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ESCO Corporation Title V Permit, No. 26-2068

Semi-Annual Report

Semi-Annual Compliance Certification

FORM R1002

Semi-Annual Compliance Certification Answer Sheet

Oregon Department of Environmental Quality Page 1 of 3

Oregon Title V Operating Permit Application Forms revised 1/31/12

Facility name: ESCO Corporation: Main Plant and Plant 3 Permit Number: 26-2068

1. Reporting period January 1, 2016 through June 30, 2016

2. Plan development/revision triggered [yes/no] No

3. Compliance status:

a. Permit Condition

Number

b. Compliance

Statues (C/I) c. Emissions Unit(s)

d. Permit

Deviation

Type

e. Number of

Deviations

3 C

4 C

5 C

6 C

7 C

8 C

9 C

10 C

11 C

12 C

13 C

14 C

15 C

16 C

17 C

18 C

19 C

20 C

21 C

22 C

23 I MU-3 Material

Handling/Sand Transport

EE 1 (See Appendix A)

24 C

25 C

26 C

27 C

C

C

28 C

29 C

30 C

31 C

32 C

33 C

34 C

35 C

36 C

37 C

38 C

39 C

40 C

41 C

42 C

FORM R1002




43 C

44 C

45 C

46 C

47 C

48 C

49 C

50 C

51 C

52 C

53 C

54 C

55 C

56 C

57 C

58 C

59 C

60 C

61 C

62 C

63 C

64 C

65 C

66 C

67 C

68 C

69 C

70 C

71 C

72 C

73 C

74 C

75 C

76 C

77 C

78 C

79 C

80 C

81 C

82 C

83 C

84 C

85 C

86 C

87 C

88 C

89 C

90 C

91 C

92 C

G4 C

FORM R1002




G5 C

G6 C

G7 C

G8 C

G9 C

G10 C

G12 C

G13 C

G14 C

G15 C

G16 C

G17 C

G18 C

G19 C

G20 C

G23 C

G26 C

G29 C

1. Pursuant to Form R1002 Instructions, Permit conditions 1, 2, G1, G2, G3, G11, G21, G22, G24, G25, G27 and G28

are not listed.

Statement of Certification:

Based on information and belief formed after reasonable inquiry, the statements and information in this document

and any attachments are true, accurate and complete. I also certify that all statements made concerning

compliance, which are based on monitoring required by the permit but not required to be submitted to the Department,

are true, accurate and complete based on information and belief formed after reasonable inquiry.

Travis Quarles Lead Environmental Engineer

Name of Responsible Official Title of Responsible Official

Signature of Responsible Official Date

FORM R1003


Facility name: ESCO Corporation: Main Plant and Plant 3 Permit Number: 26-2068

1. Reporting period January 1, 2016 through June 30, 2016

2. Summary of permit deviations:

a. Permit

Condition

Number

b. Emissions

Unit(s) c. Cause

d. Time Began e. Time Ended

f. Deviation g. Corrective Action/Prevention (date) (hour) (date) (hour)

23 MU-3 pa 05/09 02:30 05/09 08:30 EE See May 24, 2016 Deviation Report




Semi-Annual Report

Semi-Annual Compliance Certification – NESHAP Subpart ZZZZZ

World Headquarters 2141 NW 25th Avenue

Portland, Oregon 97210-2578

Phone: 503.228.2141 Fax: 503.499.6040

www.escocorp.com

July 29, 2016 Subject: Semi-Annual Report pursuant to 40 CFR Part 63, Subpart ZZZZZ:

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundry Area Sources

ESCO Corporation submits the following semi-annual report pursuant to the U.S. Environmental Protection Agency (EPA)’s NESHAP for Iron and Steel Foundries Area Sources, 40 CFR § 63.10899(c). This report is for the affected large foundry sources, at the locations identified below. Name and address of owner or operator:

ESCO Corporation 2141 NW 25th Avenue Portland, OR 97210

Physical location and regulatory status of the affected source: ESCO Corporation – Main Plant 2141 NW 25th Avenue Portland, OR 97210 Title V Air Permit No. 26-2068 Existing Source, Large Foundry

ESCO Corporation – Plant 3 2211 NW Brewer Street Portland, OR 97210 Title V Air Permit No. 26-2068 Existing Source, Large Foundry

Semiannual reporting period: 01-January-2016 thru 30-June-2016 - Report due date: 30-July-2016.

Summary Information: Management Practices for Metallic Scrap and Binder Formulation

A. ESCO Corporation’s Main Plant and Plant 3 foundries operated in compliance with written material specifications for metallic scrap according to 40 CFR § 63.10885(a)(1) of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report.

B. ESCO Corporation’s Main Plant and Plant 3 foundries operated in compliance with written material specifications for general iron and steel scrap according to 40 CFR § 63.10885(a)(2) of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report.

