3104 E. Augusta, Spokane, WA (509) JUNE 1, Addition of Spray Systems Bench Booth Model BB-72 to tow cart line (vented to RTOs)

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1 Notice of Construction (NOC) Approval Issued in accordance with: Chapter RCW, SRCAA Regulation I, Article V, Chapter WAC, and Chapter WAC 3104 E. Augusta, Spokane, WA (509) NOTICE OF CONSTRUCTION (NOC): #1242B DATE APPROVED: MAY 27, 2005 DATE REVISED: OCTOBER 13, 2005 Addition of one-time requirement to allow for start-up testing of one spray booth without venting exhaust to RTOs NOVEMBER 1, 2005 Revision of Condition A.4 to allow for periodic coating testing in one spray booth without venting exhaust to RTOs for control of emissions MARCH 21, 2006 Addition of Primac Lineal Finishing Line and UV ovens (all vented to RTOs) and removal of one-time requirements that have been met JUNE 1, Addition of Spray Systems Bench Booth Model BB-72 to tow cart line (vented to RTOs) MAY 7, 2007 Addition of Spraying Systems booth to overhead hanging line and Cattinair G8 automatic spray machine to automatic paint lines (both vented to RTOs) APRIL 14, 2009 Revision to allow for limited touch-up spray application of stains in three repair areas outside of spray booths JUNE 17, 2010 Revision to allow for the addition of the colormatch easel process to repair area #2 and increase allowable coating usage in three repair areas outside of spray booths. Revision to add 2 additional Cattinair G8 automatic NGR spray machines to automatic paint lines (both vented to RTOs); addition of outlet VOC emission limit to be met in lieu of destruction efficiency in low production scenarios, addition of CO limit to be met when hanging line is operational; and revision of periodic source test requirement to every 3 years COMPANY NAME: FACILITY LOCATION: DESCRIPTION OF EQUIPMENT BEING INSTALLED: HUNTWOOD INDUSTRIES E. APPLEWAY RD. LIBERTY LAKE, WA SAME SEE ATTACHMENT A

2 PREPARED BY: April L. Westby REVIEWED BY: Joe Southwell, PE APPROVED BY: William Dameworth, Control Officer Page 2 of 9

3 PRELIMINARY DETERMINATION A preliminary revised determination has been made, based on review of the Notice of Construction and Application for Approval (NOC) #1242B. The proposed project, if constructed and operated as described in the NOC will be in compliance with the applicable rules and regulations, as adopted pursuant to Chapter RCW, including Chapters WAC, WAC, and SRCAA Regulation I, provided that the following conditions are met: A. On-going Requirements for 22 Spray Booths: 1. The surface coating operations shall comply with the requirements of SRCAA Regulation I, Article VI, Section The exhaust filters used in each of the 22 spray booths must be designed to capture paint overspray (i.e. paint arrestor filters). The filters must completely cover the openings to the exhaust ducting such that no gaps, leaks, etc. exist. Filters must be replaced as often as necessary to ensure that paint overspray does not break through to the back side of the filters. If filters are cleaned instead of replaced, cleaning must be performed in a manner such that particulate matter captured on the filters does not become airborne. Records must be kept of the dates when filters are changed in each spray booth. Filter change records shall be kept in accordance with Condition A.11 below. Filters must be disposed of in a manner such that particulate matter captured on the filters does not become airborne. If a manometer is used to determine when the filters are replaced, the following shall occur: a) The gauge shall be marked with the manufacturer or installer s recommended pressure drop limit (or range) for filter change-out; b) If equipped with a liquid gauge, the gauge shall be checked periodically to ensure it is zero d and full of fluid; c) Filters shall be replaced before the pressure drop limit (or range) marked on the gauge is exceeded; and d) The date of filter change and corresponding pressure drop reading shall be recorded for all filter replacements. Records shall be kept in accordance with Condition A.11 below. 3. Only high volume low pressure (HVLP) spray guns or other application methods listed in SRCAA Regulation I, Section 6.13 E.3 shall be used to apply coatings with a VOC content of 2.1 lb/gal or higher, except that airless spray guns may be used to apply wiping stains in spray booths that are exhausted to the RTOs for control, and touch-up spray guns may be used to apply stains in the three repair areas. 4. The exhaust gases from the 22 spray booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered under this approval order must be vented to the RTOs for control at all times, except during coating testing, or during unavoidable upset conditions or unavoidable and unforeseeable breakdown conditions, as detailed in a) e) below: a) One automatic spray booth and associated oven may be operated at a time for periodic coating testing with the exhaust vented through the RTO emergency bypass without thermal destruction of the emissions, provided that the following conditions are met: i. The testing shall be conducted as described in Huntwood s paint testing plan, sent via e- Page 3 of 9

