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Puget Sound Clean Air Agency
Notice of Construction Worksheet
NOC Number:
10699
Reg. No. :
21429
Received Fee:
11/12/13
Due Date:
12/12/13
Inspector:
W. Voegtlin
Engineer:
A.
G. Pade
LD Commodities Seattle
Export Elevator LLC
Source Location: 955 Alaskan Way West,
Seattle, WA 98119
Source Name:
Compliance Issues:
Yes, see WW 2-008400
Project Description
One Mac Process Model 120MCF756 Baghouse rated at 63,000 cfm to replace three existing
Carter Day baghouses used for receiving grain from railcars and trucks. This permit also
includes a synthetic minor limitation for Title V avoidance.
B.
Fees
Description
Filing Fee
Review fee
SEPA DNS surcharge
Synthetic Minor surcharge
Public Notice
Total Fees for NOC
C.
Cost
Paid 11/12/13
$600
$800
$2,000
$700+publication costs
$4,100 paid 7/31/14
publication costs (to be invoiced)
SEPA Review
According to the Environmental Checklist, a checklist was sent to the Port of Seattle for the
baghouse replacement project and permits were required by the City of Seattle. However,
apparently neither agency issued a Determination of NonSignificance.
Further review by the applicant determined the earlier SEPA information was for a different
project. A replacement SEPA checklist for this proposal was prepared and submitted to this
Agency on 8/14/14. Along with the checklist, the applicant provided copies of an updated
project description (consistent with this NOC application), drawings, and copies of City of
Seattle DPD inspection reports for the project installation (e.g. Building Permit Field Inspection
Puget Sound Clean Air Agency
NOC Worksheet
Page 2 of 16
Report, Site Inspection Report, and Electrical Permit Inspection Report). The SEPA record for
this application is complete. The checklist provided by the applicant did not refer to the nonproject action of creating the Synthetic Minor emission limits to legally document the
inapplicability of the Title V (Operating Permit) Program. However, the Agency is including
this action in our SEPA review.
After review of this information, I conclude that the proposal would not have probable
significant adverse impact on the environment. I recommend that a Determination of
NonSignificance (DNS) be issued for this proposal and be open for public comment concurrently
with the proposed order of approval.
D.
Database Information (Required)
Delete CE(2) and CE(3)
Amend CE(1) as follows:
Year installed
Units installed
Rated capacity
NOC
2011
1
63000
10699
Comments (Make, model, etc.)
E.
Mac Process Model 120MCF756 for railcar and truck
receiving pits
Emission Estimate
1.
ACTUAL emissions
There should be no increase in emissions for this baghouse replacement. The EPA’s
Compilation of Air Pollutant Emission Factors has emission factors for grain receiving by
railcar. These are E rated factors, meaning poor (developed from C and D rated test data with
reason to suspect they aren’t representative).
All of the grain is received by railcar – typically around 3 million tons per year. At 95% capture
efficiency, the total fugitive emissions would be about 2.7 ton/yr. At 0.003 gr/dscf and 2000
hr/yr, the baghouse emissions would be 1.6 ton/yr.
2.
POTENTIAL to emit
At the proposed synthetic minor limit of 0.003 gr/dscf, the pte of this baghouse would be 4.1
ton/yr at 5000 hr/yr of operation (7.5 Mg/yr of grain throughput).
A.)
PRODUCTION RESTRICTIONS
None were in existence when the application was submitted.
3.
Facility wide Emissions
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 3 of 16
A.)
REPORTING SOURCE
Probably not but this is highly uncertain. Last year’s throughput was 1,383,030 Mg. If the
baghouses emitted 0.002 gr/dscf for 1000 hr/yr, their emissions would be 2.5 ton/yr and the
facility’s emissions would be 7.8 ton/yr.
B.)
SYNTHETIC MINOR
In reviewing this application, I discovered that the facility is a major source of PM, based on the
potential to emit of the baghouses alone (which have no emission limit other than 20% opacity).
