# TECHNICAL SUPPORT DOCUMENT FOR

THE BOEING COMPANY

BOEING EVERETT

777X PROJECT

Prepared by

Air Quality Program Washington State Department of Ecology Olympia, Washington

September 9 , 2014ii TABLE OF CONTENTS

1. EXECUTIVE SUMMARY

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

2. INTRODUCTION

................................ ................................ ................................ ................................ ................ 3

2.1. The Permittin g Process

................................ ................................ ................................ ................................ 3

2.1.1. The PSD Process

................................ ................................ ................................ ................................ . 3

2.1.2. The NOC Process

................................ ................................ ................................ ................................ 3

2.2. Site and Project Description

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

2.2.1. Site Description

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

2.2.2. Pro ject Description

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

3. PSD APPLICABILITY REVIEW

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

3.1. Overview and Permitting History

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

3.2. Emissions Calculation

................................ ................................ ................................ ................................ 17

3.2.1. Significant Emissions Increases

................................ ................................ ................................ ........ 17

4. BACT

................................ ................................ ................................ ................................ ................................ . 23

4.1. Definitions and Pol icy Concerning BACT

................................ ................................ ................................ . 23

4.2. BACT Analysis

................................ ................................ ................................ ................................ .......... 25

4.2.1. Prep and Spray Paint Booths BACT Analysis

................................ ................................ ................... 25

4.2.2. Available Control Technologies

................................ ................................ ................................ ........ 26

4.2.3. BACT Feasibility Review

................................ ................................ ................................ ................. 27

4.2.4. Ranking of BACT by Control

................................ ................................ ................................ ........... 28

4.2.5. Cost

- Effectiveness Evaluation

................................ ................................ ................................ ........... 28

4.2.6. Thermal Oxidizer

................................ ................................ ................................ .............................. 28

4.2.7. Carbon Adsorption

................................ ................................ ................................ ............................ 29

4.2.8. R egenerative Thermal Oxidizer

................................ ................................ ................................ ......... 29

4.2.9. RTO with Concentrator

................................ ................................ ................................ ..................... 29

4.2.10. Low VOC Coatings, High Transfer Efficiency Coating Techniques, and Good Work Practices

..... 29

4.2.11. Summary of Cost

- Effectiveness Analysis

................................ ................................ ......................... 30

4.2.12. Comparison w ith Other Aerospace BACT Determinations

................................ ............................... 33

4.2.13. BACT Selection

................................ ................................ ................................ ................................ 38

4.3. BACT for Natural Gas Combustion

................................ ................................ ................................ ........... 39

4.3.1. Available Control Technologies

................................ ................................ ................................ ........ 41

4.3.2. BACT Selection

................................ ................................ ................................ ................................ 41

4.4. BACT for Emergency Generators

................................ ................................ ................................ .............. 42

4.4.1. Available Control Technologies

................................ ................................ ................................ ........ 42

4.4.2. BACT Selection

................................ ................................ ................................ ................................ 42

4.5. BACT for Wing Composite Layup and Curing

................................ ................................ ......................... 42

4.5.1. Available Control Technologies

................................ ................................ ................................ ........ 43

4.5.2. BACT Feasibility Review

................................ ................................ ................................ ................. 44iii 4. 5.3. RTO with Concentrator

................................ ................................ ................................ ..................... 44

4.5.4. Thermal Incineration

................................ ................................ ................................ ......................... 45

4.5.5. Carbon Adsorption

................................ ................................ ................................ ............................ 45

4.5.6. R anking of BACT by Control

................................ ................................ ................................ ........... 45

4.5.7. Cost

- Effectiveness Evaluation

................................ ................................ ................................ ........... 46

4.6. BACT for Crush Core Press

................................ ................................ ................................ ....................... 46

4. 6.1. Available Control Technologies

................................ ................................ ................................ ........ 46

4.6.2. BACT Feasibility Review

................................ ................................ ................................ ................. 47

4.6.3. RTO with Concentrator

................................ ................................ ................................ ..................... 47

4.6. 4. Thermal Incineration

................................ ................................ ................................ ......................... 48

4.6.5. Carbon Adsorption

................................ ................................ ................................ ............................ 48

4.6.6. Ranking of BACT by Control

................................ ................................ ................................ ........... 48

4.6.7. Cost

- Effectiveness Evaluation

................................ ................................ ................................ ........... 49

4.6.8. BACT Selection

................................ ................................ ................................ ................................ 49

4.7. BACT for Open Floor Emissions

................................ ................................ ................................ ............... 49

4.7.1. Wing Component Fabrication

................................ ................................ ................................ ........... 50

4.7.2. Available Control Technologies

................................ ................................ ................................ ........ 50

4.7.3. BACT Feasibility Review

................................ ................................ ................................ ................. 51

4. 7.4. BACT Selection

................................ ................................ ................................ ................................ 51

4.8. Toxic Air Pollutants

................................ ................................ ................................ ................................ ... 52

5. AMBIENT AIR QUALITY IMPACTS ANALYSIS

................................ ................................ ........................ 52

5.1. Regulatory Requirements

................................ ................................ ................................ ........................... 52

5.2. Impacts on Class I Areas

................................ ................................ ................................ ............................ 52

5.3. Ozone Impacts

................................ ................................ ................................ ................................ ............ 54

6. ADDITIONAL IMPACTS ANALYSIS

................................ ................................ ................................ ............ 55

6.1. Air Quality Related Values (AQRV)

................................ ................................ ................................ ......... 55

6.2. Growth Analysis

................................ ................................ ................................ ................................ ........ 56

6.2.1. Const ruction and Growth Impacts

................................ ................................ ................................ ..... 56

6.3. Soils and Vegetation Analysis

................................ ................................ ................................ .................... 56

7. ENDANGERED SPECIES ACT

................................ ................................ ................................ ....................... 57

8. STA TE ENVIRONMENTAL POLICY ACT (SEPA)

................................ ................................ ...................... 57

9. PUBLIC INVOLVEMENT

................................ ................................ ................................ ................................ 57

10. AGENCY CONTACT

................................ ................................ ................................ ................................ .. 58

APPENDIX A. B ACKGROUND PSD APPLICABILITY ANALYSIS FOR THE 777X AND PRODUCTION

RATE INCREASE

................................ ................................ ................................ ................................ ...................... 59

APPENDIX B. ESTIMATE OF NON

- SIGNIFICANT PSD POLLU TANT EMISSIONS INCREASES FROM

THE 777X PROJECT

................................ ................................ ................................ ................................ .................. 84

REFERENCES

................................ ................................ ................................ ................................ ............................ 94

ACRONYMS AND ABBREVIATIONS

................................ ................................ ................................ .................... 95iv LIST OF FIGURES

Figure 1. The Boeing Everett facility location map

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

Figure 2. The Boeing Ev erett facility aerial photograph with new 777X Wing Component Fabrication Building identified

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

LIST OF TABLES

Table 1. Wing Component Fabrication VOC Emissions from New Emission Units

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

Table 2. Wing and Body St ructures Seal/Paint and Vertical Fin Paint VOC Emissions from New and Modified

Emission Units

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

Table 3. Airplane Assembly VOC Emissions from New and Modified Emission Units

................................ ............ 11

Table 4. Comfort and Process Heating VOC Emissions from New 777X Wing Component Fabrication Building

.. 12

Table 5. Emergency Diesel Generators VOC Emissions

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

Table 6. IRC VOC Emissions from New Emission Units

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

Table 7. Proposed PSD VOC Emission Limit Changes

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

Table 8. Estimated VOC Emissions from 777 Assembly Operations for 2005 through 2013

................................ .... 18

Table 9. Projected Actual Emissions of Regulated NSR Pollutants for

................................ ................................ ...... 18

Table 10. Baseline Actual Emi ssions of Regulated NSR Pollutants for Existing 777 Assembly Operations and Related 777 Operations (tpy)

................................ ................................ ................................ ................................ ....... 20

Table 11. Emissions Inc reases of Regulated NSR Pollutants for New Units (tpy)

................................ ..................... 20

Table 12. Emissions Increases of Regulated NSR Pollutants

................................ ................................ ..................... 21

Table 13. Pollutant and PSD SERs

................................ ................................ ................................ ............................. 21

Table 14. New and Modified Booths

................................ ................................ ................................ .......................... 25

Table 15. BACT Review

................................ ................................ ................................ ................................ ............ 27

Table 16. Ranking of Control Technologies

................................ ................................ ................................ ............... 28

Table 17. Vendor Quote Basis Summary

................................ ................................ ................................ ................... 30

Table 18. Summary of Costs for Wing Component Fabrication (WCF)

................................ ................................ .... 31

Table 19. Summary of Costs for Wing and Body Structure Paint (WBSP)

................................ ................................ 31

Table 20. Summary of Costs for Airplane Assembly (AA)

................................ ................................ ........................ 32

Table 21. RBLC Aerospace Coating Entries Since 2000 (Process Type 41.001)

................................ ....................... 34

Table 22. RBLC Aerospace Coating Entries Between 1990 and 2 000

................................ ................................ ....... 35

Table 23. Summary of Aerospace NESHAP VOC Emission Standards Applicable to the New and Modified

Emission Units of the 777X Project

................................ ................................ ................................ ............................ 39

Table 24. Proposed Natural Gas Combustion Units

................................ ................................ ................................ ... 40

Table 25. Potential Control Technologies for VOCs for Composite Layup and Curing

................................ ............ 44

Table 26. Potential Control Technologies for VOCs for Crush Core Press

................................ ................................ 47

Table 27. Summary of Aerospace NESHAP VOC Emission Standards Applicable to the New and Modified Emission Units of the 777X Project

................................ ................................ ................................ ............................ 51

Table 28. Class I Areas within 200 KM of the Boeing Everett Facility

................................ ................................ ..... 53Technical Support Document Page 1 of 96 Boeing Everett 777X Project September 9, 2014

1. EXECUTIVE SUMMARY

Boeing Commercial Airplane’s Everett facility (Boeing Everett) produces wide

- body airplanes

. Boeing Everett currently manufactures the plane models 747, 767, 777, and 787. Boeing proposes to produce new models of the Boeing 777 . These new models are re ferred to as the Boeing 777X models

. Production of the 777X is scheduled to begin in 2017, and make the first 777X delivery in 2020. As production of the 777X ramps up, the production of the current 777

models wil l be phased out.

The 777X will differ from the 777 models in that the 777X wings will be primarily made of composite material rather than aluminum. The 777X will have a greater wing span that will require folding wing tips so the 777X will fit at the ai rport ’ s gate s

. The 777

- 9X will have a slightly longer fuselage than the longest 777 model currently in production.

The components for the 777X wing will be made at Boeing Everett in a new building

. Final assembly of the 777X will occur in the same buil ding where the current models of the 777 are assembled.

The 777X project involves two phases. The first phase is a transition from production of the traditional 777 models to 777X models. The second phase will be an increase in the maximum production c apacity and thereafter, production rate from the current rate of about 8.3 777X per month (or about 100 planes per year) to as many as 10.4 777Xs per month (about 125 777Xs per year).

Phase 1 of the project consists of two components

. The first componen t will make the changes to the facility necessary to begin production of the 777X

. This will occur while maintaining production of legacy 777 models at levels up to about 8.3 airplanes per month, which is consistent with the Prevention of Significant Dete rioration (PSD) permit number 11

- 01

. The changes include constructing a new building in which to manufacture the components for the new composite wing, but also creating additional wing and airplane assembly capacity for the 777X within the existing build ings.

The second component of Phase 1 will be an increase in 777X production capacity and rate to about 8.3 airplanes per month while correspondingly decreasing production of the 777 s to the point of eventually transitioning to producing only the 777X

. During Phase 1 , Boeing does not plan to exceed a combined production rate (i.e., rate for legacy 777s plus 777Xs) of about 8.3 airplanes per month

. Phase 1 will include the following changes at Boeing Everett to achieve a production capacity of 8.3 777Xs per month:

• Construct a new building to fabricate 777X wing components

. The new building will include new emission units such as autoclaves to cure the wing components and spray and sealing booths.

• Install a new 777X wing spar build

- up line in an existing factory building.Technical Support Document Page 2 of 96 Boeing Everett 777X Project September 9, 2014

• Install a new 777X wing assembly line in an existing factory building.

• Install a new 777X final assembly line in an existing factory building.

• Reconfigure the existing 777 final assembly line to accommodate final assembly of the

777X.

• Constructing new 777X vertical fin spray booths and pre p booths in an existing factory building.

• Change existing tooling and equipment throughout the 777 factory to accommodate the larger 777X body sections and wings.

Phase 2 is a second independent phase of the Boeing 777X project

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

. Phase 2 is tentatively scheduled to begin in 2021, and wi ll 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 additional spray booths and a composite press might be installed in the interiors manufacturing building.

Currently

, it is anticipated that construction of Phase 1 will begin on or before November 1, 2014, and construction of Phase 2 will begin on or before December 1, 2021.

The Wa shington State Department of Ecology (Ecology) received the PSD application and fee for the project on February 20, 2014. Ecology determined the application to be complete on March 20, 2014

. Boeing submitted a revised PSD permit application on May 23, 20 14, and that application was determined to be complete on June 23 , 2014.

The proposed project emissions for volatile organic compounds ( VOCs ) are above the PSD

threshold

. Therefore, a full technical review of the project for VOCs, including a Best Avail able 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 this Technical Support Document (TSD).

The emissions of othe r air pollutants not subjected to PSD review will be covered in the Puget Sound Clean Air Agency’s (PSCAA) Notice of Construction (N OC ) approval for this project.

Ecology has issued several PSD permits to Boeing Everett in past years that established VO C emission limits for 777 production

. These permits are:

• Permit number PSD

- 91

- 06 established a VOC emission limit of 238.8 tons per year ( tpy ) for all 777 assembly operations.

• Permit number PSD

- 05

- 02 established a VOC emission limit of 205 tpy for interiors manufacturing operations associated with all Boeing airplane models and a VOCTechnical Support Document Page 3 of 96 Boeing Everett 777X Project September 9, 2014

e mission limit of 412 tpy for paint hangar final exterior coating operations for all Boeing airplane models.

• Permit number PSD

- 11

- 01 established a VOC emission li mit of 34 tpy for three existing 777 wing spray booths in Building 40

- 37.

Of the existing VOC emission limits noted above, the 777X project will require an increase in all but the paint hangar final exterior coating limit.

