DEPARTMENT OF ENVIRONMENTAL QUALITY 

DMSION OF AIR QUALITY 

Micbacl o. Leavin 150Nonb 1950 West 

Go-..or P.O. Box 144820 

Dianne R. Nielson. Ph.D. Salt Lake City. Utah 84114~820

EuicuDw I>ua:ulr (80l) 536-4000 

Russell A. Roberts (801) 536-4099 Fax 

DiIa:ulr (801) 538-4414 T.O.D. 

December 7, 1995	 DAQE-1134-95 

Lynn S. Hill 

Hill Air Force Base 

Headquaners 

Ogden Logistics Center (AFMC) 

Hill Air Force Base, Utah 84056 

Dear Mr. Hill: 

Re:	 Approval Order for Setup Chemical Milling Process Line in Bldg 238 

Davis County, CDS-AI, Non-Attainment., Title V 

The attached document is an Approval Order for the above referenced project. 

Future correspondence on this Approval Order should include the engineer's name as well as the DAQE 

number as shown on the upper right-hand corner of this letter. Please direct any technical questions you 

may have on this project to Mr. Nando Mell. He may be reached at (801) 536-4052. 

RAR:NM:aj 

cc:	 Davis County Health Department 

28 East State Street 

POBox 618 

Farmington, UT 84025-618 

' . • I'll

. 4.2.4-61 

P"ntea on recycled Daper 
DAQE-1134-95 

Pagel 

STATE OF UTAH 

Department of Environmental Quality 

Division of Air Quality 

APPROVAL ORDER FOR SETUP CHEMICAL MILLING
 

PROCESS LINE IN BLDG 238
 

Prepared By: Nando Meli, Engineer 

801·536-4052 

APPROVAL NUMBER 

DAQE.1134.95 

Date: December 7, 1995 

Source 

Hill Air Force Base 

Lynn S. Hill . 

801-777-0359 

Russell A. Roberts
 

Executive Secretary
 

Utah Air Quality Board
 

4.2.4-62
 
DAQE-1134-95 

Page 2 

Abstract 

Hill Air Force Base (AFB) is requesting approval to move and replace their existing Chemical Milling 

Process Line (Chem MiU Line). The current Chem Millli.ne is a grand/athered source and needs to be 

relocated from Building 265 to Building 238. A water based maskant will replace the existing solvent 

based maskant that is currently being used. This new maskllnl wiU result in the VOC emissions being 

reduced from 11.9 to 0.38 tons per year. The Sodium Hydroxide emissions will remain at 0.29 tons per 

year and the Isoprep emissions wiU remain at 0.44 tons per year. Hill AFB is a major source that is 

located in Davis Counry which is a Nonattainment Area/or PM1D and Ozone. 

The above-referenced project has been evaluated and found to be consistent with the requirements of the 

Utah Air Conservation Rules (UACR) and the Utah Air Conservation Act. A 30-day public comment 

period was held and all comments received were evaluated. The conditions of this AO reflect any changes 

to the proposed conditions which resulted from the evaluation of the comments received.This air quality 

AO authorizes the project with the following conditions and failure to comply with any of the conditions 

may constitute a violation of this order: 

General Conditions; 

1.	 This AO applies to the following company: 

Facility Location 

Depanment of the Air Force
 

Headquaners Ogden Logistics Center (AFMC)
 

Hill Air Force Base, Utah
 

PHONE NUMBER (801) 777-0359
 

FAX NUMBER (801) 777-6742
 

The equipment listed below in this AO shall be operated at the following location: 

PLANT LOCATION: 

East of Exit 336 on Interstate 15 

Universal Transverse Mercator (UTM) Coordinate System: 

4,55.5 kilometers Northing; 418.0 kilometers Easting; Zone 12 

2.	 Definitions of tenus, abbreviations, and references used in this AO conform to those used 

in the UACR, Utah Administrative Codes (UAC), and Series 40 of the Code of Federal 

Regulations (40 CFR). These definitions take precedence unless specifically defined 

otherwise herein. 

3.	 Hill Air Force Base (AFB) shall install and operate the Chemical Processing Line in 

Building 238 according to the terms and conditions of this AO as requested in the Notice 

of Intent dated March 3, 1995, and additional information submitted to the Executive 

Secretary dated May 3, 1995, and May 6, 1995. 

4.2.4-63 
DAQE-1134-95 

Page 3 

4.	 A copy of this AO shall be posted on site. The AO shaH be available to the employees 

who operate the air emission producing equipment. i.":lese employees shall receive 

instruction as to their responsibilities in operating the equipment according to all of the 

relevant conditions listed below. 

5.	 The approved installations shall consist of the following equipment or equivalent: 

A.	 Five 2000 gallon Chemical ~.filling Process Tanks 

1)	 Maskant Dip Tank 

2)	 Hot Water Dip Tank 

3)	 Isoprep Tank 

4)	 Water Spray Rinse Tank 

5)	 Sodium Hydroxide Tank 

* Equivalency shall be detennined by the Executive S:cretary. 

Limitations and Tests Procedures 

6.	 Visible emissions from any stationary point or fugitive emission source associated with 

the source or with the control facilities shall not exceed 10% opacity. Opacity 

observations of emissions from stationary sources shall be conducted in accordance with 

40 CFR 60. Appendix A. Method 9. 

7.	 The following production limits shall not be exceeded without prior approval in 

accordance with R307-1-3.1. UAC: 

A.	 1500 gallons of Water Based Maskant per rolling l2-month period 

B.	 660 gallons of Sodium Hydroxide per rolling 12-month period 

C.	 220 gallons of Isoprep per rolling 12-month period 

Compliance with the annual limitations shall be deter: :.;.ed on a rolling 12-month total. 

The owner/operator shall calculate a new 12-month tow.i based on the flrstiay of each 

month using data from the previous 12 months. Records of consumption ~ill be kept for 

all periods when the plant is in operation. Records of consumption. including rolling 12­

month totals shall be made available to the executive secretary or his representative upon 

request and shall include a period of two years ending ',','ith the date of the request. 

Consumption shall be determined by purchase records and operations log. The records 

shall be kept on a daily basis. 

Volatile Daanic Compound cyOC) and Hazardous Air Pollutants (HAPs) Limitations 

8.	 The facility shall abide by all applicable requirements of UAC R307-14 for volatile 

organic compound (VOC) sources located in an ozone Nonattainment area At a 

minimum. RACf control measures are required and BACf will be no less stringent than 

RACT. These requirements include but are not limited to: 

4.2.4-64 
DAQE-1134-95 

Page 4 

"14-5.A.(5) Written procedures for the operation and maintenance of the 

degreasing or solvent cleaning equipment shall be permanently posted in an 

accessible and conspicuous location near the equipment." 

The full text ofUAC R307-14 is included as Appendix A. However. to be in compliance. 

this facility must operate in accordance with the most current version of R307-14 or the 

applicable section(s), if renumbered. 

9.	 The emissions ofVOCs from the Chemical Milling Process Line tanks. etc. and 

associated operations located in Building 238 shall not exceed: 

0.38 tons per rolling 12-month period for VQCs 

This value shall not be exceeded without prior approval in accordance with R307-1-3.1, 

UAC. Compliance with the limitation shall be determined on a rolling 12-month total. 

Based on the first day of each month a new l2-month total shall be calculated using data 

from the previous 12 months. 

VOCs and HAPs emissions from the chemical milling process line in Building 238 

emitted to the atmosphere shall be determined by maintaining a record of volatile organic 

compound potential and hazardous air pollutant potential contained in materials used each 

month. The record shall include the following data for each item used: 

A.	 Name of the VOC and HAPs emitting material, such as: paint, adhesive. solvent. 

thinner. reducers. chemical compounds. isocyanates. etc. 

B.	 The weight and use location of the volatile organic compound potential and 

hazardous air pollutant potential of the material(s) listed in A in pounds per 

gallon. 

C.	 Percent by weight of all volatile organic compound potential and hazardous air 

pollutant potential for each individual material listed in A. The percent by weight 

of the volatile and hazardous air pollutant potentials can be obtained from the . 

manufacturers' MSDSs. The owner/operator can obtain MSDS data from the 

manufacturers of the materials and retain the information on-site. 

D.	 Amount and location of materials containing VOCs and HAPs used on a monthly 

basis and summed for every location and for the entire plant each month. 

E.	 To calculate the above potentials contained in the material listed in D use the 

following procedure: 

voc =(% volatile by Weight) x (Density Ib) x (Gal Consumecj) x (.l...lm1) 

(100) (gal)	 (2.000 lb) 

F.	 The amount of volatile organic content potential (potential air emissions) and 

hazardous air pollutant potential (potential air emissions) in pounds contained in 

materials deposited as solid or hazardous waste for the month shall be quantified 

and subtracted from the quantities calculated above. This is done to allow 

4.2.4-65 
DAQE-1134-95 

PageS -. 

quantification by the source of the total VOCs and HAPs emissions. (The 

assumption is that all the two above potentials of the materials applied to :.l 

product evaporate and are therefore considered emissions). 

G.	 Records of consumption of VOCs and HA.;s shall be kept for all periods . hen 

the plant is in operation. Records of consumption shall be maoe availab; . to the 

executive secretary upon request. and shall include a period of two years cnding 

with the date of the request. 

10.	 All HAPs are subject to the annual Operating Permit Program if one of the following 

conditions is met: 

A.	 The emissions of anyone of the 189 HAPs listed in the 1990 Clean Air Act is 

over ten (10) tons/yr 

B.	 The emissions of any combination of these HAPs are over 25 tons/yr 

11.	 This source is a major Title V source needing an Operating Permit. It is required to pay 

an annual emission fee upon stan-up [or if an existing facility, upon issuance of this AO. 

The fee will be based on calculated annual emissions listed at the end of this AD. This fee 

is valid until inventory data for one year are available for the source. The owner or 

operator of this source will be billed upon start-up for all emissions that are considered 

"chargeable" as of that date. 

Records & MiscellaneoUS 

12.	 All installations and facilities authorized by this AD shall be adequately and properly 

maintained. All pollution control vendor recommended equipment shall be installed, 

maintained. and operated. Instructions from the vendor or established maintenance 

practices that maximize pollution control shall be used. All necessary equipment control 

and operating devices, such as pressure gauges, amp meters, volt meters, flow rate 

indicators. temperature gauges. etc.• shall be installed and operated properly and easily 

accessible to compliance inspectors. A copy of all manufacturers' operating instructions 

for pollution control equipment and pollution emitting equipment shall be kept on site. 

These instructions shall be available to all employees who operate the equipment and shall 

be made available to compliance inspectors upon their request. 

13.	 The owner/operator shall comply with R307-1-3.5. UAC. This rule addresses emission 

inventory reporting requirements. 

\4.	 The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses 

unavoidable breakdown reporting requirements. The owner/operator shall 

calculate/estimate the excess emissions whenever a breakdown occurs. All excess 

emissions shall immediately be reported to the executive secretary. The total of excess 

emissions shall be reponed to the executive secretary as directed for each calendar year. 

15.	 All records referenced in this AD which are required to be kept by the owner/operator, 

shall be made available to the Executive Secretary or his representative upon request and 

shall include a period of two years ending with the date of the request. All records shall 

4.2.4-66 
DAQE-1134-95
 

Page 6
 

be kept for a period of two years. Examples of records to be kept at this source shall 

include the following as applicable: 

A. Production rate (Condition number 7) 

B. VOC and HAP consumption records (Condition number 10) 

C. Maintenance records (Condition number 12) 

D. Upset, breakdown episodes (Condition number 14) 

Any future modifications to the equipment approved by this order must also be approved in accordance 

with R307-1-3.1.1, UAC. 

This AO in no way releases the owner or operator from any liability for compliance with all other 

applicable federal, state, and local regulations including the UACR. 

Annual emissions for this Chemical Milling Process Line at Building 238 are currently calculated at the 

following values: 

Pollutant Ions/yr 

A. VOC; 0.38 

B. NaOH 0.29 

C. Isoprep 0.44 

•.- These calculations are for the purposes of detennining the applicability of Prevention of Significant 

Deterioration and Nonanainment area major source requirements of the UACR. Except for VOC's they 

are not to be used for purposes of determining compliance. 

In accordance with the requirements of Title V of the 1990 Clean Air Act. the following pollutants may be 

subject to an operating permit fee. Emissions of the following pollutants from all sources, including preNovember 19, 1969, sources, may be subject to the operating permit fee. Both the fees rate and the class 

of pollutants are subject to change by State, the federal agencies, or both. 

Pollutant Ions/yr 

VOC 0.38 

4.2.4-67
 
DEPARTMENT OF ENVIRONMENTAL QUALITY 

DMSION OF AIR. QUALITY 

Michael O. Le.avitt 150Nonh 1950 West 

Gawmar P.O. BOll 144820 

Dianne R. Nielson. Ph.D. Salt Lalce City. Utah 84114-4820 

Ezecuaw: D!recIlr (80l) 5364000 

Russell A. Roberts (801) 536-4099 Fax 

Direclar (80l) 538-4414 T.D.D. 

October 18, 1995	 DAQE-951-95 

Hill Air Force Base 

Headquaners 

Ogden Logistics Center (AFMC) 

Hill Air Force Base. lIT 84056 

Dear Mr. Graziano: 

Re:	 Intent to Approve Setup Chemical Milling Process Line in Bldg 238 

Davis County, CDS-AI. Non-Attainment. Title V 

The attached document is an Intent to Approve for the'above referenced project. 

Future correspondence on this Approval Order should include the engineer's name as well as the DAQE 

number as shown on the upper right-hand comer of this letter. Please direct any technical questions you may 

have on this project to Mr. Nando Meli. He may be reached at (801) 536-4052. 

Sincerely, 

.h~/;:( ;{:/~~~~~~
 Ann R. Menlove. Manager 

New Source Review Section 

Utah Division of Air Quality 

LRM:NM:aj 

cc:	 Davis County Health Department 

28 East State Street 

POB 618 

Farmington. lIT 84025-618 

•	 4.2.4-68 

Printeo on recycled Dacer 
DAQE-951-95 

Page 2 

STATE OF UTAH
 

Department of Environmental Quality
 

Division of Air Quality
 

INTENT TO APPROVE SETUP CHEMICAL MILLING
 

PROCESS LINE IN BLDG 238
 

Prepared By: Nando Meli, Engineer 

(801) 536-4052 

INTENT TO APPROVE NUMBER 

DAQE-951-95
 

Date: October 18, 1995
 

Source
 

Hill Air Force Base 

Lynn S. Hill 

(801) 777-0359 

Russell A. Roberts
 

Executive Secretary
 

Utah Air Quality Board
 

4.2.4-69 
DAQE-951-95 -, Page 3 

Abstract 

Hill Air Force Base (AFB) is requesting approval to move and replace their existing ChemicDl Milling 

Process Line (Chem Mill Line). The cUn'ent Chem Mill Line is a grand/athered source and needs to be 

relocated from Building 265 to Building 238. A water based maskant will replace the existing solvent based 

maskant tluzt is cUn'ently being used. This new maskant will resuil in the VOC emissions being reduced 

from 11.9 to 0.38 tons per year. The Sodium Hydroxide emissions will remain at 0.29 tons per year and 

the Isoprep emissions will remain at 0.44 tons per year. HiIJ AFB is a major source tluzt is located in Davis 

County which is a Nonattainment Area/or PM/oand Ozone. 

The Notice of Intent for the above-referenced project has been evaluated and has been found to be consistent 

with the requirements of the Utah Air Conservation Rules (UACR) and the Utah Air Conservation Act. Air 

pollution producing sources and/or their air control facilities may not be constructed, installed, established. 

or modified prior to the issuance of an Approval Order (AO) by the Executive Secretary of the Utah Air 

Quality Board. 

A Notice of Intent to issue an AO will be published in the Newspaper Agency on October 23, 1995. A 304iy 

period following the publishing date will be allowed during which the proposal and evaluation of its impact 

on air quality will be available for both you and the public to review and comment. If anyone so requests 

within 15 days of publication of the notice, a hearing will be held. The hearing will be held as close as 

practicable to the location of the source. Any comments received during the 304iy period and the hearing, 

if held, will be evaluated. - Please review the proposed AO conditions during this period and make any comments you may have before 

its closure. The proposed conditions of the AO may be changed as a result of the comments received. Unless 

changed, the AD will be based upon the following conditions: 

General Conditions; 

1. This AD applies to the following company: 

facility Location 

Depamnent of the Air Force
 

Headquarters Ogden Logistics Center (AFMC)
 

Hill Air Force Base, Utah
 

PHONE NUMBER (801) 777-0359
 

FAX NUMBER (801) 777-6742
 

The equipment listed below in this AO shall be operated at the following location: 

PLANT LOCATION: 

East of Exit 336 on Interstate 15 

Universal Transverse Mercator (UTM) Coordinate System: 

4.2.4-70 
DAQE-951-95 

Page 4 

4.55.5 kilometers Nonhing; 418.0 kilometers Easting; Zone 12 

2.	 Definitions of tenn5. abbreviations. and references used in this AO conform to those used in 

the UACR. Utah Administrative Codes (UAC). and Series 40 of the Code of Federal 

Regulations (40 CFR). These definitions take precedence unless specifically defined 

otherwise herein. 

3.	 Hill Air Force Base (AFB) shall install and operate the Chemical Processing Line in Building 

238 according to the terms and conditions of this AO as requested in the Notice of Intent 

dated March 3. 1995. and additional information submiUed to the Executive Secretary dated 

May 3. 1995. and May 6. 1995. 

