will he used for the VOC and HAP content of the item and will be used to calculate emissions of VOC and HAPs from that material. 20 12. Quality Assurance/Quality Control: Any monitoring system used with the record keeping shall he subject to appropriate performance specifications, calibration requirements and quality assurance procedures. ❑ A quality assurance/quality control plan for the monitoring program is attached for Division review. • The plan is not attached, but will be submitted to the Division by Plan was submitted with the original construction pemuil application 13. The applicant shall propose an appropriate averaging period, (i.e., a particular number of continuous hours) for the purpose of defining excess emissions. The Division may approve the proposed averaging period, or other period which the Division determines to be appropriate. Provide the uronosed averaging ueriod(s) below. Parameter Averaging Period Paint and solvent material usage Daily measurements Emissions Monthly Annual Emissions 12 -month rolling total 21 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-503 Colorado Department of Public Health and Environment MONITORING CONTROL SYSTEM PARAMETERS OR Rev 06-95 :Pollution Control Division OPERATING PARAMETERS OF A PROCESS the monitoring of a control system parameter or a process may be acceptable as a compliance demonstration method provided that a correlation between the parameter value and the emission rate of a particular pollutant is established in the form of a curve of emission rate versus parameter values. Ideally stack test data that bracket the emission limit, if possible, could be used to define the emission curve. This correlation shall constitute the certification of the system. It should he attached for Division approval. If it is not attached, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE L Facility name: AFCO Steel, I -LC 2. Facility identification code: CO _/ 123/0488 3. Stack identification code: S002 4. Unit identification code: P001 5. Pollutant(s) being monitored: PM, PM -10 6. Name of manufacturer: US Filter/Wheelabrator 7. Model number: Size 4551-I, Model 36 cartridge filter system, STN: A140533 9. Reserved for future use 8. Is this an existing system? I Yes al 10. Describe the method of monitoring: A log of the actual daily hours of operation is kept as well as a twelve-month rolling total ofoperating hours. 6 -minute Visible Emissions observations are performed per EPA Reference Method 22, of the shot blast system exhaust daily when operation. The results are maintained in a log. If visible emissions are observed, appropriate corrective process and/or maintenance is performed as soon as practicable. Monthly emissions shall be calculated by the cod of the subsequent month. A twelve-month rolling total ol'cmkssions will be maintained in order to monitor compliance with the annual emission limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of the calculated emissions and compliance determinations shall be maintained and made available to the Division for review 1111O11 request. Pressure drop across the control device is measured by differential pressure ^_nukes or manometers during_routine Operutine conditions. If the pressure drop exceeds the specified ranee of I to 6 inches 112O. the shot blast system and control equipment performance are investi¢ared within 24 hours to make imecessary repairs or adjustments. Al] pressure gauges are installed and calibrated per manufacturer's recommendations and have minimum accuracy of'0.25 inches 112O. Pressure drop measurements are taken weekly when in operation and recorded in lug -book. 11. Backup system: If pressure drop measurements fail. a trained observer will conduct a Visual Emissions observation per EPA Reference Method 22 requirements. Any visible emissions will result in necessary equipment repairs or adjustments within 24 hours. 22 12. Quality Assurance/Quality Control: Any monitoring system used with the record keeping shall he subject to appropriate performance specifications, calibration requirements and quality assurance procedures. ❑ A quality assurance/quality control plan for the monitoring program is attached for Division review. The plan is not attached, but will be submitted to the Division by Plan was submitted with the original construction peen it application 13. The applicant shall propose an appropriate averaging period, (i.e., a particular number of continuous hours) for the purpose of defining excess emissions. The Division may approve the proposed averaging period, or other period which the Division detennines to be appropriate. Provide the proposed averacintz periodls) below. Parameter Averaging Period Pressure drop Weekly measurements Visual Emissions observation 6 minutes Hours of operation Daily Emissions Monthly 23 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-503 Colorado Department of Public Health and Environment MONITORING CONTROL SYSTEM PARAMETERS OR Rev 06-95 Air Pollution Control Division OPERATING PARAMETERS OF A PROCESS `te monitoring of a control system parameter or a process may be acceptable as a compliance demonstration method provided that a correlation ,etween the parameter value and the emission rate of a particular pollutant is established in the form of a curve of emission rate versus parameter values. Ideally stack test data that bracket the emission limit, if possible, could be used to define the emission curve. This correlation shall constitute the certification of the system. It should be attached for Division approval. If it is not attached, please submit it within 60 days of the startup of the system. Facility name: AFC() Steel, LLC Facility identification code: CO / 123/0488 Stack identification code: S003 Unit identification code: P003 5. Pollutant(s) being monitored: PM, PM -10 6. Name of manufacturer: DuPont 7. Model number: Starblast Blasting Abrasive 8. Is this an existing system? U Yes EN Reserved for future use 10. Describe the method of monitoring: A log of the actual daily hours of operation. a twelve-month rolling total of operating hours, as well as the amount or blasting material used are recorded. Calendar war annual emissions shall he calculated by January 31 lbr the previous calendar year. Records of the calculated emissions and compliance determinations shall be maintained and made available to the Division for review upon mutest. 11. Backup system: A backup syslcnt will not be required. 12. Quality Assurance/Quality Control: Any monitoring system used with the record keeping shall be subject to appropriate performance specifications, calibration requirements and quality assurance procedures. ❑ A quality assurance/quality control plan for the monitoring program is attached for Division review. The plan is not attached, but will be submitted to the Division by No plan. lust monitoring of usage and hours_ 13. The applicant shall propose an appropriate averaging period, (i.e., a particular number of continuous hours) tier the purpose of defining excess emissions. The Division may approve the proposed averaging period, or other period which the Division determines to be appropriate. Provide the proposed averaging period(s) below. Parameter Averaging Period Starblast material usage Weekly measurements Emissions Monthly Annual Emissions 12 -month rolling total 24 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-504 Colorado Department of Public Health and Environment MONITORING MAINTENANCE PROCEDURES Rev 06-95 Air Pollution Control Division e monitoring of a maintenance procedure may be acceptable as a compliance demonstration method provided a correlation between the ,rocedure and the emission rate of a particular pollutant is established. VOC leak detection programs or fugitive dust control programs are examples of procedures that could be monitored. The correlation shall be established using test data. This correlation shall constitute the certification of the monitoring system. It should he attached for Division approval. If it is not attached, please submit it within 60 days of the startup of the monitoring program. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO / 123/0488 3. Stack identification code: S002 4. Unit identification code: P001 5. Pollutant(s) being monitored: Particulate, PM -l0 6. Procedure being monitored: Descaling (Wheelabrator) 7. Is this an existing maintenance procedure? In Yes aro 8. Implementation date: 9. Describe the method of monitoring: The cartridge filter is maintained/renewed as per the manufacturer's recommendations, or more often if needed. If the manufacturer's recommendations are no longer available, a written document detailing the procedures to be followed in controlling emissions shall be submitted for Division approval. A record of the maintenance/renewals performed is kept on site. 10. Compliance shall be demonstrated: [Daily [Weekly ❑ Monthly • Other — specify — per Manufacturer 11. Quality Assurance/Quality Control: The monitoring program shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the monitoring program is attached for Division review. " The plan is not attached, but will be submitted to the Division by Plan was submitted with the orieinal construction permit anulicauon ***** Any failure to fulfill a maintenance requirement shall be reported as an excess emission. ***** 25 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division ecordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and de emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must he attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC Facility identification code: CO / 123/0488 3. Stack identification code: 5001 4. Unit identification code: P002 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: VOC, HAP Paint, thinner and solvent usage and emissions 7. Method of monitoring and recording (see information on back of this page): Records of monthly usage of naiads. thinners and solvents are kept in a worksheet_ Rolling 17 -month I IAP and VOC emissions from this usage ate calculated by the end of each new calendar month. The MSDS of any coating which has not been previously used at AFCO shall be reviewed prior to use to ensure that Coatings containing chromium (Cr), lead (Pb), manganese (Mu), nickel (NiI,or_cadmium (IA) are not used. 8. List any EPA methods used: NA 9. Is this an existing method of demonstrating compliance? Yes [Vo 10. Start dale: 11. Backup system 12 a. Data collection frequency: wily [Weekly • Monthly [Batch (not to exceed monthly) [Other - specify 12 b. Compliance shall he demonstrated: Qlaily [Weekly • Monthly [Batch (not to exceed monthly) Dither - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the recordkeeping system is attached for Division review. II The plan is not attached, but will be submitted to the Division by Plan was submitted with the oriental construction pennil application 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 26 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division ;cordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and de emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ / 123/0488 Stack identification code: S002 4. Unit identification code: P001 5. Pollutant(s) being monitored: PM and PM10 6. Material or parameter being monitored and recorded: Steel shot blasting material usage and emissions 7. Method of monitoring and recording (see information on back of this page): Records of monthly usage of steel slim and horns of operation are kept. Rolling 12 -month PM and PMIO emissions are calculated and records are maintained. Cartridge Inter maintenance, pressure drop and visible emission observation results are maintained on site. The MSDS of any steel shot blasting material which has nom been previously used at AFCO shall be reviewed prior to use to ensure that the appropriate paruculate emissions are calculated for the blasting materials_ 8. List any EPA methods used: NA 9. Is this an existing method of demonstrating compliance? • Yes ❑ No 10. Start date: 1 I. Backup system: 12 a. Data collection frequency: daily ❑Weekly • Monthly OBatch (not to exceed monthly) ❑Dther - specify 12 b. Compliance shall he demonstrated: Daily ❑Weekly • Monthly [Batch (not to exceed monthly) ❑Dther - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑ A quality assurance/quality control plan for the monitoring program is attached for Division review. • The plan is not attached, but will be submitted to the Division by Plan was submitted with the uri2iira€ construction permit application 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** ***** The compliance records shall he available for Division inspection. The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 27 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division 'ecordkeeping may he acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and _te emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO — / 123/0488 Stack identification code: S003 4. Unit identification code: P003 5. Pollutant(s) being monitored: PM and PM 10 6. Material or parameter being monitored and recorded: Welding rod material usage and emissions 7. Method of monitoring and recording (see information on back of this page): Records of monthly usage of welding rods are kept in a worksheet. Emissions are calculated by the end of each calendar year. NESHAP XXXXXX requires visible emission monitoring. Records are kept per the NESHAP. 