2. INTRODUCTION

2.1. The Permitting Process

2.1.1. The PSD Process

PSD permitting requirements in Washington State are established in Title 40, Code of Federal Regulations (CFR) § 52.21; Washington Administrative Code (WAC) 173

- 400

- 700 through 750; and the agreement for the delegation of the fede ral PSD regulations by the United States Environmental Protection Agency (EPA) to Ecology, dated December 10, 2013.

Federal and state rules require PSD review of all new or modified air pollution sources that meet

certain criteria in an attainment or un classifiable area with the NAAQS. The objective of the PSD program is to prevent significant adverse environmental impact from emissions into the atmosphere by a proposed new major source

, or major modification to an existing major source. The program li mits degradation of air quality to that which is not considered “ significant.” PSD rules require the utilization of BACT for certain new or modified emission units, which is the most effective air pollution control equipment and procedures that are determ ined to be available after considering environmental, economic, and energy factors.

The PSD rules must be addressed when a company is adding a new emission unit or modifying an existing emission unit in attainment or unclassifiable area. PSD rules apply to pollutants for which the area is classified as attainment or unclassifiable with the NAAQS. PSD rules are designed to keep an area with "good" air in compliance with the NAAQS. The distinctive requirements of PSD are BACT, air quality analysis (allowa ble increments and comparison with the NAAQS), and analysis of impacts of the project on visibility, vegetation, and soils.

2.1.2. The N OC Process

Boeing Everett’s 777X project is subject to NOC permitting requirements under state of Washington regulations Chap ters 173

- 400 and 173

- 460

. PSCAA is the permitting authority for all air emission regulatory requirements not included in PSD permitting

. This includes the New Source Review (NSR) permitting of criteria pollutants that are not PSD

- applicable , air toxics

i ssues under federal maximum achievable control technology ( MACT ) and state 173

- 460 WAC

, and Title V permitting requirements

. The procedure for issuing a n NOC permit was established in Chapter 70.94 RCW.Technical Support Document Page 4 of 96 Boeing Everett 777X Project September 9, 2014

WAC 173

- 400

- 110 outlines the NSR procedures for permitting criteria pollutants. These procedures are further refined in WAC 173

- 400

- 113 (requirements for new sources located in attainment or unclassifiable areas).

WAC 173

- 460

- 040 NSR supplements the require ments contained in Chapter 173

- 400 WAC by adding additional requirements for sources of toxic air pollutants (TAPs).

2.2. Site and Project Description

2.2.1. Site Description

The Boeing Everett facility is located in the City of Everett in Snohomish County , Washington (see F igure 1 )

. Boeing Everett is situated in the south half of Section 10 and the north half of Section 15, Township 28N, Range 4E Willamette Meridian, and consists of the North and South Complexes located north and south, respectively, of S tate Route 526

. A building number starting with 40 identifies North Complex buildings, and buildings on the South Complex are identified with a number starting with 45 (see F igure 2). The proposed project will not increase the current footprint acreage o f the site.

The Boeing Everett facility is located in a Class II area that is designated as “attainment or unclassifiable” for the purpose of PSD permitting for all pollutants.

Figure 1 . The Boeing Everett facility location m ap

(Source : Boeing application 2 nd revision, received May 23, 2014)Technical Support Document Page 5 of 96 Boeing Everett 777X Project September 9, 2014

Figure 2 . The Boeing Everett facility aerial photograph with new 777X Wing Component Fabrication Building identified

(Source: Boeing’s application 2 nd revision, received May 23, 2014)

2.2.2. Project Description

The Boeing Company owns and operates the Boeing Everett facility. The existing Boeing Everett facility consists of:

• 777 Assembly Operations: Model 777 assembly operations currently occur primarily in Buildings 40

- 04, 40

- 25, 40

- 34, 40

- 35, 40

- 36, 40

- 37, and 40

- 53.

The primary 777 assembly operations are:

• Wing component fabrication

• Wing assembly

• Body (fuselage) section assembly

• Wing and body structures seal and paint

• Airplane assemblyTechnical Support Document Page 6 of 96 Boeing Everett 777X Project September 9, 2014

The 777X proj ect will add a new building to fabricate composite wing components for the new 777X wing. The project will also add new operations such as a new vertical fin coating operation. The vertical fin on the current 777 models is painted in the existing airplan e paint hangars after the fin is installed on the airplane. The new vertical fin coating operation requires that the fin be coated in a dedicated spray booth before it is installed on the airplane. In addition, some existing equipment such as body sectio n spray booths may have to be modified to accommodate the larger 777X body sections.

2.2.2.1. Wing Component Fabrication

The wings of the 777X will be primarily made of composite material

. The main wing components that will be made of composite material include upper and lower panels, front and rear spars, and upper and lower panel stringers

. The manufacturing process of each of these parts is similar and involves the following steps:

• Wing component layup

• Curing in an autoclave

• Trimming and drilling

• Washing

• No n

- destructive inspection

• Preparation for priming (e.g., abrading, solvent cleaning)

• Priming

• Wing component build

- up

Composite material is in the form of resin pre

- impregnated tape or sheets

. Part layup involves the manual or automated layup of composite material onto a mandrel (i.e., mold) which is preformed into the shape of the part being fabricated

. E missions associated with the part layup primarily occur from preparing the mandrel between each layup/cure cycle

. Preparing the

mandrel includes cleanin g the surface with solvent, applying a mold release compound, and applying a tackifier solution.

Once the part is laid up on the mandrel, a vacuum bag is sealed around the part and the assembly is then sent to an autoclave for curing

. In the autoclave, vacuum from a vacuum pump is used to hold the bagged part under negative pressure while the autoclave is pressurized with nitrogen and heated to the curing temperature of up to about 350 degrees Fahrenheit ( ° F )

. The part is then held under negative pressu re for the entire curing cycle, which is about 12 to 14 hours.

Emissions during the curing cycle are gases from the composite material and combustion emissions from the indirect gas

- fired heater that is used to heat the autoclave. The gases travel

throu gh the vacuum system and are exhausted by the vacuum pump. Boeing is planning for as many as three autoclaves, each equipped with a gas

- fired heater with a rated heat input of approximately 40 million British thermal units per hour (MMBtu/hr). The curing cycle will begin with the autoclave initially being brought up to the curing temperature with the naturalTechnical Support Document Page 7 of 96 Boeing Everett 777X Project September 9, 2014

gas

- fired heater for about one to two hours. After this initial heating stage, an electric heater will be used to maintain the curing temperature fo r the rest of the cure cycle.

Once the part is cured, it is taken out of the autoclave, removed from the bag, and undergoes various machining operation such as trimming and drilling. After machining is complete, the part is placed in a wash stall and w ashed using an aqueous solution and water rinse. After washing, the parts are inspected for defects. Following inspection, the parts are placed in a prep booth where the part surface is abraded and cleaned with solvent prior to being moved to either

be c leaned within the spray booth or at specially designed equipment cleaning booths. After priming, the part might be moved to a heated cure booth to allow the primer to cure. VOC emissions will result from the solvent cleaning, spray coating, and curing of the parts as well as form cleaning of spray equipment. The trimming, drilling, abrading, and spray coating operations result in particulate emissions and will be controlled using a dust collection system and spray booth exhaust filters.

Once priming is completed, “build

- up” work will be performed on the parts. For example, the spars will have stiffeners, bracket, and other components attached, including a portion of the leading and trailing edges. The wing panels will similarly undergo some build

- up w ork. This type of work consists of open floor mechanical assembly processes (e.g., vacuum pumps, prep booths, and spray booths) and will involve the application of VOC containing products such as

hand wipe cleaning solvents, sealants, and touch

- coatings. At this time, it is planned that all the wing component fabrication work will take place in a new building with the exception of some wing spar build

- up work, and possibly wing panel build

- up work that will occur in an existing building, and the emission units (e.g., vacuum pumps, prep booths, and spray booths) associated

with the fabrication work will be new. The new emission units and activities and related VOC emissions for wing component fabrication are shown in Table 1. Table 1 also lists open floor activities that will take place as part of wing component fabrication. Boeing believes that such activities should not be treated as new emission units since similar open floor activities occur throughout the Boeing Everett facility, and can be easily mo ved about.

Table 1

. Wing Component Fabrication VOC Emissions from New Emission Units

Unit ID Emission Unit or Activity New or
Modified Combustion

Emissions (lb/plane) Open
Floor
Emissions (lb/plane) Stack Non

Combustion

Emissions (lb/plane)

WCF

- 1 Open floor activities which include prep of layup

mandrels (e.g., hand wipe cleaning and application
of mold release and tackifier) and wing panel and wing spar build

- up (e.g.

, hand wipe cleaning and sealant application) New 0.00 1,895 0

WCF

- 2 Gas

- fired heater for liquid nitrogen vaporization unit New 1.45 0 0

WCF

- 3 Gas

- fired process heater for autoclave #1 New 1.45 0 0

WCF

- 3b Gas

- fired process heater for autoclave #2 New 1.45 0 0

WCF

- 3c Gas

- fired process heater for autoclave #3 New 0.00 0 0

WCF

- 4 Vacuum pump(s) servicing autoclaves New 0.00 0 114Technical Support Document Page 8 of 96 Boeing Everett 777X Project September 9, 2014

Table 1

. Wing Component Fabrication VOC Emissions from New Emission Units

Unit ID Emission Unit or Activity New or
Modified Combustion
Emissions (lb/plane) Open

Floor
Emissions (lb/plane) Stack Non

Combustion
Emissions (lb/plane)

WCF

- 5 Dust collector(s) used to collect particulates from trimming, drilling, and other machining operations on cured components New 0.00 0 0

WCF

- 6a Wing panel wash stall #1 New 0.12 0 0

WCF

- 6b Wing panel wash stall #2 New 0.12 0 0

WCF

- 6c Wing spar and stringer wash stall #1 New 0.03 0 0

WCF

- 6d Wing spar and stringer wash stall #2 New 0.03 0 0

WCF

- 7 Gas

- fired plasma unit for treatment of wing panel stringers New 0.17 0 0

WCF

- 8a Wing panel prep booth(s) (abrasive blast/sanding,

solvent hand wipe, edge seal) (see Note 1) New 0.46 0 504

WCF

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

solvent hand wipe, edge seal ) New 0.00 0 70

WCF

- 9a Wing panel spray booth #1 Ne w 1.39 0 273

WCF

- 9b Wing panel spray booth #2 New 1.39 0 273

WCF

- 9d Wing panel spray booth #3 New 1.39 0 273

WCF

- 9c Wing spar spray booth New 0.33 0 118

WCF

- 10a Wing panel primer curing booth #1 New 0.70 0 See Note 2

WCF

- 10b Wing panel primer curing booth #2 New 0.70 0 See Note 2

WCF

- 10c Wing spar primer curing booth Ne w 0.17 0 See Note 2

WCF

- 11 Small quantity paint mix booth New 0.00 0 Less than 1

WCF

- 12a Coating equipment cleaning booth #1 New 0.00 0 16

WCF

- 12b Coating equipment cleaning booth #2 New 0.00 0 16

WCF

- 14 Wing spar seal booth(s) #1 ( s ee Note 3 ) New 0.18 0 152

Notes:

1. Currently Boeing is considering building one or two wing panel prep booths

. If Boeing decides to build two wing panel prep booths, the 504 pounds of VOC emission s will be divided between the two booths.

2. Curing emissions are minimal and included in the spray booth emissions.

3. Currently Boeing is considering building as many as four wing spar seal booths

. If Boeing decides to build more than one wing spar seal booth, the 152 pounds of VOC emission s per plane will be divided between the multiple booths.

All the emission units shown in Table 1 will be installed in Phase 1 of the project. Additional tooling and equipment such as tape

- laying machines and additional work positions might be

installed in Phase 2 , but no addition emission units associated with wing component fabrication are planned for Phase 2

.Technical Support Document Page 9 of 96 Boeing Everett 777X Project September 9, 2014

2.2.2.2. Wing Assembl y

After the wing panel and wing spar build

- up work is complete, the 777X wings will be assembled from the completed panels, spars, and ribs which will have been manufactured elsewhere. This assembly work primarily consists of open floor mechanical assemb ly processes and will involve the application of V OC

- containing products such as hand wipes with cleaning solvents, sealants, and touch

- up coatings.

Boeing plans to locate the 777X wing assembly line in the main factory building with the existing 777 win g assembly line, but at a new location within that building

. Neither Phase 1 nor
P hase 2 require the installation or establishment of any new emission units or modification of any existing emission units associated with wing assembly.

2.2.2.3. Body Section Assemb ly

Body section assembly involves the assembly of individual body section panels into forward, aft,

and mid body sections

. This work consists of open floor mechanical assembly processes and the application of VOC products such as hand wipe cleaning solvents, sealants, and touch

- up coatings.

Boeing plans to locate the 777X body section assembly work in the main factory building with the existing 777 body section assembly work, but a l l 777 body section assembly work will

transition to a new location within that building

. Neither Phase 1 nor Phase 2 will require the installation or establishment of any new VOC emission units or modification of any existing emission units associated with body section assembly.

2.2.2.4. Wind and Body Structures Seal/Pa int and Vertical Fin Paint

Once the 777X wings and individual body sections are assembled, they will be moved to the existing 777 wing and body section spray booths in Building 40

- 37 for cleaning, sealing, and coating

. The 777X wings will be cleaned, pri med, and top coated in the same booths where the existing 777 model wings are cleaned, primed, and top coated. Similarly, 777X body sections will have their interior structures and a small portion of their exterior structures (e.g., the area

under the win g fairing) cleaned, sealed, primed, and sprayed with a corrosion

- inhibiting compound (CIC) in the same booths that the existing 777 model body structures use.

In Phase 1 of the project, some of the existing 777 body section booths may be lengthened to

acc ommodate the slightly longer forward and aft fuselage sections of the 777

- 9X.

Also

, as part of Phase 1 , Boeing will add a new prep bo o th and three new spray booths to coat

the 777X vertical fins

. As noted above, the 777 vertical fin painting is currently completed in the existing Boeing Everett airplane paint hangars after the fin is installed on the airplane

. The new coating operation will result in less aerodynamic drag and requires that the fin be coated in a

dedicated spray booth before it i s installed on the airplane.Technical Support Document Page 10 of 96 Boeing Everett 777X Project September 9, 2014

In Phase 2 of the 777X project, two additional robotic cleaning and coating machines might be added to the existing wing booths to achieve a production capacity of up to 10.4 airplanes per

month.

The new or modified emission units and related VOC emissions for the wing and body structures seal/paint and vertical fin paint are listed in Table 2.