4.	 A copy of this AO shall be posted on site. The AO shall be available to the employees who 

operate the air emission producing equipmenL These employees shall receive insU1Jction as 

to their responsibilities in operating the equipment according to all of the relevant conditions 

listed below. 

5.	 The approved installations shall consist of the following equipment or equivalent: 

A.	 Five 2000 gallon Chemical Milling Process Tanks 

1) Maskant Dip Tank 

2) Hot Water Dip Tank 

3) Isoprep Tank 

4) Water Spray Rinse Tank 

5) Sodium Hydroxide Tank 

* Equivalency shall be determined by the Executive Secretary. 

Limitations and Tests Procedures 

6.	 Visible emissions from any stationary point or fugitive emission source associated with the 

source or with the control facilities shall not exceed 10% opacity. Opacity observations of 

emissions from stationary sources shall be conducted in accordance with 40 CFR 60. 

Appendix A. Method 9. 

7.	 The following production limits shall not be exceeded without prior approval in accordance 

with R307-1-3.1, UAC: 

A.	 1500 gallons of Water Based Maskant per rolling 12-month period 

B.	 660 gallons of Sodium Hydroxide per rolling 12-month period 

C.	 220 gallons of Isoprep per rolling 12-month period 

Compliance with the annual limitations shall be determined on a rolling 12-month total. The 

owner/operator shall calculate a new 12-month total based on the first day of each month 

4.2.4-71 
DAQE-951-95	 -. 

Page 5 

using data from the previous 12 months. Records of consumption shall be kept for all periods 

when the plant is in operation. Records of consumption. including rolling 12-month totals 

shall be made available to the executive secretary or his representative upon request and shall 

include a period of two years ending with the date of the request. Consumption shall be 

determined by purchase records and operations log. The records shall be kept on a daily 

basis. 

VolatHe Qrganic Compound (YOC) and Hazardous Air Pollutants (HAPs) Limjtations 

8.	 The facility shall abide by all applicable requirements of UAC R307-14 for volatile organic 

compound (VOC) sources located in an ozone Nonattainment area. At a minimum, RACf 

control measures are required and BACf will be no less stringent than RACf. These 

requirements include but are not limited to: 

"14-5.A.(5) Written procedures for the operation and maintenance of the degreasing 

or solvent cleaning equipment shall be pennanentiy posted in an accessible and 

conspicuous location near the equipment." 

The full text of UAC R307-14 is included as Appendix A. However, to be in compliance, 

this facility must operate in accordance with the most current version of R307-14 or the 

applicable section(s), if renumbered. 

9.	 The plant-wide emissions of VOCs from the Chemical Milling Process Line tanks, etc. and 

associated operations shall not exceed: 

0.38 tons per rolljn2 12-montb period (or yoCs 

This value shall not be exceeded without prior approval in accordance with R307-1-3.1, 

UAC. Compliance with the limitation shall be determined on a rolling 12-month total. 

Based on the first day of each month a new 12-month total shall be calculated using data from 

the previous 12 months. 

VOCs and HAPs emissions from the chemical milling process line in building 238 emitted 

to the atmosphere shall be determined by maintaining a record of volatile organic compound 

potential and hazardous air pollutant potential contained in materials used each month. The 

record shall include the following data for each item used: 

A.	 Name of the VOC and HAPs emitting material, such as: paint, adhesive, solvent, 

thinner, reducers, chemical compounds, isocyanates, etc. 

B.	 The weight and use location of the volatile organic compound potential and 

hazardous air pollutant potential ofthe material(s) listed in A in pounds per gallon. 

C.	 Percent by weight of all volatile organic compound potential and hazardous air 

pollutant potential for each individual material listed in A. The percent by weight 

4.2.4-72 
DAQE-951-95 

Page 6 

of the volatile and hazardous air pollutant potentials can be obtained from the 

manufacturers' MSDSs. The owner/operator can obtain MSDS data from the 

manufacturers of the materials and retain the information on-site. 

D.	 Amount and location of materials containing VOCs and HAPs used on a monthly 

basis and summed for every location and for the entire plant each month. 

E.	 To calculate the above potentials contained in the material listed in D use the 

following procedure: 

VOC = (% Volatile by Wej~ht) x (Density Ib) x (Gal Consumed) x (l.1ml) 

(l(0) (gal) (2,000 lb) 

F.	 The amount of volatile organic content potential (potential air emissions) and 

hazardous air pollutant potential (potential air emissions) in pounds contained in 

materials deposited as solid or hazardous waste for the month shall be quantified and 

subttaeted from the quantities calculated above. TIlls is done to allow quantification 

by the source of the total VOCs and HAPs emissions. (The assumption is thal all the 

two above potentials of the materials applied to a product evaporate and are therefore 

considered emissions). 

G.	 Records of consumption of VOCs and HAPs shall be kept for all periods when the 

plant is in operation. Records of consumption shall be made available to the 

executive secretary upon request, and shall include a period of two years ending with 

the date of the request. 

10.	 All HAPs are subject to the annual Operating Permit Program if one of the following 

conditions is met: 

A.	 The emissions of anyone of the 189 HAPs listed in the 1990 Clean Air Act is over 

10 tonslyr 

B.	 The emissions of any combination of these HAPs are over 25 tons/yr 

11.	 TIlls source is a major Title V source needing an Operating Permit. It is required to pay an 

annual emission fee upon start-up [or if an existing facility, upon issuance of this AO. The 

fee will be based on calculated annual emissions listed at the end of this AO. TIlls fee is valid 

until inventory data for one year are available for the source. The owner or operator of this 

source will be billed upon start-up for all emissions that are considered "chargeable" as of that 

date. 

RecQrds & Miscellaneous 

12.	 All installations and facilities authorized by this AO shall be adequately and properly 

maintained. All pollution control vendor recommended equipment shall be installed, 

maintained. and operated. Instructions from the vendor or established maintenance practices 

that maximize pollution control shall be used. All necessary equipment control and operating 

4.2.4-73 
DAQE-951-95 

Page 7 

devices, such as pressure gauges, amp meters. volt meters, flow rate indicators, temperatUre 

gauges, etc., shall be installed and operated properly and easily accessible to compliance 

inspectors. A copy of all manufacturers' operating inslIUctions for pollution control 

equipment and pollution emitting equipment shall be kept on site. These instructions shall 

be available to all employees who operate the equipment and shall be made available to 

compliance inspectors upon their requesL 

13.	 The owner/operator shall comply with R307-1-3.5, UAC. This rule addresses emission 

inventory reporting requirements. 

14.	 The owner/operator shall comply with R307-1-4.7, UAC. This rule addresses unavoidable 

breakdown reporting requirements. The owner/operator shall calculate/estimate ~e excess 

emissions whenever a breakdown occurs. All excess emissions shall immediately be reponed 

to the executive secretary. The total of excess emissions shall be reported to the executive 

secretary as directed for each calendar year. 

15.	 All records referenced in this AO which are required to be kept by the owner/operator, shall 

be made available to the Executive Secretary or his representative upon request and shall 

include a period of two years ending with the date of the request. All records shall be kept 

for a period of two years. Examples of records to be kept at this source shall include the 

following as applicable: 

.-.,.. 

A.	 Production rate (Condition number 7) 

B.	 VOC and HAP consumption records (Condition number 10) 

C.	 Maintenance records (Condition number 12) 

D.	 Upset. breakdown episodes (Condition number 14) 

Any future modifications to the equipment approved by this order must also be approved in accordance with 

R307-1-3.1.1, UAC. 

This AO in no way releases the owner or operator from any liability for compliance with all other applicable
 

federal, state, and local regulations including the UACR.
 

Annual emissions for this Chemical Milling Process Line .at Building 238 are currently calculated at the
 

following values:
 

Pollutant	 Tonslyr 

A.	 VOC " 0.38 

B.	 NaOH 0.29 

C.	 Isoprep 0.44 

These calculations are for the purposes of determining the applicability of Prevention of Significant
 

Deterioration and Nonattainment area major source requirements of the UACR. Except for VOCs they are
 

not to be used for purposes of determining compliance. 

- 4.2.4-74
 
DAQE-95 1-95 

Page 8 

In accordance with the requirements of Title V of the 1990 Clean Air Act, the following pollutants may be 

subject to an operating permit fee. Emissions of the following pollutants from all sources. including preNovember 19. 1969 sources. may be subject to the operating permit fee. Both the fees rate and the class of 

pollutants are subject to change by State. the federal agencies. or both. 

Pollutant Tons/yr 

A. VDC 0.38 

The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs incurred in the 

issuance of an AD. Unless public comments are received which require additional work. the fee for this AD 

will be $1,000.00. An invoice will follow. You may pay this fee prior to the end of the comment period. If 

there are comments or additional fees. you will be notified. 

Sincerely, 

nn R. Menlove. Manager 

New Source Review Section 

4.2.4-75
 
Newspaper Agency Corpo ~-1on

143 SOUTH ~!AI~ ST. 

P.O. BOX 458.38 ~t jalt ~kt f&tilnmt (~) DESERET ~I:.f\IS CUSTOMER'S

SALT LAKE CITY, VV"H 84145 -' COpy FED. TAX I.D. # 8 i-021 j 663 PROOF OF PUBLICATION 

,·/""··,RECEIVE 

\""':OCT 2$19~:l

CCOmIT . 

U 364000L-07 10/23/ 

CUSTOMER NAHE AND ADDRESS 

UT ST DEPT OF ENVR QULTY 

DIV OF AIR QUALITY 

P.O. BOX 144820 

SALT LAKE CITY, UT 84114 

ACCOUNT. NAME· Air Qualit 

UT ST DEPT OF ENVR OULTY 

··TELEPHONE ..•....•..•. INVOICE NUMBER . .... '«. 

801-536-4000 TLAI8200701 I 

SCHEDULE 

START 10/2~/9C) END 10/23/95 NOlie! •

ITile toIlOWlng nonce ot tnienl to CUST. REF. NO .. ... cansnuct. suDmmed In QCl:Of
 

aan<:e wnn secnon 3.1. Ulan I>Jr
 

conservanon Rules. nos Dee
 

reoetveQ 10' conslO8fOllCl/'l "V
 ....Execunve sec:relo/y. Ulan I>J
 QuatlIy Boara: .
 

n

, HILL AIR F , '. CAPTION 1 Mike GlaZlano. HiU All Force Ul I

ea.. 7274 WCICleion R~~",­ fI>J' Foree ilase. \Jlan ............
 5137. LOCC1Ion: 5e1UP ChemICCl NOTICETHE FOLLOWING NOTICE OF 

Milling Ptocess un- ln Bldg. 2Ja. 

. ·c····.·· . ·.SIZE 

1n-,i; Net Inc:reOs8 In i

,. . '-,Ions wtU De (A neoanve
 'nate:ales a d_on
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 66 LINES 1. 00 COLUMN ·11..47 tons""" . TIMES .. RATE n . 'Tile engineering e"aluallO Iond 01' QuClIIIV Is ImpCICt analYS nave oeen compl8MlQ at1Cl nol ·aa-se at quall1V IInCXICSI Cl'" 1 1.64 •e~eo. " IS me lntenl ot me
 

Exee::ulMt sea-rarv 10 ­ , .... ~projecI. ...... .. MISC~ CHARGES
 .' AD CHARGES

·!he consntJCl1on I)roposaI ond
 

I .sltmales ot .... ec18C1 on IOCXI
I 

ai, quautV. are 0VQIIallIe .. 101. .00 108.24

lI-. TOTAL' COST .. 

I

=~~n~':=tn'. ty. 

Vlronmentat UIOIISlale QuatIlV. 

~ot'1950 West
 

NoIlII- Teml)ie. ··san Lake C 11y. '
 

\JtoIl 84114420. WIlll9Il. c0m­
 108.24 ments rec:eMId "V I". DMIIOt\.
 