Conversely, the emissions without the baghouses but with grain oiling and dead-boxes on the
ship loading spouts would be >700 ton/yr. At 7,500,000 Mg/yr and 5000 hr/yr of baghouse
operation at the anticipated baghouse emission performance levels, the potential to emit would
be about 70 ton/yr. At 8760 hr/yr, these calculations for the site estimate emissions of 99.99
ton/yr. The site has potential operational levels greater than 7,500,000 Mg/yr.
LDC preferred not to have an Air Operating Permit so they requested a synthetic minor
limitation. The methodology used to develop the synthetic minor limit is based in large part on
SWCAA’s Technical Support Document for Kalama Export Co.’s synthetic minor permit and, to
a lesser extent, their TSD for the new EGT terminal. Both relied on (uncontrolled, E-rated)
emission factors (from AP-42, Table 9.9.1.1) and SWCAA’s estimate of 65% control efficiency
for oiling the grain. Oil is applied at 0.75 gallons/1000 bushels to the grain as it falls onto the
railcar unloading belt. The TSD for Kalama Export’s permit cited four test reports with very
similar results so I’m inclined to believe this control efficiency estimate.
SWCAA has considerable experience with permitting of grain elevators and submitted
comments to EPA on the 2002 revisions to the AP-42 marine loading emission factors developed
by MRI (http://www.epa.gov/ttn/chief/ap42/ch09/related/c090901.html). Their reviewing
engineer, John St. Clair, recommended that I inspect the facility to estimate the capture
efficiencies myself, which vary considerably. Inspector Voegtlin and I visited the facility on
5/1/14 but were only able to observe railcar unloading. The practices used by the operator of the
west unloading station resulted in unnecessary fugitive emissions so I’m inclined to believe 95%
capture is probably more representative than the 99% used for Kalama Export and EGT. We
have since received a dust complaint for ship loading fugitives. The spout design used by LDC
is more similar to Kalama Export, so I’m inclined to believe the 70% capture used for Kalama
Export is more representative than the 85-98% used for EGT.
Grain is rarely loaded into trucks or railcars but LDC has that capability and wants to retain it.
We looked at the skirt/hood that fits over the open top of the truck or railcar, which was being
repaired at the time. (Kalama Export doesn’t have any control on this other than oiling; EGT
doesn’t load any trucks or railcars.) Without any data for reference and no prospect for
observing such loading, I’m inclined to assume 90% capture, provided that the aspiration rate
(cfm) is higher than the volumetric loading rate.
Screenings and dust collected by the baghouses is periodically loaded into trucks or railcars
using the same equipment. LDC assumed this amounted to 0.30% of the total of the total grain
throughput, which is at the high end of the range reported to SWCAA and over 3 times the actual
reported by LDC for 2013 (0.10% of throughput). This material is dustier than grain and was
assumed by SWCAA to be 10 times the AP-42 factor for loading of grain. LDC requested to use
the truck loading factor, even though it’s higher than the railcar loading factor, as it’s simpler
than tracking and apportioning them and the emissions aren’t significantly different. Moreover,
the last railcar of dust loaded was in 2006. SWCAA assumed that this dust was not effectively
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 4 of 16
oiled and I’m inclined to agree with them. They assumed a 50% capture for the aspirated spout
and partial enclosure. As for loading of grain, I’m inclined to assume 90% capture.
Stack emissions at LDC occur from ten baghouses. Each of the baghouses at Kalama Export
was tested and met SWCAA’s BACT limit of 0.002 gr/dscf; the results varied from 0.00010.0008 gr/dscf. LDC proposed emission limits of 0.003 gr/dscf for their two newest baghouses
and 0.008 gr/dscf for the other eight. The 0.003 gr/dscf limit was taken from a dust collector
vendor quotation and the 0.008 limit is 10 times the highest source test result from Kalama
Export. As the proposed limits are considerably less stringent than SWCAA’s BACT limit and
Kalama Export’s test data, I’m inclined to believe they will not underpredict the emissions
The baghouse PLCs are reportedly capable of logging the hours of operation of each baghouse.
