Notice of Construction Application Zodiac Advanced Composites and Engineered Materials 501 North Newport Avenue Newport, Washington 99156 February 22, 2017 Terracon Project No. MP157289C

Prepared for: Zodiac Advanced Composites and Engineered Materials

Prepared by: Terracon Consultants, Inc. Minneapolis, Minnesota

lrerracan February 22, 2017

Department of Ecology Cashiering Unit P.O. Box 47611 Olympia, WA 98504-7611

Re: Notice of Construction Application Zodiac Advanced Composites and Engineered Materials 501 North Newport Avenue Newport, Washington 99156

Dear Department of Ecology:

Terracon Consultants, Inc. was retained by Zodiac to assist with the completion and submittal of this Notice of Construction Application for their Newport, Washington facility.

Included in this submittal is the Notice of Construction Application and permit application fee of $10,000.

A copy of the final stack test report for the testing on the Panel Press will be submitted when the report has been received.

If you have any questions please give me a call at (763) 489-3158.

Sincerely,

Liesch - A Terracon Company ~ \)~( Joshua Kurtz, PE David C. Reynol Staff Engineer Senior Air Quality Eng

Attachment: Notice of Construction Application Notice of Construction Application CD Permit Application Fee

Liesch - A Ter racon Co mpany 13400 15 th Avenue North Minneapolis, Minnesota 55441 P [7631489 3100 F [763 1489 3101 terracon com

Environmental • Facilities • Geotechnical • Materials TABLE OF CONTENTS

APPENDIX A – NOC GENERAL INFORMATION (SECTIONS I-II)

APPENDIX B – NOC TECHNICAL INFORMATION (SECTIONS III, V-VII)

APPENDIX C – NOC SEPA CHECKLIST (SECTION IV)

APPENDIX D – NOC BACT ANALYSIS (SECTION VIII)

APPENDIX E – AMBIENT AIR IMPACTS ANALYSES (SECTION IX)

APPENDIX F – PTE CALCULATIONS

APPENDIX G – 2016 ACTUAL EMISSION CALCULATIONS

APPENDIX H – NOC SUPPORTING FIGURES

APPENDIX I – PANEL PRESS PRELIMINARY STACK TEST RESULTS

APPENDIX J – GEORGIA-PACIFIC POLYMERIZATION INFORMATION/RESULTS

APPENDIX K – THERMAL OXIDIZER SPECIFICATIONS

APPENDIX A NOTICE OF CONSTRUCTION APPLICATION

GENERAL INFORMATION SECTIONS I-II

Notice of Construction Application

This application applies statewide for facilities under the Department of Ecology’s jurisdiction. Submit this form for review of your project to construct a new or modified source of air emissions. Please refer to Ecology Forms ECY 070-410a-g, “Instructions for NOC Application,” for general information about completing the application.

Ecology offers up to two hours of free pre-application assistance. We encourage you to schedule a pre-application meeting with the contact person specified for the location of your proposal, below. If you use up your two hours of free pre-application assistance, we will continue to assist you after you submit Part 1 of the application and the application fee. You may schedule a meeting with us at any point in the process.

Upon completion of the application, please enclose a check for the initial fee and mail to:

Department of Ecology For Fiscal Office Use Only:

Cashiering Unit 001-NSR-216-0299-000404 P.O. Box 47611 Olympia, WA 98504-7611

Check the box for the location of your proposal. For assistance, call the contact listed below: Ecology Permitting Office Contact Lynnette Haller Chelan, Douglas, Kittitas, Klickitat, or Okanogan County (509) 457-7126 CRO Ecology Central Regional Office – Air Quality Program [email protected] Adams, Asotin, Columbia, Ferry, Franklin, Greg Flibbert Garfield, Grant, Lincoln, Pend Oreille, Stevens, (509) 329-3452 ERO Walla Walla or Whitman County [email protected] Ecology Eastern Regional Office – Air Quality Program David Adler San Juan County (425) 649-7082 NWRO Ecology Northwest Regional Office – Air Quality Program [email protected] For actions taken at Garin Schrieve Kraft and Sulfite Paper Mills and Aluminum Smelters (360) 407-6916 IND Ecology Industrial Section – Waste 2 Resources Program [email protected] Permit manager: ______For actions taken on the Philip Gent US Department of Energy Hanford Reservation (509) 372-7983 NWP Ecology Nuclear Waste Program [email protected]

ECY 070-410 (Rev. 1/2013) Page 1 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application Check the box below for the fee that applies to your application.

New project or equipment:

$1,500: Basic project initial fee covers up to 16 hours of review.

$10,000: Complex project initial fee covers up to 106 hours of review.

Change to an existing permit or equipment:

$200: Administrative or simple change initial fee covers up to 3 hours of review Ecology may determine your change is complex during completeness review of your application. If your project is complex, you must pay the additional $675 before we will continue working on your application. $875: Complex change initial fee covers up to 10 hours of review $350 flat fee: Replace or alter control technology equipment under WAC 173-400-114 Ecology will contact you if we determine your change belongs in another fee category. You must pay the fee associated with that category before we will continue working on your application.

Read each statement, then check the box next to it to acknowledge that you agree. The initial fee you submitted may not cover the cost of processing your application. Ecology will track the number of hours spent on your project. If the number of hours Ecology spends exceeds the hours included in your initial fee, Ecology will bill you $95 per hour for the extra time. You must include all information requested by this application. Ecology may not process your application if it does not include all the information requested. Submittal of this application allows Ecology staff to visit and inspect your facility.

ECY 070-410 (Rev. 1/2013) Page 2 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application Part 1: General Information I. Project, Facility, and Company Information 1. Project Name Zodiac - Total Facility NOC Application 2. Facility Name Zodiac Cabin and Structures Support, LLC dba Engineered Materials 3. Facility Street Address 501 North Newport Avenue, Newport, Washington 99156 4. Facility Legal Description Manufacturer of Composite Materials 5. Company Legal Name (if different from Facility Name)

6. Company Mailing Address (street, city, state, zip) 501 North Newport Avenue, Newport, Washington 99156 II. Contact Information and Certification 1. Facility Contact Name (who will be onsite) Mark Harper 2. Facility Contact Mailing Address (if different than Company Mailing Address) 501 North Newport Avenue, Newport, Washington 99156 3. Facility Contact Phone Number 4. Facility Contact E-mail 509-447-4122 [email protected] 5. Billing Contact Name (who should receive billing information) Ti Bertram 6. Billing Contact Mailing Address (if different than Company Mailing Address) 12806 State Avenue, Marysville, WA 98271 7. Billing Contact Phone Number 8. Billing Contact E-mail 360-653-2600 [email protected] 9. Consultant Name (optional – if 3rd party hired to complete application elements) Dave Reynolds 10. Consultant Organization/Company Terracon Consultants 11. Consultant Mailing Address (street, city, state, zip) 13400 15th Avenue North, Plymouth, MN 55441 12. Consultant Phone Number 13.Consultant E-mail 763-489-3158 [email protected] 14. Responsible Official Name and Title (who is responsible for project policy or decision-making) Mike Pound, Vice President 16. Responsible Official Phone 17. Responsible Official E-mail 360-653-2600 [email protected] 18. Responsible Official Certification and Signature I certify, based on information and belief formed after reasonable inquiry, the statements and information in this application are true, accurate and complete.

Signature ______Date______

ECY 070-410 (Rev. 1/2013) Page 3 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

APPENDIX B NOTICE OF CONSTRUCTION APPLICATION

TECHNICAL INFORMATION SECTIONS III, V-VII

Notice of Construction Application Part 2: Technical Information The Technical Information may be sent with this application form to the Cashiering Unit, or may be sent directly to the Ecology regional office with jurisdiction along with a copy of this application form.

For all sections, check the box next to each item as you complete it.

III. Project Description Please attach the following to your application. Written narrative describing your proposed project. Projected construction start and completion dates. Operating schedule and production rates. List of all major process equipment with manufacturer and maximum rated capacity. Process flow diagram with all emission points identified. Plan view site map.

Manufacturer specification sheets for major process equipment components. Manufacturer specification sheets for pollution control equipment. Fuel specifications, including type, consumption (per hour & per year) and percent sulfur.

A. Written narrative describing your proposed project. The Zodiac Aerospace facility located in Newport, Washington specializes in the manufacture of composites used for structural and cabin components in the aerospace industry.

The manufacturing of composite materials at the Zodiac facility consists of several major processes. These processes consist of the formulations room, the treater process, the winder process, and the panel press. Additional supporting processes and sources of emissions include powder weighing and adding, solvent cleaning, the core saw, the cleaning booth, the measuring table, Thermwood trimming, and the thermal oxidizer. The potential to emit (PTE) and limited PTE can be found in Appendix F. The 2016 actual emission calculations from the facility can be found in Appendix G.

Formulation. The Formulations area consists of 7 mixing vessels where the resins are produced. In addition to the mixing vessels there is a powder weighing station and areas where the powder can be added to the resins. Some of the resins are required to be stored at a slightly elevated temperature so there is an electric oven in the room where some of the resins are stored. Some of the resins that are produced are used on site in the Treater and Winder processes, however some of the resins are also shipped to other locations. Zodiac is proposing a limit on the amount of certain higher emitting resins that can be produced to limit the potential to emit (PTE) from the process.

ECY 070-410 (Rev. 1/2013) Page 4 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application

Treater. The Treater is an enclosed process that applies resins to a glass substrate which is essentially a thick sheet with a honeycomb structure. After the resin is applied the prepreg material passes through dryer sections to be cured before being rolled and stored in plastic bags until they are used in other processes. All of the emissions from the Treater are captured and vented to the thermal oxidizer. Zodiac tracks resin usage and performs testing that documents the amount of phenol and formaldehyde that remains in the product after being processed by the Treater.

Winders. The Winder room contains 5 Winder machines where resins are applied to a narrow fiber core strand and wound around a rotating barrel to create layered sheets. The prepreg product is removed from the barrel and either packaged and sold or stored on racks for a number of days until the prepreg meets the required specifications for processing in the Panel Press. Stack testing has shown that the majority of VOCs from the resin are emitted in the Winder room. There may be some minimal amounts of VOCs that remain on the prepreg material that are emitted during the storage period, however the PTE calculations for the Winder room assume that all VOCs (less formaldehyde and phenol) are emitted in the Winder room. Any emissions of VOCs (not including formaldehyde and phenol) from the product storing or Panel Press would result in a decrease in the PTE from the Winder room. Zodiac adds acetone to the low-VOC resins to maintain the desired resin viscosity and solvent is added to the high-VOC resins. Zodiac is proposing to limit the VOC emissions from the Winder processes to less than 22 tons/year.

Panel Press. Once the layered sheets (prepreg plies) produced by the winders have reached the desired specification they can be applied to a core material and processed in the Panel Press. The panels that are processed in the Panel Press can have up to 8 total plies of Winder or Treater prepreg material placed on the top and/or bottom of the core and then loaded into the Panel Press. The Panel Press can process up to 80 plies on 10 panels during one cycle which takes a minimum of an hour to complete. During the cycle the Panel Press applies pressure and heat to adhere the prepreg to the panels to create the final cured product. Zodiac is proposing a limit on the amount of Winder and Treater prepreg plies that will be processed through the Panel Press to comply with the acceptable source impact levels (ASIL).

Supporting Processes. Supporting processes at Zodiac include solvent cleaning, a core saw, cleaning booth, and measuring table. The PTE calculation methodology for all of these processes were based on calculating an actual usage rate and applying a safety factor.

The only combustion source at the Zodiac facility is the thermal oxidizer which burns propane fuel and controls the emissions from the treater process. The combustion emissions for the unit were calculated using the burner size and AP-42 emission factors.

ECY 070-410 (Rev. 1/2013) Page 5 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application

B. Projected construction start and completion dates.

The Zodiac Aerospace facility in Newport, Washington is currently operating and no construction is taking place as part of this permitting action.

C. Operating schedule and production rates.

The current operating schedule of the facility is 24 hours/day for Monday through Friday and 12 hours/day on Saturday and Sunday.

D. List of all major process equipment with manufacturer and maximum rated capacity.

The following table includes the major process equipment for the Zodiac Aerospace facility.

Table D.2: Treater Process Emission Unit Emission Fan Rated Emission Unit Amount Associated Unit ID Make Model Size Capacity Description (pounds) Stack(s) No. (scfm) (lbs/hr) EU001 Mixing Tote Custom Varies 3,143 EU002 Mixing Tote Custom Varies 3,143 EU003 Mixing Vat Custom Varies 5,000 Vented inside EU004 Mixing Barrel Custom Varies 1,320 room EU005 Mixing Barrel Custom Varies 1,320 EU006 Mixing Barrel Custom Varies 1,320 EU007 Mixing Barrel Custom Varies 1,320

Emission Emission Unit Make Model Fan Rated Associated Unit ID Description Size Capacity Stack(s) No. (scfm) (tons/hr)

EU008 Powder Weighing Custom Custom 1.40 Vented inside EU009 Powder Adding Custom Custom 1.40 room Emission Fan Rated Emission Unit Associated Unit ID Make Model Size Capacity Description Stack(s) No. (scfm) (sq.ft./hr) Treater: Resin Vented to EU010 Application and Custom Custom ~2000 6,100 Thermal Curing Oxidizer

ECY 070-410 (Rev. 1/2013) Page 6 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application Emission Fan Rated Emission Unit Associated Unit ID Make Model Size Capacity Description Stack(s) No. (acfm) (sq.m./hr) McClean EU011 Winder #1 Custom 35.7 Anderson McClean EU012 Winder #2 Custom 35.7 Anderson McClean EU013 Winder #3 Custom 5,080 35.7 SV004 Anderson McClean EU014 Winder #4 Custom 35.7 Anderson McClean EU015 Winder #5 Custom 35.7 Anderson Emission Fan Rated Emission Unit Associated Unit ID Make Model Size Capacity Description Stack(s) No. (acfm) (plies/hr) EU016 Panel Press Fjeliman Custom 10,000 80 SV005 Emission Fan Rated Emission Unit Associated Unit ID Make Model Size Capacity Description Stack(s) No. (scfm) (MMBtu/hr) Catalytic Quadrant EU022 Thermal Oxidizer 3,000 3.5 SV008 Products SR-3000

E. Process flow diagram with all emission points identified.

The process flow diagram is located in Appendix H.

F. Plan view site map.

The plan view site map is located in Appendix H.

G. Manufacturer specification sheets for major process equipment components

All major process equipment components except for the thermal oxidizer were custom-made for Zodiac Aerospace therefore manufacturer’s specification sheets are not available.

H. Manufacturer specification sheets for pollution control equipment.

The specification sheets for the thermal oxidizer can be found in Appendix K.

I. Fuel specifications, including type, consumption (per hour & per year) and percent sulfur.

ECY 070-410 (Rev. 1/2013) Page 7 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application The only fuel burning stationary source at the facility is the thermal oxidizer. The thermal oxidizer combusts propane and the thermal oxidizer manufacturer has indicated that maximum propane consumption of propane is 1,500 cubic feet per hour. Actual propane consumption for 2016 can be found in the actual emission calculations in Appendix G.

ECY 070-410 (Rev. 1/2013) Page 8 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application IV. State Environmental Policy Act (SEPA) Compliance

Check the appropriate box below.

SEPA review is complete: Include a copy of the final SEPA checklist and SEPA determination (e.g., DNS, MDNS, EIS) with your application.

SEPA review has not been conducted:

If review will be conducted by another agency, list the agency. You must provide a copy of the final SEPA checklist and SEPA determination before Ecology will issue your permit. Agency Reviewing SEPA: ______

If the review will be conducted by Ecology, fill out a SEPA checklist and submit it with your application. You can find a SEPA checklist online at www.ecy.wa.gov/programs/sea/sepa/docs/echecklist.doc

A copy of the SEPA checklist can be found in Appendix C.

ECY 070-410 (Rev. 1/2013) Page 9 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application

V. Emissions Estimations of Criteria Pollutants Does your project generate criteria air pollutant emissions? Yes No If yes, please provide the following information regarding your criteria emissions in your application.

The names of the criteria air pollutants emitted (i.e., NOx, SO2, CO, PM2.5, PM10, TSP, VOC, and Pb)

Zodiac currently emits NOx, SO2, CO, PM2.5, PM10, TSP, and VOCs.

Potential emissions of criteria air pollutants in tons per hour, tons per day, and tons per year (include calculations)

The potential emission calculations can be found in Appendix F. Zodiac is proposing the following limits to be incorporated into the permit.

Emission Limits Facility Wide Criteria Pollutants limited to <99 tons/year Facility Wide Individual HAPs limited to <9.9 tons/year each Facility Wide Total HAPs limited to <24 tons/year Winder Room VOCs limited to <22 tons/year

Panel Press Throughput Limits Prepreg plies from 1113, 1114, 1502, and 1510 resins and resins not containing formaldehyde limited to <525,000 plies/year Prepreg plies from 1180 and 1112 resins limited to <350,000 plies/year Prepreg plies from 6070 resin and all other prepreg plies that contain formaldehyde limited to <22,000 plies/year

Formulation Throughput Limit Combined production limit for 1102, 1114, 1502, and 1520 resins limited to <1,000,000 lbs/year Production of other resins is unlimited

ECY 070-410 (Rev. 1/2013) Page 10 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application

If there will be any fugitive criteria pollutant emissions, clearly identify the pollutant and quantity

The facility does not have any fugitive emissions that are generated outdoors, however there are some processes that vent PM and VOC emissions fugitively within the building. The emissions that are vented fugitively within the building can be found in Appendix F.

ECY 070-410 (Rev. 1/2013) Page 11 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application VI. Emissions Estimations of Toxic Air Pollutants

Does your project generate toxic air pollutant emissions? Yes No

If yes, please provide the following information regarding your toxic air pollutant emissions in your application. The names of the toxic air pollutants emitted (specified in WAC 173-460-1501)

The specific toxic air pollutants that are emissions can be found in the potential to emit calculations in Appendix F.

Potential emissions of toxic air pollutants in pounds per hour, pounds per day, and pounds per year (include calculations)

The emission rates of specific toxic air pollutants that are emitted at the facility can be found in the potential emission calculations in Appendix F.

If there will be any fugitive toxic air pollutant emissions, clearly identify the pollutant and quantity

The facility does not have any fugitive emissions that are generated outdoors, however the facility does have some sources of emissions that will emit toxic air pollutants fugitively within the building.

1 http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150 ECY 070-410 (Rev. 1/2013) Page 12 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application VII. Emission Standard Compliance Provide a list of all applicable new source performance standards, national emission standards for hazardous air pollutants, national emission standards for hazardous air pollutants for source categories, and emission standards adopted under Chapter 70.94 RCW. Does your project comply with all applicable standards identified? Yes No

New Source Performance Standards The facility manufactures resin and epoxy impregnated fiberglass/graphite products, primarily for the aerospace industry. The New Source Performance Standards (NSPS) that were reviewed include Subpart HHH for Synthetic Fiber Production Facilities and Subpart VVV for Polymeric Coating of Supporting Substrates Facilities. The other NSPS do not appear to be applicable to the operations.

It was determined that Subpart HHH was not applicable because an affected facility is one that uses a spinning process to produce synthetic fibers.

However it was determined that Subpart VVV does apply to the facility. Since the facility formulates resins that contain more than 130 Mg of VOCs and there is no concurrent construction of a control device, the facility is required to install, operate, and maintain a cover on each piece of affected equipment. Since the facility uses resins for coating operations that contain less than 95 Mg of VOCs the facility is required to monitor VOC use.

National Emission Standards for Hazardous Air Pollutants (40 CFR 61) The operations at the facility do not include any of the emission unit types that are listed in the regulation.

National Emission Standards for Hazardous Air Pollutants (40 CFR 63) The facility is not subject to any of the regulations written for major source categories as the facility is proposing synthetic minor limits to remain below the major source threshold for hazardous air pollutants (HAPs). A review of the area source categories did not result in any regulations that would appear to apply to the facility.

Emission standards adopted under Chapter 70.94 RCW The facility is subject to the general standards of WAC 173-400-040 for visible emissions, particle fallout, odors, emissions detrimental to persons or property, sulfur dioxide, concealment and masking, and fugitive dust. The thermal oxidizer is subject to the emission standards included in WAC 173-400-050(1) and (3). The process operations are also subject to the particulate matter emission requirements in WAC 173-400-060 and the federal HAP regulations referenced in WAC 173-400-075.

This source is required to register with Ecology as a Plastics and fiberglass product fabrication facility (WAC 173-400-100(ff)). The facility is subject to New Source Review of minor sources in a limited way under WAC 173-400-111(8)(vi) for changes to permit conditions. This section states

ECY 070-410 (Rev. 1/2013) Page 13 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application that “The revised order will continue to require BACT, as defined at the time of the original approval. . .” Further the rule specifically states that the revised order must meet “the requirements of WAC 173-400-111, 173-400-112, 173-400-113, 173-400-720, 173-400-830, and 173-460-040, as applicable”.

The facility is proposing synthetic minor limits in this application that will allow the facility to remain below major source thresholds for criteria pollutants and HAPs.

VIII. Best Available Control Technology Provide a complete evaluation of Best Available Control Technology (BACT) for your proposal.

As requested by Ecology, a Best Available Control Technology (BACT) analysis has been prepared for the emissions from the Winder processes and can be found in Appendix DE.

IX. Ambient Air Impacts Analyses Please provide the following: Ambient air impacts analyses for Criteria Air Pollutants (including fugitive emissions)

Zodiac had submitted draft PTE calculations to Ecology prior to the stack testing of the panel press and Ecology did not request a criteria pollutant Ambient Air Impacts Analyses.

Ambient air impacts analyses for Toxic Air Pollutants (including fugitive emissions)

Zodiac had submitted draft PTE calculations to Ecology prior to the stack testing of the panel press and Ecology indicated that they wanted the NOC application to include an ambient air toxics analyses for Toxic Air Pollutants. A copy of the ambient air impacts analyses can be found in Appendix E.

Discharge point data for each point included in air impacts analyses (include only if modeling is required) Exhaust height Exhaust inside dimensions (ex. diameter or length and width) Exhaust gas velocity or volumetric flow rate Exhaust gas exit temperature

ECY 070-410 (Rev. 1/2013) Page 14 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application The volumetric flow rate Description of the discharges (i.e., vertically or horizontally) and whether there are any obstructions (ex., raincap) Identification of the emission unit(s) discharging from the point The distance from the stack to the nearest property line Emission unit building height, width, and length Height of tallest building on-site or in the vicinity and the nearest distance of that building to the exhaust Whether the facility is in an urban or rural location

Specific details on the exhaust parameters can be found in the ambient air impacts analysis located in Appendix E.

Does your project cause or contribute to a violation of any ambient air quality standard or acceptable source impact level? Yes No

ECY 070-410 (Rev. 1/2013) Page 15 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application

Appendix A – Figures

Figure III.1 Process Flow Diagram

Exhaust to atmosphere (SV008)

Exhaust within room (Fugitive) Thermal Oxidizer Raw Materials (EU022)

Resin Formulations Treater Glass Product (EU001-EU009) (EU010)

Exhaust to Exhaust to atmosphere atmosphere (SV005) (SV004)

Resin Winders Panels Press Finished Fiber Core Panels (EU011-EU015) (EU017)

ECY 070-410 (Rev. 1/2013) Page 16 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Notice of Construction Application

Figure III.2 Site Plan View

ECY 070-410 (Rev. 1/2013) Page 17 of 17 If you need this document in a format for the visually impaired, call the Air Quality Program at 360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

APPENDIX C NOTICE OF CONSTRUCTION APPLICATION

TECHNICAL INFORMATION SECTION IV – STATE ENVIRONMENTAL POLICY ACT (SEPA) CHECKLIST

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 1 of 12

Part 2: Technical Information

IV. State Environmental Policy Act (SEPA) Compliance

WAC 197-11-960 Environmental checklist.

ENVIRONMENTAL CHECKLIST

Purpose of checklist:

The State Environmental Policy Act (SEPA), chapter 43.21C RCW, requires all governmental agencies to consider the environmental impacts of a proposal before making decisions. An environmental impact statement (EIS) must be prepared for all proposals with probable significant adverse impacts on the quality of the environment. The purpose of this checklist is to provide information to help you and the agency identify impacts from your proposal (and to reduce or avoid impacts from the proposal, if it can be done) and to help the agency decide whether an EIS is required.

Instructions for applicants:

This environmental checklist asks you to describe some basic information about your proposal. Governmental agencies use this checklist to determine whether the environmental impacts of your proposal are significant, requiring preparation of an EIS. Answer the questions briefly, with the most precise information known, or give the best description you can. You must answer each question accurately and carefully, to the best of your knowledge. In most cases, you should be able to answer the questions from your own observations or project plans without the need to hire experts. If you really do not know the answer, or if a question does not apply to your proposal, write "do not know" or "does not apply." Complete answers to the questions now may avoid unnecessary delays later. Some questions ask about governmental regulations, such as zoning, shoreline, and landmark designations. Answer these questions if you can. If you have problems, the governmental agencies can assist you. The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to determining if there may be significant adverse impact.

Use of checklist for nonproject proposals:

Complete this checklist for nonproject proposals, even though questions may be answered "does not apply." IN ADDITION, complete the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (part D). For nonproject actions, the references in the checklist to the words "project," "applicant," and "property or site" should be read as "proposal," "proposer," and "affected geographic area," respectively.

A. BACKGROUND

1. Name of proposed project, if applicable: Notice of Construction Application

2. Name of applicant: Zodiac Cabin and Structures Support, LLC dba Engineered Materials

3. Address and phone number of applicant and contact person: Facililty:Mark Harper HQ: Jennifer Shull 509-447-4122 360-653-2600 501 N. Newport Ave 12806 State Ave Newport, WA 99156 Marysville WA 98271

4. Date checklist prepared: 2/19/2017

5. Agency requesting checklist: Washington Dept. of Ecology

6. Proposed timing or schedule (including phasing, if applicable): Upon issuance of permit

7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. Zodiac Aerospace, Newport plant 2 of 12

There are no current plans for facility expansion.

8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal.

Stack testing has been performed at the request of Ecology on the exhaust of the oxidizer and the Winder room stacks. Additional stack testing has recently been performed on the exhaust stacks associated with the panel press operations. Potential to emit calculations, actual emission calculations, a Best Available Control Technology (BACT) analysis, and an Ambient Air Impacts Analyses for Toxic Air Pollutants are included in the Notice of Construction application.

9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, explain.

There are no pending permits

10. List any government approvals or permits that will be needed for your proposal, if known.

N/A

11. Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information on project description.)

The Zodiac Aerospace facility located in Newport, Washington is an existing facility that specializes in the manufacture of composites used for structural and cabin components in the aerospace industry. For a detailed description of the operations see Section III of the Notice Of Construction (NOC) application.

12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range, if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist.

This facility is located at 501 N. Newport Ave, Newport, WA 99156

The legal description of the facility is Lot 3 Government Block; Parcel 2, Section 18, Township 31N, Range 46E WM

See the attached figure showing the location of the Zodiac facility. Additional figures can be found in Appendix H of the NOC application.

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Zodiac Aerospace, Newport plant location

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 4 of 12

B. ENVIRONMENTAL ELEMENTS

1. Earth

a. General description of the site (circle one): Flat, rolling, hilly, steep slopes, mountainous, other ......

The site is generally flat however there is some sloping on the east side of the property. See figure on page 3.

b. What is the steepest slope on the site (approximate percent slope)?

The site is basically flat in the area of the existing building. However outside of the building and parking area there is some sloping on the east side of the property. No earthwork will be performed as part of this project.

b. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any prime farmland.

Not Applicable – this project will not involve construction d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe.

No e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. Indicate source of fill.

Not Applicable – this project will not involve construction f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe.

Not Applicable – this project will not involve construction g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)?

Not Applicable – this project will not involve construction

h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any:

Not Applicable – this project will not involve construction

2. Air a. What types of emissions to the air would result from the proposal (i.e., dust, automobile, odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities if known.

There is no construction associated with this project so there will not be any air emissions associated with construction activities.

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 5 of 12

Zodiac is an existing manufacturing facility located on the site which does have air emissions. The facility reported the following actual emissions in 2016.

PM10: 0.433 tons SO2: 0.065 tons NOx: 0.566 tons VOC: 19.403 tons CO: 0.326 tons CO2e: 556.056 tons Total HAPs: 3.329 tons b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe.

No c. Proposed measures to reduce or control emissions or other impacts to air, if any:

The facility has an existing thermal oxidizer that controls the emissions from the Treater process.

3. Water a. Surface:

1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river it flows into.

The Pend Oreille River is near the property however it is located several hundred yards east of the manufacturing building (see map on page 3). Some surface water from the property may drain into the river.

2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans.

No

3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material.

None

4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known.

No

5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan.

No

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 6 of 12

6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge.

No. b. Ground:

1) Will ground water be withdrawn, or will water be discharged to ground water? Give general description, purpose, and approximate quantities if known.

No

2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: Domestic sewage; industrial, containing the following chemicals. . . ; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve.

None. c. Water runoff (including stormwater):

1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe.

Runoff from grounds and parking lots flows into the municipal stormwater system.

2) Could waste materials enter ground or surface waters? If so, generally describe.

Only in the event of a transportation accident. All waste chemicals are shipped out by truck under manifest. Cleanup from such an event would be carried out under standard WashDOT procedures. d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any: Not applicable

4. Plants a. Check or circle types of vegetation found on the site:  deciduous tree: alder, maple, aspen, other  evergreen tree: fir, cedar, pine, other  shrubs  grass pasture crop or grain wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other water plants: water lily, eelgrass, milfoil, other other types of vegetation b. What kind and amount of vegetation will be removed or altered?