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 aI me 1OtIle._on or be­

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~~~~

Novemoer 22:"1995. - De AFFIDAVIT OF PUBLICATION Cll)I)IO\IOl ot N I)rOI)OI8Cl 

SII\ICllOt\. ~_

"~';;~k:.= NEWSPAPER AGENCY CORPORATION LEGAL BOOKKEEPER, I CERTIFY THAT THE ATTACHED 

=5=:~~0I7ERTISEMENT OF NOTICETHE FOLLOWING NOTICE OF FOR me NotiCe.' a IIeOMq WlU oe 

~~~_ana UT ST DEPT OF EN VR QOLT1 WAS PUBLISHED BY THE NEWSPAPER AGENCY
 

==~= PORATION, AGENT FOR THE SALT LAKE TRIBUNE AND DESERET NEWS, DAILY NEWSPAPERS
 

.=:c:~ot= rNTED IN THE ENGLISH LANGUAGE WITH GENERAL CIRCULATION IN UTAH, AND PUBLISHED dWlnga~De"""'" I==e~;"~j SALT LAKE CITY, SALT LAKE COUNTY IN THE STATE OF UTAH. 

~l/dlSQl:lPI'OIWOI:"ot·N" 

projecI.·:;"''':'''''c,~; -·:.3LISHED ON STP.RT 10/23/95 END 10/23/95 

~~:OCI.2.'I.1995. 1fh . NOT~"UBUC~ SIGNATURE .?~ /' ,/. JOANNE. 1o!OONEY ~"'t81!i'Or~S'_

.3a: i.JLK8 '::;1 \.i7 .j.o; c,e 

DATE 10/23. .'.. ~_.'_-. . I \w? ;.,.ty =X:;lr.. I

j It.Met.3~,i;sa ­

}3.;JO C:1,3 I ~xx.X qli~~ .;~ ~'D\ ST'\~OFUT»l

THIS IS NOT A STATEMENT BUT A "PROOF OF PUBLICATION" 

PLEASE PAY FROM BILLING STATEMENT. 

4.2.4-76 
DEPARTMENT OF ENVIRONMENTAL QUALm" 

DMSION OF AIR QUALITY 

Mic:hae.l O. Leavm 150 North 1950 West 

ao­ P.O. B01 144820 

Di_ R. Nie1soD. Ph.D. SaltLakcCity. Utah &4114-4820 

~Dinaor (801) 536-4000 

Russell A. Robens (801) 536-4099 Fax 

DiI.­ (801) 538-4414 T.D.D. 

October 18. 1995 DAQE-952-95 

Newspaper Agency 

Legal Advertising Department 

157 Regent Street 

Salt Lake City, lIT 84111 

This letter will confirm the authorization to publish the attached NOTICE in the Newspaper Agency on 

October 23. 1995. 

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, 

Division of Air Quality, P.O. Box 144820. Salt Lake City, Utah 841144820. 

Sincerely, 

~<'\!IrJ.Qc- . ararrlillo 

Office Technician 

Utah Division of Air Quality 

Enclosure 

• 4.2.4-77 

Printed on recycled oaper 
DAQE-952-95 

Pagel 

NOTICE 

The following notice of intent to construct, submitted in accordance with Section 3.1. Utah Air Conservation 

Rules. has been received for consideration by the Executive Secretary, Utah Air Quality Board: 

1.	 Mike Graziano
 

Hill Air Force Base
 

7274 Wardleigh Road
 

Hill Air Force Base. UT 84056-5137
 

Location: Setup Chemical Milling Process Line in Bldg 238
 

The Net Increase in Approved Emissions will be ( A negative sign indicates a decrease in 

emission rates.): 

.. 

voe ............................... -11.47 tons/year
 

The engineering evaluation and air quality impact analysis have been completed and no adverse air quality 

impacts are expected. It is the intent of the Executive Secretary to approve the construction project. 

The construction proposal and estiuwes of the effect on local air quality are available for public inspection 

and comment at the Division of Air Quality, Utah State Depanment of Environmental Quality, 1950 West 

North Temple. Salt Lake City, Utah 84114-4820. Written comments received by the Division. at the same 

address on or before November 22, 1995. will be considered in making the final decision on the 

approval/disapproval of the proposed construction. 

If anyone so requests to the Executive Secretary in writing, within 15 days of publication of the Notice, -


hearing will be held to explain the project and technical rationale for proposed action. A hearing will be 

4.2.4-78 
DAQE·952·95 

Page 3 

scheduled as close as practicable to the proposed project location. Comments obtained during a hearing will 

be evaluaxed and considered by the Executive Secretary before making a final decision on the 

approval/disapproval of the project. 

Date of Notice: October 23,1995 

4.2.4-79
 
__ 

L .AH DIVISION OF AIR OUALm 

NEW!MODIFIED SOURCE PLAN REVIEW 

Lynn S. Hill 

Chief. Envirorunental Compliance 

Depamnent of the Air Force 

Headquaners Ogden Logistics Center (AFMC) 

Hill Air Force Base. Utah 

RE: Relocation of Chemical Milling Process Line 

Davis County. CDS AI; NA: HAPs. TITLE V MAJOR 

REVIEW ENGINEER: Nando Meli 

DATE: September 13. 1995 

NOTICE OF INTENT DATED: May 3. 1995 

PLANT CONTACf: Mike Graziano 

PHONE NUMBER: (801) 777-0359 

FAX NUMBER (801) 777-6742 

PLANT LOCATION: East of Exit 336 on Interstate 15 Freeway 

UTM COORDINATES: 4.551.5 kIn Nonhing. 418.0 krn Easting. Zone 12 

FEES: 

Basic Approval Order Fee $1000.00 

Review Engineer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. $000.00 

Modeler . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. $000.00 

Notice To Paper $80.00 

Travel $000.00 

TOTAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. $1080.00 

APPROVALS: 

Peer Engineer ~/1l----,.....:.../~L~L..-m:......L......:.,----&4=""=:""::::..........L-Ir..l...JL~_t:J---+;~0~?:~/_?_·.r Mike Beheshti 

We request that you read the proposed Approval Order conditions: if you do not understand or do not agree 

with the contents of the conditions. please contact the review engineer within five days. However. when you 

understand the attached proposed/draft Approval Order conditions. please sign below and return. Thank You. 

Applicant Contact !}Jj:t J /~:£.i/ Gr{LhC1 ( q..;... J, 9j :4-( 

! ! (Signature & Date) ) 

F:\AQ\ENGINEER\NMeli\WPlHil-Chem.Rev 

- 4.2.4-80
 
TYPE OF IMPACT AREA 

Nonanainment Area 

PM10 .••••••••.••••••••••••••••.••••• Yes 

S01 No 

NO .•••••••••••••••••••....••..••••• No x 

CO No 

Ozone Yes 

NSPS No 

NESHAP No 

Hazardous Air Pollutants No 

Hazardous Air Pollutants Major Source No 

New Major Source " No 

Major Modification No 

PSD Permit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. No 

PSD Increment No 

(modeling) 

Send to EPA No 

Operating Permit Program Yes 

FOR MODIFIED SOURCES 

The Notice of Intent is for a modification to an existing source. The following standards apply in this 

review: 

NSPS applies to modification? No 

PSD review of entire source required? No 

NESHAPS applies to modification? . . . . . . . . . . . . . . . .. No
 

HAPs involved in modification? No 

TITLE V required for entire source? Yes 

HAPs MAJOR for modification? . . . . . . . . . . . . . . . . . .. No
 

NONATT MAJOR for entire source? Yes 

4.2.4-81 

Hill AFB Chem Mill Line Engineering Review 

September 13. 1995 

Page 2 
Abstract 

Hili Air Force Base (APB) is requesting approval to move and replace their existing Chemical Miiiing 

Process Line (Chem Miii Line!. The current Chem Miii Line is a grandfathered source and needs to be 

relocated from Building 265 to Building 238. A water based maskant wiii replace the existing solvent 

based maskant that is currently being used. This new maskant wiii result in the VOC emissions being 

reduced from 11.9 to 0.38 tons per year. The 5odium Hydroxide emissions wiii remain at 0.29 tons per 

year and the lsoprep emissions wiii remain at 0.44 tons per year. Hill APB is a major source that is 

located in Davis County which is a Nonattainment Area for PMIO and Ozone. 

I.	 DESCRIPTION OF PROPOSAL 

Hill Air Force Base (AFB) is requesting approval to move and replace their existing Chemical Milling 

Process Line (Chern Mill Line). The current Chern Mill Line is a grandfathered source and needs to be 

relocared from Building 265 to Building 238. A water based maskant will replace the existing solvent 

based maskant is presently being used. This new maskant will result in the VOC emissions being reduced 

from 11.9 tons to 0.11 tons per year. 

II.	 EMISSION SUMMARY 

The emissions from the Hill Air Force Base Chemical Milling Process Line will be as follows: 

Current Emissions Emission Changes Total Emissions 

Pollutant tons/vear tons/year tons/year 

VOC 11.85 , -11.47 " 0.38 

NaOH 0.29 0.0 . . . . . . . . . . . .. 0.29 

Isoprep . . . . . . . . . . . . . . . . 0.44 0.0 . . . . . . . . . . . .. 0.44 

The VOC emissions come from the warer based maskant. and 0.4% of the maskant is Styrene (0.4% x 

0.11 tpy =0.0004 tpy), 4% of the maskant is Toluene (4% x 0.11 tpy = 0.0044 tpy). 

III.	 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 

Presently a VOC maskant is being used on the Chemical Milling Process Line in Building 265. When 

the 01emical Milling Line is moved to Building 238 a new water based maskant will be used. This will 

result in a 99% reduction in VOC emissions. 

The New Source Review section recommends that the new Chemical Milling Process Line be accepted 

as BACf with a 10% opacity limit 

IV.	 APPLICABILITY OF FEDERAL REGULATIONS AND UTAH ADMINISTRATIVE 

CODES fUAC} 

TItis Notice of Intent is for grandfathered source. It is not a new major source or a major modification. 

The following federal regulations and state rules have been examined to determine their applicability to 

this Notice of Intent: 

1.	 R307-1-3.L UAC - Notice of Intent required for a modified source. This rule applies. 

A Notice of Intent is required for the new Chemical Milling Process Line. 

Hill AFB Chern Mill Line Engineering Review 4.2.4-82 

September 13, 1995 

Page 3 
2.	 R307-1-3.1.5. L .•C - Continuous program of constructio.. required to begin within 

eighteen months of Approval Order dare. If a continuous program of construction is not 

proceeding, the executive secretary may revoke the Approval Order. 

3.	 R307-1-3.1.7 (A), UAC - A Notice of Intent is not required for all narural gas fuel 

burning equipment with a total rared capacity of less than 5 MMBTU per hour. There 

will be no new natural gas devices installed. Therefore. this rule applies. and a Notice 

of Intent is not required based on this rule but is required based on R307-1-3.1. UAC. 

4.	 R307-1-3.1.7 (E), UAC - Notice of Intent required for a new parking lot of 600 or more 

spaces and adding 350 or more spaces to an existing lot. This rule will not apply because 

a new lot or addition is not being constructed. 

5.	 R307-1-3.1.7 (F), UAC - Notice of Intent not required for sources with emissions less 

than 10 tons/yr of the following compounds: 1.1.1-Oichloroethane. methylene chloride. 

nichlorofluoromethane. d.ichlorodifluoromethane. chlorodifluoromethane. trifluoromethane. 

1.1.2-trichloro-I.2.2-trifluoroethane. 1.2-dichloro1.1.22-tetrafluoroethane. methane. ethane 

and chloropentafluoroethane. However. if the source is emitting more than 10 tons/yr of 

any of these compounds. a Notice of Intent must be filed and an annual report of 

emissions thereafter. This emission point will not emit 10 tons/year of any of these 

regulated pollutants. Therefore. this rule applies. and a Notice of Intent is not required 

based on this rule. 

6.	 R307-1-3.1.8 (A). UAC - Application of best available control technology (BACT) 

required at all emission points. This rule applies to all sources throughout the state unless 

they are located in a Nonanainment area. RACT applies in Nonanainment areas. 

7.	 R307-1-3.1.8 (C), UAC - Approval of the Utah Air QUality Board (UAQB) is required 

before the executive secretary can approve a source under Section 3.6.5 that consumes 

more than 50% of a PSD increment. This rule does not apply to this NOI because a PSD 

permit is not being issued. 

8.	 R307-1-3.1.9. UAC - Rules for relocation of temporary sources. TIlls source is a 

permanent source. Therefore. this rule does not apply. 

9.	 R307-1-3.1.12. UAC - Requirement for installation of 10w-NO x burners on all eXisting 

sources whenever existing fuel combustion burners are replaced. unless the replacement 

is not physically practical OT cost effective. The effective date is November 15. 1990. 

There will be no burners replaced at this time. Therefore. this rule does not apply. 

However, BACT requires low NOx burners. 

10.	 R307-1-3.2.1. UAC - Paniculate emission limitations for existing sources that are located 

in a Nonanainment area. This rule has been superseded by the Section IX. Pans A and 

H of the SIP except for Weber County. TIlls source is not listed in the SIP. Therefore. 

this rule does not apply. 

II.	 R307-1-3.3.2. UAC - Review requirements for new major sources or major modifications 

that are located in a Nonanainment area or which impact a Nonattainment area This 

Notice of Intent does not represent a new major source or a major modification. 

Therefore. this rule will not apply. 

12.	 R307-1-3.3.3.B (2), UAC - Enforceable offset of 1.2: 1 required for new sources or 

mod.ifications that would produce an emission increase greater than or equal to 50.00 tons 

Hill AFB Chern Mill Line Engineering Review 4.2.4-83 September 13. 1995
 

Page 4
 
per year of any '- ..nbination of PM:a• SO:. and NO,. This is '_'-luired in Salt Lake. Davis. 

and Utah Counties and in any area that affects these three counties as defined in the rule. 

The effective date is November 15. 1990. This source will have no emission increases. 

Therefore. an offset will not be required. 

13.	 R307-1-3.3.3.B (3), UAC - Enforceable offset of li required for new sources or 

modifications that would produce an emission increase greater than or equal to 25.00 tons 

per year but less than 50 tons per year of any combination of PM10' SO:. and NO,. 'This 

is required in Salt Lake. Davis. and Utah Counties and in any area that affects these three 

counties as defined in the rule. The effective date is November 15. 1990. TItis source 

will have no emission increases. Therefore. an offset will not be required. 

14.	 R307-1-3.3.3.C. UAC - Enforceable offset of 1.15:1 required for new sources or 

modifications of sources as defined in Section 182 of the CAA. Section 182(b)(1 )(A)(i) 

of the CAA defines these sources as sources of volatile organic compounds and as sources 

of oxides of nitrogen. 'This is required in Salt Lake and Davis Counties and in any area 

that affects these three counties as defined in the rule. The effective date is August 16. 

1993. 'This source will have no emission increases. Therefore. an offset will not be 

required. 

If the contingency measures are triggered the following will not apply and see 

R30713.3.3.C on offsets for ozone Nonanairunent area restrictions. 

If it is an existing Major source with a 40 tpy increase or a new major source offsets of 

1.15: 1 are required. There will be no emissions increase. Therefore. an offset will not 

be required. 

15.	 R307-1-3.5. UAC - Emission inventory reporting requirements. TItis rule requires any 

source that emits 25 tons or more per year of any pollutant or any Pan 70 source to 

submit an emission inventory to the Division of Air Quality every year or as determined 

necessary by the executive secretary. TItis source must comply with this rule. 

16.	 R307-1-3.6.3. UAC - Prevention of Significant Deterioration (PSD) Increment 

Consumption - 'This rule lists the allowable PSD increment consumption. Under the PSD 

rules. the entire state has been triggered for Particulate (PM10)' S0:, and NO,. The 

allowable increments are as follows: 

Three Hour 24 Hour Annual 

Class I Area N/A 8	 4 

Class II Area N/A 30	 17 

Class I Area . . . . . . . . .. 25 5 2
 

Class II Area 5 12 91 20
 

Class I Area . . . . . . . .. N/A N/A 2.5 

Class II Area N/A N/A 25 

Hill AFB Chern Mil\ Line Engineering Review 4.2.4-84 

September 13, 1995 

PageS 
There are also L..5S III increments. which do not apply in \.-,db. The above increments 

apply at all locations. unless the area is already Nonanainment. The entire increment may 

not be available at all locations due to previously permined sources consuming increment 

17.	 R307-1-3.6.5 (b). VAC - Prevention of Significant Deterioration (PSD) review 

requirements for new major sources or major modifications. This Notice of Intent does 

not represent a new major source or a major modification under PSD rules. Therefore. 

this rule does not apply. 

18.	 R307-1-3.6.6. UAC - Increment violations. This rule requires the uAQB to promulgate 

a plan and implement rules to eliminate any PSD increment violations that occur in the 

state. No known violations have yet occurred. This proposed Notice of Intent will not 

consume any increments. 

19.	 R307-1-3.7. UAC - Air Quality Modeling - All estimates of ambient concentrations 

required in meeting the requirements of the regulations shall be based on appropriate air 

quality models. data bases. and other requirements specified in the Utah Guidelines to Air 

Quality Models. Modeling analysis is not routinely performed for air pollution sources 

with emissions below the following levels: 

Criteria for Screen Modeling 

(:2: Tons per Year) 

TSP 10 

PM 10 ••••••••••• 5 

SO:! 20 

N02 ..•••••••• 20 

CO 50 

VOC 20 °3 , ••.••••••••• 5

HAPs 10 

There will be no increase in emissions. Therefore. modeling will not be required. 

20.	 R307-1-3.8. UAC - Stack height rule. This rule limits the creditable height of stacks to 

that height determined to be good engineering practice. The formulas used to determine 

good engineering practice are fOWld in 40 CFR 51.100. The maximum creditable height 

of 65 meters (213.2 feet) is allowed. Hill AFB has no stacks that exceed 65 meters in 

height. Therefore. this source/facility is in compliance with this rule. 

21.	 R307-1-3.l0. UAC - Visibility screening analysis requirements. This rule requires all new 

major sources or major modifications to undergo a visibility screening analysis to 

determine visibility impact on any mandatory Class I area. This Notice of Intent does not 

represent a new major source or a major modification Wlder UACR rules. Therefore. this 

rule does not apply. 

22.	 R307-1-4.1.2. UAC - 20% opacity limitation at all emission points. Unless a more 

stringent limitation is required by New Source Performance Standards (NSPS) or BACT 

or National Emission Standards for Hazardous Air Pollutants (NESHAPS). In this case. 

an opacity limitation of 10% is recommended as BACT. 

23.	 R307-1-4.1.9. UAC - EPA Method 9 shall be used for visible emission observations. This 

rule applies. 

4.2.4-85 

HiU AFB Chern Mill line Engineering Review 

September 13. 1995 

Page 6 
24.	 R307-1-4.7, Ur. _ - Unavoidable breakdown reponing req\!••..:ments.1bis rule applies. 

Section 4.7.1 discusses reponing requirements. A breakdown for any period longer than 

two hours must be reponed to the executive secretary within three hours of the beginning 

of the breakdown, if reasonable. but in no case longer than 18 hours after the beginning 

of the breakdown. A written repon is required within seven calendar days. The report 

shall include the estimated quantity of pollutants (total and excess). R307-1-4.7.2 

discusses penalties. 

25.	 R307-1-5, UAC - Emergency episode requirements. 1bis rule requires the executive 

secretary to determine the stage and extent of an air pollution episode based on pollution 

levels and meteorological conditions. Under Section 40 of the Code of Federal 

Regulations, Part 51. Subpart H (51.150 to 153), it is required that sources plan 

emergency measures based upon the severity of the Nonattainment area in which they 

operate. In Utah, these rules require that CO sources in CO Nonanainment areas and 

sources of ozone precursors in ozone Nonanainment areas, who emit at least 25 tons per 

year (SIP, Section VII.B.) of either pollutant, submit an Emergency Episode Plan which 

provides for additional pollution reductions in the event of an Air Pollution Alen, 

Warning or Emergency Episode. These plans can include total shut-down of the process. 

(Some sources are required to submit an emergency episode plan according to Section 

VII.B. of the SIP). 1bis rule applies. 

26.	 R307-14. UAC - Review requirements for volatile organic compound (VOC) sources 

located in an ozone Nonattainment area. For sources located in ozone Nonattainment 

areas (Salt Lake and Davis Counties) this rule specifies the minimwn (RACI') control 

measures promulgated by the Utah Air Quality Board. In addition, UACR 3.1.1 requires 

