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02-8331 Hard File ScannedPage 1 of 1 Scott Anderson From: Scott Anderson [scott@anderson-boone.comj Sent: Tuesday, October 29, 2002 2:19 PM To: Tami Merriman Subject: RE: a quick question about Lasco Tami: Thanks for your assistance in obtaining a timely decision. I will inform the Lasco.administration of your decision and conditions.---Scott -----Origins! Message----- From: Tami Merriman [mailto:tmerriman@ywave.com] Sent: Tuesday, October 29, 2002 i:37 PM To: 'Scott Anderson' Subject: RE; a quick question about Lasco After some discussion, we have determined that Lasco may apply far the building permit'to enclose the resin tanks at their building; no Site Plan Review required. It is a very fine line, but we feel that the enclosure is far storage of the tanks, and not for increasing their use of the site. When Lasco is ready to submit their Building Permit Application, please have them submit plans that clearly show where the existing tanks are located, and how they will be moved, installed, and enclosed in the new enclosure. The plans must clearly show these items. tf you have any further questions, please don't hesitate to contact me. Tami 10/24/2043 Page 1 of 2 Tami Merriman From: Scott Anderson [scott@anderson-boone.com] Sent: Tuesday, October 29, 2002 2:19 PM To: Tami Merriman Subject: RE: a quick question about Lasco Tami: Thanks for your assistance in obtaining a timely decision. I will inform the Lasco administration of your decision and conditions.---Scott -----Original Message----- From: Tami Merriman [mailto:tmerriman@ywave.com] Sent: Tuesday, October 29, 2002 1:37 PM To: 'Scott Anderson' Subject: RE: a quick question about Lasco After some discussion, we have determined that Lasco may apply for the building permit to enclose the resin tanks at their building, no Site Plan Review required. It is a very fine line, but we feel that the enclosure is for storage of the tanks, and not for increasing their use of the site. When Lasco is ready to submit their Building Permit Application, please have them submit plans that clearly show where the existing tanks are located, and how they will be moved, installed, and enclosed in the new enclosure. The plans must clearly show these items. If you have any further questions, please don't hesitate to contact me. Tam i -----Original Message----- From: Scott Anderson [mailto:scott@anderson-boone.com] Sent: Friday, October 25, 2002 8:15 AM To: Tami Merriman Subject: RE: a quick question about Lasco Tami: It is my understanding that the existing tanks are located inside the facility. In my conversation with Ron Lawson, Facility Engineer, I asked about the space to be vacated by the existing tanks. He indicated that they have no plans for the use of that space and it probably would just remain dead space. While no one stated anything explicitly to me, I gathered, from my meeting with Lasco last Wednesday, that their proposed resin tank storage addition was a functional improvement rather than a response to a need for more facility space. That is my interpretation. Should you need more clarification of this particular issue, Mr. Lawson (360-458-3900) will be a better source of detailed information. --Scott -----Original Message----- From: Tami Merriman [mailto:tmerriman@ywave.com] Sent: Thursday, October 24, 2002 2:36 PM To: 'Scott Anderson' Subject: RE: a quick question about Lasco 10/24/2003 Page 2 of 2 Are the original tanks stored inside a facility, or are they outdoors at this time? What do they plan to do with the area that the existing tanks are located? Tami -----Original Message----- From: Scott Anderson [mailto:scott@anderson-boone.com] Sent: Thursday, October 24, 2002 2:34 PM To: Tami Merriman Subject: RE: a quick question about Lasco Tami: I spoke today with Ron Lawson, Facility Engineer, at the Lasco plant. In answer to your question, he told me there are existing old resin tanks located within the facility about 200 feet north of the proposed tank storage addition. These old existing tanks are planned for removal. New tanks will be located in the proposed resin storage building as replacements to, NOT in addition to, the old existing. resin storage tanks. Please let me know should you need additional information. --Scott Anderson -----Original Message----- From: Tami Merriman [mailto:tmerriman@ywave.com] Sent: Wedhesday, October 23, 2002 4:59 PM To: scoff@anderson-boone.com Subject: a quick question about Lasco Mr. Anderson: A quick question about the resin tank enclosure at Lasco. I need to know if the resin tanks are currently located at the site, and if so, where at the site, or are they bringing new tanks in? Thanks Tami 10/24/2003 ~; .fix . ANDERSON & BO~O`NE '-ARCHITE'~ T 'I't~f.`.S. October 24, 2003 City Of Yelm Community Development Department 105 Yelm Avenue West PO Box 479 Yelm, WA 98597 Fax 360-458-3144 ATTN: Grant Beck, Director RE: Lasso Bathware Resin Storage Tank Addition Dear Mr. Beck: ~~~EIV~D O CT 2 7 2003 Thank you for your letter of October 23, 2003. I must admit that your stated requirement for Site Plan Review Approval for this project was quite a surprise. In mid October of 2002, I met with Tami Merriman and Gary Carlson at City Hall to discuss the City processes that would be needed for this project. There was some question as to whether Site Plan Review and SEPA review processes were required. I understood at that time that a SEPA review would only be required if the Site Plan Review process was required. I requested a specific determination of that potential requirement. My answer arrived on October 29, 2003 by e-mail from Tami Merriman (copy attached). She stated, in part, "After some discussion, we have determined that Lasso may apply for the building permit to enclose the resin tanks at their building, no Site Plan Review required." We informed Lasso of the City determination at that time and proceeded with the project based on the City's decision. On behalf of Lasso Bathware, we respectfully request your reconsideration of the recent decision regarding the need for the Site Plan Review process for this project so that the Building Permit review can continue. Thank you very much for your consideration of this matter. Sincerely, And on & Boone Architects AIA, PS Scott E. Anderson 525 Columbia St NW, Suite 201 Olympia, WA 98501 (360)754-7766 Fax (360) 754-1357 ~~~ T~p~ CLty Of 'elm Community Development Department 105 Yelm Avenue West P.O. Box 479 YELM Yelm, WA 98597 ~IIN-iM111GTON October 23, 2003 Scott Anderson Anderson and Boone Architects AIA, PS 525 Columbia Street NW, Suite 201 Olympia, WA 98501 Re: Lasco Bathware Resin Storage Tank Addition Dear Mr. Anderson: The Community Development Department has reviewed the building permit application you submitted on behalf of your client, Lasco Bathware, for a resin storage tank building at the site of Lasco's facility in Yelm on N.P. Road. As part of the building permit review, the application was reviewed for consistency with the Environmental Checklist and SEPA threshold determination that the City had issued for Lasco to modify the third polyester spray station with equipment and storage to enable spray application of polyurethane. Neither the environmental checklist nor any of the supporting documents indicate that a new building was to be constructed as part of the project. In fact, On February 21, 2003, Viktor Prismantas, Lasco's agent, informed the City that the project was on hold and that they were still investigating the possibility of enclosing the storage tank area. Mr. Prismantas was informed at that time that the Environmental Determination would remain effective provided the project was not changed or expanded, such as enclosing the tanks. In order to issue a building permit with the new proposed building, the following would be required: Site plan review approval. This land use approval is required for any new or expanded commercial or industrial use in the City of Yelm. As part of the site plan approval process, the property would be have to meet the current requirements of Yelm's Development Guidelines. The development guidelines can be reviewed online at www.ci.yelm.wa.us. An updated SEPA threshold determination may be required as part of this process. Civil plans showing all site work, any changes to the existing storm water drainage system, and how additional stormwater runoff will be accommodated, ~:360~ ~sx-R~~nB (360) -158-.314.1 FAX wrau~. c i.ye!»~. ma. ux including additional stormwater from paved parking areas and interior access lanes. The Site Plan Review committee meets every Wednesday afternoon for pre-submission conferences. If you would like to schedule apre-submission meeting, or if you have any questions, please contact the Community Development Department at (360) 458-3835. Gr t Beck, C~if'ector partment of Community Development t~~`~ October 23, 2003 Page 2 of 2 ~ ... ~' ,,~ , .,f 1?; STATE OF `A'ASHINGTON DEPARTMENT OE ECOLOGY P.O. Box 47775 • Olympia, Washington 98504-7775 • (360) 40: -6300 March 5, 2003 Ms. Tami Merriman City of Yelm P.O. Box 479 Yelm, WA 98597 Dear Ms. Merriman: ~~ f `~ ,~~ ~. ~.~r ., r - I _._ _...r.~ r ~ L~ MAR 1 ~ goo? Your address is in the watershed Thank you for the opportunity to comment on the mitigated determination ofnon-significance for the proposed Polyurethane (SEPA 8331) modification of the their polyester spray station at Lasco's facility with equipment and storage capacity to enable spray application of Polyurethane, located at 801 NP Road, as proposed by Lasco Bathware. We reviewed the environmental checklist and have the following comments: Water Ouality: Erosion control measures must be in place prior to any clearing, grading, or construction. These control measures must be effective to prevent soil from being carried into surface water by stormwater runoff. Sand, silt, and soil will damage aquatic habitat and are considered pollutants. Any discharge of sediment-laden runoff or other pollutants to waters of the state is in violation of Chapter 90.48, Water Pollution Control, and WAC 173-201A, Water Quality Standards for Surface Waters of the State of Washington, and is subject to enforcement action. During construction, all releases of oils, hydraulic fluids, fuels, other petroleum products, paints, solvents, and other deleterious materials must be contained and removed in a manner that will prevent their discharge to waters and soils of the state. The cleanup of spills should take precedence over other work on the site. Hazardous Waste: Please Refer To: "A Guide For Fiberglass Operations" On the Internet at: llttp:i~~~l~~«-.ec~-.«~a.t7ovi'I'rograms'bti~-tr;`P2lsectars;'frl~~uidel.html or you may contact: Mr. Bob Goldberg at (360) 407-6350. ~~ Just a reminder that the City of Yelm and its contractors should be aware that any releases of hazardous materials to the environment or waters of the state need to be reported to the Department of Ecology Spills Program immediately. Ms. Tami Merriman March 5, 2003 Page 2 If you have any questions or would like to respond to these comments, please call Ms. Margaret Hill with the Water Quality Program at (360) 407-0246, Mr. Hugh O'Neill with the Hazardous Waste and Toxics Reduction Program at (360) 407-6354, and/or Mr. Eric Heinitz with the Spills Program at (360) 407-6375 Sincerely, Jeri Berube Administrative Coordinator Southwest Regional Office JB:lmc(03-0927) cc: Lasco Bathware, Applicant Margaret Hill, SWRO/WQ Hugh O'Neill, SWRO/HWTR Eric Heinitz, SWRO/Spills MAR-05-2003 WED 12:07 PM DOE SW REGIONAL OFFICE FAX N0, 3604076305 4 l O .LI Y J J~ tj Y ~~~ lMtl7 H STAY[ Of WASHINGTON nF..PnRTMENT Of CCt:)I.OGY P.U. Box 47775. Olympia, Washington 91lSU4.777.5 • (360) a0T-G30U March 5, 2003 P. Ol Ms, Tami Merriman t~"~ • ~ ~~'-- ' ~ ~ •' ~~ Crty of Yclm ° .. ~y'~~ ;'~ . ; ~, Your address y~1:. .`r~;.~ ~. ','., '`" ~•~ ~ is in the P.O..f3ux 479 ~ ~ .~... Yclm, WA 98597 'i'' , '-.I'~,i- }, 14°~6~z~t,t.~~rY~'t~ ~~ ~ ~I watershed -i °,: -•,..,.~ Dear Ms. Merriman: C.~.:..V,,,""`~ Thank you for the opportunity to cumme;nt on the mtttgated determination ofnun-significance fur the: proposed Polyurethane (SEYA 8331 }modification o.f the their polyester spray station at Lasco's facility with equipment and storage capacity to enable spray application of Polyurethane, located at 801 NP Road, as proposed by Lasco aathware. We rcvie;we;d the environmental checklist and have the following comments: Water Quulety: Erosion control measures must he in place prior to any clearing, grading, or construction. Thcsc control measures must be effective to prevent soil from being carried into surface water by slormwater runoff. Sand, silt, and soil will damage aquatic habitat and are considered pollutants. Any discharge of sediment-laden runoff or other pollutants to waters of the state; is in violation of Chapter 90.48, Water Pollution Control, and WA(' 173-201 A, Water Quality Standards for Surface Waters of the State of Washinbton, and is subject to enforcement action. .During construction, all relc;ascs of oils, hydrnttltc fluids, tiiels, other pctrulc;um products, paints, solvents, and other deleterious materials must be contained and removed in a manner that will prevent their discharge to waters and soils of the state. The cleanup of Spills should take precedence over ether 'work on the site. Hazardous V4'aste: Please Rc;fer "l'o: "A Guide For Fiberglass Operations" Un the Internet at: F1ttp://www.ecy_wa, ~w/l'ru>:rams/h.wtr/1.'2/scctgrs/fr~~gu~del .htnil or you may contact: Mr Boh Goldberg at (360) 407-6350. Spills: Just a reminder that the City of Yelm and its contractors should be aware that any releases of hazardous materials to the environment or waters of the state need to be reported to the Ucpartment of Ecology pis rogram immediately. °~ ~ "~ ' Post-it• Fax Note 7671 081e pages To '"'^ R !~ +-~- From Co i0ept Co. P31a18 N Photle >+ fax o ~~' 3~ Fex p _. ~ U~ 4~ MAR-05-2003 WED 12 07 PM DOE SW REGIONAL OFFICE FAX N0, 3604076305 P, 02 Ms. Tami Merriman March 5, 2003 Page 2 !f' you have any questions or would like to respond to these comments, please cal! Ms. Margaret Hill with the Water Quality Program at (360) 407-0246, Mr. Hugh O'Neill with the Hazardous Waste and Toxics Reduction Program at (360} 407-6354, and/or Mr. Eric Heiniu with the Spills Program at {360}-407-6375 Sincerely, Seri Be~ube Administrative Coordinator Southwest Regional Office JB:lmc(03-0927) cc' Lasco Bathware, Applicant Margaret Hill, SWRO/WQ Hugh O'Neill, SWROJHWTR Eric Heinit2, SWRO/Spills C~R~~ ~~ ~~ l.