8. List any EPA methods used: Method 22 9. Is this an existing method of demonstrating compliance? • Yes [ado 10. Start date: 11. Backup system: 12 a. Data collection frequency: [Daily ❑Weekly • Monthly [Hatch (not to exceed monthly) • Other — specify — Per NESHAP XXXXXX 12 b. Compliance shall be demonstrated: (daily [Weekly Qvtonthly match (not to exceed monthly) • Other — specify — Per NESHAP XXXXXX 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑A quality assurance/quality control plan for the recordkeeping system is attached for Division review. •The plan is not attached, but will be submitted to the Division No plan. just ntouitorluu tisane and visible emissions monitoring results 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. ***** ***** The compliance records shall be available for Division inspection. The source shall record any malfunction that causes or may cause an emission limit to he exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall he reported to the Division immediately. 28 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division cordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and .e emission rate of a particular pollutant is established in the fonn of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must he attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ / 123/0488 3, Stack identification code: 5004 4. Unit identification code: P004 5. Pollutant(s) being monitored: PM and PMIO 6. Material or parameter being monitored and recorded: Abrasive blasting material usage and emissions 7. Method of monitoring and recording (see information on back of this page): Records of monthly usage of abrasive blasting material and daily operating hours are kept in a worksheet. PM and PM1O emissions are calculated by the end of each calendar year. NESHAP XXXXXX requires visible emission monitoring. Records are kept per the NESHAP. 8. List any EPA methods used: Method 22 9. Is this an existing method of demonstrating compliance? ' Yes Lry0 10. Start date: 11. Backup system: 12 a. Data collection frequency: DDaily ['Weekly ' Monthly [Hatch (not to exceed monthly) • Other — specify — Per NESHAP XXXXXX 12 b. Compliance shall be demonstrated: [Daily ['Weekly ['Monthly [Batch (not to exceed monthly) • Other— specify— Per NESHAP XXXXXX 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. ❑A quality assurance/quality control plan for the recordkeeping system is attached for Division review. 'The plan is not attached, but will be submitted to the Division No elan. lust monitoina usage and visible emissions monitoring results. 14. ❑ A proposed tbnnat for the compliance certification report and excess emission report is attached. ***** ***** The compliance records shall be available for Division inspection. The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 29 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division ':E INSTRUCTIONS ON REVERSE SIDE FORM 2000-600 Rev U6-95 1. Facility name: AFCO Steel, LLC Facility identification code: CO / 123/0488 Stack identification code: 5001 4_ Unit identification code: P002 5- Unit material description: Paint and Solvents 6. Complete the following summary of hazardous air emissions from this unit Attach all calculations and emission factor references. Attached °Actual Emissions Data is for calendar year 2011 Pollutant CAS Couunon or Generic Pollutant Name Actual emissions Allowable OR Potential to emit Quantity Measurement Units Quantity Measurement Units 11-43-2 Benzene 8.0 TPY 100-41-4 Ethylbenzene 8.0 TPY 50-00-0 Formaldehyde 8.0 TPY None Glycol Ethers 8.0 TPY 822-06-0 HDI Isocvnate 8.0 TPY 110-54-3 n -Hexane 8.0 TPY 67-56-1 Methanol 8.0 TPY 108-10-1 MIBK 8.0 TPY 98-82-8 Cumene 8.0 TPY 91-20-3 Naphthalene 8.0 TPY 108-95-2 Phenol 8.0 TPY 100-42-5 Styrene 8.0 TPY 108-88-3 Toluene 8.0 TPY 79-01-6 Trichloroethylene 8.0 TPY 1330-20-7 Xylene 8.0 TPY Total HAPs 20.0 TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 30 Operating Pe nrit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS Colorado Department of public Health and Environment Air Pollution Control Division 'EE INSTRUCTIONS ON REVERSE SIDE FORM 2000-600 Rev 06-95 1. Facility name: AFCO Steel, TIC 2. Facility identification code: CO / 123/11488 3. Stack identification code: S004 4. Unit identification code: P004 Unit material description: Welding 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 2011 Pollutant CAS Common or Generic Pollutant Name Actual emissions Allowable OR Potential to emit Quantity Measurement Units Quantity Measurement Units 7440-47-3 Chromium 0.10 'fPY 7439-96-5 Manganese 0.10 TPY N495 Nickel Compounds 0.10 TPY Total HAPs <0.50 TPY 3i Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division EE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: AFC() Steel, LLC 2. Facility identification code: CO _ / 123/0488 3. Stack identification code: S002 4. Unit identification code: P001 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached " Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY U TPY Particulates (TSP) 3.6 TPY 3.6 8 TPY PM -10 3.6 TPY 3.6 8 TPY Nitrogen oxides TPY Volatile organic compounds TPY Carbon monoxide TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY deduced sulfur compounds TPY Hydrogen sulfide TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY TPY Units (U) should be entered as follows: 1 = lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other (specify) 9 = other (specify) 1 = other (specify) 32 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ / 123/0488 3. Stack identification code: S001 4. Unit identification code: P002 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached ■ Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY U TPY Particulates (TSP) 6.10 WY 6.10 TPY PM -10 TPY Nitrogen oxides TPY Volatile organic compounds 72.4 TPY 72.4 TPY Carbon monoxide TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY Reduced sulfur compounds TPY Hydrogen sulfide TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY I TPY Units (U) should be entered as follows: 1 = lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf 6 = other (specify) 9 = other (specify) 10 = other (specify) 33 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ / 123/0488 3. Stack identification code: S003 4. Unit identification code: P003 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached • Air pollutant Actual Potential to emit Maximum allowable Quantity U WY U TPY Particulates (TSP) 0.821 TPY 0.821 TPY PM -10 TPY Nitrogen oxides TPY Volatile organic compounds TPY Carbon monoxide TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY Reduced sulfur compounds TPY Hydrogen sulfide TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY TPY Units (U) should be entered as follows: 1 = Ib/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf B = other (specify) 9 = other (specify) 10 = other (specify) 34 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-601 09-94 1. Facility name: AFC() Steel, LLC 2. Facility identification code: CO _ / 123/0488 3, Stack identification code: S004 4. Unit identification code: P004 5, Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached • Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY U TPY Particulates (TSP) 0.20 TPY 0.20 TPY PM -10 0.20 TPY 0.20 TPY Nitrogen oxides TPY Volatile organic compounds TPY Carbon monoxide TPY Lead TPY Sulfur dioxide TPY Total reduced sulfur TPY Reduced sulfur compounds TPY Hydrogen sulfide TPY Sulfuric Acid Mist TPY Fluorides TPY TPY TPY TPY TPY Units (U) should be entered as follows: 1 = lb/hr 2= Ib/mmBTU 3 = grains/dscf 4 = lb/ gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf 8 = other (specify) 9 = other (specify) 10 = other (specify) 35 Operating Permit Application PLANT -WIDE HAZARDOUS AIR POLLUTANTS Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-602 Rev 06-95 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ / 123/0488 Complete the following emissions summary for all hazardous air emissions at this facility. Calculations attached. Attach a copy of all calculations to this form. Attached ❑ Pollutant CAS Common or Generic Pollutant Name Actual emissions Allowable OR Potential to emit Quantity Units Quantity Units 71-43-2 Benzene 8.0 TPY 100-41-4 Ethylbenzene 8.0 TPY 50-00-0 Formaldehyde 8.0 1PY None Glycol Ethers 8.0 TPY 822-06-0 IIDI Isocynate 8.0 TPY 110-54-3 n -Hexane 8.0 TPY 67-56-1 Methanol 8.0 TPY 108-10-I MIRK 8.0 TPY 98-82-8 Cumene 8.0 TPY 91-20-3 Naphthalene 8.0 TPY 108-95-2 Phenol 8.0 TPY 100-42-5 Styrene 8.0 TPY 108-88-3 Toluene 8.0 TPY 79-01-6 Trichloroethylene 8.0 TPY 1330-20-7 Xylene 8.0 TPY TotalllAPs 20.0 'TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 36 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division PLANT -WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 09-94 1. Facility name: AFC() Steel, LLC 2. Facility identification code: CO / 123/0488 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY TPY TPY Particulates (TSP) 15 15 PM -10 15 15 Nitrogen oxides Volatile organic compounds 72 . 4 72 . 4 Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist Fluorides 37 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFC() Steel, TLC 2. Facility identification code: CO / 123/0488 _ 3. Stack identification code: S002 4. Unit identification code: POOL 5. Pollutant 6. Colorado Air Quality Regulations or Construction Permit Number 7. State Only 8. Limitation 9. Compliance Status IN OUT PM, PMI O 95WE890 X 1.3 tpy Opacity not to exceed 20% (30% for certain operational activities) X 10. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, hours ot'operation, etc.) State Only Compliance Status IN OUT Maintains records of hours of unit operation X APPLICABLE REQUIREMENTS AND STATUS OF EMISSION UNIT FORM 2000-604 Rev 06-95 **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 38 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ / 123/0488 _ 3. Stack identification code: S001 4. Unit identification code: P002 5. Pollutant 6. Colorado Air Quality Regulations or Construction Permit Number 7. State Only 8. Limitation 9. Compliance Status IN OUT VOCs 95WE890 X 72.4 tpy X HAPs 95WE890 X 8.0 tpy for any single HAP 20.0 tpy for total HAPs No use of coatings containing lead, chromium, nickel, manganese, or cadmium 10. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, hours of operation, etc.) State Only Compliance Status IN OUT Maintains records of hours of unit operation X APPLICABLE REQUIREMENTS AND STATUS OF EMISSION UNIT FORM 2000-604 Rev 06-95 **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 39 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REV'FRSIi SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _ i 123/0438 _ 3. Stack identification code: S003 4. Unit identification code: P003 5. Pollutant 6. Colorado Air Quality Regulations or Construction Permit Number 7. State Only 8. Limitation 9. Compliance Status IN OUT PM, PM -10 40 CFR 63, Subpart XXXXXX Opacity not to exceed 20% X 10. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, hours of operation, etc.) State Only Compliance Status IN OUT Maintains records of hours of unit operation X APPLICABLE REQUIREMENTS AND STATUS OF EMISSION UNIT FORM 2000-604 Rev 06-95 "*** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 40 Operating Pennit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE. SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO / 123/0488 _ 3. Stack identification code: 5004 4. Unit identification code: P004 5. Pollutant 6. Colorado Air Quality Regulations or Construction Permit Number 7. State Only 8. Limitation 9. Compliance Status IN OUT PM, PM -10 40 CFR 63, Subpart XXXXXX Opacity not to exceed 20% X 10. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, hours of operation, etc.) State Only Con pliance Status IN OUT Maintains records of hours of unit operation X APPLICABLE REQUIREMENTS AND STATUS OF EMISSION UNIT FORM 2000-604 Rev 06-95 **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 41 Operating Permit Application dorado Department of Public IIealib and Environment Pollution Control Division PERMIT SHIELD PROTECTION IDENTIFICATION FORM 2000-605 Rev 06-95 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO / 123/0488 3. Specify Emission Source: Shot Blast Cleaning (P001) 4. Do not use 5. Pollutant, Equipment, or Process 6. Colorado Air Quality Regulations 7. State Only Particulate, PM -10 Permit No. 98WE890 No. 2, 5 CCR 1001-3 X No 1, 5 CCR 1001-3, I -II X No.1, % CCR 1001-3 II_C.1 X No 15. 