LDC wants to use this data to quantify the emissions for all baghouses except system 9, which
operates continuously. I’m okay with this but wary of using a method that hasn’t yet been
proven in practice at the terminal. At our inspection on 5/1/14, I requested the relationship
between grain throughput and the hours of operation of the various baghouses. LDC agreed to
provide this information. Without it, the Agency would need to know both the grain throughput
and hours of operation of each baghouse in order to calculate the emissions.
Initial discussions with the source focused on a request that the grain throughput limit be based
on the facility’s highest actual throughput of 6.3 Mg/yr plus some safety margin. LDC proposed
a limit of 7.5 Mg/yr but more recently requested 12.5 Mg/yr. Below is a copy of my emission
calculations spreadsheet. If the baghouses were to all operate 8760 hr/yr, the spreadsheet
indicates that 7.5 Mg/yr would equate to 99.9 ton/yr of PM emissions. LDC had estimated this
throughput would require up to 5000 hr/yr of baghouse operation, which works out to 70 ton/yr
of PM emissions. An initial engineering recommendation was for the synthetic minor conditions
to include both a throughput limitation (7.5 Mg/yr) and a 70 ton/yr limit of PM emissions. This
dual approach was based on the concern about a higher degree of uncertainty in the emission
factors used in these sitewide emission estimates.
In the final analysis, the uncertainties may be addressed through other means that don’t rely on
duplicative limits and partial allowances under the Title V thresholds. The final synthetic minor
limitations will be based on 99 ton/yr of PM (equal to 99% of the Title V applicability
threshold), the baghouse performance emission limits proposed by LDC, and a requirement for
LDC to notify the Agency in the event the annual PM emissions reach 75 ton/yr (75% of the
Title V threshold). This notification of emission estimates for the site that are approaching that
intermediate threshold will provide the opportunity for LDC and the Agency to cooperatively
review the emission factors and/or identify new information or other pathways to address the
uncertainties before the Title V emission threshold might be exceeded.
The proposed synthetic minor conditions also specify that LDC shall use an emission calculation
methodology approved in advance by the Agency. The emission factors and assumptions
included in the embedded spreadsheet file below represent the methodology that the Agency is
proposing approval of for this purpose. In the event that LDC had new information or wanted to
consider different calculation methods, those changes would need to be approved by the Agency
prior to their use.
LDC NOC 10699 & SM
FINAL 9-23-14.xlsx
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 5 of 16
C.)
OPERATING PERMIT
This facility will be a synthetic minor source upon issuance of this permit. Technically, the
operating permit program applicability should have been addressed prior to this review. The
source has never reported emissions above Agency reporting thresholds (thresholds at 25% of
the Title V program).
F.
Applicable Regulations
1.
PUGET SOUND CLEAN AIR AGENCY
Regulation I, Sections 5.05, 9.03 and 9.20 apply.
Regulation I, Section 5.05(c)
(c) The owner or operator of a registered source shall develop and implement an operation
and maintenance plan to ensure continuous compliance with Regulations I, II, and III. A
copy of the plan shall be filed with the Control Officer upon request. The plan shall reflect
good industrial practice and shall include, but not be limited to, the following:
(1) Periodic inspection of all equipment and control equipment;
(2) Monitoring and recording of equipment and control equipment performance;
(3) Prompt repair of any defective equipment or control equipment;
(4) Procedures for start up, shut down, and normal operation;
(5) The control measures to be employed to ensure compliance with Section 9.15 of this
regulation; and
(6) A record of all actions required by the plan.
The plan shall be reviewed by the source owner or operator at least annually and updated to
reflect any changes in good industrial practice.
Regulation I, Section 9.03
(a) It shall be unlawful for any person to cause or allow the emission of any air contaminant
for a period or periods aggregating more than 3 minutes in any 1 hour, which is:
(1) Darker in shade than that designated as No. 1 (20% density) on the Ringelmann Chart, as
published by the United States Bureau of Mines; or
(2) Of such opacity as to obscure an observer's view to a degree equal to or greater than
does smoke described in Section 9.03(a)(1).
(b) The density or opacity of an air contaminant shall be measured at the point of its
emission, except when the point of emission cannot be readily observed, it may be measured
at an observable point of the plume nearest the point of emission.
