Willamette Valley Sandblasting Page 1 of 6. Lane Regional Air Protection Agency Simple Low Air Contaminant Discharge Permit REVIEW REPORT

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1 Willamette Valley Sadblastig Page 1 of 6 Lae Regioal Air Protectio Agecy Simple Low Air Cotamiat Discharge Permit REVIEW REPORT Willamette Valley Sadblastig 1250 Bertelse Road Eugee, Orego Source Iformatio: SIC NAICS 1799 Special trade cotractor All other Specialty Trade Cotractors Source Categories (LRAPA Title 37, Table 1) Public Notice Category B. 74 All other sources ot listed herei that LRAPA determies a air quality cocer exists II Compliace ad Emissios Moitorig Requiremets: Uassiged emissios Source test [date(s)] Emissio credits COMS Special Coditios CEMS Compliace schedule Ambiet moitorig Reportig Requiremets: Aual report (due date) Feb 15 Excess emissios report y NSPS Report (due date) Other reports Mothly report (due dates) Air Programs: NSPS (list subparts) NESHAP (list subparts) CAM Regioal Haze (RH) Sythetic Mior (SM) Part 68 Risk Maagemet Title V ACDP (SIP) New Source Review (NSR) Prevetio of Sigificat Deterioratio (PSD) Acid Rai Clea Air Mercury Rule (CAMR) TACT

2 Willamette Valley Sadblastig Page 2 of 6 Permittig Actio 1. The permit is a reewal for a existig Air Cotamiat Discharge Permit (ACDP) which was issued o July 18, 2012 ad was origially scheduled to expire o July 18, The existig permit remais valid util the proposed permit is issued because the facility submitted a timely ad complete applicatio for reewal. The facility was issued its first ACDP i The facility idicated i their 2017 reewal applicatio that o chages have bee made to the permit sice the last reewal. Other Permits 2. No other permits have bee issued or are required by LRAPA for this facility. Attaimet Status 3. The facility is located i a maiteace area for CO ad PM10. The area is i attaimet for all other criteria pollutats. Geeral Backgroud Iformatio 4. Willamette Valley Sadblastig operates a sadblastig operatio at 1250 South Bertelse Road i Eugee ad at various locatios i Lae Couty. The facility cotrols PM (particulate matter)/pm10 emissios by the use of eclosures ad water spray. Reasos for Permit Issuace 5. Lae Regioal Air Protectio Agecy (LRAPA) has determied that the facility qualifies for the Simple Low fee category for the followig reasos: Emissios from this facility are estimated to be less tha 5 tos per year of particulate matter ad less tha 10 tos per year for the criteria gaseous pollutats. Emissio Uit Descriptio 6. The facility cotrols particulate matter emissios iside usig eclosures with fabric curtais ad a water sprikler system. Particulate matter emissios are cotrolled outside usig a wet blastig system. Other specific emissio sources iclude: EU ID Emissio Uit (EU) Cotrol Device EU-1 Sadblastig - Eclosed Eclosures ad water spray EU-2 Sadblastig - Ope Water spray Compliace History 7. The followig eforcemet actios have bee take agaist this facility: O March 21, 1994 LRAPA issued NON 1025 to Willamette Valley Sadblastig for sadblastig without cotaimet. NON 1025 was closed o April 04, 1994 with o further actio.

3 Willamette Valley Sadblastig Page 3 of 6 O July 12, 1994 LRAPA issued NON 9443 to Willamette Valley Sadblastig for sadblastig without cotaimet. NCP (NON 9443) was issued o July 12, 1994 i the amout of $1,900. There was a request to reduce the pealty amout o August 4, The full amout was received August 24, O April 6, 1995 LRAPA issued NON 9507 to Willamette Valley Sadblastig for failure to miimize emissios while operatig sadblastig equipmet. NCP (NON 9507) was issued o April 6, 1995 i the amout of $1,200. The full amout was received April 27, O September 12, 1995 LRAPA issued NON 1132 to Willamette Valley Sadblastig for sadblastig without cotaimet. NCP (NON 1132) was issued o September 12, Resolved o Jue 17, 1996 alog with NCP , see below. O February 1, 1996 LRAPA issued NON 1198 to Willamette Valley Sadblastig for sadblastig without cotaimet ad o water spray system. NCP (NON 1198) was issued o February 1, The facility paid $1,500 o February 22, 1996 ad both NCP ad NCP were closed Jue 17, O April 2d, 1996 LRAPA issued NON 1217 to Willamette Valley Sadblastig for failure to miimize emissios while operatig sadblastig equipmet. NCP (NON 1217) was issued o April 2d, 1996 i the amout of $2,200. NCP was withdraw ad dismissed o the coditio that a facility cotaimet ad compliace assurace pla be agreed upo. O Jue 21, 1999 LRAPA issued NON 1800 to Willamette Valley Sadblastig for failure to take reasoable precautios to prevet particulate matter from becomig airbore, ad failure to use adequate cotaimet (water) durig sadblastig. NCP (NON 1800) was issued o Jue 21, 1999 i the amout of $1,200. There was a request to reduce the pealty amout o August 4, The request was approved, ad the amout was reduced to $900. LRAPA further agreed to susped $300 of the remaiig amout o the coditio that Willamette Valley Sadblastig would operate i compliace with LRAPA regulatios ad would abide by the CAOP (Compliace Assurace Operatig Procedures) submitted to LRAPA o November 29, The full amout of $600 was received Jauary 14, O May 25, 2000 LRAPA issued NON 1914 to Willamette Valley Sadblastig for failure to take reasoable precautios to prevet particulate matter from becomig airbore; failure to use water i sadblast gu; failure to use water sprikler off cotaimet shed. The suspeded civil pealty of NCP i the amout of $300 became due ad was paid July 20, Willamette Valley Sadblastig was also required to submit a applicatio for a ACDP withi 45 days of the receipt of the July 5, 2000 otice. O Jue 07, 2011 LRAPA issued NON 3300 to Willamette Valley Sadblastig for failure to use reasoable precautios such as adequate cotaimet durig sadblastig to prevet particulate matter from becomig airbore. NON 3300 was closed o Jue 28, 2011 with o further actio. The facility was ispected o Jauary 17, 2018 ad foud to be i compliace with permit coditios.