5 CCR 1001-17 No 4, 5 CCR 1001-6 X 8. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, operating hours, etc.) State Only Operating hours limited to 2080 hours per year, maintain records of hours of unit ope ral ion X NOTE: REQUESTS FOR 171E SHIELD MUST BE FORA SPECIFIC REQUIREMENT IN THE REGULATIONS. LSE FORM 2000-700 TO PROVIDE AN EXPLANATION OF WHY THE SHIELD IS REQUESTED 42 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: AFCO Steel, LLC 2. Facility identification code: CO _/12310468 3. Stack identification code: S0001, S002, 4. Unit identification code: P001, P002, P003, P004 S003, S004 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. • We will continue to operate and maintain this Unit in compliance with all applicable requirements. ❑ Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. ❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 43 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division "EE INSTRUCTIONS ON REVERSE SIDE SUPPLEMENTAL INFORMATION FORM 2000-700 09-94 1. Facility name: AFCO Steel, LLC. 2. Facility identification code: CO /123/0488 3. This form supplements Form 2000 - 605 for Emission Unit (e.g. B001, P001, etc.) P001 Additional Information, Diagrams Item Number AFC0 Steel, LLC. Will not be subject to Subpart MMMM due to the Federally Enforceable Synthetic HAP Minor Source status Coatings containing chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) are not currently, and will not be used in the future. Therefore, Subpart HHHHHH is not applicable to AFC0 Steel, LLC. 40 CFR 63 Subpart MMMM 40 CFR 63 Subpart HHHHHH 44 Operating Permit Application Colorado Department of Health Air Pollution Control Division TABULATION OF PERMIT APPLICATION FORMS Jollity Name: AFC° Steel- L ADMINISTRATION Facility Identification Code: CO/123/0488 FORM 2000-800 09-94 This application contains the Ibllowing forms: ■ Form 2000-1(10, Facility Identification • Form 2000-101, Facility Plot Plan • Forms 2000-102. -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler. orintine a Form 2000-200. Stack Identification 4 ❑ Form 2000-300, Boiler or Furnace Operation ❑ Form 2000-301, Storage"Tanks ❑ Form 2000-302, Internal Combustion Engine ❑ Form 2000-303, Incineration ❑ Form 2000-304, Printing Operations • Form 2000-305, Painting and Coating Operations 1 • Form 2000-306, Miscellaneous Processes 3 ❑ Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following foams: ❑ Foam 2000-400. Miscellaneous ❑ Foam 2000-401, Condensers ❑ Foam 2000-402. Adsorbers ❑ Foam 2000-403, Catalytic or Thermal Oxidation ❑ Foam 2000-404, Cyclones/Settling Chambers ❑ Foam 2000-405, Electrostatic Precipitators ❑ Form 2000-406, Wet Collection Systems • Form 2000-407, Baghouses/Fabric Filters 1 Id. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the folknving forts (one for each facility boiler, printing operation, CtC.I: • Form 2000-500, Compliance Certification - Monitoring and Reporting 4 ❑ Form 2000-501, Continuous Emission Monitoring ❑ Form 2000-502, Periodic Emission Monitoring Using Portable Monitors • Form 2000-503, Control System Parameters or Operation Parameters of a Process 3 • Form 2000-504, Monitoring Maintenance Procedures 1 ❑ Form 2000-505, Stack Testing ❑ Foam 2000-506, Fuel Sampling and Analysis • Form 2000-507, Recordkeeping 4 ❑ Form 2000-508, Other Methods 45 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number orT his Form "his application contains the following forms ,tuantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan ■ Form 2000-600, Emission Unit Hazardous Air Pollutants 2 • Form 2000-601, Emission Unit Criteria Air Pollutants 4 • Form 2000-602, Facility Hazardous Air Pollutants 1 • Foot 2000-603, Facility Criteria Air Pollutants 1 • Form 2000-604, Applicable Requirements and Status of Emission Unit 4 • Foam 2000-605, Permit Shield Protection Identification 1 • Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 1 ❑ Form 2000-607, Plant -Wide Applicable Requirements ❑ Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application inquiry, I certify that the statements 3. CERTIFICATION OF FACILITY box only) • I certify that the facility applicable requirements. in its entirety and, based on information and belief formed after reasonable and information contained in this application are true, accurate and complete. COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one described in this air pollution permit application is fully in compliance with all described in this air pollution permit application is fully in compliance with all except for the following emissions unit(s): • I certify that the facility applicable requirements, (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Joe IIonesto Title Plant Manager Signature Date Signed 46 erasing Permit Application .u00-800 Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 09-94 Facility Name: Facility Identification Code: CO VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application certify that the statements and information B. CERTIFICATION OF FACILITY only) ■ I certify that the facility applicable requirements. in its entirety and, based on information and belief formed after reasonable inquiry, I contained in this application are true, accurate and complete. COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box described in this air pollution permit application is fully in compliance with all described in this air pollution permit application is hilly in compliance with all except for the following emissions unit(s): • I certify that the facility applicable requirements, (list all non -complying units) NARNING: Any person who knowingly, as defined in $ 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Joe Honesto Title Plant Manager Signature Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CIIERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 47 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS SUMMARY FORM 1. FACILITY NAME: AFCO Steel. LLC 2. PERMIT: 990PWE213 3. REVIEW ENGINEER: 4. DATE OF APPLICATION: 5. DATE RECEIVED BY APCD COMPLETENESS DETERMINATION I. IDENTIFYING INFORMATION II. EMISSIONS III. APPLICABILITY IV. COMPLIANCE COMPLETE _ INCOMPLETE _ NOT APPLICABLE COMPLETE INCOMPLETE _ NOT APPLICABLE COMPLETE - INCOMPLETE _ NOT APPLICABLE COMPLETE INCOMPLETE NOT APPLICABLE APPLICATION FORM CERTIFIED FOR TRUTH, ACCURACY, AND COMPLETENESS BY: OFFICIAL TITLE SIGNATURE DATE APPLICATION EVALUATION _ COMPLETE (BASIC INFORMATION PRESENT TO BEGIN PROCESSING) INCOMPLETE - RETURN WITH ADDITIONAL INFORMATION BY: COMMENTS REVIEWED BY: DATE 48 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS CHECK LIST IDENTIFYING INFORMATION COMPLETE _ INCOMPLETE _ NOT APPLICABLE A. FACILITY INFORMATION FACILITY NAME, LOCATION & MAILING ADDRESS PERMIT CONTACT PERSON RESPONSIBLE OFFICIAL PERMIT REQUESTED B. SOURCE DESCRIPTION YES NO YES NO YES NO YES NO 1. OPERATIONAL INFORMATION: _ YES _ NO SIC/SCC CODES YES _ NO LISTING AND DESCRIPTION OF EMISSION SOURCE(S) YES _ NO 2. IDENTIFICATION AND DESCRIPTION OF ALTERNATIVE OPERATIVE SCENARIOS (IF APPLICABLE) _ YES _ NO N/A C. PERMIT SHIELD REQUESTED YES NO II. EMISSIONS _ COMPLETE INCOMPLETE _ NOT APPLICABLE A. EMISSIONS INFORMATION 1. QUANTIFICATION OF ALL EMISSIONS OF REGULATED AIR POLLUTANTS YES _ NO 2. EMISSION SOURCES: IDENTIFICATION AND DESCRIPTION OF ALL EMISSION SOURCES IN SUFFICIENT DETAIL TO - YES _ NO ESTABLISH THE BASIS FOR FEES AND APPLICABILITY OF REQUIREMENTS. A LIST OF INSIGNIFICANT EMISSIONS UNITS OR ACTIVITIES EXEMPTED _ YES _ NO N/A BECAUSE OF SIZE OR PRODUCTION RATE. 4. PROCESS INFORMATION TO THE EXTENT IT IS NEEDED TO DETERMINE OR REGULATE EMISSIONS: FUELS YES _ NO _ N/A RAW MATERIAL(S) / MATERIALS USED YES _ NO _ N/A PRODUCTION RATES _ YES _ NO _ N/A 5. FOR REGULATED AIR POLLUTANTS, LIMITATIONS ON SOURCE OPERATIONS AFFECTING: EMISSIONS YES _ NO _ N/A ANY WORK PRACTICE STANDARDS YES _ NO _ N/A 6. OTHER INFORMATION REQUIRED BY ANY APPLICABLE REQUIREMENTS FOR ALL REGULATED AIR POLLUTANTS SUCH AS: FLOW RATES YES NO _ N/A STACK PARAMETERS YES NO N/A 7. CALCULATIONS ON WHICH EMISSIONS RELATED INFORMATION ARE BASED _ YES _ NO _ NIA III. APPLICABILITY COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS 2. OTHER SPECIFIC INFORMATION THAT MAY BE NECESSARY TO IMPLEMENT AND ENFORCE OTHER APPLICABLE REQUIREMENTS OR TO DETERMINE THE APPLICABILITY OF REQUIREMENTS YES NO YES NO 3. AN EXPLANATION OF ANY PROPOSED EXEMPTIONS FROM OTHERWISE APPLICABLE REQUIREMENTS _ YES _ NO _ N/A 49 IV. COMPLIANCE COMPLETE _ INCOMPLETE _ NOT APPLICABLE COMPLIANCE STATUS 1 A DESCRIPTION OF THE COMPLIANCE STATUS OF THE SOURCE WITH RESPECT TO ALL YES NO APPLICABLE REQUIREMENTS 2. FOR APPLICABLE REQUIREMENTS WITH WHICH THE SOURCE IS IN COMPLIANCE, A STATEMENT YES NO THAT THE SOURCE WILL CONTINUE TO COMPLY WITH SUCH REQUIREMENTS 3. FOR APPLICABLE REQUIREMENTS THAT WILL BECOME EFFECTIVE DURING THE PERMIT TERM, _ YES _ NO _ N/A A STATEMENT THAT THE SOURCE WILL MEET SUCH REQUIREMENTS ON A TIMELY BASIS 4. FOR REQUIREMENTS FOR WHICH THE SOURCE IS NOT IN COMPLIANCE AT THE TIME OF _ YES _ NO _ N/A PERMIT ISSUANCE, A NARRATIVE DESCRIPTION OF HOW THE SOURCE WILL ACHIEVE COMPLIANCE WITH SUCH REQUIREMENTS 5. IDENTIFICATION AND DESCRIPTION OF AIR POLLUTION CONTROL EQUIPMENT AND COMPLIANCE _ YES _ NO MONITORING DEVICES OR ACTIVITIES 6. DESCRIPTION OF OR REFERENCE TO ANY APPLICABLE TEST METHOD FOR DETERMINING YES NO COMPLIANCE WITH EACH APPLICABLE REQUIREMENT B. COMPLIANCE SCHEDULE COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. A SCHEDULE OF COMPLIANCE FOR SOURCES THAT ARE NOT IN COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS AT THE TIME OF PERMIT ISSUES YES NO N/A 2. A SCHEDULE FOR SUBMISSION OF CERTIFIED PROGRESS REPORTS NO LESS FREQUENTLY . YES NO _ N/A THAN EVERY SIX MONTHS FOR SOURCES REQUIRED TO HAVE A SCHEDULE OF COMPLIANCE TO REMEDY A VIOLATION C. COMPLIANCE CERTIFICATION COMPLETE INCOMPLETE NOT APPLICABLE 1. CERTIFICATION OF COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS BY A RESPONSIBLE OFFICIAL 2. A STATEMENT OF METHODS USED FOR DETERMINING COMPLIANCE, INCLUDING A DESCRIPTION OF MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS AND TEST METHODS 3. A SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS 4. A STATEMENT INDICATING THE SOURCE'S COMPLIANCE STATUS WITH ANY APPLICABLE ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS OF THE FEDERAL ACT YES NO YES NO YES NO YES NO 50 AECOM Environment Attachment C Emission Calculations September 2012 re `?JX A ap,' 4.X '' XO� �9,/A0 f/ ii.,„ 441'14 1 /i vvt ::" e M _ 7.7 3 boner nx:thr I 5101 I I 32500 I 740.00 I 1421.1.1111 I 11.00 [ 105.00 I 0.110 I OAII I 0.00 I 0.110 I 0.1117 0.110 I 0.00 I 0.00 I 0.00 1 0.00 I 1315.00 SOLVENTS 1`dfml TnuuoI Acetone I 20101_1 .W I O.00 110001XII 0.00 11 017 11.0(11L00 11 �iL00I 0.11.WW 0.00WI 0.000.10) r1U011h1 0.WW 0.WINI 0.11001101 11.110 (1.1111 0-101 0.10111/1 0.110 0.001 A___:.===aa - o= o 6 A 7-7 •1 = - o - 0 0 _ ' = o= - c 0 0000d00E 2 c E = P _ c c a n i H a_ a o c C g a _ o�la Yi 3S3 s Yia a. aa,s solo€_ 3_ _ a= to 3`d 4„,0IIIi. oy 6 _ ..ry ¢ E 6 PSX 700 B54W101 Enamel B5[N Z6 Kern K ror_i ik 055NR Steel Spec 2 is t v✓ v H? N v v� x l - 6 v c . AFCO Steel, LLC Particulate Matter Emissions from Coating and Cleaning Processes articulate Emissions from Rotoblasters Hourly Exhaust PM10' x Exhaust Rate (gr/scf) (scfh) 0.02 x 480000 Annual Annual Emissions 2000 (lbs/hr) (lb/ton) 1.371 + 2000 x 4380 Indoor Abrasive Blasting Annual Annual Usage (tons/yr) 7000 (gr/lb) 7000 = 1.371 x 4380 (hours/yr) x Emission Factor + (lb/ton abrasive) (lb/ton) 2000 15 x 2.6 - 2000 Hourly Annual Emissions x (tons/yr) Emission Rate (lbs/hr) Emission Rate (tons/yr) = 3.003 Emission Rate (tons/yr) 0.0195 2000 - 104 = Emission Rate (lb/ton) (hours/yr) (lbs/hr) 0.0195 x 2000 Particulate Emissions from Painting Operations 104 0.375 Annual Paint Usage Average Paint 1 - Transfer Annual (gal/yr) x Density x Efficiency" (lb/gal)3 12600 x 14.90 x 0.65 Hourly Annual Emissions x 2000 + 4380 (tons/yr) (lb/ton) (hours/yr) 6.10 x 2000 + 4380 1 - Building x Reductions x 0.1 Emission Rate (lbs/hr) 2.79 PM2.5 (tons/yr) 0.30 Emission Rate = (Ibs/yr) 12203 Emission Rate (tons/yr) 6.10 Assumed outlet grain loading based on other equipment produced by Wheelabrator (no longer in business) s Emission factor from AP -42, Table 13.2.6-1, abrasive blasting of mild steel panels, taking into account a 90% reduction due to blasting inside of a warehouse. 