## DEPARTMENT OF 

# ECOLOGY

State of Washington

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) PERMIT

Issued To:

Facility Location:

Permit Number:

Date of Original Permit Issuance:

Effective Date ofPermit: The Boeing Company Boeing Commercial Airplanes

Everett Facility

3003 West Casino Road
Everett, Washington 98203

PSD-14-01

September 10, 2014

September 10,2014

1bis PSD permit is issued under the authority of the Washington State Clean Air Act, Chapter

70.94 Revised Code of Washington; the Washington State Department of Ecology regulations

for the Prevention of Significant Deterioration of Air Quality as set forth in Washington

.Administrative Code 173-400-700 through 750; and the agreement for the delegation of the

federal Prevention of Significant · by the United States Environmental

Protection Agency to the Washington dated December 10, 2013.

REVIEWED BY:

Marc E. Crooks, P .E.

Science and Engineering Section

Air Quality Program

APPROVED BY:

Stuart A. Clark 

### _ ..... _____ , .

Air Quality Program Manager Washington State Department ofEcology Dateii TABLE OF CONTENTS

PROJECT SUMMARY

................................ ................................ ................................ ................. iii

APPROVAL CONDITIONS

................................ ................................ ................................ .......... 1

I. EFFECTIVE DATE OF PERMIT

................................ ................................ ................... 1

II. PERMIT EXPIRATION

................................ ................................ ................................ .. 1

III. PERMIT NOTIFICATION REQUIREMENTS

................................ .............................. 2

IV. EQUIPMENT RESTRICTIONS

................................ ................................ ...................... 2

V. EMISSION LIMITS

................................ ................................ ................................ ......... 4

VI. BACT EMISSION LIMITS

................................ ................................ ............................. 5

VII. SPECIFIC OPERATING REQUIREMENTS

................................ ................................ . 7

VIII. COMPLIANCE MONITORING REQUIREMENTS

................................ ................... 10

IX. RECORDKEEPING AND REPORTING REQUIREMENTS

................................ ..... 12

X. GENERAL RESTRICTIONS ON FACILITY OPERATIONS

................................ .... 13

XI. MALFUNCTION AND EXCESS EMISSIONS REPORTING

................................ .... 13

XII. RIGHT OF ENTRY

................................ ................................ ................................ ....... 14

XIII. TRANSFER OF OWNERSHIP

................................ ................................ ..................... 15

XIV. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER

ENVIRONMENTAL LAWS

................................ ................................ ......................... 15

XV. APPEAL PROCEDURES

................................ ................................ .............................. 16

ACRONYMS AND ABBREVIATIONS

................................ ................................ ..................... 17iii PROJECT SUMMARY

Boeing C ommercial Airplane’s Everett facility (Boeing Everett) builds wide

- body airplanes

. Boeing Everett manufactures the model 747, 767, 777, and 787 airplanes

. This manufacturing effort includes making the airplane cabin interior components for the Boeing 737, as well as for the 747, 767, 777, and 787.

Boeing proposes to produce new models of the Boeing 777, hereafter referred to as the “ 777X ”

models in this d ocument

. Production of the 777X is scheduled to begin in 2017

. Delivery of the first 777X is targeted for 2020

. As production of the 777X ramps up, production of the current

777 models , hereafter referred to as “legacy 777s” in this document, will decre ase

. By the early to mid 2020s, production of the legacy 777 models is expected to be phased out.

Certain components for the 777X wing will be made in Everett in a new building located on the Boeing Everett site

. Final assembly of the 777X will occur i n the same building where the legacy 777 models are currently assembled.

The proposed project includes two phases

. The first phase will transition production of legacy

777 models to 777X models

. The second phase will increase the maximum production cap acity and thereafter the production rate from the current rate of about 8.3 legacy 777 s per month (or about 100 per year) to as many as 10.4 777X models per month (about 125 777X per year).

Boeing request ed Phase 1 to consist of two components :

1. The first component of Phase 1 will be to make the changes to the facility necessary to begin production of the 777X model while maintaining production of legacy 777 models at levels up to approximately 8.3 airplanes per month per existing approval under P SD

P ermit No. 11

- 01

. The changes include constructing a new building to manufacture the components for the new composite wing and creating additional wing and airplane assembly capacity for the 777X within the existing buildings.

2. The second component of Phase 1 is an increase in 777X production capacity and rate to approximately 8.3 airplanes per month that corresponds with a decrease production of legacy 777 models to the point where eventually the facility will no longer produce legacy 777 models. During Phase 1, Boeing Everett does not plan to exceed a combined

777 production rate (i.e., rate for legacy 777 s plus 777Xs) of approximately 8.3 airplanes per month.

Phase 1 will include the following modifications at Boeing Everett to achieve a production

c apacity of 8.3 777Xs per month:

1. Constructing a new building (Building 40

- 58) to fabricate 777X wing components.

2. Installing a new 777X wing spar build

- up line in an existing building.