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 7 of 12

None. c. List threatened or endangered species of vegetation known to be on or near the site.

None. d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any:

Not applicable

5. Animals a. Circle any birds and animals which have been observed on or near the site or are known to be on or near the site:

birds: hawk, heron, eagle, songbirds, other: Hawk, eagle, water fowl on river mammals: deer, bear, elk, beaver, other: Deer, muskrats, opossum and voles fish: bass, salmon, trout, herring, shellfish, other: Trout, Bass in Pend Oreille River

b. List any threatened or endangered species known to be on or near the site.

Wolves are under federal protection and have been reported in Idaho. Wolves have not been seen on or near the site. c. Is the site part of a migration route? If so, explain.

No d. Proposed measures to preserve or enhance wildlife, if any:

Not applicable

6. Energy and natural resources a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc.

Electricity from the local utility has been used for general building heating/cooling. b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe.

No. c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any:

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 8 of 12

Zodiac has been careful to not propose the use of any equipment that would consume additional energy.

7. Environmental health

a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe.

Manufacture of fiberglass/graphite sheets using epoxies and resins involves the use of alcohol-based solvents and acetone which are flammable which can present a fire and explosion risk. These chemicals do evaporate in the process and can present a potential inhalation hazard. Various toxic chemicals in the epoxies and resins evaporate during the manufacturing process. These processes also result in the generation of hazardous waste in the form of spent alcohol related to laboratory and cleaning processes. Industrial hygiene monitoring has found that worker exposure levels are well below any “action level”. All hazardous wastes are shipped offsite and manifested as required by law and regulations.

1) Describe special emergency services that might be required. Arrangements have previously been made with the local fire department. No new services will be required.

2) Proposed measures to reduce or control environmental health hazards, if any:

The facility has an Illness and Accident Prevention Program detailing the environmental health procedures and personal protective equipment necessary to minimize occupational exposures. Skilled professionals are on staff to ensure these procedures are followed. Engineering controls are also used to reduce contaminant airborne concentrations. b. Noise

1) What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other)?

None.

2) What types and levels of noise would be created by or associated with the project on a short-term or a long-term basis (for example: traffic, construction, operation, other)? Indi- cate what hours noise would come from the site.

None.

3) Proposed measures to reduce or control noise impacts, if any:

There are no noise impacts that extend beyond the property. Inside the building, PPE is required in certain areas to limit occupational noise exposure.

8. Land and shoreline use a. What is the current use of the site and adjacent properties?

Zodiac operates an existing manufacturing facility on the site. Adjacent properties to the site are primarily commercial or vacant land.

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 9 of 12

b. Has the site been used for agriculture? If so, describe.

Not to Zodiac’s knowledge. c. Describe any structures on the site.

The existing structure is an approximately 70,000 sq. foot concrete tilt up. d. Will any structures be demolished? If so, what?

No. e. What is the current zoning classification of the site?

Industrial f. What is the current comprehensive plan designation of the site?

Industrial g. If applicable, what is the current shoreline master program designation of the site?

Not applicable. h. Has any part of the site been classified as an "environmentally sensitive" area? If so, specify.

No.

i. Approximately how many people would reside or work in the completed project?

Approximately 95 employees currently work at the site. No new employees would be added as a direct result of this proposal. j. Approximately how many people would the completed project displace?

None. k. Proposed measures to avoid or reduce displacement impacts, if any:

Not applicable l. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any:

There are no planned changes to the existing property.

9. Housing

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 10 of 12

a. Approximately how many units would be provided, if any? Indicate whether high, mid- dle, or low-income housing.

None. b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing.

None. c. Proposed measures to reduce or control housing impacts, if any:

None.

10. Aesthetics a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building material(s) proposed?

There are no new structures planned for the existing property. b. What views in the immediate vicinity would be altered or obstructed?

None. c. Proposed measures to reduce or control aesthetic impacts, if any:

Not applicable

11. Light and glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur?

There are no lighting changes planned for the property. b. Could light or glare from the finished project be a safety hazard or interfere with views?

No. c. What existing off-site sources of light or glare may affect your proposal?

None. d. Proposed measures to reduce or control light and glare impacts, if any:

Not applicable.

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12. Recreation a. What designated and informal recreational opportunities are in the immediate vicinity?

There is a company-owned riverside park open to the public near the site. b. Would the proposed project displace any existing recreational uses? If so, describe.

No. c. Proposed measures to reduce or control impacts on recreation, including recreation op- portunities to be provided by the project or applicant, if any:

Not applicable.

13. Historic and cultural preservation a. Are there any places or objects listed on, or proposed for, national, state, or local preser- vation registers known to be on or next to the site? If so, generally describe.

None known b. Generally describe any landmarks or evidence of historic, archaeological, scientific, or cultural importance known to be on or next to the site.

None known c. Proposed measures to reduce or control impacts, if any:

Not applicable.

14. Transportation a. Identify public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any.

No new access required. b. Is site currently served by public transit? If not, what is the approximate distance to the nearest transit stop?

No public transit nearby c. How many parking spaces would the completed project have? How many would the project eliminate?

There will be no changes to the existing parking lot.

Zodiac Aerospace, Newport plant - Air Permit Revision for VOC limits 12 of 12

d. Will the proposal require any new roads or streets, or improvements to existing roads or streets, not including driveways? If so, generally describe (indicate whether public or private). No e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transporta- tion? If so, generally describe. No f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur.

No impact on daily vehicle traffic g. Proposed measures to reduce or control transportation impacts, if any:

Not applicable

15. Public services a. Would the project result in an increased need for public services (for example: fire pro- tection, police protection, health care, schools, other)? If so, generally describe.

No. b. Proposed measures to reduce or control direct impacts on public services, if any.

Not applicable

16. Utilities a. Circle utilities currently available at the site: electricity, natural gas, water, refuse serv- ice, telephone, sanitary sewer, septic system, other.

Electricity, water, refuse service, telephone, cell phone and sanitary sewer are currently used. b. Describe the utilities that are proposed for the project, the utility providing the service, and the general construction activities on the site or in the immediate vicinity which might be needed.

No new utilities are required.

C. SIGNATURE

The above answers are true and complete to the best of my knowledge. I understand that the lead agency is relying on them to make its decision.

Signature: ______

Name, title: Mike Pound, Vice President

Date Submitted ______

APPENDIX D NOTICE OF CONSTRUCTION APPLICATION

TECHNICAL INFORMATION SECTION VIII – BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS

VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington February 19, 2017 ■ Terracon Project No. MP157289C

VOC BACT Analysis –Winder Operations Zodiac Aerospace – Engineered Materials Newport, Washington Terracon Project No. February 19, 2017

INTRODUCTION

Zodiac Aerospace – Engineered Materials (Zodiac) in Newport, Washington had submitted a Best Available Control Technology (BACT) analysis for the VOC emissions from the facility previously and it was determined that it would be cost effective to control the winder processes. However based on revisions to the potential to emit calculations and the recent stack testing that was requested by the Washington Department of Ecology (Ecology), the BACT analysis has been updated to reflect these changes.

EPA’s steps for a top-down BACT analysis for the winder operations are detailed below.

1. Identify all control technologies. 2. Eliminate technically infeasible options. 3. Rank remaining control technologies by effectiveness. 4. Evaluate most effective controls and document results. 5. Select BACT.

The potential VOC emissions from winder operations have been updated based on a mass balance approach and the calculations were provided to Ecology on April 1, 2015. The potential to emit (PTE) calculations have been calculated based on all 5 winders using high VOC resins, however the facility only uses 3 of the winders with high VOC resins and the other 2 winders produce product using low VOC resins. The stack testing that was performed on the Winder room exhaust stacks showed that the phenol and formaldehyde emissions were below detection limits which supported Georgia-Pacific’s believe that the phenol and formaldehyde would not be emitted at ambient temperatures. The VOC emissions from the stack testing were in reasonable correlation with the expected emissions using a mass balance methodology. Zodiac is proposing to limit the VOC emissions from the winder operations to 22 tons/year.

The VOC BACT analysis has been completed and is documented in this report. This analysis concludes the following:

 It is proposed that add-on controls are not required for the winder operations because all of the control technology is either technically infeasible or not economically feasible based on the proposed emission limit for the winder operations.

Responsive ■ Resourceful ■ Reliable VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington February 19, 2017 ■ Terracon Project No. MP157289C

A thorough review of the RACT/BACT/LAER Clearinghouse (RBLC) was performed to try and match a process contained in the RBLC to the winder processes at Zodiac. The following types of sources were searched on the RBLC for previous VOC BACT determinations.

41.001 Aerospace Surface Coating – See attached 41.017 Polymeric Coating of Fabrics – No results 41.999 Other Surface Coating/Printing/Graphics Arts Sources – See attached

The search results for these three source categories did not produce a similar process to the winder process at the Zodiac facility. A copy of the search results from the RBLC database can be found in Appendix B of this BACT analysis.

Below is the top-down approach for identifying BACT for VOCs from the winder operations at the facility.

STEP 1 – IDENTIFY CONTROL TECHNOLOGIES

Zodiac has identified the following VOC control technologies to potentially consider as BACT for the primary processes at the facility.

 Oxidation o Regenerative Thermal Oxidation o Recuperative Thermal Oxidation o Thermal Oxidation o Catalytic Oxidation  Condensation  Carbon Adsorption  Biofilter

STEP 2 – ELIMINATE TECHNICALLY INFEASIBLE OPTIONS

2.1 Oxidation Oxidation refers to the combustion of organic compounds at a sufficiently high temperature and adequate residence time. Oxidation systems are either thermal or catalytic. These categories can be further divided based on the type of heat recovery used. If a shell-and-tube or plate-type heat exchanger is used, then the system is generally classified as recuperative. If a high efficiency bed of ceramic material is used, then the system is generally classified as regenerative. With all types of systems, most hydrocarbons are oxidized to carbon dioxide and water. Capital and operating cost estimates for regenerative thermal oxidation (Appendix C),

Responsive ■ Resourceful ■ Reliable VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington February 19, 2017 ■ Terracon Project No. MP157289C

recuperative thermal oxidation (Appendix D), and catalytic oxidation (Appendix E) were prepared for the BACT analysis.

A 10-year life of the oxidizers was used in the calculations for converting the capital cost to an annualized cost.

2.2 Condensation Condensation systems utilize a refrigeration source to cool an exhaust stream until the partial pressure of the pollutant in the gas stream equals its vapor pressure as a pure substance. This allows the condenser to convert VOCs from the gaseous phase to a liquid phase. Any gas can be reduced to a liquid by sufficiently lowering its temperature and/or increasing its pressure. Based on the stack test results, the gaseous emissions from the winder operations are primarily made up of acetone, ethanol, methanol, and isopropanol. Based on a mass balance, the maximum VOC emission rate from the winder operations is 11.86 lbs/hour. The concentration of the VOCs in the measured exhaust stream of 4,680 scfm would be low (approximately 500 ppmv based on the stack test results). The vapor pressures of the individual compounds, even at 32˚F, are too high to enable condensation at these concentrations. Therefore, due to the relatively high volume of air stream, low concentration of VOCs, and the variety of different components that would be included in the exhaust stream, condensation is not a technically feasible method to control VOCs from the winder operations.

2.3 Carbon Adsorption Adsorption is the process by which molecules collect on and adhere to the surface of an adsorbent solid (usually carbon). This adsorption is due to physical and/or chemical forces. Physical adsorption, the most common in this type of application, is due to van der Waals forces. These forces are common to all matter and result from the motion of electrons. Activated carbon is typically used as an adsorbent because of its large surface area, a critical factor in the adsorption process since the adsorption capacity is proportional to surface area. Activated carbon has significant surface area due to its internal pore structure. The adsorption capacity of carbon is proportional to the vapor pressure of the compounds being adsorbed. Due to the high vapor pressure of these compounds, the compounds would be poorly adsorbed on carbon. Also as discussed previously, the concentration of VOCs in the exhaust stream is low. Because of the low concentration of VOCs and the variety of components in the exhaust stream, it would take an infeasible amount of carbon to remove the VOCs in the exhaust stream. For the reasons indicated above, carbon adsorption is not a technically feasible option for controlling VOCs from the winder operations.

2.3 Biofiltration Biofiltration is a pollution control technique that uses living material to capture and biologically degrade pollutants. Common uses include processing waste water and microbiotic oxidation of contaminants in air. Zodiac performed a trial with a biofilter that resulted in poor results. The

Responsive ■ Resourceful ■ Reliable VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington February 19, 2017 ■ Terracon Project No. MP157289C

poor results were likely the result of the cold weather. The size requirements of a full scale biofiltration system make it impractical to locate the system indoors and an outdoor system would be subject to the cold weather in Newport, Washington. In addition, the intermittent operations provide a poor food supply for the organisms. Because of these reasons it was determined that biofiltration is not a technically feasible option.

STEP 3 – RANK REMAINING CONTROL TECHNOLOGIES BY EFFECTIVENESS

Oxidation control technologies are the only remaining control technologies identified as technically feasible. The effectiveness of each oxidation control technology is approximately the same and thus economic factors will drive the decision for the BACT analysis.

STEP 4 – EVALUATE MOST EFFECTIVE CONTROLS AND DOCUMENT RESULTS

4.1 Cost Estimate Preliminary budget-level cost data was developed for the installation and operation of the control technologies listed below. Estimated oxidizer costs have been provided by Catalytic Products, Inc. and can be found in Appendix F of the BACT analysis.

 Regenerative Thermal Oxidation  Recuperative Thermal Oxidation  Catalytic Oxidation

These cost estimates were based on cost estimation guidance adapted from the USEPA Office of Air Quality Planning and Standards (OAQPS) Air Pollution Control Cost Manual (EPA/452/B- 02-001, Sixth Edition, January 2002) and recent equipment quotes.

The table below summarizes the cost and cost-effectiveness estimates developed by Terracon for the control of VOC emissions from the winder operations. Please see Appendix C through Appendix E for the cost estimate calculations. The estimated costs were provided by Catalytic Products, Inc. and have been included in Appendix F.

Total Capital Total Annualized Control Method Cost per Ton Investment Cost Regenerative Thermal Oxidizer $676,216 $244,644 $11,326 Recuperative Thermal Oxidizer $956,490 $375,299 $17,375

Responsive ■ Resourceful ■ Reliable VOC BACT Analysis Zodiac Aerospace ■ Newport, Washington February 19, 2017 ■ Terracon Project No. MP157289C

Total Capital Total Annualized Control Method Cost per Ton Investment Cost Catalytic Oxidizer $751,101 $277,265 $12,836

STEP 5 – SELECT BACT

Based on the analysis above, oxidation control technologies are not economically feasible and condensation, carbon adsorption, and biofiltration control technologies are not technically feasible.

Zodiac has evaluated alternative resins and to produce acceptable products for customers Zodiac is required to use the resins that are currently in use.

Since all of the control options are either technically or economically infeasible and there is no option for resin substitution, Zodiac is proposing that BACT for the Winders to be operated without controls.

AIR QUALITY IMPACTS

For any pollutant exceeding its PSD significant emission level as part of a new construction, a PSD air quality impact analysis is required to demonstrate compliance with any applicable ambient air quality standards established for that pollutant. However, PSD thresholds have not been exceeded by the PTE for the Zodiac Facility. As such, an impacts analysis was not performed.

Responsive ■ Resourceful ■ Reliable

APPENDIX A

Potential To Emit Calculations

Table 10: Winder Room Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU011-EU015 Emission Unit Description: Winder Process Stack/Vent Designation No.: SV004 Control Equipment No.: N/A Hours of Operation: 8760 No. of Winders 5

VOCs, HAPS, and TAPs Applied

Fiber Core + Dried Fiber Core Dried Resin Resin-Specific Total Resin Fiber Core + Volatiles Formaldehyde Methanol MIBK Phenol Total HAPs Isopropanol Resin Weight1 Weight1 (Solids) Weight Solids Content Applied Applied Resin Applied VOCs Applied Applied2 Applied Applied Applied2 Applied Applied Product ID (Resin ID/Fiberglass Part #) Resin ID (g/m^2) (g/m^2) (g/m^2) (%) (g/m^2) (g/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lbs/m^2) (lb/m^2) (lb/m^2) (lb/m^2) APG 1102/12K AR1102 219.0 140.0 79.0 50% 158.0 298.0 0.174 0.104 0.002 0.028 0.003 0.031 0.064 0.014 APG 1114/12K AR1114 219.0 140.0 79.0 50% 158.0 298.0 0.174 0.102 0.002 0.021 0.003 0.024 0.051 0.017 APG 1114/12K-300 AR1114 305.0 202.0 103.0 50% 206.0 408.0 0.227 0.133 0.002 0.027 0.005 0.032 0.066 0.023 AEG 1502/12K AR1502 252.0 150.0 102.0 50% 204.0 354.0 0.225 0.024 0.000 0.000 0.000 0.000 0.000 0.000 AEG 1510/12K AR1510 330.0 208.0 122.0 60% 203.3 411.3 0.179 0.001 0.000 0.000 0.000 0.000 0.000 0.000 AEF 1510/750 AR1510 480.0 290.0 190.0 60% 316.7 606.7 0.279 0.001 0.000 0.000 0.000 0.000 0.000 0.000 AEG1510/18K AR1510 173.0 103.0 70.0 60% 116.7 219.7 0.103 0.000 0.000 0.000 0.000 0.000 0.000 0.000

PTE From Resin Usage2 Max Production Max Production Rate for All VOC MIBK Total HAPs Isopropanol Rate Per Winder1 Number of Winders PTE3 Methanol PTE3 PTE3 PTE2,3,4 PTE3 Product ID (Resin ID/Fiberglass Part #) Resin ID (m^2/hr) Winders (m^2/hr) (TPY) (TPY) (TPY) (TPY) (TPY) APG 1102/12K AR1102 30.1 5 150.5 68.89 18.37 2.30 20.67 9.18 APG 1114/12K AR1114 22.7 5 113.5 50.74 10.39 1.73 12.12 8.66 APG 1114/12K-300 AR1114 11.9 5 59.5 34.68 7.10 1.18 8.29 5.92 AEG 1502/12K AR1502 26.0 5 130.0 13.73 0.00 0.00 0.00 0.00 AEG 1510/12K AR1510 19.4 5 97.0 0.36 0.00 0.00 0.00 0.00 AEF 1510/750 AR1510 14.0 5 70.0 0.41 0.00 0.00 0.00 0.00 AEG1510/18K AR1510 35.7 5 178.5 0.38 0.00 0.00 0.00 0.00 Worst Case 68.89 18.37 2.30 20.67 9.18

PTE From Thinner Added Max Production Total Resin Thinner Rate for All Applied Addition Rate1,4 Thinner Added Winders VOC PTE Methanol PTE MIBK PTE Total HAPs PTE Product ID (Resin ID/Fiberglass Part #) Resin ID (g/m^2) (% by weight) (g/m^2) (m^2/hr) (TPY) (TPY) (TPY) (TPY) APG 1102/12K AR1102 158.0 2.80% 4.424 150.5 6.423 0.321 0.193 0.514 APG 1114/12K AR1114 158.0 4.90% 7.742 113.5 8.477 0.424 0.254 0.678 APG 1114/12K-300 AR1114 206.0 4.90% 10.094 59.5 5.794 0.290 0.174 0.464 Worst Case 8.477 0.424 0.254 0.678

PTE Summary PTE Limited PTE5 Pollutant (tons/year) (tons/year) VOCs 77.363 22.0 Methanol 18.793 5.34 MIBK 2.550 0.73 Total HAPs 21.344 6.07 IPA 9.185 2.61

1 Information provided by Zodiac. 2 Georgia Pacific has indicated that the phenol and formaldehyde will not be released in the winder process based on operating temperatures. Previous stack testing supports this conclusion. 3 Georgia Pacific has indicated that all other VOCs in the resins should be emitted in the Winder Room. Although small amounts of other VOCs may remain on the prepreg, they are included in the Winder calculations to be conservative. 4 Acetone is added to the AR1502 and AR1510 resins, Tarsol added to AR1102 and AR1114 resins 5 Zodiac is proposing to take a limit of 22 tons/year on VOC emissions from the Winder Process calculated on a 12-month rolling basis. Limited HAP emissions have been ratioed to the 22 ton/year limit based on the PTE calculations.

APPENDIX B

RACT/BACT/LAER Clearinghouse Search Results

COMPREHENSIVE REPORT Report Date:02/19/2017 Facility Information RBLC ID: OK-0172 (final) Date Determination Last Updated: 07/06/2016 Corporate/Company TINKER AFB LOGISTICS CTR Permit 2009-394-C(M-4)PSD Name: Number: Facility Name: MIDWEST CITY AIR DEPOT Permit Date: 11/19/2015 (actual) Facility Contact: COL STEPHANIE WILSON 405-734-2102 [email protected] FRS Number: 109-00090 Facility Description: Tinker AFB is a multi-mission/multi-faceted installation that serves the U.S. Air Force, U.S. Navy, and SIC Code: 9711 other Department of Defense (DoD) organizations. The primary Standard Industrial Classification (SIC) code is 9711, National Security. It is home to the Oklahoma City Air Logistics Center (OC-ALC) and a number of associated organizations. Permit Type: C: Modify process at existing facility NAICS Code: 928110 Permit URL: EPA Region: 6 COUNTRY: USA Facility County: OKLAHOMA Facility State: OK Facility ZIP Code: 73145 Permit Issued By: OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY (Agency Name) MR. LEE WARDEN(Agency Contact) (405)702-4182 [email protected] Permit Notes: The applicant requests an increase in emissions associated with facilities needed to support the KC-46A program. The applicant discovered discrepancies in the stripper materials initially proposed in Permit No. 2009-394-C (M-2) PSD. As a result the applicant is requesting a re-opening of the prior permit and relaxation of the existing VOC emission limits from the previous PSD permit. Affected Boundaries: Boundary Type: Class 1 Area State: Boundary: Distance: CLASS1 OK Wichita Mountains 100km - 50km Facility-wide Pollutant Name: Facility-wide Emissions Increase: Emissions: Volatile Organic Compounds (VOC) 319.0000 (Tons/Year)

Process/Pollutant Information PROCESS CHEMICAL DEPAINTING/AIRCRAFT PAINT STRIPPING/AIRCRAFT PARTS PAINT STRIPPING NAME: Process Type: 41.001 (Aerospace Surface Coating) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: NA Throughput: 0 Process Notes: Tinker AFB will perform surface coating and depainting/stripping for the KC-46A aircraft. The chemical strippers used to remove the residual paint from the surface of the aircraft as well as the new paint applied to the aircraft will be formulations that meet Aerospace Manufacturing and Rework Facilities (Aerospace) National Emission Standards for Hazardous Air Pollutants (NESHAP) VOC limits. No VOC controls will be installed at the new paint hangars.

POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 333.3800 TONS YEAR Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Y Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NSPS , NESHAP , MACT Control Method: (P) 1.Low VOC vapor press. cleaning solvents and strippers( Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: No Pollutant/Compliance Notes:

Facility Information RBLC ID: OK-0171 (final) Date Determination Last Updated: 07/06/2016 Corporate/Company TINKER AFB LOGISTICS CTR Permit 2009-394-C(M-3)PSD Name: Number: Facility Name: MIDWEST CITY AIR DEPOT Permit Date: 11/18/2015 (actual) Facility Contact: COL STEPHANIE WILSON 405-734-2102 [email protected] FRS Number: 109-00090 Facility Description: Tinker AFB is a multi-mission/multi-faceted installation that serves the U.S. Air Force, U.S. Navy, and SIC Code: 9711 other Department of Defense (DoD) organizations. The primary Standard Industrial Classification (SIC) code is 9711, National Security. It is home to the Oklahoma City Air Logistics Center (OC-ALC) and a number of associated organizations. Permit Type: C: Modify process at existing facility NAICS Code: 928110 Permit URL: EPA Region: 6 COUNTRY: USA Facility County: OKLAHOMA Facility State: OK Facility ZIP Code: 73145 Permit Issued By: OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY (Agency Name) MR. LEE WARDEN(Agency Contact) (405)702-4182 [email protected] Permit Notes: The applicant discovered discrepancies in the stripper materials initially included in Permit No. 2009-394-TVR. This is a relaxation of VOC usage/emission limitation of chemical depainting. Affected Boundaries: Boundary Type: Class 1 Area State: Boundary: Distance: CLASS1 OK Wichita Mountains 100km - 50km Facility-wide Pollutant Name: Facility-wide Emissions Increase: Emissions: Volatile Organic Compounds (VOC) 400.0000 (Tons/Year)

Process/Pollutant Information PROCESS NAME: CHEMICAL DEPAINTING/AIRCRAFT PAINT STRIPPING/AIRCRAFT PARTS PAINT STRIPPING Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: NA Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 1605.5600 TONS YEAR Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Y Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NSPS , NESHAP , MACT Control Method: (P) 1.Low VOC vapor pressure cleaning solvents and strippers ( Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: No Pollutant/Compliance Notes:

Facility Information RBLC ID: WA-0347 (draft) Date Determination Last Updated: 03/14/2013 Corporate/Company THE BOEING COMPANY Permit PSD-12-01 Name: Number: Facility Name: BOEING RENTON Permit Date: 02/19/2013 (actual) Facility Contact: MICHAEL VERHAAR (425) 965-1567 [email protected] FRS Number: Facility Description: The Boeing Renton facility is located in the city of Renton in King County, Washington, and began operation in SIC Code: 3721 1942. It occupies 339 acres, and currently manufactures parts for and assembles the 737 series airplane model. The facility is located in the south half of Section 18, Township 23N, Range 5, Willamette Meridian. It is bounded to the north by Lake Washington, to the south by Airport Way, to the east by Logan Avenue, and to the west by the Renton Airport Permit Type: D: Both B (Add new process to existing facility) &C (Modify process at existing facility) NAICS Code: 336411 Permit URL: http://www.ecy.wa.gov/programs/air/psd/psd_existingpermits.html EPA Region: 10 COUNTRY: USA Facility County: KING Facility State: WA Facility ZIP Code: 98124 Permit Issued By: WASHINGTON STATE DEPARTMENT OF ECOLOGY (ECY); AIR QUALITY PROGRAM (Agency Name) MR. MARC CROOKS(Agency Contact) (360)407-6803 [email protected] Permit Notes: Affected Boundaries: Boundary Type: Class 1 Area State: Boundary: Distance: CLASS1 WA Alpine Lakes < 100 km CLASS1 WA Glacier Peak < 100 km CLASS1 WA Goat Rocks 100km - 50km CLASS1 WA Mount Adams 100km - 50km CLASS1 WA Mount Rainier NP < 100 km CLASS1 WA North Cascades NP 100km - 50km CLASS1 WA Olympic NP < 100 km INTL BORDER US/Canada Border 100km - 50km Facility-wide Pollutant Name: Facility-wide Emissions Increase: Emissions: Volatile Organic Compounds (VOC) 750.0000 (Tons/Year)

Process/Pollutant Information PROCESS NAME: Floor Activities Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 504.00 airplanes per year Process Notes: Floor activities include but are not limited to spar, wing, and aircraft assembly. POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 458.0000 TONS YEAR Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: New Vertical Wing Booth (PB5) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 65.0000 LB PER WING 12-MONTH ROLLING Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: New Vertical Wing Booth (PB6) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 65.0000 LB PER WING 12-MONTH ROLLING Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: New Vertical Wing Booth (PB7) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 65.0000 LB PER WING 12-MONTH ROLLING Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: New Corrosion Inhibitor Compound Booth (CB1) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 7.7000 LB/WING 12-MONTH ROLLING Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP Other Applicable Requirements: NESHAP Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: New Corrosion Inhibitor Compound Booth (CB2) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 7.7000 LB PER WING 12-MONTH ROLLING Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: New Corrosion Inhibitor Compound Booth (CB3) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 7.7000 LB PER WING 12-MONTH ROLLING Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: Other Applicable Requirements: Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: New Paint Hangar (P-7/P-8) Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 1350.0000 LB PER PLANE 12-MONTH ROLLING Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP Control Method: (P) Boeing must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on February 19, 2013 Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Facility Information RBLC ID: WA-0348 (draft) Date Determination Last Updated: 03/14/2013 Corporate/Company THE BOEING COMPANY Permit PSD-08-01 Name: Number: AMENDMENT 2 Facility Name: BOEING RENTON Permit Date: 02/19/2013 (actual) Facility Contact: MICHAEL VERHAAR (425) 965-1567 [email protected] FRS Number: Facility Description: The Boeing Renton facility is located in the city of Renton in King County, Washington, and began operation SIC Code: 3721 in 1942. It occupies 339 acres, and currently manufactures parts for and assembles the 737 series airplane model. The facility is located in the south half of Section 18, Township 23N, Range 5, Willamette Meridian. It is bounded to the north by Lake Washington, to the south by Airport Way, to the east by Logan Avenue, and to the west by the Renton Airport Permit Type: C: Modify process at existing facility NAICS Code: 336411 Permit URL: http://www.ecy.wa.gov/programs/air/psd/psd_existingpermits.html EPA Region: 10 COUNTRY: USA Facility County: KING Facility State: WA Facility ZIP Code: 98124 Permit Issued By: WASHINGTON STATE DEPARTMENT OF ECOLOGY (ECY); AIR QUALITY PROGRAM (Agency Name) MR. MARC CROOKS(Agency Contact) (360)407-6803 [email protected] Permit Notes: Boeing Renton increased VOC emissions at Buildings 4-20, 4-21, 4-81, and 4-82. The 118 tpy VOC limit was eliminated and incoorporated into a facility limit of 750 tpy in PSD-12-01. Affected Boundaries: Boundary Type: Class 1 Area State: Boundary: Distance: CLASS1 WA Alpine Lakes < 100 km CLASS1 WA Glacier Peak < 100 km CLASS1 WA Goat Rocks 100km - 50km CLASS1 WA Mount Adams 100km - 50km CLASS1 WA Mount Rainier NP < 100 km CLASS1 WA North Cascades NP 100km - 50km CLASS1 WA Olympic NP < 100 km INTL BORDER US/Canada Border 100km - 50km