Table 2

. Wing and Body Structures Seal/Paint and Vertical Fin Paint VOC Emissions from New

and Modified Emi ssion Units

Unit ID Emission Unit or Activity New or
Modified Combustion

Emissions (lb/plane) Open
Floor
Emissions (lb/plane) Stack Non

Combustion

Emissions (lb/plane)

WBSP

- 1a Robotic wing spray booth for LH wing Modified 0.00 0 472

WBSP

- 1b Robotic wing spray booth for RH wing Modified 0.00 0 472

WBSP

- 2 Forward body section spray booth Modified 0.00 0 209

WBSP

- 3 Mid body section spray booth Modified 0.00 0 217

WBSP

- 4 Aft body section spray booth Modified 0.00 0 209

WBSP

- 6 Forward body section CIC spray booth Modified 0.00 0 194

WBSP

- 7 Mid body section CIC spray booth Modified 0.00 0 98

WBSP

- 8 Aft body section CIC spray booth Modified 0.00 0 194

WBSP

- 10 Vertical fin HLFC prep booth New 0.39 0 20

WBSP

- 11a Vertical fin HLFC spray booth #1 New 1.14 0 70

WBSP

- 11b Vertical fin HLFC spray booth #2 New 1.14 0 70

WBSP

- 11c Vertical fin HLFC spray booth #3 New 1.14 0 70

WBSP = wing and body structure paint

LH = left hand

RH = right hand

HLFC = hybrid laminar flow control

2.2.2.5. Airplane Assembly

Airplane assembly operations include the installation of various airplane systems (e.g., hydraulic, fuel, electrical) in the wing and body sections; the installation of the empennage (i.e., vertical fin and horizontal stabilizers) onto the aft bo dy section; assembly of the body sections and wings into a completed structure; integration of the airplane systems; installation of landing gear, engines, and interior components (e.g., seats, sidewalls, partitions); and functional testing

. Most

of these activities occur on the open floor and involve the application of VOC c ontaining products such as hand wipe cleaning solvents, sealants, and touch

- up coatings.

As discussed earlier, a new 777X airplane assembly line will be located in the main factory

b uilding as is the existing 777 airplane assembly line, but at a new location within that building

.Technical Support Document Page 11 of 96 Boeing Everett 777X Project September 9, 2014

This new assembly line might only be used for the low

- rate initial production of the airplane

. After a period of time, this new li n e might be phased out an d all 777X final assembly moved to the existing 777 final assembly line reconfigured for the 777X.

The only new or modified emission units associated with 777X airplane assembly that will be installed as part of Phase 1 of the project are two wing stub ve ntilated spray coating enclosures

. These enclosures will be used to capture emissions from coating certain portions of the wing stub and wing stub join areas

. The enclosures will be filtered as required by the Aerospace National

Emission Standards for Ha zardous Air Pollutants ( A NESHAP)

. One new enclosure will be installed in the new 777X airplane assembly line, and the existing wing stub spray booth that is part of the existing 777 assembly line will be modified or replace d

.

Other than these two ventila tion systems, neither Phase 1 nor Phase 2 should require the installation or establishment of any new emission units or the modification of any existing emission units associated with airplane assembly

. VOC emissions from the wing stub ventilated

spray co ating enclosures are shown in Table 3.

Table 3

. Airplane Assembly VOC Emissions from New and Modified Emission Units

Unit ID Emission Unit or Activity New or
Modified Combustion

Emissions (lb/plane) Open
Floor
Emissions (lb/plane) Stack Non

Combustion

Emissions (lb/plane)

AA

- 2a Wing stub spray coating enclosure #1 New 0.00 0 22

AA

- 2b Wing stub spray coating enclosure #2 Modified 0.00 0 22

2.2.2.6. 777 Assembly Existing PSD VOC Emission Limits

PSD permit PSD

- 91

- 06 established a VOC emission limit of 238.8 tpy for all 777 assembly operations

. The 777X project will require that this emission limit be increased to 513 tpy to account for new wing component fabrication emissions, the higher producti on rate anticipated in

Phase 2 of the 777X project, and the new vertical fin prep and spray booths.

PSD permit PSD

- 11

- 01 established a VOC emission limit of 34 tpy for the robotic wing spray booths and a per wing average emission limit of 0.17 ton . The 7 77X project will require that these emission limits be increased to 59 tpy and 0.25 ton per wing to account for the higher production rate anticipated in Phase 2 of the 777X project, the larger size of the composite wing,

and the different materials used t o clean and coat the composite wing.

2.2.2.7. Airplane Manufacturing Support Operations Facilities

In addition to the new heating equipment associated with specific production emissions units

listed in Table 1

- 1 and 1

- 2 [A1] , there will be additional open space he ating and general processTechnical Support Document Page 12 of 96 Boeing Everett 777X Project September 9, 2014

heating requirements in the new wing component fabrication building that total approximately 111 MMBtu/hr. Table 4 lists the expected emissions from these heating processes.

Table 4

. Comfort and Process H eating VOC Emissions from New 777X Wing Component Fabrication Building

Unit ID Emission Unit or Activity New or
Modified Combustion

Emissions (lb/plane) Open
Floor
Emissions (lb/plane) Stack Non

Combustion

Emissions (lb/plane)

F

- 1 Combustion equipment for comfort or process heating New 16.88 0 0

The 777X project is expected to require as many as nine new 2,750

- kilowatt (kW) backup emergency diesel generators for the autoclaves and one 750

- kW backup diesel generator for other wing manufacturing activities

. Table 5 lists the expected VOC emissions from these engines.

Table 5

. Emergency Diesel Generators VOC Emissions

Unit ID Emission Unit or Activity New or
Modified Combustion

Emissions ( tpy )

F

- 2a Nine 2,750

- kW diesel generators New 0.94

F

- 2b 750

- kW diesel generator New 0.03

2.2.2.8. Airplane Manufacturing Support Operations

— Interiors Production Operations

Interior s production operations primarily occur in the Interiors Responsibility Center’s (IRC’s) Building 40

- 56 and support all airplane models produced at Boeing Everett, as well as the 737 model produced at Boeing Renton

. Interiors production involves the manufa cture of stowbins, sidewalls, ceilings, partitions, closets, and other cabin interior components

. Air emissions occur from activities such as spray coating, hand wipe cleaning, screen printing, composite material curing, and the use of adhesives, resins, and other VOC containing products.

No changes to the IRC emission units are planned for Phase 1 of the 777X project

. For P hase 2 of the project, it is anticipated that three adhesive spray booths, a paint booth, and a crushed core press will need to be added to the IRC to reach the 777X interiors production rate capacity of up

to 1 0.4 shipsets per month

. Table 6 lists these new emission units and their estimated VOC

emissions.Technical Support Document Page 13 of 96 Boeing Everett 777X Project September 9, 2014

Table 6

. IRC VOC Emissions from New Emission Units

Unit ID Emission Unit or Activity New or
Modified Combustion
Emissions (lb/plane) Open

Floor
Emissions (lb/plane) Stack Non

Combustion
Emissions

(lb/ year )

IRC

- 1a Adhesive spray booth #1 New 0 0 17,700

IRC

- 1b Adhesive spray booth #2 New 0 0 17,700

IRC

- 1c Adhesive spray booth #3 New 0 0 17,700

IRC

- 2 Paint spray booth New 0 0 10,000

IRC

- 3 Crushed core press New 0 0 4,500

PSD permit PSD

- 05

- 02 established a VOC emission limit of 205 tpy for all interiors production operations at Boeing Everett

. This limit covers emissions from 777 interiors production as well as interiors production for other Boeing airplane models

. The 777X project will require that this

emission limit be increased to 239 tpy to account for the additional emissions from the new emission units anticipated to achieve the higher production rate of up to 10.4 shipsets per month.

The estimated VOC emissions from interiors production for each 777X are 0.53 ton per airplane

.

2.2.2.9. Everett Delivery Center Operations

Everett Delivery Center (EDC) paint hangar and preflight/delivery operations occur in Buildings

45

- 01, 45

- 03, and 45

- 04 paint hangars; in Building 45

- 02; in Building 45

- 334 at the Everett Modification Center (EMC) plus the paint hangar in Bay 4 Building 45

- 334, and on the flight

line ; and support all airplane models produced at Boeing Everett

. Air emissions primarily occur from activities such as exterior prep and spray coating activities in the paint hangars, and the use

of hand wipe cleaning solvents and adhesives, resins, and other VOC containing products on the flight line. PSD permit PSD

- 05

- 02 establishes a VOC emission limit of 412 tpy for all airplane manufacturing operations that occur at the EDC, inc luding 777 paint hangar and pre flight and

delive ry operations

. The project will not require any increase in this VOC emission limit.

Boeing Everett paint hangars, which are all part of EDC, are operating at or near capacity

. The current paint hangar capacity is less than that necessary to serve the c ombined production of all airplane models at Boeing Everett today, requiring many airplanes to be flown offsite for final decorative coating

. There are currently no plans to increase onsite paint hangar capacity to support the increased 777X production ra te enabled by P hase 2 of the project

. Therefore, the project will not result in an emission increase at the paint hangars

. However, other EDC work such as coating and cleaning of 777 rudders and elevator and the preflight/delivery work that

occurs on eac h airplane on the flight line before it is delivered, will increase as a result of the project

. The estimated emissions from these activities are 0.15 ton of VOCs per 777X produced.Technical Support Document Page 14 of 96 Boeing Everett 777X Project September 9, 2014

Neither P hase 1 nor P hase 2 will require the installation or establishme nt of any new emission units or the modification of any existing emission units associated with the EDC operations.

2.2.2.10. Propulsion Systems Operations

Propulsion s ystems operations primarily occur in Building 40

- 54 and involve receiving airplane engines and e ngine struts for 747, 767, and 777 models from offsite and preparing them for installation on the airplane

. Air emissions are relatively minor and primarily occur from the open floor use of hand wipe cleaning solvents, touch

- up coatings, and adhesives, re sins, and other VOC containing products

. The VOC emissions from this operation are not subject to a

PSD or PSCAA established VOC annual emission limit

. The estimated emissions from

p ropulsion s ystems are 0.005 ton of VOCs per engine

. The 777X has two en gines, and the estimated emissions are 0.01 of VOCs per 777X produced.

Neither P hase 1 nor P hase 2 should require the installation or establishment of any new emission units or the modification of any existing emission units associated with propulsion sy stems operations.

2.2.2.11. Emergent Operations

Emergent operations involve the emergent, non

- routine fabrication and repair of aerospace

components

. Emergent operation s support all airplane models produced at Boeing Everett

. Air emissions from emergent operations are relatively minor and primarily occur from spray coating

and the use of hand wipe cleaning solvents and adhesives, resins, and other VOC containing products

. The V OC emissions from this operation are not subject to a PSD VOC emission limit

. The estimated emissions from these activities are 0.06 ton of V OC per 777X produced.

Neither Phase 1 nor Phase 2 should require the installation or establishment of any new emission units or the modification of any existing emission units associated wit h emergent operations.

2.2.2.12. Electrical Systems Production Operations

Electrical s ystems production operations occur in the space that the Electrical Systems Responsibility Center (ESRC) shares with the IRC in Building 40

- 56, and in Building 40

- 02, and primari ly support the 747, 767, and 777 airplane models produced at Boeing Everett, as well as the 737 model produced at Boeing Renton

. Electrical s ystems production operations involve the assembly of wiring harnesses, power panels, and other electrical componen ts

. Air emissions are relatively insignificant and occur from the use of hand wipe cleaning solvents and adhesives, resins, and other VOC containing products

. The VOC emissions from this operation are not subject to a PSD VOC emission limit

. The estimat ed emissions from these activities are 0.013 ton of VOC per 777X produced.Technical Support Document Page 15 of 96 Boeing Everett 777X Project September 9, 2014

Neither P hase 1 nor P hase 2 should require the installation or establishment of any new emission units or the modification of any existing emission units associated with electrical systems production operations.

2.2.2.13. Summary of Proposed PSD Permit Changes

Boeing propos ed to limit annual natural gas usage from new combustion units related to the 777X project to 1,000,000 MMBtu/yr. Ecology will include this annual limit of natural gas usage as a permit limit.

Table 7 lists the proposed changes to the VOC emission limits in the current PSD permits

.

Table 7

. Proposed PSD VOC Emission Limit Changes

PSD
Permit Emission Unit or Activity Current

Limit Proposed
Limit Increase (tpy)

91

- 06 777 Assembly 238.8 tpy 513 tpy 274.2

05

- 02 Interiors 205 tpy 239 tpy 34

11

- 01 Wing Painting 34 tpy 59 tpy Note 1

11

- 01 Wing Painting 0.17 tons / wing 0.24 tons / wing Note 1

11

- 01 Wing Painting 36.3 tpy 61.3 tpy Note 1

Total Proposed Increase 308.2
Note 1: These emissions are included in 777 assembly current and proposed

emission limits.

3. PSD APPLICABILITY REVIEW

3.1. Overview and Permitting History

The existing facility is a major PSD stationary source per 40 CFR 52.21(b)(1)(i)

. Under WAC

173

- 400

- 720 through 750, a project proposed at an existing major stationary source is subject to PSD review if the project either is a “major modification” to an existing “maj or stationary source,” or is a major stationary source unto itself.

Unless otherwise exempted by applicable regulation, a change to an existing major stationary source is a major modification if the change results in both a significant emissions increas e and a significant net emissions increase at the source. “Significant emissions increase” means that the emissions increase for any regulated PSD pollutant is greater than the PSD s ignificant e mission

r ate (SER) threshold for that regulated pollutant.

The proposed 777X project will require a PSD permit if both the project’s emissions increase and the net contemporaneous emissions increase caused by the project exceed any PSD SERs of any NSR pollutant, including greenhouse gases ( GHGs ) . The proposed new building andTechnical Support Document Page 16 of 96 Boeing Everett 777X Project September 9, 2014

modifications to the existing buildings at Boeing Everett require a PSD review. In accordance with the requirements of 40 CFR 52.21(a)(2), these emission increases associated with the new units is based on their potential to emit (PTE). Also, as addressed in the regulation, their

baseline actual emissions are zero.

The significant emissions increase analysis looks only at the emissions from the proposed project and is called Step 1

. The significant net emissions increas e analysis looks at additional increases and decreases from “contemporaneous” projects at the source and is called Step 2.