Regulation I, Section 9.20(a)
(a) It shall be unlawful for any person to cause or allow the operation of any features,
machines or devices constituting parts of or called for by plans, specifications, or other
information submitted pursuant to Article 6 of Regulation I unless such features, machines or
devices are maintained in good working order.
Regulation I, Section 9.09 does not apply, as this equipment is not used in a manufacturing
process. None of the emission units at this facility have a numerical emission limit for PM under
Regulation I, II or III.
2.
STATE
WAC 173-400-040 applies.
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 6 of 16
WAC 173-400-040 General standards for maximum emissions.
(1) All sources and emissions units are required to meet the emission standards of this
chapter. Where an emission standard listed in another chapter is applicable to a specific
emissions unit, such standard takes precedence over a general emission standard listed in this
chapter. When two or more emissions units are connected to a common stack and the
operator elects not to provide the means or facilities to sample emissions from the individual
emissions units, and the relative contributions of the individual emissions units to the common
discharge are not readily distinguishable, then the emissions of the common stack must meet
the most restrictive standard of any of the connected emissions units.
All emissions units are required to use reasonably available control technology (RACT)
which may be determined for some sources or source categories to be more stringent than the
applicable emission limitations of any chapter of Title 173 WAC. Where current controls are
determined to be less than RACT, the permitting authority shall, as provided in RCW
70.94.154, define RACT for each source or source category and issue a rule or regulatory
order requiring the installation of RACT.
(2) Visible emissions. No person shall cause or allow the emission for more than three
minutes, in any one hour, of an air contaminant from any emissions unit which at the emission
point, or within a reasonable distance of the emission point, exceeds twenty percent opacity
except:
***
(3) Fallout. No person shall cause or allow the emission of particulate matter from any
source to be deposited beyond the property under direct control of the owner or operator of
the source in sufficient quantity to interfere unreasonably with the use and enjoyment of the
property upon which the material is deposited.
(4) Fugitive emissions. The owner or operator of any emissions unit engaging in materials
handling, construction, demolition or other operation which is a source of fugitive emission:
(a) If located in an attainment area and not impacting any nonattainment area, shall take
reasonable precautions to prevent the release of air contaminants from the operation.
(b) If the emissions unit has been identified as a significant contributor to the
nonattainment status of a designated nonattainment area, the owner or operator shall be
required to use reasonable and available control methods, which shall include any
necessary changes in technology, process, or other control strategies to control emissions
of the air contaminants for which nonattainment has been designated.
***
(6) Emissions detrimental to persons or property. No person shall cause or allow 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.
***
(9) Fugitive dust.
(a) The owner or operator of a source or activity that generates fugitive dust must take
reasonable precautions to prevent that fugitive dust from becoming airborne and must
maintain and operate the source to minimize emissions.
WAC 173-400-060 does not apply to these emission units as this is not a general process unit as
defined in WAC 173-400-030.
(40) "General process unit" means an emissions unit using a procedure or a combination of
procedures for the purpose of causing a change in material by either chemical or physical
means, excluding combustion.
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 7 of 16
None of the emission units at this facility have a numerical emission limit for PM under the state
Clean Air Act (other than the 20% opacity limit in WAC 173-400-040(2) above).
3.
FEDERAL
None of the emission units at this facility have a federal emission limit for PM.
This project does not constitute the construction, modification, or reconstruction of the railcar
unloading stations or truck unloading station. This facility was built in 1970, well before 8/3/78.
Therefore, NSPS Subpart DD (Standards of Performance for Grain Elevators) is not applicable.
40 CFR §60.300 Applicability And Designation Of Affected Facility.
(a) The provisions of this subpart apply to each affected facility at any grain terminal elevator
or any grain storage elevator, except as provided under §60.304(b). The affected facilities
are each truck unloading station, truck loading station, barge and ship unloading station,
barge and ship loading station, railcar loading station, railcar unloading station, grain dryer,
and all grain handling operations.
(b) Any facility under paragraph (a) of this section which commences construction,
modification, or reconstruction after August 3, 1978, is subject to the requirements of this
part.
4.