Process/Pollutant Information PROCESS NAME: P1 Painting Operations Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 6.00 depainted airplanes Process Notes: No more than 6 airplanes may be depainted in Building 5-50 in any 12 consecutive months POLLUTANT NAME: CAS Number: Test Method: Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: Other Applicable Requirements: NESHAP Control Method: () Est. % Efficiency: Cost Effectiveness: $/ton Incremental Cost Effectiveness: $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: Final exterior coating Building 5-50 Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Other Other Test Method: mass ballance Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 40.8000 TONS 12 CONSECUTIVE MONTHS Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (P) low VOC primers, coatings, and solvents. Application requirements. composite vapor pressure of 45 mm Hg @ 20 degree C Est. % Efficiency: Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Facility Information RBLC ID: IN-0126 (final) Date Determination Last Updated: 10/11/2012 Corporate/Company Name: DEAN BALDWIN PAINTING LP Permit Number: 103-30549-00046 Facility Name: DEAN BALDWIN PAINTING LP Permit Date: 09/21/2011 (actual) Facility Contact: BARBARA BALDWIN 8304385340 FRS Number: 110043976301 Facility Description: STATIONARY AIRCRAFT REFINISHING FACILITY SIC Code: 4581 Permit Type: A: New/Greenfield Facility NAICS Code: 488190 Permit URL: HTTP://PERMITS.AIR.IDEM.IN.GOV/30549F.PDF EPA Region: 5 COUNTRY: USA Facility County: MIAMI Facility State: IN Facility ZIP Code: 46971 Permit Issued By: INDIANA DEPT OF ENV MGMT, OFC OF AIR (Agency Name) MR. MATT STUCKEY(Agency Contact) (317) 233-0203 [email protected] Other Agency Contact Info: PERMIT WRITER: JASON KRAWCZYK [email protected] 317-234-5174 Permit Notes:

Process/Pollutant Information

PROCESS NAME: REFINISH OPERATION Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: 23.00 GAL/H PAINT Process Notes: Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 4.5000 LB/GAL MONTHLY VOLUME-WEIGHTED AVERAGE Emission Limit 2: 4.5000 LB/GAL MONTHLY VOLUME-WEIGHTED AVERAGE Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: N Case-by-Case Basis: OTHER CASE-BY-CASE Other Applicable Requirements: N/A Control Method: (P) MANGAMENT AND WORK PRACTICES Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: EMISSION LIMIT 1: UNIT OF MEASURE: PER GAL OF PRIMER (LESS WATER & EXEPMT SOLVENTS), AS APPLIED EMISSION LIMIT 2: UNIT OF MEASURE: PER GAL OF TOPCOATS (LESS WATER & EXEPMT SOLVENTS), AS APPLIED EMISSION LIMIT 3: 4.5 LB OF VOC/ GAL OF SELF-PRIMING TOPCOATS, MONTHLY VOLUME-WEIGHTED AVERAGE, (LESS WATER & EXEPMT SOLVENTS), AS APPLIED EMISSION LIMIT 4: ALL PRIMERS AND TOPCOATS (INCLUDING SELF-PRIMING TOPCOATS) SHALL BE APPLIED USING ONE OR MORE OF THE APPLICATION TECHNIQUES SPECIFIED BELOW: FLOW/CURTAIN COAT APPLICATION, DIP COAT APPLICATION, ROLL COATING, BRUSH COATING, COTTON-TIPPED SWAB APPLICATION, ELECTRODEPOSITION (DIP) COATING, HIGH VOLUME LOW PRESSURE (HVLP) SPRAYING, ELECTROSTATIC SPRAY APPLICATION, OR OTHER COATING APPLICATION METHODS THAT ACHIEVE EMISSION REDUCTIONS EQUIVALENT TO HVLP OR ELECTROSTATIC SPRAY APPLICATION METHODS. STATE BACT

Facility Information RBLC ID: WA-0344 (final) Date Determination Last Updated: 03/03/2009 Corporate/Company Name: BOEING COMMERCIAL AIRPLANE GROUP Permit Number: PSD 08-01 Facility Name: RENTON Permit Date: 10/07/2008 (actual) Facility Contact: MICHAEL VERHAAR 4259652302 [email protected] FRS Number: 110015518965 Facility Description: THEY MAKE AIRPLANES. THIS PERMIT IS FOR A PAINT BOOTH/HANGAR. SIC Code: 3721 Permit Type: B: Add new process to existing facility NAICS Code: 336411 Permit URL: EPA Region: 10 COUNTRY: USA Facility County: KING Facility State: WA Facility ZIP Code: 98055 Permit Issued By: WASHINGTON STATE DEPARTMENT OF ECOLOGY (ECY); AIR QUALITY PROGRAM (Agency Name) MR. MARC CROOKS(Agency Contact) (360)407-6803 [email protected] Permit Notes: Facility-wide Emissions: Pollutant Name: Facility-wide Emissions Increase: Volatile Organic Compounds (VOC) 73.9000 (Tons/Year)

Process/Pollutant Information PROCESS NAME: PAINT BOOTH/HANGAR Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 40.8000 T/YR 12 MONTH ROLLING AVERAGE Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (P) COMPOLIANCE WITH 40 CFR PART 63, SUBPART GG AND LOW VOC VAPOR PRESSURE CLEANING SOLVENTS AND STRIPPERS WITH LOW PRESSURE APPLICATORS OR MANUAL APPLICATION FOR DEPAINTING. Est. % Efficiency: Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Facility Information RBLC ID: WA-0340 (final) Date Determination Last Updated: 03/27/2008 Corporate/Company THE BOEING COMPANY Permit PSD-06-04 Name: Number: Facility Name: BOEING EVERETT Permit Date: 07/27/2007 (actual) Facility Contact: JOHN FOSBERG 4257170988 [email protected] FRS Number: 110005340489 Facility Description: CURRENTLY THE AIRPLANES ARE PAINTED IN ONE OF THREE EXISTING PAINT HANGARS, I.E., SIC Code: 3721 BUILDINGS 45-01, 45-03, AND 45-04 LOCATED TO THE SOUTH OF STATE ROUTE 526. DUE TO INCREASED MARKET DEMAND FOR THESE AIRPLANES, PREDICTED PRODUCTION RATES FOR 2009 AND BEYOND MAY EXCEED THE RATE AT WHICH AIRPLANES CAN BE PAINTED IN THE THREE EXISTING HANGARS. THEREFORE, BOEING PLANS TO CONSTRUCT A NEW FOURTH AIRPLANE HANGAR AT THE EVERETT FACILITY TO ACCOMMODATE THE INCREASED PRODUCTION RATE. THE NEW PAINT HANGAR IS EXPECTED TO BE BUILT ADJACENT TO THE 45-01 BUILDING. IT WILL INCLUDE UP TO EIGHT NEW SOLVENT CLEANING BENCHES, A PAINT STRIPPING BENCH, SOLVENT RECOVERY EQUIPMENT, TWO EXHAUST HOODS FOR MIXING SMALL QUANTITIES OF PAINT, AND A BOOTH TO PAINT RUDDERS, ELEVATORS AND MISCELLANEOUS PARTS. THIS PROJECT RESULTS IN EMISSIONS OF VOLATILE ORGANIC COMPOUNDS (VOC) AND PARTICULATE MATTER (PM) SMALLER THAN 10 MICRONS IN DIAMETER (PM10). Permit Type: C: Modify process at existing facility NAICS Code: 325510 Permit URL: EPA Region: 10 COUNTRY: USA Facility County: SNOHOMISH Facility State: WA Facility ZIP Code: Permit Issued By: WASHINGTON STATE DEPARTMENT OF ECOLOGY (ECY); AIR QUALITY PROGRAM (Agency Name) MR. MARC CROOKS(Agency Contact) (360)407-6803 [email protected] Other Agency ACTUALL THIS PERMIT WAS PROCESSED BY RICHARD HIBBARD Contact Info: EMAIL [email protected] PHONE (360) 407-6896 Permit Notes: Affected Boundary Type: Class 1 Area State: Boundary: Distance: Boundaries: CLASS1 WA Alpine Lakes < 100 km CLASS1 WA Glacier Peak < 100 km CLASS1 WA Goat Rocks 100km - 50km CLASS1 WA Mount Rainier NP 100km - 50km CLASS1 WA North Cascades NP 100km - 50km CLASS1 WA Olympic NP < 100 km Facility-wide Pollutant Name: Facility-wide Emissions Increase: Emissions: Volatile Organic Compounds (VOC) 412.0000 (Tons/Year)

Process/Pollutant Information PROCESS PAINT HANGAR/FINAL EXTERIOR COATING NAME: Process Type: 41.001 (Aerospace Surface Coating) Primary Fuel: Throughput: Process THE PROPOSED PROJECT CONSISTS OF CONSTRUCTING A NEW PAINT HANGAR TO PAINT AIRPLANES, INCLUDING 747, 767, 777, Notes: AND 787 MODEL AIRPLANES. IN ADDITION TO EQUIPMENT FOR AIRPLANE CLEANING AND COATING OPERATIONS IN THE HANGAR BAY, THE PAINT HANGAR WILL ALSO INCLUDE UP TO EIGHT NEW SOLVENT CLEANING BENCHES, A NEW PAINT STRIPPING BOOTH, A NEW SOLVENT RECOVERY SYSTEM, TWO NEW PAINT MIX BOOTHS, AND A NEW RUDDER SPRAY BOOTH.

POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 412.0000 T ANY 12 CONSECUTIVE MONTHS Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: Other Case-by-Case Other Applicable Requirements: NESHAP Control Method: (P) Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

COMPREHENSIVE REPORT Report Date:02/19/2017 Facility Information RBLC ID: OK-0145 (draft) Date Determination Last Updated: 12/07/2016 Corporate/Company HUBER ENGINEERED WOODS LLC Permit Number: 2003-099-C(M-3)PSD Name: Facility Name: BROKEN BOW OSB MILL Permit Date: 06/25/2012 (actual) Facility Contact: RICKY FRANKLIN 580-584-7000 [email protected] FRS Number: 089-00015 Facility Description: Oriented Strand Board (OSB) Mill includes the OSB pressing operation (press), the wood strand drying SIC Code: 2493 operation (drying) and two 150 million BTU per hour (MMBtu/Hr) wood fired furnaces that supply heat for the drying process. Permit Type: C: Modify process at existing facility NAICS Code: 321219 Permit URL: EPA Region: 6 COUNTRY: USA Facility County: MCCURTAIN Facility State: OK Facility ZIP Code: 74728 Permit Issued By: OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY (Agency Name) MR. LEE WARDEN(Agency Contact) (405)702-4182 [email protected] Permit Notes: Huber Engineered Woods, LLC is seeking to increase their permitted hourly and annual production rates and also requests the capability to use another resin, melamine urea phenol formaldehyde (MUPF) to provide operational flexibility in variable market conditions. Affected Boundaries: Boundary Type: Class 1 Area State: Boundary: Distance: CLASS1 AR Caney Creek < 100 km CLASS1 MO Hercules-Glades 100km - 50km CLASS1 AR Upper Buffalo 100km - 50km CLASS1 OK Wichita Mountains > 250 km Facility-wide Pollutant Name: Facility-wide Emissions Increase: Emissions: Carbon Monoxide 443.3000 (Tons/Year) Nitrogen Oxides (NOx) 944.7000 (Tons/Year) Particulate Matter (PM) 201.1000 (Tons/Year) Sulfur Oxides (SOx) 69.8000 (Tons/Year) Volatile Organic Compounds (VOC) 1071.1000 (Tons/Year)

Process/Pollutant Information PROCESS Energy System/Dryers and RTO Burners NAME: Process Type: 12.120 (Biomass (includes wood, wood waste, bagasse, and other biomass)) Primary Fuel: Wood Throughput: 80.00 Oven Dried Tons/hr Process Notes: Regenerative Thermal Oxidizer (RTO) ; Oven Dried Tons (ODT) ; The energy system/dryers are controlled by a regenerative thermal oxidizer (RTO). Emissions from the energy source/dryers and the RTO burners are being emitted through a common exhaust stack. As such, emissions from the RTO burners cannot be separated from those of the energy source and dryers and are therefore combined together with the energy source and dryers here and in the BACT analysis.

POLLUTANT NAME: Nitrogen Oxides (NOx) CAS Number: 10102 Test Method: EPA/OAR Mthd 7 Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 2.5700 LB/ODT Emission Limit 2: 900.5300 TPY Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: N Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NSPS , OPERATING PERMIT Control Method: (P) Staged Combustion Est. % Efficiency: 45.000 Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: Compliance based on monitoring dryer throughput (12-mo rolling avg) and annual stack test.

POLLUTANT NAME: Carbon Monoxide CAS Number: 630-08-0 Test Method: EPA/OAR Mthd 10 Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 1.1600 LB/ODT Emission Limit 2: 406.4600 TPY Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: N Case-by-Case Basis: BACT-PSD Other Applicable Requirements: OPERATING PERMIT Control Method: (A) Regenerative Thermal Oxidizer (RTO) Est. % Efficiency: 90.000 Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: No Pollutant/Compliance Notes: Compliance based on monitoring dryer throughput (12-mo rolling avg) and bi-annual stack test

POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: EPA/OAR Mthd 18 Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 0.7700 LB/ODT Emission Limit 2: 269.8100 TPY Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: N Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NESHAP , MACT , OPERATING PERMIT Control Method: (A) RTO Est. % Efficiency: 90.000 Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Yes Pollutant/Compliance Notes: Monitor dryer throughput (12-mo rolling avg) and stack test every other year.

POLLUTANT NAME: Particulate matter, total < 10 µ (TPM10) CAS Number: PM Test Method: EPA/OAR Mthd 201A and OTM 28 Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 0.2300 LB/ODT Emission Limit 2: 82.0000 TPY Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: N Case-by-Case Basis: BACT-PSD Other Applicable Requirements: NSPS , OPERATING PERMIT Control Method: (A) Wet ESP Est. % Efficiency: 90.000 Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Yes Pollutant/Compliance Notes: Monitor dryer throughput (12-mo rolling avg) and stack test every 5 years

POLLUTANT NAME: Sulfur Dioxide (SO2) CAS Number: 7446-09-5 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) ) Emission Limit 1: 0.1800 LB/ODT Emission Limit 2: 61.6000 TPY Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Y Case-by-Case Basis: BACT-PSD Other Applicable Requirements: OPERATING PERMIT Control Method: (N) Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: Monitor dryer throughput (12-mo rolling total) and stack test once every 5 years

POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e) CAS Number: CO2e Test Method: Unspecified Pollutant Group(s): ( Greenhouse Gasses (GHG) ) Emission Limit 1: 792.4400 TPY FOR ENERGY SYSTEM/DRYERS Emission Limit 2: 117.1000 LB/MMBTU FOR RTO BURNERS Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (P) Use biomass fuel and good combustion/operating practices Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: Oriented Strand Board (OSB) Press Process Type: 30.520 (Board Presses. ) Primary Fuel: Throughput: 110.00 MSF/hr Process Notes: MSF - thousand square feet / hr (daily avg) on a 3/8" basis POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 0.4200 LB/MSF VOC AS EMITTED Emission Limit 2: 204.3000 TPY Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Y Case-by-Case Basis: BACT-PSD Other Applicable Requirements: MACT , NESHAP , OPERATING PERMIT Control Method: (A) Biofilter Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: Stack test every 5 years

POLLUTANT NAME: Carbon Monoxide CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 11.6000 TPY Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: OPERATING PERMIT Control Method: (P) Good operating practice Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, total < 10 µ (TPM10) CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 58.7000 TPY Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (P) Good operating practice Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: Stack test every 5 years

POLLUTANT NAME: Nitrogen Oxides (NOx) CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 9.6000 TPY Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (P) Good operating practice Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

POLLUTANT NAME: Sulfur Oxides (SOx) CAS Number: 7446 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) ) Emission Limit 1: 4.8000 TPY Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: OPERATING PERMIT Control Method: (N) Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e) CAS Number: CO2e Test Method: Unspecified Pollutant Group(s): ( Greenhouse Gasses (GHG) ) Emission Limit 1: Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (P) Operating biofilter in accordance with manufacturer's guidance; No emission limit proposed because a limit would work against controlling VOC. Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: No emission limit proposed because a limit would work against controlling VOC.

Process/Pollutant Information PROCESS NAME: PM Control System Process Type: 30.540 (Board Product Finishing. (e.g. sanders, saws and trimmers)) Primary Fuel: Throughput: 80.00 ODT/hr Process Notes:

POLLUTANT NAME: Particulate matter, total < 10 µ (TPM10) CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (A) Baghouse/Fabric filter Est. % Efficiency: 99.000 Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: PM Control System Process Type: 30.590 (Miscellaneous Particle & Strand Board Operations ) Primary Fuel: Throughput: 110.00 MSF/hr Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (N) Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: Estimates of emissions from the various baghouses have been updated in accordance with available engineering test data.

Process/Pollutant Information PROCESS NAME: Branding Operations Process Type: 41.999 (Other Surface Coating/Printing/Graphic Arts Sources) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 7.5000 TPY Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Y Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (P) Use inks that have a VOC content equal to or less than 7.76% VOC Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information PROCESS NAME: Emerg Diesel Gen, Fire Pump, Rail Steam Gen, Air Makeup Units Process Type: 17.110 (Fuel Oil (ASTM # 1,2, includes kerosene, aviation, diesel fuel)) Primary Fuel: Diesel Throughput: 0 Throughput: 0 Process Notes: Also some activity that is 19.600 POLLUTANT NAME: Nitrogen Oxides (NOx) CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (N) Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: Also CO, VOC, and SO2. Equipment design and limitation on hours of operation

Process/Pollutant Information PROCESS NAME: Natural Gas Fired Sources Process Type: 19.600 (Misc. Boilers, Furnaces, Heaters) Primary Fuel: Natural Gas Throughput: 0 Process Notes:

POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e) CAS Number: CO2e Test Method: Unspecified Pollutant Group(s): ( Greenhouse Gasses (GHG) ) Emission Limit 1: Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (P) Good Combustion/operating practices. Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: aGHG emission factors from the GHG Mandatory Reporting rule (40 CFR Part 98) Subpart C, Table C-1 and C-2

Process/Pollutant Information PROCESS NAME: Storage Vessels Process Type: 42.009 (Volatile Organic Liquid Storage) Primary Fuel: Throughput: 0 Process Notes: POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: N/A Control Method: (N) Est. % Efficiency: Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Unknown Pollutant/Compliance Notes: Good Design/Operation

Facility Information RBLC ID: MN-0091 (final) Date Determination Last Updated: 07/06/2016 Corporate/Company 3M Permit Number: 12300015-009 Name: Facility Name: 3M R&D FACILITY - MAPLEWOOD BLDG 201 Permit Date: 05/15/2012 (actual) Facility Contact: TINA MUMM 651 737 3606 [email protected] FRS Number: 110043803603 Facility Description: Research and Development facility. One of the coating units is increasing allowable production by 10 SIC Code: 8731 tpy of VOC. Any increase in VOC emissions for this R&D unit requires a BACT determination. Permit Type: C: Modify process at existing facility NAICS Code: 541710 Permit URL: EPA Region: 5 COUNTRY: USA Facility County: RAMSEY Facility State: MN Facility ZIP Code: 55144 Permit Issued By: MINNESOTA POLL CTRL AGCY, AIR QUAL DIV (Agency Name) MR. RICHARD CORDES(Agency Contact) (651)757-2291 [email protected] Permit Notes: Building 201 Affected Boundaries: Boundary Type: Class 1 Area State: Boundary: Distance: INTL BORDER US/Canada Border > 250 km Facility-wide Emissions: Pollutant Name: Facility-wide Emissions Increase: Volatile Organic Compounds (VOC) 10.0000 (Tons/Year)

Process/Pollutant Information

PROCESS NAME: Coater in R&D Facility Process Type: 41.999 (Other Surface Coating/Printing/Graphic Arts Sources) Primary Fuel: Natural Gas Throughput: 9.04 lb/hr Process Notes: coating material POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 15.0000 TONS PER YEAR 12-MONTH ROLLING SUM Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: N Case-by-Case Basis: BACT-PSD Other Applicable Requirements: OPERATING PERMIT Control Method: (N) Est. % Efficiency: Cost Effectiveness: 27013 $/ton Incremental Cost Effectiveness: 27013 $/ton Compliance Verified: Yes Pollutant/Compliance Notes:

Facility Information RBLC ID: DC-0007 (final) Date Determination Last Updated: 02/08/2010 Corporate/Company UNITED STATES DEPARTMENT OF TREASURY Permit 6093 Name: Number: Facility Name: BUREAU OF ENGRAVING & PRINTING Permit Date: 07/22/2008 (actual) Facility Contact: NEAL M. MOHLMANN 2028742048 [email protected] FRS Number: 110017347879 Facility Description: THE BUREAU OF ENGRAVING AND PRINTING (BEP) PRODUCES UNITED STATES CURRENCY AND SIC Code: 2893 OTHER GOVERNMENT SECURITIES. THE BEP, LOCATED AT 14TH AND C STREETS, SW WASHINGTON, DC, IS HOUSED IN THREE BUILDINGS; MAIN, ANNEX AND FREIGHT. APPROXIMATELLY 1600 PEOPLE ARE EMPLOYED BY THE BEP IN THE DISTRICT OF COLUMBIA. THERE ARE THREE SHIFTS OF OPERATIONS. THE CURRENCY PRINTING OPERATIONS PERFORMED AT BEP INCLUDE: INTAGLIO, OFFSET, AND LETTER PRESS PRINTING; TRIMMING, CUTTING, EXAMINING, AND PACKAGING OF PRINTING PRODUCTS; INK MANUFACTURING, ROLLER RECOVERY, ENGINEERING, ELECTROPLATING, PLATE MAKING, PHOTOENGRAVING, PHOTOPROCESSING, COMPUTER TO IMAGE PROCESSING, GRAPHIC DESIGN, LABORATORY SERVICES, AND VARIOUS MAINTENANCE SUPPORT SERVICES. THE PRIMARY PRINTING OPERATIONS OCCUR IN THE MAIN BUILDING. PLATE MAKING, INK MANUFACTURING, AND RELATED SUPPORT SERVICES ARE LOCATED IN THE ANNEX BUILDING. Permit Type: C: Modify process at existing facility NAICS Code: 325910 Permit URL: EPA Region: 3 COUNTRY: USA Facility County: WASHINGTON Facility State: DC Facility ZIP Code: 20228 Permit Issued By: DISTRICT DEPARTMENT OF THE ENVIRONMENT, AIR QUALITY DIVISION (Agency Name) STEPHEN S. OURS(Agency Contact) (202) 535-1747 [email protected] Other Agency ABRAHAM T. HAGOS Contact Info: Permit Notes: BEP IS INSTALLING SUPER ORLOF INTAGLIO PRESSES TO REPLACE MUCH OLDER INTAGLIO PRINTING PRESSES. IN THE 1990'S, BEP INSTALLED THERMAL OXIDIZER TO CAPTURE THE VOC FROM THE NON HEATSET INTAGLIO PRINTING OPERATIONS. THIS METHOD OF REDUCTION HAS SINCE BEEN REPLACED BY THE USE OF LOWER VOC CLEANING SOLVENTS, LOW VAPOR PRESSURE CLEANING SOLVENTS, AND MORE EFFICIENT OPERATIONS; THE USE OF ALTERNATE MEANS OF CONTROLLING VOC'S WILL REDUCE THE COMBUSTION EMMISSIONS OF OVER 600 TPY OF CO2 AND 2 TPY OF NOX AND CO. IT ALSO CONSERVES OVER 110 MMM FEET CUBE OF NATURAL GAS. THE SOI'S HAVE A MORE EFFICIENT METHOD APPLING INK TO INGRAVE PLATE AND ARE EXPECTED TO SAVE APPROXIMATELY 50% OF THE INK IN COMPARISON TO AN I-8 PRESS. THE INTAGLIO DRYING PROCESS IS A FUNCTION OF SOLVENT LOSE, OXIDATIVE CURING OF THE INTAGLIO INK, AND ENTRAPMENT OF THE VOC IN THE SUBSTRATE (PAPER). OXIDATIVE CURING INVOLVES THE GENERATION OF FREE RADICALS WHICH REACT TO FORM POLYMERS. CURING AGENTS ARE INCORPORATED IN THE INKS THAT FORM FREE RADICALS AND REACT WITH THE ALKYD MONOMERS CAUSING THE INK TO CURE. THE DRYING PROCESS EMITS VERY LOW LEVELS OF VOCS, ESTIMATED AT 1% OF THE TOTAL INK USED. Affected Boundary Type: Class 1 Area State: Boundary: Distance: Boundaries: CLASS1 NJ Brigantine 100km - 50km CLASS1 WV Dolly Sods 100km - 50km CLASS1 VA James River Face 100km - 50km CLASS1 WV Otter Creek 100km - 50km CLASS1 VA Shenandoah NP 100km - 50km

Process/Pollutant Information

PROCESS NAME: PRINTING PROCESS - SUPER ORLOF INTAGLIO (SOI) NON-HEATSET SHEET FEED Process Type: 41.999 (Other Surface Coating/Printing/Graphic Arts Sources) Primary Fuel: Throughput: 12000.00 SHEETS PER HOUR Process Notes: THIS IS A CURRENCY PRINTING OPERATION. THERE ARE 50 SUBJECTS (CURRENCY NOTES) PER SHEET. POLLUTANT NAME: Volatile Organic Compounds (VOC) CAS Number: VOC Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 0.8800 LB/H FROM INK Emission Limit 2: 0.8000 LB/H FROM SOLVENTS Standard Emission: 6.4400 T/YR OVER 7665 HOURS PER YEAR Did factors, other then air pollution technology considerations influence the BACT decisions: N Case-by-Case Basis: LAER Other Applicable Requirements: OPERATING PERMIT Control Method: (A) 1. INDIRECT APPLICATION OF INK TO ENGRAVED PLATES. 2. LOW VAPOR PRESSURE CLEANING SOLVENT (< 10 MM HG). 3. AUTOMATIC PLATE WASHER. 4. GOOD HOUSKEEPING PRACTICES. Est. % Efficiency: 99.000 Cost Effectiveness: 0 $/ton Incremental Cost Effectiveness: 0 $/ton Compliance Verified: Yes Pollutant/Compliance Notes: IN THE 1990S, BEP ESTABLISHED THAT LAER FOR THIS TYPE OF PROCESS INCLUDED THE USE OF THERMAL OXIDIZERS WITH THE EXISTING INK AND SOLVENT TECHNOLOGIES. HOWEVER, VOC LEVELS HAVE DECREASED SUBSTANTIALLY IN SOLVENTS AND INKS TO EXTREMELY LOW LEVELS. DDOE HAS DETERMINED THAT VOC EMISSIONS WITH THESE NEW SOLVENTS AND INKS ARE AT MORE EFFECTIVE THAN THE THERMAL OXIDIZERS WITH THE OLDER INKS AND SOLVENTS. THE USE OF A THERMAL OXIDIZER INCREASES THE EXPENSE OF THE PROCESS (~110 MMCF OF NATURAL GAS USAGE AND MAINTENANCE COSTS) AND ALSO INVOLVES EMISSIONS OF APPROXIMATELY 2 TPY OF NOX AND CO AND 600 TPY OF CO2 WHICH OFFSETS THE VERY SMALL REDUCTION OF VOCS ACHIEVED WITH THE APPLICATION OF A THERMAL OXIDIZER WITH THE VERY LOW INK/SOLVENT EMISSIONS. THUS, IT WAS DETERMINED THAT THE LOW VOC INKS AND SOLVENTS CAN BE USED IN PLACE OF THE OLD LAER REQUIREMENTS.