3. Installing a new 777X wing assembly line in an existing building.

4. Installing a new 777X final assembly line in an existing building.iv 5. Reconfiguring the existing legacy 777 final assembly line to accommodate final assembly

of the 777X.

6. Constructing new 777X vertical fin spray booths and prep booths i n an existing building.

7. Changing existing tooling and equipment throughout the 777 factory to accommodate the larger 777X body sections and/or wings.

Boeing requested Phase 2 be included in this permit

. The second phase of this project will be to

make further changes to the Boeing Everett facility with the intent of increasing the overall 777X production capacity

. Phase 2 will make further changes to Boeing Everett to increase overall 777X production capacity to up to about 10.4 airplanes per month

. P hase 2 is tentatively scheduled to begin in 2021, and will involve additional tooling and equipment to increase the 777X production capacity

. For example, additional tape layup machines for fabricating wing panels might be installed in the wing component fabrication building, and include additional spray booths

.

A Prevention of Significant Deterioration (PSD) analysis was performed for the project for all pollutants to determine if any increase was above the “significance” level. The project will result in a significant net emissions increase of v olatile o rganic c ompounds (VOC)

.

A full technical review of the project for VOC , including a Best Available Control Technology (BACT) analysis, and the project’s effect on national ambient air quality standards (NAAQS)

, PSD increments, visibility, soils

, and vegetation, is required and included in a Technical Support

Document (TSD) prepared by the Washington State Department of Ecology (Ecology) on July
30, 2014

.

The emissions of other air pollutants not subjected to PSD review will be covered in the Puget Sound Clean Air Agency (PSCAA) Notice of Construction (NOC) approval for this project.Boeing Everett 777X Project Page 1 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

APPROVAL CONDITIONS

Based on the PSD permit application submitted by Boeing on February 2 0 , 201 4 , the additional

information submitted on May 23, 2014, and the technical review performed by Ecology, Ecology finds that all requirements for issuance of this PSD permit have been satisfied. Ecology determined the application complete on June 23, 2014. Approval of the project is granted subject to the following conditions:

I. EFFECTIVE DATE OF PERMIT

In accordance with 40 CFR § 124.15 and § 124.19, and the Washington Administrative Code (WAC) 173

- 400

- 730(2 ) ( c) , the effective date of this PSD p ermit is one of the following dates:

A. If no comments requesting a change in the prelimin ary determination were

received: the date of issuance; or

B. If comments requesting a change in the preliminary determination were received : thirty ( 30 ) days after the applicant and the commenters receive the final determination; or

C. If a review of the final determination is requested pursuant to 40 CFR § 124.13 and 40 CFR § 1 24.19 (see WAC 173

- 400

- 730(4) ) , the effective date of th is p ermit is suspended until such time as the review and any subsequent appeal against th is

p ermit are resolved.

II

. PERMIT EXPIRATION

Pursuant to 40 CFR § 52.21(r)(2) and WAC 173

- 400

- 730(5)

, and unless an extension is granted by Ecology prior to expiration

, Boeing’s authorization to construct under this PSD permit expires as follows :

A. This permit expires, and re

- permitting will be required before any further construction activity may occur, if :

1. Construction of Phase 1 has not commenced (as defined in 40 CFR § 52.2l (b)(9)) within eighteen (18) months of the effective date of this permit; or

2. Construction of Phase 1 is discontinued for a period of eighteen (18) months

or more; or

3. Construction of Phase 1 is not completed within a reasonable time.

B. Phase 2 of this permit expires, and re

- permitting will be required before any further construction activity occurs on the Phase 2 changes, if :Boeing Everett 777X Project Page 2 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

1. Construction of Phase 2 has not commenced (as defined in 40 CFR § 52.21(b)(9)) within eighteen (1 8 ) months of December 1, 2021; or

2. Construction of Phase 2 is discontinued for a period of eighteen (18) months

or more; or

3. Construction of Phase 2 is not completed within a reasonable time.

C. T he expiration of Boeing’s authorization to continue construction of the Phase 2 changes pursuant to Section II.B. does not affect Boeing’s authorization to continue construction the Phase 1 changes subject to all applicable requirements of this permit.

III. PERMIT NOTIFICATION REQUIREMENTS

A. Boeing ’s requirements in this PSD p ermit to notify

, report to

, or acquire approval or agreement from “Ecology and /or the PSCAA ” may be satisfied by providing such notification, report ing, or approval request to PS CAA if the conditions of

this PSD p ermit have been incorporated into Boeing Everett’s Title V Air Operating Permit issued pursuant to 40 C FR Part 70 and Chapter 173

- 401 WAC

.

B. Boeing must notify Ecology and PSCAA in writing or electronic mail of the date

const ruction on the 777X project is commenced, postmarked or received no later than thirty (30) days after such date.

