SW CAA. Southwest Clean Air Agency TECHNICAL SUPPORT DOCUMENT COUNTRY MALT SWCAA ID: Air Discharge Permit SWCAA ADP Application CL-3061

Transcription

1 SW CAA Southwest Clean Air Agency TECHNICAL SUPPORT DOCUMENT COUNTRY MALT SWCAA ID: 2365 Air Discharge Permit ADP Issued: December 12, 2018 Prepared By: Clint Lamoreaux Air Quality Engineer Southwest Clean Air Agency

2 TABLE OF CONTENTS Section 1. Facility Identification 2. Facility Description 3. Current Permitting Action 4. Process Description 5. Emission Unit Description 6. Emissions Determination 7. Regulations and Emission Standards 8. RACT/BACT/BART/LAER/PSD/CAM Determinations 9. Ambient Impact Analysis 10. Discussion of Approval Conditions 11. Startup and Shutdown Provisions/ Alternative Operating Scenarios/Pollution Prevention 12. Emission Monitoring and Testing 13. Facility History 14. Public Involvement Page

3 Abbreviations acfm ADP AP-42 BACT BART CAM cfm CFR co C02e dscfm EPA gr/dscf HAP LAER lb/hr lb/yr lbs NOx NOC PM PM10 PSD RACT RCW SQER S02 SOx SW CAA TAP T-BACT tpy voe WAC Actual (uncorrected) cubic feet per minute Air Discharge Permit Compilation of Emission Factors, AP-42, Fifth Edition, Volume l, Stationary Point and Area Sources - published by the US Environmental Protection Agency Best Available Control Technology Best Available Retrofit Technology Compliance assurance monitoring (40 CFR 64) Cubic feet per minute Code of Federal Regulations Carbon monoxide Carbon dioxide equivalent Dry standard (68 F, 1 atmosphere) cubic feet per minute U.S. Environmental Protection Agency Grains per dry standard cubic feet Hazardous air pollutant listed pursuant to Section 112 of the Federal Clean Air Act Lowest Achievable Emission Rate Pounds per hour Pounds per year Pounds Nitrogen oxides Notice of Construction application Total particulate matter (includes both filterable particulate matter measured by EPA Method 5 and condensable particulate matter measured by EPA Method 202) Particulate matter with an aerodynamic diameter less than or equal to 10 micrometers (includes both filterable particulate matter measured by EPA Method 201 or 201 A and condensable particulate matter measured by EPA Method 202) Particulate matter with an aerodynamic diameter less than or equal to 2.5 micrometers (includes both filterable particulate matter measured by EPA Method 201 or 201 A and condensable particulate matter measured by EPA Method 202) Prevention of Significant Deterioration Reasonably Available Control Technology Revised Code of Washington Small Quantity Emission Rate listed in WAC Sulfur dioxide Sulfur oxides Southwest Clean Air Agency Toxic Air Pollutant pursuant to Chapter WAC Best Available Control Technology for toxic air pollutants Tons per year Volatile Organic Compound Washington Administrative Code