3 Based on the density of the paints most commonly used at AFCO Steel Graco Silver Plus Airless Gun. Transfer efficiency 35% according to the manufacturer Painting is conducted indoors. Engineering estimate of 90% containment of overspray. co c 0 C 0 0 C O Ucj J E . LLI TD 0 SP re O E u- v a Emission Factor Source IAP-42 Section 12.19 IAP-42 Section 12.19 IAP-42 Section 12.19 IAP-42 Section 12.19 1 IAP-42 Section 12.19 [AP -42 Section 12.19 AP -42 Section 12.19 fume lb/lb T. CD cc � co I 0.0122 0.0122 cc dNrrr 0 0 0 0 0 0 6 0 0 0 MSDS % z c CC 0 CONSUMED HAP EMISSION FACTOR(.1LB/1000LB OF ELECTRODE USED) LBS I CR(VI) I Mn Ni l Pb 0 00 0 I. 0.51 0 c o 000 o CO rn O) T CO 2O . O Co O CON O N (D CD . O O V 6 o o O o M ELECTRODE L TYPE 7i om o c 0 HF(0 yW W W M LL W - W 00 co POUNDS EMITTED Z O N O O O O O N Co O O O LU O O O O 0 M 0 O O cc C 0 ro co O 0 m n 0 0 cc uo o O 0 K 0 0 0 0 0 0 0 0 0 O 0 0 0 O op op O O N N O O O cc N W O O O O O O O co 0 0 0 cD W co 0 W co 0 cc W U) J cc Co F N W r 0 W U) U) J tD Co Q 0 r 0 r AFCO Steel, LLC Pressure Washer Heater Emissions Emission Source: Source Type: Heater Rating Heating Value Diesel Annual Hours of Operation Pollutant Factor Ib/kgal Pressure Washer Heater External Combustion 385000 Btu/hr 137,000 Btu/gal Avg. Ibs/hr' 104 hours/year Total tonslyr2 Source of Factor CRITERIA i NO, 20.00 0.06 0.00 AP -42, Table 1.3-1, 5/10 CO 5.00 0.01 0.00 AP -42, Table 1.3-1, 5/10 PM10 1.08 0.00 0.00 AP -42, Table 1.3-7, 5/10 PM2.5 0.83 0.00 0.00 AP -42, Table 1.3-7. 5/10 SO2 0.00 0.00 0.00 AP -42, Table 1.3-1, 5/10 VOC 0.34 0.00 0.00 AP -42, Table 1.3-3, 5/10 R = Formaldehyde (lb/MMBtu) 0.06100 0.0002 0.0000 AP -42 Table 1.3-8 (9/98) Total HAP 0.0002 0.0000 Notes: 1 Hourly Emission Rate (Lbs/Hr) = (Emission Factor, Lb/kgal) " (1 kgal/1000 gal) " (Heater Rating, Btu/hr) / (137000 Btu/gal) 2 Annual Emission Rate (Tons/Yr) = (Hourly Emission Rate, LbslHr) " (Hour of Operation Per Year, Hr/Yr) / (2,000 lbs/ton) AFCO Steel, LLC — Title V Modification and Renewal Application Sample Emission Calculations - Coating VOC and HAP All VOC and HAP emission calculations are made with the assumption that 100% of the solvents in the coating evaporate. VOC and HAP content are obtained from the MSDS. Emissions are calculated using an Excel spreadsheet. Two part paints are calculated similarly to one part paints, however, the two parts are converted into a representative one part prior to entry into the spreadsheet. Example Single Part Paint Calculation: Sherwin-Williams B50WZ0004 Kem Bond® HS Unthinned 1000 gallons annual usage Paint Data per the MSDS: VOC Content: 2.61 lb/gal Paint Density: 13.76 lb/gal HAPs: Ethylbenzene — 2% by weight Xylene - 9% by weight Total VOC Emissions: VOC (lb/gal) x Usage (gal/yr) - 2000 (lb/ton) = Emissions (tpy) 2.61 x 1000 = 2000 = 131 tpy HAP Emissions: Wt % HAP x Paint Density (lb/gal) x Usage (gallyr) - 2000 (lb/ton) = Emissions (tpy) Ethylbenzene: 0.02 x 13.76 x 1000 - 2000 = 0.138 tpy Xylene: 0.09 x 13.76 x 1000 = 2000 = 0.619 tpy AFCO Steel, LLC — Title V Modification and Renewal Application Example Two -Part Paint Conversion: Sherwin-Williams B67A5 Recoatable Epoxy Primer Unthinned 1000 gallons annual usage From the Product Information Sheet: Mixing Ratio: 1:1 Mixed VOC (unthinned): 2.67 lb/gal From the Part A MSDS VOC Content: 2.61 lb/gal Paint Density: 13.76 lb/gal HAPs: Ethylbenzene — 2% by weight Xylene - 12% by weight From the Part B MSDS VOC Content: 2.19 lb/gal Paint Density: 12.70 lb/gal HAPs: Ethylbenzene — 2% by weight Xylene - 9% by weight Calculations: Mixed Product Density: (Ratio A x Density A + Ration B x Density B)/( Ratio A + Ratio B) (1 x 13.76 + I x 12.7)/2 = 13.23 lb/gal Mixed HAP Content: ((Wt % HAP A x Density A x Ratio A) + (Wt % HAP B x Density B x Ratio B) (Mixed Density x (Ratio A + Ratio B)) Xylene: ((0.12 x 13.76 x 1) + (0.09 x 12.7 x 1)) / (13.23 x 2) = 0.1056 (10.56%) 7/12/2016 State.co.us Executive Branch Mail - AFCO Steel, LLC Permit 99OPWE213 Renewal Draft Comments STATE OF COLORADO Dummer - CDPHE, Nicholas <nicholas.dummer@state.co.us> AFCO Steel, LLC Permit 99OPWE213 Renewal Draft Comments Loni Gaudet <loni@enviro-senseinc.com> Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, "Honesto, Joe" <jhonesto@afcosteel.com> Dear Mr. Dummer, Thu, May 19, 2016 at 12:03 PM Thank you for providing us the opportunity to review and comment on the draft Title V renewal air permit. We have outlined our comments and concerns below, as well as in the comments attached to the draft permit. Permit Location Reference Remarks Draft Permit Section II, Condition 1 • There is a broken link in the table under Condition 1. • In what manner is "Material restriction" intended to reduce opacity? • Please note that we will be sending a request to designate Carboline's CZ -11 FG coating as a high-performance coating and have it included in the permit as an acceptable use coating. Draft Permit Section II, Condition 1.1 • What is the reason to include the calculation of TSP in the permit when PM1 0 is also included? • Condition 1.1 discusses compliance with NESHAP Subpart 6H, but doesn't address NESHAP 6X. Since the facility's SIC code places them under NESHAP 6X, that is the rule they would have to comply with IF they were to trigger the surface coating requirements of the rule. Draft Permit Section II, Condition 1.3 Please note that we will be sending a request to designate Carboline's CZ -1 1 FG coating as a high-performance coating and have it included in the permit as an acceptable use coating. Draft Permit Section II, Condition 1.3.4 We request that the Division clarify this condition by stating that the Permittee is not required to use the forms shown in ""Recordkeeping Guidance Document for Surface Coating Operations and the Graphic Arts Industry," July 1989." The Permittee has spent significant time and money to develop the recordkeeping system currently in place. This recordkeeping system, along with equipment records and MSDS, includes the information listed in Section 3.1 of the document. Draft Permit Section II, Condition 1 .3.5 We request that the Division include the option in Condition 1.3.5 to use manufacturer's data in determining compliance with Condition 1.3. https://mai I.google.com/mail/u/0f?ui=2&i k=bad53d0f2f&view=pt&cat=DON OTD ELETE%2FAFCO%20Steel&search=cat&msg=154ca30373cb6683&sim I=154c... 1/4 7/12/2016 State.co.us Executive Branch Mail - AFCO Steel, LLC Permit 99OPWE213 Renewal Draft Comments Draft Permit Section II, Condition 2.1 There is a space missing between "above" and "(95WE890)." Draft Permit Section II, Condition 2.3 The first word of the second sentence needs to be capitalized. TRD, Page 4, Item 4 Draft Permit Section II, Condition 3.1.4.1 We request that the Division clarify, either in the TRD or in the permit, that the facility complies with the standards and management practices outlined in 40 CFR 63.11516(f) and is not required to use capture and control devices. The Permittee will comply with the requirement of §63.1 1 516(f)(1) by operating all welding equipment according to the manufacturer's instructions. This clarification is related to the next comment, below. Draft Permit Section II, Condition 3.1.4.2 The requirement is for the source to "implement one or more of the following management practices..." The Permittee uses shielding gases to reduce welding fume generation (§63.1 1516(f)(2)(c)) Permit Condition 3.1.4.2.d ends in "and," implying either that the Permittee is supposed to comply with all of the management practices a — e, or that if the Permittee is complying with d, that they must also comply with e. If the former, the "and" should be an "or." Either interpretation is contrary to "one or more of the following..." Unfortunately, the rule is written with the same language. We request that the state clarify the permit so that it is not open to interpretation. Draft Permit Section III Condition 1 40 CFR 63 Subpart 6H should be included in the shield for the following reasons: 1. NESHAP 6X would be the applicable rule, IF triggered, due to the facility SIC code. 2. Until and if the Permittee uses a coating containing MFHAP in amounts above the threshold, neither rule is applicable. TRD, Page 4, Item 2 And TRD, Page 5, Third We request that the TRD clarify that compliance with NESHAP Subpart 6X demonstrates compliance with NESHAP Subpart 6H, IF either were to be triggered. https://mat Lgoogle.com/mail/u/0f?ui=2&i k=bad53d0f2f&view= pt&cat=0ONOTDELETE% 2FAFCO % 20Steel&search=cat&msg=154ca30373ch6683&sim l= 154c... 2/4 7/12/2016 Paragraph State.co.us Executive Branch Mail - AFCO Steel, LLC Permit 99OPWE213 Renewal Draft Comments Since the facility's SIC code places them under NESHAP 6X, that is the rule they would have to comply with. Per 40 CFR 63.11514(b)(4): " Affected source(s) subject to the requirements of this paragraph are not subject to the miscellaneous surface coating provisions of subpart HHHHHH of this part, "National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources."" (There is no intention to use any coating that contains MFHAP/MHAP in amounts that would trigger either of these rules for the coating operations.) TRD, Page 5, First Paragraph Please insert "40 CFR 63" prior to "Subpart XXXXXX" for clarity. Should you have any questions or require any additional information, please call me at the number below. Sincerely, Loni Gaudet (on behalf of AFC0 Steel, LLC) Loni M. Gaudet Enviro-Sense, Inc. Project Manager Cell: 985-966-3832 Loni@enviro-senseinc.com https:/fmail.google.com/mai I/u/0/?ui=2&ik=bad53d0f2f&view=pt&cal=DONOTDELETE%2FAFCO%20Steel&search=cat&msg=154calM73cb6663&sim1=154c... 3/4 7/12/2016 State.co.us Executive Branch Mail - AFCO Steel, LLC Permit 99OPWE213 Renewal Draft Comments o nvlist! This email has been checked for viruses by Avast antivirus software. www.avast.com 99OPWE213 Renewal 2 Draft (LMG Comments).docx 1502K https://mail.google.com/maillui0Pui=26.ik=bad536O21&view= pt&cat= DONOTDELETE%2FAFCO%20Steel&search=cat&ms 154ca30373cbRaFtlXsim1=154c... 4/4 7/12/2016 State.co.us Executive Branch Mail - Questions from AFCO STATE OF COLORADO Questions from AFCO 9 messages Dummer - CDPHE, Nicholas <nicholas.dummer@state.co.us> Loni Gaudet <loni@enviro-senseinc.com> Tue, Mar 29, 2016 at 1:35 PM Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, "Burgett - CDPHE, Matt" <matt.burgett@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Nick, Matt and Jeffrey, I just finished a conference call with AFCO, and they have a few questions for you (in addition to my questions in yesterday's email). 1) We need to send a formal notification to CDPHE regarding the coating VOC issue. To whom should that be sent? 2) How was the regulated community notified of the changes to Reg 7? They are curious as to why they weren't notified. I explained that most states notify through the newspapers because it's cost prohibitive to try to notify every regulated entity. 3) Are there any email lists that they (and I) can subscribe to for rule change notifications from CDPHE? 4) What is the time frame for CDPHE to make a decision about an exemption for the coating, and do you need more information? 5) Can you please help me understand if there will be another renewal application due within the next year, or if the deadline will be based on the issue date of the current renewal? Thank you, Loni Loni M. Gaudet Enviro-Sense, Inc. Project Manager Cell: 985-966-3832 Loni@enviro-senseinc.com o uunst! This email has been checked for viruses by Avast antivirus software. www.avast.com Burgett - CDPHE, Matt <matt.burgett@state.co.us> Wed, Mar 30, 2016 at 8:23 AM https://m ail.google.com/mail/W0l?ui=28ik=bad53d0f2F&view=pt&cat=DONOTDELETE%2FAFCO°/ 20Steel&search=cat&th= 153c3e054070b23b&sim I=153c3e0... 1/9 7/12/2016 State.co.us Executive Branch Mail - Questions from AFCO To: "Wojtach, Dena" <dena.wojtach@state.co.us>, Leah Martland - CDPHE <leah.martland@state.co.us>, Sean Hackett - CDPHE <sean.hackett@state.co.us> Cc: Nicholas Dummer- CDPHE <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Reg Dev group, Can one of you respond to me with answers to questions #2 & #3 below please. Background: AFCO was outside the 1 - hr ozone AMA, but is now within the 8 -hr ozone NAA and they are now subject to some Reg. 7 metal surface coating requirements which they are not currently in compliance with. They want some information about notifications on rule changes. Thanks and let me know if you have questions. Matt Burgett, P.E. Title -V Operating -Permits Unit -Supervisor - Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Health b Er Mronrnent P 303.692.3183 4300 Cherry Creek Drive South, Denver, CO 80246-1530 matt.burgett@state.co.us I wWN.colorado.gov/cdphe/aped As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or Incomplete APENs. Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section II. A). Current APEN forms can be found at: https://wwwco/orado.gov/cdphe/APENforms [Quoted text hidden] Burgett - CDPHE, Matt <matt.burgett@state.co.us> Wed, Mar 30, 2016 at 8:29 AN To: Loni Gaudet <loni@enviro-senseinc.com> Cc: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Hi Loni, I forwarded you questions on the Reg changes to our Reg Development group and will forward their answers to you. AFCO's next Title V renewal application will not be due until four years after we issue this current renewal. I should be able to respond to your other questions by the end of this week. Matt Burgett, P.E. Title V Operating Permits Unit Supervisor Stationary Sources Program COLORADO Air Pollution Control Division Department or Puio,ic Health H Environment P 303.692.3183 4300 Cherry Creek Drive South, Denver, CO 80246-1530 matt.burgett@state.co.us I v.a w.colerado.govlcdphe/aped As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section 11.A). Current APEN forms can be found at: hltps://wwwcolorado.gov/cdphe/APENforrns [Quoted text hidden] https://mail.googie.com/mail/u/0nui=2&ik=bad5360f2f&view=pt&cat--DON OTD ELETE/02FAFCO%20Steel&search=cat&th=153c3e054070b23b&sim I=153c3e0... 2/9 7/12/2016 State.co.us Executive Branch Mail - Questions from AFCO Hackett - CDPHE, Sean <sean.hackett@state.co.us> Wed, Mar 30, 2016 at 2:40 PM To: "Burgett - CDPHE, Matt" <matt.burgett@state.co.us> Cc: "Wojtach, Dena" <dena.wojtach@state.co.us>, Leah Martland - CDPHE <leah.martland@state.co.us>, Nicholas Dummer - CDPHE <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Matt, Please see our responses below and let me know if you have any questions. Sincerely, Sean Hackett Regulatory Development and Outreach Planning and Policy Program COLORADO Air Pollution Control Division Department of Public Health 5 Environment P 303.692.3131 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246-1530 sean.hackett@state.co.us I www.colorado.00v/cdohe/apcd On Wed, Mar 30, 2016 at 8:23 AM, Burgett - CDPHE, Matt <matt.burgett@state.co.us> wrote: Reg Dev group, Can one of you respond to me with answers to questions #2 & #3 below please. Background: AFCO was outside the 1 -hr ozone AMA, but is now within the 8 -hr ozone NAA and they are now subject to some Reg. 7 metal surface coating requirements which they are not currently in compliance with. They want some information about notifications on rule changes. Thanks and let me know if you have questions. Matt Burgett, P.E. Title V Operating Permits Unit Supervisor Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Health & Environment P 303.692.3183 4300 Cherry Creek Drive South, Denver, CO 80246-1530 matt.burgett@state.co.us I wvnv.colorado.gov/cdohe/apcd As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if on APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section ll.A). Current APEN forms can be found at: hitps://wwwcolorado.gov/cdphe/APENforms ------ Forwarded message ----- From: Loni Gaudet <loni@enviro-senseinc.com> Date: Tue, Mar 29, 2016 at 1:35 PM Subject: Questions from AFCO To: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, "Burgett - CDPHE, Matt" <matt.burgett@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Nick, Matt and Jeffrey, https:Nmai I.google.com/mai I/u/0nui=2&ik=bad5360f2f&view=pt&cat=DON OTD ELETE"/ 2FAFCO%20Steel&search=cat&th=153c3e054070b23b&sim I=153c3e0... 3/9 7/12/2016 State.co.us Executive Branch Mail - Questions from AFCO I just finished a conference call with AFCO, and they have a few questions for you (in addition to my questions in yesterday's email). 1) We need to send a formal notification to CDPHE regarding the coating VOC issue. To whom should that be sent? 2) How was the regulated community notified of the changes to Reg 7? They are curious as to why they weren't notified. I explained that most states notify through the newspapers because it's cost prohibitive to try to notify every regulated entity. Whenever there is a rulemaking or adjudicatory hearing, notice is published in the legal ads of the Denver Post as well as on the Air Quality Control Commission's website and email list (https://www.colorado.gov/pacific/cdphe/aqcc-past- 12-months-meeting-documents-hearing-notices). Additionally, notice is published by the Secretary of State (http://www.sos.state.co.us/pubs/rule_making/rules.html; http://www.sos.state.co.us/pubs/CCR/CCRHome.html) and the Department of Regulatory Agencies. For that specific regulatory change, the Division participated in formal and informal stakeholder processes through both the Air Quality Control Commission and the Regional Air Quality Council. In addition, the Division's Small Business Assistance Program conducted outreach meetings, mass -mailed brochures and published a guidance document on ozone nonattainment area implications for business (https://www.colorado.gov/ pacific/sites/default/files/A P_Ozone-Nonatta i nment-Area-Implications-For-B us i ness es. pdf). 3) Are there any email lists that they (and I) can subscribe to for rule change notifications from CDPHE? To subscribe to any of the Division's email lists (including ozone), please visit https://www.colorado. gov/pacific/cdphe/air-mailing-Iists.To subscribe to the Commission's email list, please email them at cdphe.aqcc- comments@state.co.us. You will need to contact DORA and the RAQC directly if you'd like to subscribe for their email lists as well. 4) What is the time frame for CDPHE to make a decision about an exemption for the coating, and do you need more information? 5) Can you please help me understand if there will be another renewal application due within the next year, or if the deadline will be based on the issue date of the current renewal? Thank you, Loni Loni M. Gaudet Enviro-Sense, Inc. Project Manager Cell: 985-966-3832 Loni@enviro-senseinc.com n nvnst! This email has been checked for viruses by Avast antivirus software. L- www.avast.com https://mail.google.com/maiVW0f?ui=2&i k=bad53d0f2f&view=pt&rat=DONOTDELETE%2FAFC O%20Steel&search=cat&th=153c3e054070b23b&si m1=153c3e0... 4/9 7/12/2016 State.co.us Executive Branch Mail - Questions from AFCO Wojtach - CDPHE, Dena <dena.wojtach@state.co.us> Wed, Mar 30, 2016 at 4:11 PM To: "Hackett - CDPHE, Sean" <sean.hackett@state.co.us> Cc: "Burgett - CDPHE, Matt" <matt.burgett@state.co.us>, Leah Martland - CDPHE <leah.martland@state.co.us>, Nicholas Dummer - CDPHE <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> FYI, SBAP's efforts targeted all stationary sources and not just small businesses. Thanks, Dena Dena Wojtach Regulatory Compliance Support Unit Supervisor Planning and Policy Program P 303.692.3147 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246-1530 dena.wojtach@state.co.us I www,coEorado.aav/cdphe/apcd El [Quoted text hidden] Burgett - CDPHE, Matt <matt.burgett@state.co.us> Fri, Apr 1, 2016 at 4:46 PM To: Loni Gaudet <loni@enviro-senseinc.com> Cc: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Hi Loni, I will try to respond to all your questions in this email. Please respond if I missed something or you have additional questions. 1. If you want to self -report that you are not in compliance with the Reg. 7 coating limit, please send that to Shannon McMillan, Compliance & Enforcement Program Manager. 2. Whenever there is a rulemaking or adjudicatory hearing, notice is published in the legal ads of the Denver Post as well as on the Air Quality Control Commission's website and email list (https://www.colorado.gov/pacific/cdphe/agcc-past-12- months-meeting-documents-hearing-notices). Additionally, notice is published by the Secretary of State (http://www.sos.state.co.us/pubs/rule_making/rules.html; http://www.sos.state.co.us/pubs/CCR/CCRHome.html) and the Department of Regulatory Agencies. For that specific regulatory change, the Division participated in formal and informal stakeholder processes through both the Air Quality Control Commission and the Regional Air Quality Council. In addition, the Division's Small Business Assistance Program conducted outreach meetings, mass -mailed brochures and published a guidance document on ozone nonattainment area implications for business (https://www.colorado.gov/ pacific/sites/default/files/AP_Ozone-Nonattai nment-Area-I mplications-For-Businesses.pdf). ications-For-B usi nesses. pdf). 3. To subscribe to any of the Division's email lists (including ozone), please visit https://www.colorado. gov/pacific/cdphe/air-mailing-lists.To subscribe to the Commission's email list, please email them at cdphe.aqcc- comments@state.co.us. You will need to contact DORA and the RAQC directly if you'd like to subscribe for their email lists as well. 4. I also took a look at the Technical Review Document (TRD) associated with the October 1, 2008 Title V issuance. The TRD clearly identified that Reg. 7, IX would soon apply to AFCO (see text below). AFCO was supplied with this TRD during source review of the draft permit and it is publicly available on the Division's website. I believe AFCO was subject to the surface coating limitations as of 12/12/2008. Regulation No. 7 Applicability https://mai l.google.com/mail/u/0/?ui=2&ik=bad53d0f2r&view=pt&cat=DONOTDELETE%2FAFCO%20Steel&search=cat&th=153c3e054070b23hAsim I=153c3e0... 5/9 7/1 212 01 6 State.co.us Executive Branch Mail - Questions from AFCO The surface coating operation was evaluated to determine if the Regulation No. 7 requirements for surface coating operations would apply (Regulation No. 7, IX.L — Manufactured Metal Parts and Metal Products). This operation meets the applicability requirements of Reg. 7, IX.L.1.(a).8 since it coats metal products under the SIC code of major group 34. However, Reg. 7, I.A.1.a states that the requirements apply to the Denver 1 -hour ozone attainment/maintenance area, and to any non -attainment area for the 1 -hour ozone standard. This facility is located outside these areas. Yet, it is located within the 8 -hour ozone nonattainment area. Regulation No. 7 will be modified at some point to apply to sources within any ozone non -attainment area. At that point, this facility will be required to meet the requirements of No. 7, IX.L. Requirements will include: • Fugitive emission control techniques and work practices (Reg. 7, IX.A.7.a) • 3.5 lb of solvent VOC per gallon of coating (Reg. 7, IX.L.2.a(3)). 5. The Reg. 7 surface coating limits are typically established from EPA documents called Control Technique Guidelines (CTGs). These CTGs are EPA's suggestion on presumptive RACT limits that can be implemented in nonattainment areas. You can find the CTGs here: htt ps: //www. epa. gov/ozone-pol I ution/control-tec hniques-g uidel i nes-and-altemative-control-techniques-documents- reducing Nick and I took a look at the September 2008 CTG for Misc Metal & Plastic Parts Coating. We have not adopted this more recent CTG into Reg. 7 yet, however, it may inform our decision on whether AFCO's non compliant coating could be considered a High Performance Coating (since Reg. 7 does not contain a definition for High Performance). The 2008 CTG has a 6.2 lb/gal limit for High Performance Architectural coatings. The definition for this coating is: HIGH-PERFORMANCE ARCHITECTURAL COATING means a coating used to protect architectural subsections and which meets the requirements of the Architectural Aluminum Manufacturer Association's publication number AAMA 2604-05 (Voluntary Specification, Performance Requirements and Test Procedures for High Performance Organic Coatings on Aluminum Extrusions and Panels) or 2605-05 (Voluntary Specification, Performance Requirements and Test Procedures for Superior Performing Organic Coatings on Aluminum Extrusions and Panels). This CTG also has a limit of 3.5 lb/gal for Extreme Performance coatings which are defined as: EXTREME -PERFORMANCE COATING means a coating used on a metal or plastic surface where the coated surface is, in its intended use, subject to the following: (A) Chronic exposure to corrosive, caustic or acidic agents, chemicals, chemical fumes, chemical mixtures or solutions; or (B) Repeated exposure to temperatures in excess of 250° F; or (C) Repeated heavy abrasion, including mechanical wear and repeated scrubbing with industrial grade solvents, cleansers or scouring agents. Extreme performance coatings include, but are not limited to, coatings applied to locomotives, railroad cars, farm machinery, and heavy duty trucks. It still seems that AFCO's coating would fall under the definition of Extreme -Performance and be required to meet a 3.5 lb/gal limit. 6. If AFCO would like to request that the coating be considered high-performance and exempt, they should send that request to Nick for review. The request should contain information, support and justification as to why it should be considered high performance. I don't have a specific time frame for how long it will take APCD to make a decision as that will depend on what is submitted to support the request. 