C. By June 15 of each year, Boeing must submit to Ecology, in writing or electronic mail, an annual report containing a brief summary of the con struction activities related to the 777X project that occurred during the previous calendar year. This reporting obligation shall end when Boeing submits a notification to Ecology, in writing or electronic mail, that all construction activities related to the 777X project have been completed. This notification of completion shall contain a brief summary of any construction activities related to the 777X project that have not been included in a prior annual report.

IV. EQUIPMENT RESTRICTIONS

This PSD permit authorizes the construction of the new and modified equipment associated with the 777X project, as listed in Table IV

- 1 . H owever, Boeing may choose not to construct all the listed equipment.Boeing Everett 777X Project Page 3 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

Table IV

- 1. New and Modified Equipment Associated with the 777X Project

Unit ID Equipment Description New or
Modified

WCF

- 2 Gas

- fired heater for liquid nitrogen vaporization unit New

WCF

- 3a Gas

- fired process heater for autoclave #1 New

WCF

- 3b Gas

- fired process heater for autoclave #2 New

WCF

- 3c Gas

- fired process heater for autoclave #3 New

WCF

- 4 Vacuum pump(s) servicing autoclaves New

WCF

- 6a Wing panel wash stall #1 New

WCF

- 6b Wing panel wash stall #2 New

WCF

- 6c Wing spar and stringer wash stall #1 New

WCF

- 6d Wing spar and stringer wash stall #2 New

WCF

- 7 Gas

- fired plasma unit for treatment of wing panel stringers New

WCF

- 8a Up to t wo (2) Wing panel prep booth(s) (abrasive blast/sanding, solvent

hand

- wipe, edge seal) New

WCF

- 8b Wing spar prep booth (abrasive blast/sanding, solvent hand

- wipe, edge seal) New

WCF

- 9a Wing panel spray booth #1 New

WCF

- 9b Wing panel spray booth #2 New

WCF

- 9d Wing panel spray booth #3 New

WCF

- 9c Wing spar spray booth New

WCF

- 10a Wing panel primer curing booth #1 New

WCF

- 10b Wing panel primer curing booth #2 New

WCF

- 10c Wing spar primer curing booth New

WCF

- 11 Small quantity paint mix booth New

WCF

- 12a Coating equipment cleaning booth #1 New

WCF

- 12b Coating equipment cleaning booth #2 New

WCF

- 14 Up to f our (4) Wing spar seal booth(s) New

WBSP

- 1a Robotic wing spray booth for left hand wing Modified

WBSP

- 1b Robotic wing spray booth for right hand wing Modified

WBSP

- 2 Forward body section spray booth Modified

WBSP

- 3 Mid body section spray booth Modified

WBSP

- 4 Aft body section spray booth Modified

WBSP

- 6 Forward body section corrosion

- inhibiting compound spray booth Modified

WBSP

- 7 Mid body section corrosion

- inhibiting compound spray booth Modified

WBSP

- 8 Aft body section corrosion

- inhibiting compound spray booth Modified

WBSP

- 10 Vertical fin hybrid laminar flow control prep booth New

WBSP

- 11a Vertical fin hybrid laminar flow control spray booth #1 New

WBSP

- 11b Vertical fin hybrid laminar flow control spray booth #2 New

WBSP

- 11c Vertical fin hybrid laminar flow control spray booth #3 New

AA

- 2a Wing stub spray coating enclosure #1 New

AA

- 2b Wing stub spray coating enclosure #2 ModifiedBoeing Everett 777X Project Page 4 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

Table IV

- 1. New and Modified Equipment Associated with the 777X Project

Unit ID Equipment Description New or
Modified

F

- 1 Combustion equipment for comfort or process heating not otherwise
identified elsewhere in this table; multiple units, most of which will be less
than 5 MMBtu/hr, and all of which will be less than 10 MMBtu/hr New

F

- 2a Up to n ine (9) 2,750

- kW diesel generators New

F

- 2b 750

- kW diesel generator New

IRC

- 1a Adhesive spray booth #1 New

IRC

- 1b Adhesive spray booth #2 New

IRC

- 1c Adhesive spray booth #3 New

IRC

- 2 Paint spray booth New

IRC

- 3 Crushed core press New

V. EMISSION LIMITS

1. Consistent with requirements of 40 CFR § 52.21(j)(3), the following limitations apply

to VOC emissions from the Boeing 777X project:

a. This permit hereby amends the VOC emission limit from wing cleaning and coating operations in the two 777 robotic wing laydown spray booths and the nonrobotic southwest wing laydown spray booth in Building 40

- 37 in Approval

Condition IV.A3

. of PSD

- 11

- 01 from 34 tons per year ( tpy ) to 59 tpy in any twelve (12) consecutive months and in Approval Condition IV.A.2. of PSD

- 11

- 01 from 0.17 tons per wing to 0.24 ton per wing.

b. This permit hereby amends the VOC emission limit from wing cleaning and coating operations in the two 777 robotic wing laydown spray booths and the nonrobotic southwest and southeast wing laydown spray booths in Building 40

- 37 in Approval Condition IV.B of PSD

- 11

- 01 from 36.3 tpy to 61.3 tpy in any twelve (12) consecutive months.