For the significant emissions increase analysis, the 777X project will involve both constructing new emissions units and modifying existing units. The PSD regulations require use of the hybrid test for projects that involve both the addition of new emissions units and the modification of existing emissions units. The PSD regulations require use of the hybrid test for projects that

i nvolve both the addition of new emissions units and the modification of existing emissions units (40 CFR 52.21(a)(2)(iv)(f)). Under the hybrid test, a significant emissions increase of a regulated NSR pollutant is projected to occur if the sum of the emis sions increases for each emissions unit, using the actual

- to

- projected

- actual applicability test (40 CFR 52.21(a)(2)(iv)(c)

for modified units and the actual

- to

- potential applicability test (40 CFR 52.21(a)(2)(iv)(d)) for new units, equals or exceeds the s ignificance threshold for that pollutant as defined in paragraph 40 CFR 52.21(b)(23). The actual

- to

- projected

- actual applicability test involves adding the projected actual emissions from existing emissions units that are modified as part of the project

o r that are otherwise expected to experience an emission increase as a result of the project, and then subtracting the past actual emissions (called the “baseline actual emissions”) from those

units.

However

, in lieu of projecting future actual emissions for a particular existing emissions unit, an applicant can choose instead to use the unit’s PTE as the unit’s post project emissions (40 CFR 52.21(b)(41)(ii)(d))

. The actual

- to

- potential test, which is required for all new units being constructed as part of the project, involves totaling the potential emissions of the proposed new emissions units, then subtracting past actual emissions o f those units

. A new unit that is being constructed as part of the project has a baseline of zero (40 CFR 52.21(b)(48)(i ii)).

If the project would result in a significant emissions increase, then a significant net emissions increase analysis is often conducted

. However, EPA has clearly stated that calculating a net emissions increase is at the source’s option (see, for e xample, 67, Federal Register 80186, at 80197 [December 31, 2002])

. Therefore, a source may seek a PSD permit based on a calculated significant emission increase alone

. For the 777X project, Boeing requested that option, and is

for e going the Step 2 signif icant net emission increase analysis.

Essentially

, this means that the 777X project will trigger PSD review because the Boeing Everett facility currently has the PTE more than 250 tpy of VOC which is a regulated NSR pollutant. Therefore, Boeing Ever ett is considered a “major stationary source” for PSD purposes, as defined by 40 CFR 52.21(b)(1)(i).Technical Support Document Page 17 of 96 Boeing Everett 777X Project September 9, 2014

As a result of the possible increased 777X production rate enabled by P hase 2 of the project, emissions from the existing 777 assembly operations are expe cted to increase as well as emissions from other operations where Boeing Everett produces or processes 777 components (including interiors production, some EDC operations, and p ropulsion s ystems operations). Further, the amount of steam and heat produced at the Boeing Everett facility will increase to support the increased production.

3.2. Emissions Calculation

3.2.1. Significant Emissions Increases

The 777X project will involve both modifying existing emission units and constructing new emission units. There a hy brid test is required under 40 CFR 52.21(a)(2)(iv)(f). The hybrid test involves using the actual

- to

- projected

- actual applicability test (40 CFR 52.21(a)(2)(iv)(c)) for modified and debottlenecked units, and the actual

- to

- potential applicability test (40 C FR 52.21(a)(2)(iv)(d)) for new units to be constructed as part of the project. In addition, EPA’s aggregation policy is to deter sources from attempting to expedite construction by permitting several changes separately as minor modifications. In the case of a new project that is undergoing PSD permitting, the aggregation analysis is used to determine all of the pollutants and emission units that are subject to PSD review. In the situation of the 777X project, all projects involving the future production of 777X models has been included in the 777X project.

3.2.1.1. Actual

- to

- Projected

- Actual Applicability Test for Modified and

Debottlenecked Emission s Units

De bottlenecking is the term used for situations when emission units upstream or downstream

from the unit(s) undergoing a physical change or change in the method of operation will experience an emission increase a result of the project. Emissions increases from debottlenecked units are calculated using an actual

- to

- projected

- actual applicability test.

For existing emission units that are being modified or debottlenecked as part of the 777X project, the PSD baseline emissions are emissions averaged over any 24 consecutive month period in the 10 years before Ecology receives a complete application for the project

. For a regulated NSR pollutant, when a project involves more than one emission unit, only one 24 consecutive month period may be used to determine the baseline actual emissions for all emission units being changed

. However, a different 24 consec utive month period can be used for each regulated NSR pollutant (40 CFR 52.21(b)(48)(ii)(d))

. For the 777X project, the 10

- year period from which the baseline period may be selected for all NSR regulated pollutants begins in 2004 and includes the

full cal endar years 2005 through 2013

. For “new” units constructed prior to the 777X project (i.e., units that have been in operation for less than two years), baseline actual emissions are the

units’ PTE (40 CFR 52.21(b)(48)(iii)).Technical Support Document Page 18 of 96 Boeing Everett 777X Project September 9, 2014

Table 8 presents the VOC emi ssions from 777 assembly operations and the number of 777s produced for the nine years 2005 through 2013

. B oe ing selected 2012 and 2013 calendar years as the baseline period for VOC emissions.

Table 8

. Estimated VOC Emissions fro m 777 Assembly Operations for 2005 through 2013

Year # of 777s

Produced Estimated VOC

Emissions Before Subtracting Estimated
VOCs

in Waste

(tons) Estimated VOC
Emissions A fter Subtracting Waste (tons) Estimated VOC Emissions per Airplane

(tons)

2005 44 107.8 4.2 103.6 2.35

2006 62 117.9 5.9 112.0 1.81

2007 83 179.3 8.7 170.6 2.05

2008 68 152.7 8.2 144.5 2.13

2009 83 164.5 10.1 154.4 1.86

2010 71 133.3 8.0 125.3 1.77

2011 75 146.8 8.6 138.2 1.84

2012 83 167.7 11.2 156.5 1.89

2013 99 181.1 17.1 164 1.66

Note: A 2

- month work stoppage occurred in 2008.

Increased 777X production enabled by Phase 2 of the project would be expected to result in increased emissions from the existing 777 assembly operations and related combustion from

boilers and heaters

. Table 9 lists the projected actual emissions (at the maximum production rate of 10.4 airplanes pe r month, or 125 airplanes per year) from the 777X assembly operations and from the related operations that would experience increased emissions as a result of increased production at the assembly operations

. Details of the emission estimates are shown in Appendices A and B.

Table 9 . Projected Actual Emissions of Regulated NSR Pollutants for Existing 777 Assembly Operations and Related 777 Operations (tpy)

Operation CO NO X PM SO X Lead VOC CO 2 e

777 Assembly * 26 5.5

Interiors * 66 .3

EDC * 1 8.8

Propulsion * 1 .3

Emergent * 7.5

ESRC * 1.6

Boilers † 55 67 5.1 1.5 0.0004 3.6 79,500

Total 55 67 6.35 1.5 0.0004 36 4.6 79,500

* Non

- combustion PM emissions will primarily be generated from spray coatingTechnical Support Document Page 19 of 96 Boeing Everett 777X Project September 9, 2014

Table 9 . Projected Actual Emissions of Regulated NSR Pollutants for Existing 777 Assembly Operations and Related 777 Operations (tpy)

Operation CO NO X PM SO X Lead VOC CO 2 e operations

. Total combined PM emissions from spray coating operations from all 777 operations are estimated to be less than or equal to approximately 0.01 ton per airplane

. Therefore, total combined PM projected actual emissions from all 777 spray coatin g operations are estimated to be less than or equal to 0.01 ton/airplane x 125 airplanes/yr = 1.25 tpy.

† All combustion

- related emissions are accounted for in Boilers.

CO = carbon monoxide

NO X = nitrogen oxides

PM = particulate matter

SO X = sulfur oxides

CO 2 e = carbon dioxide equivalent

EDC = Everett Delivery Center

ESRC = Electrical Systems Responsibility Center

The existing boilers and heaters provide heat and energy to all operations at the Boeing Everett facility, including operations such as office buildings and other airplane model manufacturing that are not directly related to 777 production

. Therefore, emissions from boilers and heaters are treated differently than those from the other operations

. The projected actual emissions rate for

combust ion operations is the baseline rate for the entire Boeing Everett facility plus the expected additional heat that would be required to support 777X production at the maximum potential production rate, based on an average heat usage of 3,206 MMBtu per airpl ane

. Details of the

emission estimates are shown in Appendices A and B.

VOC emissions from the EDC operations do not include final painting of the airplane exterior, which is performed in paint hangars

. Currently, the paint hangars at the Boeing Everett facility are operating at or near capacity, with many airplanes being flown offsite for final coating

. Because there are currently no plans to increase paint hangar capacity to support the 777X, the 777X project will not result in an increase emissions a t Boeing Everett facility from paint hangars.

Table 10 shows the baseline actual emissions for calendar years 2012 and 2013 from the 777 assembly operations and related operations that are expected to experience an emission increase

as a result of the in creased 777X production enabled by P hase 2 of the project, except that carbon dioxide equivalent (CO 2 e ) is based on 2006 and 2007, which was the 2

- year period with the greatest CO 2 e production rate.Technical Support Document Page 20 of 96 Boeing Everett 777X Project September 9, 2014

Table 10

. Baseline Actual Emissions of Regulated NSR

Pollutants for Existing 777 Assembly Operations and Related 777 Operations (tpy)

Operation CO NO X PM SO X Lead VOC CO 2 e

777 Assembly * 160

Interiors * 48

EDC * 14

Propulsion * 1

Emergent * 5

ESRC * 1

Boilers † 50 60 4.5 1. 1 0.000 3 3 7 2,0 00

Total 50 60 4.5 1. 1 0.000 3 233 72,000

∗ Non

- combustion PM emissions will primarily be generated from spray coating operations

. Total combined PM emissions from spray coating operations from all 777 operations are estimated to be less than or equal to approximately 0.01 ton per airplane

. Therefore, total combined PM baseline actual emissions from all 777 spray coating operations for calendar years 2012 and 2013 are estimated to be less than or equal to 1 tpy.

† All combustion

- related emissions are accounted for in b oilers.

During the baseline period, Boeing Everett did not operate above any legally enforceable emission limitation, and there are no new emission standards that affect these units or activities that have come into effect between the baseline period and the date of the application

. Therefore, no adjustments are required under 40 CFR 52.21(b)(48)(ii)(b) or (c).

3.2.1.2. Actual

- to

- Projected Test for Newly Constructed Emissions Units

For emissio ns units that will be newly constructed as part of the 777X project, baseline emissions are zero and post

- project emissions are the units’ PTE

. Therefore, the emission increase from these new units resulting from the project is their PTE

. The proposed ne w emissions units and

their associated PTE are identified in Table 11

. The PTE for the new non

- combustion emission units is based on a maximum production rate of 125 airplanes per year

. The potential emissions

from new combustion emissions units are base d on a voluntary total combined heat input limit of 1,000,000 MMBtu per year for all new combustion units associated with this project. Detailed

calculations are included in Appendices A and B.

Table 11 . Emissions Increases of Re gulated NSR Pollutants for New Units (tpy)

Emission Unit CO NO X PM SO X Lead VOC CO 2 e Wing component fabrication emission units (non

- combustion) <0.5 235

Vertical fin prep and spray booths <0.1 14

Wing stub spray coating enclosure <0.1 1Technical Support Document Page 21 of 96 Boeing Everett 777X Project September 9, 2014

Table 11 . Emissions Increases of Re gulated NSR Pollutants for New Units (tpy)

Emission Unit CO NO X PM SO X Lead VOC CO 2 e

Interiors emission units <0.1 34

Emergency engines 11 18 0.6 0.74 0 1 2,100

Combustion emission units 20 6 4 0.50 0 3 59,400

Total for new units 31 24 5.4 1.24 0 288 61,500

3.2.1.3. Hybrid Total Emissions Increase

The total emission increase relating to the 777X project is the sum of the increases from the existing units (projected actual minus baseline actual emissions) and the PTE from the newly constructed units and is presented in Table 12

.

Table 12 . Emissions Increa ses of Regulated NSR Pollutants for Existing and New Emissions Units (tpy)

Emissions CO NO X PM SO X Lead VOC CO 2 e

Baseline actual emissions 50 60 5.5 1.1 0 0.0003 233 72,000 Projected actual emissions from existing units 55 67 6.4 1.5 1 0.0004 365 79,500

Potential emissions from new units 31 24 5.4 1.2 4 0 288 61,500

Emissions increase 3 6 31 6.3 1. 66 0.0001 4 20 69,000 PSD Significant Emission Rate (SER) 100 40 10 40 0.6 40 75,000

Significant? No No No No No Yes No

The federal rule defines a significant increase to be equal to or exceeding any of the rates listed

in Table 13 (40 CFR 52.21(b ) ( 23))

. The 777X project is not expected to emit measurable quantities of f luorides, h ydrogen s ulfide (H 2 S), or reduced sulfur comp ounds (TRS)

. The expected increase in ozone depleting substances is about 2.25 tpy (see Appendix B)

. As noted in

Table 12 , the emissions increases from the 777X project will exceed the SER for only VOCs

. Therefore, the project will only have a significant emissions increase for VOCs.

Table 13 . Pollutant and PSD SERs

Pollutant SER

CO 100

NO X 40

SO 2 40

PM 25

PM 10 15Technical Support Document Page 22 of 96 Boeing Everett 777X Project September 9, 2014

Table 13 . Pollutant and PSD SERs

Pollutant SER

PM 2.5 10

Ozone 40 (VOCs or NO X ) ∗

Lead 0.6

Fluorides 3

Sulfuric a cid m ist 7

H 2 S 10

Total Reduced Sulfur 10

Reduced s ulfur c ompounds 10

Ozone

- d epleting s ubstances 100 †

Greenhouse g ases 75,000 CO 2 e

Note: There are additional rates for municipal waste

combustors and landfills; however, Boeing does not combust or landfill municipal waste at the Boeing Everett facility.

∗ VOC and NO X are precursors of ozone.

† WAC 173

- 400

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

SO 2 : sulfur dioxide

PM 10 : particulate matter less than 10 microns in diameter

PM 2.5 : particulate matter less than 2.5 microns in diameter

H 2 S: hydrogen sulfide

3.2.1.4. Significant Emissions Increase Analysis

If the project causes a significant emissions increase, then the project is a major modification only if it also results in a significant net emissions increase (40 CFR 52.21(a)(2)(iv)(a) )

. The 777X project will result in a significant emissions increase only for VOCs, and will be considered a major modification only if it also results in a significant net emission s increase of

VOCs

. The steps necessary to calculate the net emission increase are outlined in 40 CFR 52.21(b ) ( 3 ) ( i)

. As noted earlier in this section, EPA has stated that calculating a net emission increase is at the source’s option

. So a source may seek a PSD permit based on a calculated significant emission increase alone

. For t he 777X project, Boeing is taking that option and

for e going the Step 2 significant net emission increase analysis.