application of BACT for all new or modified sources in the state. However, within an 

ozone Nonanainment area BACT can not be less stringent than RACT. Therefore, for 

ozone Nonanainment areas the more stringent requirement is applicable (i.e., BACT as 

required by UACR 3.1.1 or RACT as defmed by rule 14 or as defined in a published 

Control Techniques Guidance document). 

1bis 14 rule covers the following processes: 

A.	 Section 14-1 - General 

B.	 Section 14-2 - Petrolewn liquid storage 

C.	 Section 14-3 - Gasoline transfer/storage 

D.	 Section 14-4 - Control of hydrocarbon emissions in refineries 

4.A.	 Vacuum producing systems 

4.B	 Wastewater separators 

4.C	 Process unit turnaround 

4.D	 Catalytic cracking units 

4.E	 Safety pressure relief valves 

4.F	 Leaks from petrolewn refinery equipment 

E.	 Section 14-5 - Degreasing and solvent cleaning operations 

1) Cold cleaning facilities
 

2) Open top vapor degreasers
 

3) Conveyorized degreasers
 

4.2.4-86 

Hill AFB Chern Mill Line Engineering Review 

Seplember 13, 1995 

Page? 
F. Section _+-6 - Cutback asphalt 

G. Section 14-7 - Surface Coating Processes 

1) Section 7.A - General Provisions 

2) Section 7.B - Paper Coating 

3) Section 7.C - Fabric and Vinyl Coating 

4) Section 7.D - Metal Furniture Coating VOC Emissions 

5) Section 7.E - Large Appliance Surface Coating VOC Emissions 

6) Section 7.F - Magnet Wire Coating VOC Emissions 

7) Section 7.G - Rat Wood Coating 

8) Section 7.H - Miscellaneous Metal Pans and Products VOC Emissions 

9) Section 7.I - Graphic Arts 

10) Section 7.J - Exemptions 

11) Section 7.K - Capture Systems 

12) Section 7.L - Testing and MOnitoring 

H. Section 14-8 - Perchloroethylene Dry Cleaning Plants 

1. Section 14-9 - Compliance Schedule 

J. Section 14-10 - Stage II Vapor Recovery Systems 

For painting operations this rule specifies specific limits on the VOC content in paints and 

coatings used. In addition there is a provision for allowing use of coatings with higher 

VOC content if. because of emission control measures. "equivalent" emissions will result. 

Therefore. sources proposing to use coatings that do not meet the VOC contents specified 

in rule 14. must submit an analysis of their control measure that demonstrates equivalency 

with the VOC limitations of rule 14. 

The published erGs as of April 1, 1995 include: 

1) Control Methods for Surface Coating Operations 

2) Surface Coating of Cans. Coils. Paper. Fabrics. Automobiles. and LightDuty Trucks 

3) Surface Coating of Metal Furniture 

4) Surface Coating of Insulation of Magnet Wire 

5) Surface Coating of Large appliances 

6) Surface Coating of Miscellaneous Metal Pans and Products 

7) Surface Coating of Rat Wood Paneling 

8) Graphic Ans - Rotogravure and Rexography 

9) Bulk Gasoline Plants 

10) Storage of Petroleum Liquids in Fixed Roof Tanks 

11) Wastewater Separators and process unit turnarounds 

12) Use of Cutback Asphalt 

13) Tank Truck Gasoline Loading Terminals 

14) Stage I Vapor Control Systems - Gasoline Service Stations 

15) Leaks from Petroleum refmery Equipment 

16) Manufacture of Vegetable Oils 

17) Petroleum Liquid Storage in External Roating Roof Tanks 

18) Perchloroethylene Dry Cleaning Systems 

19) Leaks from Gasoline Tank Trucks and Vapor Collection Systems 

20) Large Petroleum Dry Cleaners 

Hill AFB Chem Mill Line Engineering Review 4.2.4-87 

September 13. 1995 

Page 8 
21)	 _.mthetic Orgaruc Chemical. Polymer. ..uld Resin Manuiacruring 

Equipment 

22) Leaks from Natural Gas/Gasoline Processing Plants 

23) Solvent Metal Cleaning 

24) Synthesized Pharmaceutical Products 

25) Pneumatic Rubber Tires 

26) Stationary Sources 

27) Air Oxidation Processes in Synthetic Organic Chemical Manuiacruring 

Industry 

28) High-Density Polyethylene. Polypropylene. and Polystyrene Resins 

29) Fugitive Emission Sources of Organic Compounds 

30) Synthetic Organic Chemical Manufacruring Industry - Reactor and 

Distillation Operations Processes 

31) Measurement of Volatile Organic Compounds 

For ozone attainment areas the requirements of UACR 3.1.1 (BACf) apply. 

However. BACT for these sources should be evaluated in light of the RACf 

requirements that have been established by UACR 14. BACT in an attairunent 

area may be determined to be less stringent than the RACf requirements 

established in rule 14 or a published Control Techniques Guidance document 

(which apply to a Nonanairunent area) however. a detailed BACT analysis should 

be conducted by the source to justify a less stringent control measure in an 

anairunent area. This source is located in Davis County. Therefore. this rule 

applies to this source. 

27.	 40 CFR. Pan 60 - New Source Performance Standards (NSPS) - There is no NSPS for 

this industrial process. There is a NSPS for this industrial process. 

28.	 40 CFR. Pan 61 - National Emission Standards for Hazardous Air Pollutants (NESHAP)­

There is no NESHAP for this industrial process. There is a NESHAP for this industrial 

process. 

29.	 40 CFR. Part 50 - National Ambient Air Quality Standards (NAAQS) - This source is 

located in Davis Countv, which is a Nonanairunent area for ozone. 

The Division of Air Quality guidelines do not call for this source to be modeled for any 

pollutant. The Division has found through experience that a source or emission point of 

this small size is very unlikely to cause a new violation of the NAAQS. This is because 

of the small quantity of emissions involved and the conservative predictions made by 

modeling. However. it will make a small contribution to the existing violation for ozone 

of the NAAQS. 

For VOC emissions. there is no model that can predict an ozone impact directly from 

VOC emissions. However. since VOCs are precursors to ozone formation. this new 

source will contribute to the existing exceedances of the ozone standard in Davis County. 

The amount of that contribution has not been decided. The ozone Nonattairunent area of 

Davis and Salt Lake Counties must show reasonable further progress toward attairunent 

of the standard. This source. along with all other VOC sources having emissions above 

ten tons per year. may have to apply more controls to lower the VOC emissions. This 

would be a SIP change action. 

30.	 40 CFR 60.14. Definition of Modification - Any physical or operational change to an 

existing facility that results in an increase in the emission rate to the annosphere of any 

Hill AFB Chern Mill line Engineering Review 4.2.4-88

September 13, 1995 

Page 9 
pollutant to Wl~_.l an NSPS standard applies. The follo ....1g are not by themselves 

considered modifications: 

A.	 Maintenance. repair. and replacement 

B.	 An increase in production rate of an existing facility. if that increase can be 

accomplished without a capital expenditure on that facility 

C.	 An increase in the hours of operation 

D.	 Use of an alternate fuel or raw material if. before the date any standard under this 

part becomes applicable to that source type, as provided by 60.1. the existing 

facility was designed to accommodate that alternative use 

E.	 The addition or use of any system or device whose primary function is the 

reduction of air pollutants 

F.	 Relocation or change in ownership 

Also see R307-1-1 (Modification). which is the State's defmition. This Notice of Intent 

is a modification. 

31.	 40 CFR 60.15. Definition of Reconstruction - the replacement of components of an 

existing facility to such an extent that: 

A.	 The fixed capital cost of the new components exceeds 50% of the fixed capital 

cost that would be required to construct a comparable entirely new facility and 

B.	 It is technologically and economically feasible to meet the applicable standards 

set forth in this part 

TIlis Notice of Intent is a reconstruction. 

32.	 R307-I-I. Definition of Major Modification - It means any physical change in or changes 

in the method of operation of a major source that would result in a significant net 

emission increase of any pollutant. A net emissions increase that is significant for VOC 

shall be considered significant for ozone. A physical change or change in the method of 

operation shall not include: ' 

A.	 Routine maintenance, repair. or replacement 

B.	 Use of an alternative fuel or raw material by reason of an order under Sections 

2a and 2b of the ESECA of 1974 or by reason of a natural gas cunailment plan 

pursuant to the Federal Power Act 

C.	 Use of an alternative fuel by reason of an order under Section 125 of the CAA 

D.	 Use of an alternative fuel at a steam generating unit to the extent that the fuel is 

generated from municipal solid waste 

E.	 Use of an alternative fuel or raw material by a source: 

4.2.4-89 

Hill AFB Chern Mill Line Engineering Review 

September 13, 1995 

Page 10 
1) .. 1uch the source was capable of accommoQ..ung before Janual7 6. 1975. 

- unless such change would be prohibited under any enforceable pennit 

condition 

2)	 which the source is otherwise approved to use -


F.	 An increase in the hours of operation or the production rate unless such change 

would be prohibited under any enforceable pennit condition 

G. Any change in ownership at a source 

TIlis Notice of Intent is not a major modification. 

Hill AFB Chern Mill Line Engineering Review 

September 13. 1995 4.2.4-90 Page 11 
V.	 RECOMMENDED AL KOVAL ORDER CONDITIONS 

General Conditions: 

1.	 This Approval Order (AO) applies to the following company: 

Facilitv Location 

Department of the Air Force
 

Headquaners Ogden Logistics Center (AFMC)
 

Hill Air Force Base. Utah
 

PHONE NUMBER (801) 777-0359
 

FAX NUMBER (801) 777-6742
 

The equipment listed below in this AD shall be operated at the following location: 

PLANT LOCATION: 

East of Exit 336 on Interstate 15 

Universal Transverse Mercator (UTM) Coordinate System: 

4,55.5 kilometers Northing; 418.0 kilometers Easting; Zone 12 

")	 Defmitions of tenns. abbreviations. and references used in this AO confonn to those used 

in the Utah Air Conservation Rules (UACR), Utah Administrative Codes (UAC), and 

Series 40 of the Code of Federal Regulations (40 CFR). These definitions take 

precedence unless specifically defined otherwise herein. 

orce Base (AFE) shall install and operate the Chemical Processing Line in 

Bui1din 53 cording to the tenns and conditions of this AO as requested in the Notice 

of Intent ated March 3. 1995 and additional information submitted to the Executive 

Secretary dated May 3, 1995, and May 6, 1995. 

3. 

4.	 A copy of this AO shall be posted on site. The AD shall be available to the employees 

who operate the air emission producing equipment. These employees shall receive 

instruction as to their responsibilities in operating the equipment according to all of the 

relevant conditions listed below. 

5.	 The approved installations shall consist of the following equipment or equivalent: 

A.	 Five 2000 gallon Chemical Milling Process Tanks 

1) Maskant Dip Tank 

2) Hot Water Dip Tank. 

3) Isoprep Tank. 

4) Water Spray Rinse Tank 

5) Sodium Hydroxide Tank 

* Equivalency shall be detennined by the Executive Secretary. 

Limitations and Tests Procedures 

Hill AFB Chern Mill Line Engineering Review 4.2.4-91 

September 13, 1995 

Page 12 
6.	 Visible emissio.. from any stationary point or fugitive em1...,lon source associated with 

the source or with the control facilities shall not exceed 10% opacity. Opacity 

observations of emissions from stationary sources shall be conducted in accordance with 

40 CPR 60. Appendix A. Method 9. 

7.	 The following production limits shall not be exceeded without prior approval in 

accordance with R307-1-3.L UAC: 

A.	 1500 gallons of Water Based Maskant per rolling 12-month period 

B.	 660 gallons of Sodium Hydroxide per rolling 12-month period 

C.	 220 gallons of Isoprep per rolling 12-month period 

Compliance with the annual limitations shall be detennined on a rolling 12-month total. 

The owner/operator shall calculate a new 12-month total based on the first day of each 

month using data from the previous 12 months. Records of conswnption shall be kept 

for all periods when the plant is in operation. Records of consumption. including rolling 

12-month totals shall be made available to the executive secretary or his representative 

upon request and shall include a period of two years ending with the date of the request. 

Conswnption shall be detennined by purchase records and operations log. The records 

shall be kept on a daily basis. 

Volatile Organic Compound (VOO and Hazardous Air Pollutants (HAPs) Limitations 

8.	 The facility shall abide by all applicable requirements of UAC R307-14 for volatile 

organic compound (VOC) sources located in an ozone Nonattainment area. At a 

minimwn. RACf control measures are required and BACT will be no less stringent than 

RACT. These requirements include but are not limited to: 

"14-5.A.(5) Written procedures for the operation and maintenance of the 

degreasing or solvent cleaning equipment shall be permanently posted in an 

accessible and conspicuous location near the equipment." 

The full text of UAC R307-14 is included as Appendix A. However. to be in compliance. 

this facility must operate in accordance with the most current version of R307-14 or the 

applicable section(s). if renwnbered. 

9.	 The plant-wide emissions of VOCs from the Chemical Milling Process Line tanks. etc. 

and associated operations shall not exceed: 

0.38 tons per rolling 12-month period for VOCs 

This value shall not be exceeded without prior approval in accordance with R307-1-3.1. 

UAC. Compliance with the limitation shall be detennined on a rolling 12-month total. 

Based on the first day of each month a new 12-month total shall be calculated using data 

from the previ~us 12 months. ::; )( 

(k~Ic.~{ '\1,/k1j 6 1c-l 

The ~Iant wide emissions of VOCs and HAPs emitted to the atmosphere shall be 

/'1	 detennined by maintaining a record of volatile organic compound potential and hazardous 

air pollutant potential contained in materials used each month. The record shall include 

the following data for each item used: 

Hill AFB Chern Mill line Engineering Review 4.2.4-92 

September 13, 1995
 

Page 13
 
A.	 Name CJ....le VOC and HAPs emining material. SUCt, ...s: paint. adhesive. solvent. 

thinner. reducers. chemical compounds. isocyanares. etc. 

B.	 The weight and use location of the volatile organic compound potential and 

hazardous air pollutant potential of the material(s) listed in A in pounds per 

gallon. 

C.	 Percent by weight of all volatile organic compound potential and hazardous air 

pollutant potential for each individual material listed in A. The percent by weight 

of the volatile and hazardous air pollutant potentials can be obtained from the 

manufacturers' MSDSs. The owner/operator can obtain MSDS data from the 

manufacturers of the materials and retain the information on-site. 

D.	 Amount and location of materials containing VOCs and HAPs used on a monthly 

basis and summed for every location and for the entire plant each month. 

E.	 To calculate the above potentials contained in the material listed in D use the 

following procedure: 

VOC :;:; (% Volatile hv Weight) x (Density Ih) x (Gal Consumed) x <l.JQ!l) 

(100) (gal)	 (2,000 lb) 

F.	 The amount of volatile organic content potential (potential air emissions) and 

hazardous air pollutant potential (potential air emissions) in pounds contained in 

materials deposited as solid or hazardous waste for the month shall be quantified 

and subtracted from the quantities calculated above. TIlis is done to allow 

quantification by the source of the total VOCs and HAPs emissions. (The 

assumption is that all the two above potentials of the materials applied to a 

,-	 product evaporate and are therefore considered emissions). 

G.	 Records of consumption of VOCs and HAPs shall be kept for all periods when 

the plant is in operation. Records of consumption shall be made available to the 

executive secretary upon request. and shall include a period of two years ending 

with the date of the request. 

10.	 All HAPs are subject to the annual Operating Permit Program if one of the following 

conditions is met: 

A.	 The emissions of anyone of the 189 HAPs listed in the 1990 Clean Air Act is 

over 10 tons/yr 

B.	 The emissions of any combination of these HAPs are over 25 tons/yr 

11.	 TIlis source is a major Title V source needing an Operating Permit. It is required to pay 

an annual emission fee upon stan-up [or if an existing facility. upon issuance of this AO. 

The fee will be based on calculated annual emissions listed at the end of this AO. TItis 

fee is valid until inventory data for one year are available for the source. The owner or 

operator of this source will be billed upon stan-up for all emissions that are considered 

"chargeable" as of that date. 

Records & Miscellaneous 

Hill AFB Chern Mill Line Engineering Review 4.2.4-93 September 13. 1995
 

Page 14
 
12.	 All installation~ ..nd facilities authorized by this AO shall ve adequately and properly 

maintained. All pollution control vendor recommended equipment shall be installed. 

maintained. and operated. Instructions from the vendor or established maintenance 

practices that maximize pollution control shall be used. All necessary equipment control .. 

and operating devices. such as pressure gauges. amp meters. volt meters. flow rate 

indicators. temperature gauges. etc.• shall be installed and operated properly and easily 

accessible to compliance inspectors. A copy of all manufacrurers' operating ins01lctions 

for pollution control equipment and pollution emitting equipment shall be kept on site. 

These instructions shall be available to all employees who operate the equipment and shall 

be made. available to compliance inspectors upon their request. 

13.	 The owner/operator shall comply with R307-1-3.5. UAC. This rule addresses emission 

inventory reporting requirements. 

14.	 The owner/operator shall comply with R307-1-4.7. UAC. This rule addresses unavoidable 

breakdown reponing requirements. The owner/operator shall calculate/estimate the excess 

emissions whenever a breakdown occurs. All excess emissions shall immediately be 

reponed to the executive secretary. The total of excess emissions shall be reponed to the 

executive secretary as directed for each calendar year. 

15.	 All records referenced in this AO which are required to be kept by the owner/operator. 

shall be made available to the Executive Secretary or his representative upon request and 

shall include a period of two years ending with the date of the request All records shall 

be kept for a period of two years. Examples of records to be kept at this source shall 

include the following as applicable: 

A.	 Production rate (Condition number 7) 

B.	 VOC and HAP consumption records (Condition number 10) 

C.	 Maintenance records (Condition number 12) 

D.	 Upset. breakdown episodes (Condition number 14) 

Any future modifications to the equipment approved by this order must also be approved in accordance 

with R307-1-3.1.1. UAC. 

This AO in no way releases the owner or operator from any liability for compliance with all other 

applicable federal. state. and local regulations including the Utah Air Conservation Rules. 

Annual emissions for this Chemical Milling Process Line at Building 238 are currently calculated at the 

following values: 

Pollutant	 Tons/yr 

A.	 VOC 0.38 

B.	 NaOH 0.29 

C.	 Isoprep 0.44 

These calculations are for the purposes of determining the applicability of Prevention of Significant 

Deterioration and nonanainment area major source requirements of the UACR. Except for VOC's they 

are not to be used for purposes of determining compliance. 

Hill AFB Chern Mill Line Engineering Review 

September 13. 1995 4.2.4-94 

Page 15 