4 1. FACILITY IDENTIFICATION Applicant Name: - Owned by Great Western Malting Applicant Address: 2501 Kotobuki Way, P.O. Box 1529, Vancouver, WA Facility Name: Facility Address: 2501 Kotobuki Way, Vancouver, WA SWCAA Identification: 2365 Contact Person: Mr. Ken Weaver- Engineering Projects Manager- Great Western Malting Primary Process: Malt Handling SIC /NAICS: 2083 / Facility Classifications: BACT I Minor source when operating as independent entity - Synthetic Minor for PM, S02 when operating as pait of Great Western Malting 2. FACILITY DESCRIPTION is owned by Great Western Malting, although it can operate independently of Great Western Malting. is a malt and grain packaging facility and warehouse. Malt and/or grain delivered by railcar and truck is packaged into bags or super sacks for customers. Some product cleaning may be conducted prior to bagging. 3. CURRENT PERMITTING ACTION This permitting action is in response to Air Discharge Permit application number CL-3061 (ADP ) received October 9, ADP application CL-3061 requests approval to install the following additional malt and grain unloading and conveying equipment: Outdoor choked flow rail unloading system (mostly enclosed with rubber boot to receiving trench) Fully enclosed conveyors In addition, the application indicates that the following equipment approved in Air Discharge Permit will not be installed: 12 outdoor storage silos controlled by individual Donaldson Torit CPV-1 powered cattridge-style filters (East Exterior Storage Silos) Because this facility can operate completely independently from Great Western Malting and may handle grain or malt from sources other than Great Western Malting; this facility will be given a separate Air Discharge Permit from Great Western Malting. 4. PROCESS DESCRIPTION Malt or grain products are brought to the facility via hopper trucks, straight trucks, or railcar. Hopper trucks bottom dump inside the warehouse building onto covered mechanical conveyors. A small, portable duct collector (Oneida Mini-Gorilla) is used to capture dust at the transfer point from the hopper truck to the conveyor. The dust collector exhausts within the building. Straight trucks tip dump inside the warehouse building through an enclosed flexible spout onto a fully enclosed conveyor. The entire unloading process from straight trucks is almost entirely enclosed. A small, po1table dust collector (Oneida Mini-Gorilla) was originally used to capture dust at the transfer point from the hopper trucks to the conveyor and may be used occasionally when manually loading broken bags into a hatch on the conveyor. This dust collector exhausts within the building. Railcars will discharge product through a rubber boot into a below-grade receiving trench in a choked flow arrangement.

5 The malt or grain products are either mechanically conveyed into storage silos/bins or directed to one of two bagging lines. The facility utilizes four storage silos located outside the north wall of the building and two storage bins located in the northeast comer of the building. The outdoor silos each utilize a sock filter to control dust generated during loading. The outdoor silos are top loaded by conveyor; therefore, displacement is the only mechanism that induces air flow out of the silo. The two indoor storage bins utilize Donaldson Torit model CPV-1 filters discharged within the building. Product directed to the SO-pound bagging line passes through the Single Kice Aspirator before filling 50 pound bags or super sacks. Dust from the Single Kice Aspirator and 50 Pound Bagging Line is collected and filtered by a Donaldson Torit Power Core CPC-12 dust collector located outside the northwest comer of the building. Product directed to the 55 Pound Bagging Line passes through the Double Kice Aspirator before filling 55 pound bags. Dust from the Double Kice Aspirator and 55 Pound Bagging Line are each collected and filtered by separate Donaldson Torit dust collectors discharged at the northeast comer of the building. Silos 2 and 3 discharge onto Conveyor 4. Silos 1 and 4 discharge onto Conveyor 3. Both Conveyors 3 and 4 drop onto Conveyor 5 which takes material to the aspirator and bagging. The only transfer point downstream of the truck unloading that is not fully enclosed is the drop from Conveyor 4 onto Conveyor 5. At this point material that bypasses the silos (comes straight from the truck conveyor system) drops onto Conveyor 5. This additional pipe interferes with a clean connection between Conveyors 4 and 5. The drop point is enclosed as well as possible with rubber matting and the Oneida V-3000 portable dust collector is used as necessary to collect dust at this drop point. The drop point and the discharge of the Oneida V-3000 are both inside of the warehouse building. 5. EQUIPMENT/ACTIVITY IDENTIFICATION 5.a Hopper Truck Unloading. Hopper truck unloading occurs inside of the building. Trucks bottom dump onto conveyor belts feeding the Columbian TecTank storage silos, indoor storage bins, or a bagging line. A portable dust collector using a flexible intake hose is used to control dust from truck unloading as necessary to meet applicable visible emission limits. The dust collector vents inside the building, however building truck doors will generally be open during unloading, therefore emissions from these activities could escape the building. Duct Collector Details Make I Model: Date Manufactured: Capacity: Filter Description: Oneida I Mini Gorilla cfm Round filter cartridge rated for 99.9% control of micron material at 11 feet per second Indoor Truck Unloading 2