The 777X project will not exceed the SER of any regulated NSR pollutant except for VOCs

. Therefore, Boeing submitted an application for PS D review only for VOCs.

Ecology has discussed the emissions from painting previously in this section

. As noted above,

the emissions fr o m painting completed airplanes in the paint hangars were not included in theTechnical Support Document Page 23 of 96 Boeing Everett 777X Project September 9, 2014

777X project PSD application because Boei ng is operating those activities at near capacity and will not be adding additional paint hangars as part of this project

. The paint hangars will not experience an increase in utilization as a result of this project

. Even if those activities were

include d, the 777X project would not be a major modification for any non

- VOC NSR

- regulated pollutant.

In addition to regulated NSR pollutants, GHGs are subject to regulation as of January 2, 2011

. EPA’s PSD rule under 40 CFR 52.21(b ) ( 49) states the following:

Beginning January 2, 2011, the pollutant GHGs is subject to regulation if: The stationary source is a new major stationary source for a regulated NSR pollutant that is not GHGs, and also will emit or will have the potential to emit 75,000 tpy CO 2e or mor e; or The stationary source is an existing major stationary source for a regulated NSR pollutant that is not GHGs, and also will have an emissions increase of a regulated NSR pollutant, and an emissions increase of 75,000 tpy CO 2e or more.

Boeing Everett is an existing major stationary source for a regulated NSR pollutant that is not GHGs, and the proposed 777X project is expected to result in a significant increase of VOCs

. However, the project will not result in an emissions increase of 75,000 tpy of C O 2 e

.

40 CFR 52.21(b) (49) continues:

Beginning July 1, 2011, in addition to the provisions in paragraph (b) (49) (iv) of this section, the pollutant GHGs shall also be subject to regulation: At a new stationary source that will emit or have the potential to emit 100,000 tpy

CO 2e ; or At an existing stationary source that emits or has the potential to emit 100,000 tpy

CO 2e , when such stationary source undertakes a physical change or change in t he method of operation that will result in an emissions increase of 75,000 tpy CO 2e

or more.

Boeing Everett is an existing stationary source with the PTE 100,000 tpy CO 2 e ; however, the 777X project will not result in an emissions increase of 75,000 tpy o f CO 2 e . Therefore, the GHGs emissions from the project are not subject to PSD review.

4. BACT

4.1. Definitions and Policy Concerning BACT

All new major sources or major modifications are required to utilize BACT for those new and modified emission units that will experience an increase in emissions as a result of the project.

BACT is defined as an emissions limitation based on the maximum d egree of reduction for each pollutant subject to regulation, emitted from any proposed major stationary source or majorTechnical Support Document Page 24 of 96 Boeing Everett 777X Project September 9, 2014

modification, on a case

- by

- case basis, taking into account cost

- effectiveness, economic, energy, environmental, and other impacts (40 CF R § 52.21(b)(12)).

Federal guidance requires each PSD permit applicant to implement a “top

- down” BACT analysis process for each new or physically or operationally changed emissions unit. Ecology has adopted the top

- down BACT process for its BACT determ inations. This top

- down BACT analysis process consists of five basic steps described below: 1

Step 1. Identify all available control technologies with practical potential for application to the specific emission unit for the regul ated pollutant under eva luation.

Step 2. Eliminate all technically infeasible control technologies.

Step 3. Rank remaining control technologies by control effectiveness a nd tabulate a control hierarchy.

S tep 4. Evaluate most effective co ntrols and document results.

Step 5. Select BACT, which will be the most effective practical option not rejected, based on economic, environmental, and/or energy impacts.

If the applicant proposes to implement the most effective or “top” available control strategy, S tep 4 is not necessary.

As shown above, the "top

- down" BACT process starts by considering all available emission control technologies, and ranks them for further evaluation from most effective to least effective technically available control technology. The most effective emis sion reduction technology is then evaluated for economic feasibility. If the technology is proven infeasible based on economics, energy

, or other environmental considerations, then the next most stringent level of reduction is considered. The most string ent level of emissions control that is not determined to be technically and economically infeasible is selected as BACT. While the permitting agency makes the final BACT decision, the burden is on the applicant to prove why the most stringent

level of con trol should not be used.

Boeing provided a 5

- step top

- down VOCs BACT analysis for the 777X project, which was fully evaluated by Ecology.

For the 777X project, the only regulated NSR pollutant for which the project results in a plantwide significant emi ssion increase is VOCs

. This section will discuss the BACT analysis focusing on VOCs for the new and modified prep booths, spray booths, combustion sources, and fugitive (open floor) sources using the EPA top

- down approach.

1 See EPA’s Draft New Source Review Workshop Manual , 1990; and PSD and Title V Permitting Guidance for

Greenhouse Gases < http://www.epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf >.Technical Support Document Page 25 of 96 Boeing Everett 777X Project September 9, 2014

4.2. BACT Analysis

4.2.1. Prep and Spray Paint Booths BACT Analysis

There are several proposed new or modified prep and spray paint booths anticipated for the 777X project

. These booths are listed in Table 14

. The table presents the total potential VOC emissions based on the anticipated annual hours of operation for each of the new or modified

emissions units.

Table 14 . New and Modified Booths

Emission

Unit Booth Type Qty. New/
Modified Annual Hr of Operation (per booth) VOC

Emissions (tpy/booth) Exhaust

Rate (acfm)

WBSP

- 2 Forward body section spray
booth 1 Might need to be modified to accommodate larger sections 1,000 12.5 54,900

WBSP

- 3 Mid body

s ection spray booth 1 Might need to be modified to accommodate larger section 1,000 12.5 65,750

WBSP

- 4 Aft body section spray booth 1 Might need to be modified to accommodate larger sections 1,000 12.5 64,000

WBSP

- 6 Forward body
section CIC spray booth 1 Might need to be modified to accommodate larger sections 625 12.1 33,500

WBSP

- 7 Mid body

section CIC spray booth 1 Might need to be modified to accommodate larger sections 625 6.1 44,800

WBSP

- 8 Aft body section CIC spray

b ooth 1 Might need to be modified to accommodate larger sections 625 12.1 33,500

WBSP

- 10 Vertical fin
HLFC prep booth 1 NEW (Currently this work is done

on the 777 vertical fin with final coat in the airplane paint

h angars.) 500 1.3 50,000

WBSP

- 11a,b,c Vertical fin
HLFC spray booths 3 NEW (Currently this work is done

with final coat in the airplane paint hangars.) 500 4.4 150,000

AA

- 2 Wing stub

s pray booths 2 One new, one modified 1,000 1.4 4,000

IRC

- 1a,b,c Adhesive spray
booths 3 NEW 2,000 8.9 20,000

IRC

- 2 Paint spray

booth 1 NEW 2,000 5 20,000

Acfm: Actual cubic feet per minute

VOC emission estimates for paint spray booths include gun and line cleaning operations because the paint containers and the spray guns are connected by long lines that need to be cleaned

. Although the cleaning solution is collected in containers, for the purposes of the emission

estimates and the BAC T analysis, a portion of the gun and line cleaning solvent is assumed to be emitted through the booth.Technical Support Document Page 26 of 96 Boeing Everett 777X Project September 9, 2014

BACT analysis was performed for each emission unit operating at the emission rates and exhaust

flow rates listed in Table 14

. Boeing currently uses a combination of low

- VOC coatings, high transfer efficiency application techniques, and good work practices (i.e., keeping containers of coating closed when not in use) to minimize VOC emissions

. The Aerospace National Emission

Standard for Hazardous Air Po llutants ( A NESHAP) regulation require s low

- VOC coatings, high transfer efficiency coating techniques, and these work practices

. Therefore

, these coatings, application techniques

, and work practices are considered the base case for BACT.

The cleaning and coating operations planned for the new and modified spray paint booths are as

follows:

• Aircraft parts cleaning: Before the parts of the airplane can be sealed and/or coated, they first must be cleaned and prepped.

• A ircraft parts sealing: Areas on certai n parts of the airplane (e.g., parts that will become part of a fuel tank or the pressurized fuselage) must be sealed prior to coating.

• Aircraft parts priming: Priming provides corrosion protection and ensures the necessary

bond between the surface of the airplane components and the topcoat.

• Aircraft parts topcoat: The topcoat is the final coating of the normally visible surfaces of the airplane

. The topcoat not only provides the final protection of the airplane surface,

but on the exterior of the fusela ge and empennage (the tail assembly of an aircraft, including the horizontal and vertical stabilizers, elevators, and rudder) also provides the decorative color to the airplane.

• Aircraft parts corrosion inhibiting compound (CIC): Portions of the airplane that are not normally visible often need a special coating to further protect them from corrosion.

• Adhesive spray booths: Interior composite panels (e.g., aircraft cabin sidewalls and ceilings) are sprayed with adhesive to apply a decorative laminate.

• Spr ay equipment cleaning: The spray equipment used to perform the operations above is

cleaned after each use

. A small amount of solvent evaporates while cleaning the spray equipment.

4.2.2. Available Control Technologies

BACT databases from EP A (EPA, RACT/BACT/LAER Clearing house [RBLC]), California Air Resources Board (CARB), and South Coast Air Quality Management District (SCAQMD) were reviewed for possible control technologies that are both available on the market and proven practice in the aerospace or other industries with similar requirements for coating very large objects

. The technologies reviewed are summarized in Table 15

.Technical Support Document Page 27 of 96 Boeing Everett 777X Project September 9, 2014

4.2.3. BACT Feasibility Review

The control technologies in Table 15 have been demonstrated and achieved in practice and therefore could be feasible technologies for implementation for the 777X project.

Table 15 . BACT Review

Control Technology Equipment Description Company Date Implemented Pollutant
Controlled Control Efficiency (%) Emission
Limit Database
Reference

Thermal

oxidizer Spray b ooth Watkins Manufacturing Corporation 10/28/2002 VOC 98.9 95%
control CARB, BACT Clearinghouse

RTO Spray b ooth Arcadia, Inc 2/6/2001 VOC 99.3 .89 lb/hr CARB, BACT Clearinghouse,
SCAQMD Clearinghouse

RTO Spray b ooth Huck

International

– Deutsch Operations N / A VOC 90.6 59 lb/day CARB, BACT Clearinghouse,
SCAQMD Clearinghouse

RTO w /

concentrator Spray b ooth Kal

- Gard Coating & Mfg, E/M Corp. 8/14/2008 VOC Not

Available 2 tpy CARB, BACT Clearinghouse

R TO w /

concentrator Spray b ooth Douglas

Production
Division 3/30/94 VOC 93.2 341 gal/ day CARB, BACT Clearinghouse,
SCAQMD Clearinghouse

Carbon adsorption Spray b ooth Lippert Components,

Inc. 5/8/2002 VOC 99.3 85.5%
control CARB, BACT Clearinghouse

Carbon adsorption Spray b ooth Northrop

Grumman 2/25/91 VOC 90 414 lb/day CARB, BACT Clearinghouse

Low

- VOC coatings, HVLP coating gun, best management practices Spray b ooth Dean Baldwin Painting LP 09/21/2011 VOC N / A 4.5 lb VOC/gal coating EPA, RBLC Clearinghouse

Low

- VOC coatings, HVLP coating gun, best management practices Spray b ooth Time Aviation Services, Inc. 6/18/99 VOC N / A 3 gal/day CARB, BACT Clearinghouse

Low

- VOC coatings, HVLP coating gun, best management practices Spray bo oth California Air

National Guard,

Fresno 1/22/97 VOC N / A 5.23 lb VOC / gal coating CARB, BACT Clearinghouse

Low

- VOC coatings, HVLP coating

gun, enclosed gun

cleaner Spray b ooth Toter 12/16/99 VOC N / A 1.09 lb
VOC / gal CARB, BACT Clearinghouse

RTO = regenerative thermal oxidizer

N / A = not applicable

HVLP = high

- volume low

- pressureTechnical Support Document Page 28 of 96 Boeing Everett 777X Project September 9, 2014

4.2.4. Ranking of BACT by Control

The potential control options listed in Table 15 are ranked in Table 16 based on the control efficiencies documented as being achieved in practice.

Table 16 . Ranking of Control Technologies

Type of Control Technology Control Efficiency Ranking

RTO 99.3% 1
Carbon adsorption 99.3% 2

Thermal oxidizer 98.9% 3

R TO w / concentrator 93.2% 4

Low

- VOC coatings, HVLP coating gun, best management practices N / A 5

4.2.5. Cost

- Effectiveness Evaluation

Vendors of paint operation control technologies were contacted by Boeing to assess implementation of the different controls available in the marketplace listed in Table 16 . Vendor quotes were collected and are summarized in the cost

- effectiveness evaluati on spreadsheets

. Cost

- effectiveness evaluations were made following EPA’s guidance for VOC Control by Incinerator and by Carbon Adsorption (EPA

, 2002). These evaluations are discussed below.

Before discussing the evaluations’ results, note the cost

- effectiveness analyses use the standard default values for construction as provided by EPA unless otherwise noted. Boeing Everett expects the installation of any add

- on control technology at an existing part of the facility would require complicated retrofit construction and expenses. The existing facility has limited space available for the footprint of additional equipment, which might require that any add

- on controls be placed on the roof. The need for additional structural support would have to be evaluated, and the existing natural gas lines might need to be upgraded to supply sufficient follow and pressure to operate the control equipment as designed. Retrofits and new equipment installation add costs

to the cost

- effectiveness analysis. Provi ding utilities such as natural gas is expected, but not currently available at every location. For these reasons, Boeing projected construction costs for both retrofits and for new equipment installed at Boeing Everett’s existing facility are expected

to be above standard EPA default values for construction for a new facility.

4.2.6. Thermal Oxidizer

A thermal oxidizer uses a burner to destroy VOC emissions prior to release to the atmosphere through a stack. This control technology includes preheating the inco ming air stream to obtain additional fuel efficiencies. In prior BACT reviews for Boeing (PSD application for 737 MAX production and capacity increase, February 2013), the thermal oxidizer technologies have been demonstrated to be the most expensive techn ology to implement for this application. It wasTechnical Support Document Page 29 of 96 Boeing Everett 777X Project September 9, 2014

implemented only once in the industry over 10 years ago (see Table 15 above). Since that implementation, other control technologies for coating applications have been implemented.