In accordance with the requiremcalts of Title V of Lile 1990 Clean Air Act. me following pollutants may 

be subject to an operating permit fee. Emissions of the following pollutants from all sources. including 

pre-November 19. 1969 sources. may be subject to the operating permit fee. Both the fees rate and the 

class of pollutants are subject to change by State. the federal agencies. or both. 

Pollutant Tons/yr 

A. VOC 0.38 

F:\AQ\ENGINEER'NMeli\WP'Hil-Chern.Rev 

Hill AFB Chern Mill Line Engineering Review 4.2.4-95 September 13. 1995
 

Page 16
 
UTAH DIVISION OF AIR QUALITY
 

FAX COVER SHEET 

150 NORTH 1950 WEST CANNON L770 FAX # (801) 536-4099 

SALT LAKE CITY, UTAH 84114-4820 CONFIRMATION # (801) 536-4000 

FROM: Nando Meli Jr. PHONE: (801) 536 - 4052 

To:;1,'!r'e Grp ,(i/lQ PHONE: )7) - 0 S'r9 

AGENCY!FIRM VI' I( .9F is 

FAX NUMBER 7))- 62 (/2- CONFIRMATION #: _ 

NUMBER OF PAGES TO FOLLOW: ----L...I...l'o<.~__ 

SUBJECT: ENGINEERlNG REVIEW 

REMARKS: Could you reply as soon as possible with any comments that you may have on 

this Engineering Review. 

Thank you. 

LOGGED: ---'-49t-=-~--=-J__ SENT: Jtu- RECEIVED: /:L/5 CONFIRMED:---t/::£. 

4.2.4-96 
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4.2.4-97
 
_.. 

FAX MESSAGE 

From:	 Michael J. Graziano 

Air Quality Manager 

OO-ALC/EME 

7274 Wardleigh Road 

Hill AFB, UT 84056-5137 

Phone: (801) 777·0359 or DSN: 458·0359 

FAX: (801) 777·4306 or DSN 458·4306 

To: koo /l1&L I 

)JAQ 

Number of pages this Transmission: _ 

4.2.4-98 
4.2.4-99
 
l..rrAH DIVISION OF AIR QUAUD' 

NEWIM.ODlflED SOURCE PIAN REVIEW 

T.ynn S. Hill 

one!. Bnvtronmcntll CDmplima: 

Department M the Air Force 

!ieadqaartas Ogden Log1&dCs o:mer (AFMe) 

Hill Air Force Base. Ut4dI 

RE: R.elnca:E:ion of Chemical MiDin~ rac:es.~ Une 

ll:LvlS COunty. CDS Al; NA; HAPs. nn.E V MAJOR 

REVIEW ENGINBBR: NawJo Meli 

DATE: September 13. 1995 

NOTICE OF INIENT DA1ED: 

PLANT CONTACf: ;~ike Gr.m.ano 

PHONE NUMB1SR: (801) Tr,-(p,59 

FAX NUMBER (801) m·t1142 

PLANr LOCATION: East of ExiT :n~ on J~te 1~ Freeway 

UI'M COORDINA'I'ES: 4,S~ 1.5 k.ro NOJ1hWg, 418.0 km .Easung. Zo= 12 

FEES: 

Dasic Approval Order l"ee ........••.........•...... $1000.00 

Review f.rl&ineer • • . . . . . . . . . . . . . • . • . . . . . • . • . . . • • • .• SCOO.OO
 

Modeler . . . . • . . . . . . . . . . . . . . . . . • • . . . . . . . • . . . • . • .. $000.00
 

Notil::e T!) Paper .•• . . . . . . . . . . . . . . . . . . . . . . . • . . . • •. •• $80.00
 

Tmvel ....•...•.............................•.• W.OO
 

TOTAL. . . • . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . . . .. $1OIJOJ)t}
 

APPROVALS: 

4.2.4-100
 
.: .:.. :~ ~. 'to. ~~ FAX MESSAGE ... -.-- '" .,.­

From: 

Phone: 

Michael J. Graziano 

Air Quality Manager 

OO~ALC/EME

7274 Wardleigh Road 

Hill AFB, UT 84056-5137 

(801) m-0359 or DSN: 458·0359 

FAX: (801) 777·4306 or OSN 458-4306 

To: #J.W.c10 /J16L I 

))IlQ 

Phone: 5~-40S2

)fa.--& .' 

~~ dL /-2­

r /'fk.RIJ m~_N"Z; 

04 tv( ~~--?~, . 

?~~~v'OC-~

750 -Ph (/L)~ (/..••./ ~.$

(~S"oo~) .?~ ~1'

r r ~.

Number of pages this Transmission: 2 . 

4.2.4-101
 
Sodium Hydroxide (MSDS Attachment 4) 

Twelve 55 gallon drums per year = 660 gallons 

Specific gravity = 2.12 

therefore 8.4 Ib water/gallon X 2.12 X 660 gaJJons = 11,753.3 Ib NaOH 

Engineering estimate for NaOH losses from process tanks is 5% 

11,753.3 Ib X .05 ;= S88 lba NaOH 

lsoprep (MSDS Attachment 5) 

Four 55 gallon drums per year = 220 gallons 

SpecifIC gravity =,.43 

therefore 8.4 Ib water/gal X 1.43 X 220 gallons .. 2,642.6 Ib Isoprep 

Engineering estimate for Sulfuric Acid losses from process tanks is 33% 

2,642.6 Ib X .33 • 872 Ib 'soprep 

Emissions Summary Grandfathered Process 

vee Maskant 2.252.8Ibs 

vee Thinners 21,450.0 

Total voe 23,702.8 11.9 tons 

Sodium Hydroxide 588.0 0.30 to" 

laoprep 872.0 0.44 ton 

D. Emissions Estimate Proprosed Precess 

Water based Maskant (MSOS Attachment 6) 

Estimated Use 1.500 gallons 

Specific Gravity E: 1.2 

therefore 8.4 Ib water/gallon X 1.2 X , .500 gallons = 15.120 Ib rnaskant 

from MSDS sOlvent content is 5"10 so 

15.120 Ib maslcant X 5% vee =756 Ib voe 

Thinning agent for this maskant is deionized water 

Emissions from Sodium Hydroxide and Isoprep remain the same. 

E. Annual Emissions Summary 

voe NaeH lsoprep 

Old Maskant 23.702.81b 588.0Ib 872.01b 

Test Maskant 7561b 588.0Ib 872.01b 

Estimated Annual voe Emiuion. from new Pr0C888 756 lb. 

4.2.4-102 
HEADQUARTERS 

DEPARTMENT 

OGDEN AIR 

OF THE 

LOGISTICS 

AIR FORCE 

CENTER (AFMC) RECEIVED " . 

HILL AIR FORCE BASE. UTAH ". MAY 04 1995 

Air Quality 

Mr Lynn Menlove 3 May 1995 

Manager, New Source Review 

Division of Air Quality 

1950 West North Temple 

. PO Box 144820
 

Salt Lake City, UT 84114-4820
 

RE: Relocation of the Chemical Milling Process Line from Building 265 into Building 238 

Dear Mr Menlove 

This letter supersedes the one dated 3 March 1995 in which we requested an Experimental 

Approval Order to test a new maskant in the chemical milling process, and to relocate the process 

to Building 238. The current chemical milling operation is a grandfathered source and must be 

relocated from its present location in Building 265 into Building 238. However, there is no need for 

on-site testing of the altemative maskant material. Process engineers have investigated the use 

of the new material at other locations and based upon this information have determined it will 

meet their needs. This letter is to serv~ ~~Q!~? of IntenUor an Approva~r to use the new 

maSKant material and relocate the process to Building 238. 

A detailed emissions estimate is provided in attachment 1. This estimate shows that the new 

maskant will reduce VOC emissions, from this process, by more than 11.5 tons. The estimated 

annual VOC emissions from the new process would be approximately 223 Ibs per year. Based 

upon this analysis the new process would qualify as an insignificant source under Title V. The 

new maskant exceeds standards established in the proposed 40 CFR 63.747, National Emission 

Standards for Hazardous Air Pollutants, Aerospace Manufacturing and Rework, which specifies 

VOC content for compliant maskants must be less than 1.3 Ibslgal. 

Your prompt response to this request would be greatly appreciated, so we may start up this new 

process as soon as possible. The original 3 March 1995 letter was assigned to Mr Nando Meli. If 

you have any questions regarding this matter please contact Mike Graziano at 7n-0359. 

sincere,) ttJ ~.HILL . Chief, Environmental Compliance 

6 Attachments 

1. Process Description & Emissions Estimate 

2. Project Layout 

3. High VOC Maskant Tech Data Bulletin 

4. MSDS Sodium Hydroxide 

5. MSDS Isoprep 

6. MSDS Low VOC Maskant 

cc: LAOPE (John Vidic) .,,--. LARTW (Rich Trejos) 

4.2.4-103
 
CHEMICAL MILLING PROCESS DESCRIPTION
 

AND EMISSIONS ESTIMATE
 

A. Install five new process tanks in building 238 (Proposed layout attachment 2) 

Tank #1 Maskant Dip, exhausted to,outside
 

Tank #2 Hot Water Dip. exhausted to outside
 

Tank #3 Isoprep, exhausted to outside
 

Tank #4 Water Spray Rinse
 

Tank #5 Sodium Hydroxide, exhausted to outside
 

All dip tanks are 2000 gallons.
 

Slotted ventilation systems across the top of tanks 1, 2, and 3 will be manifolded together and
 

exhausted through a 38" duct 60' above ground level.
 

The slotted ventilation system across the top of tank 5 will be exhausted through a 24" duct 60'
 

above ground level.
 

B. The general process for each part is as follows; 

1. Dip in Sodium Hydroxide. tank #5, for 30 seconds; flash cleaning. 

2. Dip in Hot Rinse, tank #2. 

3. Dip in Isoprep, tank #3; desmutting. 

4. Spray Rinse in tank #4 

5. Hang Dry 

6. Dip in Maskant, tank #1. 

7. Hang Dry 24 hours 

8. Use template and cut away maskant from area to be milled. 

9. Dip in Sodium Hydroxide tank #5, exposed metal areas are milled at 0.001 inch per 

minute. 

10. Dip in Hot Rinse tank #2. 

11. Dip in Isoprep tank #3, for cleaning. 

12. Spray Rinse in tank #4. 

13. Repeat steps 8-12 as needed to mill various areas to desired depths. 

C. Emissions Estimate Grandfathered Process 

Maskant (Tech Data Sheet Attachment 3) 

Eight 55 gallon drums per year =440 gallons 

8.0 Ibs per gallon =3,520 Ibs
 

from MSDS solids are 36%, therfore solvents are 64%
 

3,520 Ibs of maskant/yr X 64% VOC = 2,252.8 Ib vee 

Thinner 

Maskant must be thinned with 1 drum of solvent each week 

52 drumslyr X 55 gaVdrum X 7.5 Ibs VOC/gal = 21,450 Ibs vee 

4.2.4-104 

It," .~, ,." JJ / - /

( '- , , 
Sodium Hydroxide (MSDS Attachment 4) 

Twelve 55 gallon drums per year =660 gallons 

Specific gravity = 2.12 

therefore 8.4lb water/gallon X 2.12 X 660 gallons =11 ,753.3Ib NaOH 

Engineering estimate for NaOH losses from process tanks is 5% 

11,753.3 Ib X .05 =588 Ibs NaOH 

Isoprep (MSDS Attachment 5) 

Four 55 gallon drums per year = 220 gallons 

Specific gravity =1.43 

therefore 8.4 Ib water/gal X 1.43 X 220 gallons =2,642.6 Ib Isoprep 

Engineering estimate for Sulfuric Acid losses from process tanks is 33% 

2,642.6 Ib X .33 =872 Ib Isoprep 

Emissions Summary Grandfathered Process 

voe Maskant 2,252.81bs
 

voe Thinners 21,450.0
 

Total vee 23,702.8 11.9 tons 

Sodium Hydroxide 588.0 0.30 ton 

Isoprep 872.0 0.44 ton 

D. Emissions Estimate Proprosed Process 

Water based Maskant (MSDS Attachment 6) 

Eight 55 gallon drums per year = 440 gallons 

Specific Gravity = 1.2 

therefore 8.4 Ib water/gallon X 1.2 X 440 gallons =4435.2 Ib maskant 

from MSDS solvent content is 5% so 

4435.2 lb maskant X 5% voe =221.8 Ib vee 

Thinning agent for this maskant is deionized water 

Emissions from Sodium Hydroxide and Isoprep remain the same. 

E. Annual Emissions Summary 

voe NaOH Isoprep 

-I,'" ,.., "'\ G 

Old Maskant C. If L{ "/' $, 23,702.81b 588.01b v"" l 872.01b 

Test Maskant 221.8Ib 588.01b 872.01b 0. 1 / 

4.2.4-105 

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DIP ;"ND FLOW COAT CHE:M·r/ILL t,~ASKANT

DESCRIPTION: 

TURCOFOR,'/:: '.JA~~ :22 ;s c. ten iic\Jlc, 5[ngle C8~:J:;~er,~, cir c~(jng, ~ee!::.ble p~QreC::lve

cOctiiig fOrrihJjaL:=~ ~;: ;::: ..':2 :,ro!ec~;:·.-: =·;=.:r~s: :.-:~ c::,'",·::.s;\/2 =-'::::.1 Cot :~ct Cc:Jscic c::C c::C:: 

solutions used in the C:-Oe:ll·r",1ill D:ccessin~ c; 2.1Umln:.;~. :i"c~"cS;J~, s:eei c;.::; ;,tcnIUIT. 2110Y3. 

TURCOFORM MASK 522 C2n :e c:::~iied by immerse;, or !iow C~2li~~ ~e~hCC5 2nd cdes :0 2 

c~e~~c~! iss:Si:=.n: ~~2s~=-r.2~:c ~ijm ','.. ilnin ..,2 r-LC~~3. ~'_'~'::'~C,~:\~ \·~I;'.S:-\. :22 :~:-l ::e force: ;:(c-: 

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LlCUID PROPE~TIES:

Appearance T2n visc~us iic.:ic
 

Solids by wt. 3~.S =1 ~/;
 

Gallon weight 8.0# min.
 

Viscosity, Poise is = 
 

Flash Point (SET;", ~oef
 

S!ora~e ll~e @ 75 =~
 

FILM PROPERTIES: 

Tensiie s:ierig:~ seo ~Si :"1;-,,
 

Elon~;:;,ticn 2, ii..:ptL!i: L 75 :/0 .7,i".
 

Peel Aahesicn: (pc~ '-:C3;;,'1, ',',fIG ;.~)
 

Solvent wioec panels 8efore etch Altei etch 

202a.·T3 C!c=.(J AlumInum 0.5 =0.3 "1.3 m2X. 

DrRECT10NS FOR USE: 

1.	 Precleaning: For optimum uniformity in adhesion u:d perfcrri1=n::e the ~2ns ;0 be mas~ed

must be free of oil, grease, dirt or corrosion. Your TURCO Territory Manas;er v::.n recommend 

suitable TURCO cleaners basea on specWc2.tions anc prcduc:lcii neeQs. 

2.	 MixIng: To ::.ssure re~roducjble resuits In appllCc:Uon 2nd pertom:ance of the TURCO FORM 

MASK 522. adeauars mixing of the solution is very important prior to 2r.d curing use. Caution 

must be exercIsed \0 prevent 2ir froril beIng ara','m into the ma.sr. by the mi::.ing action. Since 

some solvent is last during use due to evaporation. periodic aodillens of thinner are required. 

The amount at thinner requir;d is baseo on viscosity measurements. A #5 Zahn cuo 

o,,:iscometc:r ri12y be used to measure Cind adjust the masl<ar.t to the ceslred operaring viscosity. 

4.2.4-107 Itrcr+ "3 
00 

· .-._-~-----~ .., (-

(	 ( 

MATERIAL SAFETY OATl\ S II'; ';'1' 

telll Name.. . . . . . . . . . . . . . . 

art NUlIlber IT) dele Nallle. . . 

Cltion<:ll Stocl'. NUllIbet'. 

I\GE Code	 . 

Clrt Number J llc1icatol'.
 

~;IJ.s Numbc r. . . . . . . . . . . . .
 

facturer	 NClllle. . . . . 

Street. 

City ... 

S t~ a I: c .. 

Country. . . 

Zip Code. .. 

lIIergency Phone . 

Ilforlllation Phone " .. 

cite MSD,s	 Pn~pared/H(~vi[;cd. .. 

;Itc of Technical He\' LeVI.
 

, : t i v P. Tlid i c;\ tor. . . . ' , . . , ., ..
 

I;/ldor /I Ij	 ('l\CE . 

pecificatio/l NUlllbcr, . 

lJ" r; i [ i cat i 0 II T YpelG) ,I delCIa ~; [; . . . . 

'- .rd Storage Campa I i lJil.ity Code. 

RC License NUllIber. .. . .. 

(~t PJ,opcllallt Weight (I\1I11110) ...•....... 

ppcar<:tnce/Odor. , .... 

oiling Point . 

elting Point , 

apor Pressure . 

apor Density. . . . . . . . . . . . . . . . . .. . . 

,pecific Gravity , . 

lecornposition Temperature .. , , . , . 

,vaporation Rate . 

:olubility in Water . 

'tlemical PI' . . . . . . . . . 

'l.Clsh Pail . 

,... o 

SODIUM :IYIJIWX I DI':,l\CS 

SODr UM ,I '( IWOX 1IJI-: 

GU1 0 0 0 0 1'1 Wj '7 0 

'10U29 

l\ 

fJ 9 fJ F) 

.­

I 

"T 

N '::t 

< 

J.T.I3l\I(~';I; CIIEMICAIJ CO 

222 I{EU ~. '11001., Ll\NE 

PIIILLII";/ II{G 

N,J 

US 

OUOGS-/.) I) 

2 0 1 - 0 5 9 . ~) I S 1 

20 1 - fJ ',{ . /. 1 ,; 1 

Pl{E-II('.'· 

271,'EIHliJ 

y 

Il(':< N,J 

NOT 

II/Ii 

C2 

N/I{ 

N/ I~

l\ I' I I, I '/\ n1.1;: 

vIlli 'L'E, 1JI':LIQIJI':SCENT 

STICK;;. 

/. 5 3 4 F, I 3 ~) 0 C 

UNKNOWI' 

NIH 

N/I( 

2.120 

Pl ECES, LUMPS OR 

UNKNOHI 

N/({ 

l\Pl'HECIl\I' 

NIl( 

NOlIE 

,E 
lll~;'

....1' 

t'­

,;-}jufshill~ Media" "".",.,"
 

<,cial Fire Figllt:i 119 Procechll es,
 

lusual Fire/Explosion Ilaz,uc1::, .. , , , , , , 

:clbility, ., ", ., , .. , . ,. . . ' ., ,., 

d(~rialfJ to Avoid .. , , ... , . .. ." 

.1 Z <:l rcloll s De COIlIPOS i t i Oil Produc l: s .. , . , , , 

Izardous Polymerization. 

I l:OIlI~; of OverCXp0[Jlll~e.

IIcrSjcllcy/Pirst Aid 1'1~ocedures.. , ... , , , 

: ern; if t'll1.tcrial I~eleasecl/Spilled,.".

wte Disposal Method"."", , , , , . , , , , , 

I' -11i119 & Stora~e PrecClut i.Oll~;, , , , , , , , , 

:lIer Precautions, .. , ................ 

~f]pir<:ltory Protectiol 

~Iltilatioll. , , ... , , ,. .", .. , , . , , , 

cotecli ve Gloves, .. , ., .... , , , . , , 

fe Protection ... ,... . .. , . , , , .... 

:her Protective Equi] :nent ... , . , .. , , , . 

lpplemental Ilc<:llth/Sd [ety Data, .. , , , , 

WATEH 

FLOOD Wi '1'1 \\/ATEI~, DO NOT 81')'1\,'311 em SPLASII 

MATrm I 1\ I, 

NONCOIIIlII,';' '1111.,1,: BUT SOLID FOI~M IN ('()NTACT 

~oJITII r\lol~j' IJlm MI\Y GENEI~ATE SUFFICII,:NT 

IIEAT TO ,(:1 I': ~;lJP DA']'A 

YES 

MO 1 STlIl~ !.:,I .I':'I'Al,S, EXPLOS1 VI':.'j, OI<GAN 1c'
 

PEI<OX I DI:S
 

MAY GI';NI :1(/ 'I'!:: IIYDROGEN GAS ON CONTACT
 

WITII r,m' 'AI,';
 

NO 

IUGIILY ,'UI I~()S I VE ACTION UPON BODY 

TISSIJI-: , 

SPEED J II I 1<[''lOVING TillS CAUSTIC Ml\TEIUAL 

IN cor,IT/\C" WITH SKIN IS OF VEI<Y 

H1PO«'I'AJ ICI: '['0 AVOl D BUI<NS. ImMOVE ALL 

CONTAt,1 II lA' '1m CLOTIIING AT ONCE AND GIVE 

SIIOWEI~ 'Ii'll Ifm DELUGE TUPE or WATEI<, 

ll<I<ICATI'; I Y/;;S \'1'1'1'11 WAI~M IvATrm FOI~ AT 

LEAST J ') r I NlJTES ' 

COLLECT 1\/ /) I~EMOVE WITH A 13IWOM IN A 

LAI~GE [IIJCj 1-: " urLUTE WITII WATEH I\ND 

NEUTIUII,IZI ':1'1'11 6M IICL. Dr~AIN INTO A 

SEWFI\ WITJ ;UFFICIENT WATEI~.

PUT II/TO .. IJl\r~GE VESSEL CONTAINING 

Wl\TEH. ImIJTHl\f,r7.E WITII 6M IICJJ. DISCIIl\RGE 

INTO 'I'lli':';I~WI~:I< WITH SUFFICIENT WATEI~,

TEeT /\(;,11:1.';'[' I'IIYSICAL DAMAGE OF 

CONTA I N m:;. STOlZE IN A DI~Y PLACE. 

PIWTI~:("l' AGAINST MOISTURE, STOJ<E 

SEPAHA'n:LY FIWt'l ACIDS,METALS,OXIDIZING 

MATEI~ II\! ,S l\V 

AVOID SU J CONTACT. 

NIOSII/r,]:;I!,. APPROVED RESP DEVlcE IN 

ACCOIW \'1 J' 'II EXPOSURE OF CONCEI"(N. 

LOCAL/M j,:c II\N I CAL. 

IWGBIW 

GOGGLES 

PLl\ST 1C 0 /I~:RALLS

IGNITE CO: 1I1USTIBLE MATEIUALS. CONTAINEI~

SIZE: 1 I,', BOTTLE 

I 

0-. -.do 

...... I :t ":t 

0i i­

<t 

. , , , , , , . , , ..... ,. 01 Igrcdicllt ( 
·,' 

'" ,.1.;;~	 

( ( N': ...:li' I j;I;,;Uicnt	 1'lal1le. . . sal) J UM II 'IJROX J uE (SARA III) 

.l.cJ NUlllber. . . . .. . . 13l0-73' :
 

.I OSI( I,jumber. . .. . . Wl319000()11 
 

loprielary . NO
 o 

.-. crcenl: . >9'1	 .-. ,':IIA PEL . 2 MG/M3	 '1"

I 

('(illl 'l'LV. . . . . . . . . . . . . . . . . . . ... C /. MG/I'" ; 9291	 N 

'1" 

l),l'lCE:	 If you require a complete, 1I11<1bbrev.i.ate( t'1,';US, 

cClll Bioenvironmental Engineering. 
flJ1\'fEIU1\L S1\F'I~'1'Y D1\'1'1\ .'~IIJo:I';"·

I~III

It 

Hame 

Number/Trade Name 

. 

. 

I SOPlml' 

JSOP[{EP 

III 

111· ::ULFURIC 1\CID SOLUTION th 

Lional Stock 

GE Code 

Number . 

. 

G81 UP I SO /11\: :l' 1 f) 1 

99112 

-I 

"1: :t: 

.~

rt Number IndicCltor. . . 1\ N f )~; NUlllbe)~ . 17.129 

Jlufactllrer Nallle ... 1\LLI ED-I< ;';1. ''l'I'~

street. 29111 Ml ,I: llW DR. 

City ... NEW IIUD.' l!'l 

state .. fIJI 

Country, .. US 

L:ip Code. . , '101G5 

ergency pholle ... 000-12'1-93 JO ronllLl l j 011 Phone....... . . .. .. J 13 1 J '/ - UI d 

I c MSDS Prepared/H.ev i~;ed .. NONE 

t Lve Indicator .. , . Y 

rJ('LlrallC(~/Od()l .. /\MBf<l{ II(WI N / 1\CEDIC ODOR 

i' 'llg ['Oillt .... :no Ime I: 

c .. fic Gravity. I . I) J 

Jubility ill Water .... /:(WELY 

reent. VolatJJe~; by Val lillie , . 't5 

ash Point , . N/H. 

tinguishing Media . USE ~l1\TEI{ SPR1\Y, DRY CHEMICAL, C02, 

ecial Fire Figlll1ng Procedul or.;. F If{E FIGIl'/'EI{S SHOULD WE1\R PROTECTI VI;: 

EQUIPME:NT 

usual Fire/Explosion Hazards. NON'~

ability , YES 

tcrials La 1\void , , STRONG 1\C DS 

zardous Decomposition Products . NIl{ 

zardous Polymerization . NO 

lymerization Condition:; l:o 1\void, WILL NOT (lCClJ[{ 

'~JO- LD50 Mixture., . N/R 

ute of Er : Skin....... . . YES 

ute o[ Ef I : Tnhalat.ion.. .. YES ( 
I 

;,.: ,,,,I (" 

I, , . . ,­

::~'l th Ilazurds - Acute & Chronic .... , .. 

Ircinogeni t y: NTP . 

lrciuogenity: IARC . 

lrcinoge/li ty: OSIIA . 

/mptollls of Overexposure . 

~dical Cond. Aggrevated by Exposure . 

IcrS-Icllcy /First Aid I'n1Cedurcs . 

cus if Material Released/Spilled ..... 

'utralizillg Agent . 

I~Lc Disposal Method . 

~;piratory Protection . 

Iitilation . 

otective Gloves . 

e Protection............... .. 

'rk Ilygenic Practices . 

( 

1NIIA[,ATHJ; CAUSE EYE, NOSE /\ND TIIROAT 

I RIUTATICl/ , PULMONAln EDEMA, AND 

BRONCIIIAJ, ':r'~PIIYSEMAi BURNS SKIN 1\.N]) 

1;:n:S, ANI> '!\IJSES DENTAl) EHOSIO~I.

COIWOSTVI< I~YES AND SKIN AND INTEHNAf, 

OH.GANS 

NO 

NO 

NO 

SKI NAND 1 " I;: nURNS AND INTERNAL a/mANS 

N/R 

(EYES] FI,I ;11 WITII WA'l'EH. FOR 15 MIN WIIJLE 

IIOLDING 1-:': .; LIDS APART TO INSUH.E OF CLE 

)) I 1< ESPI fol lWEA WITII INEKl' MATERIAL, 

COVER 1\.ND lEMOVE AND PLACE INTO 

CONTAINEI~ 'llWKEO fOR 01 SPaSM, 

LIME 

DISPOSE 01 IN ACCORDANCE TO ALL STATE 

AND FEDElU , LAWS 

USE NIOSII \PPROVlm RESPIIU\TOR WilEN TL.V 

LEVELS AHI I':XCEEDED 

;LOCAL OR :/ NERl\JJ 

IWBBER 

CIIEMICAL ( J(;GL,ES 

WASil WIT/I ;(lAP AND WATER AfTER l\J/NDEIJING 

ANY CIIEMI' \ I, 

(
 

C'l 

...... 

...... I 

C'i 

-i 

N
 

t.n 

"i: 

c) 

\­

<t 

c-:r r~ dieII t H........................... () 1 

(, .dient Name .. , POTASSIUM DICIIH.OMATE 

S Numbe r. . . . . . . . . . . . . . . . . . . . . . . . . . . .. '/ '7 '7 U- 50- 9 

oprietary NO 

qredielll: II...................... .., 02 

\F'edielll~ Name................... .,. POTASSIUM 'I,U0130RATE 

.<; NUlliber.. 110'75-53-' 

oprictary. . . . . . . . . . . . . . . . . . . . . .. ..,. NO 

0rediellt It........................... 03 

gredient Name , SOPIUM BI~ UJ.,FATE 

.s Numbe r , . . . . . . . . . . . . . .. '76 fl \ - 3 £3 - 1 

opriet<:lty NO 
.:.y \-­ MA-: ilAL SAFETY DATA~ SHEE. 

'\­

~I~~~:::,~;;~,,:~~~·-~~::~;~·:.~::-~~-.:~~~~·iL~·~~:;~~:~~:i~.: ~~:~~~·~~;;;~~.i~~~~~:G§·E~N~·ER~·.:-=A=;:t;~=-~rS:N=E~O.=H~M~A=:~=·i~6S;:.N=L=~C=~==--=-;;:-=····.~=--==--=";'=.:'=~'::::::::::2~-~~".:=:.~:::::::.~:::::::: ..._=.:~~::=:=:::==:-s::'1\ \ 