6 5.b Straight Truck Unloading. Trucks bring malt or grain to the facility where the trucks end-dump with a choked flow arrangement through a flexible hose connected directly to the conveyor system. The truck and transfer system is fully enclosed with the only potential for fugitive dust being at the transfer point from the flexible hose to the conveyor where the connection may not be fully sealed. 5.c Columbian TecTank Storage Silos. Four storage silos are used for grain or malt storage. The storage silos are located outside the north wall of the building. The following equipment details were provided: Make I Model: Serial Numbers: Capacity: Year Installed: Loading/Unloading Method: Emission Control: Exhaust Description: Columbian TecTank , , , ft 3 (Tank shells measure 12' diameter by 33' 3 11 tall) 2005 Top gravity load from conveyor Sock filter on tank top vent Through sock filter approximately 4' above grade Storage Silo Vent Exhaust 5.d Single Kice Aspirator - Cleaning. Aspirator cleaning is conducted inside of the building. The aspirator is used to separate fines and impurities from malt or grain prior to bagging. The aspirator utilizes air to classify the material passing through it by size and density. As grain or malt falls by gravity through the aspirator, air passes through the falling material in four locations (four pass). Materials with a lower terminal velocity (e.g. fines) are carried away from the product with the air stream. Exhaust air is filtered through a dust collector before exhausting to the ambient air. Aspirator Details Make I Model: Installed: Dust Collector Details Make I Model: Serial Number: Kice Industries I 4E Series 108 Startup trial February 23, Full operation - April 13, Donaldson Torit I Power Core CPC

7 Capacity: Filter Description: Cleaning Method: Exhaust Description: 5,800 cfm (12) Powercore Ultra-web filter packs with MERV 13 rating, each measuring 7" deep by 22" long in an oval shape. Total filter area of 804 ft 2 At least daily reverse air jet ~20" diameter exhausting vertically above the building roof approximately 32.5' above grade outside the northwest comer of the building. 5.e 50 Pound Bagging Line. Bagging is conducted inside of the building. Product may be loaded into 50 pound bags or super sacks. Dust generated by the bagging operations is collected by the same Donaldson Torit dust collector that also controls emissions from the Single Kice Industries aspirator I cleaner. After filling, bags are sealed and loaded onto pallets for shipment. Maximum bagging capacity is estimated at 500 pounds per minute (10 50-lb bags per minute). Super Sack Filling 5.f Double Kice Aspirator - Cleaning. The aspirator is used to separate fines and impurities from malt or grain prior to bagging. The aspirator utilizes air to classify the material passing through it by size and density. As grain or malt falls by gravity the stream is split to fall through each of two back-to-back aspirators. Air passes through the falling material in four location (four pass). Materials with a lower terminal velocity (e.g. fines) is carried away from the product with the air stream. Exhaust air is passed through a dust collector before exhausting to the ambient air. Dust collected by the filter system is hard-piped by auger to an enclosed waste bin shared with the 55 Pound Bagging Line dust collector. Aspirator Details Location: Make I Model: Year Installed: Dust Collector Details Make I Model: Serial Number: Rated Airflow: Filter Description: Cleaning Method: NE comer of building, above 55 Pound Bagging Line Kice Industries / 4E Series 2017 Donaldson Torit I DFE Ll-1 8,800 cfm based on model 30DC New York Blower (8,800 cfm capacity at 12" w.g.) (16) Ultra-web filter cartridges with MERV 15 rating. Total filter area of 4,064 ft2. At least daily reverse air jet 4