4 mail to SRCAA on October 10, 2005 (i.e., test quantities will not exceed 10 gallons per day, testing will occur no more than 5 days per month, etc.). ii. During each coating test when the exhaust gases from the spray booth and associated oven are not vented through the RTO, records shall be kept of the date, duration (start and end time) and quantity of each material used. Records shall be kept in accordance with Condition A.11 below. iii. During testing, all conditions in Section A. of this approval order must be met. iv. Upon written notification from the Control Officer that SRCAA has documented nuisance or odor impacts beyond the facility s property boundaries that occurred concurrent with coating testing, during all future coating testing, the exhaust gases from the automatic spray booth and associated oven must be vented to the RTOs for control. For the purposes of this NOC approval, documented is defined as receipt by SRCAA of one or more odor complaints and subsequent detection by SRCAA personnel of odors at or beyond the facility s property boundaries. b) Except during coating testing, as described in a), emissions from the spray booths and associated ovens and equipment may be exhausted uncontrolled through the RTO stack (i.e., bypass the RTOs) only during unplanned upset conditions for the purpose of protecting the health and safety of employees. c) Except during coating testing, as described in a), after a RTO bypass commences, no new parts may be started on any individual paint line (i.e., automatic stain line, automatic sealer line, automatic topcoat line, automatic glaze line, towcart line, custom hanging line, and accessories line), unless the Control Officer authorizes continued operation according to the provisions in Section 6.08 B of SRCAA Regulation I. d) Each RTO shall be equipped with a recording device to log the date, time, and duration of each incident when the bypass valve is used to route emissions from the spray booths and associated ovens and equipment uncontrolled through the RTO stack (i.e., bypass the RTOs). Records of all RTO bypasses shall be kept in accordance with Condition A.11 below. e) Except during coating testing, all occasions when the emissions from the spray booths and associated ovens and equipment are exhausted uncontrolled through the RTO stack are subject to the Report of Breakdown requirements, given in SRCAA Regulation I, Article VI, Section 6.08 and WAC The 22 spray booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered under this approval order shall be maintained in good operating condition, according to the manufacturer recommendations. Records shall be kept of the date and nature of all maintenance activities performed in each booth. Records shall be kept in accordance with Condition A.11 below. 6. Coatings containing lead or hexavalent chromium compounds in excess of 0.1% by weight shall not be used at the facility. 7. All spray application of coatings shall be conducted in a spray booth covered under a Notice of Construction approval order issued by SRCAA, except limited spray application of stains, NGRs, and color-match / repair toner may be performed using touch-up spray guns in the three repair areas which are outside of the spray booths (i.e., Repair Station #1, Color-Match / Repair #2, which includes the color-match easels and Repair Station #3), provided the quantities of coatings applied in the three repair areas do not exceed 1 gallon per day combined. Records shall be kept of the quantities of coatings applied each day in each repair area in accordance with Condition A.11 below. Page 4 of 9