Registration Applicability/Fee Classification
There will be no changes related to this project. However, the synthetic minor limit carries with
it a surcharge of $2300/yr. If PM emissions are >25 ton/yr, a surcharge of $60/ton will also
apply.
20140594 21429.pdf
G.
Technology Review BACT, RACT, LAER
This project is being reviewed under WAC 173-400-114.
WAC 173-400-114 Requirements for replacement or substantial alteration of emission
control technology at an existing stationary source.
(1) Any person proposing to replace or substantially alter the emission control technology
installed on an existing stationary source or emission unit shall file a notice of construction
application with the appropriate authority, or with ecology in areas or for sources over which
ecology has jurisdiction. Replacement or substantial alteration of control technology does not
include routine maintenance, repair or similar parts replacement.
(2) A project to replace or substantially alter emission control technology at an existing
stationary source that results in an increase in emissions of any air contaminant is subject to
new source review as provided in WAC 173-400-110. For any other project to replace or
significantly alter control technology the permitting authority may:
(a) Require that the owner or operator employ RACT for the affected emission unit;
(b) Prescribe reasonable operation and maintenance conditions for the control equipment;
and
(c) Prescribe other requirements as authorized by chapter 70.94 RCW.
(3) Within thirty days of receipt of a notice of construction application under this section
ecology or the authority shall either notify the applicant in writing that the application is
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 8 of 16
complete or notify the applicant in writing of all additional information necessary to complete
the application. Within thirty days of receipt of a complete notice of construction application
under this section ecology or the authority shall either issue an order of approval or a
proposed RACT determination for the proposed project.
(4) Construction shall not "commence," as defined in WAC 173-400-030, on a project subject
to review under this section until ecology or the authority issues a final order of approval.
However, any notice of construction application filed under this section shall be deemed to be
approved without conditions if ecology or the authority takes no action within thirty days of
receipt of a complete notice of construction application.
(5) Approval to replace or substantially alter emission control technology shall become
invalid if construction is not commenced within eighteen months after receipt of such
approval, if construction is discontinued for a period of eighteen months or more, or if
construction is not completed within a reasonable time. Ecology or the authority may extend
the eighteen-month period upon a satisfactory showing that an extension is justified. This
provision does not apply to the time period between construction of the approved phases of a
phased construction project; each phase must commence construction within eighteen months
of the projected and approved commencement date.
Per WAC 173-400-030:
WAC 173-400-030 Definitions.
(77) "Reasonably available control technology (RACT)" means the lowest emission limit that
a particular source or source category is capable of meeting by the application of control
technology that is reasonably available considering technological and economic feasibility.
RACT is determined on a case-by-case basis for an individual source or source category
taking into account the impact of the source upon air quality, the availability of additional
controls, the emission reduction to be achieved by additional controls, the impact of
additional controls on air quality, and the capital and operating costs of the additional
controls.
1.
GENERIC RACT
We have some generic requirements for baghouses (see Section G.2 of this worksheet). Some
BACT determinations have included grain loading limits of 0.01 gr/dscf or less.
2.
Similar to:
The most recent baghouse permits I reviewed (NOC Nos. 10695 and 10617) contained the
following conditions:
3. There shall be no visible emissions or fallout from these dust collectors.
4. These dust collectors shall be equipped with gauges to measure the pressure drop across
the filters. The normal operating range of pressure drop shall be clearly marked on (or near)
the gauges within 30 days after startup and shall be included in the Operation &
Maintenance plan.
5. These dust collectors shall be inspected monthly while in operation. If any exhibit visible
emissions or fallout or are operating outside of the normal pressure drop range, [facility
name] shall take corrective actions (as specified in the Operations and Maintenance Plan)
within 24 hours of the initial observation.
6. Records fully documenting all inspections and corrective actions shall be maintained for at
least 5 years and be made available to Puget Sound Clean Air Agency personnel upon request
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 9 of 16
3.