C. ESCO Corporation’s Main Plant and Plant 3 foundries operated in compliance with the no methanol requirement for the catalyst portion of each binder chemical formulation for a furfuryl alcohol warm box mold or core making line according to 40 CFR § 63.10886 of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report.

Management Practices for Mercury Switch Removal

ESCO Corporation’s Main Plant and Plant 3 foundries operated in compliance with the requirements for scrap that does not contain motor vehicle scrap in accordance with 40 CFR § 63.10885(b)(4) of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report.

of 2

Notification and Compliance Status for Emission Limits, Capture and Collection System and O & M Plan

A. ESCO Corporation’s Main Plant and Plant 3 foundries notifies and operated in compliance with the requirements for emission limits in accordance with 40 CFR § 63.10895(c)(1) of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report.

B. ESCO Corporation’s Main Plant and Plant 3 foundries notifies and operated in compliance with the requirements for opacity limits in accordance with 40 CFR § 63.10895(e)of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report.

C. ESCO Corporation’s Main Plant and Plant 3 foundries notifies and operated in compliance with the requirements for capture and collection systems associated with melting in accordance with 40 CFR § 63.10895(b) of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report.

D. ESCO Corporation’s Main Plant and Plant 3 foundries notifies and operated in

compliance with the requirements of their written operation and maintenance (O&M) plan for affected emission sources in accordance with 40 CFR § 63.10896(a) of Subpart ZZZZZ, during the reporting period. ESCO Corporation has no deviations from those requirements to report. The latest Air Emission Control Device Operating Plan (AECDOP) was revised and submitted to DEQ on April 28, 2016.

E. ESCO Corporation’s Main Plant and Plant 3 foundries notifies and operated in

compliance with the requirements for reporting excess emissions in accordance with 40 CFR § 63.10(e)(3)(v) of Subpart ZZZZZ, during the reporting period. One deviation with excess emissions was reported in this first half of 2016. The deviation is described in Appendix A.

Certification and Signature: I hereby certify that based on information and belief formed after reasonable inquiry, the statements in this document are true, accurate, and complete. Name of Responsible Official Title Date

Travis Quarles Lead Environmental Engineer July 29, 2016

Signature of Responsible Official


Semi-Annual Report

Monthly Process Parameters and Emission Calculations

Emission Summary

Production Inputs

RACT Compliance – Main Plant and Plant 3

ESCO Corp: Main Plant and Plant 3 Compliance Dates:

Issue Date 3/1/2012 2/1/2015 1/31/2016

Emission Summary PSEL 11/30/2011

Pollutant Baseline/Netting Basis Previous PSEL Emission Inventory Estimate PSEL from permit

tpy tpy tpy tpy

PM10 264 214 29.5 134

PM2.5* 264 29.5 134

CO 277 312 136.7 348

NOx 71 65 26.6 65

SO2 7 39 2.6 39

VOC 122 93 27.9 93

Lead 0.10 0.10 0.03 0.10

CO2e 25,826 14,735.0 74,000

Individual HAP 9 3.5 9

Total HAPs 24.4 8.2 24

* PM2.5 is a subset of PM10. Emissions assume PM2.5 is 100% of PM10.

Hazardous Air Pollutants

Pollutant

lb/yr tpy

Lead 54.9 0.03

Mn 299.0 0.15

Ni 66.7 0.03

Cr 34.3 0.02

Hg 1.8 0.00

Cd 11.0 0.01

Co 3.1 0.00

As 3.4 0.00

Sb 0.4 0.00

Se 7.9 0.00

Phenol 7,018.3 3.51

Formaldehyde 3,089.0 1.54

Benzene 999.8 0.50

Cresols 1,442.5 0.72

Toluene 518.5 0.26

Naphthalene 424.4 0.21

Triethylamine 51.5 0.03

Diisocyanates 6.2 0.00

Trimethylbenzene 28.2 0.01

POMs* 0.0 0.00

Hexane 323.9 0.16

Dichlorobenzene 0.2 0.00

Acrolein 35.1 0.02

Ethylbenzene 58.2 0.03

Xylenes 248.7 0.12

Biphenyl 74.7 0.04

Aniline 104.1 0.05

Acetaldehyde 191.8 0.10

Methylnaphthalene 472.7 0.24

Propionaldehyde 11.0 0.01

Cyanide compounds 320.0 0.16

Dimethylaniline 73.3 0.04

Tetrachloroethylene 19.3 0.01

Trichloroethylene 230.4 0.12

Cumene 28.3 0.01

MIBK 23.4 0.01

Styrene 42.0 0.02

Total HAPs 16,318.1 8.2

*POMs excluding naphthalene and methylnaphthalene

24 tpy major source threshold

from natural gas combustion


Emission Inventory Notes

ESCO Corporation Air Permit No. 26-2068

Facility name/site identifier ESCO Corp: Main Plant and Plant 3

Permit number 26-2068 Compliance Dates:

Issue Date 3/1/2012 2/1/2015 1/31/16

Production Inputs PSEL 11/30/2011

Main Plant Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)

Main Plant Total 6,168.00 4,436.00

EAF 6,168.00 4,436.00

AOD - 5810.00

Doghouse -

V-Bay 1,901.00

Main Floor/Slinger Bay 2,266.00

Chain Floor 269.00

MP, 12 Month Rolling Gas

Usage, mmcf: 117.80

Plant 3 Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)

Plant 3 Total 11,014.00 9,523.00

EAF/Pouring Loop 10,831.00 9,351.00

Research Induction - -

Research AOD -- -

Induction 183.00 172.00

P3, 12 Month Rolling Gas

Usage, mmcf: 48.80

Welding rods and wire 19,962 lb/yr based on 4.5 lb per tmp in MP

P3 Resin usage 523,765 lb/yr based on 55 lb resin per tmp in P3

P3 Coated Sand Throughput 6,715 tons/yr Assumes 78 lb resin/ton sand in P3

MP Sand Usage 2,662 tons/yr based on 0.6 tons/tmp new sand into system

Production Inputs 2 of 5 PSEL 01-2016

Plant Site Emission Limits (PSEL)

Natural Gas Usage - Yearly and Monthly 2/1/2015 Thru 1/31/2016

Enter Data into Yellow Cells

Issue Date 3/1/2012

Rolling 12 Month

Sum

Rolling 12 Month

Sum

Month/Yr Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15 Total (therms) Total (mmcf)

Main Plant Therms 124,207 108,751 110,778 117,674 105,959 95,611 87,499 87,911 79,278 91,715 95,892 108,065 1,213,340 117.800

Plant 3 Therms 39,032 46,892 56,070 50,025 43,506 49,333 38,969 36,800 33,078 34,752 36,059 38,154 502,670 48.803

166.6

Note; effective 01-Jan-10, Btu factor was changed to 1030 Btu/cu ft per Northwest Natural. Previously was 1036 Btu/cu ft.

Facility name/ site identifier ESCO Corp - Main Plant and Plant 3

Permit number 26-2068

Issue Date 3/1/2012

Reporting Period 2/1/2015 Thru 31-Jan-16

Coating RACT Limit Compliance Determination

Emission Unit MU-9 COAT Enter Data into Yellow Cells

Based on daily average of coatings as applied

Building 9; Air Dried Paint Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15

12 Month

Consumption

(gal/yr)

Coating MSDS VOC as

Applied Content (lbs/gal)

Tank Adjuster Thinner, HAP's-free (28400) added to Green 55 0 0 0 0 55 0 5 0 0 55 0 170 7.49

Green Dip Enamel, Low HAP/VOC (28GG402) added to tank 165 0 273 0 163 0 0 165 0 324 110 161 1,361 3.28

Volume of old paint in tank at time of thinner addition. VOC

content of old paint < original, however using original for

calculations sake. 1,147 0 0 0 0 1,147 0 1,197 0 0 1,147 0

Operating Volume in Tank; 1202 gallons. VOC content averaged

from given quantities of old, new and thinner. Represents

material as applied.

Monthly VOC Paint content from given quantities of old, new

and thinner as Applied. 3.5 3.3 3.3 3.3 3.3 3.5 3.3 3.3 3.3 3.3 3.5 3.3

Tank Adjuster Thinner, HAP's-free (28400) added to Red 55 0 0 0 0 0 0 0 0 0 55 0 110 7.49

Red Dip Enamel, Low HAP/VOC (28RG401) added to tank 0 0 0 165 0 0 0 0 55 108 110 161 599 3.38



calculations sake. 1,034 0 0 0 0 0 0 0 0 0 1,034 0






Building 4; Chain Dip-Painting





calculations sake. 695 700 0 0 0 0 0 0 0 0 0 0




For RACT compliance includes all dip-paint colors. 3.5 3.5 3.4 3.4 3.4 3.4 3.4 3.4 3.4 3.4 3.4 3.4

Monthly avg. VOC Paint content from given quantities of old,

new and thinner as applied. 3.5 3.4 3.3 3.3 3.3 3.4 3.3 3.4 3.3 3.3 3.5 3.3

RACT Limit (operating air permit, condition 13)

Clear Coatings

Tank Adjuster Thinner, HAP's-free (28400) added to Clear 0 0 0 0 0 0 0 0 0 0 0 0 0 7.49

Clear Dip Enamel, Low HAP/VOC (28LG403) added to tank 0 0 0 0 0 0 0 0 0 0 0 0 0 3.48

Volume of old clear coating in tank at time of thinner addition.