c. This permit hereby amends th e 777 assembly operations VOC emission limit in Approval Condition 3.1 of PSD

- 91

- 06 from 238.8 tpy to 513 tpy in any twelve (12) consecutive months. For purposes of demonstrating compliance with Approval Condition 3.1 of PSD PSD

- 91

- 06, all 777X related pro duction operations in Building 40

- 58 are considered part of 777 assembly operations.

d. This permit hereby amends the Interiors Manufacturing VOC emission limit in Approval Condition 4 of PSD

- 05

- 02 from 205 tpy to 239 tpy in any (12)

consecutive months.Boeing Everett 777X Project Page 5 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

e. VOC emission from 777X wing component fabrication operations in Building 40

- 58 must not exceed 1.73 tons per completed shipset of 777X wing components, on

a 12

- month rolling average.

f. As used in this PSD permit, VOC means any compound defined as VOC in 40 CFR § 51.100(s).

2. Boeing Shall limit the increase in non

- VOC criteria pollutant emissions resulting from the 777X project as follows :

NOx: 39 tpy

CO: 99 tpy

CO2e: 74,000 tpy

PM 2.5 : 9 tpy

3. Boeing Everett shall limit natural gas usage from the new 777X project combustion

emission units listed in Table VI

- 1 below to 1,000,000 MMBtu per calendar year. The annual natural gas usage must be reported to PSCAA in writing or electronic mail, postmarked or received by June 15 of the following year.

VI. BACT EMISSION LIMITS

A. BACT for VOC C oatings O perations:

For cleaning and coating operations in the new and modified 777X spray booths, prep booths, and seal booths, the Boeing Everett facility must comply with all applicable VOC emission standards of the Aer ospace NESHAP in 40 CFR 63 Subpart GG , as in effect on July 1, 2014

. These requirements are described in

more detail in Condition VII.A below.

B. BACT for Natural Gas O perations:

Boeing is required to use good combustion practices as BACT for VOC emissions from the proposed new natural gas combustion units listed in Table V I

- 1.

Table V I

- 1 . Proposed Natural Gas Combustion Units

10

– 50 MMBtu/hr

Unit ID (from Table IV

- 1) Description

WCF

- 3a Gas

- fired process heater for autoclave #1

WCF

- 3b Gas

- fired process heater for autoclave #2

WCF

- 3c Gas

- fired process heater for autoclave #3

WCF

- 9a Space heating

- wing panel spray booth #1Boeing Everett 777X Project Page 6 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

Unit ID (from Table IV

- 1) Description

WCF

- 9b Space heating

- wing panel spray booth #2

WCF

- 9d Space heating

– wing panel spray booth #3

WBSP

- 11a Space heating

- vertical fin HLFC spray booth #1

WBSP

- 11b Space heating

- vertical fin HLFC spray booth #2

WBSP

- 11c Space heating

- vertical fin HLFC spray booth #3

5

– 1 0 MMBtu/hr

Unit ID (from Table IV

- 1) Description

F

- 1 Combustion equipment for comfort or process heating not otherwise identified elsewhere in this table; multiple units, most of which will be less than 5 MMBtu/hr, and all of which will be less than 10

MMBtu/hr

WCF

- 2 Gas

- fired heater for liquid nitrogen vaporization unit (if th is option is chosen to supply autoclaves with nitrogen

WCF

- 10a Space heating

- wing panel primer curing booth #1

WCF

- 10b Space heating

- wing panel primer curing booth #2

2

– 5 MMBtu/hr

Unit ID (from Table IV

- 1) Description

WBSP

- 10 Space heating

- vertical fin HLFC prep booth

WCF

- 9c Space heating

- wing spar spray booth

WCF

- 8a Space heating

- wing panel prep booth

WCF

- 14 Space heating

- wing spar seal booth

<2 MMBtu/hr

Unit ID (from Table IV

- 1) Description

WCF

- 7 Gas

- fired plasma unit for treatment of wing panel stringer

WCF

- 10c Space heating

- wing spar primer curing booth

WCF

- 6a Space heating

- wing panel wash stall #1

WCF

- 6b Space heating

- wing panel wash stall #2

WCF

- 8b Space heating

- wing spar prep booth

WCF

- 6c Space heating

- wing spar and stringer wash stall #1

WCF

- 6d Space heating

- wing spar and stringer wash stall #2Boeing Everett 777X Project Page 7 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

C. BACT for Emergency Generators:

This permit for the 777X project authorizes up to nine 2,750

- kW diesel

emergency generators for the autoclaves in Building 40

- 58 , and one 750

- kW diesel emergency generator for other emergency backup power needs in Building

40

- 58

.