5 8. All solvents containing volatile organic compounds (VOCs) or volatile toxic air pollutants (e.g., acetone) flushed through spray equipment during equipment cleaning must be collected in closed containers. 9. All materials (coatings, wash solvents, waste materials, shop towels, etc.) containing volatile organic compounds (VOC) or volatile toxic air pollutants (e.g., acetone) shall be kept in closed containers, including the waste solvent buckets on the Rotoclean automatic spray booths. 10. Records must be kept of the total amount of each coating and solvent collectively used each year in the 22 spray booths that are exhausted to the RTOs. Purchase records may be kept in lieu of usage records if the proponent assumes that purchase equals usage. The total amount of each coating and solvent collectively used in the 22 spray booths that are exhausted to the RTOs each year shall be reported to SRCAA on forms provided by SRCAA. Credit for materials recycled or disposed of as waste will be given if records documenting the amount of material recycled / disposed are kept and submitted with the annual report. Records shall be kept in accordance with Condition A.11 below. 11. The following records must be retained on site for the previous 24 months of operation and made available to SRCAA personnel upon request. a) Spray booth filter replacement records for each spray booth covered under this approval order (described in Condition A.2); b) Records of all coating tests when exhaust gases from the spray booth and associated oven are not vented through the RTO (described in Condition A.4 a) ii.); c) Records of all RTO bypasses (described in Condition A.4.d); d) Spray booth maintenance records (described in Condition A.5); e) Material Safety Data Sheets (MSDS) for each paint and solvent used in each paint booth; f) Quantities of coatings applied each day in each repair area (described in Condition A.7); and g) Coating and solvent purchase or usage records (described in Condition A.10). B. On-going Requirements for RTOs: 1. The thermal oxidizers shall be maintained in good operating condition. To ensure that the thermal oxidizers are maintained in good operating condition, the following actions shall be taken: a) Huntwood must follow the most recently SRCAA approved operation and maintenance plan (O&M) for the thermal oxidizers. The O&M plan shall at a minimum include: i. Normal operating parameters for the thermal oxidizers, including the acceptable pressure drop range and combustion chamber temperature range; ii. Description and frequency of required maintenance for the thermal oxidizers, including the external natural gas fired burners; and iii. Description of corrective actions to be taken in case of system failure or operation outside of normal operating parameters identified in i. If SRCAA determines that the O&M plan is not complete, Huntwood must provide the Page 5 of 9

6 additional information requested by SRCAA by the specified deadline. Once approved, the O&M plan shall be followed. SRCAA approval shall be obtained prior to revising the plan. A copy of the most recently approved O&M plan shall be kept on-site and made available to SRCAA personnel upon request. b) Records shall be kept of all inspection, monitoring, and maintenance activities performed on the thermal oxidizers, including the natural gas fired burners, for the previous 24 months of operation. Records shall be kept in accordance with Condition B.11 below. 2. Visible emissions from the thermal oxidizers combined exhaust stack shall not exceed 5% during any six-minute average, as determined using EPA Reference Method Only natural gas and exhaust gases from the 22 spray booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered under this approval order shall be combusted in the thermal oxidizers. 4. The thermal oxidizers exhaust stack shall have a minimum height of 45 feet above the ground and shall exhaust vertically. No elbows, tees, or stack caps that impede exhaust air vertical flow shall be installed at the end of the stack. 5. Except during unavoidable upset conditions, breakdowns, or failures which have been deemed by SRCAA to meet the requirements of WAC and SRCAA Regulation I, Section 6.08, a minimum temperature of 1500º F, or an alternative temperature, as specified by SRCAA, shall be maintained in the combustion chamber of each thermal oxidizer at all times when exhaust gases generated from one or more of the 22 spray booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered under this approval order are vented to the thermal oxidizers for control. The combustion chamber temperature in each thermal oxidizer shall be continuously monitored, using a thermocouple or other SRCAA approved method, and recorded using a stripchart recorder or other SRCAA approved recording device, whenever the thermal oxidizers are in operation. The temperature recording device (i.e., stripchart recorder or equivalent) on each thermal oxidizer shall be calibrated periodically, per the manufacturer recommendations. Records (dates, times, and temperatures) generated from the temperature data recorders and records of calibrations shall be kept in accordance with Condition B.11 below. 6. The RTOs shall destroy at least 99% by weight of the total combined volatile organic compound (VOC) and acetone emissions contained in the exhaust gases from all or any combination of the 22 spray booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered and in operation under this approval order, based on the equation below, or based on a SRCAA approved alternative equation. [Emissions in Emissions out ] * 100 > 99% Emissions in Where: Emissions in = Total VOC and acetone combined emission rate (lb/hr) in the exhaust gases from all or any combination of the 22 spray booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered and in operation under this approval order prior to entering RTOs, as determined using EPA Method 25A (it is acceptable to use Method 18 to subtract methane and/or ethane emissions from the total hydrocarbon value measured using Method 25A), or SRCAA approved alternative method; and Emissions out = Total VOC and acetone combined emission rate (lb/hr) in the exhaust gases exiting the RTOs, as determined using EPA Method 25A (it is Page 6 of 9