APPENDIX C

Regenerative Thermal Oxidizer Cost Estimate

Zodiac Aerospace Regenerative Thermal Oxidizer Newport, Washington Winder Room BACT Analysis Summary Sheet

SYSTEM INPUTS Temperature (In): 72 oF Temperature (combustion): 1500 oF Overall Heat Transfer Efficiency: 95% Flow rate: 4,680 scfm RTO Operating Hours 2,468 hours/year Capture Efficiency 100% Destruction Efficiency 98% Overall Control Efficiency: 98.0% Uncontrolled VOC Emissions 22 tons/yr

SYSTEM OUTPUTS Total Capital Investment = $676,216 Total Annual Costs = $244,644 Total VOC destroyed = 21.6 tons/yr

Cost per Ton = $11,326 /ton Zodiac Aerospace Regenerative Thermal Oxidizer Newport, Washington Winder Room BACT Analysis Estimated Capital Investment

DIRECT CAPITAL COSTS Purchased equipment costs Incinerator + auxillary equipment (EC) $ 290,000 Instrumentation 10% of EC $ 29,000 Sales taxes 3% of EC $ 8,700 Freight $ 17,000 Total purchased equipment costs (PEC) $ 344,700

Installation costs Foundations & supports $ 25,000.00 Handling & erection $ 15,000.00 Electrical $ 165,000.00 Piping $ - Insulation $ - Painting $ - Total installation costs $ 205,000

Site preparation (elevated structure) $ - Buildings $ -

Total Direct Capital Costs = $ 549,700

INDIRECT CAPITAL COSTS Engineering 10% of PEC $ 34,470 Construction and field expenses 5% of PEC $ 17,235 Contractor fees 10% of PEC $ 34,470 Start-up $ 18,000 Performance test $ 12,000 Contingencies 3% of PEC $ 10,341

Total Indirect Capital Costs = $ 126,516

Total Capital Investment $ 676,216 Zodiac Aerospace Regenerative Thermal Oxidizer Newport, Washington Winder Room BACT Analysis Estimated Annual Costs

DIRECT ANNUAL COSTS Operation costs Operator * 2 hr/shift 35 $/hr $ 21,592 Supervisor 15% of operator $ 3,239 Operating materials $ - Total operation costs $ 24,830

Maintenance Labor 2 hr/shift 35 $/hr $ 21,592 Materials 100% of maintenance labor $ 21,592 Total maintenance costs $ 43,183

Utilities Propane 1.20 $/gal $ 6,100 Electricity 0.0694 $/kWh $ 6,396 Total utilities $ 12,496

Total Direct Annual Costs = $ 80,510

INDIRECT ANNUAL COSTS

Overhead 60% of operating and maintenance $ 40,807.94 Administrative charges 2% of capital costs $ 13,524 Property taxes 1% of capital costs $ 6,762 Insurance 1% of capital costs $ 6,762 Capital recovery (CRC) ** 14.24% of capital costs $ 96,278

Total Indirect Annual Costs = $ 164,135

Total Annualized Cost $ 244,644

* Assumes 308.45 shifts per year ** Assumes a 7 percent interest rate and a 10-year life span

APPENDIX D

Recuperative Thermal Oxidizer Cost Estimate

Zodiac Aerospace Recuperative Thermal Oxidizer Newport, Washington Winder Room BACT Analysis Summary Sheet

SYSTEM INPUTS Temperature (In): 72 oF Temperature (combustion): 1500 oF Overall Heat Transfer Efficiency: 65% Flow rate: 4,680 scfm RTO Operating Hours 2,468 hours/year Capture Efficiency 100% Destruction Efficiency 98% Overall Control Efficiency: 98.0% Uncontrolled VOC Emissions 22.0 tons/yr

SYSTEM OUTPUTS Total Capital Investment = $956,490 Total Annual Costs = $375,299 Total VOC destroyed = 21.6 tons/yr

Cost per Ton = $17,375 /ton Zodiac Aerospace Recuperative Thermal Oxidizer Newport, Washington Winder Room BACT Analysis Estimated Capital Investment

DIRECT CAPITAL COSTS Purchased equipment costs Incinerator + auxillary equipment (EC) $ 489,000 Instrumentation 10% of EC $ 48,900 Sales taxes 3% of EC $ 14,670 Freight $ 15,000 Total purchased equipment costs (PEC) $ 567,570

Installation costs Foundations & supports $ 20,000.00 Handling & erection $ 15,000.00 Electrical $ 165,000.00 Piping $ - Insulation $ - Painting $ - Total installation costs $ 200,000

Site preparation (elevated structure) $ - Buildings $ -

Total Direct Capital Costs = $ 767,570

INDIRECT CAPITAL COSTS Engineering 10% of PEC $ 56,757 Construction and field expenses 5% of PEC $ 28,379 Contractor fees 10% of PEC $ 56,757 Start-up $ 18,000 Performance test $ 12,000 Contingencies 3% of PEC $ 17,027

Total Indirect Capital Costs = $ 188,920

Total Capital Investment $ 956,490 Zodiac Aerospace Recuperative Thermal Oxidizer Newport, Washington Winder Room BACT Analysis Estimated Annual Costs

DIRECT ANNUAL COSTS Operation costs Operator * 2 hr/shift 35 $/hr $ 21,592 Supervisor 15% of operator $ 3,239 Operating materials $ - Total operation costs $ 24,830

Maintenance Labor 2 hr/shift 35 $/hr $ 21,592 Materials 100% of maintenance labor $ 21,592 Total maintenance costs $ 43,183

Utilities Propane 1.20 $/gal $ 85,640 Electricity 0.0694 $/kWh $ 6,396 Total utilities $ 92,036

Total Direct Annual Costs = $ 160,049

INDIRECT ANNUAL COSTS

Overhead 60% of operating and maintenance $ 40,807.94 Administrative charges 2% of capital costs $ 19,130 Property taxes 1% of capital costs $ 9,565 Insurance 1% of capital costs $ 9,565 Capital recovery (CRC) ** 14.24% of capital costs $ 136,183

Total Indirect Annual Costs = $ 215,250

Total Annualized Cost $ 375,299

* Assumes 308.45 shifts per year ** Assumes a 7 percent interest rate and a 10-year life span

APPENDIX E

Catalytic Oxidizer Cost Estimate

Zodiac Aerospace Catalytic Oxidizer Newport, Washington Winder Room BACT Analysis Summary Sheet

SYSTEM INPUTS Temperature (In): 72 oF Temperature (combustion): 650 oF Overall Heat Transfer Efficiency: 70% Flow rate: 4,680 scfm RTO Operating Hours 2,468 hours/year Capture Efficiency 100% Destruction Efficiency 98% Overall Control Efficiency: 98.0% Uncontrolled VOC Emissions 22.0 tons/yr

SYSTEM OUTPUTS Total Capital Investment = $751,101 Total Annual Costs = $277,265 Total VOC destroyed = 21.6 tons/yr

Cost per Ton = $12,836 /ton Zodiac Aerospace Catalytic Oxidizer Newport, Washington Winder Room BACT Analysis Estimated Capital Investment

DIRECT CAPITAL COSTS Purchased equipment costs Incinerator + auxillary equipment (EC) $ 347,000 Instrumentation 10% of EC $ 34,700 Sales taxes 3% of EC $ 10,410 Freight $ 15,000 Total purchased equipment costs (PEC) $ 407,110

Installation costs Foundations & supports $ 20,000.00 Handling & erection $ 15,000.00 Electrical $ 165,000.00 Piping $ - Insulation $ - Painting $ - Total installation costs $ 200,000

Site preparation (elevated structure) $ - Buildings $ -

Total Direct Capital Costs = $ 607,110

INDIRECT CAPITAL COSTS Engineering 10% of PEC $ 40,711 Construction and field expenses 5% of PEC $ 20,356 Contractor fees 10% of PEC $ 40,711 Start-up $ 18,000 Performance test $ 12,000 Contingencies 3% of PEC $ 12,213

Total Indirect Capital Costs = $ 143,991

Total Capital Investment $ 751,101 Zodiac Aerospace Catalytic Oxidizer Newport, Washington Winder Room BACT Analysis Estimated Annual Costs

DIRECT ANNUAL COSTS Operation costs Operator * 2 hr/shift 35 $/hr $ 21,592 Supervisor 15% of operator $ 3,239 Operating materials $ - Total operation costs $ 24,830

Maintenance Labor 2 hr/shift 35 $/hr $ 21,592 Materials 100% of maintenance labor $ 21,592 Total maintenance costs $ 43,183

Utilities Propane 1.20 $/gal $ 25,064 Electricity 0.0694 $/kWh $ 6,396 Total utilities $ 31,460

Total Direct Annual Costs = $ 99,473

INDIRECT ANNUAL COSTS

Overhead 60% of operating and maintenance $ 40,807.94 Administrative charges 2% of capital costs $ 15,022 Property taxes 1% of capital costs $ 7,511 Insurance 1% of capital costs $ 7,511 Capital recovery (CRC) ** 14.24% of capital costs $ 106,940

Total Indirect Annual Costs = $ 177,792

Total Annualized Cost $ 277,265

* Assumes 308.45 shifts per year ** Assumes a 7 percent interest rate and a 10-year life span

APPENDIX F

Estimated Costs From Catalytic Products

Customer Name: Aerocell Set G1 to 1 to eliminate electric costs 0 0 Date: 9/9/2015 1 Price per Therm $0.9500 Price per kWh $0.0393 6,000 SCFM 6,000 SCFM 6,000 SCFM VECTOR Catalytic QUADRANT Thermal TRITON Regenerative Thermal Oxidizer Oxidizer Oxidizer Destruction Rate Efficiency 98% 99% 98% Thermal Efficiency 70% 65% 95% OPERATIONAL MODE: IDLE IDLE IDLE Flow 1,500 SCFM 3,000 SCFM 1,500 SCFM Process Temperature 70 °F 70 °F 70 °F Concentration 0 ppmv 0 ppmv 0 ppmv 0 lb/hr 0 lb/hr 0 lb/hr Combustion Chamber Set Point 650 °F 1400 °F 1600 °F Gas Required 310,000 BTU/HR 1,790,000 BTU/HR 390,000 BTU/HR BHP 3.5 BHP 9 BHP 0.97 BHP Electric 2.63 kWh 6.75 kWh 0.73 kWh Total per Hour $3.05 $17.27 $3.73 OPERATIONAL MODE: ONLINE, Max Flow ONLINE, Max Flow ONLINE, Max Flow Flow 6,000 SCFM 6,000 SCFM 6,000 SCFM Process Temperature 70 °F 70 °F 70 °F VOC Concentration 25 lb/hr 25 lb/hr 25 lb/hr VOC Net Heat (BTU/lb) 9,713 BTU/lb 9,713 BTU/lb 9,713 BTU/lb Solvent Heat (MMBTUH) 242,900 BTU/hr 242,900 BTU/hr 242,900 BTU/hr Combustion Chamber Set Point 650 °F 1400 °F 1600 °F Gas Required 980,000 BTU/HR 3,340,000 BTU/HR 680,000 BTU/HR BHP 31 BHP 22.5 BHP 24.4 BHP Electric 23.25 kWh 16.88 kWh 18.30 kWh Total per Hour $10.22 $32.39 $7.18 Operating Hours Per Year (Avg. Conditions) 6,200 6,200 6,200 THERMS PER YEAR 60,760 207,080 42,160 Annual Operating Costs $63,387.10 $200,837.76 $44,510.98

Drop-In Place Installation Yes Yes Yes BUDGETARY COST ESTIMATES Equipment Cost Estimate $ 347,000 $ 489,000 $ 290,000 Rigging Cost Estimate $ 15,000 $ 15,000 $ 15,000 Foundation Cost Estimate $ 20,000 $ 20,000 $ 25,000 Mechanical and Electrical installation $ 165,000 $ 165,000 $ 165,000 <100' Shipping Cost Estimate $ 15,000 $ 15,000 $ 17,000 Startup Cost Estimate $ 18,000 $ 18,000 $ 18,000 Compliance Test $ 12,000 $ 12,000 $ 12,000 Total Project Investment $ 592,000 $ 734,000 $ 542,000

APPENDIX E NOTICE OF CONSTRUCTION APPLICATION

TECHNICAL INFORMATION SECTION IX – AMBIENT AIR IMPACTS ANALYSES

Acceptable Source Impact Analysis Report Zodiac Aerospace 501 N Newport Ave. Newport, Washington 99156 February 20, 2017 Terracon Project No. MP157289C

Prepared for: Zodiac Aerospace Newport, Washington

Prepared by: Terracon Consultants, Inc. Minneapolis, Minnesota TABLE OF CONTENTS

Page 1.0 INTRODUCTION ...... 1 2.0 Small Quantity Emission Rate Analysis ...... 1 3.0 Model Information ...... 2 4.0 Site ...... 2 4.1 Location ...... 2 4.2 Emissions ...... 4 4.3 Source parameters ...... 4 5.0 Terrain Data ...... 4 6.0 Meteorological Data ...... 5 7.0 Receptor Grid ...... 6 8.0 Model Results ...... 6

APPENDIX A – MET DATA INFORMATION

APPENDIX B – CONTOUR PLOTS OF MODEL RESULTS Exhibit B-1 2011 MODEL RESULTS Exhibit B-1 2012 MODEL RESULTS Exhibit B-1 2013 MODEL RESULTS Exhibit B-1 2014 MODEL RESULTS (OVERVIEW) Exhibit B-1 2014 MODEL RESULTS (LOCAL) Exhibit B-1 2015 MODEL RESULTS

Responsive ■ Resourceful ■ Reliable 1.0 INTRODUCTION

The purpose of this document is to demonstrate compliance for the toxic air impacts of the Zodiac Aerospace facility, located in Newport, Washington. A First Tier Review was performed based on the guidance from WAC 173-460-080. This report is issued as part of the Notice of Construction (NOC) Application that is being provided to the Department of Ecology in the State of Washington. As further explained in this report, all of the air toxics emitted from the Zodiac Aerospace facility meet the First Tier Review requirements.

2.0 SMALL QUANTITY EMISSION RATE ANALYSIS

The first step in the First Tier Review process is to compare the emission rates of each of the toxic air pollutants to the Small Quantity Emission Rate (SQER) established by the State of Washington and listed in WAC 173-460-150. See Table 2-1 below for the SQER analysis.

Table 2-1: SQER Analysis Air PTE De Minimis SQER Averaging Dispersion Pollutant (lbs/ averaging (lbs/ averaging (lbs/averaging Period Modeling period) period) period) Required? Formaldehyde Year 215 1.6 32 YES Methanol 24-hr 52 26.3 526 NO MIBK 24-hr 11 19.7 394 NO Phenol 24-hr 15 1.31 26.3 NO Toluene 24-hr 0.04 32.9 657 NO Triethylamine 24-hr 0.064 1.31 26.3 NO Isopropanol 1-hr 1.11 0.35 7.01 NO

As can be seen from the SQER analysis above, the majority of the toxic air pollutants are emitted in quantities less than the SQER. As such, the acceptable source impact analysis requirement is satisfied for all of the toxic air pollutants with the exception of formaldehyde. The maximum potential emissions for formaldehyde exceed the SQER so air dispersion modeling is required for formaldehyde. The remainder of this Report relates to the air dispersion modeling performed for formaldehyde.

There are three stacks associated with the formaldehyde emissions (thermal oxidizer stack and two panel press stacks). Stack testing was performed on the winder room and thermal oxidizer stacks (May 2015) and the panel press stacks (January 2017). The stack test results indicated that the formaldehyde emissions from the winder room were below detection limits and the observed formaldehyde concentrions from the thermal oxidizer stack (Treater process) and the Panel Press stacks were used to calculate the potential to emit (PTE).

Responsive ■ Resourceful ■ Reliable 1 Acceptable Source Impact Analysis Report Zodiac Aerospace ■ Newport, Washington February 20, 2017 ■ Terracon Project No. MP157289C

3.0 MODEL INFORMATION

Air dispersion modeling was conducted with the most recent version of AERMOD (version 16216r). The proprietary software package BREEZE AERMOD version 7.12 was used for this project. This package is a GUI shell that directly uses the EPA executable AERMOD program. The AERMOD modeling systems contains several pre-processor programs that was used as part of this analysis:

n AERMET (version 16216) n AERSURFACE (version 13016) n AERMINUTE (version 15272) n AERMAP (version 11103) n BPIPPRM

4.0 SITE

4.1 Location

The facility is located at approximately 48.185252 N, 117.040150 W in Newport, Washington. The UTM coordinates include an Easting of 497015.7 and a Northing of 5336891.3 in Zone 11. The facility consists of one multi-tier multiple rectangles-shaped building. A map of the facility including the positions of the existing source stacks and the height of each portion of the building is included in Figure 4.1-1.

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Figure 4.1-1: Layout of the Facility

Responsive ■ Resourceful ■ Reliable 3 Acceptable Source Impact Analysis Report Zodiac Aerospace ■ Newport, Washington February 20, 2017 ■ Terracon Project No. MP157289C

4.2 Emissions

Three stacks were modeled:

n Two exhaust points for the “Panel Press,” labeled as Stacks SV007 and SV008 in Figure 4.1-1. n One exhaust point for the Thermal Oxidizer, labeled as Stack SV003 in Figure 1

See Table 4.2-1 below for the modeling emission rates for each stack:

Table 4.2-1: Modeling Emission Rates SV007 Emission Rate* SV008 Emission Rate* SV003 Emission Rate** Pollutant (lbs/hr) (lbs/hr) (lbs/hr) Formaldehyde 0.004792 0.004792 0.0154 * Based on stack testing data for the Panel Press stacks and an annual limit aas documented in the PTE calculations. ** Based on stack testing data for the thermal oxidizer stack.

4.3 Source parameters

The following are the source parameters for the three stacks that are being modeled.

Table 4.3-1: Source Parameters Stack Height Temperature Flow Rate Stack Diameter Source ID (ft) (°F) (cfm) (in.) SV007 27 70* 3,962** 28.75 SV008 27 70* 3,962** 28.75 SV003 35 971 8,590 22 * Based on disussions with the Department of Ecology, the minimum temperature recorded in the stack tests was chosen to account for the meteorological station (see Section 6.0 for more information). ** Based on disussions with the Department of Ecology, the minimum flow rate recorded in the stack tests was chosen to account for the meteorological station (see Section 6.0 for more information).

5.0 TERRAIN DATA

Terrain data was downloaded from the Multi-Resolution Land Characteristics Consortium (MRLC): http://www.mrlc.gov/viewerjs/. The data is in the National Elevation Dataset (NED) format with a resolution of 1 arc-second. Receptor elevations and hill scaling heights were determined using AERMAP.

Responsive ■ Resourceful ■ Reliable 4 Acceptable Source Impact Analysis Report Zodiac Aerospace ■ Newport, Washington February 20, 2017 ■ Terracon Project No. MP157289C

6.0 METEOROLOGICAL DATA

The Guideline requires that at least five years of National Weather Service data be used in the impact analysis. Data sets from 2011-2015 was used in this analysis. Preprocessed met data was purchased from Lakes Environmental. Please see Appendix A for the hourly surface station met data information, ASOS wind data information, upper air station met data information, and the AERSURFACE parameters that were used by Lakes Environmental to process the met data.

The Spokane KOTX upper air sounding site (WBAN: 4106) was used for the upper air data.

The surface station that was used is located at the Deer Park Airport (KDEW, WBAN: 94119). This surface station was chosen in discussions with the Department of Ecology. The Deer Park Airport station was the closest surface station to the Zodiac facility containing 1-minute and 5- minute ASOS wind data. The Department of Ecology expressed concern that the Zodiac facility was located near a water body and the surface station at the Deer Park Airport is not. The concern is that the stable air flows that may occur at the Zodiac facility due to the water body would not adequatically be represented in the Deer Park station weather data (i.e., the air dispersion model may underpredict the concentration using the Deer Park station weather data). However, given the location of the Zodiac facility, there are no other stations with high quality data in the area. In order to account for the higher frequency of stable air conditions that may occur at the Zodiac facility, the Department of Ecology requested that the lower limits for temperature and flow rates from the stacks be utilized. Therefore, the temperature and flow rates from each of the stacks utilize the minimum recorded temperature and flow rate from the stack tests performed. The wind rose for the Deer Park surface station for 2011-2015 data is located in Figure 6-1 below.

Figure 6-1: Windrose for Deer Park Airport Surface Station

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7.0 RECEPTOR GRID

The following receptor grid spacing was used based on guidance from the Department of Ecology. The distances represented will be measured from the property line identified in Figure 4.1-1 above. The modeling included receptors out to 15 km from the site (i.e. 30 x 30 km grid with the facility in the center).

Table 7-1: Receptor Grid Spacing Distance from Property Line Grid Spacing (m) (m) 0-150 12.5 150-400 25 400-900 50 900-2,000 100 2,000-4,500 300 4,500-15,000 600

8.0 MODEL RESULTS

The following are the maximum yearly average modeled concentrations for 2011 through 2015. See Appendix B for contour plots of the model results for each year.

Table 8-1: Model Results Maximum Average Year Concentration (µg/m3) 2011 0.13476 2012 0.14596 2013 0.13583 2014 0.16309 2015 0.15121

The following is the 2014 model result (year with the maximum yearly concentration) compared to the Acceptable Source Impact Level (ASIL) for formaldehyde established by the State of Washington and listed in WAC 173-460-150. The maximum modeled concentration for formaldehyde is below the ASIL.

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Table 8-1: ASIL Comparison Maximum Modeled ASIL Pollutant Averaging Period Concentration (µg/m3) (µg/m3) Formaldehyde Year 0.167

Responsive ■ Resourceful ■ Reliable 7 APPENDIX A MET DATA INFORMATION

Responsive ■ Resourceful ■ Reliable 8 Lakes Environmental Software Met Data Services

AERMOD-Ready Station Met Data

SFC and PFL Met Data Files

January 4, 2017

Met Data Order Information Order # MET169427 Ordered by David Reynolds Company Terracon Met Data Type AERMOD-Ready Station Met Data (Surface & Profile Met Data Files) Start-End Date Jan 1, 2011 to Dec 31, 2015 Modeling Site Latitude 48.1852 N Modeling Site Longitude 117.04009 W Datum WGS 84 Site Time Zone UTC/GMT UTC - 8 hour(s) Closest City & State Newport, Washington - USA

Modeling Site Surface Met Station Upper Air Met Station

Location of Modeling Site, Surface Station, and Upper Air Station

1 of 5 Lakes Environmental Software

E-mail: [email protected] Web: www.webLakes.com

Lakes Environmental Software Met Data Services

Model Versions Used for Met Data Preprocessing Parameter Value AERMET Version 16216 AERMINUTE Version 15272 AERSURFACE Version 13016

Hourly Surface Station Met Data Information

Parameter Value Surface Station Name DEER PARK ARPT, WA Latitude, Longitude 47.97418 N, 117.42919 W Station ID (WBAN) 94119 ASOS Station? Yes File Format NCDC TD-3505 (ISHD) Base Elevation 672 m Adjustment to Local Time 8 hours Anemometer Height 10 m

1-Minute & 5-Minute ASOS Wind Data Information: Parameter Value AERMINUTE Data Used? Yes Station Name DEER PARK ARPT, WA Latitude, Longitude 47.97418 N, 117.42919 W Station Code DEW Station ID (WBAN) 94119 File Format NCDC TD-6405, NCDC TD-6401 IFW Installation Date September 12, 2006

Upper Air Station Met Data Information Parameter Value Upper Air Station Name SPOKANE INTNL APT, WA Latitude, Longitude 47.68 N, 117.63 W Station ID (WBAN) 4106 File Format FSL Adjustment to Local Time 8 hours

AERSURFACE Parameters

Parameter Value Land Use Data File USGS NLCD92 – Binary Format Center Lat/Long 47.97418 N, 117.42919 W Datum NAD83 Radius for Surface Roughness 1km

2 of 5 Lakes Environmental Software

E-mail: [email protected] Web: www.webLakes.com

Lakes Environmental Software Met Data Services

Parameter Value Number of Sectors 12 sectors of 30° (starting at 0°) Period Monthly Surface Moisture Average Continuous Snow: Yes Other Settings Airport Site: Yes Arid Region: No

3 of 5 Lakes Environmental Software

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Lakes Environmental Software Met Data Services

AERMOD View Instructions

Start your AERMOD View project and go to the Meteorology Pathway – Met Input Data window.

Under the Meteorology Pathway – Met Input Data window, specify the Surface Met Data file (*.SFC) and the Profile Met Data file (*.PFL) you received from Lakes Environmental according to table below:

AERMOD Parameters

Parameter Value Surface Met Data File MET169427_2011_2015.SFC Profile Met Data File MET169427_2011_2015.PFL Station Base Elevation (MSL) 672 m Surface Station No. 94119 Surface Station Name DEER PARK ARPT, WA Start Year 2011 Upper Air Station No. 4106 Upper Air Station Name SPOKANE INTNL APT, WA Start Year 2011

4 of 5 Lakes Environmental Software

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Lakes Environmental Software Met Data Services

Having Problems?

If you have any problems with the met data you received from us or need additional information on the above steps, please do not hesitate to contact us by sending an email to: [email protected]

When contacting us, please provide:

. Met data Order # MET169427 . Detailed description of the problem

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APPENDIX B CONTOUR PLOTS OF MODEL RESULTS Project Manager: Project No. CONTOUR PLOT (MODELING RESULTS) Exhibit DR MP157289C Drawn by: Scale: JK AS SHOWN Formaldehyde – 2011 Yearly Average Checked by: File Name: DR Zodiac_Form 13400 15th Ave N Zodiac Aerospace B-1 Approved by: Date: Plymouth, MN 55441-4532 Newport, Washington DR 2-20-2017 Project Manager: Project No. CONTOUR PLOT (MODELING RESULTS) Exhibit DR MP157289C Drawn by: Scale: JK AS SHOWN Formaldehyde – 2012 Yearly Average Checked by: File Name: DR Zodiac_Form 13400 15th Ave N Zodiac Aerospace B-2 Approved by: Date: Plymouth, MN 55441-4532 Newport, Washington DR 2-20-2017 Project Manager: Project No. CONTOUR PLOT (MODELING RESULTS) Exhibit DR MP157289C Drawn by: Scale: JK AS SHOWN Formaldehyde – 2013 Yearly Average Checked by: File Name: DR Zodiac_Form 13400 15th Ave N Zodiac Aerospace B-3 Approved by: Date: Plymouth, MN 55441-4532 Newport, Washington DR 2-20-2017 Project Manager: Project No. CONTOUR PLOT (MODELING RESULTS) Exhibit DR MP157289C Drawn by: Scale: Formaldehyde – 2014 Yearly Average JK AS SHOWN Checked by: File Name: (Overview) DR 13400 15th Ave N B-4 Zodiac_Form Zodiac Aerospace Approved by: Date: Plymouth, MN 55441-4532 DR 2-20-2017 Newport, Washington Project Manager: Project No. CONTOUR PLOT (MODELING RESULTS) Exhibit DR MP157289C Drawn by: Scale: JK AS SHOWN Formaldehyde – 2014 Yearly Average (Local) Checked by: File Name: DR Zodiac_Form 13400 15th Ave N Zodiac Aerospace B-5 Approved by: Date: Plymouth, MN 55441-4532 Newport, Washington DR 2-20-2017 Project Manager: Project No. CONTOUR PLOT (MODELING RESULTS) Exhibit DR MP157289C Drawn by: Scale: JK AS SHOWN Formaldehyde – 2015 Yearly Average Checked by: File Name: DR Zodiac_Form 13400 15th Ave N Zodiac Aerospace B-6 Approved by: Date: Plymouth, MN 55441-4532 Newport, Washington DR 2-20-2017

APPENDIX F NOTICE OF CONSTRUCTION APPLICATION

POTENTIAL TO EMIT CALCULATIONS

Table 1: Potential to Emit Summary (Uncontrolled/Unlimited) Zodiac Aerospace Engineered Materials Newport, WA

Toxic Air Criteria Pollutants Greenhouse Gas Pollutants Hazardous Air Pollutants & Toxic Air Pollutants Pollutants

Control 1 1 Emission Unit PM PM10 PM2.5 SO2 NOX VOC CO CO2 CH4 NOx Formaldehyde Methanol MIBK Phenol Toluene Triethylamine Total HAPs Isopropanol Stack Vent (SV) Equipment Description CO2e (TPY) (EU) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (CE) EU001-EU002 Fugitive N/A Mixing Totes - 330 gallons 0.584 0.183 0.122 0.000 0.000 0.304 0.000 EU003 Fugitive N/A Mixing Vat - 550 gallons 0.110 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Fugitive N/A Mixing Barrels - 55 gallons 33.583 5.532 0.691 0.008 0.012 6.223 3.420 EU008 SV001 CE001 Powder Weighing 5.606 3.086 EU009 SV002 CE001 Powder Adding 5.606 3.086 EU010 SV003 CE002 Treater 638.709 93.907 81.468 0.000 271.157 0.000 0.000 365.064 54.312 EU011- EU015 SV004 N/A Winder Process 77.363 18.793 2.550 21.344 9.185 EU016 SV005/SV006 N/A Panel Press 10.515 0.367 0.053 0.421 EU017 Fugitive N/A Solvent Cleaning 10.950 0.548 0.329 0.876 EU018 SV007 CE003 Core Sawing 82.955 82.955 EU019 Fugitive N/A Cleaning Booth 1.818 1.818 EU020 SV008 CE004 Measuring Table 1.818 1.818 EU021 SV009 CE005 Thermwood Trimming 23.636 23.636 EU022 SV003 N/A Combustion - Thermal Oxidizer 0.117 0.034 0.152 0.251 2.178 0.168 1.257 2,094.262 0.034 0.151 2,140.034 Unlimited Total PTE 121.557 116.434 0.152 0.251 2.178 771.981 1.257 2,094.262 0.034 0.151 2,140.034 94.274 106.523 3.692 271.210 0.008 0.012 394.232 66.917 Table 2: Limited Potential to Emit Summary (Controlled/Limited) Zodiac Aerospace Engineered Materials Newport, WA

Toxic Air Criteria Pollutants Greenhouse Gas Pollutants Hazardous Air Pollutants & Toxic Air Pollutants Pollutants

Control 1 1 Emission Unit PM PM10 PM2.5 SO2 NOX VOC CO CO2 CH4 NOx Formaldehyde Methanol MIBK Phenol Toluene Triethylamine Total HAPs Isopropanol Stack Vent (SV) Equipment Description CO e (TPY) (EU) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) 2 (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (CE) EU001-EU002 Fugitive N/A Mixing Totes - 330 gallons 0.584 0.183 0.122 0.000 0.000 0.304 0.000 EU003 Fugitive N/A Mixing Vat - 550 gallons 0.110 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Fugitive N/A Mixing Barrels - 55 gallons 14.966 2.673 0.478 0.008 0.012 3.120 1.691 EU008 SV001 CE001 Powder Weighing 0.056 0.031 EU009 SV002 CE001 Powder Adding 0.056 0.031 EU010 SV003 CE002 Treater 6.387 0.068 0.815 0.286 2.712 0.000 0.000 3.651 0.543 EU011- EU015 SV004 N/A Winder Process 22.000 5.344 0.725 6.070 2.612 EU016 SV005/SV006 N/A Panel Press 5.338 0.040 0.040 0.080 EU017 Fugitive N/A Solvent Cleaning 10.950 0.548 0.329 0.876 EU018 SV007 CE003 Core Sawing 0.830 0.830 EU019 Fugitive N/A Cleaning Booth 0.018 0.018 EU020 SV008 CE004 Measuring Table 0.018 0.018 EU021 SV009 CE005 Thermwood Trimming 0.236 0.236 EU022 SV003 N/A Combustion - Thermal Oxidizer 0.117 0.034 0.152 0.251 2.178 0.168 1.257 2,094.3 0.034 0.151 2,140.0 Limited PTE (tons/year) 1.332 1.198 0.152 0.251 2.178 60.502 1.257 2,094.3 0.034 0.151 2,140.0 0.108 9.562 1.939 2.752 0.008 0.012 14.100 4.846 Limited PTE (lbs/year) 2,663 2,395 304 503 4,356 121,003 2,513 4,188,525 67 302 4,280,069 215 19,125 3,879 5,503 15 23 28,201 9,693