Boeing is required to meet the emergency generator requirements for VOC

emissions contained in 40 CFR 60 Subpart II II, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. These standards require emergency diesel engines of the size for the 777X project to comply with

the Tier 2 emission standards for VOC emissions in 40 CFR 89.112 , which are 6.4 g/kWh for VOC and NO X combined

. Compliance with the VOC emission standards will be determined by maintaining the engine according to manufacturer’s recommendation, and an EPA issued emissions certificate which certifies that the engine com plies with EPA Tier 2 emission rates. The operating requirements for emergency stationary internal combustion engines are provided

in 40 CFR 60

, Subpart IIII, which limit non

- emergency use of each engine to 100 hours per year per engine

.

V I I. SPECIFIC OPERATING REQUIREMENTS

A. For cleaning and coating operations in the new and modified 777X spray booths, prep booths, and seal booths , Boeing Everett must comply with all applicable VOC emission standards of the Aerospace NESHAP, 40 CFR Part 63, Subpart GG ( as in effect on July 1, 2014), including but not limited to the following requirements, as applicable:

1. Cleaning solvent laden cloth, paper, or any other absorbent applicators used for cleaning will be deposited in bags or other closed containers upon

comp leting their use to the extent required by 40 CFR § 63.744(a)(1).

2. Fresh and spent cleaning solvents, except semi

- aqueous solvent cleaners as defined in 40 CFR § 63.742 must be stored in closed containers to the extent required by 40 CFR § 63.744(a)(2).

3. Conduct the handling and transfer of cleaning solvents to or from enclosed systems and other cleaning operation equipment that hold or store fresh or spent cleaning solvents in a manner that minimizes spills to the extent required by 40 CFR § 63.744(a)(3)

.

4. Hand wipe cleaning solvents must comply with 40 CFR § 63.744(b):

a. A VOC composite vapor pressure not greater than 45 mm Hg at 20°C; orBoeing Everett 777X Project Page 8 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

b. The composition requirements in Table 1 of 40 CFR § 63.744.

5. To the extent required by 40 CFR § 63,744(d), when co nducting flush cleaning operations subject to 40 CFR Part 63, Subpart GG (excluding those in which the cleaning solvents used either meet the composition requirements in Table 1 of 40 CFR § 63.744 or are semi

- aqueous as defined in 40 CFR § 63.742), Boeing shall empty the used cleaning solvent each time aerospace parts or assemblies, or components of a coating unit (with the exception of spray guns) are flush cleaned into an enclosed container or collection system that is kept closed when not in use or into a system with equivalent emission

control.

6. The VOC content level in primers and topcoats must meet the following requirements:

a. Exterior primers: Not greater than 5.4 lb VOC per gallon, as applied, less water and exempt solvents to the extent required by 40 CFR §

6 3.745(c)(2).

b. All other primers: Not greater than 2.9 lb VOC per gallon as applied, less water and exempt solvents to the extent requir ed by 40 CFR § 63.745(c)(4).

c. Topcoats: Not greater than 3.5 lb VOC per gallon, as applied, less water and exempt solvents to the extent required by 40 CFR § 63.745(c)(4).

7. To the extent required by 40 CFR § 63.745(f)(1), spray applied primers and

topcoa ts for wings must be applied using High Volume Low Pressure (HVLP), electrostatic, or other spray coating application methods, as approved by Ecology and/or PSCAA as specified in Condition III.A. , with a transfer efficiency equivalent to or greater than HV LP or electrostatic spray application methods.

8. To the extent required by 40 CFR § 63.744(c), spray guns and hoses will be cleaned by one or more of the methods specified below , or equivalent methods that are approved by Ecology and/or PSCAA as specified in

Condition III.A :

a. Enclosed system to the extent required by 40 CFR § 63.744(c)(1):

i. Clean the spray gun in an enclosed system that is closed at all times except when inserting or removing the spray gun.

ii. Cleaning must consist of forcing solvent through the gun.Boeing Everett 777X Project Page 9 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

b. Non

- atomized cleaning to the extent required by 40 CFR § 63.744(c)(2):

i. Clean the spray gun by placing cleaning solvent in the pressure pot and forcing it through the gun with the atomizing cap in place.

ii. No atomizing air is to be used.

iii. Direct the cleaning solvent from the spray gun into a vat, drum,

or other waste container that is closed when not in use.

c. Disassembled spray gun cleaning to the extent required by 40 CFR § 63.744(c)(3):

i. Disassemble the spray gun and clean the com ponents by hand in a vat, which must remain closed at all times except when in use;

or

ii. Soak the components in a vat, which must remain closed during the soaking period and when not inserting or removing

components.

d. Atomized cleaning to the extent require d by 40 CFR § 63.744(c)(4):

i. Clean the spray gun by forcing the cleaning solvent through the

gun.

ii. Direct the resulting atomized spray into a waste container that is fitted with a device designed to capture the atomized cleaning

solvent emissions.