VOC content of old clear coating < original, however using

original for calculations sake. 0 0 0 0 0 0 0 0 0 0 0 0




Monthly avg. VOC Clear Coatings content from given

quantities of old, new and thinner as applied. 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5


Total gallons/yr Wt Avg VOC lbs/gal

NOTES: Total 2,285 3.91

1. Paint usage from Paint/Coat Usage Logs Non-Clear 2,285 3.91

2. The lower-end of the paint tank operating levels for each tank were used as a conservative volume for calculating normal tank operating volumes Clear 0 #DIV/0!

3. All paint, as purchased from Drew Paint, has a VOC content that is less than the RACT VOC/gallon limit. Paint VOC content can not be in excess of the limit.

Glycol went from non-HAP to HAP, effective 01-Apr-05

Effective 02-Mar-06, paint component; ethylene glycol monobutyl ether (EB) was de-listed by EPA/DEQ and is no longer a HAP.

Main Plant dip painting usages only.

Stopped using yellow dip-paint. Removed tanks from service 15Sep09. Dropped from monthly averaging for Aug, 2010 reporting.

Started Red chain dip-painting at the Main Plant in Building 4, beginning Sep, 2010.

As applied is also referred to as "ready for application".

Per 14-Mar-11 call with George Davis; RACT compliance is based on the sum of coating types (listed in Cond. 13). Chain dip-tank usages summed with other "Force Air Dried or Air Dried Coatings".

4.3

4. Over time, the paint within the paint tanks thickens, especially if the paint is infrequently used, and may require adjustment (addition of thinner). Prior to any addition of thinner or water, the paint tank contents are viscosity tested by

Drew Paint personnel to determine the quantity of material needed to thin the paint and maintain proper paint specifications for the process. If tank adjuster is needed, it is delivered to ESCO on an as-need basis; no adjuster is stored at

ESCO. For purposes of calculating the RACT VOC content of paint in months when thinner is added, this spread sheet conservatively assumes that the VOC content of the paint in the tank (prior to thinning), is the same at the specified VOC

content for new paint. In actuality, the paint tank VOC content is less than the "as purchased" VOC content (based on paint sampling results); testing data shows that the dip tank paint is more viscous, has lower VOC content and has

greater solids content.

5. OAR 340-232-0160 "no person shall operate a coating line which emits into the atmosphere volatile organic compounds in excess of the limits of this rule". ESCO Paint and Packing operates only one coating line with several types of

paint available on that one paint line. Only one type of paint is applied per casting.

6. In-line averaging has been implemented, so that monthly average RACT VOC content of coatings, used on a single coating line is less than the applicable VOC content limit (low VOC coatings offset high VOC coatings). See, Wisconsin DNR

7. The "coating VOC" (also known as the regulatory VOC) from the paint MSDS, is used for RACT compliance only. "Coating VOC" excludes water and exempt solvents and is expressed as a higher VOC number (the denominator is smaller).

578

Monthly Reconciliation of Coating/Paint (gallons)

1,202

1,089

720

3.5


Permit number 26-2068Issue Date 3/1/2012

Reporting Period 2/1/2015 Thru 31-Jan-16


Emission Unit MU-9 COAT - Plant 3 Spray Painting Enter Data into Yellow CellsBased on daily average of coatings as applied

Air Dried Paint Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15

12 Month

Consumption (gal/yr)

Coating MSDS VOC as

Applied Content

(lbs/gal)

Green Spray Paint, low VOC & no HAP (07GG402); gallons 220 275 215 165 220 330 330 230 220 220 165 330 2,920 1.18

Monthly VOC Paint Content as Applied. 1.18 1.18 1.18 1.18 1.18 1.18 1.18 1.18 1.18 1.18 1.18 1.18

Cat Yellow Spray Paint, low VOC & no HAP (07YG502); gallons 0 0 0 0 0 0 0 0 0 0 0 0 0 1.12Monthly VOC Paint Content as Applied. 1.12 1.12 1.12 1.12 1.12 1.12 1.12 1.12 1.12 1.12 1.12 1.12

Red Spray Paint, low VOC & no HAP (07RG401); gallons 0 0 0 0 0 10 0 0 5 0 0 0 15 1.10


CLR Paint, low VOC & no HAP (07GG402); gallons 0 0 0 0 0 0 10 0 10 5 0 0 25 1.18


Total (gal/yr) wt avg VOC (lbs/gal)

2,960 1.18

Monthly avg. VOC Paint content from given quantities as

Applied. 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13

RACT Limit (operating air permit, condition 13) (OAR 340-

232-0160 (j)(B) force air-dried or air-dried)

NOTES:

1. Paint usage from Plant 3 staff

2. All paint, as purchased from Drew Paint, has a VOC content that is less than the RACT VOC/gallon limit.


R & D Plant 3 spray painting from Jan-Nov, 2007. Went to full production spray painting beginning Dec, 2007; received Oregon DEQ approval.