7. Another Title V renewal application will not be due until 4 years after we issue this next one. 8. Has AFCO contacted their client and the paint manufacturer to determine if an equivalent compliant coating is available or could be developed? I know that the paint manufacturers are aware that limitations like this exist and may be able to provide options to the current coating. This would be the best solution. 9. The only flexibility I could find in Reg. 7 for a longer averaging period was this (which would not be a fast solution): IX.A.10.a. Compliance with this section shall be determined on a daily basis. Sources may request a revision to the State Implementation Plan for longer times for compliance determination. 10. I believe AFCO could drop out of Title V permitting and be covered by a construction permit only. However, they would still need to comply with the Reg. 7 requirements. I assume this would be less costly to them in the long run since construction permits do not expire like Title V permits. As such, there would not be the need to apply for and obtain a Title V renewal permit every 5 years. We can draft and issue a revised construction permit for AFCO if that is their decision. Nick would need to draft the construction permit, but all the analysis is already done, so it should not be a large amount of additional time. Contact Nick if that is your decision and we can let you know what needs to be submitted. https://mail.google.com/mail/u/0Y?ui=2&ik=bad53d0r2r&view=pt&cat=DONOTDELETE°/ 2FAFCO%20Steel&search=cat&th=153c3e054070b23b&sim1=153c3e0... 6/9 7/12/2016 State.co.us Executive Branch Mail - Questions from AFC° 11. APCD's fee structure is set up such that we charge permit processing fees based on the number of hours it takes the engineer to process the permit application. This is established in Regulation No. 3. Part 70 also requires that Title V permit programs collect enough fees to fund themselves. I know Nick spent time researching the Reg. 7 and MACT issues at AFCO, as well as drafting the permit and TRD. The Division's fee structure is such that we must charge the applicant this time to recover those costs to pay for the Title V program. I don't feel that the time spent on this application was excessive. Reg. 3, Part A, VI.A.1. Every person required to obtain a Construction or Operating Permit or to file an Air Pollution Emission Notice shall pay fees as set forth in the following sections. Such fees shall be charged to recover the direct and indirect costs incurred by the Division in processing permit applications, issuing permits, and in conducting a compliance monitoring and enforcement program. Such fees shall apply without regard to whether a permit is issued, denied, withdrawn, or revoked. Fees shall be charged as indicated in Section VI.D. of this part. • Part 70 requires states to charge fees to cover the cost of the TV program, including: 70.9.b(iii) General administrative costs of running the permit program, including the supporting and tracking of permit applications, compliance certification, and related data entry; 70.9.b(iv) Implementing and enforcing the terms of any part 70 permit (not including any court costs or other costs associated with an enforcement action), including adequate resources to determine which sources are subject to the program; Hopefully I responded to all your questions. Let me know if you have more, Matt Burgett, P.E. Title V Operating Permits Unit Supervisor Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Health & Environment P 303.692.3183 4300 Cherry Creek Drive South, Denver, CO 80246-1530 matt.burgett@state.co.us I www.colorado.gov/cdphe/apcd As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section II.A). Current APEN forms can be found at: https://www colorado gov/cdphe/APENfo nns On Tue, Mar 29, 2016 at 1:35 PM, Loni Gaudet <loni@enviro-senseinc.com> wrote: [Quoted text hidden] Loni Gaudet <loni@enviro-senseinc.com> Mon, Apr 4, 2016 at 7:03 AM Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Burgett - CDPHE, Matt" <matt.burgett@state.co.us> Cc: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Thank you Matt, for the detailed and helpful response. I'll talk to Joe about this, and let you know what he decides to do with the permit and the coating. He'll probably need a few days to decide. Have a great day, Loni [Quoted text hidden] Loni Gaudet <loni@enviro-senseinc.com> Thu, Apr 14, 2016 at 7:56 AM Reply -To: Loni Gaudet <loni@envirosenseinc.com> https://mail.google.com/mail/u/0flui=2&ik=bad53d0f2f&view=pt&cat=DONOTDELETE%2FAFCO%20Steel&searcha--cat&th=153c3e054070b23b&siml=153c3e0... 7/9 7/12/2016 State.co.us Executive Branch Mail - Questions from AFCO To: "Burgett - CDPHE, Matt" <matt.burgett@state.co.us> Cc: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Matt, Nick and Jeffrey, AFCO has taken the time to evaluate their situation, and they have committed to not using any coatings with a VOC content greater than 3.5 lb/gal. I do not know if they found an alternative to the coating they were using or they moved that work to their Arkansas facility. I will prepare the self -report today, and get it to the client for submittal to CDPHE. AFCO didn't let me know -about dropping to a minor source permit. I'll clarify with them and get -back to you. Again, thank you all for your patience as they sort through their options and make clear, unhurried decisions which are best for their business and the environment. Regards, Loni Original Message ---- From: "Burgett - CDPHE, Matt" <matt.burgett@state.co.us> To: "Loni Gaudet" <loni@enviro-senseinc.com> Cc: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>; "Jeffrey Bishop - CDPHE" <jeffrey.bishop@state.co.us> Sent: 4/1/2016 4:46:05 PM Subject: Re: Questions from AFCO Hi Loni, [Quoted text hidden] [Quoted text hidden] Loni Gaudet <loni@enviro-senseinc.com> Thu, Apr 14, 2016 at 8:51 AM Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us> I'm sorry it's taking so long, but this is a big item for them and required careful consideration. They've decided to stick with the Title V permit for now, so if you're on hold you can probably get back to started again. Is there any other information you were waiting for? Loni Original Message ---- From: "Dummer-CDPHE, Nicholas" <nicholas.dummer@state.co.us> To: "Loni Gaudet" <loni@enviro-senseinc.com> Sent: 4/14/2016 8:48:49 AM Subject: Re: Re[2]: Questions from AFCO Thanks for your help Loni. Cheers, Nick [Quoted text hidden] Nicholas Dummer Title V Permit Engineer Operating Permits Unit Stationary Sources Program https://mai l.google.corn/mail/u/0/7ui=2&ik=bad53d0f2f&view=pt&cat=DONOTD ELETE%u2FAFCO%20Steel&search=cat&th=153c3e054070623h&sim 1=153c3e0... 8/9 7/12/2016 State.co.us Executive Branch Mail - Questions from AFCO COLORADO Air Pollution Control Division Department of Public Health & Environment P 303.692.3125 4300 Cherry Creek Drive South, Denver, CO 80246-1530 mailto:blue.parish@state.co.us i www.colorad000v/cdphe/aped As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an AP EN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section II.A}. If you need assistance, please refer to: https://••vww.colorado.gov/cdphe/APENforms o ❑vosu This email has been checked for viruses by Avast antivirus software. www.avast.com https://mail.google.cam/mail/u/0Pui=2&ik=bad53d0f2f&viev=pt&carDONOTDELETE%2FAFCO%20Steel&search=cat&th=153c3e054070b23b&sim I=153c3e0... 9/9 7/12/2016 State.co.us Executive Branch Mail - Re: AFCO question STATE OF COLORADO Re: AFCO question 10 messages Dummer - CDPHE, Nicholas <nicholas.dummer@state.co.us> Loni Gaudet <loni@enviro-senseinc.com> Wed, Mar 16, 2016 at 8:58 AM Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Dummer-CDPHE, Nicholas" <nicholas.dummer@state.co.us>, "Honesto, Joe" <jhonesto@afcosteel.com> Hi Nick, Here is my review of the Rule 7 requirements you have listed below. Your email stated that they would be subject to the general requirements in Sections III, IV and V, but my reading of the rules indicates that there are no applicable requirements. Please correct me if my analysis is incorrect. Section III: • I I I.A - Not applicable - the facility does not store coatings, solvents or thinners in storage tanks. Only in drums and cans. • II I.B - Not applicable - the facility does not transfer coatings, solvents or thinners into containers of greater than or equal to 56 gallons capacity. • III.C - Not applicable - the facility does not produce beer. Section IV: Not applicable - None of the coatings, thinners or solvents are "Highly Volatile Organic Compounds" which are defined as a Volatile Organic Compound or mixture of such compounds with a true vapor pressure in excess of 570 torr (11 Psia) at 20 C. Section V: • V.A - Not applicable - VOC compounds are disposed of by an offsite, licensed, hazardous waste disposal contractor and are not disposed of via evaporation or spillage. • V.B. - Not applicable - The facility is not a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Section VI.C.2., VI.C.3. and XV.A.3. Section VI - Not applicable - the facility does not store or transfer petroleum liquid as defined in Section VI.A.2.g. Section IX: IX.A.7.a - The facility uses the following management practices to reduce fugitive VOC emissions: o All containers that store volatile materials are kept sealed when not in use. o Spills are prevented whenever possible. If a spill occurs, it is cleaned up immediately. o Solvent wiping cloths are stored in a closed container. o Volatile waste materials (including spent cleaning solvent) are stored in sealed containers • IX.A.7.b - Emissions of organic material released during clean-up operations, disposal, and other fugitive emissions are included when determining total emissions, excluding properly documented VOCs which are collected and disposed of in a manner that prevents evaporation to the atmosphere • IX.A.8. - Not applicable - the facility does not use add-on control equipment for VOC emission control. • IX.A.9 - The Permittee will comply with the emission limits outlined in Section IX.L. • IX.A.10 - AFCO requests that compliance be determined on a monthly basis, not a daily basis. • IX.A.11 - The facility is only subject to the requirements of IX.L for Manufactured Metal Parts and Metal Products • IX.A.12 - Not applicable • IX.L - The permittee utilizes coatings which will meet the VOC limitations of IX.L.2.a Please let me know if you see any holes in this analysis. Thank you, Loni ----- Original Message ----- From: "Dummer-CDPHE, Nicholas" <nicholas.dummer@state.co.us> To: "Loni Gaudet" <loni@enviro-senseinc.com> Sent: 2/24/2016 1:05:27 PM hops://mai I.google.comlm ai l/u/o/?ui=2&ik=bad53d0f2f&view=pt&carDONOTDELETE % 2FAFCO % 20Steel&search=cat&th=1537fef061406ba2&sim I=1537fef06... 1/8 7/12/2016 State.co.us Executive Branch Mad - Re: AFCO question Subject: AFCO question Loni, Good afternoon. I am working on the Regulation 7 section related to the use of VOC in the Denver 8 -hr 03 NAA. AFCO is an affected source as they use spray coatings on metal components (section IX.L). I was hoping you could review sections Ill, IV, V, and VI and let me know how the VOC are handled, contained, stored, transported, disposed, etc. Thanks for your help. Cheers, Nick Nicholas Bummer Title V Permit Engineer Operating Permits Unit Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Hearth E Environment P 303.692.3125 4300 Cherry Creek Drive South, Denver, CO 80246-1530 mailto:blue.parish@state.co.us I www.colorado.00v/cdphe/apcd As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an APEN is submitted without the recessary information. An application with missing information may result in longer processing times. Please note that ail APEN submissions should he completed using forms currently supplied by the Division (See Rag, 3, Part A. Section II.A). If you need assistance, please refer to: hdps://www.colorado.govicdphe/APENfomis o ntfnst! This email has been checked for viruses by Avast antivirus software. www.avast.com Dummer - CDPHE, Nicholas <nicholas.dummer@state.co.us> Thu, Mar 17, 2016 at 9:58 AM To: Loni Gaudet <loni@enviro-senseinc.com> Cc: Matt Burgett - CDPHE <matt.burgett@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Loni, I've discussed some of your Reg 7 issues with senior engineers. With regard to averaging time: Compliance is required on a daily basis; however, daily averages are used to calculate a monthly average which will determine the monthly compliance. In this way, it may be possible to use surface coatings that are high-VOC in the same month as low-VOC coatings to achieve compliance. From PS Memo 97-03: (https://www.colorado.gov/ pacific/s ites/default/files/AP_Memo-97-03-Construction-Perm it -Conditions. pdf) https://mai I.google.ccm/mai I/u/0!?ui=2&ik=bad53dar2f8view=pt&cat=DONOTDELETE%2FAFCO%20Steel&search=cat&th=1537fef061406ba28si m1=1537fef06... 