B. In addition to complying with the VOC emission standards of the Aerospace NESHAP, 40 CFR Part 63, Subpart GG (as in effect on July 1, 2014 ), cleaning solvent for all cleaning and coating operations in the new and modified 777X

spray booths, prep booths, and seal booths must comply with the following requirements:

1. All wing panel and wing spar cleaning solvents must be applied either manually or by low pressure applicators, except in the following situations:

a. Cleaning intricate surf aces;

b. Where access is limited to the extent that using a low pressure applicator is infeasible;Boeing Everett 777X Project Page 10 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

c. Use of a cleaning solvent that either meets the composition requirements in Table 1 of 40 CFR § 63.744 or meets the definition of a semi

- aqueous cleaning solv ent as defined in 40 CFR § 63.742 (as in effect on July 1,

201 4 ).

2. Solvent used for hand wiping inside of fuel cells, fuel tanks, and confined spaces must have a VOC composite vapor pressure not greater than 72 mm Hg at 20°C.

VI I I. COMPLIANCE MONITORING REQUIREMENTS

A. Boeing must monitor compliance with Condition V.1.a. and V.1.b. by complying with the compliance monitoring requirements in Condition V.1.a . of PSD 11

- 01.

B. Boeing must monitor compliance with Condition V.1.c. by complying with the compliance monitoring requirements in Condition 15 of PSD 91

- 06.

C. Boeing must monitor compliance with Condition V.1.d. by complying with the compliance monitoring requirements in Condition 6 of PSD 05

- 02.

D. Beginning the first calendar month that production operations begin in Building

40

- 58

, Boeing must monitor compliance with Condition V.1.e. as follows:

1. Quantify the amount of each VOC

- containing material used in each calendar

month in the 777X wing component fabrication operations in Building 40

- 58 and calculate the corresponding total consumption over the previous twelve (12) consecutive months

. For this calculation, the amount of each VOC

containing material used in the 777X wing component fabrication operations in Building 40

- 58 during the eleve n (11) months prior to the first month in

which production operations begin in building 40

- 58 will be considered zero.

2. Determine VOC content of each VOC

- con taining material from the corresponding Material Safety Data Sheets (MSDS) or other data supplied b y the material’s manufacturer, or other method approved by Ecology and/or

PSCAA

.

3. Calculate the monthly VOC emissions from each VOC

- containing material

used in the 777X wing component fabrication operations in Building 40

- 58 by multiplying the VOC content of each material as obtained in Condition VIII.D.2. by the amount of that material used during the month as obtained in Condition VIII.D.1, then sum the monthly total VOC

- emissions from all VOC containing materials used over the previous twelve (12) conse cutive months.

4. Quantify the total number of 777X wing component shipsets completed in Building 40

- 58 over the previous twelve (12) consecutive months

. VerifyBoeing Everett 777X Project Page 11 of 18

Permit No

. : PSD

- 14

- 01

Issued: September 10, 2014

compliance with Condition V.1.e. by dividing the twelve (12) consecutive month total VOC emissions as obtained in Condition VIII.D.3. by the total

number of 777X wing component shipsets completed in Building 40

- 58

.

5. Boeing may deduct from the total VOC emissions calculated:

a. Any VOCs that a re included in the coating formulation as reactive components to the extent that they are incorporated into the final wing coating as verified by the coating’s manufacturer documentation.

b. Any VOCs recovered for reuse, recycling or disposal, or discharged from Boeing Everett to wastewater or solid waste, from materials used in the

777X wing component fabrication operations in Building 40

- 58

.

E. Beginning the first calendar month that any of the new and modified 777X spray booths, prep booths, or seal booths a re first used, Boeing must monitor compliance with conditions VII.A.1. through VII.A.5., VII.A.7., VII.A.8., and

VII.B by:

1. Conducting inspections of the work practice activities in the new and modified

777X spray booths, prep booths, or seal booths at least once per calendar year.

2. Work practices will be randomly sampled during each inspection, and observed for consistency with permit requirements.

3. To monitor compliance with Condition VII.A.4.a. and VII.B.2., Boeing must determine, as applicable, each cleaning solvent’s VOC composite vapor pressure in accordance with:

a. 40 CFR § 63.750(b)(1) for single component solvents (as in effect on July 1,

2014 ); or

b. The equation in 40 CFR § 63.750(b ) ( 2) for blended solvents (as in effect on July 1, 2014 ).

4. To monitor compliance with Condition VII.A.4.b., Boeing must determine, as applicable, each cleaning solvent’s composition in accordance with 40 CFR § 63.750(a) (as in effect on July 1, 2014 ) or by another method approved by Ecology and/or PSCAA.Boeing Everett 777X Project Page 12 of 18

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F. Beginning the first calendar month that any of the new or modified 777X spray booths, prep booths, or seal booths are first used for cleaning and coating, Boeing must monitor compliance with Condition VII.A. 6. by determining the VOC content (less water and exempt solvents) for each affected coating from the MSDS or other data supplied by the manufacturer, or by another method approved by Ecology and/or PSCAA as specified in Condition II I .A.

G. Boeing must monitor compliance with Condition V.2 by complying with the requirements in WAC 173

- 400

- 720(4)(b)(iii)(D).

