TECHNICAL SUPPORT DOCUMENT TRISTAR TRANSLOAD PNW, INC. SWCAA ID: Air Discharge Permit Air Discharge Permit Application CL-3004

Transcription

1 SW CAA Southwest Clean Air Agency TECHNICAL SUPPORT DOCUMENT TRISTAR TRANSLOAD PNW, INC. SWCAA ID: 2500 Air Discharge Permit Issued: May 24, 2017 Prepared By: Clint Lamoreaux Air Quality Engineer Southwest Clean Air Agency

2 TABLE OF CONTENTS Section I. Facility Identification 2. Facility Description 3. Current Permitting Action 4. Process Description 5. Equipment/ Activity Identification 6. Emissions Determination 3 7. Regulations and Emission Standards 7 8. RACT/BACT/BART/LAER/PSD/CAM Detenninations 8 9. Ambient Impact Analysis Discussion of Approval Conditions Start-up and Shutdown Provisions/ Alternative Operating Scenarios/Pollution I 0 Prevention 12. Emission Monitoring and Testing FacilityHistory II 14. Public Involvement 11 Page

3 Abbreviations ADP AP-42 BACT BART Btu CAS# CPM CFR co C02e EPA GWP HAP lb/hr lb/mm Btu lb/yr MMBtu/hr NOx PM PM10 ppm PSD RCW SQER S02 SW CAA TAP T-BACT tpy voe WAC Air Discharge Permit Compilation of Emission Factors, AP-42, Fifth Edition. Volume I, Stationary Point and Area Sources - published by the US Environmental Protection Agency Best available control technology Best Available Retrofit Technology British thermal unit Chemical Abstracts Service registry number Condensable particulate matter Code of Federal Regulations Carbon monoxide Carbon dioxide equivalent U.S. Environmental Protection Agency Global warming potential Hazardous air pollutant listed pursuant to Section 112 of the Federal Clean Air Act Pounds per hour Pounds per million British thermal units Pounds per year Millions of British thermal units per hour Nitrogen oxides Total particulate matter (includes both filterable and condensable particulate matter as measured by EPA Methods 5 and 202) Particulate matter with an aerodynamic diameter less than or equal to I 0 micrometers (includes both filterable and condensable particulate matter as measured by EPA Methods 5 and 202) Pa1ticulate matter with an aerodynamic diameter less than or equal to 2.5 micrometers (includes both filterable and condensable particulate matter as measured by EPA Methods 5 and 202) Parts per million Prevention of Significant Deterioration Revised Code of Washington Small Quantity Emission Rate listed in WAC Sulfur dioxide 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: Applicant Address: 3702 NW Gateway Ave., Vancouver, WA Facility Name: Facility Address: SWCAA Identification: Contact Person: Primary Process: SIC/NAICS Code: Facility Classification: Tristar Transload PNW, Inc 3702 NW Gateway Ave., Vancouver, WA Mr. Peter Howe Butane transfer 5171 / BACT / Minor 2. FACILITY DESCRIPTION Tristar Transload will transfer butane/lpg from railcars to tanker trucks using two portable transloaders. 3. CURRENT PERMITTING ACTION This permitting action is in response to Air Discharge Permit application number CL-3004 (ADP Application CL-3004) received February 15, ADP application CL-3004 requests approval to operate two portable transloaders. Each transloader is powered by a diesel engine-powered hydraulic compressor. 4. PROCESS DESCRIPTION Butane/LPG will be received by railcar on a rail spur at the site. Two liquid lines and one vapor return line will be connected to the railcar and the tank truck. The transfer compressor and hydraulics on each transloader will be powered by a diesel engine. The compressor pushes vapor collected from the tank car to the top of the railcar, which pushes liquid butane out of drop tubes in the railcar. Displaced vapors are all retained within this system (balanced vapor recovery, no displacement venting). The rail spur at the site can accommodate up to eight railcars at one time. The connectors to the railcar and tank truck are valved off until connected. At disconnection, the space between the valves is vented. Operators know that the rai lcar is empty when only vapor is being pushed through the liquid loading lines. This is evident from sight glasses on liquid line check valves. Emissions result from the diesel engines, leaks, and venting of the connectors upon disconnection. No, flares, heaters, chillers, dryers, or intermediate storage tanks are associated with the transloading process. The faci lity will primarily operate during the winter season when there is butane demand for blending into gasoline. 5. EQUIPMENT/ACTIVITY IDENTIFICATION 5.a Transloader I. The compressor on Transloader I is powered by the Transloader I Engine. Specific equipment details are listed below: Make I Model: Serial Number: Manufactured: Custom "Unit 15" identifier found on the unit 2016 Transfer Rate: gallons per minute Connection Points: (6) - Two liquid connections and one vapor connection to the railcar, two liquid connections and one vapor connection to the tank truck.