8 Exhaust Description: 26.5" diameter exhausting vertically approximately 30' above grade and 7' above the roof outside the northeast comer of the building. 5.g 55 Pound Bagging Line. Bagging is conducted inside of the building. Product is loaded primarily into 55 pound bags. Dust generated by the bagging operations is collected by strategically located pickup points all vented to a single Donaldson Torit dust collector located outside the east wall of the building. After filling, bags are sealed and loaded onto pallets for shipment. Maximum bagging capacity is estimated at 1,210 pounds per minute (22 55-lb bags per minute). Dust Collector Details Make I Model: Serial Number: Rated Airflow: Filter Description: Cleaning Method: Exhaust Description: Donaldson Torit I DFE Ll-1 4,000 cfm based on model 15PLR New York Blower (4,00 cfm capacity at 12" w.g.) (6) Ultra-web filter cartridges with MERV 15 rating. Total filter area of 1,524 ft 2. At least daily reverse air jet 14.75" diameter exhausting vertically approximately 30' above grade and 7' above the roof outside the northeast comer of the building. 5.h Railcar Unloading (new). Railcars will discharge product through a rubber boot into a below-grade receiving trench in a choked flow arrangement. The rubber boot will enclose the area between the railcar and the receiving trench to protect the product from the rain and reduce the possibility of fugitive dust. Gaps in the boot seal will be the only potential source of fugitive emissions. All downstream conveyors will be fully enclosed and vented to the existing dust collector for the 55 Pound Bagging Line. 5.i Other Activities. 1. Miscellaneous Indoor Activities. Portable dust collectors may be used to capture dust from various indoor material handling transfer points, grinding, or other activities as necessary. Such portable dust collectors are used away from any opening to the ambient air and exhaust directly into the building. Potential emissions from these indoor activities are expected to be negligible. Super Dust Gorilla 5

9 RMS Roller-Grinder- Model# RMS 9X12 Double Pair Brew Mill Oneida /Mini Gorilla at right (yellow) 6

10 Dust Collector Details Make / Model Capacity: Filter Media: Oneida I V-3000 ~ 1,285 3" w.c. HEP A rated media Oneida I V Indoor Storage Bins. Two indoor storage bins are used for grain or malt storage. The bin vent filters vent inside the building, and not to the ambient air, therefore emissions from these units are not considered significant. The bins are located approximately 40' from the nearest doorway. The following equipment details were available: Make I Model: Serial Numbers: Capacity: Custom built To be determined 831 ft 3 each. Rectangular bins measuring approximately 8' x 12' horizontally, and 8' 8" vertically Year Installed: Loading/Unloading Method: Top gravity load from fully enclosed conveyor Emission Control: Exhaust Description: One dust collector is installed on each bin. The dust collectors are Donaldson Torrit PowerCore model CPV-1 units rated for up to 700 cfm airflow, utilizing a single PowerCore filter pack with a filter area of 63 ft 3 and a MERV 15 rating, pulse flow cleaning. Two additional bins (if installed) will share these first two dust collectors. Filter will only be powered when the bins are being loaded. This will control dust emissions from the bins as well as will create a negative pressure in attached conveyors, minimizing the possibility of dust leakage. Bin 1 Bin Vent Serial Number: Ll-2 Bin 2 Bin Vent Serial Number: Ll-1 Exhausted vertically above each bin ~ 20' above grade. 7

11 3. Dust Bin. A fully enclosed roll-off dust bin is located inside the building and may be vented. If vented, the unit may be vented to the 55 Pound Bagging Line, or a dedicated filter. Any dedicated filter will vent inside the building, and not to the ambient air, therefore emissions from this unit are not considered significant. 4. Fully Enclosed Conveyors. Fully enclosed conveyors (existing and new) will be used to transfer malt and grain within the system. 5.j Eguipment/Activity Summary. #of #of ID No. Generating Equipment/ Activity Units Control Measure/Equipment Units 1 Hopper Truck Unloading 1 Choked flow from hopper truck, 1 Oneida I Mini Gorilla cartridge filter 2 Straight Truck Unloading 1 Enclosure and choked flow feeding NIA from straight truck 3 Railcar Unloading 1 Partial enclosure, choked flow NIA arrangement 4 Columbian TecTank Storage Silos 4 Passive fabric sock filter 1 each 5 Single Kice Aspirator I 50 Pound 1 Donaldson Torit Dust Collector 1 Bagging Line Power Core CPC-12 6 Double Kice Aspirator 1 Donaldson Torit Dust Collector 1 DownFlo DFE Pound Bagging Line 1 Donaldson Torit Dust Collector 1 DownFlo DFE 3-6 8