~" 2~~i~~3 SEPA NO: 8331 MITIGATED DETERMINATION OF NONSIGNIFICANCE Proponent: LASCO Bathware Description of Proposal: Modify the third polyester spray station at LASCO's facility with equipment and storage capacity to enable spray application of polyurethane. Location of the Proposal: 801 NP Road, Yelm, WA 98597 Section/Township/Range: S 19, T 17N, R 2E. Threshold Determination: The City of Yelm as lead agency for this action has determined that this proposal does not have a probable significant adverse impact on the environment. Therefore, an environmental impact statement (EIS) will not be required under RCW 43.21C.030(2)(c). This decision was made after review of a completed environmental checklist and other information on file with the lead agency. This information is available to the public on request. Conditions/Mitigating Measures: SEE ATTACHED Lead agency: Responsible Official Date ck, -City of Yelm Grant Beck, Community Development Director Friday, February 21, 2003 5:00 P.M. March 7, 2003 nity Development Director This Mitigated Determination of NonSignificance is issued pursuant to Washington Administrative Code 197-11- 340(2). The City of Yelm will not act on this proposal prior to 5:00 p.m., March 7, 2003. Comments must be submitted to Tami Merriman, Community Development Department at, City of Yelm, 105 Yelm Ave. W., P.O. Box 479, Yelm, WA 98597, by 5:00 p.m., March 7, 2003. You may appeal this determination to the City of Yelm Hearing Examiner, at above address, by submitting a written appeal no later than 5:00 p.m., March 14, 2003. You should be prepared to make specific factual objections. Contact Grant Beck, Community Development Director about the procedures for SEPA appeals. This MDNS is not a permit and does not by itself constitute project approval. The applicant must comply with all applicable requirements of the City of Yelm prior to receiving construction permits which may include but are not limited to the City of Yelm Comprehensive Plan, Zoning Title (17), Critical Areas Ordinance (14.08), Storm water Drainage Design and Erosion Control Manual (DOE), Uniform Building Code, State Environmental Policy Act (SEPA) Title (14), Road Design Standards, Platting and Subdivision Title (16), and the Shoreline Master Program. DO NOT PUBLISH BELOW THIS LINE Published: Nisqually Valley News, Friday, February 21, 2003 Posted in public areas: Friday, February 21, 2003. Copies to: -Dept. of Ecology w/checklist February 19, 2003. All agencies/citizens on SEPA mailing list and adjacent property owners. ATTACHMENT SEPA CASE NO.: 8331 This Mitigated Determination of Non Significance is based on the project as proposed and impacts and mitigation reflected in the following; Environmental Checklist (dated 12/26/02) Draft determination from Olympic Region Clean Air Agency, dated January 27, 2003 And the following conditions: 1. The applicant shall provide to the City of Yelm, verification from the Olympic Region Clean Air Agency, that emissions into the air from this project are acceptable. 2. The applicant shall provide to the City of Yelm, a Hazardous Spill Containment Plan approved by Thurston County. SHELLY BADGER MAYOR ADAM RIVAS CITY ADMINISTRATOR GARY CARLSON T MI MERRIMAN BUILDING OFFICIAL PLANNING TECHNICIAN GRANT BECK COMMUNITY DEVELOPMENT DIRECTOR CHIEF MARK KING THURSTON CO FIRE DISTRICT #2 P.O. BOX 777 YELM, WA 98597 PUGET SOUND ENERGY ATTN: BARRY LOMBARD 3130 S 38T" ST TACOMA, WA 98409-5615 TC ENVIRONMENTAL HEALTH ATTN: PHIL BRINKER 2000 LAKERIDGE DR SW OLYMPIA, WA 98502 THURSTON CO. PLANNING DEPT. 2000 LAKERIDGE DR SW OLYMPIA, WA 98502 THURSTON CO. COMMUNICATIONS 2000 LAKERIDGE DR SW OLYMPIA, WA 98502 ORCAA JIM WILSON 2490-B LIMITED LANE NW OLYMPIA WA 98502 STEVE GILBERT PARAMETRIX P.O. BOX 460 SUMNER, 98390 YELM TELEPHONE CO. ATTN: KEN BECKMAN P.O. BOX 593 YELM, WA 98597 WSDOT OLYMPIC REGION P.O. BOX 47440 OLYMPIA, WA 98502 l~ NISOUALLY RIVER MGMT COUNCIL ATTN: PETER MOULTON PO BOX 47775 OLYMPIA WA 98504 NISOUALLY INDIAN TRIBE ATTN: GEORGE WALTERS 4820 SHE-NA-NUM DR SE OLYMPIA, WA 98503 INTERCITY TRANSIT ATTN: DENNIS BLOOM P.O. BOX 659 OLYMPIA, WA 98507 THURSTON CO. ROAD DIV 9605 TILLEY ROAD SW OLYMPIA WA 98512 TODD STANCIL YELM POLICE DEPT. JIM GIBBON YELM CITY ENGINEER CHIEF RITA HUTCHESON THURSTON CO FIRE DISTRICT #2 P.O. BOX 777 YELM, WA 98597 PUGET SOUND ENERGY ATTN: DENNY LENSEGRAV 2711 PACIFIC AVE SE OLYMPIA WA 98501 DEPT OF ECY SW REG OFFICE ENV REVIEW: BARB RITCHIE P.O. BOX 47375, MS 4775 OLYMPIA, WA 98504-6811 THURSTON COUNTY DEVELOPMENT REVIEW 2000 LAKERIDGE DR SW BLDG 1 OLYMPIA WA 98502 DEPT OF ECOLOGY ENVIRONMENTAL REVIEW SECTION P.O. BOX 47703 OLYMPIA WA 98504-7703 YELM COMMUNITY SCHOOLS ATTN: ERLING BIRKLAND P.O. BOX 476 YELM, WA 98597 SEPA CENTER DEPT OF NATURAL RESOURCES PO BOX 47015 OLYMPIA WA 98504-7015 THURSTON CO PUBLIC WORKS LASCO BATHWARE MARK V GOODIN PE ATTN: DALE RANCOUR 801 NP ROAD ORCAA 2404 HERITAGE CT SUITE A YELM WA 98597 2490-B LIMITED LANE OLYMPIA WA 98502 OLYMPIA WA 98502 SEPA NO: 8331 MITIGATED DETERMINATION OF NONSIGNIFICANCE Proponent: LASCO Bathware Description of Proposal: Modify the third polyester spray station at LASCO's facility with equipment and storage capacity to enable spray application of polyurethane. Location of the Proposal: 801 NP Road, Yelm, WA 98597 SectionlTownship/Range: S 19, T 17N, R 2E. Threshold Determination: The City of Yelm as lead agency for this action has determined that this proposal does not have a probable significant adverse impact on the environment. Therefore, an environmental impact statement (EIS) will not be required under RCW 43.21C.030(2)(c). This decision was made after review of a completed environmental checklist and other information on file with the lead agency. This information is available to the public on request. Conditions/Mitigating Measures: SEE ATTACHED Lead agency: Responsible Official: Date Cot~r Co City of Yelm Grant Beck, Community Development Director Friday, February 21, 2003 5:00 P.M. March 7, 2003 unity Development Director This Mitigated Determination of NonSignificance is issued pursuant to Washington Administrative Code 197-11- 340(2). The City of Yelm will not act on this proposal prior to 5:00 p.m., March 7, 2003. Comments must be submitted to Tami Merriman, Community Development Department at, City of Yelm, 105 Yelm Ave. W., P.O. Box 479, Yelm, WA 98597, by 5:00 p.m., March 7, 2003. You may appeal this determination to the City of Yelm Hearing Examiner, at above address, by submitting a written appeal no later than 5:00 p.m., March 14, 2003. You should be prepared to make specific factual objections. Contact Grant Beck, Community Development Director about the procedures for SEPA appeals. This MDNS is not a permit and does not by itself constitute project approval. The applicant must comply with all applicable requirements of the City of Yelm prior to receiving construction permits which may include but are not limited to the City of Yelm Comprehensive Plan, Zoning Title (17), Critical Areas Ordinance (14.08), Storm water Drainage Design and Erosion Control Manual (DOE), Uniform Building Code, State Environmental Policy Act (SEPA) Title (14), Road Design Standards, Platting and Subdivision Title (16), and the Shoreline Master Program. ----------------------------------------- DO NOT PUBLISH BELOW THIS LINE Published: Nisqually Valley News, Friday, February 21, 2003 Posted in public areas: Friday, February 21, 2003. Copies to: -Dept. of Ecology w/checklist February 19, 2003. All agencies/citizens on SEPA mailing list and adjacent property owners. ATTACHMENT SEPA CASE NO.: 8331 This Mitigated Determination of Non Significance is based on the project as proposed and impacts and mitigation reflected in the following: • Environmental Checklist (dated 12/26/02) • Draft determination from Olympic Region Clean Air Agency, dated January 27, 2003 And the following conditions: 1. The applicant shall provide to the City of Yelm, verification from the Olympic Region Clean Air Agency, that emissions into the air from this project are acceptable. 2. The applicant shall provide to the City of Yelm, a Hazardous Spilf Containment Plan approved by Thurston County. z "~ Yx ~ M^~' ~ ~,%~ ~; ~ ~~ ~~~ NOTICE OF CONSTRUCTION FINAL DETERMINATION Issued by Olympic Region Clean Air Agency Issued to Lasco Bathware Prepared on January 27, 2003 Project Modify the third polyester spray station at Lasco's facility located at 801 Northern Pacific, in Yelm, with equipment and storage capacity to enable spray application of polyurethane. 02NOC276 File: 250 RC: OP1 Cnty: 67 Srce: 10 1. FINAL DETERMINATION DRAFT ORCAA staff recommends conditional approval of the Notice of Construction (NOC) application by Lasco Bathware to modify the third polyester spray station at Lasco's facility in Yelm, with equipment and material storage capacity to enable spray application of polyurethane. The recommended conditions of approval are specified in Section 6 of this report, and are recommended for inclusion in a final Order of Approval. Once issued, conditions in the final Order of Approval will be enforceable by ORCAA. Staff's recommendation to approve this project is based on the following findings and conclusions: 1. Maximum emission rates from proposed new sources of air pollution are likely to comply with applicable federal, ORCAA and Washington air regulations and standards; 2. Proposed air pollution controls meet the State's requirement that Best Available Control Technology (BACT) be employed to control emission increases from new sources; 3. Ambient air impacts are not likely to cause or contribute to any violation of an ambient air quality standard; and 4. Projected toxic air pollutant (TAP) impacts were found to be less than the Acceptable Source Impact Levels (ASILs) prescribed under the Washington Air Toxics regulation. The following report provides a brief project description, a summary of determinations with respect to applicable regulations and standards, and describes staff's recommended conditions of approval. Other details regarding description of the proposed project are provided in the associated NOC application (02NOC276). 2. PROJECT DESCRIPTION AND BACKGROUND Lasco Bathware Inc. proposes to modify the existing "gelcoat" production line at their facility in Yelm, Washington, by adding material storage structures and equipping the third lamination station (ID#s A8 & A9) with two new day tanks and new spray equipment. The proposed modifications and new equipment only involve the third lamination station. Production operations and equipment prior to and after the third lamination station will remain unchanged. The modifications will provide Lasco the flexibility to incorporate a polyurethane layer as the third lamination in the composite structure of its products. It is Lasco's intent to completely eliminate using polyester resin in the third lamination. The proposed polyurethane material will consist of a one to one mixture of "polyol" resin and a solution containing isocyanate. The isocyanate solution contains 4', 4'- methylene diisocyanate (MDI) and polymeric methylene diisocyanate isomer (PMDI), and has a composition of 45% MDI and 50% PMDI. MDI is both a federally listed hazardous air pollutant (HAP) and a toxic air pollutant (TAP) regulated under Washington air regulations for new toxic air pollutant sources (WAC 173-460). According to the MSD sheet for the material, MDI is only HAP/TAP constituent of the Urethane.02NOC276.FD Page 1 of 13 isocyanate solution. According to the Material Safety Data Sheet for the polyol resin, it does not contain any volatile HAPs or TAPs. Lasco will construct a storage rack for storing totes of the polyol resin and isocyanate. The storage rack will be located within the main production building adjacent to the main production line referred to as the "gelcoat" production line. The proposed storage rack will be capable of storing up to 40 storage totes. Each tote will weigh 2,500 pounds and will contain 270 gallons of either resin or isocyanate. A staging rack and two new day tanks, one for resin and one for isocyanate, will be constructed directly adjacent to the third lamination spray station. The day tanks will hold the resin and isocyanate prior to spray application. Each will have a 350 gallon holding capacity. The day tanks will be covered and vented to the building air space. Day tanks will be gravity filled from storage totes in a batch-wise fashion. A tote will be placed above a day tank in the staging rack, connected to the day tank and then allowed to gravity flow into the day tank. During filling, vapors in the day tank will be vented into the building. Storage totes will be fitted with special moisture knock-out filters while being offloaded into the day tanks to remove any moisture that may react with the isocyanate. Empty storage totes will be closed and periodically sent back to the material vendor for refilling. Emissions of MDI from the displacement of vapors in the day tanks were accounted for in emission calculations (see below) and were determined to be insignificant. During production, resin and isocyanate will be pumped from their respective day tanks to special mixing heads that mix the polyol resin and isocyanate to form the polyurethane within the head just prior to spraying. The polyurethane is then spray applied to the surface of the composite within the third lamination station. The reaction of the polyol resin with the isocyanate is exothermic resulting in elevated temperatures on the surface of the polyurethane lamination up to 140 °F. Curing of the polyurethane is rapid with a tack time of 30 to 40 seconds. Emissions resulting from spray application of polyurethane were accounted for (see below) and make up the bulk of the emissions increase proposed. There will be no physical modifications to the third lamination spray station except for equipping it with spray equipment capable of mixing and delivering the two-part polyurethane and constructing the staging rack adjacent to the station. Emissions from the third lamination station will be captured by the existing capture system and exhausted directly to the outside air through the four existing 75' exhaust stacks. Production operations and equipment prior to and after the third lamination station will remain unchanged. Urethane.02NOC276.FD Page 2 of 13 DRAFT TABLE 2.1. EQUIPMENT SPECIFICATIONS Resin/isocyanate Storage . Rack capable of storing 40 totes Tote Rack Totes capable of storing 270 gallons of either resin or isocyanate • Totes will be com letel sealed not vented Burin stora e Day Tanks Two, 350-gallon day tanks • Com letel enclosed and vented to buildin airs ace S ra E ui ment Air Pollution Controls Pollution prevention measures only Pro osed: 3. EMISSIONS