2/8 7/12/2016 State.co.us Executive Branch Mail - Re: AFCO question "Compliance with Regulation 7 VOC emission limits for surface coating (applicable in the Denver non attainment area) must be demonstrated on a daily Page 9 basis. Material usage records must be kept on a daily basis, however compliance calculations can be done at the end of the month, not each day. If compliant coatings (VOC content is less than the lb/gallon standard) are used, only monthly or annual (depending on source type) emissions would need to be calculated, since it is already known that compliance has occurred each day. If compliant coatings are not used the source must demonstrate that compliance was achieved each day by averaging non -compliant coatings with compliant coatings at the end of each month. This is referred to as a daily weighted average. Sources which are exempted from the surface coating requirements because they are below the 3 pound per hour and 15 pound per day cutoffs (§ IX.A.6.b.) will be required to calculate daily emissions at the end of the month to show that they are below 15 pounds per day. If they are below 15 pounds a day it will be assumed that they are also below 3 pounds per hour. In this case daily emissions will be calculated by dividing monthly emissions by the number of operating days." Also from PS Memo 94-10: (https://www.colorado.gov/pacific/sitesldefault/files/AP_Memo-94-10-Reg-7-Surface-Coating- Com pl ince. pdf) "Specific emission limitations (pounds per gallon coating, pounds per unit area, etc.) are to be complied with on a daily basis. Averaging is permitted. That is, each individual coating need not be a "compliance" coating, as long as the daily average emission limitation is complied with. This memo will supercede any permit condition which does not specify that daily averaging is acceptable." This may allow you to average out your high-VOC spray coating. If not, there was the question of whether or not your coating may be exempted and classified as high-performance under Reg 7 due to its anti -corrosive properties. This would meet the definition of extreme performance coatings wherein an extreme environmental condition includes corrosive conditions and would be subject to the VOC limits for extreme performance coatings and would not be exempt. High-performance coating exemptions are granted for spray coating operations of components that are too large to fit in a conventional spray paint booth (think 747 airplanes, etc.). If you would like to request an exemption under Reg 7 for this, you would need to submit specifications for the largest components that are spray -painted at the facility and a reasonable estimated cost for a Reg 7 compliant spray -paint booth for the described components. We would also like to see all the specifications of the spray -coating in question, including SDS with VOC content as applied, and how much coating is used on a yearly basis and what fraction of the total spray coating used this amounts to. There was the final option of attempting to submit a SIP revision under Reg 7. If you are interested in this, I will need to discuss some things with our regulation development folks. This would likely be a lengthy process and would require AQCC and EPA approval. Please let me know if you have any questions or what route/s you'd like to pursue moving forward. In the mean -time, please submit the information about the spray -coating in question. Thanks. Cheers, Nick [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] nicholas.dummer@state.co.us www.coEorado.00vlcdohelaocd As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please rote that alt APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section I€.A). If you need assistance, please refer to: https://www. soloiado.gov/cdphe/APENforms Bishop - CDPHE, Jeffrey <jeffrey.bishop@state.co.us> To: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us> Cc: Matt Burgett - CDPHE <matt.burgett@state.co.us> Nick, Thu, Mar 17, 2016 at 12:36 PM Would you please follow up with me with your intended determination on this issue prior to finalizing/providing AFC0 the answer. I would like to make sure that it does not put the enforcement unit in a problematic situation. https:/lmai l.google.coo/mai l/u/0/?ui=2&ik=load53d0f2f&view=pt&cat=DONOTD ELETE%2FAFCO%20Steel&search=cat&th=1537fef061406ba2&sim1= 1537fef06.., 3/8 7/12/2016 State.co.us Executive Branch Mail - Re: AFCO question Thank you, Jeffrey Bishop Environmental Protection Specialist Compliance and Enforcement Program COLORADO Air Pollution Control Division o-ommmaon-,ati ic,:m scvvcaa P 303.692.3106 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246-1530 teffrey.bishopOstate.co.us I www.colorado.00v/cdohe/aocd [Quoted text hidden] Dummer - CDPHE, Nicholas <nicholas.dummer@state.co.us> Thu, Mar 17, 2016 at 12:40 PM To: "Bishop - CDPHE, Jeffrey" <jeffrey.bishop@state.co.us> Absolutely, we will need to make sure that this is very clear in the permit. I will get with you when I know more. Thanks, N [Quoted text hidden] Loni Gaudet <loni@enviro-senseinc.com> Tue, Mar 22, 2016 at 1:08 PM Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us> Cc: Matt Burgett - CDPHE <matt.burgett@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Nick, Matt and Jeffrey, Sorry for the delay in my response - I've been out with the flu for a week, and am catching up now. I have a meeting with AFCO tomorrow, and will present their options to them. I'm beginning to wonder if we shouldn't have a conference call with you guys. I will ask them if they would like to do that. The way the memos read, one appears to allow averaging only within one single day, and not over a greater period of time, while the other allows averaging over a month. Am I reading this incorrectly? • PS 94-10: Averaging is permitted. That is, each individual coating need not be a "compliance" coating, as long as the daily average emission limitation is complied with. • PS 97-03: If compliant coatings are not used the source must demonstrate that compliance was achieved each day by averaging non -compliant coatings with compliant coatings at the end of each month. This is referred to as a daily weighted average. Regarding classifying the coating as a high-performance coating, I am unclear what you mean when you say that the coating "would be subject to the VOC limits for extreme performance coatings and would not be exempt." Does the state have no provisions or mechanisms for flexibility in the rule? Are you saying that there is no exemption, when the rule states that an exemption can be applied for on a case -by -case basis? You suggest a high performance coating exemption for components that are too large to fit in a conventional paint booth. AFCO manufactures structural steel components for use in building stadiums (the new CU stadium in Boulder is one of their projects), convention centers and bridges. Jeffrey has seen the facility, and knows that they are coating items such as I -beams and trusses, which would not fit in a paint booth. However, the documentation that you would request for that exemption appears to amount to a minor BACT analysis, which seems out of proportion, and is cost prohibitive as well. They have one coating, required by the client, that is non -compliant. This option seems constructed more for an auto manufacturer's paint line than AFCO's operation. There are dozens of coating and abrasive blasting operations in Weld and Latimer counties. Is the state enforcing this https://mail.google.com/mail/u/01?ui=2&ik=bad53d0f2f&view=pt8cat=DONOTDELETE%2FAFCO%020Steel&search=cat&th=1537fef061406ba2&siml=1537fef06.. 4/8 7/12/2016 state.co.us Executive Branch Mail - Re: AFCO question burden on each of them? Please excuse my frustration, but the client is feeling singled out, and I'm not seeing an option that fits them. Loni ---- Original Message From: "Dummer-CDPHE, Nicholas" <nicholas.dummer@state.co.us> To: "Loni Gaudet" <loni@enviro-senseinc.com> [Quoted text hidden] Burgett - CDPHE, Matt <matt.burgett@state.co.us> Tue, Mar 22, 2016 at 3:21 PM To: Loni Gaudet <loni@enviro-senseinc.com> Cc: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Hi Loni, We are open to having a conference call on this issue. Contact Nick if you and AFCO want to schedule one. I'll respond to some of your other questions in this email. PS Memos: I'm reading those to both require compliance on a daily basis. This is consistent with the language in Reg. 7. I think 97- 03 allows the calculation to be performed at the end of each month, but I'm not reading that to allow monthly averaging. I can consult with other Division staff if AFCO believes a monthly average would allow them to operate in compliance. I didn't get the impression based on our last conversation that a monthly average would resolve the issue. High -Performance coating: You mentioned that the non -compliant coating is needed due for its anti -corrosive properties. Reg. 7 IX.L.2.a.(ii) has a 3.5 Ib/gc limit for extreme performance coatings. Extreme performance coatings are defined as coatings designed for extreme environmental conditions, which includes exposure to corrosive environments. Regulation No. 7 does not contain a definition for high performance coatings, so we would need to receive information from AFCO as to why they should receive an exemption for high performance coatings when a category already exists for coatings intended for use in a corrosive environment. I think there was some confusion regarding the high performance coatings being related to large components that do not fit in a conventional booth. I don't follow the logic of that approach and do not believe it is correct. I still believe there may be a possibility to consider the coating to be high performance and exempt. What is the lb VOC/gc for that coating? How many gallons are used per year? I'm sorry AFCO is feeling singled out, but we would address this issue with any facility that is under permit review. I'm not sure if we have any other Title V coating operations with this issue in the nonattainment area, so this situation is new to the Title V group. Matt Burgett, P.E. Title V Operating Permits Unit Supervisor Stationary Sources Program COLORADO Air Pollution Control Division Department of Public I lealth B Environment P 303.692.3183 4300 Cherry Creek Drive South, Denver, CO 80246-1530 matt.burgett@state.co.us I www.colorado.qovicdohe/accd As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section II. A). Current APEN forms can be found https://mai l.google.com/mail/WO/7ui=28i k=bad53d0r2f&view=pt&cat=DONOTDELETE%2FAFCO%20Steel&search=cat&th=1537fef061406ba2&sim1=1537fef06... 5/8 7/12/2016 State.co.us Executive Branch Mail - Re: AFCO question . at: https://www..colorado.gov/cdphe/APENfomis [Quoted text hidden] Loni Gaudet <loni@enviro-senseinc.com> Fri, Mar 25, 2016 at 8:25 AM Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Burgett - CDPHE, Matt" <matt.burgett@state.co.us> Cc: "Duinmer - CDPHE, Nicholas" <nicholas.dummer@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Hi Matt, I've attached the coating PDS. The thinned VOC content is 4.5 lb/gal. As we discussed, averaging would not be useful because they often spray only one coating during a day, and often during a week or more. Last year they used approximately 1200 gallons of this coating. Emissions due to this coating were approximately 2.5 tpy of VOC and 0.5 tpy of total VOHAP. This is one of AFCO's major clients, which they can not afford to lose. They lost a million dollar project last year because of the permit limitation for metals (which we are working with CDPHE on with the current permit to modify that requirement). I'm still flabbergasted that the state does not have an averaging option on a longer basis than a day. Averaging options are common in the Federal rules and are at least as protective of the environment as Colorado's rule. Environmental regulations can be both protective of the environment, and allow flexibility for businesses to remain competitive in their fields. Please let me know what other information you would need to make a determination of exemption. Thank you, Loni Original Message ----- From: "Burgett - CDPHE, Matt" <matt.burgett@state.co.us> To: "Loni Gaudet" <loni@enviro-senseinc.com> [Quoted text hidden] Carbozinc_11_FG_PDS.pdf 73K Dummer - CDPHE, Nicholas <nicholas.dummer@state.co.us> Fri, Mar 25, 2016 at 9:46 AM To: Matt Burgett - CDPHE <matt.burgett@state.co.us>, Jeffrey Bishop - CDPHE <jeffrey.bishop@state.co.us> Matt and Jeff, The Reg 7 limit is 3.5 lb/gal for extreme performance coatings- this coating is 1 lb/gal (30%) over that. Also, I looked up the SDS. It is possible there is a problem if they're using the zinc filler for this coating because it contains cobalt which would be a violation of their permit. However, I am unsure if they are using it or not. http: //www. carbol i ne. com/prod ucts/product-brands/products-by-brand/product-details/?brand=Carboni nc&product=F250 Regardless of the potential cobalt issue, this coating does not comply with Reg 7 if they cannot 'average it out' with daily calculations. Pioneer Metal Finishing has a surface coating SIP revision which: IX.L.2.c.