5 Potential Leak Points: - 8 valves in vapor service, 11 valves in liquid service, I compressor, 92 screwed connectors and flanges in vapor service, 82 connectors and flanges in liquid service, I pressure relief device in vapor service, and 4 pressure relief devices in liquid service. 5.b Transloader 2. The compressor on Transloader I is powered by the Transloader I Engine. Specific equipment details are listed below: Make I Model: Custom Serial Number: Unknown Manufactured: Unknown Transfer Rate: gallons per minute Connection Points: (6) - Two liquid connections and one vapor connection to the railcar, two liquid connections and one vapor connection to the tank truck. Potential Leak Points: -8 valves in vapor service, 11 valves in liquid service, I compressor, 92 screwed connectors and flanges in vapor service, 82 connectors and flanges in liquid service, I pressure relief device in vapor service and 4 pressure relief devices in liquid service. 5.c Transloader 1 Engine. Specific equipment details are listed below: Make I Model: Serial Number: Manufactured: Fuel: Engine Power: Certification: Stack Description: Yanmar I 4TNV84T-ZDSADT October 19, 2010 Diesel 55.2 brake horsepower EPA Interim Tier 4-2" diameter oriented vertically -6' above grade 5.d Trans loader 2 Engine. Specific equipment details are listed below: Make I Model: Serial Number: Manufactured: Fuel: Engine Power: Certification: Stack Description: Yanmar I 4TNV84T-ZDSADT September 14, 2016 Diesel 55.2 brake horsepower EPA Interim Tier 4-2" diameter oriented vertically - 6' above grade 5.e Equipment/Activity Summary. ID #of No. Generating Equipment/Activity Units Control Measure/Equipment 1 Transloader I I Balanced vapor recovery 2 Transloader 2 1 Balanced vapor recovery 3 Transloader 1 Engine 1 Ultra-low sulfur diesel, EPA Interim Tier 4 Certification 4 Transloader 2 Engine I Ultra-low sulfur diesel, EPA Interim Tier 4 Certification #of Units I 1 NIA NIA 2

6 Tristar Transload PN W, Inc. 6. EMISSIONS DETERMINATION 6.a Transloading. Potential emissions were estimated using the South Coast Air Quality Management District's "Guidelines for Fugitive Emissions Calculations (June 2003)." In this guidance, the District updated emissions factors that were identified in the EPA's "Protocol for Equipment Leak Emission Estimates (November 1995)". For purposes of determining emissions, equipment in contact with liquid butane is considered to be in "light liquid" service and equipment in contact only with butane vapor is in "vapor service". There are a variety of techniques for determining emissions from leaking components. In this case, SWCAA has determined that the use of an "average" emission factor for untested components and a "screening value range" emission factor for tested components provides a straightforward method of determining emissions. The "average" emission factor was determined using actual survey data from multiple facilities and based on the survey, a ce1tain percentage of components at the facilities were found to be leaking and others were not. Using statistical methods, an average emission rate among all the components within the survey sample was determined and represents a probable leak rate for components that have not been tested. This would represent a base level for determining emissions from a facility that has not yet been built or for a facility that has not determined whether a specific component was leaking. Once a testing program has been established, then a "screening value range" emission factor can be used. Using similar survey data and a screening value - which is typically 500 ppm, 1,000 ppm, 10,000 ppm, or I 00,000 ppm - a probable leak rate can be calculated for a screening value range. For example, assuming the screening value is 10,000 ppm, there would be two ranges, <10,000 ppm and 2:10,000 ppm, and using the actual leak rates determined during the survey, an emission factor for components leaking < l 0,000 ppm or 2: 10,000 ppm can be determined. Based on leak-no leak determination or an actual leak concentration reading, a faci lity can determine which emission factor to use. In the case where a non-numeric method is being used, such as a soap solution, SWCAA assumes that if no leak is detected that the component could be leaking at less than the screening value and that if a leak is detected then it is leaking at a rate above the screening value. From an emissions standpoint, this means that only the presence or absence of a leak is necessary to determine which emission factor to use. Based on the above discussion, the following emission factors are used to determine fugitive emissions: Description Average Emission Factor (lb/hr)/unit Non-Leaker (<10,000 ppm) Emission Factor (lb/hr)/unit Leaker (2:10,000 ppm) Emission Factor (lb/hr)/unit Valves (includes flanges) in Vapor Service I.4x x x 10-2 Valves (includes flanges) in Light Liquid Service 5.4x J0-3 3Jx I x 10-2 Others (compressors, sightglasses, meters, etc.) in Vapor Service I.7x! x x 10-2 Fittings (connectors and flanges) in Vapor Service 5.6x I x I x l0-2 Fittings (connectors and flanges) in Light Liquid Service 5.6x 10-4 J.6 x I 0-5 l.4x J0-2 Pressure Relief Devices (PRVs) in Vapor Service 2.2x x Jx