12 6. EMISSIONS DETERMINATION 6.a Dust Emissions - Fugitive and Passive Sources. Unloading and Columbian TecTank silo loading are potential sources of dust that will not pass through a powered filtration system. Most emissions will be the result of fugitive dust escaping the capture and control systems. Facility throughput is limited by the capacity of the bagging equipment. Control efficiencies are engineering estimates, and are most likely conservative. The table below shows potential emissions from both hopper truck, straight truck, and railcar unloading, assuming the full facility throughput is delivered by each method. The maximum emissions scenario is where all grain and malt is delivered to the facility from straight trucks. - Fugitive and Passive Emission Sources Annual Throughput Potential (50 Pound Line) Annual Throughput Potential (55 Pound Line) 131,400 tons malt/year 317,988 tons malt/year PM PM10 PM2.s Emission Emission Emission Throughput Control Factor I PM Factor I PM1 0 Factor I PM2.s Source (tons) Efficiency (lb/ton) (tons/yr) (lb/ton) (tons/yr) (lb/ton) (tons/yr) Hopper Truck "' Unloading 449,388 90% Straight Truck Unloading 449,388 90% Railcar Unloading 449,388 90% Columbian TecTank Silos 131,400 90% "' Indoor Bin Filling 317, % Maximum I Total: In the future, annual emissions must be calculated using the emission factors identified above unless better emission factors are developed and approved in writing by SW CAA. 6.b Dust Emissions - Active Dust Collectors. Emissions from the powered dust collectors that vent outside of the building were calculated assuming 8,760 hours of operation for each activity at the rated airflow and maximum emission level for each dust collector. - Powered Dust Collectors Dust Collectors (PM10IPM2.s Emissions) Rated Hours Emissions flow (cfm) of Op. gr/dscf lb/hr tov Single Kice Aspirator and Bagging 5,800 8, Pound Bagging Line 4,000 8, Double Kice Aspirator 8,800 8, In the future, annual emissions must be calculated using the emission factors identified above unless better emission factors are developed through source testing of the individual units. 9

13 6.c Facilitywide Potential Emissions Summary. Pollutant Nitrogen oxides Carbon monoxide Volatile organic compounds Sulfur oxides as sulfur dioxide Particulate matter PM10 PM2.s C02e Toxic Air Pollutants Hazardous Air Pollutants Potential Annual Emissions (tons) REGULATIONS AND EMISSION STANDARDS Regulations that have been used to evaluate the acceptability of the proposed facility and establish emission limits and control requirements include, but are not limited to, the regulations, codes, or requirements listed below. 7.a Title 40 Code of Federal Regulations (CFR) Pa11 70 "State Operating Permit Programs" requires facilities with site emissions of any air pollutant greater than 100 tpy, any single hazardous air pollutant greater than I 0 tpy, and/or any aggregate combination of hazardous air pollutants greater than 25 tpy to obtain a Title V permit. This facility is owned by Great Western Malting and can be considered a support facility for Great Western Malting for the purposes of Title V applicability if most or all of the malt processed comes from Great Western Malting. It should be noted that Country Malt can handle grain or malt from other facilities, and is not contiguous and adjacent to Great Western Malting. Potential emissions of Title V pollutants (PM10) from will be too small to impact the synthetic minor status of Great Western Malting which has a PM10 PTE of tons per year; therefore SWCAA will treat these as separate facilities except to monitor Title V applicability when changes are made to either facility. 7.b Revised Code of Washington (RCW) empowers any activated air pollution control authority to prepare and develop a comprehensive plan or plans for the prevention, abatement and control of air pollution within its jurisdiction. An air pollution control authority may issue such orders as may be necessary to effectuate the purposes of the Washington Clean Air Act [RCW 70.94] and enforce the same by all appropriate administrative and judicial proceedings subject to the rights of appeal as provided in Chapter 62, Laws of 1970 ex. sess. 7.c RCW provides for the inclusion of conditions of operation as are reasonably necessary to assure the maintenance of compliance with the applicable ordinances, resolutions, rules and regulations when issuing an Order of Approval (Air Discharge Permit) for installation and establishment of an air contaminant source. 7.d Washington Administrative Code CW AC) I "Operating Permit Regulation" requires all major sources and other sources as defined in WAC to obtain an operating permit. This regulation is not applicable because this source is not a potential major source and does not meet the applicability criteria set forth in WAC e WAC "Ambient Air Quality Standards" establishes ambient air quality standards for PM10, PM2s, lead, sulfur dioxide, nitrogen dioxide, ozone, and carbon monoxide in the ambient air, which must not be exceeded. 7.f SW CAA "General Standards for Maximum Emissions" requires all new and existing sources and emission units to meet ce11ain performance standards with respect to Reasonably Available Control Technology (RACT), visible emissions, fallout, fugitive emissions, odors, emissions detrimental to persons or property, sulfur dioxide, concealment and masking, and fugitive dust. 10