Storage, transport and spray application of the two-part polyurethane proposed by Lasco will result in minor emissions of 4', 4'-methylene diisocyanate (MDI). MDI is not currently emitted at the Lasco facility in Yelm and, therefore, any emissions of MDI resulting from this proposal constitute an emissions increase. MDI is both a federally listed hazardous air pollutant (HAP) and a toxic air pollutant (TAP). regulated under Washington air regulations for new toxic air pollutant sources (WAC 173-460). MDI is also a volatile organic compound (VOC) and, therefore, subject to the existing plant- wide limit on Lasco's VOC emissions (Lasco AOP condition 4.25). MDI emission rate estimates were provided in Lasco's NOC application. Lasco's MDI emissions estimates were based on calculation methods and procedures recommended by the Alliance for the Polyurethane Industry (API) in their guidance document titled MDI/Polymeric MDI Emissions Reporting Guidelines For the Polyurethane Industry (API, 2002). The calculation methods recommended by API in this guidance document are available from EPA's web site, but are currently under review by the U.S. EPA. MDI emission rates were estimated independently by ORCAA staff (see Table 3.1 below). Attachment 1 contains staffs emission calculations including descriptions of assumptions made and methods used. Staff's calculations also relied on the calculation methods recommended by the API in their guidance document. However, staff s calculations differed from Lasco's in that the equations modeling spray application of polyurethane were used where Lasco's calculations relied on the equations modeling evaporation losses from an open mold surface. Staff's main reason for using the spray coating equations was that Lasco's proposed polyurethane process will rely on spray application of the polyurethane on to molds. Since the equations for spray coating result in much higher estimated MDI emissions compared to the open mold equations, Staff believes spray coating influences will dictate the rate of emissions. In addition to emissions from spray coating, staff s estimates include fugitive losses from storing the polyol resin and isocyanate, and day tank working losses. Estimated fugitive emissions and emissions from day tank working losses are both small compared to emissions from spray application of the polyurethane. Staff's annual emissions estimates are based on Lasco's estimated maximum potential use rate of 2 million pounds of polyurethane per year. Hourly and daily emissions were based on the maximum potential use rate and Lasco's current operating schedule. Urethane.02NOC276.FD Page 3 of 13 DRAFT TABLE 3.1. AIR POLLUTANT EMISSION INCREASES Source of Emission Factors Used Daily Emission Rates (pounds/hour) Annual Emissions ounds/yr MDI/Polymeric MDI Emissions Reporting MDI Guidelines For the Polyurethane Industry (TAP,_HAP,_and a VOC) (AP1, 2002) 0.0875 542 Notes: 1. VOC stands for vo-atile organic compounds. 2. HAP designates a hazardous air pollutant pursuant to Section 112 of the Federal Clean Air Act. 3. TAP designates a toxic air pollutant pursuant to Chapter 173-460 of the Washington Administrative Code. 4. NEW SOURCE APPROVAL CRITERIA The following subsections document staff's conclusions with respect to applicable new source review approval requirements and criteria pursuant to the Washington State Clean Air Act (Chapter 70.94 RCW). 4.1 NEW SOURCE REVIEW APPLICABILITY [ORCAA Article 7 8~ WAC 173-400- 110] The term "New Source Reviev~' (NSR) refers to the regulatory process designed to facilitate review and evaluation of air implications prior to construction, installation, establishment or modification of an air contaminant source. The goal of NSR is to assure sources of air pollution are established in a manner that assures compliance with applicable air regulations and standards, including the ambient air quality standards. NSR is conducted by the local air regulatory authority with jurisdiction in the area, which, in this case, is ORCAA. Approval is contingent on a final determination by the air regulatory authority that the proposed source will likely comply with all applicable air regulations and standards. Both State and ORCAA NSR regulations are applicable in reviewing and approving new sources and modifications in ORCAA's jurisdiction since ORCAA's regulations are not yet contained in the State's Implementation Plan (SIP). WAC 173-400-110 contains the State of Washington NSR procedures and requirements. Article 7 of ORCAA's Regulation 1 contains NSR procedures and requirements unique to ORCAA. Both regulations require a Notice of Construction (NOC) application to be filed with and approved by ORCAA prior to establishing, constructing, installing or modifying any source of air pollution in ORCAA's jurisdiction. 4.2 PUBLIC NOTICE AND COMMENT REQUIREMENTS [ORCAA 1.7.04] Article 7 of ORCAA's Regulation 1 specifies public notice and involvement requirements associated with NOC approvals. A 30-day public notice and comment period is required prior to approval or denial of any NOC if the proposed new source or modification will result in emissions greater than any of the thresholds stated in Urethane.02NOC276.FD Page 4 of 13 DRAFT Regulation 1 Section 7.04. Also, ORCAA has authority to require public notice and an opportunity for a public hearing for cases likely to generate significant public interest. In this case, estimated emission increases attributable to Lasco's proposal to use polyurethane are less than the triggering thresholds in Regulation 1 Table 7.03a (see Table 4.1 be-ow). ORCAA staff is not aware of any current concern over air pollution sources in the project area, nor any general concern over the type of source being proposed. Therefore, staff s determination is that public notice and involvement requirements are not triggered for this case. TABLE 4.1. PUBLIC NOTICE APPLICABILITY THRESHOLDS Thresholds Triggering Public Noticing Annual Emissions Requirements Controlled tons/ r tons/ r NOX 0 40.0 CO 0 100.0 OC (as CH4) 0.271 40.0 PM 0 _25~_~__....._........_ ................_...... S02 0 40.0 4.3 STATE ENVIRONMENTAL POLICY ACT (SEPA) The State Environmental Policy Act (SEPA) under Chapter 197-11 WAC is intended to provide information to agencies, applicants, and the public to encourage the development of environmentally sound proposals. The goal of SEPA is to assure that significant impacts are mitigated. Lasco's proposal to modify the third polyester spray station with equipment to enable spray application of polyurethane is subject to SEPA review requirements since the action will require permits and approvals by other agencies including ORCAA, and since it may result in environmental impacts including air impacts. Lasco initiated the SEPA process by submitting a project description and Environmental Checklist to the City of Yelm, the agency serving as the "Lead Agency" for SEPA. Yelm is currently reviewing Lasco's Environmental Checklist. ORCAA can not issue a Final Determination on this case until the SEPA review process has been completed. 4.4 NEW SOURCE APPROVAL CRITERIA [WAC 173-400-113] New source approval criteria are found in Sections 112 and 113 of Chapter 173-400 WAC. Whether the criteria of Section 112 or Section 113 apply depends on the existing air quality of the proposed project site with respect to both the national and state ambient air quality standards. Ambient Air Quality Standards (AAQS) are standards for the ambient air, which have been established by law to protect human health and welfare. Air pollutants for which standards have been developed are referred to as "criteria" air pollutants. Urethane.02NOC276.FD Page 5 of 13 DRAFT Section 112 contains the approval criteria for new sources and modifications proposed in areas designated as "non-attainment" with respect to any one or more of the national or state ambient air quality standards. A "non-attainment" area is an area formally designated as not meeting the national or state ambient air quality standard for one or more of the criteria air pollutants. Section 113 contains the approval criteria for areas that are designated as either "attainment" or "unclassified" with respect to all of the national and state ambient air quality standards. A designation of "attainment" means that ambient monitoring data has confirmed that the area currently meets the national and the state ambient standards for a particular criteria air pollutant. Areas that are not required to monitor ambient air quality with respect to a particular pollutant are designated as "unclassified" for that pollutant. Lasco is located in the City of Yelm, which is within Thurston County. ORCAA has conducted ozone, carbon monoxide and particulate ambient air quality monitoring in Thurston County. To date, Thurston County is designated as "in attainment" of the ambient air quality standards for particulate matter less than 10 microns in diameter (PM10). Thurston County is "unclassified" with respect to all other criteria air pollutants. Therefore, since there are no "non-attainment" areas within Thurston County, the new source review and approval criteria under WAC 173-400-113 apply. There are five new source approval criteria under WAC 173-400-113: 1. The proposed new source or modification will comply with all applicable emission standards including federal new source performance standards (NSPS), national emission standards for hazardous air pollutants (NESHAPs), emission standards adopted under chapter 70.94 of the Revised Code of Washington (RCW) and, for sources regulated by an authority, the applicable emission standards of that authority (WAC 173-400-113(2)(a)); 2. The proposed new source or modification will utilize Best Available Control Technology (BACT) for all pollutants not previously emitted or whose emissions would increase as a result of the new source or modification (WAC 173-400- 113(2)(b)); 3. Allowable emissions from the proposed new source or modification will not delay the attainment date for an area not in attainment nor cause or contribute to a violation of any ambient air quality standard (WAC 173-400-113(2)(c)); 4. If the proposed new source is a major stationary source or the proposed modification is a major modification for purposes of the Prevention of Significant Deterioration (PSD) program described in WAC 173-400-141, it meets all the requirements of that chapter including requirements for visibility protection (WAC 173-400-113(2)(d)); and, 5. If the proposed new source or modification will emit any TAPs regulated under Chapter 173-460 WAC, the source meets all applicable requirements of that program (WAC 173-400-113(2)(e)). Urethane.02NOC276.FD Page 6 of 13 DRAFT Based on review of Lasco's NOC application, staff's conclusion is that their proposal to modify the third polyester spray station with equipment to enable spray application of polyurethane meets all of the criteria for approval under WAC 173-400-113. Staff's conclusions with respect to each criterion will be discussed separately in the following sections. 4.4.1 APPROVAL CRITERIA #1-COMPLIANCE WITH APPLICABLE EMISSIONS STANDARDS: WAC 173-400-113(1) requires a finding that that a new source or modification will comply with all applicable emission standards federal including new source performance standards (NSPS), national emission standards for hazardous air pollutants (NESHAP), emission standards adopted under chapter 70.94 of the Revised Code of Washington (RCW), and any applicable emissions standard of ORCAA. The proposal to modify the third polyester spray station with equipment to enable spray application of polyurethane will be subject to both the State of Washington and ORCAA's emission standards. ORCAA and State of Washington emission standards prohibiting odors, fugitive dust and nuisances will also apply. There are no federal performance standards that will apply. A summary of air regulations and standards applicable to Lasco's proposal are shown in Table 4.2 below. Based on information provided in their NOC application, staff has determined that Lasco's proposal will likely comply with all applicable federal, state, and ORCAA emission standards. Therefore, staff's determination is that the first of new source approval criteria found in WAC 173-400-113 is confirmed. Urethane.02NOC276.FD Page 7 of 13 DRAFT TABLE 4.2. APPLICABLE AIR REGULATIONS AND STANDARDS CATEGORY REGULATION BRIEF DESCRIPTION Annual Title V ORCAA Reg. 1, Article Provides local air pollution agencies the authority to assess an annual Fees 6 fees to ma'or sources sub'ect to Title V of the federal clean Air Act. Concealment and WAC 173-400-040(7) Prohibits the installation or use of any means which conceals or Masking ORCAA Reg. 1, Sect. masks an emission of an air contaminant which would otherwise 9.12 violate an rovisions of this cha ter. Control ORCAA Reg. 1, Sect. Requires air contaminant sources to keep any process and/or air Equipment 9.16 pollution control equipment in good operation and repair. Maintenance and Re air Emission WAC 173-400-105(1) Requires maintenance of records relating to air pollutant emissions Inventory ORCAA Reg. 1, Sect and submittal of an annual emissions inventory if required. 5.03 Emissions WAC 173-400-040(5) Prohibits emissions of any air contaminant from any source which are Detrimental to ORCAA Reg. 1, Sect. detrimental to persons or property. Persons or 9.23 Pro e Fallout Prohibition WAC 173-400-040(2), Prohibits particulate emissions from any source to be deposited, ORCAA 1.9.05(e) beyond the property under direct control of the owner or operator of the source, in sufficient quantity to interfere unreasonably with the use and en'o ment of the roe u on which the material was de osited. Fugitive Dust WAC 173-400-040(8) Requires reasonable precautions be taken to prevent fugitive dust Sources ORCAA Reg. 1, Sect. from becoming airborne. 