4.2.7. Carbon Adsorption

Carbon adsorption uses a filter bank of canisters that contain activated carbon which adsorbs the VOC emissions as the emissions pas s through before being released to the atmosphere

. Vendor information for the carbon adsorption technology was obtained from Thermal R ecover Systems (TRS)

. The carbon adsorption control technology overall cost

- effectiveness in dollars per ton

removed is discussed below.

4.2.8. Regenerative Thermal Oxidizer

A r egenerative thermal oxidizer (RTO) was ranked as one of the top control technologies available based on control efficiency

. VOC emissions created from cleaning and coating

activities are burned inside an enclosed chamber

. Heat from the exhaust gas is rec overed in a heat exchanger, which allows for fuel efficiencies in sustaining the high burn temperature

. Vendor information for the RTO technology was obtained from Epcon

. T he RTO with control technology overall cost

- effectiveness in dollars per ton remov ed is discussed in the summary

section below.

4.2.9. RTO with Concentrator

This control technology augments the RTO methodology with the addition of a concentrator

wheel

. The wheel provides for a more concentrated VOC content in a smaller air stream for

burnin g

. The concentration of VOCs allows greater fuel efficiencies to be obtained during operation

. Vendor information for the RTO with concentrator control technology was obtained from Anguil

. The RTO with concentrator control technology overall cost

- effect iveness in dollars per ton removed is discussed below in the summary section below

.

4.2.10. Low VOC Coatings, High Transfer Efficiency Coating Techniques, and

Good Work Practices

Boeing Everett currently uses low VOC coatings that meet specifications for airplane coating operations

. Boeing also uses high transfer efficiency coating techniques, such as high volume low pressure (HVLP) spray guns, which provide high transfer efficiency and reduce the overall amount of paint required to perform a job

. In add ition, Boeing uses good work practices to minimize VOC emissions, including storing coatings and solvents in closed container, bagging

solvent hand wipe cleaning rags when not in use, and capturing and containing solvent used for cleaning spray equipment

. The VOC emissions standards for uncontrolled use will be applied in this operation

. No cost analysis was performed because Boeing considers this to be the base case

for BACT.Technical Support Document Page 30 of 96 Boeing Everett 777X Project September 9, 2014

4.2.11. Summary of Cost

- Effectiveness Analysis

The costs of control technologies identified as being available and technologically feasible for the new and modified prep booths and spray booths are summarized in Tables 17 through 20

. These cost estimates are conservative (potentially underestimating the costs) and include an

additiona l construction expense estimated at 15 percent of the Total Purchased Equipment Cost

. In some cases

, that additional expense was included in the vendor’s quote, and in others the expense was added.

Vendor information was not collected for every booth co nfiguration and VOC loading rate expected for the 777X project

. Vendor cost basis information is summarized in Table 17

. Costs were scaled from the parameters quoted from vendors in Table 17 to match those emission units

listed in Table 14

. The carbon a dsorption quote from Thermal Recovery Systems was obtained in 2011 for a previous Boeing PSD application using a 25,000 cubic feet per minute (CFM) air

flow rate

. The same quote was used in this analysis using a conservative cost approach to not

include i nflation costs

. The RTO quote from Epcon was for a 33,500 cfm, and a 100,000 cfm

booth

. Quotes for RTO with concentrator from Anguil were provided for 46,800 cfm, 120,000 cfm, 195,000 cfm, and 400,000 cfm capacity booths

. RTO with concentrator equipment operating costs were only obtained for the 400,000 cfm unit as operating costs are minimal compared to the equipment costs.

For control equipment that would be installed in existing buildings, a 15 percent contingency factor was applied

. This is a very conservative estimate considering that the thermal oxidizers would likely be outside the building, and require considerable duct work and foundation

supports.

Table 17 . Vendor Quote Basis Summary

Type of Control Technology Vendor Air Flow

Rates (cfm) Operating Costs
Inc. in Quote? Equipment Cost Contingency
Inc. in Quote

Regen erative canister thermal oxidize Epcon 33,500 Yes 15%

Regenerative canister thermal oxidizer Epcon 100,000 Yes 0%
Carbon adsorption TRS 25,000 Yes 0%

RTO w / Zeolite concentrator Anguil 46,800 120,000 195,000 No ∗ 15%

R TO w / Zeolite concentrator Anguil 400,000 Yes 15%

∗ Operating costs were scaled from four 100,000

- cfm units.

The standard method of evaluating the cost

- effectiveness of various air pollution control options is to calculate the annualized cost of each option and divide t hat by the amount of emissions that would be removed by that option

. Using this approach, the annualized cost of removing one tonTechnical Support Document Page 31 of 96 Boeing Everett 777X Project September 9, 2014

of VOC emissions was calculated for each applicable control option and is summarized in Tables 18, 19, and 20

.

Table 18 . Summary of Costs for W ing Component Fabrication (WCF) Control Technologies by Emission Unit

Emission

Unit Unit Description TRS Carbon Adsorption
Control Costs ($/ton of VOC

controlled) A n guil R T O
w/Zeolite
Concentrator
Control Costs ($/ton of VOC

controlled) Epcon Canister

RTO
Control Costs ($/ton of VOC

controlled)

WCF

- 8a Wing panel prep booth(s) (abrasive blast/sanding, solvent hand wipe, edge seal) ( s ee Note 1) $177,294 $9,177 $11,638

WCF

- 8b Wing spar pre p booth (abrasive blast/sanding,

solvent hand wipe, edge seal) $181,961 $19,135 $21,459

WCF

- 9a, b, and d Wing panel spray booth ( s ee Note 2) $179,228 $34,789 $47,347

WCF

- 9c Wing spar spray booth $180,074 $42,914 $48,706

WCF

- 10a
and 10b Wing panel primer curing booth $217,873 $275,799 $377,238

WCF

- 10c Wing spar primer curing booth $245,353 $403,271 $454,442

WCF

- 11 Small quantity paint mix booth $333,083 $498,125 $533,096

WCF

- 12a
and 12b Coating equipment cleaning booth $184,137 $31,133 $33,318

WCF

- 14 Wing spar seal booth(s) (see N ote 3) $179,439 $20,722 $24,382

Note s:

1. As explained in Note 1 to Table 1

, Boeing is considering building one or two wing panel prep booths

. It is conservatively assumed for purposes of calculating the control technology costs that only one wing panel prep booth will be built

. If the control technology costs

were instead based on two booths, the costs would be higher than those shown in the above table.

2. Although the current plan is to build three wing panel spray booths, it is conservatively assumed for purposes of calculating the control technology costs that only two wing pan el spray booths will actually be built

. If the control technology costs were instead based on three booths, the costs would be higher than those shown in the above table.

3. As explained in Note 3 to Table 1 , Boeing is considering building from one to as man y as four wing spar seal booths

. It is conservatively assumed for purposes of calculating the control technology costs that only one wing spar seal booth will actually be
built

. If the control technology costs were instead based on two or more booths, th e costs would be higher than the costs shown in

the above table.

Table 19 . Summary of Costs for Wing and Body Structure Paint (WBSP) Control Technologies by Emission Unit

Emission

Unit Unit Description TRS Carbon Adsorption
Control Costs ($/ton of VOC controlled) A n guil RTO
w/Zeolite
Concentrator
Control Costs ($/ton of
VOC controlled) Epcon Canister

RTO
Control Costs ($/ton of VOC

controlled)

WBSP

- 1a and 1b Robotic wing spray booth

– 120,000 acfm $180,958 $22,944 $40,850

WBSP

- 1a and 1b Robotic wing spray booth

– 90,000
acfm $179,209 $18,050 $24,331Technical Support Document Page 32 of 96 Boeing Everett 777X Project September 9, 2014

Table 19 . Summary of Costs for Wing and Body Structure Paint (WBSP) Control Technologies by Emission Unit

Emission

Unit Unit Description TRS Carbon Adsorption
Control Costs ($/ton of VOC controlled) A n guil RTO
w/Zeolite
Concentrator
Control Costs ($/ton of
VOC controlled) Epcon Canister

RTO
Control Costs ($/ton of VOC

controlled)

WBSP

- 1a and 1b Robotic wing spray booth

– 60,000
acfm $178,248 $14,126 $13,357

WBSP

- 2 Forward body section spray

booth $179,65 4 $32,206 $38,495

WBSP

- 3 Mid body section spray booth $180,185 $36,908 $43,945

WBSP

- 4 Aft body section spray booth $180,313 $37,366 $44,477

WBSP

- 6 Forward body section CIC spray

booth $177,730 $21,008 $23,958

WBSP

- 7 Mid body section CIC spray booth $182,221 $54,501 $63,344

WBSP

- 8 Aft body section CIC spray booth $177,730 $21,008 $23,958

WBSP

- 10 Vertical fin HLFC prep booth $211,205 $291,315 $329,290

WBSP

- 11a, 11b,
and 11c Vertical fin HLFC spray booth $190,538 $118,905 $153,698

Table 20 . Summary of C osts for Airplane Assembly (AA) and Interior Fabrication (IRC) Control Technologies by Emission Unit

Emission

Unit Unit Description TRS Carbon Adsorption
Control Costs ($/ton of
VOC controlled) A n guil RTO
w/Zeolite
Concentrator
Control Costs ($/ton of VOC controlled) Epcon Can ister
RTO
Control Costs ($/ton of VOC controlled)

AA

- 2a and 2b Wing stub spray booth $199,978 $44,284 $47,829

IRC

- 1a, 1b, A nd 1c Adhesive spray booth $183,800 $24,144 $29,528

IRC

- 2 Paint spray booth $191,095 $42,735 $52,265

T he robotic wing spray booths (WPSB

- 1a and 1b) are designed to operate in three operating modes, with ventilation rates of 120,000 cfm, 90,000 cfm, and 60,000 cfm

. In that supplement

, three options were evaluated:

1. Option A is to use a VOC control system for each booth designed to handle all 120,000

cfm

. This option would ensure that all VOC emissions are treated by the control system

. It would operate all the time that coating or cleaning occurred

. About 29.5 ton s of VOC s per year would be treated by each system and no VOC would be untreated.Technical Support Document Page 33 of 96 Boeing Everett 777X Project September 9, 2014

2. Option B is to use a VOC control system for each booth designed only to handle up to 60,000 cfm, the most common operating mode of the robotic booth

. Any exhaust above 60,000 cfm would be vented directly to the atmosphere without going through the VOC control system

. Because the 60,000 cfm mode represents most of the operation and potential emissions, most emissions would be controlled

. About 26 tons of VOC would be treated per year and about three tons per year would be untreated.

3. Option C is similar to Option B except that the VOC control system for each booth would be designed to handle up to 90,000 cfm, and any exhaust greater than 90,000 cfm wou ld be vented directly to the atmosphere

. About 29.1 tons of VOC s would be treated per year, and 0.4 tpy would be untreated.

Each of these options was evaluated and the results are presented in Table 19

. Note that under the current Boeing plan, a decisi on to modify the r obotic w ing spray b ooth by installing a second robotic spray system in each booth will not be made until Phase 2 of the project and

, at that time

, BACT will likely be reevaluated

. Phase 2 is tentatively scheduled to begin in 2021.

4.2.12. Compa rison with Other Aerospace BACT Determinations

Boeing is currently the only manufacturer of large commercial airplanes in the United States

. Even though Boeing has some smaller facilities elsewhere in the country and Airbus is scheduled

to start

- up a new airplane assembly plant in Alabama, there are few airplane facilities to compare to Boeing Everett due to the size of the planes made at Everett, and the size of the facilities at

Everett.

A review of RBLC entries of the last 10 years for aerospace surface coatings (Process Type 41.001) shows entries for Boeing commercial airplane operations in the Puget Sound area and one entry for a Dean Baldwin aircraft refinishing operation in Indiana (T able 21 )

. None of these

entries indicates that add

- on controls were considered BACT

. Also, no BACT determinations for the Alabama Airbus facility are listed in the RBLC, even though the plant is under

construction

. A further review of the RBLC entries f or permits between 1990 and 2003 (Table

22 ) indicates some BACT decisions for aerospace coating operations that required add

- on controls

. However, evaluation of the location of each of these operations indicates that each was

in an ozone nonattainment are a at the time of permitting

. For example, Huck International is located in Los Angeles, an ozone nonattainment area; CA

- 0889, CA

- 1045, and CA

- 0977

. For each of these RBLC entries, we believe that the control determinations were intended to implement LAER for those operations under non attainment area NSR rather than BACT under the PSD program.Technical Support Document Page 34 of 96 Boeing Everett 777X Project September 9, 2014

Table 21 . RBLC Aerospace Coating Entries Since 2000 (Process Type 41.001)

ID Co. State Permit

Date Process Control

Method Description BACT

WA

- 0326 Boeing Commercial Airplanes Group WA 10/12/2005 Exterior coating operations N/A

WA

- 0326 Boeing Commercial Airplanes Group WA 10/12/2005 Final assembly N/A

WA

- 0326 Boeing Commercial Airplanes Group WA 10/12/2005 Interiors manufacturing N/A

WA

- 0330 Boeing Commercial Airplanes Group WA 10/12/2005 Paint hangar final exterior coating A BACT review was not required because Ecology determined
that there was no physical change, or change in the method of operation, that

causes or results in an

emissions increase. BACT

- PSD

WA

- 0330 Boeing Commercial Airplanes Group WA 10/12/2005 787 final assembly A BACT review was not required because Ecology determined
that there was no physical change, or change in the method
of operation, that

causes or results in an

emissions increase. BACT

- PSD

WA

- 0330 Boeing Commercial Airplanes Group WA 10/12/2005 Interiors manufacturing A BACT review was not required because Ecology determined
that there was no physical change, or change in the method of operation, that

causes or results in an

emissions increase. BACT

- PSD

WA

- 0340 The Boeing Company WA 07/27/2007 Paint hangar/final exterior coating Other c ase

- by

c ase

WA

- 0344 Boeing Commercial Airplanes Group WA 10/07/2008 Paint booth/hangar Compliance with 40 CFR Part 63, Subpart
GG and low

- VOC

vapor pressure cleaning solvents and strippers with low pressure applicators or manual application for depainting BACT

- PSD

IN

- 0126 Dean Baldwin Painting LP IN 09/21/2011 Aircraft refinishing Other c ase

- by

c ase

WA

- 0347 The Boeing Company Boeing Renton WA 02/19/2013 Paint booths/ hangars/floor

A ctivities Compliance with 40 CFR Part 63, Subpart
GG and low

- VOC

vapor pressure cleaning solvents and strippers with low pressure applicators or manual application for depainting. BACT

- PSD

WA

- 0348 The Boeing Company Boeing Renton WA 02/19/2013 Paint booth/final exterior coating Compliance with 40 CFR Part 63, Subpart
GG and low

- VOC BACT

- PSDTechnical Support Document Page 35 of 96 Boeing Everett 777X Project September 9, 2014

Table 21 . RBLC Aerospace Coating Entries Since 2000 (Process Type 41.001)

ID Co. State Permit

Date Process Control

Method Description BACT

vapor pressure cleaning solvents and strippers with low

pressure applicators or manual application for depainting.