14 7.g SW CAA (1) "Visible Emissions" requires that no emission of an air contaminant from any emissions unit exceed twenty percent opacity for more than three minutes in any one hour at the emission point, or within a reasonable distance of the emission point. 7.h SWCAA (2) "Fallout" states that no emission of particulate matter from any source shall be deposited beyond the property under direct control of the owner(s) or operator(s) of the source in sufficient quantity to interfere unreasonably with the use and enjoyment of the property upon which the material is deposited. 7.i SWCAA (3) "Fugitive Emissions" requires that reasonable precautions be taken to prevent the fugitive release of air contaminants to the atmosphere. 7.j SWCAA (4) "Odors" establishes that no person shall cause or allow the generation of any odor from any "source" or activity, which may unreasonably interfere with any other property owner's use and enjoyment of his property. Recognized good practice and procedures must be used to reduce odors to a reasonable minimum. 7.k SWCAA "New Source Review" requires that an Air Discharge Permit application be filed with SWCAA prior to the establishment of any new source, emission unit, or modification and that an Air Discharge Permit be issued prior to establishment of the new source, emission unit, or modification. 7.1 SWCAA "Requirements for Sources in a Maintenance Plan Area" requires that no approval to construct or alter an air contaminant source shall be granted unless it is evidenced that: (1) The equipment or technology is designed and will be installed to operate without causing a violation of the applicable emission standards; (2) Emissions will be minimized to the extent that the new source will not exceed emission levels or other requirements provided in the maintenance plan; (3) Best Available Control Technology will be employed for all air contaminants to be emitted by the proposed equipment; ( 4) The proposed equipment will not cause any ambient air quality standard to be exceeded; and (5) If the proposed equipment or facility will emit any toxic air pollutant regulated under WAC , the proposed equipment and control measures will meet all the requirements of that Chapter. 8. RACT/BACT/BART/LAER/PSD/CAM DETERMINATIONS New Determinations 8.a BACT Determination - Railcar Unloading. The proposed unloading method nearly eliminates the possibility of fugitive dust from this activity by fully enclosing the transfer conveyors, and utilizing choked flow through a rubber boot from the railcar to the receiving trench (which is the only location where grain might be exposed to the ambient environment). This method of activity is capable of maintaining visible emissions at 0% opacity and represents BACT. Older BACT Determinations 8.b BACT Determination - Straight Truck Unloading (ADP ). The proposed unloading method nearly eliminates the possibility of fugitive dust from this activity by fully enclosing the truck and transfer conveyors and utilizing choked flow at the transfer to the first conveyor (which is the only location where grain will be exposed to the ambient environment). This method of activity is capable of maintaining visible emissions at 0% opacity and represents BACT. 8.c BACT Determination - Malt and Grain Transfer To and From Bins, Silos, Cleaning, and Bagging Equipment (ADP ). All of the proposed conveying equipment is fully enclosed. The only discharge to ambient air is through 11