9.05 c Fugitive WAC 173-400-040(3), Requires that reasonable precautions be taken for controlling fugitive Emissions emissions. Particulate WAC 173-400-060 Prohibits emissions from any process unit in excess of 0.1 grain/dscf. Standards for ORCAA Reg. 1, Sect. EPA test methods from 40 CFR Appendix A shall be used should Process units 9.05 a demonstration of com liance be re uired. New Source ORCAA 1.7; Approval by ORCAA through a NOC application is required prior to Review (NSR) WAC 173-400-110; establishing or constructing any new source of emissions, or Requirements WAC 173-400-114 modifying an existing source. Addition of another production line, removal of a control device, or substantial modification of the existing s ra booths would tri era licabili of NSR. Odors WAC 173-400-040 (4) Requires use of "recognized good practices and procedures" for State Regulation control of any odor which may unreasonably interfere with the use or en'o ment of another erson's roe Odors ORCAA Reg. 1, Sect. Requires that reasonably available control techniques and measures ORCAA 9.11 be used to control odor-bearing gases. Regulation Prohibits emissions of any odor which unreasonably interferes with another erson's use and en'o ment of their roe Record Keeping ORCAA Reg. 1, Article Requires the following: and Reporting 13 1. Maintenance of records on the nature and amounts of emissions and other related information as deemed necessary by ORCAA; 2. Re ortin of emissions to ORCAA u on re uest. Visible Emissions WAC 173-400-040(1), Prohibits emissions for more than 3 minutes in any one hour of a gas (Opacity) ORCAA 1.9.03 stream containing air contaminants which exhibit greater than 20% opacity as determined by DOE Method 9A visual readings or, if required, an opacity monitoring device certified in accordance with 40 CFR Part 60, A endix B, Pertormance S ecification 1. Urethane.02NOC276.FD Page 8 of 13 DRAFT 4.4.2 APPROVAL CRITERIA #2- BEST AVAILABLE CONTROL TECHNOLOGY (BACT): WAC 173-400-113(2) requires new sources of air pollution and modifications to existing sources of air pollution to use Best Available Control Technology (BACT) to control all pollutants not previously emitted, or those for which emissions would increase as a result of the new source or modification. BACT is defined in Chapter 173-400 as, "an emission limitation based on the maximum degree of reduction for each air pollutant subject to regulation under chapter 70.94 RCW emitted from or which results from any new or modified stationary source, which the permitting authority, on a case-by-case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such source or modification through application of production processes and available methods, systems, and techniques, including fuel cleaning, clean fuels, or treatment or innovative fuel combustion techniques for control of each pollutant." BACT applies in this case since Lasco's proposal constitutes a modification that will cause emissions of a new HAP, namely MDI. Use of polyurethane in the third lamination of Lasco's products will displace the current use of polyester resin in the third lamination. Current use of polyester resin in the third lamination results in approximately 7% of Lasco's total styrene emissions (1997 stack test results). For 2001 styrene emissions attributable to the third lamination was roughly 15 tons based on ORCAA's estimates. Therefore, at current production rates, Lasco's proposal will result in decreasing styrene emissions by roughly 15 tons per year. The increase in MDI at current production rates is not known for certain, but will be less than the estimated total potential MDI emission rate of 0.271 tons. However, the net reduction in styrene emissions from eliminating polyester as the third lamination will diminish if Lasco's production increases compared to current levels. As production increases from current levels, the reduction of styrene in the third lamination will be diminished by increases of styrene in the first and second laminations. Nevertheless, because of the immediate reduction in styrene, staff considers Lasco's proposal to use of polyurethane in the third lamination as a pollution prevention measure itself, constituting BACT for this case. 4.4.3 APPROVAL CRITERIA #3 -MAINTENANCE OF AMBIENT AIR QUALITY STANDARDS: Both national and state ambient air quality standards have been established by law to protect human health and welfare. WAC 173-400-113(3) requires a finding that allowable emissions from proposed new sources or modifications will not delay the attainment date of areas not in attainment, nor cause or contribute to a violation of any ambient air quality standard. Evaluation of meeting this approval criteria requires estimating the ambient air impacts from the proposed project, adding the projected impacts to measured background air pollutant concentrations, and evaluating the Urethane.02NOC276.FD Page 9 of 13 DRAFT resulting total impact relative to the appropriate AAQS. As an alternative, the regulation provides that this requirement may be considered met if the projected impact of the allowable emissions from the proposed new source, at any location, does not exceed the pollutant-specific, significant impact levels (SILs) established in the regulation. The SILs represent incremental, project-specific impact levels the State of Washington accepts as insignificant with respect to maintaining compliance with the AAQSs. Both styrene and MDI are VOCs and contribute to formation of ozone under certain atmospheric conditions. Ozone is a criteria air pollutant and subject to an ambient air quality standard. However, as explained earlier, Lasco will still be subject to the 249 ton per year limit on VOC emissions. In addition, at current production rates, incorporating polyurethane as the third lamination will result in a decrease in styrene emissions several orders of magnitude greater than the MDI emissions increase. In other words, at current production levels, total VOCs will be decreased. Therefore, Lasco's proposal will not impact ambient air quality. 4.4.4 APPROVAL CRITERIA #4 -PREVENTION OF SIGNIFICANT DETERIORATION In areas that currently meet the National Ambient Air Quality Standards, new major sources and major modifications (as defined under WAC 173-400-113(1)) are subject to federal new source review requirements under the Prevention of Significant Deterioration (PSD) program. The purpose of the PSD program is to maintain air quality in areas that currently meet the standards, and to provide additional air quality protection to areas where maintaining pristine air quality is required. Since all areas in ORCAA's jurisdiction are currently listed as "in attainment" or "unclassified" with respect to the National Ambient Air Quality Standards, the PSD program applies to all new major sources and major modifications in ORCAA's jurisdiction. The terms "major source" and "major modification" are defined specifically for the PSD program under WAC 173-400-113. For certain special source categories, a major source under the PSD program is one that has a potential to emit greater than 100 tons per year of any pollutant subject to regulation under the Federal Clean Air Act. For general source types, a major source is one that has a potential to emit greater than 250 tons per year or more of any regulated pollutant. The Washington State Department of Ecology has been delegated by the U.S. Environmental Protection Agency to implement Washington's PSD program in ORCAA's jurisdiction. The goal of the PSD program is to insure that construction of new major stationary sources and major modifications will not significantly degrade areas with pre-existing good air quality. As explained earlier, Lasco will still be subject to the 249 ton per year plant-wide limit on VOC emissions. Therefore, PSD permitting requirements do not apply. Urethane.02NOC276.FD Page 10 of 13 DRAFT 4.4.5 APPROVAL CRITERIA #5 -NEW SOURCE REVIEW OF TOXIC AIR POLLUTANTS WAC 173-400-113(5) requires new sources and modifications that emit toxic air pollutants (TAPs), to comply with the requirements of Chapter 173-460 WAC, the Washington Air Toxics Regulation. Chapter 173-460 WAC requires new sources, and modifications resulting in increases of TAP emissions, to control emissions using Best Available Control Technology (BACT). Chapter 173-460 WAC also requires an assessment of health risk from TAP emissions increases unless impacts are demonstrated to be either below acceptable source impact levels (ASILS) using dispersion modeling and conservative emission rate assumptions, or below the prescribed "small quantity emission rates" (SQERs) contained in the regulation. As explained earlier, staff calculated maximum MDI emissions based on the Lasco's estimated maximum potential usage of polyurethane. Impacts were calculated using the EPA-approved model SCREEN (see attachment 1). Maximum MDI impacts determined using the SCREEN model were found to be less than the MDI ASIL as shown below in Table 4.4. This result satisfies the approval criteria in Chapter 173-460 WAC that projected impacts be below acceptable source impact levels (ASILS). Table 4.4: ASIL Analysis Results Pollutant Small Quantity Potential to Modeling ASIL° Maximum Pass Tier 1 Emission Emitz Required? Source Analysis Rates (yes/no)3 Impacts (YES/NO) CLASS "A" TOXICS: ................................................................. None ............................................. ............................................. .. .................................. ................................................. ................................ ......................................... CLASS "B" TOXICS: ................................................................. MDI ...................... 175 ...................... 0.02 ...................... 542 ..................... .09 .................................... Yes ................................................. 0.02 ................................ 0.01 ......................................... Yes Notes: 1. Small Quantity Emission Rates in terms of pounds per year for Class "A" pollutants and pounds per year (15~ column) and pounds per hour (2"d column) for Class "B" unless otherwise indicated. 2. Potential to Emit in same terms as Small Quantity Emission Rates for each pollutant. 3. If Potential to Emit is greater than the Small Quantity Emission Rate, then modeling is required. 4. ASIL stands for Acceptable Source Impact Level prescribed under Chapter 173-460 WAC. ASILs are in terms of micrograms per cubic meter. 5. Maximum Source Impact is the maximum impact predicted through modeling in terms of micrograms per cubic meter. 5. OPERATING PERMIT PROGRAM [Chapter 173-401 WAC) The State of Washington program pursuant to Title V of the federal Clean Air Act is governed under Chapter 173-401 WAC, the Washington Air Operating Permit Program. Chapter 173-401 WAC requires existing major stationary sources to operate in compliance with an approved Air Operating Permit (AOP). Major stationary sources are those stationary sources with a potential to emit which is greater than 100 tons per year of any criteria pollutant, greater than 10 tons per year of any hazardous air Urethane.02NOC276.FD Page 11 of 13 DRAFT pollutant (HAP), or greater than 25 tons per year of any combination of HAPs. Lasco Yelm is a major source and subject to the requirements of Chapter 173-401 (WAC). Lasco currently operates under an air operating permit issued by ORCAA on September 12, 2002. Lasco's proposed use polyurethane as the third lamination in the current "gelcoat" production line will result in an increase in MDI emissions. This increase in emissions was subject to new source review, and staff is recommending conditions of approval (see section 6). Once the Order of Approval is issued, any conditions of approval become "applicable requirements" that will need to be incorporated into Lasco's AOP in accordance with permit modification procedures in WAC 173-401-725. Pursuant to this section, Lasco will be required to submit a complete AOP permit modification application within 12 months after the physical modifications have been completed. Urethane.02NOC276.FD Page 12 of 13 DRAFT 6. CONDITIONS OF APPROVAL Several conditions of approval were determined necessary for assuring compliance with the applicable regulations and standards summarized in Table 4.2 above. These conditions are listed below, and will be incorporated into the enforceable Order of Approval, that will be issued by ORCAA upon final approval. Once issued, conditions in the Order of Approval are legally binding requirements that are in addition to requirements from applicable regulations and standards. All conditions of approval contained in the Order of Approval as well as applicable air regulations are enforceable by ORCAA and non-compliance may result in penalties. 1. MDI EMISSIONS LIMIT: Emissions of 4, 4'-methylene Biphenyl diisocyanate (MDI) as determined by ORCAA approved emission factors and calculation methods shall not exceed 542 pounds per consecutive 12 month period. 2. MDI EMISSIONS MONITORING: Compliance with the MDI emission limit in condition #1 above shall be monitored as follows: a) Lasco shall monitor compliance with the MDI limit on at least a monthly basis by computing actual MDI emissions over the previous month and previous 12 consecutive month period; b) Actual emissions of MDI shall be calculated using ORCAA approved emission factors and calculation methods, the inventory of actual materials used over the period, and the actual percent composition of each unique material; c) Actual material usage in pounds or gallons per month of materials containing MDI shall be determined by conducting a monthly inventory; d) Results from the monthly inventory shall be cross checked with material purchase records; e) The composition of MDI shall be determined based on material safety data sheets (MSDS) and/or Certificates of Analyses specific to each material used. 7. FINAL DETERMINATION ORCAA staff's final determination is that the NOC application (02NOC276) submitted by Lasco Bathware seeking approval to modify the third polyester spray station with equipment to enable spray application of polyurethane be conditionally approved for construction subject to the conditions of approval described in section 6 above. REVIEWED by Mark V. Goodin, PE Urethane.02NOC276.FD Page 13 of 13 DRAFT ATTACHMENT 1 EMISSION CALCULATIONS AIR IMPACTS ANALYSIS _. _a_ _ __ ~~~,~~~.~~~ _ __ _ .DRAFT _ _ _ ~,__ x .. ._ ..... ...',,._. ~ _ ___ _ ~~ 1 1, ~A p ~.. ... `_ .. .. .... _. '" <t. ~d ~ _.. a 1{~Cy :,w4e~W'-... n..a~, _ q{ Y~ Piy~4,,.. +. ..' ~.'. 's ~. . -:... _.. .1 ~_ ...:_.... z y.:_ l;;~ ~. _r~' F @ 4t.... ~ ~~. w'L 4..°L~,i+ l a ;1 r.^t. ~ e ~ ~ ~~.,. . ~ ~,.~..i°'~'~ ...g .~ .~ rt _. _... ..... .... . m :. .wo ~4...,.,; wit r.. > ~~ ^s y, , ~ ~- _. _ _ 4,; ;~ ~ ~ ~ _.: _ ..,F 1 ,/ L __. __.._. -.-.. i.. ._ .. _. _ .. f d'_ Y'~ $ E .. .. 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'': +' t~ ~ ~ ~ ~,. .Y i r~,. ui ~ ~: ~~>~' sue' ~ =--~t~~ F ~~,~ _~~~ ~ '~ ~ `` ~~ ~-~ -~- 4~' _ ~,_, _ _ ~ ~~ .., ~~. - .S ~ vla. kP ~, ~ ~, .. _, _ _u __ _ __ , u<.~ a ~. _ _ ._. .~ ^^D ; a r ~ ~~ ~, fr , 0 ~_ ~ 4 a . _ =~ . _ .. „~.._ .~ ~~ °. ~ ,,rrte~ (~ ~. ,.. ~. z s ~, ~~~ (~ ~ ..; ~ ~~~ _, ~ v ..~. _: ~ _ ~ .,~ ,: ,~ ~ ~ ~ ~. ... __ ~ t ~ E ..., ~~. ,,. ~., s' t ~ ~ ~_, ~. .