~~~~~~:-?~==..'":~=~~:=:::-:::;':"-=--::"'-:::?=:=':==:~~::~:7..~~;::-~~~:::-~::':-:":-=-::~~_ ...._ ., ('"M~::S:~~~~~~~==,§\

de Name: CAX-200, CAX-200.;-, C;..X- i COLA. 1 FormuLa: 

CAX-i77, CAX·177+, CAX-200 R WATE;:\SORNE I

MASKANTS i Froorietary ~:::::tur2

Manutacturer: I Manufacturer's Phone Number: 

'I 

j[f-N_'2_i_e_k_'_In_,c_:::_~_;=_c_r_at_e_a I1~6_1_9_'_2_7_9_.0_2_7_7 ----:11 

il Manufacturers Address: I Name of Pre;Jzrer: II 

: 495 i RUT7in Roae I M<:i~k, :01cor::oratec 1, 

San Diego. CA 92123 1

,I

, 

'1::-:~:"~;:c'::;:;t;~~~~;~BIG~~:,Ji~I~R§2VS,[\~:~R~QX~~2~ 0§2~("H:~:'·~':~;~'·.···'0·"11 

II 

EX;:Josure Limits in Air (give units) I Princioai Hazardous Corr.positi::::n 

Components (% by weight) AC~JH T:"'V 

< _.- ­

. ..., """" ... (CAS ,;'100-42-5) 00 ppm (ceiling) 200 pom (ceiiinc;l 

-so N/A N/A

-

Wa:er (CAS #7732-18-5) 

Toluene < 4 ~CO ::;:m (T\'./A) 200 p~;:-: Ci'l/Al 

II I (CAS #108-88-3) i 50 P;:lr.1 ISTE!...l 300 ppm (ST::LJ 

II 

I 

Scdium Dcc2cylbenzene ::; '1.0 

I 

N/A N/A 

I Sultonate 

i (CAS ,;'25155-30-0) I 

I 11, 

!/ 

?ro;;rie:uy Non-hazardous 

Solies 

N/A NIA 

: ~ ...... :~:.::~:~~:;.:'.~~.: ...:~:::::.~:=,:::~~:;.??:~:.t:?::.:.:;,7:~~~::::'!:·f?:i~~{ff~~;?f.:~-.:y.·.'~.:_:~ ..:...~.~.·C.·.:::.~-.:9;hb.·:A:~fA:~;I;~:~:~~::~i7;~~~:~:?~:~::~~::i·J~~~:g~~~::·~;~:~;::::.::~~H::::::\.~I,' ...... -."....... . ..::;:::. .. :~~..•' .., ,•........., ".. ", -"" ' .. 

;/:1 EoiiingPoint(OF}: II:.-­ 212 c F SpecificGraviry(H:O=1J: :-­

i.'·1.2 II' I 

i 

!:i,' Vapor Pressure (.... ... , m Hg.) © 20°C.· 7 mm (wc!e~) Evar

ene 

;oration Rar2 (butyl acetate = 1): Less ri:an (I

, 

I 

! 

Vapor Density (Air = 1): Not Known pH: 8.8 - 8.2 

Revised 8-2-94 Page l'ot 5 

4.2.4-113 
, -----------~\-:.. Solubiiiry in Water: Miscible with water Melting Peint cr Range. 0 F: Liquid at rcem --ii 

'emoercit:.:re 1/-­ r-----=-~---:~~~~____:_-~------.:...-------------------..1I! \~~
 , MC ea,,"ca & 0 dcr: Uouid.: mad od", I '"'"" 

il 

",===================1\ 

11~~b+~~~~¥il.i~~~~~i~~~12M];~~~~~:4~~:tll
 :1II Flash ?oint (Test Method): Not op::;lice:Jle I ' Auto Ignitio". .. -I"... ~m"'era't".·e·. .. " " I' "'1 ,,,at ,,:::::l ICc.., e IIII 

Ii FIClmmab:e Limits in Air, Volume %: Not appiiceble lEl: N/A

I

i 

E.xtinguishing Media: ;"S ,:-.:5 prodt.:c' is pr:mariiy aqueoL's. ;, is not a fire haLerc. 

tlie remaining solids coulC :'wrn. 

UEL: N/A 

;:"f,er wct=r :s =V2CC;etec 

I[

' ': 

x "'Vater Spray Carbcn cioxide 

:J, 

:i 

Foam X Drv chemicai 

" " 

'/ 

, S;:e~:al Fire Fighting Procedures: '.Veer NIOSH/:vISHA ac:;r::;YEC self-ccmcinea bre2thir,g ;:opar2tL.!S il~_- - _ &. bp,::siol~ :;azar::::s: 

:.• '\ generated. ii,: 

<~ ===================================~:l.-..

;!~0j5~~}:FS;~_~~~}~~.~~~fi~~{~~~~~~f~1@~~.~;i~~1

;1 SYMPTOMS OF EXPOSURE: 

" . :1 lr:gestion Ingesi:ion is not a orocaole rCUi:e at expo~t.:re. However, jf ingesi:ed. this 

:1 substance may cause Qest~oimesi:inal irrii:a;:ion. nausea. "/cr.-.iring c:nd

:, diarrhea. The degree ot ;:~i;:ai:ion wiil ce~enc on the Guantli:Y sIN2/jowed. \ 

Ii ! 

and the soeed croci '~crou,;r.ness of 'the firs, 2ic ,re;:';-;,en:s. i[ 

~--------------------:--------------------------------------:::

Skin Irritation This SubSi:2nCe may ca'l~e skin irrir::ion. C:~ns -nc <:'/r"'"'·~;,]S ~2Y ii 

;1 indude discclc""cn 'nd 'we!lins. -'-"' - "-.V., .. II 

:\ Dermal Toxicity The dermal toxicity of mis su~s!anC9 has not been determined. 

:,'.,,""\'-\-n-...-a-la-t-I'o-n--------------:---------------------------------11 l\u The inhalation toxicitY c: ,his s;;bs,zr.ce hc:s net ::een determined. 1 

",'I However, it m2Y czuse irritation if inhale-:=:. The degree of injury will 

"depend on "ie airborne c:::ncentration and curation of e~:lcsure. 1:1 

Breerhing toluene vaeor cO:o1cen,rations a:,cve the recommended exposure I 

, Si:Cincard C<in cause centra: :1erVOUS SYSt2~ effec:s. S;;~s ",-.0 .::yl71oro.7.s .. 

i,'!i ot central nervous system effects may incluce or-a or more of the 

following: headac:le. dizzir.ess end Joss of coordination. 

'll. 

Revised' 8-2-94 Page 20f 5 

4.2.4-114 
____________________________________________________

II 

I 

I 

.._, 

!I	 Eye Contact 

\1 

\'­

~~-. Direc: contact with the liquic T"r;c;y resuit :r. severe irri:c;!i:::ln :.:e eves .._ 

and could cause imoairmer.: c~ vision. ,ne aegree or :~e ':"'.::,,:;1' wlil ii\.\:. 

cepend on the ar.10Um cf rr:zteri2!! that gets into troe eye 2r.::i the S=2e~ Ii \:: 

and thoroughness of the firs, 2:C trealmer.;:. Signs end sym:::::;.:s r.-:ay II '. __ indude pain, lears, redness, ana biL:rred vision. 