7 Tristar Trans load PNW, Inc. Description Average Emission Factor (lb/hr)/unit Non-Leaker (<10,000 ppm) Emission Factor (lb/hr)/unit Pressure Relief Devices (PRVs) in Light Liquid Service 2.2x x Applies to any component other than fittings, pump seals, or valves. Leaker (~10,000 ppm) Emission Factor (lb/hr)/unit 5.1 x 10-2 With the exception of the PRVs, all leaker/non-leaker emission factors came from Table IV-2b. PRV's nonleaker/ leaker emission factors came from the emission factors for valves because no comparable emission factors was available in Table IV-2b. Average emission factors for all components came from the Terminals/Depots table on Page 6. To calculate potential fugitive leak emissions the total number of each component type was counted on one of the transloaders and the number multiplied by 1.25 to account for up to 25% more components on each transloader. This allows for minor configuration modifications (and the potential for miscounting). c omponent Count per T rans I oa d er Valves in Vapor Service 8 Valves in Light Liauid Service 11 Others (compressors, sight-glasses, meters, etc.) in Vapor Service l Fittings (connectors and flanges) in Vapor Service 92 Fittings (connectors and flanges) in Light Liquid Service 82 Pressure Relief Devices in Vapor Service I Pressure Relief Devices in Liquid Service 4 Based on the number of components and using the "average" emission factor, the emissions from the components on both transloaders combined are calculated to be 3,231 lb/yr ( 1.62 tpy) of butane based on 8,760 hours per year of service. Connection I Disconnection During disconnection of the transfer connector valve assemblies from the railcars and tanker trucks, the internal volume between the valves on each end of the connection must be vented. There are two liquid connections and one vapor connection to each railcar and tanker truck. Railcars and tanker trucks have butane load capacities of approximately 30,000 gallons and 8,000 gallons respectively. Therefore, four tanker trucks will be needed to unload each railcar. Each tanker truck could be connected/disconnected twice if the truck is disconnected to be weighted once prior to completion of loading. Potential emissions from disconnection were calculated from a total potential throughput of 200,000 barrels per year (8,400,000 gallons per year). This translates to unloading 280 railcars into 1,050 tanker trucks per year. It is assumed that there is one disconnection of each railcar before it is fully unloaded, and two disconnections of every truck before the railcar is fully unloaded. When a railcar is fully unloaded, it is not empty, but vapor has displaced the majority of the liquid in the liquid transfer lines. In this fully unloaded state, disconnection results in negligible butane emission. Disconnection emissions are - I 00 times lower when the transfer lines are filled with vapor instead of liquid (butane vapor density is times less than butane liquid at the temperatures and pressures in the lines transfer lines). 4

8 The liquid transfer lines have a nominal diameter of 2". The liquid connections to the railcars have approximately 18" of connection between the isolation valves. Approximately 2.46 pounds of butane would be lost when these two liquid lines are decoupled from the railcar before the railcar is empty. The liquid connections to the tanker truck have approximately 3.5" of connection between the isolation valves. Approximately 0.48 pounds of butane would be lost when these two liquid lines are decoupled from the tanker truck before the railcar is empty. Based on these estimates an average of 1.57 pounds of butane will be emitted per truck loaded. Disconnecting Emissions Number of Truckloads= Emissions per Truckload = Annual Emissions= 1, lbs/event 0.82 tons The above emission factor per truckload must be used to calculate annual em issions from the facility unless the number of truck and railcar disconnections is documented. If the number of truck and railcar disconnections is documented, the railcar and tanker truck disconnection factors (2.46 lbs/event and 0.48 lbs/event respectively) may be used. 5