I X. RECORDKEEPING AND REPORTING REQUIREMENTS

A. Beginning the first calendar month that any of the 777X production begins, Boeing must keep the following records at the site (or electronically accessible at the site):

1. Number of 777X wing component shipsets completed in Building 40

- 58 in the previous twelve (12) consecutive month period

.

2. The calculations and results pursuant to Condition VIII.D.

3. An annually updated list of all VOC containing materials used in the 777X wing component fabrication operations in Building 40

- 58 within the immediate past twelve (12) months

. For the purpose of this record, the immediate past twelve (12) moths shall not include any month prior to the

month that production operation began in Building 40

- 58

.

4. For material containing VOCs that were deducted as reactive VOCs , the manufacturer documentation verifying the quantity of reactive VOC incorporated into the final wing coating.

5. For VOCs that were deducted as waste , inventory records verifying the quantity of VOCs recovered for reuse, recycling or disposal, or discharged from Boeing Everett to wastewater or solid waste, from materials used in the

777X wing component fabrication operations in Building 40

- 58

.

B. Records must be retained for not less than five (5) years after their origination.

1. At a minimum, the most recent two (2) ye ars of data must be retained on site (or be electronically accessible at the site)

. The remaining three (3) years of data may be retained offsite.

2. Records must be available for inspection by Ecology and PSCAA within ten (10) days of request.Boeing Everett 777X Project Page 13 of 18

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C. Beginning the first calendar year after 777X production operations begin in Building 40

- 58

, Boeing must report in writing or electronic mail, postmarked or received by June 15 of each year, the following information to Ecology and/or

PSCAA.

1. The types and corresponding monthly and rolling 12

- month total quantities of VOC containing materials used in the 777X wing component fabrication operations in Building 40

- 58 for the previous calendar year.

2. The quantity of VOCs in the VOC containing mater ials reported.

3. For VOCs that were deducted, the monthly and rolling 12

- month total quantity of reactive VOCs incorporated into the final coating for the previous calendar year.

4. For VOCs that were deducted, the monthly and rolling 12

- month total quantity of VOCs recovered for reuse, recycling or disposal, or discharged from Boeing Everett to wastewater or solid waste, from materials used in the

777X wing component fabrication operations in Building 40

- 58 for the previous calendar year.

D. Boeing must keep records and submit reports with regard to Condition V.2 as specified in WAC 173

- 400

- 720(4)(b)(iii)(D)

.

X

. GENERAL RESTRICTIONS ON FACILITY OPERATIONS

A. At all times

, Boeing must, to the extent practicable, maintain and operate the 777X spray and sealing booths, including any associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions.

B. Determination of whether acceptable operating and maintenance procedures are being used for the 777X spray and sealing booths will be based on inf ormation available to Ecology, PSCAA, EPA and/or their authorized representatives, which may include, but is not limited to , monitoring results, opacity observations, review of operating and maintenance procedures

, and inspection of the source.

XI

. MALFUNCTION AND EXCESS EMISSIONS REPORTING

A. Prior to incorporation of the conditions of this PSD permit into Boeing’s Title V Air Operating Permit issued pursuant to 40 CFR Part 70 and WAC 173

- 401

, Boeing must report to Ecology and PSCAA , in writing or electronic mail, following the discovery of any malfunction of air pollution control equipment, process equipment, or of a process, which results in an increase in VOC emissionsBoeing Everett 777X Project Page 14 of 18

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above the allowable emission limits of this permit , in accordance with WAC 173

- 400

- 107 and the following conditions:

1. Boeing must notify Ecology and PSCAA , in writing or electronic mail, postmarked o r received no later than thirty (30) days after the end of the month in which a malfunction is discovered, for any malfunction of air pollution control equipment, process equipment, or of a process, which results

in an increase in emissions above the allowable emission limits of this permit

. This notification must include a description of the malfunctioning equipment, process equipment or process, the date and time of the initial malfunction (if known), the period of time over which emissions were increased due to the

malfunction , the cause of the malfunction (if known), the estimated resultant

excess emissions , and the methods utilized to mitigate emissions and restore normal operations.

2. For purposes of this permit , “malfunction” means any failure of air pollution

control equipment, process equipment, or of a process to operate in a normal

manner.

B. After the conditions of this PSD permit have been incorporated into Boeing’s Title V Air Operating Permit issued pursuant to 40 CFR Part 70 and WAC 173

- 401

, Boeing shall report t o PSCAA the discovery of any malfunction of air pollution control equipment, process equipment, or of a process, which results in

an increase in emissions above the allowable emission limits specified in this permit, pursuant to the deviation reporting req uirements and, if applicable, pursuant to the unavoidable excess emissions reporting requirements of th at Title V Air Operating Permit.

C. Compliance with the malfun ction notification requirements, as applicable, will

not excuse or otherwise constitute a def ense to any violation of this PSD permit or any law or regulation such malfunction may cause.