- ,; ~ ; ,~ T,M,. .~ ~ ~~.. _ _. _ _ _ _ _ .., ~„ +~ ~- ~. ~, ~ k .~ °' ..~ ~° M ~ C ~ O O •\- Q- (~ N ~ o ~ C~ J Z vI G +N+ N~ 1.L z W W N .;r V Q ~ ~ ~ a ~ m C O o L ~ ~ N Q ~ ~ J N N ~ ~• ~ E a ~ ~ `• M .r l J ~ E i ' i1J : O Q ~ E i ~ ~N L V Q Q . ~ M :f0 i N C ~ :C i ~ ~ 7 ,~ , ~ O C a ° z M d ~ ~': i C) :N T O N 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I I 1 1 1 1 1 1 J.. `N ~~ i I C 1 M C iL i M lyr 1 C i 1 C '~ ~ i~ i ~ i~ i~ i Y N ~ ~ • 1 1 1 1 1 1 I 1 I I ~ i i 1 I 1 I 1 I i i 1 I 1 1 1 1 i 1 1 1 W 1 I 1 I 1 I 1 1 1 1 1 1 1 1 1 1 I 1 1 1 1 1 I 1 1 1 1 1 1 1 N I 1 I 1 1 ~ 1~ i N i~ i M i ~ ~ '~ N ~ ~ Ln ( C ~ ~ i~ , ~ ~ ~ N iN ~ ~ ~ N ~ L y ~ :N 1 1 1 1 1 ` i 1 1 1 I 1 I 1 I 1 1 1 1 1 I I 1 1 1 1 1 I 1 1 1 1 1 I 1 1 1 1 1 1 1 1 Q 1 1 I 1 I 1 I 1 1 a 1 1 1 ~ 1 1 ~ ~ 1 1 1 1 1 1 1 1 1 ~ 1 ~ 1 1 1 1 1 ~ ~ 1 1 ~ 1 1 ~ ~ I 0 I I 1 1 1 = 1 1 ~ I 1 ~ 1 1 i C iV i i C .O i i ~ i~ i C i 1 1 IQ 1 Q a l a 1 1 ~ I~ l I ~ '~ i' ~ c ~ O ~ ~ ~ ~ r+ i i Q Q ~ i i ~ N i o C ~ 1 1(B 1 U 1 C .~ I X 1 ~ ~~ ~ X ~ ly 1 ~ . ~ n i N 1 ~ ~ rn ~ O p ' ~ E I C G C ~ / 6...1 1 c I p G. ; EC E DRAFT ^~ LL t DRAFT 01/21/03 15:47:50 *** SCREENS MODEL RUN *** *** VERSION DATED 96043 *** Lasco Bathware, MDI Impacts Evaluation, 02NOC276 SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 1.00000 STACK HEIGHT (M) = 22.8000 STK INSIDE DIAM (M) = 1.7200 STK EXIT VELOCITY (M/S)= 10.4833 STK GAS EXIT TEMP (K) = 299.8000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) _ .5000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 6.1000 MIN HORIZ BLDG DIM (M) = 41.4000 MAX HORIZ BLDG DIM (M) = 152.4000 THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. STACK EXIT VELOCITY WAS CALCULATED FROM VOLUME FLOW RATE = 51612.000 (ACFM) BUOY. FLUX = 1.725 M**4/S**3; MOM. FLUX = 79.438 M**4/S**2. *** FULL METEOROLOGY *** ********************************** *** SCREEN AUTOMATED DISTANCES *** ********************************** *** TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES *** DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) ------- (UG/M**3) ---------- STAB ---- (M/S) ---- (M/S) (M) HT (M) Y (M) - Z -(M) DWASH 95. 5.219 1 - 3.0 ----- 3.2 ------ 960.0 ------ 39.82 ----- 26.13 ------ 14.16 ----- NO 100. 6.587 1 3.0 3.2 960.0 39.82 27.29 14.77 NO 200. 28.08 1 2.5 2.6 800.0 43.22 50.31 29.88 NO 300. 28.68 1 1.5 1.6 480.0 56.84 72.42 48.43 NO 400. 27.67 3 2.5 2.7 800.0 42.73 45.01 27.05 NO 500. 28.47 3 2.0 2.2 640.0 47.71 55.23 33.21 NO 600. 27.67 3 1.5 1.6 480.0 56.01 65.40 39.48 NO 700. 26.70 3 1.5 1.6 480.0 56.01 75.09 45.13 NO 800. 24.85 3 1.0 1.1 320.0 72.61 85.34 51.85 NO 900. 24.19 3 1.0 1.1 320.0 72.61 94.75 57.32 NO 1000. 22.98 3 1.0 1.1 320.0 72.61 104.09 62.78 NO 1100. 22.01 4 2.0 2.3 640.0 46.70 74.62 34.80 NO 1200. 21.17 4 1.5 1.7 480.0 54.67 80.95 37.22 NO 1300. 20.73 4 1.5 1.7 480.0 54.67 87.00 39.08 NO 1400. 20.17 4 1.5 1.7 480.0 54.67 93.00 40.89 NO 1500. 19.54 4 1.5 1.7 480.0 54.67 98.96 42.65 NO 1600. 19.40 5 1.0 1.3 10000.0 55.18 78.69 30.53 NO DRAFT 1700. 19.80 5 1.0 1.3 10000.0 55.18 83.09 31.61 NO 1800. 20.06 5 1.0 1.3 10000.0 55.18 87.46 32.67 NO 1900. 20.20 5 1.0 1.3 10000.0 55.18 91.82 33.72 NO 2000. 20.24 5 1.0 1.3 10000.0 55.18 96.14 34.74 NO 2100. 20.12 5 1.0 1.3 10000.0 55.18 100.45 35.66 NO 2200. 19.94 5 1.0 1.3 10000.0 55.18 104.74 36.55 NO 2300. 19.73 5 1.0 1.3 10000.0 55.18 109.02 37.43 NO 2400. 19.48 5 1.0 1.3 10000.0 55.18 113.27 38.30 NO 2500. 19.21 5 1.0 1.3 10000.0 55.18 117.50 39.15 NO 2600. 18.92 5 1.0 1.3 10000.0 55.18 121.72 39.99 NO 2700. 18.61 5 1.0 1.3 10000.0 55.18 125.93 40.82 NO 2800. 18.30 5 1.0 1.3 10000.0 55.18 130.11 41.63 NO 2900. 17.98 5 1.0 1.3 10000.0 55.18 134.29 42.43 NO 3000. 17.70 6 1.0 1.6 10000.0 48.23 92.21 27.94 NO 3500. 17.38 6 1.0 1.6 10000.0 48.23 105.90 29.88 NO 4000. 16.79 6 1.0 1.6 10000.0 48.23 119.39 31.68 NO 4500. 16.08 6 1.0 1.6 10000.0 48.23 132.70 33.37 NO 5000. 15.32 6 1.0 1.6 10000.0 48.23 145.85 34.97 NO MAXIMUM 1-HR CONCEN TRATION AT OR BEYOND 95. M: 273. 29.27 1 1.5 1.6 480.0 56.84 66.90 43.41 NO DWASH= MEANS NO CALC MADE (GONG = 0.0) DWASH=NO MEANS NO BUILDING DOWNWASH USED DWASH=HS MEANS HUBER-SNYDER DOWNWASH USED DWASH=SS MEANS SCHULMAN-SCIRE DOWNWASH USED DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB **************************************** *** REGULATORY (Default) *** PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988) **************************************** *** CAVITY CALCULATION - 1 *** CONC (UG/M**3 ) _ .0000 GRIT WS @lOM (M/S) = 99.99 GRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 6.10 CAVITY LENGTH (M) = 36.81 ALONGWIND DIM (M) = 41.40 *** CAVITY CALCULATION - 2 *** CONC (UG/M**3 ) _ .0000 GRIT WS @lOM (M/S) = 99.99 GRIT WS @ HS (M/S) = 99.99 DILUTION WS ( M/S) = 99.99 CAVITY HT (M) = 6.10 CAVITY LENGTH (M) = 26.87 ALONGWIND DIM (M) = 152.40 CAVITY CONC NOT CALCULATED FOR GRIT WS > 20.0 M/S. CONC SET = 0.0 **************************************** END OF CAVITY CALCULATIONS **************************************** *** INVERSION BREAK-UP FUMIGATION CALC. *** CONC (UG/M**3) _ .0000 DIST TO MAX (M) = 945.23 DIST TO MAX IS < 2000. M. CONC SET = 0.0 DRAFT *************************************** *** SUMMARY OE SCREEN MODEL RESULTS *** *************************************** CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M**3) MAX (M) HT (M) -------------- ----------- ------- ------- SIMPLE TERRAIN 29.27 273. 0. *************************************************** ** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS ** *************************************************** DRAFT ATTACHMENT 2 STANDARD FORMS COMPLAINT INVESTIGATION AND RESOLUTION REPORT ,~ Date/Time complaint received: Page of Received by: Referred to: Complainant Name: Telephone Address: Does Complainant require confidentiality? [ ]yes [ ] no COMPLAINT: [ ]Smoke [ ]Dust [ ]Odors [ ]Fallout [ ]Other: Time and date first noticed: Time and date last noticed: COMPLAINT DESCRIPTION: POSSIBLE CAUSES: ACTIONS TAKEN: RESOLUTION OF COMPLAINT: [ ]Notify ORCAA Signature: [ ]Follow-up call to Complainant Date: OLYMPIC REGION CLEAN AIR AGENCY 2940-B Limited Lane NW -Olympia, Washington 98502 - 360-586-1044 -Fax 360-491-6308 FORM 3 NOTICE OF COMPLETION Please complete the following form and submit to ORCAA no later than 15 days from completion of construction of the new source or modification. Company Name: Lasco Bathware Source Name: Lasco Bathware Mailing Address: 801 E Kaiser Blvd, Suite 130 Anaheim, CA 92808 Facility Address: 801 Northern Pacific, in Yelm Contact Person and Phone Number: Viktor Prismantas, (714) 993-1220 NOC #: 02NOC276 Project Description: Modify the third polyester lamination spray station with equipment and material storage capacity to enable spray application of polyurethane. The modifications will provide Lasco the flexibility to incorporate a polyurethane layer as the third lamination in the composite structure of its products. It is Lasco's intent to eliminate polyester resin specifically in the third lamination. Structures to store polyurethane totes will be fabricated adjacent to the main "gelcoat" production line. Day tanks for storing the two-part polyurethane material prior spraying will also be added. Polyurethane will be spray applied in the third lamination spray station (A8-A9). There will be no physical modifications to this spray station except for equipping it with spray equipment capable of mixing and delivering the two-part polyurethane. Date NOC Approved: January 27, 2003 Date Construction Completed: Anticipated Start of Operation: Signature Date Signed f ~ ar,~.. ADDENDUM TO ye`~ NOTICE OF CONSTRUCTION 02NOC276 Lasco Bathware, Yelm Plant January 27, 2003 ORDER OF APPROVAL This Order of Approval is issued in accordance with Olympic Region C-ean Air Agency's (ORCAA) Regulation 1, and Chapter 173-400 of the Washington Administrative Code (WAC). Conditional approval is hereby granted to Lasco Bathware, to modify the third polyester spray station with equipment to enable spray application of polyurethane as described in the associated NOC application (02NOC276), at 801 Northern Pacific, in Yelm. The special conditions established in this order are enforceable requirements, which are additional to requirements of applicable state, local and federal regulations and standards. Compliance with this order and its conditions does not relieve the owner or operator from compliance with ORCAA Regulation 1, RCW 70.94, or any other emissions control requirements, nor from the resulting liabilities and/or legal remedies for failure to comply. The owner or applicant may petition ORCAA for reconsideration of this Approval Order by filing a petition in writing within twenty (20) days to ORCAA's Executive Director. ORCAA must consider all petitions and respond in writing within thirty (30) days. Within thirty (30) days from notice of ORCAA's final decision on a petition, the owner or applicant may appeal the Approval Order to the Pollution Control Hearings Board (PCHB) by filing the appeal in writing with the PCHB and serving a copy upon ORCAA. THIS ORDER OF APPROVAL IS ISSUED SUBJECT TO THE FOLLOWING CONDITIONS: 1. MDI EMISSIONS LIMIT: Emissions of 4, 4'-methylene Biphenyl diisocyanate (MDI) as determined by ORCAA approved emission factors and calculation methods shall not exceed 542 pounds per consecutive 12 month period. 2. MDI EMISSIONS MONITORING: Compliance with the MDI emission limit in condition #1 above shall be monitored as follows: a) Lasco shall monitor compliance with the MDI limit on at least a monthly basis by computing actual MDI emissions over the previous month and previous 12 consecutive month period; b) Actual emissions of MDI shall be calculated using ORCAA approved emission factors and calculation methods, the inventory of actual materials used over the period, and the actual percent composition of each unique material; c) Actual material usage in pounds or gallons per month of materials containing MDI shall be determined by conducting a monthly inventory; d) Results from the monthly inventory shall be cross checked with material purchase records; e) The composition of MDI shall be determined based on material safety data sheets (MSDS) and/or Certificates of Analyses specific to each material used. REVIEWED BY Mark V. Goodin, PE Approval Order for 02NOC276 Page 1 of 1 N~-~~p~~; r~~ CITY OF YELM PO Box 479 ,~'` Yelm WA 98597 360-458-3835 ,~~, ,/,,` NOTICE OF AF1'PLICATION Mailed on: PROJECT NAME AND LOCATION: LASCO 801 No LAND USE CASE: ENV-02-8331-YL ~,~~ fiZ~ Pacific Road, Yelm, WA PROJECT DESCRIPTION: Substjl~ute polyester resin with polyurethane resin, necessitating installation of polyurethane tank. / ENVIRONMENTAL and OTHER D~bCUMENTS SUBMITTED WITH THE APPLICATION: Additional Information or Prgject Studies Requested by the City: No preliminary determina on of consistency with City development regulations has been made. At minimum, this project ill be subject to the following plans and regulations: City of Yelm Comprehensive Plan, Zo ng Title (17), Critical Areas Ordinance (14.08), Storm Water Drainage Design and Erosion Control Ma al (DOE), Uniform Building Code, State Environmental Policy Act (SEPA) Title (14), Road Design Stan ards, Platting and Subdivision Title (16), and the Shoreline Master Program. The City of Yelm invit s your comments early in the review of this proposal. Comments should be directed to Tami Mer lman, Community Development Department, P.O. Box 479, Yelm WA 98597, 360- 458-3835. THE 1~-DAY PUBLIC COMMENT PERIOD ENDS AT 5:00 PM ON This notice has een provided to appropriate local and state agencies, and property owners within 300 feet of the proj t site. These recipients, and any others who submit a written request to be placed on the mailing list, wi also receive the following items when available or if applicable: Environmental Threshold Determinatio ,Notice of Public Hearing and Notice of Final Decision. If the proposed project requires a City Council ecision, it will be mailed to all those who participate in the public hearing and to anyone else requesting a decision in writing. Additionally, there will be a 14-day public comment period if an environme tal determination is issued. Opportunities for appeal occur within twenty one (21) days after the date t environmental determination is issued. City Council decision can be appealed through Superior ourt. Appeals of site plan review decisions may be filed within 14 days of Notice of Final Decision. C:\Community Development\Project Files\ENV Environmental Checklist\8331 I,ASCO\Notice of Application.doc .~ ~~ ~ ~~ ff V a ~~ u `, ~; ~~ V\ \i ~S ~J ^~~~5. \J ~~ ~-~\ ~ ~ ~~ ~~~~0 BATHWARE AMERICA'S 6ATHTU6 COMPANY January 8, 2003 Mrs. Tami Merrriman 105 Yelm Avenue West P.O. Box 479 Yelm, Washington Corporate Office 8101 East Kaiser Blvd. Anaheim, CA 92808 ,~ TEL: 714/993-1220 ~ i l 800/877-2005 FAX: 714/998-1022 RE: Environmental Checklist for Polyurethane Project located at LASCO, Yelm, WA. Dear Mrs. Merriman: Attached please find the documentation you requested in your email and letter dated January 2, 20003. The new polyurethane project will replace a portion of our existing process. Lasco plans on storing totes of the two components used in the polyurethane process. I have included a site map which details the location of any new equipment and specifications on the size of the equipment. No old tanks are being removed at this time. This new process will be put through a trial phase to test the reaction of our customers. In addition to the new storage inside the existing building Lasco plans to re-grade an existing loading dock. Only a small amount of grading is expected. The location of this loading area can be found on the attached maps. Please review the attached diagrams and let me know if you have any further questions. Thank ou, ,'~~ ` Viktor Prismantas RETURN RECEIPT REQUESTED /CERTIFIED #7001 2510 0006 7428 9484 or site" should be read as "proposal," "proposer," and "affected geographic area," respectively. CITY OF YELM ENVIRONMENTAL CHECKLIST CITY USE ONLY FEE: $150.00 DATE RECD FILE NO. ~ ~'' ~`'~- -3~i-YL- A. BACKGROUND 1. Name of proposed project, if any: Polyurethane 2. Name of applicant: Lasco Bathware Inc. 3. Address and phone number of applicant and of any other contact person: 801 Northern Pacific Yelm, WA. 98597 4. Date checklist prepared: 12/19/02 5. Agency requesting checklist: ORCAA 6. Proposed timing or schedule (including phasing, if applicable): March 1, 2003 7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. No 8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. Notice to Construct for ORCAA 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. No 10. List any government approvals or permits that will be needed for your proposal, if known. Permit to Construct from ORCAA ~~ l-e ~~r. 11. Give brief, complete description of your proposal, including the proposed uses iT and the size of the project and site. There are several questions later in this checklist ~rY-1 Dl'UflA that ask you to describe certain aspects of your proposal. You do not need to repeat f}~a~he~~. ~ those answers on this page. ~ c~ Lasco Bathware proposes to substitue its polyester resin with polyurethane in the thirds stage of its production process. This change will eliminate styrene emissions from this p~~C.C~ point of the operation. Polyeurethanes have been found to have insignificant emission U and will help Lasco reduce the amount of styrene put into the air. 