9 6.b Transloader 1 Engine and Transloader 2 Engine. Potential annual emissions from the combustion of ultra-low sulfur diesel (<0.0015% sulfur by weight) were calculated with the assumption that each engine will operate at full load for up to 3,080 hours per year. Each engine is capable of producing 55.2 horsepower at full load. Skid Engines (each) Hours of Operation = 3,080 hours Power Output = 55.2 horsepower Diesel Density = pounds per gallon Fuel Sulfur Content = % by weight Fuel Consumption Rate = gallons per hour Fuel Heat Content = MMBtu/gal (for use with GHG factors from 40 CFR 98) Annual Fuel Consumption = 9,783 gallons Emission Emission Emission Factor Factor Factor Emissions Emission Factor Pollutant lb/hp-hr lb/hr lb/1,000 gal tpy Source NOx I CARBCERT co CARBCERT voe AP-42 Table (10/96) SOx as S Mass Ba lance PM/PM1 0/PM2.s CARB CERT C02e C02e Greenhouse Gases kg/mmbtu GWP lb/mmbtu lb/gallon tpy, C02e C CFR 98 C H CFR 98 N CFR 98 Total GHG - C0 2 e Emissio ns must be calculated us ing the hourly emission factors identified above unless new emission factors are developed through source testing. 6.c Facilitywide Potential Emissions (PTE) Summary. Pollutant N itrogen oxides Carbon monoxide Volatile organic compounds Sulfur oxides as sulfur dioxide Particulate matter PM1 0 PM2.s Toxic Air Po llutants Hazardous Air Pollutants C02e Annual Emissions (tpy)

10 7. 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 ( 40 CFR) Part et seq. "Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines" requires that new diesel engines meet specific emission standards at the point of manufacture and during operation. In addition, maximum fuel sulfur contents are specified and minimum maintenance standards are established. The Transloader I Engine and the Transloader 2 Engine are affected sources. For new non-emergency engines, the following is required: (I) Owners or operators must comply with the emission standards for new nonroad compression ignition engines as specified in , for all pollutants. New non-emergency engines must meet the same standards as nonroad engines for the same size and model year found in 40 CFR 89 or 40 CFR [40 CFR (b)] (2) Owners or operators must operate and maintain each stationary CI internal combustion engine and control device according to the manufacturer's written instructions. In addition, owners and operators may only change those settings that are permitted by the manufacturer; and (40 CFR l(a)] (3) Beginning October 1, 20 I 0, owners and operators must use diesel fuel with a sulfur content that does not exceed 15 ppm. [ 40 CFR (b )] 7.b 40 CFR 68 "Chemical Accident Prevention Provisions" requires affected stationary sources to compile and submit a risk management plan, as provided in Sections to Applicability is determined by the type and quantity of material at the facility. This facility is subject to this regulation because more than I 0,000 pounds of butane will be present at one time at the facility. Submission of an initial plan is scheduled for May c 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.d 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 Air Discharge Permit for installation and establishment of an air contaminant source. 7.e Washington Administrative Code (WAC) "Controls for New Sources of Toxic Air Pollutants" (as in effect August 21, 1998) requires Best Available Control Technology for toxic air pollutants (T-BACT), identification and quantification of emissions of toxic air pollutants and demonstration of protection of human health and safety. 7.f WAC "Ambient Air Quality Standards" establishes ambient air quality standards for PM1 0, PM2.s, lead, sulfur dioxide, nitrogen dioxide, ozone, and carbon monoxide in the ambient air, which shall not be exceeded. 7.g SWCAA "General Standards for Maximum Emissions" requires all new and existing sources and emission units to meet certain 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. 7.h SW CAA (1) "Visible Emissions" requires that no emission of an air contaminant from any emissions unit shall 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