7 acceptable to use Method 18 to subtract methane and/or ethane emissions from the total hydrocarbon value measured using Method 25A) or SRCAA approved alternative method. During periods when the inlet VOC loading is decreased due to lower production levels at the facility, in lieu of meeting the minimum 99% destruction efficiency given above, the combined VOC and acetone emissions from the RTO exhaust stack (i.e., total emissions from both RTOs) shall not exceed the VOC limit given in Condition B The emissions from the RTO exhaust stack (i.e., total emissions from both RTOs) shall not exceed the following limits when exhaust gases generated from all or any combination of the 22 spray booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered and in operation under this approval order are vented to the thermal oxidizers for control: Oxides of nitrogen (NOx): Carbon monoxide (CO): Volatile organic compounds (VOC) and acetone combined: 1.69 pounds per hour 2.25 pounds per hour (or) 6.5 pounds per hour when the custom hanging line is running for 2 or more test runs during a source test 5.7 pounds per hour 8. A periodic source test shall be performed on the RTOs at least once every 3 calendar years to demonstrate compliance with the emission limits given in Conditions B.6 and B.7. Periodic testing must be performed at least 730 days apart. If Huntwood successfully passes two consecutive periodic source tests, Huntwood may request, and SRCAA may approve, an alternate periodic testing frequency of not less than every five calendar years. During each periodic source test, the testing, specified below, shall be conducted, unless alternate test methods or equivalent tests are requested in writing and approved by SRCAA: a) The source test plan is subject to SRCAA approval. It is the responsibility of Huntwood Industries to submit the source test plan sufficiently in advance for SRCAA to review and approve the plan, prior to the test. b) During the test, the RTOs shall be operated as close to 100% of the maximum capacity as possible (i.e., maximum expected coating application rate in each booth and total combined exhaust airflow of ~120,000 scfm). c) The combustion chamber temperature from each RTO and pressure drop across each RTO shall be recorded during each test run and reported with the test results. d) The source test shall consist of at least three separate test runs, each of which is at least one hour in duration. e) The following constituents shall be measured during each test run: i. Volumetric flow rate and temperature, per EPA Methods 1 & 2; ii. Oxygen (O 2 ) & Carbon Dioxide (CO 2 ), per EPA Method 3A; iii. Oxides of Nitrogen (NOx), per EPA Method 7E; iv. Carbon Monoxide (CO), per EPA Method 10; v. Total VOC and acetone combined emissions in the exhaust gases from the spray Page 7 of 9