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. You need not duplicate maps or detailed plans submitted with any permit applications related to this checklist. The proposed change would take place at 801 Northern Pacific in Yelm. On the FRP bathtub production line. B. ENVIRONMENTAL ELEMENTS 1. Earth a. General description of the site (circle one): flat, rolling, hilly, steep slopes, mountainous, other b. What is the steepest slope on the site (approximate percent slope)? Loading dock ramp 8% c. 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. Sandy Loam with River rock d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. None ~~o `, ,~.e, ~ ,.~~ e. Describe the purpose, type, and approximate quantities of any filling or /_~,~N' ~~~-' grading proposed. Indicate source of fill. l~ ~ ~c~ None ~' ~p~ f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe. None Page 2 g. About what percent of the site will be covered with impervious surfaces after project construction such as asphalt or buildings? None h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: None 2. Air a. What types of emissions to the air would result from the proposal (i.e., dust, automobile exhaust, odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities if known. MDI = 5 pounds per year b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe. None ~~ ~~ c. Proposed measures to reduce or control emissions or other impacts to air, if any: Lasco Bathware is voluntarily converting from polyester resin to polyurethane. This change will reduce approximately 15% of Lasco's overall emissions. 3. Water a. Surface Water 1) Is there any surface water body or wetland on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds)? If -~~~ yes, describe type and provide names. State what stream or river it flows into? None 2) Will the project require any work over, in, or adjacent to (within 300 feet) the described waters? If yes, please describe and attach available plans. None 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 Page 4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. None 5) Does the proposal lie within a 100-year floodplain? If so, note elevation on the site plan. No 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. Groundwater: 1) Will groundwater be withdrawn, or will water be discharged to groundwater? Give general description, purpose, and approximate quantities if known. No 2) Describe the underlying aquifer with regard to quality and quantity, sensitivity, protection, recharge areas, etc. No 3) Describe waste material that will be discharged into or onto the ground from septic tanks or other sources, if any (such as domestic sewage; industrial byproducts; agricultural chemicals). None c. Water Runoff (including storm water): 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? C~~~,~~ Will this water flow into other waters? If so, describe. ~\~,~'~ S~ ~~ Runoff from the facility percolates into the ground. `,~~ ~'~ 2) Could waste materials enter ground or surface waters? If so, generally describe. "" N o d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any: None Page 4 4. Plants a. Check or circle types of vegetation found on the site: deciduous tree: alder, maple, oak, aspen, other evergreen tree: fir, cedar, pine, other _X_ shrubs _X_ grasses pasture crops or grains wet soil plants: cattail, buttercup, bulrush, 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? None c. List threatened or endangered species 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: None 5. Animals a. Circle any birds and animals that have been observed on or near the site or are known to be on or near the site: birds: hawk, heron, ducks, eagle, songbirds, other: pigeons crows and sparrows mammals: deer, bear, elk, beaver, other: Deer fish: bass, salmon, trout, shellfish, other: None b. List any priority, threatened or endangered species known to be on or near the site. None c. Is the site part of a migration route? If so, explain. None d. Proposed measures to preserve or enhance wildlife, if any: None Page 5 6. Energy and Natural Resources a. What kinds of energy (electric, natural gas, gasoline, heating oil, wood, solar etc.) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, transportation, etc. No new energy requirements 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: None 7. Environmental Health a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spills, of hazardous waste, that could occur as a result of this proposal? If so, describe. Risk of exposure to MDI if spills occur. 1) Describe special emergency services that might be required. Safety shower in location of materials 2) Proposed measures to reduce or control environmental health hazards, if any: Training, secondary containment 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)? Indicate what hours noise would come from the site. None 3) Proposed measures to reduce or control noise impacts, if any: None 8. Land and Shoreline Use Page 6 a. What is the current use of the site and adjacent properties? The current site is used only for manufacturing. Adjacent properties are used for manufacturing, residential, a church and a sewage treatment plant. b. Has the site been used for mineral excavation, agriculture or forestry? If so, describe. No c. Describe any structures on the site. Warehouse, Office buildings and production facility d. Will any structures be demolished? If so, what? no e. What is the current comprehensive plan designation of the site? Industrial f. What is the current zoning classification of the site? Industrial/Commercial g. If applicable, what is the current shoreline master program designation of the site? N/A h. Has any part of the site been classified as a "natural resource", "critical" or environmentally sensitive" area? If so, specify. N/A i. Approximately how many people would reside or work in the completed project? 200 j. Approximately how many people would the completed project displace? 0 k. Proposed measures to avoid or reduce displacement impacts, if any: N/A I. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any: N/A P;~rfe 9. Housing a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing. N/A b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing. N/A c. Proposed measures to reduce or control housing impacts, if any: N/A 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? N/ b. ~ What views in the immediate vicinity would be altered or obstructed? ~/ ~ ~ N/A c\ V ~ Proposed measures to reduce or control aesthetic impacts, if any: V" N/A T' 11. Light and Glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur? N/A b. Could light or glare from the finished project be a safety hazard or interfere with views? N/A c. What existing off-site sources of light or glare may affect your proposal? N/A d. Proposed measures to reduce or control light and glare impacts, if any: N/A 12. Recreation a. What designated and informal recreational opportunities are in the immediate vicinity? N/A Page 8 b. Would the proposed project displace any existing recreational uses? If so, describe. N/A c. Proposed measures to reduce or control impacts or provide recreation opportunities: N/A 13. Historic and Cultural Preservation a. Are there any places or objects listed on, or proposed for, national, state, or local preservation registers known to be on or next to the site? If so, generally describe. N/A b. Generally describe any landmarks or evidence of historic, archeological, scientific, or cultural importance known to be on or next to the site. N/A c. Proposed measures to reduce or control impacts, if any: N/A 14. Transportation a. Identify sidewalks, trails, public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any. N/A b. Is site currently served by public transit? By what means? If not, what plans exist for transit service? N/A c. How many parking spaces would the completed project have? How many would the project eliminate? N/A d. Will the proposal require any new sidewalks, trails, roads or streets, or improvements to existing sidewalks, trails, roads or streets, not including driveways? If so, generally describe (indicate whether public or private). N/A Pale 9 e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe. N/A f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur. N/A g. Proposed measures to reduce or control transportation impacts, if any: N/A 15. Public Services a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe: N/A b. Proposed measures to reduce or control direct impacts on public services, if any. N/A 16. Utilities a. Circle utilities currently available at the site: electricity, natural aas, water, refuse service, telephone, sanitary sewer, seetic system, other. 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. N/A C. SIGNATURE The above answers are true and complete to the best of my knowledge. I understand that the City of Yelm is relying on them to make its decision. Si nature: 9 Of ~ l U `~ Date Submitted: _ / ~ -._~~~~ ~________ _. Page. 10 ,.. I~ Send.To__Prin_ter Back_to Map Yelm WA 98597 US Notes: ~, Need Roadside Help? [at a locf;~rilith, to•;+;~, tire char7,~e, jurnp~==tart or g~;, c°,~ !~_~ ]I.1_t $r9,9a ~;r;;t_1e,r_I yol_~ rnentic~n h•'1.3KrQl_~e~st cone OLl7. Call 888-627-7623 _..._._. ~ a Fun La'ari;~ 0 ~ 80~of[ Sy ~ s z ~`~ Esc nii~ C~ ~e _~,rd ~,t _~a a ~ n_ _ „C, ~ _ ~ J fq ` r , ~ ,~ .~_. .... - fq ~ ~. S L.ellfLgll ~-8n 31 ~ ~ .` ,;, _ ~ a .» ,. f ~ a = U`~ TI ' :{3rd r'+J 3 ==y n Qy i,a T r + Qi ~ S7 (i _~ ~J.~~ - .~ ii '7 sir 4f. - ..1 ` ,, ry i. C..yrr ,r ~~, ^ - ~S r, F,3I~` ,. Longrnir~ ~?t ~a `'' ~`~elrr~ "•~r . V r- '' [- . fit} W I QS ~ r i, ;~~: .ti .o PJti 1~~!3rd ::.{r„a ~6 1~~3rd ~.'u~ o ~~ ;., ~~ - ~ - -~ ~, ~ s,' Golden Ln~ s? __ ~:~ LaatiyJ, _ lei CG i~~~gth ::.{rg f-y a '~'+,'~ . - ~' y7" ~bh,-* ?i - <t?•~ 11 :7th ::.{re Se Q?2Ci0'~ Ml3t~~.~u»s.t.a~m, Inc , C~2iiCr~ ~ C~13rh Rd `,=y ~y.'v !~ C'~T, Inc. All rights reserved. Use Subject to License/Copyright M !~ V '_. . This map is informational only. No representation ~s mad= or warranty given as to its content. User assumes all risk of use. MapQuest and its suppliers assume no respons~h~lity frr any loss or delay resulrinq from such use. Privacy Policy & Legal Notices J 2003 MapQuest.com, Inc. All rights reserved. (/ ~f THE p~Q~ a~ 9~_ Cl o ~el~~ a 10~ Yelm Avenue West P.O. Box 479 YELSMoTON Yelm, Washington 9897 (360) 458-3244 January 2, 2003 LASCO Bathware Viktor Prismantas 8101 E Kaiser Blvd., Ste 130 Aneheim, CA 92808 Re: Environmental Checklist for Polyurethane Project located at LASCO, Yelm, WA Dear Mr. Prismantas: I received your Environmental Checklist. At this point, the checklist is incomplete, and I will need further information to continue our environmental review. Please forward the following items to me, and when received, I will continue the environmental review. 1. Mail Labels of owners of property within 300 feet of the perimeter of the site. Include Assessors tax parcel numbers and map. (see attachment, these maybe ordered from a local title company.) (I apologize for not stating this in our earlier contact.) 2. Vicinity map, 8 1/2 x 11, showing nearby property, streets, streams, etc. 3. Site Plan map, showing the site, and where the proposed project will located, and any construction drawings.: 4. I'll need a little better description of the project, and drawings. Are these new tanks being placed? Are old tanks being removed? Is there any new construction at the site as a result? 5. Does LASCO have a spill containment plan approved by Thurston County? If you have any questions, please feel free to give me a call. Thanks, i. ~,~~ ~ ~ Tami Merriman Assistant Planner 1. FINAL DETERMINATION ORCAA staff recommends conditional approval of the Notice of Construction (NOC) application by Lasco Bathware to modify the third polyester spray station at Lasco's facility in Yelm, with equipment and material storage capacity to enable spray application of polyurethane. The recommended conditions of approval are specified in Section 6 of this report, and are recommended for inclusion in a final Order of Approval. Once issued, conditions in the final Order of Approval will be enforceable by ORCAA. Staff's recommendation to approve this project is based on the following findings and conclusions: 1. Maximum emission rates from proposed new sources of air pollution are likely to comply with applicable federal, ORCAA and Washington air regulations and standards; 2. Proposed air pollution controls meet the State's requirement that Best Available Control Technology (BACT) be employed to control emission increases from new sources; 3. Ambient air impacts are not likely to cause or contribute to any violation of an ambient air quality standard; and 4. Projected toxic air pollutant (TAP) impacts were found to be less than the Acceptable Source Impact Levels (ASILs) prescribed under the Washington Air Toxics regulation. The following report provides a brief project description, a summary of determinations with respect to applicable regulations and standards, and describes staff's recommended conditions of approval. Other details regarding description of the proposed project are provided in the associated NOC application (02NOC276). 