Proposed Emission Limits Criteria Pollutants <99 tons/year Individual HAPs <9.9 tons/year Total HAPs <24 tons/year Winder Room VOCs <22 tons/year

Proposed Panel Press Throughput Limits

Total Throughput Limit 525,000 plies/yr Limit for 1180 and 1112 Resins 350,000 plies/yr Limit for 6070 Resin and other similar resins 22,000 plies/yr

Proposed Formulations Throughput Limits Combined Resin Production Limit for AR1102, AR1114, AR1502, and AR1510 1,000,000 lbs/yr Combined Resin Production Limit for all other Resins Unlimited Table 3: Maximum Hourly and Daily Emissions (Controlled/Limited) Zodiac Aerospace Engineered Materials Newport, WA

Toxic Air Maximum Emissions (lbs/hour) Criteria Pollutants Greenhouse Gas Pollutants Hazardous Air Pollutants & Toxic Air Pollutants Pollutants Control Emission Unit PM PM PM SO NO VOC CO CO CH N O CO e Formaldehyde Methanol MIBK Phenol Toluene Triethylamine Total HAPs Isopropanol Stack Vent (SV) Equipment Description 10 2.5 2 X 2 4 2 2 (EU) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (lbs/hr) (CE) EU001-EU002 Fugitive N/A Mixing Totes - 330 gallons 0.133 0.042 0.028 0.000 0.000 0.069 0.000 EU003 Fugitive N/A Mixing Vat - 550 gallons 0.025 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Fugitive N/A Mixing Barrels - 55 gallons 7.667 1.263 0.158 0.002 0.003 1.421 0.781 EU008 SV001 CE001 Powder Weighing 0.013 0.007 EU009 SV002 CE001 Powder Adding 0.013 0.007 EU010 SV003 CE002 Treater 1.458 0.015 0.186 0.065 0.619 0.000 0.000 0.833 0.124 EU011- EU015 SV004 N/A Winder Process 17.663 4.291 0.582 4.873 2.097 EU016 SV005/SV006 N/A Panel Press 2.401 0.084 0.012 0.096 EU017 Fugitive N/A Solvent Cleaning 2.500 0.125 0.075 0.200 EU018 SV007 CE003 Core Sawing 0.189 0.189 EU019 Fugitive N/A Cleaning Booth 0.004 0.004 EU020 SV008 CE004 Measuring Table 0.004 0.004 EU021 SV009 CE005 Thermwood Trimming 0.054 0.054 EU022 SV003 N/A Combustion - Thermal Oxidizer 0.027 0.008 0.035 0.057 0.497 0.038 0.287 478.1 0.008 0.034 488.6 Total (lbs/hr) 0.304 0.273 0.035 0.057 0.497 31.886 0.287 478.1 0.008 0.034 488.6 0.099 5.906 0.908 0.631 0.002 0.003 7.493 3.002

Toxic Air Maximum Emissions (lbs/day) Criteria Pollutants Greenhouse Gas Pollutants Hazardous Air Pollutants & Toxic Air Pollutants Pollutants Control Emission Unit PM PM PM SO NO VOC CO CO CH N O CO e Formaldehyde Methanol MIBK Phenol Toluene Triethylamine Total HAPs Isopropanol Stack Vent (SV) Equipment Description 10 2.5 2 X 2 4 2 2 (EU) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (lbs/day) (CE) EU001-EU002 Fugitive N/A Mixing Totes - 330 gallons 3.200 1.000 0.667 1.667 EU003 Fugitive N/A Mixing Vat - 550 gallons 0.600 EU004-EU007 Fugitive N/A Mixing Barrels - 55 gallons 184.017 30.310 3.789 0.042 0.064 34.099 18.741 EU008 SV001 CE001 Powder Weighing 0.307 0.169 EU009 SV002 CE001 Powder Adding 0.307 0.169 EU010 SV003 CE002 Treater 34.998 0.371 4.464 1.565 14.858 20.004 2.976 EU011- EU015 SV004 N/A Winder Process 423.905 102.977 13.975 116.952 50.327 EU016 SV005/SV006 N/A Panel Press 57.616 2.012 0.293 2.305 EU017 Fugitive N/A Solvent Cleaning 60.000 3.000 1.800 4.800 EU018 SV007 CE003 Core Sawing 4.545 4.545 EU019 Fugitive N/A Cleaning Booth 0.100 0.100 EU020 SV008 CE004 Measuring Table 0.100 0.100 EU021 SV009 CE005 Thermwood Trimming 1.295 1.295 EU022 SV003 N/A Combustion - Thermal Oxidizer 0.643 0.184 0.832 1.377 11.934 0.918 6.885 11,475.410 0.184 0.826 11,726.216 Total (lbs/day) 7.297 6.562 0.832 1.377 11.934 765.253 6.885 11,475.4 0.184 0.826 11,726.2 2.383 141.751 21.796 15.151 0.042 0.064 179.827 72.044 Table 4: Formulations Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU001-EU007 Emission Units Descriptions: See Table Below Stack/Vent Designation No.: Fugitive- Indoors Control Equipment No.: N/A Hours of Operation: 8760 Max Number of Mixing Barrels (55gal): 4 Max Number of Mixing Vats: 1 Max Number of Mixing Tanks (330gal): 2

Batch Information for Mixing Tote Formulations1

Average Loss During Throughput Volatile Number of Batch Size Minimum Mix VOC PTE3 Formaldehyde4 MIBK5 Phenol4 Toluene5 Triethylamine5 Total HAPs Isopropanol5 EU Identification No. EU Description Product Formulation1,2 Rate Losses Methanol5 (TPY) Mixing Units (pounds) Time1 (minutes) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/batch) (lbs/hr) (lbs/hr)

EU001-EU002 Mixing Totes 2 AR1180 3,143 0.100 90 4,191 0.133 0.584 0.000 0.183 0.122 0.000 0.000 0.000 0.304 0.000

Batch Information for Mixing Vat Formulations1

Average Loss During Throughput Volatile Number of Batch Size Minimum Mix VOC PTE3 Formaldehyde4 MIBK5 Phenol4 Toluene5 Triethylamine5 Total HAPs Isopropanol5 EU Identification No. EU Description Product Formulation1,2 Rate Losses Methanol5 (TPY) Mixing Units (pounds) Time1 (minutes) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/batch) (lbs/hr) (lbs/hr)

EU003 Mixing Vat 1 AR1112 5000 0.100 240 1,250 0.025 0.110 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Batch Information for Mixing Barrels Formulations1

Average Loss During Throughput Volatile Number of Batch Size Minimum Mix VOC PTE3 Formaldehyde4 MIBK5 Phenol4 Toluene5 Triethylamine5 Total HAPs Isopropanol5 EU Identification No. EU Description Product Formulation1,2 Rate Losses Methanol5 (TPY) Mixing Units (pounds) Time1 (minutes) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/batch) (lbs/hr) (lbs/hr)

EU004-EU007 Mixing Barrels 4 AR1113 1320 0.620 120 2,640 1.240 5.431 0.000 0.794 0.212 0.000 0.000 0.000 1.006 0.529 EU004-EU007 Mixing Barrels 4 AR1102 420 5.920 300 336 4.736 20.744 0.000 5.532 0.691 0.000 0.000 0.000 6.223 2.766 EU004-EU007 Mixing Barrels 4 AR1114 420 5.720 300 336 4.576 20.043 0.000 4.104 0.684 0.000 0.000 0.000 4.788 3.420 EU004-EU007 Mixing Barrels 4 AR1502 820 6.070 190 1,036 7.667 33.583 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AR1510 440 7.780 280 377 6.669 29.208 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1507-NAT A 405 0.990 145 670 1.639 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1507-NAT B 365 0.236 145 604 0.391 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1507-WHT A 405 1.330 165 589 1.935 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1507-WHT B 365 0.263 165 531 0.383 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-NAT A 365 0.960 145 604 1.589 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-NAT B 365 1.170 145 604 1.937 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-WHT A 365 1.390 165 531 2.022 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-WHT B 365 1.150 165 531 1.673 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-FR A 405 1.350 215 452 1.507 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-FR B 365 0.738 215 407 0.824 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1518 A 405 0.500 35 2,777 3.429 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1518 B 405 1.580 35 2,777 10.834 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AF1504A 305 0.730 185 396 0.947 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AF1504B 210 0.190 105 480 0.434 1.902 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1600A 440 0.100 90 1,173 0.267 1.168 0.000 0.000 0.000 0.000 0.000 0.012 0.012 0.000 EU004-EU007 Mixing Barrels 4 AB1600B 210 0.100 90 560 0.267 1.168 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1801 210 0.100 90 560 0.267 1.168 0.000 0.635 0.000 0.000 0.008 0.000 0.642 0.000 EU004-EU007 Mixing Barrels 4 AR1180 210 0.100 90 560 0.267 1.168 0.000 0.365 0.243 0.000 0.000 0.000 0.608 0.000

Worst Case Batch PTE Maximum Number of VOC PTE Formaldehyde Methanol MIBK Phenol Toluene Triethylamine Total HAPs Isopropanol EU Identification No. EU Description Throughput Rate Mixing Units (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/hr) EU001-EU002 Mixing Tote Formulation 2 4,191 0.584 0.000 0.183 0.122 0.000 0.000 0.000 0.304 0.000 EU003 Mixing Vat Formulation 1 1,250 0.110 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels Formulations 4 2,777 33.583 0.000 5.532 0.691 0.000 0.008 0.012 6.223 3.420 Totals 8,218 34.28 0.000 5.714 0.813 0.000 0.008 0.012 6.527 3.420

1 Information involving the number of mixing units, maximum batch sizes, average losses during formulation, and minimum mix times was provided by Zodiac. 2 Losses are based on facilitiy measurements, however there are no measurable losses when mixing AR1180, AR1112, AB1600A, AB1600B, and AB1801. For these batches losses have been estimated to be 0.1 lbs/batch. If a batch only contains phenol, formaldehyde, and water, it is assumed that the only emissions are water. 3 For materials that contain VOCs, VOC losses are estimated to be equal to volatile losses as some VOCs are expected to volatilize faster than water. 4 Georgia Pacific has indicated that phenol and formaldehyde have low vapor pressures and are not expected to be emitted at room at room temperature. This was confirmed by the Winder room stack test. 5 Since phenol and formaldehyde are not expected to be emitted, the other HAPs/toxics emissions have been increased above their composition content to account for their relative percentage of the VOCs being emitted. Table 5: Formulations Limited Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU001-EU007 Emission Units Descriptions: See Table Below Stack/Vent Designation No.: Fugitive- Indoors Control Equipment No.: N/A Hours of Operation: 8760 Max Number of Mixing Barrels (55gal): 4 Max Number of Mixing Vats: 1 Max Number of Mixing Tanks (330gal): 2 Combined Resin Production Limit for AR1102, AR1114, AR1502, and AR1510: 1,000,000 lbs/yr

Limited PTE for Resins with Limits Annual Average Loss During Volatile Number of Batch Size Throughput VOC PTE3 Formaldehyde4 MIBK5 Phenol4 Toluene5 Triethylamine5 Total HAPs Isopropanol5 EU Identification No. EU Description Product Formulation1,2 Losses Methanol5 (TPY) Mixing Units (pounds) Average Loss Limit (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/batch) (lbs/yr) (lbs/lb) (lbs/yr) EU004-EU007 Mixing Barrels 4 AR1102 420 5.920 1.410E-02 14,095 7.048 0.000 1.879 0.235 0.000 0.000 0.000 2.114 0.940 EU004-EU007 Mixing Barrels 4 AR1114 420 5.720 1.362E-02 13,619 6.810 0.000 1.394 0.232 0.000 0.000 0.000 1.627 1.162 1,000,000 EU004-EU007 Mixing Barrels 4 AR1502 820 6.070 7.402E-03 7,402 3.701 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AR1510 440 7.780 1.768E-02 17,682 8.841 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Worst Case 8.841 0.000 1.879 0.235 0.000 0.000 0.000 2.114 1.162

Batch Information for Mixing Tote Formulations1

Average Loss During Minimum Mix Throughput Volatile Number of Batch Size VOC PTE3 Formaldehyde4 MIBK5 Phenol4 Toluene5 Triethylamine5 Total HAPs Isopropanol5 EU Identification No. EU Description Product Formulation1,2 Time1 Rate Losses Methanol5 (TPY) Mixing Units (pounds) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/batch) (minutes) (lbs/hr) (lbs/hr)

EU001-EU002 Mixing Totes 2 AR1180 3,143 0.100 90 4,191 0.133 0.584 0.000 0.183 0.122 0.000 0.000 0.000 0.304 0.000

Batch Information for Mixing Vat Formulations1

Average Loss During Minimum Mix Throughput Volatile Number of Batch Size VOC PTE3 Formaldehyde4 MIBK5 Phenol4 Toluene5 Triethylamine5 Total HAPs Isopropanol5 EU Identification No. EU Description Product Formulation1,2 Time1 Rate Losses Methanol5 (TPY) Mixing Units (pounds) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/batch) (minutes) (lbs/hr) (lbs/hr)

EU003 Mixing Vat 1 AR1112 4200 0.100 240 1,050 0.025 0.110 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Batch Information for Mixing Barrels Formulations1

Average Loss During Minimum Mix Throughput Volatile Number of Batch Size VOC PTE3 Formaldehyde4 MIBK5 Phenol4 Toluene5 Triethylamine5 Total HAPs Isopropanol5 EU Identification No. EU Description Product Formulation1,2 Time1 Rate Losses Methanol5 (TPY) Mixing Units (pounds) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/batch) (minutes) (lbs/hr) (lbs/hr)

EU004-EU007 Mixing Barrels 4 AR1113 1320 0.620 120 2,640 1.240 5.431 0.000 0.794 0.212 0.000 0.000 0.000 1.006 0.529 EU004-EU007 Mixing Barrels 4 AB1507-NAT A 405 0.990 145 670 1.639 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1507-NAT B 365 0.236 145 604 0.391 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1507-WHT A 405 1.330 165 589 1.935 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1507-WHT B 365 0.263 165 531 0.383 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-NAT A 365 0.960 145 604 1.589 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-NAT B 365 1.170 145 604 1.937 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-WHT A 365 1.390 165 531 2.022 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-WHT B 365 1.150 165 531 1.673 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-FR A 405 1.350 215 452 1.507 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1508-FR B 365 0.738 215 407 0.824 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1518 A 405 0.500 35 2,777 3.429 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1518 B 405 1.580 35 2,777 10.834 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AF1504A 305 0.730 185 396 0.947 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AF1504B 210 0.190 105 480 0.434 1.902 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1600A 210 0.100 90 560 0.267 1.168 0.000 0.000 0.000 0.000 0.000 0.012 0.012 0.000 EU004-EU007 Mixing Barrels 4 AB1600B 210 0.100 90 560 0.267 1.168 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels 4 AB1801 210 0.100 90 560 0.267 1.168 0.000 0.635 0.000 0.000 0.008 0.000 0.642 0.000 EU004-EU007 Mixing Barrels 4 AR1180 210 0.100 90 560 0.267 1.168 0.000 0.365 0.243 0.000 0.000 0.000 0.608 0.000

Limited PTE6 Maximum Number of VOC PTE Formaldehyde Methanol MIBK Phenol Toluene Triethylamine Total HAPs Isopropanol EU Identification No. EU Description Throughput Rate Mixing Units (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (lbs/hr) EU001-EU002 Mixing Tote Formulation 2 4,191 0.584 0.000 0.183 0.122 0.000 0.000 0.000 0.304 0.000 EU003 Mixing Vat Formulation 1 1,050 0.110 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU004-EU007 Mixing Barrels Formulations 4 2,777 14.272 0.000 2.673 0.478 0.000 0.008 0.012 3.120 1.691 Totals 8,018 14.966 0.000 2.856 0.600 0.000 0.008 0.012 3.424 1.691

1 Information involving the number of mixing units, maximum batch sizes, average losses during formulation, and minimum mix times was provided by Zodiac. 2 Losses are based on facilitiy measurements, however there are no measurable losses when mixing AR1180, AR1112, AB1600A, AB1600B, and AB1801. For these batches losses have been estimated to be 0.1 lbs/batch. If a batch only contains phenol, formaldehyde, and water, it is assumed that the only emissions are water. 3 For materials that contain VOCs, VOC losses are estimated to be equal to volatile losses as some VOCs are expected to volatilize faster than water. 4 Georgia Pacific has indicated that phenol and formaldehyde have low vapor pressures and are not expected to be emitted at room at room temperature. This was confirmed by the Winder room stack test. 5 Since phenol and formaldehyde are not expected to be emitted, the other HAPs/toxics emissions have been increased above their composition content to account for their relative percentage of the VOCs being emitted. 6 The Limited PTE is overestimated because the Limited emissions from the AR1102, AR1114, AR1502, and AR1510 resins is being added to the unlimited PTE for the other resins and the amount of time it will take to produce the limited resins has not been factored into the Unlimited PTE. Table 6: Powder Weighing Potential to Emit (Formulations) Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU008 Emission Unit Description: Powder Weighing Stack/Vent Designation No.: SV001 Control Equipment No.: CE001 Maximum Formulation Throughput1: 8,218 pounds/hour 71,988,011 pounds/year Maximum Powder Weighed2: 35% Maximum Powder Throughput: 25,195,804 lbs powder/year Baghouse Control Efficiency3: 99%

Powder Weighing PTE Maximum Powder Emission Controlled Controlled Throughput Factor4 Uncontrolled Uncontrolled PTE PTE PTE Pollutant (tons/year) (lbs/ton powder) PTE (lbs/year) (tons/year) (lbs/year) (tons/year) PM 12,597.9 0.0089 11,212.1 5.606 112.1 0.06

PM10 12,597.9 0.0049 6,173.0 3.086 61.7 0.03

1 The maximum formulation throughput is calculated in Table 3. 2 The amount of powder weighed and added is equal to 35% by weight of the resin mass. 3 To be conservative the calculations assume that all of the powder emissions are captured by the baghouse. In reality, some of the powder is not captured and settles on to the floor where it is swept up and disposed. 4 The AP-42 controlled emission factors are from Table 11.12-2 for cement supplement (pneumatic) unloading to a elevated storage silo. Table 7: Powder Adding (Formulations) Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU009 Emission Unit Description: Powder Adding Stack/Vent Designation No.: SV002 Control Equipment No.: CE001 Maximum Formulation Throughput1: 8,218 pounds/hour 71,988,011 pounds/year Maximum Powder Added2: 35% Maximum Powder Throughput: 25,195,804 lbs powder/year Baghouse Control Efficiency3: 99%

Powder Adding PTE Maximum Emission Powder Factor4 Uncontrolled Throughput (lbs/ton Uncontrolled PTE PTE Controlled PTE Controlled PTE Pollutant (tons/year) powder) (lbs/year) (tons/year) (lbs/year) (tons/year) PM 12,597.9 0.0089 11,212.1 5.61 112.1 0.06

PM10 12,597.9 0.0049 6,173.0 3.09 61.7 0.03

1 The maximum formulation throughput is calculated in Table 3. 2 The amount of powder weighed and added is equal to 35% by weight of the resin mass. 3 To be conservative the calculations assume that all of the powder emissions are captured by the baghouse. In reality, some of the powder is not captured and settles on to the floor where it is swept up and disposed. 4 The AP-42 controlled emission factors are from Table 11.12-2 for cement supplement (pneumatic) unloading to a elevated storage silo. Table 8: Treater Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU010 Emission Unit Description: Treater Process Stack/Vent Designation No.: SV003 Control Equipment No.: CE002 Control Equipment Capture Eff.: 100% Control Equipment Destruction Eff.: 99% Annual Hours of Operation: 8760

Resin, VOC, HAPs, and TAPs Applied1

Maximum Glass Product Resin Application Resin Resin Application Formaldehyde Phenol Toluene Triethylamine Total HAPs Isopropanol Width2 Rate2 Application Rate Solids Applied Volatiles Applied VOCs Applied Applied Methanol Applied MIBK Applied Applied Applied Applied Applied Applied Product ID (Resin ID/Fiberglass Part #) Resin ID (in.) (lbs/linear yard) (lbs/sq.ft) (lbs/hr) (lb/sq.ft.) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) (lb/sq.ft) APF1180/7781 AR1180 60.0 1.230 0.082 492.0 0.045 0.037 0.015 0.005 0.001 0.001 0.006 0.000 0.000 0.013 0.000 APF1180/6781 HT AR1180 60.0 1.290 0.086 516.0 0.047 0.039 0.015 0.005 0.001 0.001 0.006 0.000 0.000 0.013 0.000 APF1180/16781 AR1180 61.0 1.279 0.084 511.4 0.046 0.038 0.015 0.005 0.001 0.001 0.006 0.000 0.000 0.013 0.000 APF1180/220 AR1180 60.0 0.580 0.039 232.0 0.021 0.017 0.007 0.002 0.001 0.000 0.003 0.000 0.000 0.006 0.000 APF1180/1583 AR1180 56.0 1.630 0.116 652.0 0.064 0.052 0.021 0.007 0.002 0.001 0.008 0.000 0.000 0.018 0.000 APF1180/1568 AR1180 60.0 0.980 0.065 392.0 0.036 0.029 0.012 0.004 0.001 0.001 0.005 0.000 0.000 0.010 0.000 APF1112/7781 AR1112 60.0 0.820 0.055 328.0 0.030 0.025 0.002 0.001 0.000 0.000 0.006 0.000 0.000 0.007 0.000 APF1112/220 AR1112 60.0 0.480 0.032 192.0 0.018 0.014 0.001 0.001 0.000 0.000 0.004 0.000 0.000 0.004 0.000 APF1112/1583 AR1112 56.0 2.680 0.191 1072.0 0.105 0.086 0.007 0.004 0.000 0.000 0.021 0.000 0.000 0.025 0.000 APF1112/1568 AR1112 60.0 0.740 0.049 296.0 0.027 0.022 0.002 0.001 0.000 0.000 0.005 0.000 0.000 0.006 0.000 APF1112/6781 AR1112 60.0 1.317 0.088 526.6 0.048 0.039 0.003 0.002 0.000 0.000 0.010 0.000 0.000 0.011 0.000 APF1112/16781 AR1112 61.0 1.279 0.084 511.4 0.046 0.038 0.003 0.002 0.000 0.000 0.009 0.000 0.000 0.011 0.000 APF1113/0.65 AR1113 60.0 0.620 0.041 248.0 0.010 0.031 0.024 0.000 0.003 0.001 0.003 0.000 0.000 0.007 0.002

Max Product Formaldehyde Methanol Triethylamine Total HAPs Isopropanol Line Speed3 Throughput VOC PTE4 PTE PTE MIBK PTE Phenol PTE5 Toluene PTE PTE PTE4,5,6 PTE Product ID (Resin ID/Fiberglass Part #) Resin ID (ft/min) (sq.ft/hr) (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) APF1180/7781 AR1180 20.0 6,000 383.583 69.379 32.324 21.550 79.195 0.000 0.000 202.448 0.000 APF1180/6781 HT AR1180 20.0 6,000 402.294 72.764 33.901 22.601 83.058 0.000 0.000 212.323 0.000 APF1180/16781 AR1180 20.0 6,100 398.739 72.121 33.602 22.401 82.324 0.000 0.000 210.447 0.000 APF1180/220 AR1180 20.0 6,000 180.876 32.715 15.242 10.162 37.344 0.000 0.000 95.463 0.000 APF1180/1583 AR1180 20.0 5,600 508.325 91.942 42.836 28.558 104.949 0.000 0.000 268.285 0.000 APF1180/1568 AR1180 20.0 6,000 305.619 55.278 25.754 17.170 63.098 0.000 0.000 161.300 0.000 APF1112/7781 AR1112 20.0 6,000 51.719 28.733 0.000 0.000 82.966 0.000 0.000 111.699 0.000 APF1112/220 AR1112 20.0 6,000 30.275 16.819 0.000 0.000 48.565 0.000 0.000 65.385 0.000 APF1112/1583 AR1112 20.0 5,600 169.033 93.907 0.000 0.000 271.157 0.000 0.000 365.064 0.000 APF1112/1568 AR1112 20.0 6,000 46.673 25.930 0.000 0.000 74.872 0.000 0.000 100.801 0.000 APF1112/6781 AR1112 20.0 6,000 83.041 46.134 0.000 0.000 133.211 0.000 0.000 179.345 0.000 APF1112/16781 AR1112 20.0 6,100 80.644 44.802 0.000 0.000 129.366 0.000 0.000 174.168 0.000 APF1113/0.65 AR1113 20.0 6,000 638.709 2.914 81.468 21.725 39.919 0.000 0.000 146.026 54.312 Worst Case PTE 638.709 93.907 81.468 28.558 271.157 0.000 0.000 365.064 54.312 Controlled PTE6 6.387 0.068 0.815 0.286 2.712 0.000 0.000 3.651 0.543

1 Application rates calculated using calculated resin application rates and composition data\. 2 Inofmation provided by Zodiac Table 9: Phenol Polymerization in Treater Resins Zodiac Aerospace Engineered Materials Newport, WA

Georgia Pacific Resin Analysis1

Free Phenol in Emitted in Free Phenol on Phenol Resin Resin Oven Dried Prepreg Polymerized AR1112 8.7% 3.4% 0.4% 4.9% AR1180 4.0% 2.1% 0.4% 1.5%

Destination of Phenol in Resins Remaining Resin Emitted in Oven on Prepreg Polymerized AR1112 39.1% 4.6% 56.3% AR1180 52.5% 10.0% 37.5% Other Resins2 52.5% 10.0% 37.5%

Georgia Pacific Resin Analysis - Formaldehyde1

Free Free Formaldehyde Emitted in Formaldehyde on Resin in Resin Oven Dried Prepreg AR1112 1.4% 1.4% 0.0% AR1180 4.1% 2.2% 1.9%

Destination of Formaldehyde in Resins Remaining Resin Emitted in Oven on Prepreg AR1112 100.0% 0.0% AR1180 53.7% 46.3% Other Resins2 53.7% 46.3%

1 Reported as a percentage of original liquid resin. 2 Other Treater resins will use the the results from tested resin that shows the highest amount of phenol or formaldehyde remaining on on the prepreg. Table 10: Winder Room Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU011-EU015 Emission Unit Description: Winder Process Stack/Vent Designation No.: SV004 Control Equipment No.: N/A Hours of Operation: 8760 No. of Winders 5

VOCs, HAPS, and TAPs Applied

Fiber Core + Dried Fiber Core Dried Resin Resin-Specific Total Resin Fiber Core + Volatiles Formaldehyde Methanol Total HAPs Isopropanol Resin Weight1 Weight1 (Solids) Weight Solids Content Applied Applied Resin Applied VOCs Applied Applied2 Applied MIBK Applied Phenol Applied2 Applied Applied Product ID (Resin ID/Fiberglass Part #) Resin ID (g/m^2) (g/m^2) (g/m^2) (%) (g/m^2) (g/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lbs/m^2) (lb/m^2) (lb/m^2) (lb/m^2) APG 1102/12K AR1102 219.0 140.0 79.0 50% 158.0 298.0 0.174 0.104 0.002 0.028 0.003 0.031 0.064 0.014 APG 1114/12K AR1114 219.0 140.0 79.0 50% 158.0 298.0 0.174 0.102 0.002 0.021 0.003 0.024 0.051 0.017 APG 1114/12K-300 AR1114 305.0 202.0 103.0 50% 206.0 408.0 0.227 0.133 0.002 0.027 0.005 0.032 0.066 0.023 AEG 1502/12K AR1502 252.0 150.0 102.0 50% 204.0 354.0 0.225 0.024 0.000 0.000 0.000 0.000 0.000 0.000 AEG 1510/12K AR1510 330.0 208.0 122.0 60% 203.3 411.3 0.179 0.001 0.000 0.000 0.000 0.000 0.000 0.000 AEF 1510/750 AR1510 480.0 290.0 190.0 60% 316.7 606.7 0.279 0.001 0.000 0.000 0.000 0.000 0.000 0.000 AEG1510/18K AR1510 173.0 103.0 70.0 60% 116.7 219.7 0.103 0.000 0.000 0.000 0.000 0.000 0.000 0.000

PTE From Resin Usage2

Max Production Max Production Rate for All VOC MIBK Total HAPs Rate Per Winder1 Number of Winders PTE3 Methanol PTE3 PTE3 PTE2,3,4 Isopropanol PTE3 Product ID (Resin ID/Fiberglass Part #) Resin ID (m^2/hr) Winders (m^2/hr) (TPY) (TPY) (TPY) (TPY) (TPY) APG 1102/12K AR1102 30.1 5 150.5 68.89 18.37 2.30 20.67 9.18 APG 1114/12K AR1114 22.7 5 113.5 50.74 10.39 1.73 12.12 8.66 APG 1114/12K-300 AR1114 11.9 5 59.5 34.68 7.10 1.18 8.29 5.92 AEG 1502/12K AR1502 26.0 5 130.0 13.73 0.00 0.00 0.00 0.00 AEG 1510/12K AR1510 19.4 5 97.0 0.36 0.00 0.00 0.00 0.00 AEF 1510/750 AR1510 14.0 5 70.0 0.41 0.00 0.00 0.00 0.00 AEG1510/18K AR1510 35.7 5 178.5 0.38 0.00 0.00 0.00 0.00 Worst Case 68.89 18.37 2.30 20.67 9.18

PTE From Thinner Added

Max Production Thinner Addition Rate for All Total Resin Applied Rate1,4 (% by Thinner Added Winders VOC PTE Methanol PTE MIBK PTE Total HAPs PTE Product ID (Resin ID/Fiberglass Part #) Resin ID (g/m^2) weight) (g/m^2) (m^2/hr) (TPY) (TPY) (TPY) (TPY) APG 1102/12K AR1102 158.0 2.80% 4.424 150.5 6.423 0.321 0.193 0.514 APG 1114/12K AR1114 158.0 4.90% 7.742 113.5 8.477 0.424 0.254 0.678 APG 1114/12K-300 AR1114 206.0 4.90% 10.094 59.5 5.794 0.290 0.174 0.464 Worst Case 8.477 0.424 0.254 0.678

PTE Summary PTE Limited PTE5 Pollutant (tons/year) (tons/year) VOCs 77.363 22.0 Methanol 18.793 5.34 MIBK 2.550 0.73 Total HAPs 21.344 6.07 IPA 9.185 2.61

1 Information provided by Zodiac. 2 Georgia Pacific has indicated that the phenol and formaldehyde will not be released in the winder process based on operating temperatures. Previous stack testing supports this conclusion. 3 Georgia Pacific has indicated that all other VOCs in the resins should be emitted in the Winder Room. Although small amounts of other VOCs may remain on the prepreg, they are included in the Winder calculations to be conservative. 4 Acetone is added to the AR1502 and AR1510 resins, Tarsol added to AR1102 and AR1114 resins 5 Zodiac is proposing to take a limit of 22 tons/year on VOC emissions from the Winder Process calculated on a 12-month rolling basis. Limited HAP emissions have been ratioed to the 22 ton/year limit based on the PTE calculations. Table 11: Phenol Polymerization in Winder Resins Zodiac Aerospace Engineered Materials Newport, WA Note: Since no polymerization is expected in the Winder room and stack testing was performed on the Panel Press, the GP testing that was performed on Winder Resin Sample the Winder prepreg materials is not used in the calculations. Free Phenol Free Phenol Resin Sample Description Free Phenol Analysis #11 Analysis #22 Analysis #33 AR1114 Fresh4 2.7% 2.9% 8.5% AR1114 4 days old5 1.1% 1.2% 9.2% 1 Analysis #1 involved measuring the free phenol content from fresh and 4 day old prepreg samples provided by Zodiac. The weight percent listed includes the weight of the prepreg. 2 Analysis #2 involved measuring the free phenol content from fresh and 4 day old prepreg samples generated by Georgia-Pacific. The weight percent listed includes the weight of the prepreg. 3 Analysis #3 involved measuring the free phenol content in the liquid resin. The weight percent listed only represents the weight percent in the resin. 4 Fresh samples provided by Zodiac are taken after the prepreg is removed from the drum. Fresh samples created at Georgia-Pacific are subject to being placed in front of a fan on low speed for 10 minutes to simulate the rotating drum in the Winder room. 5 4 day old samples are Fresh samples that have sat for 4 days to duplicate the prepreg waiting period prior to being processed in the Panel Press.