Effective 10-Mar-09, started using red spray paint at Plant 3.

Beginning Jun-09, all P3 red parts are now dip-painted at the Main Plant.

Plant 3 spray paint; water-based acrylic.



3.5

3. OAR 340-232-0160 "no person shall operate a coating line which emits into the atmosphere volatile organic compounds in excess of the limits of this rule". ESCO Paint and Packing operates only one coating line with several types of paint

available on that one paint line. Only one type of paint is applied per casting.

4. In-line averaging has been implemented. See, Wisconsin DNR form SBCA-MCR-10

5. The "coating VOC" (also known as the regulatory VOC) from the paint MSDS, is used for RACT compliance only. "Coating VOC" excludes water and exempt solvents and is expressed as a higher VOC number (the denominator is smaller). As an

example: "coating VOC" = ((density of paint)(% total wt. of VOC - water and exempt VOC))/(100 - volume water - volume exempt). The "material VOC" is expressed as a lower number since nothing is extracted from the denominator. As an example,

the CAT Yellow dip paint has a "coating VOC" content of 2.99 lb/gal; however, a portion of the original gallon of paint has been removed (water and exempt solvents) and the denominator is no longer one, but a fraction of one. Final RACT VOC

emissions will be greater/higher than those reported on Air Permit form R1001-C (where the "material VOC" is used). See CARB example below.


Issue Date 3/1/2012 3/1/2015 2/29/2016



tpy tpy tpy tpy

PM10 264 214 29.1 134

PM2.5* 264 29.1 134

CO 277 312 134.7 348

NOx 71 65 26.3 65

SO2 7 39 2.6 39

VOC 122 93 28.1 93

Lead 0.10 0.10 0.03 0.10

CO2e 25,826 14,631.0 74,000





Pollutant

lb/yr tpy

Lead 54.0 0.03

Mn 294.2 0.15

Ni 65.6 0.03

Cr 33.7 0.02

Hg 1.8 0.00

Cd 10.8 0.01

Co 3.0 0.00

As 3.3 0.00

Sb 0.4 0.00

Se 7.8 0.00

Phenol 6,915.8 3.46


Benzene 984.9 0.49

Cresols 1,421.2 0.71

Toluene 510.7 0.26





POMs* 0.0 0.00

Hexane 322.8 0.16


Acrolein 34.6 0.02


Xylenes 245.0 0.12

Biphenyl 73.6 0.04

Aniline 102.5 0.05








Cumene 27.9 0.01

MIBK 23.0 0.01

Styrene 41.4 0.02

Total HAPs 16,080.9 8.0









Issue Date 3/1/2012 3/1/2015 2/29/16


Main Plant Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)


EAF 6,073.00 4,366.00

AOD - 5706.00

Doghouse -

V-Bay 1,871.00


Chain Floor 265.00


Usage, mmcf: 117.81

Plant 3 Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)

Plant 3 Total 10,832.00 9,385.00



Research AOD -- -

Induction 185.00 174.00


Usage, mmcf: 48.36









Issue Date 3/1/2012

Rolling 12 Month

Sum

Rolling 12 Month

Sum



Plant 3 Therms 39,032 42,372 56,070 50,025 43,506 49,333 38,969 36,800 33,078 34,752 36,059 38,154 498,150 48.364

166.2




Issue Date 3/1/2012

Reporting Period 3/1/2015 Thru 29-Feb-16





12 Month

Consumption

(gal/yr)

Coating MSDS VOC as
















calculations sake. 1,034 1,034 0 0 0 0 0 0 0 0 1,034 0



















Clear Coatings
























4.3










578


1,202

1,089

720

3.5



Reporting Period 3/1/2015 Thru 29-Feb-16




12 Month


Coating MSDS VOC as

Applied Content

(lbs/gal)









3,015 1.18


Applied. 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13



NOTES:










3.5









Issue Date 3/1/2012 4/1/2015 3/31/2016



tpy tpy tpy tpy

PM10 264 214 29.4 134

PM2.5* 264 29.4 134

CO 277 312 133.9 348

NOx 71 65 26.2 65

SO2 7 39 2.6 39

VOC 122 93 28.0 93

Lead 0.10 0.10 0.03 0.10

CO2e 25,826 14,636.0 74,000





Pollutant

lb/yr tpy

Lead 54.5 0.03

Mn 299.7 0.15

Ni 65.6 0.03

Cr 34.1 0.02

Hg 1.7 0.00

Cd 10.9 0.01

Co 3.1 0.00

As 3.3 0.00

Sb 0.4 0.00

Se 7.8 0.00

Phenol 6,833.5 3.42


Benzene 982.8 0.49

Cresols 1,412.8 0.71

Toluene 511.5 0.26





POMs* 0.0 0.00

Hexane 322.6 0.16


Acrolein 34.5 0.02


Xylenes 244.3 0.12

Biphenyl 75.2 0.04

Aniline 104.0 0.05








Cumene 28.0 0.01

MIBK 23.5 0.01

Styrene 42.3 0.02

Total HAPs 15,959.2 8.0









Issue Date 3/1/2012 4/1/2015 3/31/16


Main Plant Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)