Table 22 . RBLC Aerospace Coating Entries Between 1990 and 2000

ID Co. State Permit

Date Process Control

Method Description BACT

WA

- 0326 Boeing C ommercial Airplanes Group WA 10/12/2005 Exterior coating operations N/A

WA

- 0326 Boeing Commercial Airplanes Group WA 10/12/2005 Final assembly N/A

WA

- 0326 Boeing Commercial Airplanes Group WA 10/12/2005 Interiors manufacturing N/A

WA

- 0330 Boeing Commercial Airplanes Group WA 10/12/2005 Paint hangar
final exterior coating A BACT review

was not required

because Ecology
determined that

there was no physical change, or change in the
method of

o peration, that
causes or results in

an emissions

increase. BACT

- PSD

WA

- 0330 Boeing Commercial Airplanes Group WA 10/12/2005 787 final assembly A BACT review was not required because Ecology
d etermined that

there was no physical change, or change in the
method of operation, that
causes or results in

an emissions

increase. BACT

- PSD

WA

- 0330 Boeing Commercial Airplanes Group WA 10/12/2005 Interiors manufacturing A BACT review was not required because Ecology
determined that

there was no physical change, or change in the
method of operation, that
causes or results in

an emissions

increase. BACT

- PSDTechnical Support Document Page 36 of 96 Boeing Everett 777X Project September 9, 2014

Table 22 . RBLC Aerospace Coating Entries Between 1990 and 2000

ID Co. State Permit

Date Process Control

Method Description BACT

WA

- 0340 The Boeing Company WA 07/27/2007 Paint hangar/final exterior coating Other c ase

- by

c ase

WA

- 0344 Boeing Commercial Airplanes Group WA 10/07/2008 Paint booth/hangar Compliance with 40 CFR Part 63, Subpart GG and

low

- VOC vapor pressure cleaning
solvents and strippers with low

pressure

a pplicators or manual application for depainting

. BACT

- PSD

IN

- 0126 Dean Baldwin Painting LP IN 09/21/2011 Aircraft refinishing Other c ase

- by

c ase

WA

- 0347 The Boeing Company Boeing Renton WA 02/19/2013 Paint booths/ hangars/floor

activities Compliance with 40 CFR Part 63, Subpart GG and

low

- VOC vapor pressure cleaning
solvents and strippers with low

pressure applicators or manual application for depainting. BACT

- PSD

WA

- 0348 The Boeing Company Boeing Renton WA 02/19/2013 Paint booth/final exterior coating Compliance with
40 CFR Part 63, Subpart GG and

low

- VOC vapor pressure cleaning

solvents and strippers with low

pressure applicators or manual application for depainting. BACT

- PSD

WA

- 0287 Boeing Commercial Airplanes

- Everett Facility WA 12/23/1991 Surface coating,

corrosion

inhibitor Best management practices

. Electrostatic, air assisted, or airless spray equipment

. Baseline emission

rate: 11.5 tpy

. Control efficiency:

15 %

- 3 5%. BACT

- PSD

CA

- 0771 California Air

National Guard, Fresno CA 01/22/1997 HVLP applicator used

to coat parts Lowest available

VOC content

which meets military specifications. LAER

CA

- 0977 Kal

- Gard Coatings & Manufacturing CA 05/28/1997 Metal parts coating operation Zeolite

c oncentrator and

thermal oxidizer LAERTechnical Support Document Page 37 of 96 Boeing Everett 777X Project September 9, 2014

Table 22 . RBLC Aerospace Coating Entries Between 1990 and 2000

ID Co. State Permit

Date Process Control

Method Description BACT

CA

- 0979 Douglas Products

Division CA 03/30/1994 Metal parts coating operation Concentrator and

thermal oxidizer LAER

CA

- 0980 Huck International

- Deutsch Operations CA 03/09/1995 Metal parts coating operation Thermal oxidizer LAER

CA

- 0549 Edwards Air Force

Base CA 05/07/1993 Hangar

- sized spray booth for aircraft up to

EC

- 18 Carbon adsorption

filter bank w /

flame i onization

detector to detect breakthrough Other c ase

- by

c ase

CA

- 0685 T.B.M. Inc. CA 11/06/1995 Aircraft refinishing operation Low

- VOC coatings and

Hercules GW/R enclosed gun Other c ase

- by

c ase

UT

- 0058 Hill Air Force Base UT 12/15/1997 Surface coating, military operations Zeolite adsorption

system

- M&W

condesorb fob

– 26 Zeolite adsorption

cells

- 100,000

acfm @ 80 °F

- max loading 122

lb VOC/hr Other c ase

- by

c ase

WA

- 0045 Heath Tecna Aerospace Co. WA 03/27/1992 Spray booth Carbon adsorber (methylene chloride) Other c ase

- by

c ase

WA

- 0287 Boeing Commercial Airplanes

- Everett Facility WA 12/23/1991 Surface coating,

corrosion

inhibitor Best management practices

. Electrostatic, air assisted, or airless spray equipment

. Baseline emission

rate: 11.5 tpy

. Control efficiency:

15 %

- 35%. BACT

- PSD

NAA = Nonattainment area

The RBLC also indicates that add

- on controls have been installed at both Edward s Air Force

Base (AFB) in California and Hill AFB in Utah

. Edwards AFB is in an ozone non a ttainment

area

. Neither of these entries purports to reflect a BACT decision under PSD

. Each of these

decisions is discussed further below

. Boeing was provided inf ormation on these facilities by CH2M Hill and Air Force personnel familiar with those operations.

Edwards AFB has two booths used to paint airplanes and parts, and the booths have carbon adsorption systems installed

. The first booth has an air flow of 11 1,000 cfm with 2.25 tpy of

uncontrolled VOC emissions

. The second booth is much larger (493,000 cfm) with 1.65 tpy ofTechnical Support Document Page 38 of 96 Boeing Everett 777X Project September 9, 2014

uncontrolled V OC emissions

. Both of the carbon systems were installed because the AFB believed a cost savings, compared to other control technologies would be achieved while meeting nonattainment area requirements applying LAER and obtaining offsets.

These systems were supposed to be regenerative carbon systems, but soon after installation the regenerative portion failed and was never rep aired. Today, carbon is swapped out manually at great expense. Albeit infrequently because of decreased VOC emissions over the years. The use of good work practices to reduce VOC emissions by using low VOC paints and applicati on methods has proved more cost

- effective than maintaining the carbon VOC control system and running it. This VOC control system’s efficiency is not achieved in practice as designed and

listed in the EPA RBLC.

Hill AFB was in an ozone nonattainment or maintenance area at the time of permitting and installed a Zeolite adsorption system

. The initial installation of the unit appears to have been associated with technology demonstration and funded under a pollution prevention program

. This unit has not been operational at Hill AFB fo r an extended period of time

. Boeing was unable to determine how long the unit operated or the reason it was taken out of operation

. Because of this lack of information, Boeing believes that no judgment can be made as to the feasibility of such a system for Boeing Everett

. Ecology agrees with this assessment.

In summary, Boeing was unable to identify similar aerospace coating operations operated by other companies in the United State s and could not find a recent BACT determination in EPA’s RBLC that req uires add

- on controls for similar aerospace coating operations

. The few older determinations that are listed as BACT were intended to implement LAER for those operations under nonattainment area NSR rather than BACT under the PSD program.

4.2.13. BACT Selection

In determining BACT, energy, environmental, and economic impacts are taken into account

. For PSD analysis, VOC is regulated as an ozone precursor

. However, ozone formation in the Puget Sound area is limited by NO X emissions and not VOC emissions

. There fore, the 777X project is not expected to have any measurable effect on ambient ozone levels

. In addition, control technologies that involve combusting the VOCs will requ i re some additional energy.

As noted above in Tables 18 through 20 , the identified add

- on control technologies are not economically feasible for the Boeing Everett facility

. After taking into account energy, environmental, and economic impacts

, add

- on control technologies are not considered BACT

. The Boeing Everett facility will be req uired to continue to implement the use of low VOC coatings, used high transfer efficiency coating equipment, and follow good work practices to minimize VOC emissions in compliance with the Aerospace NESHAP VOC emission standards in 40 CFR 63 Subpart GG

. T hese requirements are listed in Table 23

.

Ec ology reviewed the State of South Carolina’s Air Operating Permits number 0560

- 0372 (issued on July 23, 2007)

, number 0560

- 0415 (issued on August 2, 2012), and Air Quality StateTechnical Support Document Page 39 of 96 Boeing Everett 777X Project September 9, 2014

Construction Permit for the Boe ing IRC and Propulsion South Carolina number 0560

- 0415

- CB ( issued on January 22, 2014 )

. These permits are Air Operating and Notice of Construction

p ermits, and were found to not be applicable to Ecology’s PSD permitting effort for the Boeing 777X project.

Ecology also contacted Alabama in regards to the proposed Airbus facility. Ecology discovered that Airbus’ facility will be three separate facilities with different owners. One facility will be for utilities and owned by Honeywell, Inc. This facility will be permitted for natural gas

- fired boilers. The second facility is the airplane manufacturing plant, and will be owned by Airbus. The third facility will be for painting the completed airplanes. As of March 2014, the application

had not been submit ted. A foreign company will own the painting facility. The Alabama plant’s producing a final airplane for Airbus will not require a PSD permit.

Based on all this information, Ecology believes the proposed limits meet BACT requirements.

Table 23 . Summary of Aerospace NESHAP VOC Emission Standards Applicable to the New and Modified Emission Units of the 777X Project

Production Activity Control Technology

Low

- VOC primers Large commercial aircraft component exteriors: 5.4 lb VOC/gal All other applications: 2.9 lb VOC/gal

Low

- VOC topcoats 3.5 lb VOC/gal

Low

- VOC cleaning solvents Hand wipe cleaning solvent: vapor pressure less than 45 millimeters mercury (mm Hg) at 20°C or solvent meets composition requirements in Table 1 in 40 CFR 63.744

. Flush cleaning: use collection system to capture flushed solvent.
High

- transfer

- efficiency spray coating equipment HVLP, electrostatic, or other equivalent spray coating equipment

Paint gun cleaning, waste solvents, and rags Ca pture and closed containment

4.3. BACT for Natural Gas Combustion

Manufacturing of the new Boeing Model 777X will require Boeing Everett to install new natural gas combustion units. These units include process heaters, space heaters, and a gas

- fired plasma unit for surface treatment of the wing panel stringers. These new natural gas combustion

emission units are listed in T able 24 . With the exception of the natural gas combustion units associated with the vertical fin hybrid laminar flow control (HLFC) prep (WBSP 10) and HLFC spray booths (WBSP 11 a, b, and c), all the units identified in Table 24 will be located in the new wing component fabrication building.

These natural gas

- fired combustion units will emit NO X , PM 10 , PM 2.5 , CO, SO 2 , and VOCs

. Natural gas

- fired boilers and heaters less than 50 MMBtu/hr generally fall into the category of generic BACT and not case

- by

- ca se BACT

. The following section presents the generic BACT analysis for VOC from natural gas combustion units.Technical Support Document Page 40 of 96 Boeing Everett 777X Project September 9, 2014

10

– 50 MMBtu/hr

Table 24 . Proposed Natural Gas Combustion Units

Unit ID Description Rated Capacity (MMBtu/hr)

WCF

- 3a Gas

- fired process heater for autoclave #1 40

WCF

- 3b Gas

- fired process heater for autoclave #2 40

WCF

- 3c Gas

- fired process heater for autoclave #3 40

WCF

- 9a Space heating

- wing panel spray booth #1 13.34

WCF

- 9b Space heating

- wing panel spray booth #2 13.34

WCF

- 9d Space heating

– wing panel spray booth #3 13.34

WBSP

- 11a Space heating

- vertical fin HLFC spray booth #1 10.94

WBSP

- 11b Space heating

- vertical fin HLFC spray booth #2 10.94

WBSP

- 11c Space heating

- vertical fin HLFC spray booth #3 1 0.94

5

– 1 0 MMBtu/hr

Unit ID Description Rated Capacity (MMBtu/hr)

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 Range: < 10
MMBtu/hr to

< 5
MMBtu/hr

WCF

- 2 Gas

- fired heater for liquid nitrogen vaporization unit (if this option is chosen to supply autoclaves with nitrogen 8

WCF

- 10a Space heating

- wing panel prime r curing booth #1 6.67

WCF

- 10b Space heating

- wing panel primer curing booth #2 6.67

2

– 5 MMBtu/hr

Unit ID Description R ated Capacity (MMBtu/hr)

WBSP

- 10 Space heating

- vertical fin HLFC prep booth 3.69

WCF

- 9c Space heating

- wing spar spray booth 3.2

WCF

- 8a Space heating

- wing panel prep booth 2.22

WCF

- 14 Space heating

- wing spar seal booth 2.9Technical Support Document Page 41 of 96 Boeing Everett 777X Project September 9, 2014

<2 MMBtu/hr

Unit ID Description Rated Capacity (MMBtu/hr)

WCF

- 7 Gas

- fired plasma unit for treatment of wing panel stringer 1.6

WCF

- 10c Space heating

- wing spar primer curing booth 1.6

WCF

- 6a Space heating

- wing panel wash stall #1 1.11

WCF

- 6b Space heating

- wing panel wash stall #2 1.11

WCF

- 8b Space heating

- wing spar prep booth 0.534

WCF

- 6c Space heating

- wing spar and stringer wash stall #1 0.267

WCF

- 6d Space heating

- wing spar and stringer wash stall #2 0.267

4.3.1. Available Control Technologies

BACT databases from EPA (EPA, RBLC), CARB, and SCAQMD were reviewed for possible VOC control technologies that are both available on the market and proven in practice for similar sized natural gas boilers and heaters

. The review determined that no add

- on controls were listed

as BACT for similar

- sized natural gas process heaters, space heaters, or plasma surface treatment

u nits.