Note: The results from Free Phenol Analysis #3 have been discounted as resin was not placed on prepreg or thin spread and all of the solvent does not appear to have evaporated. Further analysis only includes the results from the first two analyses. Test results can be found in Appendix ?

Winder Resin Polymerization/Evaporation Phenol Phenol Percentage Average Free Average Free Phenol Phenol Percentage Polymerized/ Phenol Content in Content in 4 Day Old Percentage on on 4 Day Old Evaporated in Resin Fresh Sample Sample Prepreg Prepreg 4 days AR1114 2.80% 1.2% 100% 41.1% 58.9% Table 12: Unlimited Panel Press Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU016 Emission Unit Description: Panel Press Stack/Vent Designation No.: SV005 Control Equipment No.: N/A Minimum Time Per Cycle (hr): 1 Panels Pressed Per Cycle1: 10

Preliminary Stack Test Results1 Formaldehyde Ethanol Emission Prepreg Resin Average Flow Rate Plies per sheet Emissions Rate Phenol Emissions Rate Rate Stack Test Run Material (ACFM) Start Time End Time Total Time (hr) during test (lb/hr) (lb/hr) (lb/hr) 1 AR1113 18:05 19:10 1.08 1 0.000 0.000 0.094 2 AR1113(2) 14:11 16:12 2.02 1 0.000 0.000 0.059 3 AR1180 19:40 20:50 1.17 2 0.003 0.000 0.225 5,348 4 AR1112 7:51 9:00 1.15 4 0.005 0.000 0.543 5 Cycom 6070 9:08 10:22 1.23 4 0.056 0.000 1.536 6 AR1114 10:30 11:40 1.17 4 0.000 0.006 0.236

Emission Factor Based on Test Data

Maximum Maximum Maximum Maximum Formaldehyde Phenol Emission Ethanol Emission Formaldehyde Phenol Maximum Ethanol Formaldehyde Maximum Phenol Ethanol Emission Emission Factor Factor Factor Maximum Emissions Rate Emissions Rate Emission Rate Emissions Rate Emissions Rate Rate Tested Prepreg Resin Material2 (lb/ply) (lb/ply) (lb/ply) Plies per hour (lb/hr) (lb/hr) (lb/hr) (tons/year) (tons/year) (tons/year) AR1113 0.00E+00 0.00E+00 9.38E-03 60 0.000 0.000 0.563 0.000 0.000 2.465 AR1113 (Test #2) 0.00E+00 0.00E+00 5.89E-03 60 0.000 0.000 0.353 0.000 0.000 1.548 AR1180 1.40E-04 0.00E+00 1.13E-02 60 0.008 0.000 0.676 0.037 0.000 2.959 AR1112 1.25E-04 0.00E+00 1.36E-02 60 0.008 0.000 0.814 0.033 0.000 3.564 Cycom 6070 1.40E-03 0.00E+00 3.84E-02 60 0.084 0.000 2.305 0.367 0.000 10.094 AR1114 0.00E+00 1.53E-04 5.91E-03 80 0.000 0.012 0.473 0.000 0.053 2.070

PTE Summary PTE Pollutant (tons/year) VOCs 10.515 Formaldehyde 0.367 Phenol 0.053 Ethanol 10.094 Total HAPs 0.421

1 Preliminary stack test results from panel press testing from January 2017. 2 The VOC emission factor for AR1112 is also used for AR1510 and AR1502 since the AR1112 has the highest VOC content of the three resins. Table 13: Panel Press Limited Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU016 Emission Unit Description: Panel Press Stack/Vent Designation No.: SV005 Control Equipment No.: N/A Total limit of prepregs using resin 1113, 1114, 1502, and 1510 and other prepregs that do not include formaldehyde on the SDS1 525,000 plies Limit of prepregs using resin 1180 and 11121 350,000 plies Limit of prepregs using resin 6070 and all other similar prepregs1 22,000 plies

Limited PTE Calculation Maximum Maximum Formaldehyde Phenol Emission Ethanol Emission Formaldehyde Phenol Maximum Ethanol Emission Factor2 Factor2 Factor2 Maximum Emissions Rate Emissions Rate Emission Rate Prepreg Resin Material (lb/ply) (lb/ply) (lb/ply) Plies per year (lb/yr) (lb/yr) (lb/yr) AR11133 0.00E+00 0.00E+00 9.38E-03 AR1114 0.00E+00 1.53E-04 5.91E-03 525,000 0.00 80.06 4,923.98 AR1180 1.40E-04 0.00E+00 1.13E-02 AR1112 1.25E-04 0.00E+00 1.36E-02 350,000 49.00 0.00 4,746.88 Cycom 6070 and all others containing formaldehyde 1.40E-03 0.00E+00 3.84E-02 22,000 30.75 0.00 845.02

Limited PTE Summary Limited PTE Limited PTE Pollutant (lbs/year) (tons/year) VOCs 10,675.68 5.338 Formaldehyde 79.75 0.040 Phenol 80.06 0.040 Ethanol 10,515.87 5.258 Total HAPs 159.81 0.080

1 Zodiac is proposing a maximum limit on total plies processed by the panel press of 525,000 of which no more than 350,000 plies can be from prepregs using the AR1180 or AR1112 resins and no more than 22,000 plies can come from prepreg materials using the Cycom 6070 resin or any other purchased prepreg containing formaldehyde. 2 Emission Factors are from the Unlimited Panel Press emission calculations 3 The stack test ran two runs on the AR1113 resin and the first test run had the highest emission rate for ethanol from the AR1113 resin Table 14: Solvent Cleaning Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU017 Emission Unit Description: Solvent Cleaning Stack/Vent Designation No.: Fugitive-Indoors Control Equipment No.: N/A

VOC Solvent Usage Rate1: 50.00 pounds/day Safety Factor: 2 Maximum Solvent Usage: 100.00 pounds/day Solvent shipped as waste2: 40%

VOC emission rate: 60.000 pounds/day VOC PTE/Proposed Limit3 10.950 tons/year Non-VOC Solvent Usage Limit3 Unlimited tons/year

Cleaning Solvent Composition Non-VOC Based VOC Based Solvent Solvent Pollutant (%) (%) VOCs 100% 0% Methanol 5% 0% MIBK 3% 0% Total HAPS 8% 0%

Solvent Cleaning PTE Summary Emission Rate PTE Pollutant (lbs/hr) (tons/yr) VOC 2.50 10.950 Methanol 0.13 0.548 MIBK 0.08 0.329 Total HAPs 0.20 0.876

1 Zodiac primarily uses acetone for cleaning, however solvent containing VOCs is used for limited cleaning. The solvent usage rate has been estimated based on usage records.

2 Zodiac used just over 16,000 lbs of solvent for cleaning in 2014 of which approximately 9,000 lbs was shipped as waste (~8,000 lbs as liquid and ~1,000 lbs on cleaning rags). This calculates to approximately 55% of solvent used for cleaning is shipped as waste. For the PTE calculations, Zodiac is assuming that 40% of the alcohol is shipped as waste. 3 Zodiac is proposing a limit of 10.95 tons of VOC based solvent usage for cleaning with the maximum composition above to be calculated by purchased minus waste solvent shipments. Zodiac is also proposing to use a non-VOC based solvent which will not be limited. Table 15: Core Saw Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU018 Emission Unit Description: Core Saw Stack/Vent Designation No.: SV006 Control Equipment No.: CE003

Drums of Particulate Waste Collected: 182.5 drums Time Period: 1 year Weight of Waste Per Drum: 300 pounds/drum Filter Efficiency: 99% 2 Safety Factor : 3

Core Saw PTE Summary Uncontrolled Uncontrolled Controlled Controlled Emission Rate PTE Emission Rate PTE Pollutant (lbs/hr) (tons/year) (lbs/hr) (tons/year) PM 18.94 82.95 0.189 0.830

PM10 18.94 82.95 0.189 0.830

1 Since the waste collection amount was based on actual waste collection records, a safety factor of 3 was applied to the usage rate. Table 16: Cleaning Booth Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU019 Emission Unit Description: Cleaning Booth Stack/Vent Designation No.: Fugitive-Indoors Control Equipment No.: N/A

Cleaning Booth PTE Summary1

Uncontrolled Uncontrolled Controlled Controlled Emission Rate PTE Emission Rate PTE Pollutant (lb/hr) (tons/yr) (lbs/yr) (tons/yr) PM 0.42 1.82 0.004 0.018

PM10 0.42 1.82 0.004 0.018

1Cleaning booth emissions are assumed to be equal to emissions from the measuring table. Table 17: Measuring Table Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU020 Emission Unit Description: Measuring Table Stack/Vent Designation No.: SV007 Control Equipment No.: CE004

Drums of Particulate Waste Collected: 4 drums Time Period: 1 year Weight of Waste Per Drum: 300 pounds/drum Filter Efficiency: 99% 2 Safety Factor : 3

Core Saw PTE Summary Uncontrolled Uncontrolled Controlled Controlled Emission Rate PTE Emission Rate PTE Pollutant (lbs/hr) (tons/year) (lbs/hr) (tons/year) PM 0.42 1.82 0.004 0.018

PM10 0.42 1.82 0.004 0.018

1 Since the waste collection amount was based on actual waste collection records, a safety factor of 3 was applied to the usage rate. Table 18: Thermwood Trimming Potential to Emit Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU021 Emission Unit Description: Thermwood Trimming Stack/Vent Designation No.: SV009 Control Equipment No.: CE005

Drums of Particulate Waste Collected: 52 drums Time Period: 1 year Weight of Waste Per Drum: 300 pounds/drum Filter Efficiency: 99% 2 Safety Factor : 3

Core Saw PTE Summary Uncontrolled Emission Uncontrolled Controlled Controlled Rate PTE Emission Rate PTE Pollutant (lbs/hr) (tons/year) (lbs/hr) (tons/year) PM 5.40 23.64 0.054 0.236

PM10 5.40 23.64 0.054 0.236

1 Since the waste collection amount was based on actual waste collection records, a safety factor of 3 was applied to the usage rate. Table 19: RTO Burner Combustion Zodiac Aerospace Engineered Materials Newport, WA

Emission Unit Identification No.: EU022 Stack/Vent Designation No.: SV008 Control Equipment No.: N/A Emission Unit Description: Thermal Oxidizer

Fuel Parameters% Sulfur Maximum Rated Maximum Fuel Maximum Fuel Fuel Type (gr/100ft³) % Ash Heat Value1 Boiler Capacity Consumption Rate Consumption Rate Propane 15 negligible 91,500 Btu/gal 3,500,000 Btu/hr 38 gal/hr 335,082 gal/yr

Propane Gas Criteria Pollutants Potential to Emit

Pollutant Emission Factor Emissions Factor Source Propane Usage Rate Emission Rate PTE PM 0.0007 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.027 lbs/hr 0.12 TPY

PM10 0.0002 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.008 lbs/hr 0.03 TPY

PM2.5 0.000906 lb/gal Sum of PM2.5 Fil and PM-Con 38.25 gal/hr 0.035 lbs/hr 0.15 TPY

SO2 0.0015 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.057 lbs/hr 0.25 TPY

NOx 0.013 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.497 lbs/hr 2.18 TPY VOC 0.0 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.038 lbs/hr 0.17 TPY CO 0.0075 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.287 lbs/hr 1.26 TPY

Propane Gas Greenhouse Gas Potential to Emit

CO2e Emission 2 Pollutant Emission Factor Emissions Factor Source Propane Usage Rate Emission Rate PTE Multiplier Rate CO 2e PTE

CO2 13 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 478.1 lbs/hr 2,094.3 TPY 1 478.1 lb/hr 2,094.3 TPY

CH4 0.0002 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.0 lbs/hr 0.034 TPY 25 0.2 lb/hr 0.8 TPY

N2O 0.0009 lb/gal AP-42 Table 1.5-1 38.25 gal/hr 0.0 lbs/hr 0.151 TPY 298 10.3 lb/hr 44.9 TPY

Total CO2e 488.6 lb/hr 2,140.0 TPY

1 Propane heat value is from AP-42 Section 1.5.1 (July 1998) 2 40 CFR 98 Subpart A Table A-1 Table 20: Product MSDS & Composition Information Zodiac Aerospace Engineered Materials Newport, WA

HAP Composition, Max % TAP Composition, Max % Max Use Epichlorohydrin Formaldehyde Methanol MIBK Phenol CAS#108- Toluene Triethylamine Total HAPs Isopropanol Silica CAS#7631- Resin ID Where Used (gallons) Density (lb/gal) Volatile % VOC% Solids % CAS#106-89-8 CAS#50-00-0 CAS#67-56-1 CAS#108-10-1 95-2 CAS#108-88-3 CAS#121-44-8 % CAS#67-63-0 86-9 AR1180 Treater 7.5 45% 17.8% 55% 6% 1.5% 1% 7% 15.5% AR1113 Treater 8.75 75% 58.8% 25% 0.5% 7.5% 2% 7% 17.0% 5% AR1112 Treater 10 45% 3.6% 55% 2% 11% 13.0% AR1510 Winders 9.55 40% 0.19% 60% 0.0% AR1502 Winders 9 50% 5.36% 50% 0.0% AR1114 Winders 9 50% 36.8% 50% 0.5% 6% 1% 7% 14.5% 5% AR1102 Winders 8.85 50% 39.5% 50% 0.5% 8% 1% 9% 18.5% 4% AR1400A External Sales 11.15 10% 0% 0.0% AB1507-FR External Sales 9.65 1% 0% 0.0% AB1508-FR External Sales 9.65 1% 0% 0.0% AB1507-NAT External Sales 9.65 1% 0% 0.0% AB1508-NAT External Sales 9.65 1% 0% 0.0% AB1507-WHT External Sales 9.65 1% 0% 0.0% AB1508-WHT External Sales 9.65 1% 0% 0.0% AB1507B External Sales 8.65 5% 0% 0.0% 5% AB1508B External Sales 8.65 5% 0% 0.0% 8% AB1518 External Sales 9.7 1% 0% 0.0% AB1600A External Sales 8.5 70% 2% 2% 2.0% AB1600B External Sales 8.9 1% 0.5% 0.0% AB1801 External Sales 9.1 50% 4.6% 2.5% 3% 5.5% AF1504A External Sales 6.5 100% 0% 0% 0.0% AF1504B External Sales 10.8 100% 100% 0% 0.0% DEN439 Formulations 10.18 0% 0.0% EPON 828 Formulations 9.72 0% 0% 100% 0.0001% 0.0% EPON 160 Formulations 10.008 0% 0.0% EPON 58005 Formulations 8.9238 0% 0.0% EPON 813 Formulations 9.5076 0% 0.0% EPON 1163 Formulations 15.44 0% 0% 100% 0.0% Phenolic AR1102/1113/1114 Formulations 9.174 30% 30% 0.5% 15% 20% 35.5% ANACAMINE TETA Formulations 6.841 0% 0.0% ANACAMINE 1922A Formulations 8.428 0% 0.0% ANACAMIDE 2482 Formulations 8.095 0% 0.0% ANACAMIDE 350A Formulations 8.095 0% 0.0% AMICURE UR2T Formulations 0% 0% 100% 0.0% Phenolic AR1180 Formulations 10.258 26% 26% 6% 8% 14.0% Phenolic AR1112 Formulations 10.008 34% 34% 2% 13% 15.0% CAB-O-SIL Formulations 18.348 0% 0% 100% 0.0% Tarsol A1-200 Entire Facility 6.610 100% 100% 0% 5% 3% 8.0% BUTVAR B-98 Formulations 3.922 0% 2.8% 100% 0.0%

Purchased Prepreg Formaldehyde Methanol Phenol Resin ID Where Used VOC% CAS#50-00-0 CAS#67-56-1 CAS#108-95-2 CYCOM6070/7781 Panel Press 37% 20% 7% 10% L-501/7781 Panel Press 0% L-802 B Panel Press 13% 3% 1% 4% L591 Panel Press 11% 0.54% 3% 4% L530 Panel Press 5% L201 Panel Press 5% AX2114HR Panel Press 1% AX2115 Panel Press 1% Cycom 2400 Panel Press 8% 1% 6%

APPENDIX G NOTICE OF CONSTRUCTION APPLICATION

2016 ACTUAL EMISSION CALCULATIONS

Table 1: 2016 Actual Emissions Summary Zodiac Aerospace Newport, WA

Toxic Air Criteria Pollutants Greenhouse Gas Pollutants Hazardous Air Pollutants & Toxic Air Pollutants Pollutant Only Control Emission Unit Stack Vent Equipment PM PM10 PM2.5 SO2 NOX VOC CO CO2 CH4 NOx CO2e Formaldehyde1 Methanol MIBK Phenol1 Toluene Triethylamine Total HAPs Isopropanol (EU) (SV) (CE) Description (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) EU001-EU007 Fugitive N/A Formulations Mixing Units 0.000 0.000 0.000 0.000 0.000 1.478 0.000 0.000 0.000 0.000 0.000 0.000 0.066 0.000 0.000 0.000 0.000 0.138 0.033 EU008 SV001 CE001 Powder Weighing 0.001 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU009 SV002 CE001 Powder Adding 0.001 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU010 SV003 CE002 Treater 0.000 0.000 0.000 0.000 0.000 0.035 0.000 0.000 0.000 0.000 0.000 0.001 0.000 0.000 0.015 0.000 0.000 0.031 0.000 EU011- EU015 SV004 N/A Winder Room 0.000 0.000 0.000 0.000 0.000 14.055 0.000 0.000 0.000 0.000 0.000 0.000 2.819 0.050 0.000 0.000 0.000 2.869 1.327 EU016 SV005/SV006 N/A Panel Press 0.000 0.000 0.000 0.000 0.000 1.699 0.000 0.000 0.000 0.000 0.000 0.019 0.000 0.000 0.000 0.000 0.000 0.019 0.000 EU017 Fugitive N/A Solvent Cleaning 0.000 0.000 0.000 0.000 0.000 2.090 0.000 0.000 0.000 0.000 0.000 0.000 0.209 0.063 0.000 0.000 0.000 0.272 0.000 EU018 SV007 CE003 Core Sawing 0.346 0.346 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU020 SV008 CE004 Measuring Table 0.010 0.010 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU021 SV009 CE005 Thermwood Trimming 0.035 0.035 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EU022 SV003 N/A Combustion - Thermal Oxidizer 0.030 0.009 0.039 0.065 0.566 0.044 0.326 544.163 0.009 0.039 556.056 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Sum of Emission Units: 0.423 0.400 0.039 0.065 0.566 19.400 0.326 544.163 0.009 0.039 556.056 0.021 3.094 0.112 0.015 0.000 0.000 3.329 1.360

Note: EU019 was for the Cleaning Booth which has been removed Table 2: Formulations Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU001-EU007 Emission Units Descriptions: Mixing Vat, Totes (2), and Barrels (4) Stack/Vent Designation No.: Fugitive- Indoors

Formulations Actual Emisions Average Loss During Average Loss During 2016 Formaldehyde Methanol Phenol Toluene Total HAP Isopropanol Average Batch Formulation2,3 Formulation Per Batch Production 2 Total Volatile Losses VOC Emissions Emisisons Emissions Emissions Emissions Triethylamine Emissions Emissions Product1 Size2 (lbs) (lbs/batch) (lbs losses/lb) (lb/yr) (lbs/year) (TPY) (TPY) (TPY) (TPY) (TPY) Emissions (TPY) (TPY) (TPY) AR1112 4,200.0 0.100 2.381E-05 457,914.3 10.9 0.0055 0.000 0.000 0.000 0.000 0.000 0.001 0.000 AR1113 1,320.0 0.620 4.697E-04 412.0 0.2 0.0001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AR1102 420.0 5.920 1.410E-02 2,297.0 32.4 0.0162 0.000 0.003 0.000 0.000 0.000 0.005 0.001 AR1114 420.0 5.720 1.362E-02 46,217.0 629.4 0.3147 0.000 0.063 0.000 0.000 0.000 0.128 0.031 AR1502 820.0 6.070 7.402E-03 4,103.0 30.4 0.0152 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AR1510 440.0 7.780 1.768E-02 125,671.0 2,222.1 1.1110 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AR1400-1A 220.0 0.100 4.545E-04 160.0 0.1 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1507/1508-NAT A 405.0 0.990 2.444E-03 106,515.0 260.4 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1507B 365.0 0.236 6.466E-04 8,045.0 5.2 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1507/1508-WHT A 405.0 1.330 3.284E-03 63,585.0 208.8 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1508B 365.0 1.170 3.205E-03 44,530.0 142.7 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1507/1508-FR A 405.0 1.350 3.333E-03 31,295.0 104.3 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1518 A 405.0 0.500 1.235E-03 810.0 1.0 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AF1504A 305.0 0.730 2.393E-03 15,860.0 38.0 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AF1504B 210.0 0.190 9.048E-04 5,540.0 5.0 0.0025 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1600A 210.0 0.100 4.762E-04 6,280.0 3.0 0.0000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1600B 210.0 0.100 4.762E-04 235.5 0.1 0.0001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AB1801 210.0 0.100 4.762E-04 9,320.0 4.4 0.0022 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AR1180 3,143.0 0.100 3.182E-05 689,460.7 21.9 0.0110 0.000 0.000 0.000 0.000 0.000 0.003 0.000 Sum of Emissions: 1.478 0.000 0.066 0.000 0.000 0.000 0.138 0.033

1 AB1600A, AB1600B, and AB1801 are products that are not listed because they do not have any losses and are not used in production. 2 Information provided by Zodiac. 3 Losses are based on facilitiy measurements, however there are no measurable losses when mixing AR1180, AR1112, AB1600A, AB1600B, and AB1801. For these batches losses have been estimated to be 0.1 lbs/batch. If a batch only contains phenol, formaldehyde, and water, it is assumed that the only emissions are water. Table 3: NSPS VVV Compliance Calculation Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU001-EU007 Emission Units Descriptions: Mixing Vat, Totes (2), and Barrels (4) Stack/Vent Designation No.: Fugitive- Indoors

Formulation VOC Usage

2016 Production2 VOCs in Formulated Resins VOCs in Formulated Resins Product1 (lb/yr) (lbs/year) (Mg/year) AR1112 457,914.3 62,230.6 28.2 AR1113 412.0 253.8 0.1 AR1102 2,297.0 956.7 0.4 AR1114 46,217.0 21,070.3 9.6 AR1502 4,103.0 219.9 0.1 AR1510 125,671.0 238.8 0.1 AR1400-1A 160.0 0.0 0.0 AB1507/1508-NAT A 106,515.0 0.0 0.0 AB1507B 8,045.0 0.0 0.0 AB1507/1508-WHT A 63,585.0 0.0 0.0 AB1508B 44,530.0 0.0 0.0 AB1507/1508-FR A 31,295.0 0.0 0.0 AB1518 A 810.0 0.0 0.0 AF1504A 15,860.0 0.0 0.0 AF1504B 5,540.0 5,540.0 2.5 AB1600A 10,000.0 0.0 0.0 AB1600B 10,000.0 50.0 0.0 AB1801 10,000.0 460.0 0.2 AR1180 689,460.7 222,213.2 100.8 2. If projected VOC use is ≥130 Mg/yr but there is no §60.742(c)(2): (i) Install, operate, and maintain a cover on each piece of affected concurrent construction of a control device equipment; or (ii) install, operate, and maintain a cover on each piece of affected Total 313,233.3 142.1 equipment and vent VOC emissions to a VOC control device

Coating VOC Usage VOCs in Resing Used for 2016 Usage2 VOCs in Resins Used for Coating Coating Product1 (lb/yr) (lbs/year) (Mg/year) AR1112 23,705.6 3,221.6 1.5 AR1113 0.0 0.0 0.0 AR1102 630.0 262.4 0.1 AR1114 67,200.0 30,636.5 13.9 AR1502 3,280.0 175.8 0.1 AR1510 80,220.0 152.4 0.1 Tarsol A1-200 3,310.4 3,310.4 1.5 Total 37,759.1 17.1 1. If projected VOC use is <95 Mg/yr §60.740(b): Monitor VOC use Table 4: Powder Weighing Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU008 Emission Unit Description: Powder Weighing Stack/Vent Designation No.: SV001 Control Equipment No.: CE001 1 Formulation Throughput : 1,618,251 lb/year Maximum Weight Per Gallon of Resin: 11.15 lb/gallon 2 Maximum Powder Weighed : 35% Estimated Powder Throughput: 566,388 lbs powder/year 3 Baghouse Control Efficiency : 99%

Powder Weighing Actual Emissions Emission Powder Factor4 Controlled Controlled Throughput (lbs/ton Emissions Emissions Pollutant (lbs/year) powder) (lbs/year) (tons/year) PM 566,388 0.0089 2.52 0.00

PM10 566,388 0.0049 1.39 0.00

1 The maximum formulation throughput is calculated in Table 2. 2 The amount of powder weighed and added is approximately 35% of the weight of the resin. 3 To be conservative the calculations assume that all of the powder emissions are captured by the baghouse. In reality, some of the powder is not captured and settles on to the floor where it is swept up and disposed. 4 The AP-42 controlled emission factors are from Table 11.12-2 for cement supplement (pneumatic) unloading to a elevated storage silo. Table 5: Powder Adding Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU009 Emission Unit Description: Powder Adding Stack/Vent Designation No.: SV002 Control Equipment No.: CE001 Formulation Throughput1: 1,618,251 lb/year Maximum Weight Per Gallon of Resin: 11.15 lb/gallon Maximum Powder Added2: 35% Estimated Powder Throughput: 566,388 lbs powder/year Baghouse Control Efficiency3: 99%

Powder Adding Actual Emissions Emission Powder Factor4 Controlled Controlled Throughput (lbs/ton Emissions Emissions Pollutant (lbs/year) powder) (lbs/year) (tons/year) PM 566,388 0.0089 2.52 0.00

PM10 566,388 0.0049 1.39 0.00

1 The maximum formulation throughput is calculated in Table 2. 2 The amount of powder weighed and added is equal to 35% by weight of the resin density. 3 To be conservative the calculations assume that all of the powder emissions are captured by the baghouse. In reality, some of the powder is not captured and settles on to the floor where it is swept up and disposed. 4 The AP-42 controlled emission factors are from Table 11.12-2 for cement supplement (pneumatic) unloading to a elevated storage silo. Table 6: Treater Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU010 Emission Unit Description: Treater Process Stack/Vent Designation No.: SV003 Control Equipment No.: CE002 Control Equipment Capture Eff.: 100% 1 Control Equipment Destruction Eff. : 99%