(xiii) The state Construction Permit shall allow a daily maximum limitation of 160 lbs. of VOC emissions from non -compliant surface coatings and an annual limitation of 40,000 lbs. of non -compliant VOC emissions. The annual limitation shall be calculated on a 12 -month rolling total calculated on the first day of each month using the previous 12 months. So it does appear possible to allow for these coatings with an approved SIP revision, but my understanding is that this would be a time -intensive process. They are only using 5,000 lb annually of this coating, so it is significantly less than the SIP revision given to Pioneer. However, Pioneer used trading credits from Coors to offset the non -compliant coatings, so that probably played in their favor for getting this exemption granted. https://mai I.google.com/mai Ilu/0/?ui=28i k=bad53d0r2f8view=pt8cat=DONOTDELETE%2FAFCO%205teel8search=cat8th=1537fef061406ba28si m I=1537fef06... 6/8 7/12/2016 State.co.us Executive Branch Mail - Re: AFCO question They could also attempt to get a SIP revision to extend the averaging time: IX.A.10.a. Compliance with this section shall be determined on a daily basis. Sources may request a revision to the State Implementation Plan for longer times for compliance determination. I didn't want to reply to her before I got your input. They're obviously pretty upset about this; however, these are the rules and these appear to be their options, short of not using the coating or building a paint booth, neither of which appear to be an option for them. Let me know what you think. Happy Friday! Cheers, N [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] nicholas.dummer@state.co.us I wwwcolorado.cLov/cdphe/aped As of January 1, 2014, the Colorado Air Pollution Conti el Division no longer accepts blank or incomplete APENs, Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section II.A). If you need assistance, please refer to: https://www.colorado.gov/cdphe/APENforms Dummer - CDPHE, Nicholas <nicholas.dummer@state.co.us> Fri, Mar 25, 2016 at 9:49 AM To: Loni Gaudet <loni@enviro-senseinc.com> Loni, Thanks for the reply. We will be discussing this on Monday when Matt is back in the office. Does AFCO use the zinc filler variety of the coating? Thanks, Nick [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] nicholas.dummer@state.co.us mwvw.colorado.gov/cdphe/aped As of January 1, 2914, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs, Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section ILA). If you need assistance. please refer tc: htlps://wwv.colorado.gov/cdphe/APENfomis Loni Gaudet <loni@enviro-senseinc.com> Reply -To: Loni Gaudet <loni@enviro-senseinc.com> To: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us> Mon, Mar 28, 2016 at 11:50 AM Nick, All of the Carbozinc coatings require the use of the zinc filler. That is what gives them their anti -corrosive protection. Loni Original Message --- From: "Dummer - CDPHE, Nicholas" <nicholas.dummer@state.co.us> To: "Loni Gaudet" <loni@enviro-senseinc.com> https:Nmai I.google.com/mail/u/0/?ui=2&ik=bad53d0f2f&view=pt&cat=DONOTDELETE%2FAFCO%2QSteel&search=cat&ih=1537fef061406ba2&si m1=1537fef06... 7/8 7/12/2016 [Quoted text hidden] State.co.us Executive Branch Mail - Re: AFCO question https://mail.google.com/mai Uu/0f?ui=2&ik=bad53dO12f&viev=pt&cat=DON OTD ELETE%2FAFC O%20Steel&search= cat&th= 1537fef061406ba2&sim I=1537fef06... 8/8 � Carbozinc® 11 FG1 Garb of-in�� Selection & Specification Data Generic Type Description Features Color Finish Primer Dry Film Thickness Solids Content Solvent Based Inorganic Zinc Time -tested corrosion resistant primer that protects steel galvanically in the harshest environments. Provides high-performance inorganic zinc protection on steel structures worldwide. • Rapid cure. Dry to handle in 45 minutes at 60°F (16°C) and 50% relative humidity. • Low temperature cure down to 0°F (-18°C). • Meets FDA requirements in gray color. • Available in ASTM D520, Type II zinc version. • Very good resistance to salting. • May be applied with standard airless or conventional spray equipment. • VOC compliant in certain areas • Lower zinc loading for economics. • VOC compliant for shop/fabricator use only. Green (0300); Gray (0700) Flat Self Priming 2.0 - 3.0 mils (51 - 76 microns) per coat Dry rim thickness in excess of 6.0 mils (150 microns) per coat is not recommended. By Volume 53% +/- 2% Measured in accordance with ASTM D 2697 Zinc Content in DryBy Weight 79% Film Theoretical Coverage Rate VOC Values Topcoats 850 ft2 at 1.0 mils (20.9 m2/I at 25 microns) 425 ft2 at 2.0 mils (10.4 m2/I at 50 microns) 283 ft2 at 3.0 mils (7.0 m2/I at 75 microns) Allow for loss in mixing and application. As Supplied 4.3 lbs./gal (515 g/l) Thinned: For use In fabrication shops only to remain in VOC compliance M accordance with EPA Standards. 7 oz/gal w/ Thinner 21:4.5 (begat (539 grit 5 oz/gal w/ Thinner 25:4.5 lbs/gal (539 gilt 5 oz/gal w/ Thinner 33: 4.5 lbsrgai (539 glt) May be coated with Acrylics, Epoxies, or Polyurethanes depending on exposure and need. High -Heat Silicones and others as recommended by your Carboline sales representative- Under certain conditions, a mist coat is required to minimize topcoat bubbling. Substrates & Surface Preparation General Steel Surfaces must be clean and dry. Employ adequate methods to remove dirt, dust, oil and all other contaminants that could interfere with adhesion of the coating. Non -Immersion; SSPC-SP6 and obtain a 1.0-3.0 mil (25-75 micron) angular blast profile. Mixing & Thinning Mixing Thinning Ratio Pot Life Power mix base, then combine and power mix as follows. Pour zinc filler very slowly into premixed base with continuous agitation. Mix until free of lumps. Pour mixture through a 30 mesh screen. DO NOT MIX PARTIAL KITS. Tip: Sifting zinc through a screen will aid in the mixing process by breaking up or catching dry zinc lumps. May be thinned up to 5 oz/gal (4%) with Thinner 26 for ambient and warm surfaces. For extremely warm or windy conditions, may be thinned up to 5 oz/gal (4%) with Thinner 33. In cool weather (below 40°F (4°C)), thin up to 7 ozlgal (6%) with Thinner 21. Use of thinners other than those supplied or recommended by Carboline may adversely affect product performance and void product warranty, whether expressed or implied. 4.6 Gallon. Kit Part A: 3.75 gallons Zinc Filler: 50 lbs. 8 Hours at 75°F (24°C) and less at higher temperatures. Pot life ends when coating becomes too viscous to use. Application Equipment Guidelines Listed below are general equipment guidelines for the application of this product. Job site conditions may require modification to these guidelines to achieve the desired results. Spray Application The following spray equipment has been found (General) suitable and is available from manufacturers such as Binks, DeVilbiss and Greco. Keep material under mild agitation during application. If spraying stops for more than 10 minutes, recirculate the material remaining in the spray line. Do not leave mixed primer in the hoses during work stoppages. Agitated pressure pot equipped with dual regulators, 3/8" I.D. minimum material hose, with a maximum length of 50', .070" I.D. fluid tip and appropriate air cap. Airless Spray Pump Ratio: 30:1 (min.) GPM Output 3.0 (min.) Material Hose: 3/8" I.D. (min.) Tip Size: .019-g23" Output PSI: 1500-2000 Filter Size: 60 mesh Teflon packings are recommended and available from the pump manufacturer. Brush For touch-up of areas less than one square foot only. Use medium bristle brush and avoid rebrushing. Roller Not recommended. Conventional Spray January 2015 F250 To rile best of our knowledge the technical data contained herein is true and accurate on the date of publication and is subject to change without prior notice. User must contact Carboline Company to verify correctness before specifying or ordering. No guarantee of accuracy is given or implied. We guarantee our products to conform to Carbollne quality control. We assume no responsibility for coverage, performance of injuries resulting from use. Liability, if any, is limited to replacement of products. NO OTHER WARRANTY OR GUARANTEE OF ANY KIND IS MADE BY CARBOLINE, EXPRESS OR IMPLIED, STATUTORY, BY OPERATION OF LAW, OR OTHERWISE, INCLUDING MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. Carbolinee and Carboguarde are registered trademarks of Carboline Company. Page 1 of 2 Carbozinc® 11 FG Application Conditions Condition Material Surface Ambient Humidity Minimum 0 °F (-18 °C) 0 °F (-18 "C) 0 °F (-18 °C) 30% Minimum 130 °F (54 °C) 200 'F (93 'C) 130 °F (54 °C) 95% This product simply equires the substra e temperature to be above the dew point Condensation due to substrate temperatures below the dew point can cause flash rusting on prepared steel and interfere with proper adhesion to the substrate Special application techniques may be required above or below normal application conditions Curing Schedule Surface Temp. & 50% Dry to Handle Dry to Recoat Relative Humidity & Topcoat wl other finishes 0 "F (-18 °C) 4 Hours 7 Days 40 °F (4 °C) 1 Hours 48 Hours 60 °F t16 °C) 45.0 Minutes 24 Hours 80'F (27 'C) 45.0 Minutes 18 Hours 100 °F (38 'C) 15.0 Minutes 16 Hours These times are based on a 3 0-4 0 mil (75-100 micron) dry film thi knees. Higher film thickness. nsuffrclent ventilation or cooler temperatures will require longer cure times and could result in olvent entrapment and premature failure. Humidity levels below 50% will require longer cure times. Notes: Any salting that appears on the zinc surface as a result of p clanged weathering exposure must be removed prior to the application of additional coatings. Also, loose zinc must be removed rom the cured fun by rubbing with fiberglass screen wire if: 1) The Carbozinc 11 is to be used without a topcoat in immersion service and "zinc pick up" could be detrimental, or 2) When "dry pray/overspray" is evident on the cured film and a topcoat will be applied. For accelerated curing or where the relative humidity is below 40%. allow an initial 2 -hour ambient cure. Follow 2 hour cure with water misting or steam to keep the coated surface wet for a minimum of B hours and until the coaled surface achieves a "2H" pencil hardness per ASTM D3363 Cleanup & Safety Cleanup Safety Vent) lation Use Thinner 21 or Isopropyl Alcohol. In case of spillage, absorb and dispose of in accordance with local applicable regulations. Read and follow all caution statements on this product data sheet and on the MSDS for this product. Employ normal workmanlike safety precautions. Hypersensitive persons should wear protective clothing, gloves and use protective cream on face, hands and all exposed areas. When used as a tank lining or in enclosed areas, thorough air circulation must be used during and after application until the coating is cured. The ventilation system should be capable of preventing the solvent vapor concentration from reaching the lower explosion limit for the solvents used. In addition to ensuring proper ventilation, appropriate respirators must be used by all application personnel. Packaging, Handling & Storage Shelf Life Shipping Weight (Approximate) Storage Temperature & Humidity Flash Point (Setaflash) January 2015 To the best of our knowledge the technical data contained herein is true and accurate on the date of publication and is subject to change without prior notice. User must contact Carholine Company to verify correctness before specifying or ordering. No guarantee of accuracy is given or implied. We guarantee our products to conform to Carboline quality control. We assume no responsibility for coverage. performance or injuries resulting from use. Liability, if any, is limited to replacement of products. NO OTHER WARRANTY OR GUARANTEE OF ANY KIND IS MADE BY CARBOLINE, EXPRESS OR IMPLIED, STATUTORY, BY OPERATION OF LAW, OR OTHERWISE, INCLUDING MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. Carboline® and Carboguard® are registered trademarks of Carboline Company. Part A: 12 months at 75°F (24'C) Part B: 24 months at 75W (24°C) 'Shelf Life: (actual stated shelf life) when kept at recommended storage conditions and in original unopened containers 4.6 Gallon Kit - 104 lbs. (47 kg) 40° -100°F (4-38°C). 0-90% Relative Humidity Part A: 55°F (13°C) Zinc Filler: NA Packaging, Handling & Storage • carboluie Coatings -Linings - Fireproofing F250 Page 2 of 2 Hello