15 cartridge-style filters located on bins and silos, the Double Kice Aspirator exhaust, and ambient pickups on the bagging equipment. This level of enclosure and filtration permittee appears to be the lowest emitting configuration possible and the top choice in a "top-down" BACT analysis. Therefore, SWCAA has concluded that the proposed configuration will meet the requirements of BACT. Each of the new dust collectors is capable of achieving outlet emission levels of gr/dscf or lower and this emission level has been made a condition of the Permit. 8.d BACT Determination - Hopper Truck Unloading (ADP I ). Truck unloading is controlled by enclosing the activity to the extent practical, conducting unloading within the building, and using a portable fabric filter to capture fugitive dust at the only unenclosed point (the drop from the bottom of the truck to the first conveyor). Based on an observation of this activity, dust creation is minimal and this practice appears to represent BACT. 8.e BACT Determination - Exterior Storage Silos (ADP ). The use of fully enclosed transfer conveyors and a fabric sock filter to control dust from air displaced by loading would meet the top level of control for this equipment and therefore represents BACT. 8.f BACT Determination -Aspirator I Cleaning CADP I). Because a baghouse system such as the one proposed by the permittee is most likely to be the top choice in a "top-down" BACT analysis, SWCAA has concluded that the proposed baghouse will meet the requirements of BACT. 8.g BACT Determination - 50 Pound Bagging Line (ADP ). Dust from bagging will be controlled by conducting the activity within the building enclosure, enclosing the bagging station to the extent practical, and using a baghouse to ensure more complete capture and to filter dust from air discharged from the bagging enclosure. A baghouse system such as the one proposed by the permittee is most likely to be the top choice in a "top-down" BACT analysis, therefore SW CAA has concluded that the proposed baghouse will meet the requirements ofbact. Note that the super sacks are not filled within the bagging enclosure because the top of the sack can be tightly closed around the fill chute, which is itself fully enclosed. Any dust generated by super sack filling would stay within the bag, the fill chute, and the fully enclosed conveyor system. PSD/CAM Determinations 8.h Prevention of Significant Deterioration CPSD) Applicability Determination. This pennitting action will not result in a potential emissions increase equal to or greater than the applicable PSD thresholds. Therefore, requirements of the PSD program are not applicable to this action. 8.i Compliance Assurance Monitoring (CAM). CAM is not applicable to any emission unit at this facility because this facility is not a major source for the purposes of Title V. 9. AMBIENT IMPACT ANALYSIS This project is not associated with an increase in emissions of toxic air pollutants (TAPs) listed in WAC I (as in effect February 14, 1994). Facilitywide emissions of PM10 will be at or below 3.42 tons per year. At this emission rate, no adverse ambient air quality impact is anticipated. Conclusions 9.a Installation of the proposed unloading and conveying equipment as proposed in ADP application CL-3061 will not cause the ambient air quality standards established by Title 40 Code of Federal Regulations Pait 50 ( 40 CFR 50), "National Primary and Secondary Ambient Air Quality Standards" to be violated. 9.b The additional unloading, conveying, storing, cleaning and packaging equipment, if properly installed and maintained, can be operated without causing a violation of the applicable emission standards, which include the limits established under SWCAA "General Standards for Maximum Emissions." 12