2. PROJECT DESCRIPTION AND BACKGROUND Lasco Bathware Inc. proposes to modify the existing "gelcoat" production line at their facility in Yelm, Washington, by adding material storage structures and equipping the third lamination station (ID#s A8 & A9) with two new day tanks and new spray equipment. The proposed modifications and new equipment only involve the third lamination station. Production operations and equipment prior to and after the third lamination station will remain unchanged. The modifications will provide Lasco the flexibility to incorporate a polyurethane layer as the third lamination in the composite structure of its products. It is Lasco's intent to completely eliminate using polyester resin in the third lamination. The proposed polyurethane material will consist of a one to one mixture of "polyol" resin and a solution containing isocyanate. The isocyanate solution contains 4', 4'-methylene diisocyanate (MDI) and polymeric methylene diisocyanate isomer (PMDI), and has a composition of 45% MDI and 50% PMDI. MDI is both a federally listed hazardous air pollutant (HAP) and a toxic air pollutant (TAP) regulated under Washington air regulations for new toxic air pollutant sources (WAC 173-460). According to the MSD sheet for the material, MDI is only HAP/TAP constituent of the isocyanate solution. According to the Material Safety Data Sheet for the polyol resin, it does not contain any Urethane.02NOC276.FD Page 1 of 13 volatile HAPs or TAPs. Lasco will construct a storage rack for storing totes of the polyol resin and isocyanate. The storage rack will be located within the main production building adjacent to the main production line referred to as the "gelcoat" production line. The proposed storage rack will be capable of storing up to 40 storage totes. Each tote will weigh 2,500 pounds and will contain 270 gallons of either resin or isocyanate. A staging rack and two new day tanks, one for resin and one for isocyanate, will be constructed directly adjacent to the third lamination spray station. The day tanks will hold the resin and isocyanate prior to spray application. Each will have a 350 gallon holding capacity. The day tanks will be covered and vented to the building air space. Day tanks will be gravity filled from storage totes in a batch-wise fashion. A tote will be placed above a day tank in the staging rack, connected to the day tank and then allowed to gravity flow into the day tank. During filling, vapors in the day tank will be vented into the building. Storage totes will be fitted with special moisture knock-out filters while being offloaded into the day tanks to remove any moisture that may react with the isocyanate. Empty storage totes will be closed and periodically sent to a recycler. Emissions of MDI from the displacement of vapors in the day tanks were accounted for in emission calculations (see below) and were determined to be insignificant. During production, resin and isocyanate will be pumped from their respective day tanks to special mixing heads that mix the polyol resin and isocyanate to form the polyurethane within the head just prior to spraying. The polyurethane is then spray applied to the surface of the composite within the third lamination station. The reaction of the polyol resin with the isocyanate is exothermic resulting in elevated temperatures on the surface of the polyurethane lamination up to 140 °F. Curing of the polyurethane is rapid with a tack time of 30 to 40 seconds. Emissions resulting from spray application of polyurethane were accounted for (see below) and make up the bulk of the emissions increase proposed. There will be no physical modifications to the third lamination spray station except for equipping it with spray equipment capable of mixing and delivering the two-part polyurethane and constructing the staging rack adjacent to the station. This will also involve equipping the booth with a boom capable of supporting the new mixing heads and spray guns. Emissions from the third lamination station will be captured by the existing capture system and exhausted directly to the outside air through the four existing 75' exhaust stacks. Production operations and equipment prior to and after the third lamination station will remain unchanged. Urethane.02NOC276.FD Page 2 of 13 TABLE 2.1. EQUIPMENT SPECIFICATIONS Resin/Isocyanate Storage Rack capable of storing 40 totes Tote Rack Totes capable of storing 270 gallons of either resin or Isocyanate • Totes will be com letel sealed not vented Burin stora e Day Tanks Two, 350-gallon day tanks • Com letel enclosed and vented to buildin airs ace S ra E ui ment Air Pollution Controls Pollution prevention measures only Pro osed: 3. EMISSIONS Storage, transport and spray application of the two-part polyurethane proposed by Lasco will result in minor emissions of 4', 4'-methylene diisocyanate (MDI). MDI is not currently emitted at the Lasco facility in Yelm and, therefore, any emissions of MDI resulting from this proposal constitute an emissions increase. MDI is both a federally listed hazardous air pollutant (HAP) and a toxic air pollutant (TAP) regulated under Washington air regulations for new toxic air pollutant sources (WAC 173-460). MDI is also a volatile organic compound (VOC) and, therefore, subject to the existing plant- wide limit on Lasco's VOC emissions (Lasco AOP condition 4.25). MDI emission rate estimates were provided in Lasco's NOC application. Lasco's MDI emissions estimates were based on calculation methods and procedures recommended by the Alliance for the Polyurethane Industry (API) in their guidance document titled MDI/Polymeric MDI Emissions Reporting Guidelines For the Polyurethane Industry (API, 2002). The calculation methods recommended by API in this guidance document are available from EPA's web site, but are currently under review by the U.S. EPA. MDI emission rates were estimated independently by ORCAA staff (see Table 3.1 below). Attachment 1 contains staffs emission calculations including descriptions of assumptions made and methods used. Staff's calculations also relied on the calculation methods recommended by the API in their guidance document. However, staff's calculations differed from Lasco's in that the equations modeling spray application of polyurethane were used where Lasco's calculations relied on the equations modeling evaporation losses from an open mold surface. Staff's main reason for using the spray coating equations was that Lasco's proposed polyurethane process will rely on spray application of the polyurethane on to molds. Since the equations for spray coating result in much higher estimated MDI emissions compared to the open mold equations, Staff believes spray coating influences will dictate the rate of emissions. In addition to emissions from spray coating, staff's estimates include fugitive losses from storing the polyol resin and Isocyanate, and day tank working losses. Estimated fugitive emissions and emissions from day tank working losses are both small compared to emissions from spray application of the polyurethane. Staff's annual emissions estimates are based on Lasco's estimated maximum potential use rate of 2 million pounds of polyurethane per year. Hourly and daily emissions were based on the maximum potential use rate and Lasco's current operating schedule. Urethane.02NOC276.FD Page 3 of 13 0 I 0 H S ~_ Y U ~ d ~ ~ ~ w 0 N_ ~ ~ Q O W = m 0 `~ m _ __- f _ _ _~ m ~ V ~, ~g-~s ~ ~,o-~o ~ O ~ O ~ ImU N ~ d xOJ 'e~ _ ~ \Z ~ ~ d .... _ _. _ ,_~ _ _r t ~~~ w ~-. ~' U W =f-Q W z~ ~ cower x ~ ?~,' Z O X ~ ~ ~ Q d ~ U ~ ... ,i w O ~ ~~ __ _ ___ __ w z 0 z w U W ~ d W o o ^ a= -\O J es w Q.-. m~ F - WW ° ZC9H ZZ~ Nza \J W =~°a vQ~ j Q=~ Q my - ~~ Mv(n r- W O O I i~ N ~ - ~ ~ Q O W - ~_ ~.. __ tn _ = ao Y = V O Q ~ ~ a W C~ Q J ~~ ~ w i 3 w O i~ } _ W (~ C i! i j!. e a (/) c0 w x H U Z Q ~w~ ~ x Z \_ O (n t0 ~" ~ ~ ~ U N '~~~ ~~0- c0 \ Z ~Q J o w ~ F- M ~ Y ~ U ~ Qa ~~ N ~ - ~ Cr Q O w =m Z Y ~ Q p ~-- Q Q z _o U w z 0 z w J Q U SHELLY BADGER YELM CITY ADMINISTRATOR GARY CARLSON YELM BUILDING DEPARTMENT GRANT BECK COMMUNITY DEVELOPMENT DIRECTOR YELM PARKS ADVISORY COMM PUGET SOUND ENERGY ATTN: DENNY LENSEGRAV 2711 PACIFIC AVE SE OLYMPIA WA 98501 DEPT. OF ECOLOGY SW REGIONAL OFFICE ATTN: MARK HENDERSON P.O. BOX 4775 OLYMPIA, WA 98504-4775 THURSTON CO. COMMUNICATION 2000 LAKERIDGE DR SW OLYMPIA, WA 98502 LEMAY, INC. ATTN: DICK REHN 13502 PACIFIC AVE TACOMA, WA 98444-0459 YELM CHAMBER OF COMMERCE P.O. BOX 444 YELM, WA 98597 LASCO BATHWARE 801 NORTHERN PACIFIC YELM, WA 98597 MAYOR ADAM RIVAS Only review schedule & notice YELM CITY ENGINEER JIM GIBBON TAMI MERRIMAN PLANNING TECHNICIAN THURSTON CO. FIRE DEPT ATTN: BILL STEELE P.O. BOX 777 YELM, WA 98597 PUGET SOUND ENERGY ATTN: JOHN DICKSON 2711 PACIFIC AVE SE OLYMPIA, WA 98501-2036 THURSTON CO. ASSESSOR 2000 LAKERIDGE DR SW, BLDG 1 OLYMPIA, WA 98502 INTERCITY TRANSIT ATTN: DENNIS BLOOM P.O. BOX 659 OLYMPIA, WA 98507 VIACOM CABLE ATTN: DAVID LEE 2316 SO. STATE TACOMA, WA 98405 THURSTON COUNTY ROAD DIV 2404-A HERITAGE CT SW OLYMPIA WA 98502 Tami C:\MyDocuments\Planning Folder\Mailist\Project Review Maillist. TODD STANCIL YELM POLICE DEPT AGNES BENNICK YELM CITY CLERK/TREASURER TIM PETERSON YELM PW DIRECTOR YCOM Networks ATTN: KEN BECKMAN P.O. BOX 593 YELM, WA 98597 WSDOT, OLYMPIC REGION ATTN: DALE SEVERSON P.O. BOX 47440 OLYMPIA, WA 98504-7440 THURSTON CO. PLANNING DEPT. 2000 LAKERIDGE DR SW, BLDG 1 OLYMPIA, WA 98502 YELM COMMUNITY SCHOOLS ATTN: ERLING BIRKLAND P.O. BOX 476 YELM, WA 98597 YELM POST OFFICE POSTMASTER OAPCA ATTN: JAMES WILSON 909 SLEATER KINNEY RD SE STE 1 LACEY WA 98503 ~~o ~~ ~~ ®09L5 aase-~ s~age1 ssaaPP11 ®A213AV/ ~%/ 2271 92 10404 2271 92 40100 2271 92 40100 City Of Yelm Central Reddi-Mix Inc Central Reddi-Mix Inc NO STREET NAME or NUMBER 305 E Summa St 305 E Summa St WA Centralia, WA 98531 Centralia, WA 98531 2271 92 40100 2271 92 40202 2271 92 40203 Central Reddi-Mix Inc Church Of Christ Of Yelm Capital Dev Co 305 E Summa St 18340 138Th Ave SE PO Box 3487 Centralia, WA 98531 Yelm, WA 98597 Lacey, WA 98509 2271 92 40300 2271 92 40400 6430 07 00200 Donald Miller Travis Smith Tracy & Judith Franks PO Box 5000 404 Edwards St SW 16430 Railway Rd SE Yelm, WA 98597 Yelm, WA 98597 Yelm, WA 98597 6430 07 00302 6430 07 00303 6430 07 00304 Ronald Smith Ronald Smith Ronald Smith 16224 Vail Rd SE 16224 Vail Rd SE 16224 Vail Rd SE Yelm, WA 98597 Yelm, WA 98597 Yelm, WA 98597 6430 07 00500 6430 07 00501 6430 07 00600 Sound Energy & Elec Puget Shirley & Dewey Clawson Security Pacific Bank Wash PO Box 90868 PO Box 664 PO Box 34029 Bellevue, WA 98009 Yelm, WA 98597 Seattle, WA 98124 6430 08 00302 6430 08 00303 6430 08 00304 O Rear Family Llc O Rear Family Llc O Rear Family Llc 4635 Foxtrail Dr NE 4635 Foxtrail Dr NE 4635 Foxtrail Dr NE Olympia, WA 98516 Olympia, WA 98516 Olympia, WA 98516 6430 09 00200 6430 09 00300 6430 09 00300 O'Rear Family Llc A & J Ents Llc A & J Ents Llc NO STREET NAME or NUMBER 925 Northern Pacific Rd NW 925 Northern Pacific Rd NW WA Yelm, WA 98597 Yelm, WA 98597 6430 09 00400 6430 09 00400 6430 09 00400 Yelm Ciry Of Yelm City Of Yelm City Of PO Box 479 PO Box 479 PO Box 479 Yelm, WA 98597 Yelm, WA 98597 Yelm, WA 98597 6430 09 00400 Yelm City Of PO Box 479 Yelm, WA 98597 ®0915 ~o~ a~e~dwa~ asP Wls~aays paa~ y~oows ®09L5 aase~ 2271 92 40100 Central Reddi-Mix Inc 305 E Summa St Centralia, WA 98531 2271 92 40300 Donald Miller PO Box 5000 Yelm, WA 98597 6430 07 00303 Ronald Smith 16224 Vail Rd SE Yelm, WA 98597 6430 07 00600 Security Pacific Bank Wash PO Box 34029 Seattle, WA 98124 6430 09 00400 Yelm City Of PO Box 479 Yelm, WA 98597 ®0915 ~o} a~e~dwa} ash 2271 92 40202 Church Of Christ Of Yelm 18340 138Th Ave SE Yelm, WA 98597 2271 92 40400 Travis Smith 404 Edwards St SW Yelm, WA 98597 6430 07 00500 Sound Energy & Elec Puget PO Box 90868 Bellevue, WA 98009 6430 08 00304 O Rear Family Llc 4635 Foxtrail Dr NE Olympia, WA 98516 s~aga~ ssaappd ®11213/~~d ~U 2271 92 40203 Capital Dev Co PO Box 3487 Lacey, WA 98509 6430 07 00200 Tracy & Judith Franks 16430 Railway Rd SE Yelm, WA 98597 6430 07 00501 Shirley & Dewey Clawson PO Box 664 Yelm, WA 98597 6430 09 00300 A & J Ents Llc 925 Northern Pacific Rd NW Yelm, WA 98597 Wls}aayS paa~ y~oowS ~F THE p~+~ ~w ~ Imo/ \~! YELM WASHINOTCN January 2, 2003 LASCO Bathware Viktor Prismantas 8101 E Kaiser Blvd., Ste 130 Aneheim, CA 92808 City of Yel~n 105 Yelm Avenue West P.O. Box 479 Yelm, Washington 98597 (360) 458-3244 Re: Environmental Checklist for Polyurethane Project located at LASCO, Yelm, WA Dear Mr. Prismantas: I received your Environmental Checklist. At this point, the checklist is incomplete, and I will need further information to continue our environmental review. Please forward the following items to me, and when received, I will continue the environmental review. 1. Mail Labels of owners of property within 300 feet of the perimeter of the site. Include Assessors tax parcel numbers and map. (see attachment, these may be ordered from a local title company.) (I apologize for not stating this in our earlier contact.) 2. Vicinity map, 8 1/2 x 11, showing nearby property, streets, streams, etc. 3. Site Plan map, showing the site, and where the proposed project will located, and any construction drawings.. 4. I'll need a little better description of the project, and drawings. Are these new tanks being placed? Are old tanks being removed? Is there any new construction at the site as a result? 5. Does LASCO have a spill containment plan approved by Thurston County? If you have any questions, please feel free to give me a call. Thanks, .%`' ~~ ~~~Gt ~ y ji'~~~d~C~ ~- Tami Merriman Assistant Planner The City of YeUn is an Equnl Opportunity Providc~- 0 ~ /1 ~ ' ~ ,u ~..J ~1 ~~ ;,,, ~ +;.~ ,~ u"1 ~ ~ ~ ~~ `~. • W U Z W 2 i W LL e~fftt W w 2 U Z ''' ~ CJ a z ~ W LL1 ~ Z Q w m m Q U . '~,il ~ ° Z o (n Q ~.. o z w .~ > __ N ~_ I ~ C tN0 M W = ..r s i T- U tT : j Z' w. I ~ ~ ~ _Q'- ~ h< { p • #. ~ "~ ;al ~ .~ p, Q Q ~' } Z o # `"~.~ l ~ ~ .~ ~ i ~ ~ ,~ ~? .1:m > - m, m ZO a_ O1 .~ Z ~ ~ ~ ' H tW ~ !W- n ;-. a ~ _ U v t;~ ~> WYpW ;t . - a ¢ _ ¢Q~3 ~ to ~ a J=J;Q ca = = z Q o _ fAWY¢O U U ~ ~ 7 aLL LL ,t 002¢0 '~ ~. '4L '{F ':` '~ ~ ~ ~` ~~ ~ ` F y . y Tf ~^"~ ~ W ru in > V ~ ' n ~ ~ _ ~ C~ Q ~ U xc j c n i J gm~ w ~ ~W ~} o a~ a ~OO = a ~ y ^ U / n ~,,, ~} O ~ # fc~ r~ ~*~ a't ~~ ~~ ~ nn ,J ~~ n ~ :~ r~-~ --y ~ , ~J ~ V J ,~ ~ ,~_ ~ V ~`` `l} > ~ ,~ ~~ ~ -~ t '~~7 y ~ t • Ca U 5 C,% un ~: O • • U Z W C? w ^+ w U Z "".,~ ~'" Z w N ~ W r„r z_ _ ~ w m ~ ~ W z o tI. z Q ~~pp t~0 ~ P9 M ~~ ~ /''~ .~ u J O ~ w LCD _ `/~, .r-- U ~ ! V .~ o ~~ w ~' W ~ ~ ~ ~ -'> ~ tF Q ~ ~ ~ ~ ~ • # :.! ~ .w ~ ~ d Y ~ G~ a p +F ~ . r # (. '' • I Q ~ ~ ~, N ~ 4# = m ~ ~ Z Q ~ m d -- • Z ~ Q c = E ~~ H ' w Z Q U U ~,;. ~- 4,'~ «, o ~++ x¢¢x ~t« LLwor d ~ ¢r~;w >3iJYx ~ x., ~, ~ aaz<~ Q . + • ~za~u J ~ OVaOx O .- WLLaia 0 i°~¢ ~ (i'7 i y ~z°xIZ O .r'`.. ~ `LLU¢ U 4~ U~maLL r'f ~.. z ¢ ~ + 8300° ~ * ~ *z : r r~ ua iF ~- ~ ~ ~ ~ r --- 4n x.. ,.a U a N * F-a G: 41,1 W cn > _ ~ o ~ ~ = ~ ~ ~ aLL a c .~, Y/ F- "' ~ F m c o ~ u p Q ~ ; G K W~ ~ m~ ~ 0 a^ > a .. ~ LL ~ 00 LJ1 .