EAF 6,241.00 4,463.00

AOD - 5874.00

Doghouse -

V-Bay 1,912.00


Chain Floor 271.00


Usage, mmcf: 118.34

Plant 3 Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)

Plant 3 Total 10,671.00 9,241.00



Research AOD -- -

Induction 177.00 167.00


Usage, mmcf: 47.61









Issue Date 3/1/2012

Rolling 12 Month

Sum

Rolling 12 Month

Sum



Plant 3 Therms 39,032 42,372 48,295 50,025 43,506 49,333 38,969 36,800 33,078 34,752 36,059 38,154 490,375 47.609

166.0




Issue Date 3/1/2012

Reporting Period 4/1/2015 Thru 31-Mar-16





12 Month

Consumption

(gal/yr)

Coating MSDS VOC as



































Clear Coatings
























578


1,202

1,089

720

3.5

4.3












Reporting Period 4/1/2015 Thru 31-Mar-16




12 Month


Coating MSDS VOC as

Applied Content

(lbs/gal)









3,515 1.18


Applied. 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13



NOTES:










3.5









Issue Date 3/1/2012 5/1/2015 4/30/2016



tpy tpy tpy tpy

PM10 264 214 29.0 134

PM2.5* 264 29.0 134

CO 277 312 130.9 348

NOx 71 65 25.7 65

SO2 7 39 2.6 39

VOC 122 93 27.5 93

Lead 0.10 0.10 0.03 0.10

CO2e 25,826 14,401.5 74,000





Pollutant

lb/yr tpy

Lead 53.6 0.03

Mn 295.5 0.15

Ni 64.1 0.03

Cr 33.6 0.02

Hg 1.7 0.00

Cd 10.8 0.01

Co 3.0 0.00

As 3.3 0.00

Sb 0.4 0.00

Se 7.7 0.00

Phenol 6,664.0 3.33


Benzene 962.8 0.48

Cresols 1,381.7 0.69

Toluene 501.8 0.25





POMs* 0.0 0.00

Hexane 318.0 0.16


Acrolein 33.8 0.02


Xylenes 239.2 0.12

Biphenyl 74.5 0.04

Aniline 102.7 0.05








Cumene 27.5 0.01

MIBK 23.3 0.01

Styrene 41.9 0.02

Total HAPs 15,595.9 7.8









Issue Date 3/1/2012 5/1/2015 4/30/16


Main Plant Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)


EAF 6,175.00 4,422.00

AOD - 5805.00

Doghouse -

V-Bay 1,895.00


Chain Floor 268.00


Usage, mmcf: 117.05

Plant 3 Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)

Plant 3 Total 10,374.00 8,997.00



Research AOD -- -

Induction 176.00 166.00


Usage, mmcf: 46.59









Issue Date 3/1/2012

Rolling 12 Month

Sum

Rolling 12 Month

Sum



Plant 3 Therms 39,032 42,372 48,295 39,501 43,506 49,333 38,969 36,800 33,078 34,752 36,059 38,154 479,851 46.587

163.6




Issue Date 3/1/2012

Reporting Period 5/1/2015 Thru 30-Apr-16





12 Month

Consumption

(gal/yr)

Coating MSDS VOC as



































Clear Coatings
























578


1,202

1,089

720

3.5

4.3












Reporting Period 5/1/2015 Thru 30-Apr-16




12 Month


Coating MSDS VOC as

Applied Content

(lbs/gal)









3,790 1.18


Applied. 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13



NOTES:










3.5









Issue Date 3/1/2012 6/1/2015 5/31/2016



tpy tpy tpy tpy

PM10 264 214 28.9 134

PM2.5* 264 28.9 134

CO 277 312 130.1 348

NOx 71 65 25.5 65

SO2 7 39 2.6 39

VOC 122 93 27.3 93

Lead 0.10 0.10 0.03 0.10

CO2e 25,826 14,293.9 74,000





Pollutant

lb/yr tpy

Lead 53.1 0.03

Mn 293.0 0.15

Ni 63.5 0.03

Cr 33.3 0.02

Hg 1.7 0.00

Cd 10.7 0.01

Co 3.0 0.00

As 3.2 0.00

Sb 0.4 0.00

Se 7.6 0.00

Phenol 6,641.9 3.32


Benzene 960.6 0.48

Cresols 1,378.0 0.69

Toluene 500.1 0.25





POMs* 0.0 0.00

Hexane 316.0 0.16


Acrolein 33.7 0.02


Xylenes 238.6 0.12

Biphenyl 74.5 0.04

Aniline 102.6 0.05








Cumene 27.4 0.01

MIBK 23.3 0.01

Styrene 41.9 0.02

Total HAPs 15,545.4 7.8









Issue Date 3/1/2012 6/1/2015 5/31/16


Main Plant Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)