Case-by-Case RACT:
The new 64,000 cfm Mac Process Model 120MCF756 baghouse holds 756, 10’ long, felted and
singed Dacron polyester bags with a total filter area of 9,147 ft² providing an air to cloth ratio of
7:1. According to the Air Pollution Engineering Manual (AP-40, 2nd Edition, p. 112, Table 5.)
this is safely below the (typical) 14:1 ratio for pulse-jet baghouses used for feed and grain. It
offers the following features:
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 10 of 16
A baghouse like this is the appropriate control technology. However, RACT is an emission
limit. The (inapplicable 1978) NSPS limits in §60.302 of NSPS Subpart DD for such baghouses
are 0.01 gr/dscf and 0% opacity. The corresponding (inapplicable) fugitive emission limit for
the railcar and truck release points is 5% opacity, as determined by EPA Method 9.
40 CFR §60.302 Standard For Particulate Matter.
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 11 of 16
***
(b) On and after the date on which the performance test required to be conducted by §60.8 is
completed, no owner or operator subject to the provisions of this subpart shall cause to be
discharged into the atmosphere from any affected facility except a grain dryer any process
emission which:
(b)(1) Contains particulate matter in excess of 0.023 g/dscm (ca. 0.01 gr/dscf).
(b)(2) Exhibits greater than 0 percent opacity.
(c) On and after the 60th day of achieving the maximum production rate at which the affected
facility will be operated, but no later than 180 days after initial startup, no owner or operator
subject to the provisions of this subpart shall cause to be discharged into the atmosphere any
fugitive emission from:
(c)(1) Any individual truck unloading station, railcar unloading station, or railcar loading
station, which exhibits greater than 5 percent opacity.
RACT should be no less stringent than the NSPS emission limits plus our generic monitoring
requirements for baghouses (see Section G.2 of this worksheet). Below are copies of the O&M
plan and malfunction plan submitted on 6/20/14. The O&M plan includes weekly checks of the
baghouses for visible emissions and abnormal pressure drops, It also includes monthly checks of
the cleaning mechanism, quarterly inspections of the bags, and semiannual inspections of the
housing ducts and hoods. Corrective actions are to be taken within 8 ‘business’ hours of finding
a problem.
Operations and
Dust System
Maintenace Plan.rev.3.docx
Malfuntion.doc
A limit of 0.003 gr/dscf for this baghouse is being proposed as part of the synthetic minor order
emission calculation methodology. This is RACT.
H.
Ambient Impact Analysis
Per WAC 173-460-040(1), an impact analysis is not required for replacement or substantial
alteration of control equipment unless it results in an increase in emissions. This project does
not.
I.
Public Notice Requirement
Notice of receipt of the application was posted on our website per WAC 173-400-171(a) and (b)
but formal public notice in the newspaper isn’t required under WAC 173-400-171(c) unless the
Agency determines there is substantial public interest. There was no public interest in our
website posting and I do not believe there is substantial public interest in the baghouse
replacement.
Notwithstanding, public notice is required for the synthetic minor component per WAC 173-400171(3)(k).
J.
Operating Permit or PSD
There is no increase in actual or allowable emissions so PSD is not applicable.
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 12 of 16
K.
Recommended Approval Conditions
Rail & Truck Unloading Baghouse
3. The particulate emissions from this baghouse shall not exceed 0.003 gr/dscf, as determined by
EPA Method 5.
4. There shall be no visible emissions or fallout from this baghouse.
5. This baghouse shall be equipped with gauges to measure the pressure drop across the filters.
The normal operating range of pressure drop shall be clearly marked on (or near) the gauge
within 30 days after startup and shall be included in the Operation & Maintenance plan.
6. This baghouse shall be inspected weekly while in operation. If any exhibit visible emissions
or fallout or are operating outside of the normal pressure drop range, LDC shall take corrective
actions (as specified in the Operations and Maintenance Plan) within 24 hours of the initial
observation.
7. Records fully documenting all inspections and corrective actions shall be maintained for at
least 5 years and be made available to Puget Sound Clean Air Agency personnel upon request.
Synthetic Minor Limit
LDC shall limit particulate matter emissions from the facility to no more than 99 tons per year
during each consecutive 12-month period.