16 9.c Operation of the malt and grain unloading, conveying, storing, cleaning and packaging facility as proposed in ADP application CL-3061 in accordance with the Air Discharge Permit will not cause the requirements of WAC "Controls for New Sources of Toxic Air Pollutants," (in effect August 21, 1998) or WAC "Ambient Air Quality Standards" to be violated. 10. DISCUSSION OF APPROVAL CONDITIONS SWCAA has made a determination to issue Air Discharge Permit in response to ADP Application CL Air Discharge Permit SW CAA contains approval requirements deemed necessary to assure compliance with applicable regulations and emission standards as discussed below. 10.a General Basis. Approval conditions for equipment affected by this permitting action incorporate the operating schemes proposed by the permittee in the Air Discharge Permit application. 10.b Emission Limits. Emission limits for the facility were established at the facilitywide potential to emit identified in Section 6. Emission limits for the dust collectors were limited to the BACT emission concentration (0.005 gr/dscf for the Single Kice Aspirator and 50 Pound Bagging Line, gr/dscf for the remaining dust collectors), and the calculated equivalent emission rate at rated airflow. 1 O.c Operating Limits and Requirements. To minimize the impact of emissions on ambient air quality, the dust collectors are required to be exhausted vertically above the level of the building roof. Any device that obstructs or prevents vertical discharge (such as a traditional rain cap) is prohibited. This is good engineering practice and is required by SWCAA (1). 10.d Monitoring and Recordkeeping. Sufficient monitoring and recordkeeping was established to document compliance with the annual emission limits and provide for general requirements (e.g. upset reporting). 10.e Emission Monitoring and Testing Requirements. See Section O.f Reporting. Specific reporting deadlines were established for each reporting requirement. The submittal date refers to the earlier of the date the report is delivered to SW CAA or the postmarked date if sent through the US Post Office. Upset conditions with the potential to cause excess emissions must be reported immediately in order to qualify for relief from penalty in accordance with SWCAA for unavoidable exceedances. In addition, prompt reporting allows for prompt and accurate investigation into the cause of the event and the prevention of similar future incidents. The permit requires reporting of the annual air emissions inventory, and reporting of the data necessary to develop the emission inventory. 11. ST ART-UP AND SHUTDOWN/ ALTERNATIVE OPERA TING SCENARIOS/POLLUTION PREVENTION 11.a Startup and Shutdown Provisions. Pursuant to SWCAA "Startup and Shutdown," technology based emission standards and control technology determinations shall take into consideration the physical and operational ability of a source to comply with the applicable standards during startup or shutdown. Where it is determined that a source is not capable of achieving continuous compliance with an emission standard during startup or shutdown, SWCAA shall include appropriate emission limitations, operating parameters, or other criteria to regulate performance of the source during startup or shutdown. 13

17 The permittee did not identify any startup and shutdown periods during which the proposed equipment is not capable of achieving continuous compliance with any applicable emission standard or approval condition. Therefore, specific startup and shutdown provisions were not included in the permit. 11.b Alternate Operating Scenarios. SWCAA conducted a review of alternate operating scenarios applicable to equipment affected by this permitting action. The applicant did not propose or identify any applicable alternate operating scenarios. Therefore, none were accommodated by the approval conditions. 11.c Pollution Prevention Measures. SW CAA conducted a review of possible pollution prevention measures for the facility. No pollution prevention measures other than the control measures identified in the permit were identified by either the permittee or SW CAA. Therefore, no additional measures were included in the approval conditions. 12. EMISSION MONITORING AND TESTING Initial and periodic (once every 10 years) source emissions testing of each of the three larger dust collectors was required to demonstrate initial and on-going compliance with BACT and permitted emission limits. It is expected that the ten year testing frequency is appropriate based on the size of the equipment ( 4,000-8,800 cfm), the cartridge-style design, and the type of service (ambient temperature, grain or malt). 13. IDSTORY 13.a General History. This facility began operation in The primary source of potential emissions prior to the 2017 permitting action was the original cleaning and bagging line (50 Pound Bagging Line) which began operation in early The 55 Pound Bagging Line and Indoor Storage Bins were installed in b Previous Approvals. The following permits and approvals have been issued for this facility: Permit Number Annlication # Date Issued Descrintion CL /17/2010 Approval to install a new Kice aspirator vented to a Donaldson Torit model CPC-12 dust collector CL /27/2017 Approval for straight truck unloading, 12 outdoor storage bins (not installed), 4 indoor storage bins (two of which were installed), 55 Pound Bagging Line, and associated enclosed conveyors associated with the above equipment. Bold font indicates that the Air Discharge Permit was superseded or will no longer be in effect upon issuance of Air Discharge Permit PUBLIC COMMENT 14.a Public Notice for Air Discharge Permit. Public notice for Air Discharge Permit Application CL-3061 was published on the SWCAA internet website for a minimum of 15 days beginning on October 9, b Public/Applicant Comment for Air Discharge Permit. SWCAA did not receive formal comments, a comment period request, or any other inquiry from the public or the applicant regarding this Air Discharge Permit application. Therefore, no public comment period was provided for this permitting action. 14.c State Environmental Policy Act. SW CAA issued Determination of Non-Significance on December 12, 2018 for this permitting action. 14