11 7.i SWCAA (2) "Fallout" requires 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.j SWCAA (3) "Fugitive Emissions" requires that reasonable precautions be taken to prevent the fugitive release of air contaminants to the atmosphere. 7.k SWCAA (4) "Odors" requires that any person who shall cause or allow the generation of any odor from any source, which may unreasonably interfere with any other property owner's use and enjoyment of their property use recognized good practices and procedures to reduce these odors to a reasonable minimum. 7.1 SWCAA (5) "Emissions Detrimental to Persons or Property" prohibits the emission of any air contaminant from any "source" if it is detrimental to the health, safety, or welfare of any person, or causes damage to property or business. Some of the coating materials utilized at this facility contain compounds that are not T APs under WAC , however can be harmful if inhaled. If no filtration is used, the ambient impact could exceed the relevant worker health thresholds for these compounds. 7.m SWCAA (8) "Fugitive Dust Sources" requires that reasonable precautions be taken to prevent fugitive dust from becoming airborne, and minimize emissions. 7.n SWCAA "Emission Standards for Combustion and Incineration Units" requires that all prov1s1ons of SWCAA be met and that no person shall cause or permit the emission of particulate material from any combustion or incineration unit in excess of 0.23 grams per dry cubic meter (0.1 grains per dry standard cubic foot) of exhaust gas at standard conditions. 7.o SW CAA "New Source Review" requires that an Air Discharge Permit Application be filed with SWCAA, and an Air Discharge Permit be issued by SW CAA, prior to establishment of the new source, emission unit, or modification. 7.p SW CAA "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: ( I) 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 wi ll 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 The proposed equipment and control systems incorporate Best Available Control Technology (BACT) for the types and amounts of air contaminants emitted by the processes as described below: 8.a BACT Determination - Fugitive Emissions. Potential fugitive leaks from this facility are relatively small, however the effort to annually check for leaks should be relatively small, providing a cost-effective method of controlling fugitive leaks. SWCAA has determined that implementation a leak detection and repair program utilizing annual leak detection meets the requirements of BACT for the control of fugitive emissions from this faci lity. 8

12 8.b BACT Determination - Transloader I Engine and Transloader 2 Engine. One option to reduce emissions from operating the hydraulic system is to use alternative fuels (other than diesel) to drive the process. Electricity is an alternative fuel for this process. The applicant indicated that replacing the existing engines (the transloaders are already built with the incorporated diesel engines), would cost approximately $80,000 each for the motor and $20,000 for the electrical upgrades to the site. Offsetting this would be the reduction in maintenance and fuel costs. The reduction in fuel costs could be on the order of $ 11,000 per year per engine based on 3,080 hours of operation per year at full load, each engine burning 9, 783 gallons of fuel per year, a diesel cost of $2.30 per gallon and an electrical cost of $0.08 per kw-hr. Using an 8% cost of capital and a 5 year equipment life (15,400 hour of operation), the cost-effectiveness of replacing the diesel engines at this point in over $10,000 per ton of pollutant prevented. The CARB certification for this engine indicates an 8,000 hour useful life. The applicant has informed SWCAA that based on the fuel consumption records for a similar facility, the average engine load is less than 20% of maximum load (a facilities operating 24 hours per day burned no more than 400 gallons of fuel per month while at full load the engine would burn approximately 2,300 gallons per month). Based on this analysis, replacement of the engines with electric motors will not be a cost-effective method of reducing emissions. Available control measures for new diesel engines include engine design, the use of ultra-low sulfur fuel and addon control equipment such as selective catalytic reduction (SCR) units and oxidation catalysts. Because emission rates from these engines are relatively low (the engines meet EPA's Interim Tier 4 emission standards) neither SCR for NOx em issions, nor an oxidation catalyst for CO, VOC and organic PM emissions would be costeffective. The use of modern diesel-fired engine design meeting the relevant EPA emission standard for the new engines as applicable, the use of ultra-low sulfur diesel fuel (~ % sulfur by weight), limitation of visible emissions to 5% opacity or less, and limitation of lifetime engine operation to 3,080 hours per year has been determined to meet the requirements of BACT for the types and quantities of air contaminants emitted. The use of ultra-low sulfur fuel is also required by 40 CFR 60 Subpart IJIJ for "new" engines. 8.c Prevention of Significant Deterioration (PSD) Applicability Determination. This permitting action will not result in a potential increase in emissions equal to or greater than the PSD thresholds. Therefore, PSD review is not applicable to this action. 8.d Compliance Assurance Monitoring (CAM) Applicability Determination. CAM is not applicable to any emission unit at this facility because it is not a major source and is not required to obtain a Part 70 permit. 9. AMBIENT IMPACT ANALYSIS Emissions of criteria air pollutants or precursors (nitrogen oxides, carbon monoxide, sulfur oxides, particulate matter, and volatile organic compounds) are all at or below 3 tons per year each. At these emission rates, no significant adverse ambient air quality impact is anticipated. Incremental increases in toxic air pollutant emissions wi ll not exceed the applicable Small Quantity Emission Rates (SQER) listed in WAC (in effect August 21, 1998); therefore toxic impacts are presumed to be below regulatory significance. Conclusions 9.a Operation of the butane trans loading facility as proposed in ADP Application CL-3004 will not cause the ambient air quality requirements of Title 40 Code of Federal Regulations (CFR) Part 50 "National Primary and Secondary Ambient Air Quality Standards" to be violated. 9