-!,:I! . '\, 

I	 SUSPECTED CARCINOGENIC AGENTS: Styrene has been lis'ted bv tne Ir-tterna:ionel Age:1cy fer ~.esearc~ on I I	 Cancer (lARel as Group 28 (possible h:.Jrr:ani cuc:nogens. This ces:;,.cnion incica;:es there was SHang evidence I 

of carcinogenicity in animals, bwt limited evicence of carcir:c<;er::c:~ in humans. No sisnificam 2:noum af i 

exposwre is ar.-.:icioated when good ir.cus::ial hygiene practices ate ~::served. I 

I 

I 

EMERGENCY FIRST AID:	 ' 

i-------------~-------------------------!i I.-nmecic:ely consui, a pnysic:or. IreDon pH c~ proo:.1C:). =:i~:e::y cr:;-:kir1g 

water cr mille If vomiting occ:.;rs, aspiration (bresrtlir.si cf ':C:7::, into :fle 

lungs iT.ust be avolce:::: sir.ce i: ;:-;ay leed tc Gs;::ira:;on ;:::leumcnitis. 

Ingestion 11 

SKin Contact \\:2$....1 :.-,::~a~~~j~' wi:h 5::2: =-.C ·........'ci:er. ::='e;r:ovc 2:j;:: ·"'.'CS~ ~::nt:2i:iir,c:~::

ciatr.ing. C.::l:1Sul' <: ;:hVSiCicn if ir1'li:cnicn cevelops. 

ii Inhalation Remove e;xpo~ed person ~o fresh alf. T.ea;: symptoms of irti:ation :1 'I

j\ neecec. Ccnsuilo pr.vsicicr. i~ ;r;i:;:;:ion persists. 

11-----------------_-..:..--------------------------------------', 

: Eyes	 Flusn tt'loroushly wit,1 w;;,e~ ;0; several C7:lnU1es. Consul: c pnysician 

imm=::ictely. 

_.MEDIC~L C;::NDI7iO~.S ,;..GGRAVATED SY EX?OSURE: 

a specific ,0 product. !ndividuais witn sensitive airways (e.g. as;:hmatics) may react :0 airborne vacors. 

"sons with preexisting sj,;jn conoitions rr.ay hove a reacticn ,0 c;::r,:eC: ·.... i:h liqwic proauc' . 

.. . .... ...., .. .. ........_......... "' ......................."'._........ ....... . .. . .•.. 

I ­ I 

Stability I 

t 

i 

i Incompatl bility 

1 

~I	 HazardOUS 

~olymllrization

Uns;:aole Ccndi'rions 10 Avoid: None ):r-;own I I I 

I I 

X I

Stable I	 I 

Materials to Avoid: /l;one known I 

May O::::~r Condlt.Jons to AllOle: ~cne .:I10·.... n 

X Will Nat Occur 

HazardOUS Decomposition Products (induding combustion produ::~sl: CO 2 _ CO ana s;,-;aii zmcwnts of "rema;:l:: 

or aliphatic hydrocarbons Cl;n be gene~ar;:d from comoustion at crise ~rodu:::.