Resin, VOC, HAPs, and TAPs Applied Treater Glass Product Average Area of Resin Application Production2 Actual Treater Resin VOCs Formaldehyde Methanol Phenol Toluene Triethylamine Total HAPs Isopropanol Width2 Sheet2,3 Rate2 (lbs/linear (linear Production Application Rate Solids Applied Volatiles Applied Applied Applied Applied Applied Applied Applied Applied Applied Product ID (Resin ID/Fiberglass Part #) Resin ID (in.) (ft^2/sheet) yard) yard/year) (sheet/year) (lbs/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) APF1180/7781 AR1180 60.0 52.1 1.230 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/6781 HT AR1180 60.0 52.1 1.290 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/16781 AR1180 62.0 52.1 1.279 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/220 AR1180 60.0 52.1 0.580 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/1583 AR1180 50.0 52.1 1.630 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/1568 AR1180 60.0 52.1 0.980 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1112/7781 AR1112 60.0 52.1 0.820 19,543.0 5,628.4 16,025.3 8,813.9 7,211.4 2,177.8 160.3 0.0 1,762.8 0.0 0.0 1,923.0 0.0 APF1112/220 AR1112 60.0 52.1 0.480 900.0 259.2 432.0 237.6 194.4 58.7 4.3 0.0 47.5 0.0 0.0 51.8 0.0 APF1112/1583 AR1112 56.0 52.1 2.680 1,614.0 433.8 4,325.5 2,379.0 1,946.5 587.8 43.3 0.0 475.8 0.0 0.0 519.1 0.0 APF1112/1568 AR1112 60.0 52.1 0.740 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1112/6781 AR1112 60.0 52.1 1.317 2,220.0 639.4 2,922.9 1,607.6 1,315.3 397.2 29.2 0.0 321.5 0.0 0.0 350.7 0.0 APF1112/16781 AR1112 62.0 52.1 1.279 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1113/0.65 AR1113 60.0 52.1 0.620 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

VOCs, HAPs, and TAPs Emitted Volatiles Volatiles Remaining Glass Product Glass Product Glass + Dried Volatile % of Post Treater Emitted in on Post Treater Formaldehyde Methanol Phenol Toluene Total HAPs Isopropanol Weight2 Throughput Glass + Resin Resin Weight Post Treater Weight Treater Product VOC Losses Losses Losses Losses Losses Triethylamine Losses Losses Product ID (Resin ID/Fiberglass Part #) Resin ID (lbs/sq. ft) (lb/year) Weight (lb/year) (lb/year) Product2 (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) (lb/year) Losses (lb/year) (lb/year) (lb/hr) APF1180/7781 AR1180 0.060 0.0 0.0 0.0 4.0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/6781 HT AR1180 0.062 0.0 0.0 0.0 4.0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/16781 AR1180 0.063 0.0 0.0 0.0 4.0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/220 AR1180 0.021 0.0 0.0 0.0 4.0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/1583 AR1180 0.111 0.0 0.0 0.0 4.0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1180/1568 AR1180 0.056 0.0 0.0 0.0 4.0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1112/7781 AR1112 0.060 17,706.0 33,731.2 26,519.9 2.5% 27,199.8 6,531.4 680.0 4,677.9 344.2 0.0 3,786.4 0.0 0.0 4,130.6 0.0 APF1112/220 AR1112 0.021 287.6 719.6 525.2 2.5% 538.6 180.9 13.5 129.6 9.5 0.0 104.9 0.0 0.0 114.4 0.0 APF1112/1583 AR1112 0.111 2,510.4 6,835.9 4,889.5 2.5% 5,014.8 1,821.1 125.4 1,304.3 96.0 0.0 1,055.7 0.0 0.0 1,151.7 0.0 APF1112/1568 AR1112 0.056 0.0 0.0 0.0 2.5% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1112/6781 AR1112 0.062 2,059.3 4,982.1 3,666.8 4.0% 3,819.6 1,162.5 152.8 832.6 61.3 0.0 673.9 0.0 0.0 735.2 0.0 APF1112/16781 AR1112 0.063 0.0 0.0 0.0 4.0% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APF1113/0.65 AR1113 0.005 0.0 0.0 0.0 18% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

VOCs, HAPs, and TAPs Actual Emissions VOC Formaldehyde Methanol Phenol Toluene Triethylamine Total HAPs Emissions Emissions Emissions Emissions Emissions Emissions Emissions Isopropanol Emissions Product ID (Resin ID/Fiberglass Part #) Resin ID (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) APF1180/7781 AR1180 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1180/6781 HT AR1180 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1180/16781 AR1180 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1180/220 AR1180 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1180/1583 AR1180 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1180/1568 AR1180 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1112/7781 AR1112 2.339 0.092 0.000 0.994 0.000 0.000 2.065 0.000 APF1112/220 AR1112 0.065 0.003 0.000 0.028 0.000 0.000 0.057 0.000 APF1112/1583 AR1112 0.652 0.026 0.000 0.277 0.000 0.000 0.576 0.000 APF1112/1568 AR1112 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1112/6781 AR1112 0.416 0.016 0.000 0.177 0.000 0.000 0.368 0.000 APF1112/16781 AR1112 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 APF1113/0.65 AR1113 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Sum of Uncontrolled Actual Emissions: 3.472 0.137 0.000 1.476 0.000 0.000 3.066 0.000 Sum of Controlled Actual Emissions: 0.035 0.001 0.000 0.015 0.000 0.000 0.031 0.000

1The June 28, 2011 destruction testing documented a destruction efficiency of 99.98%, however these calculations are only using the required 99% destruction efficiency. 2Information provided by Zodiac. 3Area of treater sheets is assumed to be 60 inches wide by 125 inches long. Table 7: Phenol Polymerization in Treater Resins Zodiac Aerospace Engineered Materials Newport, WA

Georgia Pacific Resin Analysis1

Free Phenol in Emitted in Free Phenol on Phenol Resin Resin Oven Dried Prepreg Polymerized AR1112 8.7% 3.4% 0.4% 4.9% AR1180 4.0% 2.1% 0.4% 1.5%

Destination of Phenol in Resins Remaining Resin Emitted in Oven on Prepreg Polymerized AR1112 39.1% 4.6% 56.3% AR1180 52.5% 10.0% 37.5% Other Resins2 52.5% 10.0% 37.5%

Georgia Pacific Resin Analysis - Formaldehyde1

Free Free Formaldehyde Emitted in Formaldehyde on Resin in Resin Oven Dried Prepreg AR1112 1.4% 1.4% 0.0% AR1180 4.1% 2.2% 1.9%

Destination of Formaldehyde in Resins Remaining Resin Emitted in Oven on Prepreg AR1112 100.0% 0.0% AR1180 53.7% 46.3% Other Resins2 53.7% 46.3%

1 Reported as a percentage of original liquid resin. 2 Other Treater resins will use the the results from tested resin that shows the highest amount of Table 8: Winder Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU011-EU015 Emission Unit Description: Winders (5) Process Stack/Vent Designation No.: SV004 Control Equipment No.: N/A

VOCs, HAPS, and TAPs Applied

Fiber Core + Dried Dried Resin Resin-Specific Fiber Core + Volatiles Formaldehyde Methanol Toluene Triethylamine Total HAPs Isopropanol Resin Weight1 Fiber Core (Solids) Weight Solids Content Total Resin Applied Resin Applied VOCs Applied Applied Applied Phenol Applied Applied Applied Applied Applied 1 Product ID (Resin ID/Fiberglass Part #) Resin ID (g/m^2) Weight (g/m^2) (g/m^2) (%) Applied (g/m^2) (g/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) (lb/m^2) APG 1102/12K AR1102 219.0 140.0 79.0 50.00 158.0 298.0 0.174 0.145 0.002 0.028 0.028 0.000 0.000 0.057 0.014 APG 1114/12K AR1114 219.0 140.0 79.0 50.00 158.0 298.0 0.174 0.159 0.001 0.035 0.035 0.000 0.000 0.071 0.017 APG 1114/12K-300 AR1114 305.0 202.0 103.0 50.00 206.0 408.0 0.227 0.207 0.002 0.045 0.045 0.000 0.000 0.093 0.023 AEG 1502/12K AR1502 252.0 150.0 102.0 50.00 204.0 354.0 0.225 0.024 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AEG 1510/12K AR1510 330.0 208.0 122.0 60.00 203.3 411.3 0.179 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AEF 1510/750 AR1510 480.0 290.0 190.0 60.00 316.7 606.7 0.279 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 AEG1510/18K AR1510 173.0 103.0 70.0 60.00 116.7 219.7 0.103 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

VOCs, HAPs, and TAPs Losses VOC Losses Fiber Core Post Winder Post Winder Volatile Losses VOC Losses Winder Winder Alcohol from Resin & +Applied Resin Volatile Content1 Product Weight from Resin2 from Resin Production1 Area per Sheet1 Production Resin Usage Alcohol Added1 Added1 Alcohol2 Product ID (Resin ID/Fiberglass Part #) Resin ID (g/m^2) (wt%) (g/m^2) (g/m^2) (g/m^2) (sheets/year) (m^2/sheet) (m^2/year) (lbs/year) (lbs/lb resin) (lbs/year) (ton/year) APG 1102/12K AR1102 298.0 8.840 240.2 57.8 48.1 1,076.0 6.037 6,495.8 630 0.028 17.6 0.353 APG 1114/12K AR1114 298.0 4.090 228.3 69.7 63.5 35,640.0 4.633 165,120.1 67,200 0.049 3,292.8 13.207 APG 1114/12K-300 AR1114 408.0 2.000 311.2 96.8 88.2 706.0 3.414 2,410.3 0 0.049 0.0 0.234 AEG 1502/12K AR1502 354.0 2.830 259.3 94.7 10.1 2,368.0 5.580 13,213.4 3,280 0.000 0.0 0.148 AEG 1510/12K AR1510 411.3 3.220 341.0 70.4 0.3 24,618.0 4.187 103,075.6 40,110 0.000 0.0 0.038 AEF 1510/750 AR1510 606.7 3.480 497.3 109.4 0.5 30,819.0 3.736 115,139.8 40,110 0.000 0.0 0.066 AEG1510/18K AR1510 219.7 2.200 176.9 42.8 0.2 8,188.0 4.187 34,283.2 0 0.000 0.0 0.008

VOCs, HAPs, and TAPs Actual Emissions3 Formaldehyde Methanol MIBK Phenol Toluene Triethylamine Total HAPs Isopropanol VOC Emissions Emissions4 Emissions Emissions Emissions4 Emissions Emissions Emissions Emissions Product ID (Resin ID/Fiberglass Part #) Resin ID (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) APG 1102/12K AR1102 0.35 0.00 0.07 0.00 0.00 0.00 0.00 0.07 0.03 APG 1114/12K AR1114 13.21 0.00 2.70 0.05 0.00 0.00 0.00 2.75 1.27 APG 1114/12K-300 AR1114 0.23 0.00 0.05 0.00 0.00 0.00 0.00 0.05 0.03 AEG 1502/12K AR1502 0.15 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AEG 1510/12K AR1510 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AEF 1510/750 AR1510 0.07 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AEG1510/18K AR1510 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Sum of Actual Emissions: 14.05 0.00 2.82 0.05 0.00 0.00 0.00 2.87 1.33

1 Information provided by Zodiac. Acetone is added to the AR1502 and AR1510 resins. 2 The calculations assume that all alcohol added to the resins is evaporating within the winders room. The AR1502 and AR1510 resins have acetone added instead of alcohol. 3 Emissions from the Winder Room are actually less than being reported because the actual application rate is lower than rate included in the calculations. 4 Formaldehyde and phenol emissions were below detection limits in the May 2015 stack test are are not believed to be emitted at ambient temperatures. Table 9: Phenol Polymerization in Winder Resins Zodiac Aerospace Engineered Materials Newport, WA

Winder Resin Sample

Free Phenol Free Phenol Resin Sample Description Free Phenol Analysis #11 Analysis #22 Analysis #33 AR1114 Fresh4 2.7% 2.9% 8.5% AR1114 4 days old5 1.1% 1.2% 9.2% 1 Analysis #1 involved measuring the free phenol content from fresh and 4 day old prepreg samples provided by Zodiac. The weight percent listed includes the weight of the 2 Analysis #2 involved measuring the free phenol content from fresh and 4 day old prepreg samples generated by Georgia-Pacific. The weight percent listed includes the 3 Analysis #3 involved measuring the free phenol content in the liquid resin. The weight percent listed only represents the weight percent in the resin. 4 Fresh samples provided by Zodiac are taken after the prepreg is removed from the drum. Fresh samples created at Georgia-Pacific are subject to being placed in front of a 5 4 day old samples are Fresh samples that have sat for 4 days to duplicate the prepreg waiting period prior to being processed in the Panel Press.

Note: The results from Free Phenol Analysis #3 have been discounted as resin was not placed on prepreg or thin spread and all of the solvent does not appear to have

Winder Resin Polymerization/Evaporation Phenol Phenol Percentage Average Free Average Free Phenol Phenol Percentage Polymerized/E Phenol Content in Content in 4 Day Old Percentage on on 4 Day Old vaporated in 4 Resin Fresh Sample Sample Prepreg Prepreg days AR1114 2.80% 1.2% 100% 41.1% 58.9%

Evaporation Calculation From Analysis #2 Liquid Resin Phenol % 6.3% (from Georgia-Pacific analysis) Phenol % after 10 minute dry 7.8% (Adjusted by Georgia-Pacific to account for the weight of the prepreg) Phenol % after 4 day dry 3.3% (Adjusted by Georgia-Pacific to account for the weight of the prepreg) Phenol % evaporated/polymerized 4.5%

Initial Weight 0.342 grams Sample weight loss after 10 minute dry 19% Weight after 10 minute dry 0.276 grams

Phenol lost/polymerized after 4 day dry 0.0124 grams

Equilibrium Calculation of Ziplok Bag Ziplok bag size 8" x 6" x 1" air volume = 48 in3 = 0.787 Vapor pressure of phenol 0.4 mm HG Molecular weight of phenol 94.1

Grams of phenol in Ziplok bag 0.787 liters x 0.4 mm HG x 1/760 mmHg x 94.1 grams/mol x 1/24 liters/mol Grams of phenol in Ziplok bag 0.00162 grams

Phenol % Evaporated 13.1% Phenol % Polymerized 86.9%

Destination of Phenol in Winder Resins Emitted in 4 Day Resin Dry Remaining on Prepreg Polymerized AR1114 7.7% 41.1% 51.2% Table 10: Panel Press Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU016 Emission Unit Description: Panel Press Stack/Vent Designation No.: SV005

Ethanol VOC Emission Formaldehyde Phenol Emission Emission 2016 Plies VOC Phenol Factor1 Emission Factor1 Factor1 Factor Used Emissions Formaldehyde Emissions Total HAPs Prepreg Resin Material (lb/ply) (lb/ply) (lb/ply) (lb/ply) (plies/yr) (tons/yr) Emissions (tons/yr) (tons/yr) (tons/yr) AR11132 9.38E-03 0.00E+00 0.00E+00 9.38E-03 8,828 0.041 0.000 0.000 0.000 AR1114 1.14E-02 1.40E-04 0.00E+00 1.13E-02 35,312 0.201 0.002 0.000 0.002 AR1180 1.37E-02 1.25E-04 0.00E+00 1.36E-02 3,288 0.023 0.000 0.000 0.000 AR1112 3.98E-02 1.40E-03 0.00E+00 3.84E-02 23,702 0.472 0.017 0.000 0.017 AR15023 3.84E-02 3.84E-02 0 0.000 0.000 0.000 0.000 AR15103 3.84E-02 3.84E-02 49,902 0.958 0.000 0.000 0.000 Cycom 6070 and all others containing formaldehyde 6.06E-03 0.00E+00 1.53E-04 5.91E-03 1,100 0.003 0.000 0.000 0.000 Total 1.699 0.019 0.000 0.019

1 The emission factors can be found in the PTE calculations and are based on the preliminary stack test results. 2 The emission factors for AR1113 are taken from the worst case emissions from the preliminary stack test results. 3 The VOC emission factor for AR1510 and AR1502 is taken from the ethanol emission factor for AR1112. This is conservative since AR1502 and AR1510 have a lower VOC content and do not contain phenol or formaldehyde. Table 11: Solvent Cleaning Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU017 Emission Unit Description: Solvent Cleaning Stack/Vent Designation No.: Fugitive-Indoors Control Equipment No.: N/A

1 Actual Solvent Usage : 10,218 pounds 2 Actual Solvent Shipped as waste : 6,038 pounds Actual Solvent emitted 4,181 pounds

Solvent Cleaning Actual Emissions Summary Pollutant Uncontrolled Emissions VOC 2.09 TPY Methanol 0.21 TPY MIBK 0.06 TPY Total HAPs 0.27 TPY

1 Zodiac primarily uses acetone for cleaning, however alcohol is used periodically. The solvent usage has been calculated. 2 Zodiac ships solvent used for cleaning as waste. In 2016 Zodiac shipped 8,050 lbs of solvent waste which contained a minimum of 75% solvent (6037.5 lbs). Table 12: Core Saw Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU018 Emission Unit Description: Core Saw Stack/Vent Designation No.: SV006 Control Equipment No.: CE003 Core Saw Production 114,061 sheets Waste Production 500 sheets/drum waste 1 Drums of Particulate Waste Collected : 228.1 drums Time Period: 1 year Weight of Waste Per Drum: 300 pounds/drum Collection Efficiency: 99%

Core Saw Actual Emissions Summary Uncontrolled Controlled Emissions Emissions Pollutant (TPY) (TPY) PM 34.56 0.35

PM10 34.56 0.35

1The waste collection amount was based on estimated waste collection records. Table 13: Measuring Table Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU020 Emission Unit Description: Measuring Table Stack/Vent Designation No.: SV007 Control Equipment No.: CE004 1 Drums of Particulate Waste Collected : 6.4 drums Time Period: 1 year Weight of Waste Per Drum: 300 pounds/drum Collection Efficiency: 99%

Measuring Table Actual Emissions Summary Uncontrolled Controlled Emissions Emissions Pollutant (TPY) (TPY) PM 0.97 0.01

PM10 0.97 0.01

1The waste collection amount was based on estimated waste collection records. Table 14: Thermwood Trimming Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU021 Emission Unit Description: Thermwood Trimming Stack/Vent Designation No.: SV009 Control Equipment No.: CE005 1 Drums of Particulate Waste Collected : 23 drums Time Period: 1 year Weight of Waste Per Drum: 300 pounds/drum Collection Efficiency: 99%

Thermwood Trimming Actual Emissions Summary Controlled Uncontrolled Emissions Emissions Pollutant (TPY) (TPY) PM 3.48 0.03

PM10 3.48 0.03

1The waste collection is calculated on a drum of waste being produced every two weeks, however typically the process will only product a drum of waste each month. Table 15: RTO Combustion Actual Emissions Zodiac Aerospace Newport, WA

Emission Unit Identification No.: EU022 Stack/Vent Designation No.: SV008 Control Equipment No.: N/A Emission Unit Description: Thermal Oxidizer

Fuel Parameters

% Sulfur Maximum Rated Boiler Fuel Fuel Type (gr/100ft³) % Ash Heat Value1 Capacity Consumption Propane 15 negligible 91,500 Btu/gal 3,500,000 Btu/hr 87,066 gal/yr

Criteria Pollutants Actual Emissions Pollutant Emission Factor Emissions Factor Source Emissions PM 0.0007 lb/gal AP-42 Table 1.5-1 0.03 TPY

PM10 0.0002 lb/gal AP-42 Table 1.5-1 0.01 TPY

PM2.5 0.000906 lb/gal Sum of PM2.5 Fil and PM-Con 0.04 TPY

SO2 0.0015 lb/gal AP-42 Table 1.5-1 0.07 TPY

NOx 0.013 lb/gal AP-42 Table 1.5-1 0.57 TPY VOC 0.0 lb/gal AP-42 Table 1.5-1 0.04 TPY CO 0.0075 lb/gal AP-42 Table 1.5-1 0.33 TPY

Greenhouse Gas Actual Emissions 2 Pollutant Emission Factor Emissions Factor Source Emissions Multiplier CO2e Emissions

CO2 13 lb/gal AP-42 Table 1.5-1 544.2 TPY 1 544.2 TPY

CH4 0.0002 lb/gal AP-42 Table 1.5-1 0.009 TPY 25 0.2 TPY

N2O 0.0009 lb/gal AP-42 Table 1.5-1 0.039 TPY 298 11.7 TPY

Total CO2e Total CO2e 556.1 TPY

1 Propane heat value is from AP-42 Section 1.5.1 (July 1998) 240 CFR 98 Subpart A Table A-1 Table 16: Product MSDS & Composition Information Zodiac Aerospace Newport, WA

HAP Composition, Max % TAP Composition, Max % Max Use Epichlorohydrin Formaldehyde Methanol MIBK Phenol CAS#108- Toluene Triethylamine Total HAPs Isopropanol Silica CAS#7631- Resin ID Where Used (gallons) Density (lb/gal) Volatile % VOC%1 Solids % CAS#106-89-8 CAS#50-00-0 CAS#67-56-1 CAS#108-10-1 95-2 CAS#108-88-3 CAS#121-44-8 % CAS#67-63-0 86-9 AR1180 Treater 7.5 45 32.23 55 6 6 12 AR1113 Treater 8.75 75 61.6 25 1 10 9 20 5 AR1112 Treater 10 45 13.59 55 1 11 12 AR1510 Winders 9.55 40 0.19 60 0 AR1502 Winders 9 50 5.36 50 0 AR1114 Winders 9 50 45.59 50 0.4 10 10 20.4 5 AR1102 Winders 8.85 50 41.65 50 0.5 8 8 16.5 4 AR1400A External Sales 11.15 10 0 0 AB1507-FR External Sales 9.65 1 0 0 AB1508-FR External Sales 9.65 1 0 0 AB1507-NAT External Sales 9.65 1 0 0 AB1508-NAT External Sales 9.65 1 0 0 AB1507-WHT External Sales 9.65 1 0 0 AB1508-WHT External Sales 9.65 1 0 0 AB1507B External Sales 8.65 5 0 0 5 AB1508B External Sales 8.65 5 0 0 8 AB1518 External Sales 9.7 1 0 0 AB1600A External Sales 8.5 70 0 2 2 AB1600B External Sales 8.9 1 0.5 0 AB1801 External Sales 9.1 50 4.6 2.5 3 5.5 AF1504A External Sales 6.5 100 0 0 0 AF1504B External Sales 10.8 100 100 0 0 DEN439 Formulations 10.18 0 0 EPON 828 Formulations 9.72 0 0 100 0.0001 0.0001 EPON 160 Formulations 10.008 0 0 EPON 58005 Formulations 8.9238 0 0 EPON 813 Formulations 9.5076 0 0 EPON 1163 Formulations 15.44 0 0 100 0 Phenolic AR1102/1113/1114 Formulations 9.174 30 30 0.5 15 20 35.5 ANACAMINE TETA Formulations 6.841 0 0 ANACAMINE 1922A Formulations 8.428 0 0 ANACAMIDE 2482 Formulations 8.095 0 0 ANACAMIDE 350A Formulations 8.095 0 0 AMICURE UR2T Formulations 0 0 100 0 Phenolic AR1180 Formulations 10.258 26 26 6 8 14 Phenolic AR1112 Formulations 10.008 34 34 2 13 15 CAB-O-SIL Formulations 18.348 0 0 100 0 Tarsol A1-200 Entire Facility 6.610 100 100 0 10 3 13 BUTVAR B-98 Formulations 3.922 0 2.8 100 0

Purchased Prepreg

Phenol Formaldehyde Methanol CAS#108- Resin ID Where Used VOC% CAS#50-00-0 CAS#67-56-1 95-2 CYCOM6070/7781 Panel Press 17% 0.2% 7% 10% L-501/7781 Panel Press 0% L-802 B Panel Press 13% 3% 1% 4% L591 Panel Press 11% 0.54% 3% 4% L530 Panel Press 5% L201 Panel Press 5% AX2114HR Panel Press 1% AX2115 Panel Press 1% Cycom 2400 Panel Press 8% 1% 6%

1 VOC Content provided by either Georgia Pacific or Zodiac

APPENDIX H NOTICE OF CONSTRUCTION APPLICATION

SUPPORTING FIGURES

TOPOGRAPHIC MAP IMAGE COURTESY OF Project Manager: Project No. THE U.S. GEOLOGICAL SURVEY Dave Reye nolds MP157289C SITE LOCATION Figuure QUADRANGLES INCLUDE: NEWPORT, WA (1/1/1996). Drawn by: Scale: Josh Kurtz 1”=2,000’ Zodiac Engineeered Materials Air Permitting - Newport Checked by: File Name: 13400 15th Ave. N. DIAGRAM IS FOR GENERAL LOCATION ONLY, DR Figure 1-2.docx 501 North Newport Avenue 1 AND IS NOT INTENDED FOR CONSTRUCTION Approved by: Date: Plymouth, MN 55441 Newport, WWA PURPOSES DR 1/26/2016

AERIAL PHOTOGRAPHY PROVIDED BY Project Manager: Project No. Figure Dave Reye nolds MP157289C EXPLORATIOON PLAN MICROSOFT BING MAPS Drawn by: Scale: Josh Kurtz AS SHOWN Zodiac Engineered Materials Air Permitting - Newport Checked by: File Name: 13400 15th Ave. N. DIAGRAM IS FOR GENERAL LOCATION ONLY, DR Figure 1-2.doccx 501 North Newport Avenue 2 AND IS NOT INTENDED FOR CONSTRUCTION Approved by: Date: Plymouth MN 55441 Newport, WWA PURPOSES DR 1/26/2016

APPENDIX I NOTICE OF CONSTRUCTION APPLICATION

PANEL PRESS PRELIMINARY STACK TEST RESULTS

Preliminary Results Run 1 1 2 2 3 3 4 4 5 5 6 6 Product 1113 1113 1180 1180 1112 1112 6070 6070 1114 1114 1113 1113 North South North South North South North South North South North South Date 1/31/2017 1/31/2017 2/1/2017 2/1/2017 2/1/2017 2/1/2017 Start Time 18:05 18:05 19:40 19:40 7:51 7:51 9:08 9:08 10:30 10:30 14:11 14:11 End Time 19:10 19:10 20:50 20:50 9:00 9:00 10:22 10:22 11:40 11:40 16:12 16:12

Flow Rate ACFM 5,318 5,330 3,962 5,415 4,865 5,388 5,746 5,327 5,522 6,155 5,565 5,581 Flow Rate DSCFM 4,891 4,900 3,649 4,987 4,528 5,014 5,336 4,943 5,117 5,700 5,117 5,135 Temp F 76 76 75 75 70 70 71 71 72 72 76 76

O2 % 21.85 21.2 21.19 22.05 21.08 20.16 20.91 20.54 21.06 21.11 20.46 20.86 CO2 % -0.05 0.17 -0.05 -0.02 -0.11 -0.03 0.08 0.00 0.03 -0.13 0.13 -0.10 H20 % 0.30 0.35 0.32 0.34 0.23 0.25 0.27 0.31 0.30 0.33 0.32 0.30

Formaldehyde ppm -0.42 -0.33 -0.26 0.12 -0.15 0.19 0.62 1.73 -0.35 -0.08 -0.41 -0.15 Formaldehyde lb/hr 0* 0* 0* 0.0028 0* 0.005 0.016 0.0399 0* 0* 0* 0* phenol ppm -0.38 -0.71 -0.25 -0.23 -0.34 -0.60 -0.15 -0.19 0.17 -0.32 -0.09 -0.16 phenol lb/hr 0* 0* 0* 0* 0* 0* 0* 0* 0.0061 0* 0* 0*

Ethanol ppm 1.015 1.657 -1.441 1.6457 2.824 3.712 7.404 7.4082 13.828 25.416 2.23 4.225 Ethanol lb/hr 0.036 0.058 0* 0.059 0.092 0.134 0.280 0.263 0.506 1.030 0.081 0.156

*When ppm was below 0, lb/hr was treated as none

APPENDIX J NOTICE OF CONSTRUCTION APPLICATION

GEORGIA-PACIFIC POLYMERIZATION INFORMATION/RESULTS

Georgia-Pacific Resin Polymerization Analyses Description

There were two separate testing events completed by Georgia-Pacific (GP). One event dealt with the phenolic resins that are used in the Treater and the other event dealt with the phenolic resins that are used on the Winders.

Phenolic resins are required to be used by Zodiac in order to the necessary product quality. The resins contain both phenol and formaldehyde and a reaction occurs under certain conditions. Some of the phenol and formaldehyde are bound in the final product and some of the phenol and formaldehyde are emitted. The exact amount of polymerization cannot be calculated but Zodiac requested that GP perform some testing to try and identify the level of polymerization that occurs in the Treater and Winder processes.

Treater Analysis Zodiac provided GP with liquid resin samples and GP analyzed the resin to determine the amount of free phenol and formaldehyde in the liquid resins.

GP applied a known amount of resin in a similar thickness to a similar substrate and then tried to mimic the Treater process by air drying the sample for 10 minutes at ambient temperature and then placing the sample in an oven at 280˚F for 12 minutes and then at 250˚F for 12 minutes. The exhaust of the oven was analyzed for phenol and formaldehyde. The dried samples that came out of the oven were analyzed for free phenol and formaldehyde. This information was used to determine the amount of phenol and formaldehyde that is polymerized in the Treater, the amount that is emitted in the Treater, and the amount that remains on the dried prepreg.