Synthetic Minor Conditions
LDC shall calculate and record the monthly and 12-month rolling total emissions within 30 days
of the end of each month in accordance with a methodology approved in advance by the Puget
Sound Clean Air Agency. This methodology shall also be used to report annual emissions above
reporting thresholds in Regulation I, Article 5
LDC shall notify the Agency in writing no later than 60 days after the end of the month in which
the 12-month rolling total emissions first exceeds 75 tons/yr.
A minimum of 0.75 gal/1000 bushels of oil shall be applied to the grain as it is received.
The particulate emissions from the baghouses for system #12 (loading spouts/suppressors) and
the new system (railcar/truck unloading) shall not exceed 0.003 gr/dscf and the emissions from
the other baghouses shall not exceed 0.008 gr/dscf, as determined by EPA Method 5.
All of the baghouses shall be inspected weekly while in operation. If any exhibit visible
emissions or fallout or they are operating outside of their normal pressure drop range, LDC shall
take corrective actions (as specified in the Operations and Maintenance Plan) within 24 hours of
the initial observation.
Records shall be retained documenting compliance with these conditions for at least 5 years and
be made available to Puget Sound Clean Air Agency personnel upon request.
L.
Recommendation for Legal Review
None.
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 13 of 16
M.
Other Comments
The baghouse replacement is the subject of Written Warning No. 2-008400. The Corrective
Action Order required the submittal of a Notice of Construction application by 9/18/13. The
application was not received until 11/12/13.
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 14 of 16
Form No. 70-180 (9/2009 ns)
Puget Sound Clean Air Agency
NOC Worksheet
Page 15 of 16
Has the source seen this:
Emailed to Kevin
McNab
Date:
12/10/13
Done By:
Gerry Pade
Date:
12/10/13
Inspector Review:
Walter Voegtlin
Date:
7/16/14
Reviewed by:
Supervising Engineer
Form No. 70-180 (9/2009 ns)
Date:
Puget Sound Clean Air Agency
NOC Worksheet
Page 16 of 16
NOTICE OF PUBLIC HEARING
PUGET SOUND CLEAN AIR AGENCY
Proposed Order of Approval No. 10699
LD Commodities, LLC
Grain Export Terminal
955 Alaskan Way W, Pier 86
Seattle, WA 98119
We are giving public notice that LD Commodities (LDC) has filed an application with the Puget
Sound Clean Air Agency (the Agency) for the replacement of several dust collectors and has
concurrently requested the Agency to limit the total dust emissions from their grain export
terminal to no more than 99 tons during any 12-consecutive months, in accordance with
procedures approved by the Agency. The proposed emission limit formally establishes the
facility as a minor source under the Air Operating Permit program in Chapter 173-401 WAC.
PRELIMINARY DETERMINATION
The Agency has completed a review of NOC application No. 10699 and has made a preliminary
determination that the proposal meets all the requirements of Regulations I, II and III, and WAC
173-400-091 and should be approved. The Agency, as the lead agency for this proposal under
SEPA, has also made a preliminary determination that the issuance of Order of Approval No.
10699 would not have a probable significant adverse impact on the environment. The
Determination of NonSignificance (DNS) for this proposal is issued in accordance with WAC
197-11-340(2).
PUBLIC COMMENT
The application and the information considered in making these preliminary determinations are
on file and available for inspection at the Agency’s office located at 1904 3rd Ave, Suite 105,
Seattle, Washington, telephone (206) 689-4011. The proposed Order of Approval No. 10699,
along with the engineering review worksheet for this proposal, is also available on the Agency’s
website www.pscleanair.org.
Comments must be submitted in writing within 30 days of the publication date of this notice to
Steve Van Slyke, Puget Sound Clean Air Agency, 1904 3rd Ave, Suite 105, Seattle, Washington
98101, by fax to (206) 343-7522, or by e-mail to [email protected]. All comments received
during the comment period will become part of the public record. Anyone may request a public
hearing within the 30-day public comment period. A request must indicate the interest of the
entity filing it and why a hearing is warranted. The Agency may hold a public hearing if it
determines that significant public interest exists. Once the Agency has reviewed and responded
to comments from the public, the draft Order will, if necessary, be revised, and then issued in
final form.
Form No. 70-180 (9/2009 ns)