EAF 6,113.00 4,422.00

AOD - 5733.00

Doghouse -

V-Bay 1,895.00


Chain Floor 268.00


Usage, mmcf: 116.01

Plant 3 Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)

Plant 3 Total 10,299.00 8,964.00



Research AOD -- -

Induction 190.00 181.00


Usage, mmcf: 46.54









Issue Date 3/1/2012

Rolling 12 Month

Sum

Rolling 12 Month

Sum



Plant 3 Therms 39,032 42,372 48,295 39,501 43,059 49,333 38,969 36,800 33,078 34,752 36,059 38,154 479,404 46.544

162.6




Issue Date 3/1/2012

Reporting Period 6/1/2015 Thru 31-May-16





12 Month

Consumption

(gal/yr)

Coating MSDS VOC as



Green Dip Enamel, Low HAP/VOC (28GG402) added to tank 165 0 0 0 0 0 0 165 0 324 110 161 925 3.28
































Clear Coatings
























4.3










578


1,202

1,089

720

3.5



Reporting Period 6/1/2015 Thru 31-May-16




12 Month


Coating MSDS VOC as

Applied Content

(lbs/gal)









4,010 1.18


Applied. 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13



NOTES:










3.5









Issue Date 3/1/2012 7/1/2015 6/30/2016



tpy tpy tpy tpy

PM10 264 214 28.6 134

PM2.5* 264 28.6 134

CO 277 312 128.0 348

NOx 71 65 25.2 65

SO2 7 39 2.6 39

VOC 122 93 27.0 93

Lead 0.10 0.10 0.03 0.10

CO2e 25,826 14,220.6 74,000





Pollutant

lb/yr tpy

Lead 52.7 0.03

Mn 292.1 0.15

Ni 62.6 0.03

Cr 33.1 0.02

Hg 1.6 0.00

Cd 10.6 0.01

Co 3.0 0.00

As 3.2 0.00

Sb 0.4 0.00

Se 7.5 0.00

Phenol 6,504.7 3.25


Benzene 945.4 0.47

Cresols 1,353.6 0.68

Toluene 493.3 0.25





POMs* 0.0 0.00

Hexane 315.1 0.16


Acrolein 33.2 0.02


Xylenes 234.8 0.12

Biphenyl 74.2 0.04

Aniline 101.9 0.05








Cumene 27.1 0.01

MIBK 23.2 0.01

Styrene 41.7 0.02

Total HAPs 15,263.3 7.6









Issue Date 3/1/2012 7/1/2015 6/30/16


Main Plant Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)


EAF 6,132.00 4,403.00

AOD - 5752.00

Doghouse -

V-Bay 1,887.00


Chain Floor 267.00


Usage, mmcf: 116.25

Plant 3 Location

Tons Metal Melted

(Tmm/yr)

Tons Metal Poured

(Tmp/yr)

Plant 3 Total 10,067.00 8,763.00



Research AOD -- -

Induction 189.00 182.00


Usage, mmcf: 45.92









Issue Date 3/1/2012

Rolling 12 Month

Sum

Rolling 12 Month

Sum



Plant 3 Therms 39,032 42,372 48,295 39,501 43,059 42,955 38,969 36,800 33,078 34,752 36,059 38,154 473,026 45.925

162.2




Issue Date 3/1/2012

Reporting Period 7/1/2015 Thru 30-Jun-16





12 Month

Consumption

(gal/yr)

Coating MSDS VOC as



Green Dip Enamel, Low HAP/VOC (28GG402) added to tank 165 0 0 0 0 0 0 165 0 324 110 161 925 3.28
































Clear Coatings















2. The lower-end of the paint tank operating levels for each tank were used as a conservative volume for calculating normal tank operating volumes Clear 55 3.48









4.3










578


1,202

1,089

720

3.5



Reporting Period 7/1/2015 Thru 30-Jun-16




12 Month


Coating MSDS VOC as

Applied Content

(lbs/gal)









3,890 1.18


Applied. 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13 1.13



NOTES:










3.5









Semi-Annual Report

Progress Update on the Best Work Practices Agreement

World Headquarters 2141 NW 25th Avenue

Portland, Oregon 97210-2578

Phone: 503.228.2141 Fax: 503.499.6040

www.escocorp.com

Progress Update on the Good Neighbor Agreement - Attachment A Items Best Work Practices Agreement, Conditions 49 - 65, Title V Air Permit #26-2068 Prepared: July 5, 2016

Item 1 Complete. Two dust collectors were installed to improve capture and control of Doghouse Pouring-Cooling-Shakeout emissions. The collectors were tested in January 2014, and dust was weighed and correlated to tons of metal poured in the Doghouse. Because Plant 2/Doghouse operations shut down on November 12, 2014, these dust collectors are no longer in service.