4 Willamette Valley Sadblastig Page 4 of 6 Plat Site Emissio Limits (PSELs) Iformatio 8. Aual Plat Site Emissio Limits (PSELs) (tos per year) Source PM PM10 PM2.5 Sadblastig a. The proposed PSELs for all pollutats are equal to the Geeric PSEL i accordace with LRAPA (3)(b) ad the ettig basis is zero i accordace with (2). b. PSELs for CO, NOX, SO2, VOCs, ad GHGs are ot icluded i this permit sice emissios of these pollutats are less tha the respective de miimis emissio rates. c. The PSEL is a federally eforceable limit o the potetial to emit. d. Recordkeepig of the parameters listed i Coditio 9 of the permit will be used to esure compliace with the PSELs. 9. The pollutats of cocer associated with this type of facility are PM ad PM10. Emissios of the above pollutats are estimated to be 4 tos per year. The attachmet to this review report cotais emissios estimates for the facility s applicable emissio uits. Baselie Emissio Rate (BER) ad Sigificat Emissio Rate (SER) 10. Baselie Emissios were ot set i the permit because the facility is well below the Sigificat Emissio Rates (SERs) as listed i Title 12 of LRAPA s Rules ad Regulatios ad because the facility has chose ot to maitai the baselie emissios by way of the Simple ACDP permit type selectio. Hazardous Air Pollutats (HAPs) 11. A major source for hazardous air pollutats (HAP) is a facility that has the potetial to emit 10 or more tos per year of ay sigle HAP or 25 or more tos per year of combied HAPs. This source is ot a major source of hazardous air pollutats. The projected maximum potetial HAP emissios from the facility, take from the facility s Cleaer Air Orego Emissio Ivetory (CAO EI), are show i the followig table: Pollutat Pouds/year Tos/year Lead Nickel Magaese Cadmium Total

5 Willamette Valley Sadblastig Page 5 of 6 NESHAPS/MACT Applicability 12. There are o sources at this facility for which Natioal Emissio Stadards for Hazardous Air Pollutats (NESHAPs) have bee promulgated. While it may be possible that the facility performs dry abrasive blastig o idividual sources that would be classified as oe of the ie categories i the Metal Fabricatio NESHAP (Subpart 6X), LRAPA chose ot to require or perform the extesive aalysis required to make such a determiatio. Istead, LRAPA placed the pertiet sectios ito the permit from the Metal Fab NESHAP for Dry Abrasive Blastig that would be cosidered Geerally Available Cotrol Techology (GACT). NSPS Applicability 13. There are o sources at this facility for which New Source Performace Stadards (NSPS) stadards have bee promulgated. Moitorig ad Record Keepig ad Reportig 14. A record of the followig data must be maitaied for a period of five (5) years at the plat site ad must be available for ispectio by authorized represetatives of LRAPA: Activity Parameter Uits Recordig Frequecy Sadblastig Abrasive Media Usage by locatio (By EU-1 or EU-2) Pouds Mothly 15. The facility is required to perform visual determiatios of fugitive emissios for abrasive blastig of objects greater tha 8 feet (2.4 meters) i ay oe dimesio that is performed outdoors. 16. The facility is required to submit a aual report by February 15 th each year to iclude the iformatio idetified i items 14 above. Special Coditios ad Additioal Limitatios 17. The facility is required to otify LRAPA o less tha 24 hours i advace of performig ay cotract abrasive blastig at locatios other tha 1250 South Bertelse Road. 18. The facility is subject to the visible emissios stadards i LRAPA (3), the particulate grailoadig stadard i LRAPA (2)(b)(B), the highest ad best requiremet of LRAPA Sadblastig withi eclosures with the curtais draw wheever possible, ad the adequate use of water, should assure compliace with the grai-loadig ad visible emissios limits. Public Notice 19. The draft permit was o public otice from Jauary 9, 2019 to February 7, No writte commets were submitted durig the 30-day commet period CNC/cmw 02/08/2019

6 Willamette Valley Sadblastig Page 6 of 6 Willamette Valley Sadblastig Emissio Details: Sadblastig Booth Emissios Projected Projected Emissio Coversio Aual Maximum Usage Factor Factor Emissios Process Pollutat (lb abrasive/yr) (lbs PM/lb abrasive) (tos/lb) (tos) Sadblastig i shed with fabric coverig PM/PM 10 /PM , Sadblastig without cotrols i 5-mph wid PM/PM 10 /PM , Total 3.99 Maximum desig capacity is the sum of all the sadblastig operatios. Particulate Matter Emissio Factors were obtaied from AP-42 table Projected Aual Emissios = Projected Maximum Usage x Emissio Factor x Coversio Factor.