4.2.4-115 

Revised 8-2-94	 Page 3· of 5 
f";::--:=-:=~=- :~=::t?~;::;E~;~~~":" .::;~ ... '.. "; ~·:~~::'·:-~.7: :~'-"'- ~=:"::-. -=..:.._:_~:::.~~;;.c-: -"-:;"~:'" ...~~--;- _ ..~. ::_:=:·.. ·~2::....:.:- \:.; 

~~~. . 

!!~7f~i§'"¥¥t~~~y~~~:~~~~~E:E~~~~gJ~g~~4~~~~E~:.~¥~~I5?f~::-:.~fil\\._
 :1 1 -:. :.11 Spill Response: Spilled materiai is slippery. Use en ir.e~ 2t:so~bent to contain the spill ana :0 dry the area. Ail II ........ v,:c NIOSH/MHSA .resoirator should be worn as we!1 as chemicaily resistanr gloves. Place 2Dsorbec
 

,::: ;;-; ;:; ::::se:::: ::cmainer to await discosa!. II \
 

;i I 

:1 I. 

1:1 Waste Disposal Method: Lic;uid produc't shouid r.ot be disoo:;ec of in a )ancfiil. Solids snouici be disposec of in \ 

1 ac::ordance with all local, state ar.c feaerel requiations. I' il	 .. 

l!i¥~~di:~~~E~~~~:~i~~Jilf.~_2~~gILo~1~~:~~~ili~N~~~~';:if2-:"j;~lt:fi!

!I Eye Protection: Wear c:"emic~1 sate[~ goggles I Skin Protection: Water p~CG; ane cr1e;:;icaliy resistam ! 

: when proc:.Jc1: IS sprayec, or wnen s;:;li!s or gioves should be ·""'orr. 'nnen worx.ir.c wit:; orocuct. ! 

I splashing of preduc, may occ:.:r. I Weer ct:emicaliy resistant clothing w~en co~tac: witil I 

liquid orocitlct is e~::Je'::ed. ! 

I II 

I-----------S--,------,------v---·----·--·------------r!i.!i 

Respiratory Protection ( pecliic I y;:>e): /Jhere entilatlon 2nd Ensmeermg Controls: Vennla;:icr. r,--,USt 

airborne concentra,ions are ex;:::e,:,e-::i :0 exceec be adecucte :0 conrrol aerosols, r,--.is:s or vaoors 

limits. wear a NIOSH/MSHA air ;::urifying raspirator generate:: when using ;:his product. Ventilation must be I

,

I wi~h an or~anic vapor cartridge or canister re cdec;:.;ate to kee;::: eXPosures :::eiow !:e iimits !is;:ed in i 

provide protection appropriate tcr exposure tc 5e':,lon III. iii 

generated aerosols, i1'":isrs and vaoors containi:~g

ciiemica!s I:s:r=;: In Section 11. :1 

Hygienic Practices in Handling and Storage: Avoid skin and eye c·or.tact. Do no: :aJc.e ir.ternaily. Employees li,1 

I 

, _S_h_O_U_I_d_w_a_S_M_':_h_o_r_o_u_9_M_IY_a_f_!e_r_h_c_n_d_!_in_g__p_r_o_d_u_c_t_"_=_rn_p_IO_y_e_e_S_S_h_O_!2_id_V_.I_a_s_r'_-U_D_~_e_t_o_r_e_e_a_t_in_~_, _s_"_._C_k_ii'l_Q_c_r_U_s_i;"1_9__....:I ,..	 toilet facilities. If clothing or shoes :,ecome contaminated. wash ::efore reuse. ,1

Precautions for Repair & Maintenance of Contaminated Equipmen:: i=iush with water ,0 c!e::n ::lroduc: off of 

equiome~t.

Other Precautions: Do not freeze iJToduC!. Do r.ot sto~e proauc: 20'OV9 SO" F 

r ...............~.:.:.:.:.. :::...: :~::~.:: 1
 

.. , .. ....	 :>~'::,:::..~':. ~':::,~":~~,.;",,, "0••:: 

Styre:1e. sociul7l codecyioenzene s~iton2te one tOluene cre :;rese;:t i,. c::;.i:en:,-a;:i:;;:s ::-:,,: r=A::~:C: ::-:a ::2 

minimis amount for tl'le SARA Title III Section 313 and 40CfR37Z annual release re;:orting requirer.:ents. You 

must tr2:1smit this information it you d!..s:ribute this procL:c: :0 o::iers. 

4.2.4-116 Revised 8-2-94 Page 4'of 5 
I. 

DEPARTMENT OF THE AIR FORCE RECr.:!"/~D HEADQUARTERS OGDEN AIR LOGISTICS CENTER (AFMC) 

HILL AIR FORCE BASE. UTAH ,-MAR 0 7 ii::i:) 

-/Air Quality 

Mr Russell A. Roberts 3 Mar 1995 

Executive Secretary 

Division of Air Quality 

1950 West North Temple 

PO Box 144820 

Salt Lake City, UT 84114-4820 

RE: Notice of Intent to Setup a Chemical Milling Process Line in Building 238 

Dear Mr Roberts 

This letter is to serve as a Notice of Intent to setup a chemical milling process line in 

Building 238. The current chemical milling operation is a grandfathered source located 

in Building 265 which must be relocated. During the first 90 days of operation, we also 

request approval to test a new water based maskant in the process. If the results of 

this test are favorable, we will use the water based maskant in place of the solvent 

based maskant currently being used in Building 265. However, if the test is not 

successful, we request approval to continue using the present solvent based maskant at 

the new location until a lower vac maskant can be found that meets the performance 

requirements. A report of the results comparing the two maskants will be made 

available upon completion of the test period. 

The proposed project requires the installation of five 2000 gal dip tanks in Building 238, 

four of which will be exhausted to the outside (see Attachment 1, detailed process 

description and emissions estimate). The only difference between the two candidate 

processes is the type of maskant used. All equipment and other materials are the 

same. 

4.2.4-117
 
Your prompt response to this matter would be greatly appreciated as we would like to 

begin testing the new maskant as soon as possible. Please contact Michael Graziano 

at 777-0359 if you require additional information. 

Sincerely I 

j~R.~~ JAMES R. VAN ORMAN 

Director, Environmental Management 

6 Attachments; 

1. Process Description & Emissions Estimate 

2. Project Layout 

3. High voe Maskant Tech Data Bulletin 

4. MSDS Sodium Hydroxide 

5. MSDS Isoprep 

6. MSDS Low voe Maskant 

cc:	 LAOPE (John Vidic) 

LARTW (Rich Trejos) 

-


4.2.4-118
 
CHEMICAL MILLING PROCESS DESCRIPTION 

AND EMISSIONS ESTIMATE 

A. Install five new process tanks in building 238 (Proposed layout attachment 2) 

Tank #1 Maskant Dip, exhausted to outside
 

Tank #2 Hot Water Dip, exhausted to outside
 

Tank #3 Isoprep, exhausted to outside
 

Tank #4 Water Spray Rinse
 

Tank #5 Sodium Hydroxide, exhausted to outside
 

All dip tanks are 2000 gallons.
 

Slotted ventilation systems across the top of tanks 1, 2, and 3 will be manifolded
 

together and exhausted through a 38" duct 60' above ground level.
 

The slotted ventilation system across the top of tank 5 will be exhausted through a 24"
 

duct 60' above ground level.
 

B. The general process for each part is as follows; 

1. Dip in Sodium Hydroxide, tank #5, for 30 seconds; flash cleaning. 

2. Dip in Hot Rinse, tank #2. 

3. Dip in Isoprep, tank #3; desmutting. 

4. Spray Rinse in tank #4 

5. Hang Dry 

6. Dip in Maskant, tank #1. 

7. Hang Dry 24 hours 

8. Use template and cut away maskant from area to be milled. 

9. Dip in Sodium Hydroxide tank #5, exposed metal areas are milled at 0.001 

inch per minute. 

10. Dip in Hot Rinse tank #2. 

11. Dip in Isoprep tank #3, for cleaning. 

12. Spray Rinse in tank #4. 

13. Repeat steps 8-12 as needed to mill various areas to desired depths. 

(Note: The process and materials are the same for both regardless of the maskant
 

used.)
 

C. Emissions Estimate Grandfathered Process 

Maskant (Tech Data Sheet Attachment 3) 

Eight 55 gallon drums per year =440 gallons 

8.0 Ibs per gallon =3,520 Ibs
 

from MSDS solids are 36%, therfore solvents are 64%
 

3,520 Ibs of maskantlyr X 64% VOC =2,252.8 Ib voe 

4.2.4-119 

A/elf I-I 
Thinner 

Maskant must be thinned with 1 drum of solvent each week 

52 drums/yr X 55 gal/drum X 7.51bs VOC/gal = 21,450 Ibs voe 

Sodium Hydroxide (MSDS Attachment 4) 

Twelve 55 gallon drums per year = 660 gallons 

Specific gravity = 2.12 

therefore 8.4 Ib water/gallon X 2.12 X 660 gallons = 11,753.3 Ib NaOH 

Engineering estimate for NaOH losses from process tanks is 5% 

11 ,753.3Ib X .05 =588 Ibs NaOH 

Isoprep (MSDS Attachment 5) 

Four 55 gallon drums per year =220 gallons 

Specific gravity = 1.43 

therefore 8.4 Ib water/gal X 1.43 X 220 gallons =2.642.6 Ib Isoprep 

Engineering estimate for Sulfuric Acid losses from process tanks is 33% 

2,642.6 Ib X .33 = 872 Ib Isoprep 

Emissions Summary Grandfathered Process 

vac Maskant 2,252.8Ibs 

vac Thinners 21,450.0 

Total vee 23,702.8 11.9 tons 

Sodium Hydroxide 588.0 0.30 ton 

Isoprep 872.0 0.44 ton 

D. Emissions Estimate Experimental Process 

Water based Maskant (MSDS Attachment 6) 

Eight 55 gallon drums per year = 440 gallons 

Specific Gravity =1.2 

therefore 8.4 Ib water/gallon X 1.2 X 440 gallons = 4435.2 Ib maskant 

from MSDS solvent content is 5% so 

4435.2 Ib maskant X 5% vac = 221.8 Ib vee 

Thinning agent for this maskant is deionized water 

Emissions from Sodium Hydroxide and Isoprep remain the same. 

A-TflJJ 1-2 

4.2.4-120 
E. Annual Emissions Summary 

voe NaOH Isoprep 

Old Maskant 23,702.8/b 588.01b 872.01b 

Test Maskant 221.8Ib 588.01b 872.01b 

flTC.H /-3 

4.2.4-121 
- -

-- -- --

-


(' ( (
 

(I 11-R ,VI _ IYI; IJ N 

"";' + 

":t Q 

LOlli I I I I
 

1 5 10 15 2U 25
 

[

PM 

EJ EJ 

D

I 8 

t:/ tl 

0 c:: 

r I I
 

/
 8 

Sprinl<ler ---1------­ '--- ,-­ '-­ RiSer IQJ

1 

Deioniz r 

EqUipMnt 

ArPQ 

I 

r 8 I~I \ 

II 

PH 8340 -

- Hosl<ont \lot Di(ronot jodiuM .- COLD 

IJAlER Sproy 

1,[0 ter Rinse Iydroxidr DIP QI'5""",""1 Oip RINSE

;::5 0 ­

t'( l '? 

\ C6 {I PAA

:l J 'i ,5 LINE

0/I.. 

I-­ ICJ 

--

r --- I-­ I '--­

u u u PAINT / l~ INDUS TRII\L \lAS TE DRAINS

I 

. CLEANING 

BOOTH CONTROl

l=

'" 0 - , . \/l/P 

1 

~~ . PH 8341 PI 

COLD PI 

IJATDR Al 

DIP AI 

RINSE 

I}I~ t= 

I 
,-­ -TURCO ?ROCUC7S CAl-IF

:::; 2. :. S. 54 

1m] 490 

TURCO PRODU:::TS !NC.. nco 80lSA AVENUE. W:STMINSTER. CAlIFCRNI.A ;258(·:?-600 

TURCOFCRM@ MASK 522 

DIP AND FLOW COAT CHEM·MILL MASKANT 

DESCRIPTION: 

TURCOFORM~ MASK 522 is a tan, licuid, single component. air C:.;rJ,'ig, peelable protective 

coating formuiated to provide crotectlon against the corrosive ac!ion of hot caustic and 2C:C!C 

Solutions usee in the Chern·Mill Diocessmg d aluminum, magnesiur:1. steel eno t:tanlum aUoys. 

TURCOFORM MASK 522 can be appiied by immersion or How coating methods and dries to a 

chemical resistant elastomeric film within 12 hours. TURCOFORM MASK 522 can be foreea dried 

by conventional rr:e'Lhcds. after air drying fer 2 to 3 hours at room temperature. 

A top·coat of TURCOFORM MASK 550 is recommended fer steel and titanium processing to 

provide additional crotec,:cn against aggressive acid stenant soiutions. 

LICUID PROPERTIES: 

Appearance Tan viscous liquid
 

Solids by wt. 34.5 =1%
 

Gallon weight 8.0# min.
 

Viscosity, Poise 15:::4
 

Flash Point (SETA) 40°F
 

Storage life @ 75 of , year min.
 

FILM PROPERTIES: 

Tensile Sirength 900 psi mIn.
 

Elongation at rL!pture 475% min.
 

Peel Adhesion: (pounds/in. width)
 

Solvent wiped panels Before etch After etch 

2024·T3 Clao Aluminum 0.8±O.3 1.3 max. 

DIRECTIONS FOR USE: 

1.	 Precleaning: For optimum uniformity in adhesion and performance the parts to be masked 

must be free at oil, grease, dirt or corrosion. Your TURCO Territory Manager can recommend 

suitable TURCO cleaners based on specifications and proauc:lon needs. 

2.	 MixIng: To assure reproducible reSUlts In application and performance of the TURCOFORM 

MASK 522. adequate mixing of the solution is very important prior 'to and during use. caution 

must be exercised to prevent air from being dra'l'm into the mask by the mixing action. Since 

some solvent is lost during use due to evaporation. periodic additIons of thinner are required. 

TIle amount of thinner requir~d is based on viscosity measurements. A #5 Zahn cup 

viscometer may be used to measure and adjust the maskant to the desired operating viscosity. 

4? 4_1?1 
I 

I 

.----{	 ( (
 

MATERIAL SAFETY DATA SHEET 

Item Name SODIUM HYDROXIDE,ACS
 

Part Number/Trade Name SODIUM HYDROXIDE
 

National Stock Number , , 6810000778570
 

CAGE Code.............................. 70829
 

Part Number Indicator A
 

MSDS Number 89815
 

M?~ufacturer	 Name J.T.BAKER CHEMICAL CO 

Street 222 RED SCHOOL LANE. 

City PHILLIPSBURG 

State . . . . . . . . .. NJ 

Country US 

Zip Code 08865-2219 

Emergency Phone 201-859-2151 

Information Phone 201-8S9-2151 

Date MSDS Prepared/Revised PRE-HCS 

Date of Technical Review , 2'lFEB84 

Active Indicator Y 

Vendor tl5 CAGE......................... BCXNJ
 

Specification Number , .. NOT APPLICABLE 

Specification Type/Grade/Class N/R 

II lrd Storage Compatibility Code C2 

NkL License Number N/R 

Net Propellant Weight (Amlllo) N/H. 

Appearance/Odor ,	 WHITE, DELIQUESCENT PIECES, LUMPS OR 

STICKS. 

Boiljng Point 2S34F,1390C 

Melting Point UNKNOWN 

Vapor Pressure N/R 

Vapor Density N/R 

Specific Gravity 2.120 

Decomposition Temperature UNKNOWN 

Evaporation Rate N/R 

Solubility in Water APPRECIABLE 

Chemical PH N/K 

Flash Poj NONE 

":t 

N 

..... 

N 
I 

I 

.c~~ishing Media
 

~6ial Fire Fighting Procedures
 

Unusual Fire/Explosion Hazards 

Stability · 

Materia.ls to Avoid 

Hazardous Decomposition Products 

Hazardous Polymerization 

'3Yloptollls of Overexposure 

I~mergency/First Aid Procedures 

3teps jf Material Released/Spilled ..... 

'1aste Disposal Method 

landJillg & Storage Precautions 

)ther Precautions 

{espiratory Protection 

Jentilation 

Jrotective Gloves 

~ye Protection 

)ther Protective Equipment 

3upplernental Health/Safety Data 

[ngredient- ., 

WATER 

FLOOD WITII WATER,DO NOT SPLASH OR SPLASH 

MATERIAL 

NONCOMBUSTIBLE BUT SOLID FORM IN CONTACT 

WITH MOISTURE MAY GENERATE SUFFICIENT 

HEAT TO SEE SUP DATA 

YES 

MOISTURE,ME'l'ALS,EXPloOSIVES,ORGANIC 

PEROXIDES 

MAY GENERATE HYDROGEN GAS ON CONTACT 

WITH METALS 

NO 

HIGHLY CORROSIVE ACTION UPON BODY 

TISSUE. 

SPEED IN REMOVING THIS CAUSTIC MATERIAL 

IN CONTACT WITH SKIN IS OF VERY 

IMPORTANCE TO AVOID BURNS. REMOVE ALL 

CONTAMINATED CLOTHING AT ONCE AND GIVE 

SHOWER UNDER DELUGE TUPE OF WATER, 

IRRIGATE EYES WITH WARM WATER FOR AT 

LEAST 15 MINUTES. 

COLLECT AND REMOVE WITH A BROOM IN A 

LARGE BUCKET. DILUTE WITH WATER AND 

NEUTRALIZE WITH 6M HCL. DRAIN INTO A 

SEWER WITH SUFFICIENT WATER. 

PUT INTO A LARGE VESSEL CONTAINING 

WATER. NEUTRALIZE WITH 6M HCL. DISCHARGE 

INTO THE SEWER WITH SUFFICIENT WATER. 

TECT AGAINST PHYSICAL DAMAGE OF 

CONTAINERS. STORE IN A DRY PLACE. 

PROTECT AGAINST MOISTURE. STORE 

SEPARATELY FROM ACIDS,METALS,OXIDIZING 

MATERIALS. AV 

AVOID SKIN CONTACT. 

NIOSH/MSHA APPROVED RESP DEVICE IN 

ACCORD WITH EXPOSURE OF CONCERN. 

LOCAL/MECHANICAL 

RUBBER 

GOGGLES 

PLASTIC OVERALLS 

IGNITE COMBUSTIBLE MATERIALS. CONTAINER 

SIZE: 1 LB BOTTLE 

01 

( I 

\. 

V') 

C'l 

..qN 

"t" 

N 

.q. 

j:, 

<t 
( Nt 

I ...;di{	 SODIUM HYDR{••.LDE (SARA III) 

3.310-73-2 

WB4900000	 \0 :; C'l 

...... NO	 I

>97 C'l <t 

2 MG/M3 

C 2 MG/M3i 9293 

NOTICE:	 If you require a complete, unabbreviated MSDS, 

call Bioenvironmental Engineering. 
---

I 

MATERIAL SAFETY DATA SHEET
 

tem Name. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ISOPREP 181 

art Number/Trade Name " '" ., ISOPREP 184 SULFURIC ACID SOLUTION 

ational Stock Number .. " 6810PISOPREP184 

AGE Code 99442 

art Number Indicator A 

80S Number .. ,.......... . . . . . . . . . . . . . .. 12129 

!ai .:acturer Name ALLIED-KELITE 

Street 29111 MILFORD DR. 

City NEW HUDSON 

State MI 

Country .. , US 

Zip Code 48165 

mergency Phone 800-424-9300 

nformatiol1 phone 313-437-8161 

ate MSDS Prepared/Revised NONE 

ctive Indicator Y 

ppearatlce/Odor AMBER BROWN / ACEDIC ODOR 

oiling Point., 218 DEG F 

pi ',fic Gravity 1.43 

olubility in Water FREELY 

ercent Volatiles by Volume 45 

lash Point N/R 

xtinguishing Media USE WATER SPRAY, DRY CHEMICAL, C02, 

pecial Fire Fighting Procedures FIRE FIGHTERS SHOULD WEAR PROTECTIVE 

EQUIPMENT 

nusual Fire/Explosion Hazards NONE 

tability YES 

aterials to Avoid STRONG ACIDS 

azardous Decomposition Products N/R 

azardous Polymerization NO 

olymerization Conditions to Avoid WILL NOT OCCUR 

050 - LD50 Mixture N/R 

oute of Entry: Skin YES 

oute of E ': Inhalation YES 

( ( 

t-­ l} N 

...... 

'<T 

N :j 

..f 
I 

( ,..:al th III ds - Acute & Chronic .	 INHALATION J' EYE, NOSE AND THROAT 

IRRITATION, PULMONARY EDEMA, AND 

BRONCHIAL EMPHYSEMAj BURNS SKIN AND 

EYES, AND CAUSES DENTAL EROSION. 

CORROSIVE 2 EYES AND SKIN AND INTERNAL 

ORGANS 

~arcillogenity: NTP .	 NO 

~arcinogenity: IARC .	 NO 

:arcinogenity: OSHA .	 NO 

;ymptoms of Overexposure .	 SKIN AND EYE BURNS AND INTERNAL ORGANS 

1edical Condo Aggrevated by Exposure .	 N/R 

~mergency/First Aid Procedures . [EYES] FLUSH WITH WATER FOR 15 MIN WHILE 

HOLDING EYE LIDS APART TO INSURE OF CLE 

;t 3 if Material Released/Spilled .....	 DIKE SPILL AREA WITH INERT MATERIAL, 

COVER AND REMOVE AND PLACE INTO 

CONTAINER MARKED FOR DISPOSAL 

leutralizing Agent . LIME 

Taste Disposal Method . DISPOSE OF IN ACCORDANCE TO ALL STATE 

AND FEDERAL LAWS 

~espiratory Protection . USE NIOSH APPROVED RESPIRATOR WHEN TLV 

LEVELS ARE EXCEEDED 

'entilation .	 jLOCAL OR GENERAL 

'rotective Gloves .	 IUJBBER 

:ye Protection.............. . .	 CHEMICAL GOGGLES
 

lork Hygenic Practices .	 WASH WITH SOAP AND WATER AFTER AHNDELING 

ANY CHEMICAL 

ngredient U	 01 

Dr ~dient Name	 POTASSIUM DICHROMATE 

'A::' L\lumber 7778-50-9 

roprietary NO 

ngredient U 02 

ngredient Name POTASSIUM FLUOBORATE 

AS Number 14075-53-7 

roprietary NO 

ngredient U........................... 03 

ngredient Name SODIUM BISULFATE 

AS Numbe r. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7681 - 3 8 - 1 

roprietary NO 

00 

N 

..... 

"1' 

01 

..,f 

N
 

\ 

to 

1: 

d 

f­

<t 
.:.;J MA ~RIAL SAFETY DATA~ SHEl.· 

.rade Name: CAX-200. CAX-200 +, CAX-1OOLA, 

CAX-177, CAX·1 77 +, CAX·200 R WATERBORNE 

MASKANTS 

Formula: 

Proprietary mixture 

Manufacturer: Manufacturer's Phone Number: 

Malek, Incorporated 619·279·0277 

Manufacturer's Address: Name of Preparer: 

4951 Ruffin Road 

San Diego, CA 92123 

Malek. Incoroorated 

~::": :'. ;-~:":~J: :;::.:;' ~;~ ~~~::C? :~7 :.:": ~:~<J f~':::-HAZ:&RD'6'Us: i'N-G REDimTS iJ:~::;:~ ~~..::.:~~. .. :.-.':~: ;::: .-.::~::: ....: :1 .'.~ '".:' ..•?:". .': -.• :~~:.:-;:~;: ~':.;<~ ;.:; :.~ ::;.';':-.:;';::. ::.:::.~:: :__ ~~ ~: .• __ :>.' .':_ ..:. . "..n. :~_:::'.:'••;:-~::~>:.~..:;:~~~'<:::~:'-:~'. ;.-;:~:.: -: :>: <:..::~:

II 

Principal HazardOUS
 

Components
 I 

Styrene I (CAS #100-42-5) 

Toluene
 

(CAS #108-88-31
 

Sodium Dodacylbenzene
 

Sulfonate
 

(CAS #25155-30-01
 

Water (CAS #7732-18-5) 

Procrietary Non-hazardous
 

Solids
 

Exposure Umits in.Air (give units)

Composition I

('Yo by weight) 

< 0.4 

<4 

1.0 

-50 

-48 

ACGlH TLV 

50 ppm (TWA)
 

, 00 ppm (ceiling)
 

100 ppm (TVJA) 

1SO ppm (STEll 

N/A 

N/A 

N/A 

OSHA PEL 

100 ppm (TWA) 

200 ppm (ceiling) 

200 ppm (TWA) 

300 ppm (STELl 

N/A 

N/A 

N/A 

1 Boiling Point (C Fl: 21 2 CF I Specific Gravity (H2 0 = 1): 1.1".2

Vapor Pressure (mm Hg.) @ 20°C; 17 mm (water) evaporation Rate (butyl acetate == '): Less than 

one 

Vapor Density lAir"" 1): Not Known IpH: 8.8· 9.2 

Revised 8-2-94 Page "of 5 4.2.4-129 

I 
II 

\. .
 

Solubility in Water: Miscible with water
 Melting Point or Range. OF: Liquid at room 

temperature 

r------------------"--------------L 

'cearance & Odor: Wquid. mild odor 

~~f~~~~i::~4Z::_ls~tff~;~·R~~~~fl~t~~t~~~~~~BJ~~::~~~~~~ ~~~~~~~~Jt.~~~~¥~~r~1¥1~j;.~¥;~{f~~¥~~1
 Flash Point (Test Method): Not applicable Auto Ignition Temperature: Not Applicable ) 

Flammable Limits in Air. Volume %: Not applicable LEL: N/A -f UEL: N/A 

Extinguishing Media: As this product is primarily aqueous. it is not a fire hazard. After water is evaporated 

the remaining solids could burn. 

x Water Spray Carbon dioxide 

x Foam x Dry chemical 

Special Fire Fighting Procedures: Wear NIOSH/MSHA approved self-comained breathing apparatus 

Unusual Fire & Explosion Hazards: If residual solids are comousted. toxic; ,md irritating gasses will be 

generated. 

SYMPTOMS OF EXPOSURE: 

Ingestion 

Skin Irritation 

Dermal Toxicity 

Inhalation 

Ingestion is not a probable route of exposure. However, if ingested. this 

substance may cause gastrointestinal irritation. nausea, vomiting and 

diarrhea. The .degree of irritation will depend on the ouantity swallowed. 

and the speed and thoroughness of the first aid treatments. 

This substance may cause skin irritation. Signs and symptoms may 

include discoloration and swelling. 

, The dermal toxicity of this substance has not been determined. 

The inhalation toxicity of this substance has not been determined. 

However. it may cause irritation if inhaled. The degree of injury will 

·depend· on the airborne concentration and duration of exposure. 

Breething toluene vaoor concentrations above the recommended exposure 

standard can cause central nervous system effects. Signs and symptoms 

of central nervous system effects may include one or more of the 

following: headache, dizziness and loss of coordination. 

Revised 8-2-94 Page 2 of 5 

4.2.4-130 
II 

\ 

\ 

'-	 \ 

., 11 Eye Contact	 Direct contact with the liQuid may result in severe irritatIon to the eyes -. 

and could cause impairment of vision. The degree of the injury will 

depend on the amount of materiai that gets into the eye and the speed -.­ and thoroughness of the first aid treatment. Signs and symptoms may 

include pain. tears. redness. and blurred vision. 

ISUSPECTED CARCINOGENIC AGENTS: Styrene has been listed by me International Agency for Research on 

Cancer (rARC) as Group 28 (possible human) carcinogens. This designation indicates there was strong evidence 

of carcinogenicity in animals, but limited evidence of carcinogenicirv in humans. No significant amount of 

exposure is anticipated when good industrial hygiene practices are observed. 

.
 I 

EMERGENCY FIRST AID: 

Ingestion 

Skin Contact 

Inhalation 

Eyes 

Immeciately consult a physician (report pH of product). Dilute by drinKing 

water or milk. If vomiting occurs, aspiration (breathingl of vomit into the 

lungs must be avoided since it may lead to aspiration pneumonitis. 

Wash thoroughly with soap and water. Remove and wash contaminated 

dothing. Consult a physician if irritation develops. 

- Remove excosed oerson to fresn air. Treat symptoms of irritation I, 

neeced. Consult a physician if irritation perSists. 

Flush thoroughly with- water for several minutes. Consult a physician 

immediately. 

I 

I 

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: 

~,-

Ie specific to produC't. Individuals with sensitive airways (e.g. asthmatics) may react ~o airborne vapors. 

drsons with preexisting skin conditions rr:ay have a reaction to contact with liquid product. 

Unstable Conditions to Avoid: None known 

Stability 

X Stable 

Incompatibility Materials to Avoid: None known 

Hazardous May Occur Conditions to Avoid: None lcnown 

Polvmerization 

X Will Not Occur 

Hazardous Decomposition Products lindudlng combustion produc:tsl: CO2 , CO and small amounts of aromatic 

or aliphatic hydrocarbons can be generated from combustion of dried prodl.:ct. 

4.2.4-131 

ReVised 8-2-94 Page 3 of 5
I 

--- "" .., ---­ .-. 

.\ \ 

\ 

'ill Response: Spilled material is slippery. Use an inert absorbent to contain the spill end to dry the area. An
 

Jroved NIOSH/MHSArespirator should be worn as well as chemically resistant gloves. Place abscrbec
 

'daterial in a closed container to await disposal. 

Waste Disposal Method: Uquid product should not be disposed of in a landfill. Solids snould be disposed of in 

accordance with all focal, state and federal regulations. 

Eya Protection: Wear chemica! safety g09g1es Skin Protection: Water proof and chemically resistant 

when product is sprayed. or when spills or gloves should be worn when working with product. 

splashing of product may occur. Wear chemically resistant Clothing when contact with 

liquid product is expected. 

Respiratory Protection (Specific Type): Where Ventilation and Engineering Controls: Ventilation must 

airborne concentrations are expected to exceed be adeouate to control aerosols, mists or vapors
 

limits. wear a NrOSHtMSHA air purifying respirator
 generated when using this produc:. Ventilation must be 

with an organic vapor cartridge or canister to adeQuate to keep exposures below the limits listed in 

provide protection appropriate fer exposure to Section III.
 

generated aerosols. mists and vapors containing
 

chemicals listed in Section II.
 

Hygienic Practices in Handling and Storage: Avoid skin and eye contact. Do not talee internaily. Employees 

should wash 'thoroughly aner handling product. Employees shouid wash-up before eating, smoking or using 

toilet facilities. If clothing or shoes become contaminated, wash before reuse. 

Precautions for Repair & Maintenance of Contaminated Equipment: Flush with water to clean product off of 

eQ~pment.

Other Precautions: 00 not freeze product. Do not store product above 90 0 F 

StYrene, sodium dodecylbenzene sulfonate and toluene are present in concentrations that exceed the de 

minimis amount for the SARA Title III SeCtion 313 and 40CFR372 annual release reporting reQuirerr:ents. You 

must transmit this information if you d!§tribute this product to others. 

Revised 8-2-94 4.2.4-132 Page 4'of 5 
FEJ-17-1995 13:09 CR~IRN/MRLEK INC. 619 279 '::618 P.06 \ 

\ 

.'.~~ \ 

\RNING: SU8STANCES KNOWN TO THE STATE OF CALIFORNIA TO CAUSE REPRODUCTIVE TOX1CI7Y: 

Toluene (CAS ,I, 08-88-31 

While the information contained harein is believed to be correct. Malek. Incorporated shall in no event be responsible tor any damages whatsoever. 

directly or indirectly, resulting ",om the publication or use of or rlliianee upon data contained herein. No warranty. eitner excr85Seo or imphed. of 

merchantability. of fn:nes:s. or of any nature with respect to the product. or to the data IS made herein. 

4.2.4-133 

Revised 8-2-94 Page S'Qt 5 ATLt\ ~-5

TOTRL P.06