8 booths and associated ovens and equipment (e.g., wiping machines, wiping conveyors, etc.) covered under this approval order prior to entering RTOs, per EPA Method 25A ((it is acceptable to use Method 18 to subtract methane and/or ethane emissions from the total hydrocarbon value measured using Method 25A); and vi. Total VOC and acetone combined emissions in the exhaust gases exiting the RTOs, per EPA Method 25A (it is acceptable to use Method 18 to subtract methane and/or ethane emissions from the total hydrocarbon value measured using Method 25A). f) A report, detailing the source test results, shall be submitted to SRCAA for approval no later than 45 days after the test is performed. 10. SRCAA shall be notified of any unavoidable upset conditions, breakdowns, or failures (e.g. occasions when the thermal oxidizer temperature falls below 1500º F, occasions when the emissions from the paint booths are exhausted uncontrolled through the vent stack, etc.) associated with the RTOs. The notification shall occur in accordance with WAC and SRCAA Regulation I, Section The following records must be retained on site for the previous 24 months of operation and made available to SRCAA personnel upon request. a) Records shall be kept of all inspection, monitoring, and maintenance activities performed on the thermal oxidizers, including the natural gas fired burners (described in Condition B.1); b) Records (dates, times, and temperatures) generated from the RTO temperature data recorders and records of calibrations (described in Condition B.5); and c) Copy of most recent stack test results (described in Condition B.8). C. Facility-wide Requirements: 1. The Control Officer, or duly authorized representative, shall be allowed to enter the facility premises at reasonable times to inspect equipment and/or records specific to the control, recovery, or release of contaminants into the atmosphere, in accordance with SRCAA Regulation I, Article II and RCW For the purposes of this NOC approval, reasonable times include, but are not limited to, any of the following: normal business and/or equipment operating hours, periods of equipment breakdown or malfunction, and times when the Control Officer, or duly authorized representative are investigating air quality complaints filed with agency and/or have reason to believe that air quality violations have occurred or may be occurring. No person shall obstruct, hamper or interfere with any such inspection. 2. It is an ongoing condition of this NOC approval that the source be registered with the agency. Registration includes the following: a) Submittal of updated registration information at least annually as required by SRCAA, using forms provided by SRCAA. The forms provided by SRCAA shall be completed and returned to SRCAA within 45 days of issuance. b) Timely payment of annual registration fees to SRCAA in the amount required by SRCAA Regulations, as periodically amended. Failure to pay registration fees and other related fees within 120 days of the annual registration billing due date will result in an administrative closure of the facility. Re-opening will be governed by SRCAA Regulation I, Section 4.02.F.2, and may include resubmissions of a Notice of Construction and Application for Approval. Page 8 of 9

9 This condition is in addition to any other remedies available to the agency for noncompliance with agency regulations, state law or federal law. General Information This Notice of Construction approval is specific to the present location (23800 E. Appleway Rd., Liberty Lake, WA) and is not transferable to a new location. If the equipment is moved from this site to a new site, a new Notice of Construction is required. It should be noted that the approval of this Notice of Construction does not relieve the proponent of the obligation to comply with all other applicable federal, state and local regulations and requirements. This order of approval may be modified, suspended or revoked in whole or in part for just cause including, but not limited to, the following: 1. Violation of any terms or conditions of this order of approval. 2. Obtaining this order of approval by misrepresentation or failure to disclose fully all relevant facts. This order of approval may be appealed as described below: Pursuant to the Revised Code of Washington (RCW) 43.21B.310, you have the right to appeal this Order by filing a notice of appeal with both the Pollution Control Hearings Board (PCHB) and the Spokane Regional Clean Air Agency (SRCAA) on or before the 30 th day of receipt of SRCAA s order, permit, license, Notice and Order of Assessment of Civil Penalty, or Notice of Disposition. Required procedures are detailed in state law (Chapter 43.21B RCW and Chapter RCW) and the PCHB s own regulations (Chapter Washington Administrative Code) which may be found in many public libraries, county and municipal law libraries or on the Internet at Since others publish these documents, copies are not available from SRCAA. If you are filing an appeal, mail it to SRCAA and the PCHB at the following addresses: SRCAA & PCHB 3104 E. Augusta Environmental Hearings Office Spokane, WA th Avenue SE, Rowe Six, Bldg. 2 P.O. Box Lacey, WA Page 9 of 9

E. Augusta, Spokane, WA (509) E. Augusta, Spokane, WA (509)

E. Augusta, Spokane, WA (509) E. Augusta, Spokane, WA (509) Notice of Construction (NOC) Approval Issued in accordance with: Chapter 70.94 RCW, SRCAA Regulation I, Article V, Chapter 173-400 WAC, and Chapter 173-491 WAC 3104 3104 E. Augusta, Spokane, WA 99207 (509)

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