13 9.b The butane transloading facility proposed in ADP Application CL-3004, can be operated without causing a violation of the applicable emission standards, which include the limits established under SWCAA "General Standards for Maximum Emissions." 9.c Operation of the butane transloading facility as proposed in ADP application CL-3004 in accordance with the Air Discharge Permit will not cause the requ irements of WAC "Controls for New Sources of Toxic Air Po llutants," (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 contains approval requirements deemed necessary to assure compliance with applicable regulations and emission standards as discussed below. l O.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. I O.b Emission Limits. Emission limits were established equivalent to the emission potentials identified in Section 6. Engine emissions are based on 3,080 hours of operation per year, which is the maximum operation identified by the applicant. 1 O.c Operating Limits and Requirements. The fugitive VOC emission potential is relatively small, so leak detection was required only annually. Consistent with USEPA rules for other industries, leaking components must be repaired within 15 days. Because this fac ility is not a continuous process, no delay provisions related to process shutdown were included. l O.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. excess emission reporting, a nnual emission inventory submission). In addition, engine maintenance activities and leak detection events must be logged for each occurrence. Engine maintenance logs can be used to assure that the engines are being operated in accordance with 40 CFR 60 Subpart IIII. This record also allows the facility and SWCAA inspectors to assure the equipment is being properly maintained and investigate any complaints or excess emissions incidents. I O.e Emission Monitoring and Testing Requirements. See Section 12. I O.f Reporting. The permit requires reporting of the annual air emissions inventory, and reporting of the data necessary to develop the inventory. Excess emissions must be reported immediately in order to qualify for relief from monetary penalty in accordance with SWCAA In addition, prompt reporting was required because it allows for accurate investigation into the cause of the event and prevention of similar future incidents. 11. START-UP AND SHUTDOWN/ ALTERNATIVE OPERA TING SCENARIOS/POLLUTION PREVENTION I I.a Start-up and Shutdown Provisions. Pursuant to SW CAA "Start-up 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 start-up or shutdown. Where it is determined that a source is not capable of achieving continuous compliance with an emission standard during statt -up or shutdown, SWCAA shall include appropriate emission limitations, operating parameters, or other criteria to regulate performance of the source during start-up or shutdown. T his source is capable of achieving continuous compliance with all applicable requirements; therefore no startup or shutdown provisions were included in the Air Discharge Permit. 10

14 1 1.b Alternate Operating Scenarios. SWCAA conducted a review of alternate operating scenarios applicable to equipment affected by this permitting action. Neither SWCAA nor the permittee identified or proposed any applicable alternate operating scenarios. Therefore, none were included in the approval conditions. 1 I.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, none were included in the approval conditions. 12. EMISSION MONITORING AND TESTING Potential emissions from the diesel engines were too small to warrant periodic emission testing. A relatively simple leak detection and repair program was required because the relatively small effort is justified by the potential emissions prevented. 13. FACILITY HISTORY This will be a new facility. 14. PUBLIC INVOLVEMENT 14.a Public Notice for. Public notice for Air Discharge Permit Application CL-3004 was published on the SWCAA internet website for a minimum of 15 days beginning on February 24, b Public/Applicant Comment for. 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 May 24, 2017 for this project. SWCAA consulted with Mr. Chad Lawry (Lead Deputy Fire Marshal for the City of Vancouver) regarding fire-related issues. Mr. Lawry indicated that fire-related issues would be adequately addressed through required permits, and would have no comments regarding SEPA. 11