The Treater emission calculations use a mass balance approach for phenol and take into account of phenol that is emitted in the Treater based on the GP testing. The formaldehyde emission calculations are based on stack test results from testing the exhaust of the thermal oxidizer. See Table 9 in the Potential To Emit calculations for more information on this testing.

Winder Analysis Zodiac requested that GP perform testing on the prepreg materials produced on the Winders to determine if the resin polymerized during the resting period of the prepreg material prior to being processed in the Panel Press.

For the first set of testing Zodiac provided GP with a prepreg sample that had just came out of the Winder process and another prepreg sample of the same material that had been setting for 4 days. The second set of testing came from GP simulating the Winder process by applying resin to samples and having a fan blow at the samples for 10 minutes at a low speed to simulate the rotating of the drum. One sample was immediately analyzed for free phenol and other resting for four days under plastic to mimic how the material is stored at Zodiac. After four days the sample Reynolds, David C

From: Qureshi, Shahid P. Sent: Thursday, August 18, 2016 3:06 PM To: Reynolds, David C Cc: Chan, Charles C.; Qureshi, Shahid P. Subject: Emissions Results Summary Attachments: Zodiac prepreg emission modified.xlsx

Please ignore previous emails/results. We have reviewed and summarized in the attached as per your specific conditions. We look forward to discuss Monday.

Regards Shahid Qureshi

1 Prepregs from Zodiac Results: solvent extracted and based on weight of prepreg label description %phenol formaldehyde 1102-12K fresh 3.2 210 ppm 1102-12K 4 days old 2.8 230 ppm 1114-12K fresh 2.7 190 ppm 1114-12K 4 days old 1.1 200 ppm

Material prepared in Decatur Results: solvent extracted and based on weight of prepreg %phenol % formaldehyde wet resin content dried resin content 110K66c GP464D80 (AR1114) on glass fiber cloth 2.9 210 ppm 45.0% 37.5% After 10 minutes air dry at RT 110K66G GP7649 (AR1112) on glass fiber cloth 0.4 0.29 49.0% 33.0% After 12 minutes at 280F 110K66J GP7600 (AR1180) on glass fiber cloth 0.4 0.36 55.6% 36.8% After 12 minutes at 250F

Tube furnace Results: calculated as percentage of original liquid resin %phenol %formaldehyde Tempertature 280°F / Time: 12 minutes GP7600 (AR1180) flow rate: electronic 175 scc/min 2.1 2.2 Tempertature 250°F / Time: 12 minutes GP7649 (AR1112) flow rate: electronic 175 scc/min 3.4 1.4

RESIN comments %phenol %formaldehyde GP464D80 (AR1114) liquid resin 6.3 520 ppm GP7649 (AR1112) liquid resin 8.7 1.4 GP7600 (AR1180) liquid resin 4.0 4.1 Reynolds, David C

From: Chan, Charles C. Sent: Tuesday, September 27, 2016 2:54 PM To: Reynolds, David C Cc: Johnson, Michael D; Qureshi, Shahid P. Subject: RE: Zodiac - Test Review

Follow Up Flag: Follow up Flag Status: Completed

I check our numbers and summarized (with details) in the table below:

weight, g GPC resin, % resin Prepregs from Zodiac %phenol fabric wet content weight after 10 minutes dry Mn Mw Mz 1114-12K fresh 2.7 unknown unknown unknown unknown did not measure 1114-12K 4 days old 1.1 unknown unknown unknown unknown did not measure

Prepregs prepared in GP-Decatur GP464D80 (AR1114) fresh 2.9 0.5065 0.3005 37.2 did not measure 316 865 2332 GP464D80 (AR1114) 4 days old 1.2 0.5910 0.3420 36.7 did not measure 335 916 2408 GP-Decatur resin only GP464D80 (AR1114) fresh 8.5 - 2.8923 100 2.3822 305 791 2112 GP464D80 (AR1114) 4 days old 9.2 - 3.1575 100 2.6004 307 805 2148

% phenol per prepreg

· It does appear that there is more evaporation in prepregs (probably due to more surface area)----Zodiac and GP made prepregs separately and got similar results. · There is also a little more resin advancement in prepreg than resin. For the prepregs, there is an overnight digestion process (to extract resin from the fabric); perhaps leading to the slightly higher molecular weight.

I trust the above information is helpful and let me know if you have any questions.

1 Regards,

Charles Chan Chemist – Core Growth R&D - Phenolics Georgia-Pacific Chemicals LLC 2883 Miller Road, Decatur, GA 30035 770-593-5929 (office) | 770-322-9973 (fax) | 770-547-8980 (Cell)

CONFIDENTIAL NOTICE: Unless otherwise indicated or obvious from the nature of the transmittal, the information contained in this e-mail message is confidential and proprietary information, and may also be privileged, that is intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, immediately notify the sender by telephone at 770-593-5929 and return the original message to Georgia-Pacific Chemicals LLC. Thank you.

From: Reynolds, David C [mailto:[email protected]] Sent: Tuesday, September 27, 2016 10:18 AM To: Qureshi, Shahid P. ; Chan, Charles C. Cc: Johnson, Michael D Subject: Zodiac - Test Review

Sent by an external sender

Shahid/Charles,

Have you had a chance to review the data from the first test to determine if there were any calculation errors?

Sincerely,

David C. Reynolds, P.E. (licensed in Minnesota) Senior Project Environmental Engineer Liesch A Terracon Company 13400 15th Avenue North I Plymouth, MN 55441 P (763) 489 3158 I F (763) 489 3101 I M (612) 210 7279 [email protected] I liesch.com I terracon.com

2 Terracon provides environmental, facilities, geotechnical, and materials consulting engineering services delivered with responsiveness, resourcefulness, and reliability.

Private and confidential as detailed here (www.terracon.com/disclaimer). If you cannot access hyperlink, please e-mail sender.

3

APPENDIX K NOTICE OF CONSTRUCTION APPLICATION

THERMAL OXIDIZER SPECIFICATIONS

Proposal No.: 16-7714

Date: March 16, 2016

Submitted To: Mike Shantie Zodiac Advanced Composites & Engineering Materials 501 North Newport Avenue Newport, WA 99156

Submitted By: Chris Heikkila Account Executive

RE: Oxidizer Rebuild, CPI Job 10/6314, QUADRANT SR-3000 Thermal Oxidizer

Dear Mike:

Thank you for your continued interest in partnering with Catalytic Products International (CPI) and the opportunity to provide this proposal. CPI is pleased to provide this quotation to provide engineering, materials and labor to refurbish the equipment referenced above.

BASIS OF DESIGN

C & D Zodiac (Zodiac) is in the process of purchasing a new Prepreg treater that will coat several different coating types onto a vinyl-like web substrate.

Zodiac has requested a proposal to refurbish the existing QUADRANT SR-3000 recuperative thermal oxidizer, which was originally provided by CPI in 2010 to treat the emissions from the previous treater.

980 Ensell Road | Lake Zurich, Illinois 60047 | office: 847.438.0334 | fax: 847.438.0944 e-mail: [email protected] | website: www.cpilink.com

EXHAUST CHARACTERISTICS

Based on information provided by CA Litlzer, CPI has calculated the following treater exhaust characteristics:

Exhaust Rate: 2,827 SCFM Exhaust Temperature: 350° F Tarsol: 150 lbs/hr maximum, VOC loading of the following VOC’s: Ethanol 127.5 lbs/hr (max) Methanol 7.5 lbs/hr (max) MIBK 3.0 lb/hr (max) Isoproponal: 12.0 lb/hr (max) Avg. Hc (BTU/lb): 11,607 BTU/lb x 150 lbs/hr = 1,741,000 BTUH

Calculated LEL compensated for Temperature: Approximate LEL in 2,827 SCFM (temperature compensated @ 350°F) = 34.5% Approximate LEL in 3,000 SCFM (temperature compensated @ 350°F) = 32.5%

Zodiac currently utilizes an LEL Monitor at the inlet of the thermal oxidizer and the coating enclosure as a safety device and should continue this practice. Based on the maximum VOC loading conditions described above, the QUADRANT SR-3,000 Thermal Oxidizer can safely oxidize 1,741,000 BTU/hr of mixed VOC. Zodiac should confirm the suitability of operating the treater above 25% LEL.

Example of the QUADRANT SR-Series Thermal Oxidizer

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OXIDIZER REFURBISHMENT AND NEW AUXILLIARY EQUIPMENT

HEAT EXCHANGER  Replace all tubes with like materials, 309 stainless steel  Disassemble and rebuild the pressurization chamber to new condition  Replace outside seals around outside tube sheet and re-insulate  Add new inlet transition air distribution plate  Sand blast, prime and repaint

COMBUSTION CHAMBER  Replace combustion tube support stand and re-insulate the area  Repair various welds at dividing wall and expansion joint  Sand blast, prime and paint  Two (2) Type-K dual element thermocouples in the combustion chamber

BURNER CONTROL VALVE  Provide a NEW Maxon CV gas control valve with o Honeywell Modutrol-4 electric operator o The CV valve will be factory mounted in the gas piping (re-use existing gas train) and wired to the gas train junction box. o NEW Includes low fire start switch o NEW One (1) Honeywell self checking UV

VOLUME CONTROL (the following equipment will be provided NEW)  25-HP AB PowerFlex variable frequency drive. The drive will be mounted in a NEMA-1 Enclosure, to be mounted indoors next to the TSS Control Panel.  If the VFD is located more than 100 ft. from the motor a load reactor may be required at an added cost  480v/3-ph/60 Hz inverter  4-20 mA follower card  The following duct pressure sensing instrumentation will be supplied in a  NEMA-4 enclosure, to be mounted and wired by others: o Dwyer 605 pressure control transmitter o Karl Dungs 217 Series high duct pressure switch

MAIN PROCESS BLOWER (the following equipment will be provided NEW) The fan will be a New York Blower (or equivalent) arrangement 1 forced draft centrifugal fan complete with skid mounting of the following equipment:

Q u o t e 1 6 - 7 7 1 4 P a g e | 3

 Heavy duty all welded painted carbon steel construction  480v/3-ph/60-Hz – 1800 rpm - 25 HP Inverter duty rated TEFC motor  Flanged inlet & outlets  Split Housing allowing more access for potential cleaning and service  OSHA shafts & bearing guards with oversized shafts and split lock bearings.  Factory Insulated and clad painted carbon steel to NYB standard  Note: The fan is designed to provide a maximum of -3.0 W.C. of negative pressure from the oven with sufficient pressure for associated ducting.  Blower Specifications: o SCFM: 3,000 o ACFM: 4,868 o Temperature: 400 F o BHP 23.5 o Installed HP 25 o Elevation: 2,200 ft above sea level  Karl Dungs 217 Series air pressure safety switch (supplied in a weatherproof enclosure to be field mounted and piped) as DIFFERENTIAL PRESSURE SAFETY SWITCH  Heavy duty industrial flex connector at fan discharge

TSS CONTROL PANEL (the following equipment will be provided NEW)  NEMA-12 indoor rated painted carbon steel enclosure for installation and final termination by others. o Codes – TSS control panels are designed to NEC standards. Unless specifically mentioned below, no other codes or standards apply  480 V – 3ph – 60 Hz main disconnect  Allen-Bradley CompactLogix Ethernet Processor with the following: o II/O as required to manage the system and interconnect to one source o Ethernet Phone modem for connection to CPI Service Network (phone line provided by others)  Allen-Bradley PanelView 1000 color touch screen. MMI will including the following: o Start/Stop functions o PID Control Loops for: . Burner temperature control . VF Drive speed control . Allowance for LEL interlock if supplied by others o Text messaging of system status & individual graphic screens . Overall system overview screen . Combustion system detail screen

Q u o t e 1 6 - 7 7 1 4 P a g e | 4

. Booster fan detail screen . Maintenance screen . Secure PID access screen . Alarm history screen with time and date  Motor Starters for Combustion Air Blower and HX Pressurization Blower  Eurotherm high temperature limit shut off  Honeywell RM7800M1011 flame safety system  Door mounted alarm horn  Door mounted E-Stop push button

MISCELLANEOUS EQUIPMENT (the following equipment will be provided NEW)  One 12” diameter Fresh Air Purge / Makeup Air Damper: o Carbon steel construction – single blade butterfly damper o The damper will be a butterfly design to minimize air infiltration o during high flow conditions o 1” diameter shafts with ¼” think reinforced platters. Shaft to have o Packing gland tubes with adjustable compression plates. o 4-20mA modulating direct drive actuator o Open/closed proof position switches o Stainless steel

 One 18” diameter Bypass T- Damper o Painted carbon steel construction – dual butterfly dampers . 1” diameter shafts with ¼” think reinforced platters. Shaft to have packing gland tubes with adjustable compression plates. . Interior damper platter to seat into replaceable ½” diameter Teflon tadpole seats allowing < 1% leakage at 5” WC hot. . Bearings to be Dodge carbon sleeve style mounted on external standoffs. . One actuator on each damper, two actuators total will be RCS MAR-100 Series electric, direct drive actuator with external proof of position switches inputting to the PLC o The T-Damper will be constructed as a square housing and include to removable access doors to allow easy access to the tadpole seals o The T-Damper will be externally insulated with ceramic blanket and clad in painted carbon steel.

Q u o t e 1 6 - 7 7 1 4 P a g e | 5

START-UP & COMMISSIONING

Complete site supervision for one man for a period of three days and operator training for two men, for 40 hours of site time (M-F) can be included for $ 18,000.00. The startup normally begins after the customer has confirmed readiness by filling out our supplied startup checklist. This list is a simple sheet that asks you to confirm such things as: the gas supply is ready, electrical components have all been wired correctly, ductwork is ready and production conditions are ready. Our men will perform the following steps:  Confirm operation of all safeties  Establish oxidizer readiness and startup on fresh air  Balance the air volumes and flows from the source to the equipment  Set all of the system field components  Set all of the oxidizer adjustments on production conditions  Record pressures and volumes for insertion into the operation manual  Verify operation via mutual acceptance of performance by both parties  Train all necessary personnel. Training normally requires a few hours (per shift) depending on the employees ability to comprehend the system.

Q u o t e 1 6 - 7 7 1 4 P a g e | 6

EQUIPMENT COST SUMMARY

PROJECT INVESTMENT

QUADRANT SR-3000 Rebuild ...... $ 214,800.00 Start-Up and Commissioning ...... $ 18,000.00

PAYMENT TERMS

Net 10 Days upon receipt of invoice

50% down payment to initiate the order 40% upon equipment shipment or equipment ready to ship 10% upon installation or 30 days after shipment or ready to ship, whichever comes first

PROJECT COMPLETION

10-12 weeks ready to ship

EQUIPMENT SHIPMENT

EX-Works

The quoted prices and deliveries are subject to the attached TERMS AND CONDITIONS and are valid for a period of 10 days

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BUYER’S RESPONSIBILITIES

The following list will detail the items that are not included as part of an equipment only purchase.

 Structural foundation and platforms designed to adequately support the QUADRANT system.  Rigging and installation of oxidizer.  All required construction and operating permits. All fees for permits are payable by the customer.  Any Special registrations if required. This may include: PE, structural, or seismic.  Complete electrical interconnection wiring including 480 V supply to oxidizer panel.  Natural gas piping from the plant gas supply to the oxidizer gas train inlet at 5 PSIG at required flows.  Flame or detonation arrestor if required.  All controls other than specified. This can include items such as flow measurement, mass flow meters, LEL monitor and CEM equipment, among others.  Compliance testing if required  Startup service for any delays caused by the customer or representatives of the customer will be billed at $135.00/hr for normal weekdays, $200.00/hr for weekends, $270.00 for all holidays, and all expenses plus 10%.  Provide plant personnel and production ready conditions for startup and operator training at time of startup.

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PERFORMANCE GUARANTEE

Catalytic Products International guarantees that the total VOC concentration of the QUADRANT SR-3000 will reduce the concentration of gaseous phase hydrocarbons measured at the inlet of the oxidizer as compared to the concentration of gaseous phase hydrocarbons measured at the outlet (i.e.: discharge stack) of oxidizer by 99% percent to a lower limit of 20 ppm volume as C1 as verified by EPA test methods 25A (FID). This is based upon the information provided to Catalytic Products International as specified by the customer as basis for design. This guarantee is also conditioned that the QUADRANT SR-3000 and provided components are to be operated and maintained in accordance with the supplied operating and maintenance instructions. EPA-approved Test Method 25A is to be utilized for compliance testing. The above guarantee is conditioned upon simultaneous measurement of the inlet and outlet hydrocarbon solvent loadings after the deduction of any burner-generated chemical compounds such as methane or others. At all times during testing, all operating conditions are to be specified by CPI's operating instructions. Test methods must be of sufficient accuracy and reproducible for any and all test conditions encountered.

This guarantee is also conditioned that the QUADRANT SR-3000 Thermal Oxidizer and provided components are to be operated and maintained in accordance with the supplied operating and maintenance instructions.

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EQUIPMENT WARRANTY

The Seller warranty to Buyer that the equipment and machinery mentioned in this proposal shall be free from defects of materials or workmanship under normal use and maintenance for a period of one (1) year from date of shipment. The liability of Seller under this warranty shall be limited to the repair or replacement, at Seller's option, or any part or component which may prove to be defective under normal use, service and maintenance after Seller, in its sole discretion, determines same to be defective. This warranty is conditioned upon Buyer giving Seller immediate written notice of an alleged defect, and refraining from the attempted repair of alleged defects without prior written consent of Seller. The Seller makes no warranty whatsoever with respect to accessories or components not supplied by Seller. For any components purchased by Seller for use on or in conjunction with the equipment which is the subject of this contract, the Seller extends to the Buyer only the same warranty granted to Seller by the component vendor or manufacturer.

The performance and safety of the equipment mentioned herein is contingent upon proper installation, the use of suitable process materials, and operation and maintenance by properly trained personnel. Seller makes no warranty whatsoever as to the inclusion of the equipment supplied by Seller into Buyer's manufacturing process, Seller's warranty being limited solely to the operation of its equipment sold hereunder in accordance with the specifications therefore.

THIS WARRANTY IS IN LIEU OF ALL OTHER WARRANTIES, EXPRESSED OR IMPLIED, INCLUDING THE WARRANTIES OF MERCHANTABILITY AND FITNESS FOR USE. IT IS EXPRESSLY AGREED THAT UNDER NO CIRCUMSTANCES SHALL THE SELLER BE HELD LIABLE FOR ANY SPECIAL OR CONSEQUENTIAL DAMAGES OR LOSS OF PROFIT ARISING FROM ANY CAUSE, AND SELLER'S LIABILITY SHALL BE STRICTLY LIMITED AS STATED HEREIN.

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TERMS and CONDITIONS I. ACCEPTANCE All sales of material or equipment by Catalytic Products International are expressly conditioned upon the terms and conditions set forth in the written order acknowledgment of Seller. Any additional or different terms of conditions set forth in the purchase order of the Buyer or any similar such communication, are hereby objected to by Catalytic Products International and shall not be binding nor effective unless assented to in writing by Catalytic Products International.

II. CANCELLATION Buyer acknowledges this is custom engineered and fabricated equipment to the buyers exacting specifications. Buyer may cancel any order only by mutual agreement, and only upon written notice to Catalytic Products International, and with payment to Catalytic Products International of reasonable cancellation charges, including but not limited to (1) the proportionate contract price for all material completed, whether shipped or not, prior to notice of cancellation is received; (2) an inventory restocking fee equal to 30% of the original order including any change orders; and (3) all expenses incurred by Catalytic Products International by reason of such cancellation, including reimbursement for any charges arising from termination of sub-contract claims.

III. DAMAGE OR LOSS The Company shall not be liable for damage to or loss of equipment after delivery of such equipment to the point of shipment. In the case of equipment to be installed by or under supervision of the Company, the Company shall not be liable for damage or loss after delivery by the carrier to the site of installation. If, thereafter, pending installation or completion of installation or full performance by the Company, any such equipment is damaged or destroyed by any cause whatsoever, other than by the fault of the Company, the Buyer agrees promptly to pay or reimburse to the Company, in addition to or apart from any and all other sums due or to become due hereunder, an amount equal to the damage or loss so occasioned.

IV. DELAYED SHIPMENTS Quoted shipping dates are approximate. Catalytic Products International will use its best efforts to fill all orders within the time quoted. However, final shipping schedules shall be subject to any conditions that may prevent compliance with acknowledged delivery schedules. Catalytic Products International shall not be liable for failure to give notice any delay, and such delay shall not constitute grounds for cancellation.

Catalytic Products International reserves the right to store such products in a warehouse for the accounts and at the risk of the Buyer after the products or any substantial portion thereof are ready for shipment cannot be made for either of the following reasons:

(a) If CPI is prevented from making shipment or delivery in accordance with instructions of the Buyer, or (b) By strike, boycott, natural disaster, governmental law, regulation, or circumstances beyond the control of CPI.

V. FIELD SERVICE Unless otherwise noted herein, the cost of this equipment does not include service and/or installation. Field service, as stated in proper written quotation, for repair or start-up will be charged at a per diem rate plus all living and traveling expenses incurred from the time of leaving base of operations until return. Premium rate will be charged for work in excess of eight hours per day and for Saturday, Sunday, and holiday work. On start-up projects Catalytic Products International should be notified approximately thirty days prior to the start-up date, and name and title of a single authority responsible for securing and releasing personnel should be included. Catalytic Products International service representative will require time verification sheets to be approved by the Buyer's authorized representative at the completion of each day's work.

Upon request, Catalytic Products International in its discretion will furnish as an accommodation to Buyer such technical advice or assistance as is available in reference to the use of the product by Buyer. Catalytic Products International assumes no obligation or liability for the advice or assistance given or results obtained, all such advice or assistance being given and accepted at Buyer's risk.

VI. GUARANTEE Material and equipment distributed by Catalytic Products International are the products of reputable manufacturers sold under their respective brand or trade names. Catalytic Products International shall use its best efforts to obtain from each manufacturer, in accordance with the manufacturer's warranty (copies of which will be furnished upon request) or customary practice, the repair or replacement of products that may prove defective in material or workmanship. The foregoing shall constitute the exclusive remedy of the Buyer and the sole obligation of Catalytic Products International. Except as to title, THERE ARE NO WARRANTIES, WRITTEN, ORAL, IMPLIED, OR STATUTORY, relating to the described material or equipment, which extends beyond that described in this paragraph. NO WARRANTY OF MERCHANTABILITY OR OF FITNESS FOR PURPOSE SHALL APPLY. Any and all such warranties are subject to purchaser's application of purchased equipment and materials strictly and exclusively within the technical specification as defined in Catalytic Products International's order acknowledgment and general technical description.

With acknowledgment of Buyer's order, Seller assumes that Buyer has verified technical specifications as set forth in this contract and Buyer has the responsibility for correctness of said technical specifications. Unless specially noted, this proposal is not intended to exactly meet the Buyers specification and if conflict arises, this proposal takes precedence.

Performance guarantees for catalyst and systems shall be strictly and exclusively limited to those expressly stated in Seller's written order acknowledgment, and such guarantees shall only apply if catalysts were found in original and sealed factory package. Performance guarantees for heat exchangers shall be strictly and exclusively limited to those expressly stated in Seller's written order acknowledgment based on nominal (+/- 5%) efficiencies. All replacements arising from claims on guarantees as herein stated are made FOB Shipping Point (American Uniform Commercial Code) Seller’s Plant.

The foregoing warranty is in lieu of and excludes all other expressed or implied warranties of merchantability or fitness for any particular use. Seller guarantees that catalysts have been given to carrier in unbroken original factory sealed package.

VII. LIABILITY The Company will not be liable for any damage caused by the operation of the machinery or devices purchased whether or not operated in accordance with instructions or because of any failure to meet conditions of our guarantee. Liability under any contract shall in no case exceed the price paid for

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goods furnished by Catalytic Products International. In no event will Catalytic Products International be liable for consequential damages, or the failure of the Buyer to provide proper safety features for the protection of personnel in the use of operation of equipment. Catalytic Products International's liability on any claim for loss or damage arising out of this contract or from the performance or breach thereof or connected with the supplying of material or equipment hereunder, or its sale, resale, operation or use, whether based on warranty, contract, negligence or other grounds, shall not exceed the price allowable to such material or equipment or part thereof involved in the claim. Catalytic Products International shall not, under any circumstances, be liable for any labor charges unless agreed upon in advance in writing by Catalytic Products International.

Buyer assumes full responsibility for proper handling and storage of catalysts and equipment, after receipt from carrier, in accordance with Seller's instructions. Warranties and guarantees become void unless handling and storage was made in accordance with Seller's instructions.

VIIIPATENTS The Company shall hold Buyer harmless for any expense or loss resulting from infringement of patents or trademarks arising from compliance with the Buyer's designs or specifications.

IX. PRICING Seller reserves the right (a) to revise any price quoted without notice to Buyer, at any time prior to acceptance of Buyer's purchase order by Seller, (b) unless otherwise noted, all prices by Catalytic Products International are subject to change without notice. Prices do not include sales, use, excise, value added, or similar taxes, and where applicable, such taxes shall be billed as a separate item and paid by the Buyer. Unless otherwise noted, all sales are made FOB Shipping Point (American Uniform Commercial Code) with no allowance for special crating, duties or fees and in all cases, title shall pass upon delivery at point of shipment and thereafter all risk of loss or damage shall be upon the Buyer.

All items shown as freight allowed pertains to particular items and quantities. Any deviation after placement of order such as changes in quality or partial release will be subject to the manufacturer's terms and conditions where applicable.

X. RETURNED MATERIAL No credit will be given for returns except by specific written approval of Seller. No special designed catalyst materials or equipment may be returned. No catalyst, burner nozzle, burner block, or other parts directly exposed to flame, condensate or poisonous substances may be returned after use.

XI. SHIPMENT All shipments will be made FOB Shipping Point s (American Uniform Commercial Code) Catalytic Products International factory unless otherwise specified. In the absence of specific instructions, Catalytic Products International will select the carrier. Title to the material shall pass to the Buyer upon delivery thereof by Catalytic Products International to the carrier, delivery or pick-up service. Thereupon the Buyer shall be responsible thereof. Products held for Buyer, or stored for Buyer, shall be at the risk and expense of Buyer. Claims against Catalytic Products International for shortages must be made within 48 hours after arrival of shipment at Buyer's destination. Shipping dates are approximate and only as shows on the order acknowledgment. Shipping dates are not guaranteed. Catalytic Products International shall not be liable for delays in delivery or failure to manufacture or deliver due to causes beyond its reasonable control, including but not limited to acts of God, acts of Buyer, acts of military or civil authorities, fires, strikes, flood, epidemic, war, riot, delays in transportation or car shortages, or inability to obtain necessary labor materials, components or manufacturing facilities. In the event of any such delay, the date of delivery shall be extended for a period equal to the time lost by reason of such delay. In the event of impossibility of performance resulting from any of the above causes, Catalytic Products International shall have the right to cancel this contract without further liability to Buyer. Cancellation of any part of this order shall not affect Catalytic Products International's right to payment for any product delivered hereunder. Orders with indefinite delivery dates are accepted upon the understanding that Catalytic Products International shall have the right to fill said order as it sees fit in the course of its manufacturing schedules and to hold the goods for the Buyer's account at Buyer's expense and risk, pending receipt of definite delivery instructions.

XII. SUPPLEMENTAL CLAUSES FOR EXPORT ORDERS (a)...Currency: The prices quoted herein are payable in U.S. Dollars, unless otherwise stated in written order acknowledgment. (b)...Proof of Export: Those products which are to be purchased only for export: The Buyer agrees to furnish Catalytic Products International with proof of exportation of all or any part of such products within five months from the date of the Catalytic Products International invoices therefore, or if exportation of any part shall not have occurred within that period. Buyer agrees to pay Catalytic Products International upon demand, the amount of any manufacturer's excise tax or other tax which now or hereafter may be imposed on the sale of such products for consumption within the United States. (c)...License and Permit Requirements: (1)...Catalytic Products International will secure all export licenses and permits required by the United States Government and Buyer will furnish reasonable cooperation in acquiring such licenses and permits. If such licenses and permits are paid for by Buyer such payments will be added to the contract price. (2)...Buyer will secure all licenses and permits required by the foreign government and Catalytic Products International will furnish reasonable cooperation in acquiring such licenses and permits. The delivery schedule is contingent upon securing all necessary licenses and permits. (3)...Failure to obtain a required license or permit in sufficient time to permit delivery within the time set forth in the contract, and without the fault or negligence of the contracting parties, shall occasion an equitable adjustment in the delivery schedule.

XIII.TAXES The prices shown do not include any taxes (sales, excise, use, etc...) or any government charges. Such taxes or charges applicable to the order will be paid by the Buyer except where specifically exempt by a certificate. Only when Catalytic Products International is registered to collect applicable taxes will such taxes be added to the invoice and collected by Catalytic Products International.

XIV.NON-SOLICITATION Each party agrees that beginning on the contract acceptance date and for a period of twelve (12) months after final acceptance or earlier termination of this Agreement, it shall not (I) solicit, encourage, advise, induce or cause any employee of the other party [who worked directly or indirectly on the Services after the contract acceptance date] to terminate his or her employment with such party or any of its subsidiaries or Affiliates, nor provide any assistance, encouragement, information, or suggestion to any person or entity regarding the solicitation or hiring of any employee of the other party or any of its subsidiaries or Affiliates; or (ii) induce or attempt to induce any person, business or entity which is a supplier or customer of a party, or which otherwise is a contracting party with a party, to terminate any agreement with a party.

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