XII. RIGHT OF ENTRY

Section 114 of the federal Clean Air Act, 42 U.S.C. § 7414, and the Revised Code of Washington (RCW) 70.94.200 , and WAC 173

- 400

- 105(3) provide authorized representatives of EPA, Ecology, and PSCAA certain rights to enter and inspect the source. Refusal by Boeing to allow such entry and inspection may be a violation of the

federal Clean Air Act and/or the RCW subject to penalty as provide d in those statutes. Pursuant to these statutes, authorized representatives of EPA, Ecology, and PSCAA

, upon the presentation of credentials :

A. Have a right of entry to, upon, or through any premises of Boeing or any premises in which any records this per mit requires Boeing to maintain are located

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B. Have the right, at reasonable times, to access and copy any records this p ermit requires Boeing to maintain

.

C. Have the right, at reasonable times, to inspect any monitoring equipment or method required by this p ermit

.

D. Have the right, at reasonable times, to sample any emissions that Boeing is required to sample under this p ermit

.

X III

. TRANSFER OF OWNERSHIP

A. In the event of any changes in control or ownership of facilities to be constructed, this PSD permit will be binding on all subsequent owners and operators. The applicant must notify the succeeding owner and operator of the existence of this PSD permit and its conditions by letter, a copy of which must be forwarded to Ecology and/or PSCAA as specified in Condition III.A

.

B. If the conditions of this PSD permit have been incorporated into Boeing Everett’s Title V Air Operating Permit issued pursuant to 40 CFR Part 70 and WAC 173

- 401 , then the provisions for amending that Title V Air Operating Permit to allow for a change in ownership or operational control shall apply in place of the

notification provisions in Condition XIII.A.

X I V

. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER

ENVIRONMENTAL LAWS

A. Pursuant to 40 CFR § 52.21(r ) ( 1), Boeing must construct and operate the proposed emissions units in accordance with this PSD p ermit and the application

on which this p ermit is based.

B. Pursuant to 40 CFR § 52.21(r)(3), this PSD p ermit shall not relieve Boeing of the responsibility to comply fully with applicable provisions of the State Implementation Plan and any other requirements under local, state, or federal law.

C. Any applicant who fails to submit any relevant facts or who has submitted materially incorrec t relevant information in a p ermit application must, upon becoming aware of such failure, or incorrect submittal, promptly submit such supplementary facts or corrected information.

D. To the extent provided by 40 CFR § 52.12(c), for the purpose of establishi ng whether or not Boeing has violated or is in violation of any requirement of this

p ermit , nothing in this p ermit shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether Boeing would have been in compliance with applicable requirements if the appropriate performance or reference test or procedure had been performed.Boeing Everett 777X Project Page 16 of 18

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X V

. APPEAL PROCEDURE S

This PSD p ermit , or any conditions contained in it, may be appealed to :

A. The P ollution Control H earings B oard (PCHB) as provided in Chapter 43.21B

RCW and Chapter 371

- 08 WAC ; and/or

B. EPA's Environmental A ppeals B oard (EAB) as provided in 40 CFR § 124.13 and

40 CFR § 124.19.Boeing Everett 777X Project Page 17 of 18

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ACRONYMS AND ABBREVIATIONS

°C degrees Celsius

° F d egrees F ahrenheit

ASTM American Society for Testing and Materials

BACT Best Available Control Technology

Boeing Everett The Boeing Company, Boeing Commercial Airplanes

– Everett Facility

CFR Code of Federal Regulations

CEMS Continuous Emissions Monitoring Sy stem

CO c arbon m onoxide

CO 2 e carbon d ioxide e quivalents

EAB Environmental Appeals Board

Ecology Washington State Department of Ecology

EPA United States Environmental Protection Agency

gal gallon(s)

GHG g reenhouse g ases

H 2 SO 4 s ulfuric a cid m ist

H V LP High Volume Low Pressure

kW kilowatt

lb pound(s)

lb /hr p ound ( s ) per h our

mm Hg millimeters of mercury column

MMBtu/hr m illion British t hermal u nits per h our

MSDS Material Safety Data Sheet

NESHAP National Emission Standards for Hazar dous Air Pollutants

NO X n itrogen o xides

NWCAA Northwest Clean Air Agency

O 2 o xygen

PCHB Pollution Control Hearings Board

PM p articulate m atter

PM 10 p articulate m atter less than 10 m icro meters in diameter

PM 2.5 p articulate m atter less than 2.5 m icro meters in diameterBoeing Everett 777X Project Page 18 of 18

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ppm p arts per m illion

ppm v p arts per m illion by v olume

ppm vd p arts per m illion by v olume on a dry basis

PSCAA Puget Sound Clean Air Agency

PSD Prevention of Significant Deterioration of Air Quality

RCW Revised Code of W ashington

scf s tandard c ubic f eet

SCR s elective c atalytic r eduction

tpy t ons per y ear

ULSD ultra

- low sulfur diesel

U.S.C. United States Code

VOC v olatile o rganic c ompounds

WAC Washington Administrative Code