-~ ~a [~ r'1"1 l .a O r'1'I [~ ~~ ~ , [.0 f1J ~a ~~ fY1 0 ~~ O r. .a or site" should be read as "proposal," "proposer," and "affected geographic area," respectively. CITY OF YELM CITY USE ONLY FEE: $150.00 ENVIRONMENTAL CHECKLIST DATE RECD BY: ~E~E~Q FILE NO. ~' ~ ~'~ _ ~`~~~ -y ~-- A. BACKGROUND 1. Name of proposed project, if any: Polyurethane 2. Name of applicant: Lasco Bathware Inc. 3. Address and phone number of applicant and of any other contact person: 801 Northern Pacific Yelm, WA. 98597 4. Date checklist prepared: 12/19/02 5. Agency requesting checklist: ORCAA 6. Proposed timing or schedule (including phasing, if applicable): March 1, 2003 7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. No 8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. Notice to Construct for ORCAA 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. No 10. List any government approvals or permits that will be needed for your proposal, if known. Permit to Construct from ORCAA .~~ ~~,~ ~ 6~~ ~ ~ 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. ~.,~p, ~ ~ '' Lasco Bathware proposes to substitue its polyester resin with polyurethane in the thirds ~ ~~CC~~ ~Z~ stage of its production process. This change will eliminate styrene emissions from this i f h i P l h h ~ p ~ ~"' ~ po nt o t e operat on. yeuret anes o ave been found to have insignificant emission n ~ and will help Lasco reduce the amount of styrene put into the air. /^~~ VV 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. You need not duplicate maps or detailed plans submitted with any permit applications related to this checklist. The proposed change would take place at 801 Northern Pacific in Yelm. On the FRP bathtub production line. B. ENVIRONMENTAL ELEMENTS 1. Earth a. General description of the site (circle one): flat, rolling, hilly, steep slopes, mountainous, other b. What is the steepest slope on the site (approximate percent slope)? Loading dock ramp 8% c. 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. Sandy Loam with River rock d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. None e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. Indicate source of fill. None f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe. None Page 2 g. About what percent of the site will be covered with impervious surfaces after project construction such as asphalt or buildings? None h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: None 2. Air a. What types of emissions to the air would result from the proposal (i.e., dust, automobile exhaust, odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate ~~ pp~~ quantities if known. ~1` MDI = 5 pounds per year ~~, ~~/y b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe. None c. Proposed measures to reduce or control emissions or other impacts to air, if any: Lasco Bathware is voluntarily converting from polyester resin to polyurethane. This change will reduce approximately 15% of Lasco's overall emissions. 3. Water a. Surface Water 1) Is there any surface water body or wetland on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds)? If yes, describe type and provide names. State what stream or river it flows into? None 2) Will the project require any work over, in, or adjacent to (within 300 feet) the described waters? If yes, please describe and attach available plans. None 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 Page 3 4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. None 5) Does the proposal lie within a 100-year floodplain? If so, note elevation on the site plan. No 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. Groundwater: 1) Will groundwater be withdrawn, or will water be discharged to groundwater? Give general description, purpose, and approximate quantities if known. No 2) Describe the underlying aquifer with regard to quality and quantity, sensitivity, protection, recharge areas, etc. No 3) Describe waste material that will be discharged into or onto the ground from septic tanks or other sources, if any (such as domestic sewage; industrial byproducts; agricultural chemicals). None c. Water Runoff (including storm water): 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 the facility percolates into the ground. ~~ 2) Could waste materials enter ground or surface waters? If so, generally describe. ~~ ` No ~~ ~ -~~` ~ ~~ ~~ d. Proposed measures to reduce or control surface, ground, and runoff water 1~ impacts, if any: J None Page 4 4. Plants a. Check or circle types of vegetation found on the site: deciduous tree: alder, maple, oak, aspen, other evergreen tree: fir, cedar, pine, other _X_ shrubs _X_ grasses pasture crops or grains wet soil plants: cattail, buttercup, bulrush, 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? None c. List threatened or endangered species 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: None 5. Animals a. Circle any birds and animals that have been observed on or near the site or are known to be on or near the site: birds: hawk, heron, ducks, eagle, songbirds, other: pigeons, crows and sparrows mammals: deer, bear, elk, beaver, other: Deer fish: bass, salmon, trout, shellfish, other: None b. List any priority, threatened or endangered species known to be on or near the site. None c. Is the site part of a migration route? If so, explain. None d. Proposed measures to preserve or enhance wildlife, if any: None Page 5 6. Energy and Natural Resources a. What kinds of energy (electric, natural gas, gasoline, heating oil, wood, solar etc.) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, transportation, etc. No new energy requirements 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: None 7. Environmental Health a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spills, of hazardous waste, that could occur as a result of this proposal? If so, describe. Risk of exposure to MDI if spills occur. 1) Describe special emergency services that might be required. Safety shower in location of materials ~~ /~ `l ~ 2) Proposed measures to reduce or control environmental health hazards, if any: \ Training, secondary containment ~~ ~. 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)? Indicate what hours noise would come from the site. None 3) Proposed measures to reduce or control noise impacts, if any: None 8. Land and Shoreline Use Page 6 a. What is the current use of the site and adjacent properties? The current site is used only for manufacturing. Adjacent properties are used for manufacturing, residential, a church and a sewage treatment plant. b. Has the site been used for mineral excavation, agriculture or forestry? If so, describe. No c. Describe any structures on the site. Warehouse, Office buildings and production facility d. Will any structures be demolished? If so, what? no e. What is the current comprehensive plan designation of the site? Industrial f. What is the current zoning classification of the site? Industrial/Commercial g. If applicable, what is the current shoreline master program designation of the site? N/A h. Has any part of the site been classified as a "natural resource", "critical" or "environmentally sensitive" area? If so, specify. N/A Approximately how many people would reside or work in the completed project? 200 j. Approximately how many people would the completed project displace? 0 k. Proposed measures to avoid or reduce displacement impacts, if any: N/A I. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any: N/A Page 7 9. Housing a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing. N/A b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing. N/A c. Proposed measures to reduce or control housing impacts, if any: N/A 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? N/A b. What views in the immediate vicinity would be altered or obstructed? N/A c. Proposed measures to reduce or control aesthetic impacts, if any: N/A 11. Light and Glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur? N/A b. Could light or glare from the finished project be a safety hazard or interfere with views? N/A c. What existing off-site sources of light or glare may affect your proposal? N/A d. Proposed measures to reduce or control light and glare impacts, if any: N/A 12. Recreation a. What designated and informal recreational opportunities are in the immediate vicinity? N/A Page 8 b. Would the proposed project displace any existing recreational uses? If so, describe. N/A c. Proposed measures to reduce or control impacts or provide recreation opportunities: N/A 13. Historic and Cultural Preservation a. Are there any places or objects listed on, or proposed for, national, state, or local preservation registers known to be on or next to the site? If so, generally describe. N/A b. Generally describe any landmarks or evidence of historic, archeological, scientific, or cultural importance known to be on or next to the site. N/A c. Proposed measures to reduce or control impacts, if any: N/A 14. Transportation a. Identify sidewalks, trails, public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any. N/A b. Is site currently served by public transit? By what means? If not, what plans exist for transit service? N/A c. How many parking spaces would the completed project have? How many would the project eliminate? N/A d. Will the proposal require any new sidewalks, trails, roads or streets, or improvements to existing sidewalks, trails, roads or streets, not including driveways? If so, generally describe (indicate whether public or private). N/A Page 9 e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe. N/A f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur. N/A g. Proposed measures to reduce or control transportation impacts, if any: N/A 15. Public Services a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe: N/A b. Proposed measures to reduce or control direct impacts on public services, if any. N/A 16. Utilities a. Circle utilities currently available at the site- electricity, natural~c as, water, refuse service, telephone, sanitary sewer., septic system, other. 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. N/A C. SIGNATURE The above answers are true and complete to the best of my knowledge. I understand that the City of Yelm is relying on them to make its decision. Signature: Y K~f` ~ ~'L~~,~- - '~ ~!~ ~~j -/~aa~~;~8' Date Submitted: / ~ ~~ _ V Page 10 2. PROJECT DESCRIPTION AND BACKGROUND Lasco Bathware Inc. proposes to modify the existing "gelcoat" production line at their facility in Yelm, Washington, by adding material storage structures and equipping the third lamination station (ID#s A8 & A9) with two new day tanks and new spray equipment. The proposed modifications and new equipment only involve the third lamination station. Production operations and equipment prior to and after the third lamination station will remain unchanged. The modifications will provide Lasco the flexibility to incorporate a polyurethane layer as the third lamination in the composite structure of its products. It is Lasco's intent to completely eliminate using polyester resin in the third lamination. The proposed polyurethane material will consist of a one to one mixture of "polyol" resin and a solution containing isocyanate. The isocyanate solution contains 4', 4'-methylene diisocyanate (MDI) and polymeric methylene diisocyanate isomer (PMDI), and has a composition of 45% MDI and 50% PMDI. MDI is both a federally listed hazardous air pollutant (HAP) and a toxic air pollutant (TAP) regulated under Washington air regulations for new toxic air pollutant sources (WAC 173-460). According to the MSD sheet for the material, MDI is only HAP~TAP constituent of the isocyanate solution. According to the Material Safety Data Sheet for the polyol resin, it does not contain any Urethane.02NOC276.FD Page 1 of 13 volatile HAPs or TAPs. Lasco will construct a storage rack for storing totes of the polyol resin and isocyanate. The storage rack will be located within the main production building adjacent to the main production line referred to as the "gelcoat" production line. The proposed storage rack will be capable of storing up to 40 storage totes. Each tote will weigh 2,500 pounds and will contain 270 gallons of either resin or isocyanate. A staging rack and two new day tanks, one for resin and one for isocyanate, will be constructed directly adjacent to the third lamination spray station. The day tanks will hold the resin and isocyanate prior to spray application. Each will have a 350 gallon holding capacity. The day tanks will be covered and vented to the building air space. Day tanks will be gravity filled from storage totes in a batch-wise fashion. A tote will be placed above a day tank in the staging rack, connected to the day tank and then allowed to gravity flow into the day tank. During filling, vapors in the day tank will be vented into the building. Storage totes will be fitted with special moisture knock-out filters while being offloaded into the day tanks to remove any moisture that may react with the isocyanate. Empty storage totes will be closed and periodically sent to a recycler. Emissions of MDI from the displacement of vapors in the day tanks were accounted for in emission calculations (see below) and were determined to be insignificant. During production, resin and isocyanate will be pumped from their respective day tanks to special mixing heads that mix the polyol resin and isocyanate to form the polyurethane within the head just prior to spraying. The polyurethane is then spray applied to the surface of the composite within the third lamination station. The reaction of the polyol resin with the isocyanate is exothermic resulting in elevated temperatures on the surface of the polyurethane lamination up to 140 °F. Curing of the polyurethane is rapid with a tack time of 30 to 40 seconds. Emissions resulting from spray application of polyurethane were accounted for (see below) and make up the bulk of the emissions increase proposed. There will be no physical modifications to the third lamination spray station except for equipping it with spray equipment capable of mixing and delivering the two-part polyurethane and constructing the staging rack adjacent to the station. This will also involve equipping the booth with a boom capable of supporting the new mixing heads and spray guns. Emissions from the third lamination station will be captured by the existing capture system and exhausted directly to the outside air through the four existing 75' exhaust stacks. Production operations and equipment prior to and after the third lamination station will remain unchanged. Urethane.02NOC276.FD Page 2 of 13 t 8 Send To Printer Back to Map Yelm WA 98597 US Notes: _ bleed Roadside Help? (~~t a Ic~cksrnitf-~, tCr;+;+, tine changa, jl_Jmp-tart or ga-. ~~~ ~ ]I_J t $b~1,'aU t+;+t-~~n '~+rla rrleriti~,n Nlap~,~l_J~•=t rude 170?. 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