Item 2 Complete. The Main Plant, Lower Finishing Area (LFA) Bay-1 Air Arc Cutting emissions were routed to the existing Bay-2 Powder Burn dust collector (301260); this was completed March 7, 2011. Installation of an additional dust collector, the LFA Bay-2 Air Arc dust collector (301120), was completed August 12, 2011. As the method of confirmation, the Bay-2 Air Arc dust collector dust was weighed for six consecutive months, averaging 500 - 600 pounds of dust collected per month of operation. Item 3 Complete. The Main Plant, Upper Finishing Area (UFA) chain table filtration unit is functioning. For the method of confirmation, one month of data was collected, totaling 4.4 pounds of dust. Item 4 Complete. In the Plant 3 cooling room, pouring and shakeout areas, we increased our inspection frequency by ESCO maintenance personnel to semi-annually in an effort to reduce potential fugitive emissions. The cooling room enclosure is also inspected monthly by ESCO staff. Item 5 Complete. In July 2013, Plant 3 converted to a lower phenol binder system. This system was tested in August 2013, and the calculated reduction of emissions per the method specified in the permit was 70.5%. The permit requirement of at least a 35-40% reduction has been met. Item 6 The Main Plant Chain Room switched to the Pep Set Quantum line of binder and catalyst. There is a slight increase in Volatile Organic Compounds (VOCs) during molding, but a significant decrease in Hazardous Air Pollutants (HAPs) from the molding, pouring, cooling and shakeout processes. Item 7 Complete. We have installed bag leak detection probes. The Main Plant Electric Arc Furnace (EAF) dust collector, AOD dust collector, Plant 3 EAF dust collectors and Plant 3 Pouring-Cooling-Shakeout dust collector all have probes installed and operational. The alarm settings and response procedures have been added to the Air Emission Control Device Operating Plan. Item 8 Complete. ESCO modified its Overhead Door Plan to better address issues associated with capture at the EAFs and AOD process.

Progress Update on Good Neighbor Agreement - Attachment A Items Best Work Practices Agreement, Conditions 49 - 65, Title V Air Permit #26-2068, Issue Date: 3/1/2012 Prepared: July 2016

Item 9 Complete. The EAF operating procedures were reviewed and updated to optimize capture of particulate matter.

Item 10 Complete. We installed a coarse fraction separator in January 2011 to reduce wear on the thermal sand reclaim baghouse filters. Due to wear in the bottom portion of the cyclone, it was replaced in-kind in June 2012. We then designed a longer-term solution, which included a 1” ceramic liner and this was installed in July 2013. The Plant 3 thermal sand reclaim dust collector and the coarse fraction separator are inspected per the permit by ESCO staff. Items 11 and 12 Complete. The production teams at the Main Plant and Plant 3 modified their procedures to reduce the use of the dump back processes at both plants. Jim Karas and Fred Tanaka visited both Plants on June 28 and 29, 2012, viewing the dump back process in use as well as progress in reducing the use of the dump back process. A report was prepared to recap their visit. Item 13 Complete. A study was conducted and determined the recommended operating exhaust temperature of at least 1200 °F. The study was submitted to DEQ and approved, but NAC

members have requested more detailed information about VOC emissions. An expanded study was completed with neighbor involvement including additional testing in June 2015. The expanded study confirmed the recommended exhaust temperature of at least 1200 °F.

Item 14 Complete. The AOD hood has been modified to improve emissions capture, particularly while charging the vessel. AOD operators were trained on new operating procedures to improve capture using the new hood. Neighbors inspected the AOD procedures and equipment in June 2015 and further improvements to procedures have been implemented. Item 15 Complete. Additional ventilation snorkels were installed at workbenches. Operating procedures were revised so operators are required to use the snorkels and channel air from the workbenches to pollution control and capture equipment. Work Instructions are posted in these areas. Item 16 Complete. An Atypical Incident Investigation Plan was developed and implemented at the Main Plant and Plant 3. Employees have been trained to identify and report Atypical Incidents. ESCO presented an example atypical incident investigation to NAC members. Item 17 This item calls for a Slinger Bay engineering study of feasible capture and control methods for emissions from pour points. We have not started on project 17 of Attachment A due to the pending closure of the Main Plant.


Semi-Annual Report

Appendix A Event Reporting – Permit Deviations

esco corporation - complete semiannual report to … · semi-annual compliance certification answer...

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