Acceptable control technologies included good combustion practices

. Good combustion practices require operating the combustion unit in a manner to reduce incomplete combustion

. Through the reduction of incomplete combustion, VOC emissions can be reduced

. Good combustion practices are technically feasible to control VOC emissions from the natural gas

combustion units.

Boeing will be required to implement the technically feasible control technologies of good combustion practices

. In addition, Boe ing may choose to limit fuel usage on some or all of the new combustion devices, but that will be due to establishing emission limits for the process and

not due to BACT considerations

. Thus, further discussion of economic, environmental, and energy impac ts are not necessary.

4.3.2. BACT Selection

Review of BACT databases and industry standards determined that the only technically feasible VOC control methods identified for natural gas combustion units less than 50 MMBtu/hr are good combustion practices

. Boein g will implement the identified technically feasible control option of good combustion practices as BACT for VOC emissions from combustion units less

than 50 MMBtu/hr.Technical Support Document Page 42 of 96 Boeing Everett 777X Project September 9, 2014

4.4. BACT for Emergency Generators

The 777X project will need as many as nine 2,750

- kW die sel emergency generators, and one

750

- kW diesel emergency generator for the wing component fabrication building

. These diesel

fired emergency generators will emit NO X , PM 10 , PM 2.5 , CO, SO 2 , and VOCs.

4.4.1. Available Control Technologies

The emission standards and operating limits of the emergency generators in the size range that Boeing will use for the wing component fabrication building are contained in 40 CFR 60 New Source Performance Standards, Subpart IIII, Standards of Performance f or Stationary Compression Ignition Internal Combustion Engines and are considered to be BACT

. The emission standards are provided in Sections 60.4202 and 60.4205

. These standards require emergency diesel engines of the size for the 777X project to comply with the Tier 2 emission standards in 40 CFR 89.112, which are 6.4 g/kWh for VOC and NO X combined, 3.5 g/kWh for CO, and 0.20 g/kWh for particulate

. The operating requirements for emergency stationary internal combustion engines are provided in 40 CFR 60 .4205, which generally limit non

emergency use to 100 hours per year (hr/yr)

. Boeing assumed in their permit application that each engine will operate 100 hr/yr

. Boeing’s engines will each be limited in the permit to 100 hr/yr of operation in non

- emergen cy situations

.

BACT for emergency generators is the emission standards and operating conditions established in 40 CFR 60 Subpart IIII.

4.4.2. BACT Selection

Boeing will implement the emission standards and operating conditions established in 40 CFR 60 Subpar t IIII

. Therefore, further review of economic, environmental, and energy impacts are

unnecessary.

4.5. BACT for Wing Composite Layup and Curing

The wings of the 777X will be primarily made of composite material

. The composite material is

in the form of resin pre

- impregnated tape or sheets

. The main wing components include front and rear spars, upper and lower panel stringers, and upper and lower panels

. Part layup involves the layup of composite material onto a mandrel which is preformed into the shape of the part being fabricated

. Once t he part is laid up on the mandrel, a vacuum bag is sealed around the part and the assembly is then sent to an autoclave for curing

. In the autoclave, vacuum from a vacuum pump is used to hold the bagged part under neg ative pressure while the autoclave is pressurized with nitrogen and heated to the curing temperature of up to about 350°F

. The part is then held under negative pressure for the entire curing cycle, approximately 12 to 14 hours

. Emissions during the curin g cycle are offgases from the composite material and combustion emissions from the indirect gas

- fired heater that is used to heat the nitrogen in the autoclave

. The offgases travel through the vacuum system and are exhausted by the vacuum pumpTechnical Support Document Page 43 of 96 Boeing Everett 777X Project September 9, 2014

(emission u nit WCF

- 4)

. Boeing is planning for as many as three autoclaves and six vacuum

pumps.

VOC emissions from the vacuum pumps are estimated at 1.2 tpy per pump (7.2 tpy total), and were calculated based on the volatile content of the uncured composite materi al. This VOC emission estimate is conservative because a portion of the volatiles in the uncured material may

be water that is release d from the material during curing. The estimated air flow from each of the vacuum pumps is 100 dry standard cubic feet p er minute (dscfm). This estimated air flow is consistent with the measured flow rate taken during a source test conducted on a similar vacuum pump used in a similar process at Boeing’s Frederickson facility in 2013 for an EPA Section 114 Emission Data Req uest.

The air flow from the vacuum pumps is not constant, and the emission concentrations are not

consistent

. At any time, one vacuum pump or six vacuum pumps may be operating depending on the number of parts being laid up and cured

. Emission estimates are bas ed on VOCs (and potentially non

- VOCs like water) lost from the material during the entire layup and curing process, but emissions may be higher at certain times during the process than others

. The estimated emission concentrations are low (approxi mately 7.5 x 10 - 5 lb VOC/dscf, or less than 0.05 percent, on average) with the balance of the emissions being ambient air.

4.5.1. Available Control Technologies

Composite processing, except for some cleaning, coating, and composite tooling operations, is

not co vered under 40 CFR 63, Subpart GG

. BACT databases from EPA (EPA, RBLC), CARB, and SCAQMD were reviewed for possible control technologies that are both available on the market and proven in practice in the aerospace or other industries that manufacture ite ms from composite molds

. The search provided one determination for the production of structural honeycomb for aerospace and other industrial applications by Hexcel Corporation (Hexcel)

. The search also provided two determinations since the year 2000 for polyester resin operations, Lasco Bathware and Jacuzzi Whirlpool Bath

. The database provided very little information about the Hexcel operation or the type of composite material used in the process

. The bathtub manufacturing facilities use a liquid polye ster thermosetting resin t hat contains styrene

monomer.

The wing components will be made of a material containing an epoxy resin rather than a polyester resin, and the resin is pre

- impregnated into a woven fabric (prepreg)

. The composition

and emission characteristics of the prepreg woven fabric emissions are significantly different than polyester resin emissions

. Boeing also looked at carbon adsorption, which is a typical control technology for VOC emissions from a process with a stack

. The potential control technologies are presented in Table 25

.Technical Support Document Page 44 of 96 Boeing Everett 777X Project September 9, 2014

Table 25 . Potential Control Technologies for VOCs for Composite Layup and Curing

Control Technology Database
Reference Date Implemented Control Efficiency Emission

Limit

Thermal oxidizer or
RTO EPA, BACT Clearinghouse

– Hexcel 11/25/2009 95%

Regenerative thermal

oxidizer w / concentrator EPA, BACT Clearinghouse

– Lasco

Bathware 3/13/2007 95% 14.84 lb/hr

RTO w / concentrator CARB, BACT Clearinghouse

– Jacuzzi Whirlpool

B ath 10/15/2002 90%

Carbon adsorption Often used for control
of VOC emissions NA >95%

4.5.2. BACT Feasibility Review

Currently, there is no control technology demonstrated in practice for the composite processing

vacuum pumps

. The only information provided for the Hexcel process were the emissions from an oven used for the curing of honeycomb blocks and the main hazardous air pollutant (HAP) of concern was acetaldehyde

. Acetaldehyde may be present in the prepreg material Boeing uses, but it is not a significant component of the material

. There was no information provided in the BACT determination about the type of materials used in the Hexcel process, the airflow rate, or the emission rates from the operation

. Based on this in formation, it could not be determined whether the Hexcel process was similar to Boeing’s process.

4.5.3. RTO with Concentrator

The bathtub manufacturing facilities use a polyester thermosetting resin that contains styrene

monomer to manufacture bathtubs

. The Lasco Bathware process has an average throughput of raw materials of 0.645 ton per hour, which includes gelcoat, laminate, and barrier coat, all of which contain styrene monomer in a liquid state

. The raw materials are sprayed into open molds in a spray b ooth

. There was no emission rate information provided for Jacuzzi Whirlpool Bath.

The VOCs released from the process are drawn into a concentrator, which captures the VOCs by adsorption

. Hot gas desorbs the VOCs, which are then fed to the thermal oxidiz er for

incineration

. The overall efficiency for capture and control is estimated to be 90 to 95 percent.

Boeing’s composite process will use a prepreg containing an epoxy resin rather than a coating containing a polyester resin

. The resin comes pre

- impr egnated into a woven material and is not in a liquid state

. The vacuum pump flow rate and concentration of VOCs in the air stream are significantly lower than for the spray booths at Lasco Bathware

. This assumption is based on theTechnical Support Document Page 45 of 96 Boeing Everett 777X Project September 9, 2014

emission limit of 14.8 lb/hr with a control of 95 percent listed in the determination

. This should

b e compared to the maximum expected uncontrolled emission rate of less than one pound per hour for each vacuum pump

. In addition, combination concentrators or carbon adsorbers an d thermal oxidizers are intended for sources with high air flow and a high enough VOC emission

rate to make thermal oxidation viable

. The autoclave process does not meet either of these

criteria

. Individually, combustion of the VOC emissions and carbon a dsorption has additional

issues which are discussed below.

4.5.4. Thermal Incineration

Hexcel uses a thermal oxidizer or regenerative thermal oxidizer to combust the VOC emissions from the process

. When using combustion units for VOC control, the VOC emissions in an air stream are injected into a burner or chamber that destroys those emissions prior to release to the atmosphere through a stack.

The air flows from the vacuum pumps are not constant and the emission concentrations are not

consistent

. At any time , one vacuum pump or six vacuum pumps may be operating, depending on the number of parts to be laid up and cured

. Emission estimates are based on VOCs lost from the material during the entire layup and curing process, but emissions may be higher at certai n times during the process than others

. The VOC concentrations in the air stream exhausted by the vacuum pump are also very low, about 7.5 x 10 - 5 lb VOC/dscf on average, with the balance of the emissions being ambient air

. Even without knowing the exact heat content of the VOCs, it is evident that the concentration of the VOCs in the offgas is low, less than 0.05 percent

. Therefore, the heat content of the offgas will be low

. The combination of variable operation,

variable flow rates and low heat conten t for the offgases make destruction of the offgases in a

combustion device infeasible.

4.5.5. Carbon Adsorption

Carbon adsorption uses a filter bank of canisters that contain activated carbon, which adsorbs the VOC emissions from the air stream as it passes through the carbon before being released to the atmosphere

. Carbon adsorption has not been used in practice on any aerospace composite layup and curing operation

. However, carbon adsorption has been used on other low flow, low

- VOC sources, and is a feasi ble option for offgases with the characteristics described above.

4.5.6. Ranking of BACT by Control

Carbon adsorption is the only add

- on option that is feasible

. A well designed and operated carbon adsorption system can consistently demonstrate VOC removal eff iciencies over 95

percent.Technical Support Document Page 46 of 96 Boeing Everett 777X Project September 9, 2014

4.5.7. Cost

- Effectiveness Evaluation

Vendor information for the carbon adsorption technology was obtained from Thermal Recovery Systems

. Based on Boeing’s situation, potential contaminants and their concentration, the

temperature of the emission, and the high humidity ( 3 percent by volume); Thermal Recovery Systems thought that between 5 and 10 percent weight capacity for the activated carbon would be required

. If 8 percent was used as the target, it was believed it would take 90 tons of carbon

to control 7.2 t py of emissions

. The cost in carbon alone would be over $225,000 per year, or over $31,000 per ton operating costs

. Based on this cost, Ecology agrees with Boeing

t hat carbon adsorption is not cost

- effective.

4.6. BACT for Cru sh Core Press

In a crush core press, a composite “sandwich” layup co nsisting of a lightweight honey comb core material sandwiched between sheets of resin pre

- impregnated woven fabric (prepreg) is placed between heated matched dies and then the press is use d to apply pressure to the dies until the resin in the prepreg sheets cures and hardens (emission unit IRC

- 3)

. At the Boeing Everett IRC, crushed core presses are used to fabricate all Boeing airplane models’ cabin interior panels, which are ceilings and sidewalls

. Most of the emissions from the crushed core press come from the mold release agent that is applied to the surface of the matched dies

. Some VOCs are also released by the curing prepreg.

Emissions from the crush core press were calculated bas ed on the VOC content of the mold release and prepreg, and the estimated volume of those materials to be used over a year

. The estimated volume of materials to be used in the new crush core press was based on the volume of materials used in the existing c rush core presses at Boeing Everett

, and includes a safety factor of three to ensure that the potential VOC emissions from the press were not under estimated. For the prepreg , the estimated VOC emissions are conservative since it is assumed all the volatiles released from the curing prepreg are VOCs, whereas a significant portion of the volatiles may be

water

. The estimated air flow from the crush core press operation is 7,50 0 cfm

. The total VOC emission from the unit is 4,500 lb/yr or 2.25 tpy

.

4.6.1. Available Control Technologies

Composite processing, except for some cleaning, coating, and composite tooling operations, is not covered under the Aerospace NESHAP (40 CFR 63, Subpa rt GG)

. BACT databases from EPA (EPA, RBLC), CARB, and SCAQMD were reviewed for possible control technologies that are both available on the market and proven in practice in the aerospace or other industries that manufacture items from composite molds

. T here were no determinations found for a crush core

pres s operation

. The search provided one determination for the production of structural honeycomb for aerospace and other industrial applications by Hexcel

. The database provided very little information about the Hexcel operation or the type of composite material used in the

process.Technical Support Document Page 47 of 96 Boeing Everett 777X Project September 9, 2014

The crush core press process is similar to the composite layup and curing operation in that it uses resin pre

- impregnated fabric, but the prepreg used in the crush core proc ess contains a phenolic resin rather than an epoxy resin

. However, an estimated 90 percent of the emissions come from the use of the mold release compounds

. Since there were no control technologies for aerospace crush core press emissions in the database s, Boeing also looked at typical control technologies for VOC emissions from a process with a stack

. The potential control technologies are presented

in Table 26

.

Table 26 . Potential Control Technologies for VOCs for Crush Core P ress

Control Technology Database
Reference Date Implemented Control Efficiency

Thermal oxidizer or regenerative thermal

oxidizer EPA, BACT Clearinghouse

– Hexcel 11/25/2009 95%

Regenerative thermal

oxidizer w / concentrator Often used for control of
VOC emissions N / A >90%

Carbon adsorption Often used for control of
VOC emissions N / A >95%

4.6.2. BACT Feasibility Review

Currently, no control technologies have been found in practice for the crush core press operation

. It could not be determined if the Hexcel process was applicable because the only information provided for the Hexcel process was that the emissions were from an oven used for the curing of honeycomb blocks and t he main HAP of concern was acetaldehyde

. Ace taldehyde may be present in the emissions from the press, but is not a significant component of the prepreg material and should not be present in the mold release agent

. There was no information provided in the BACT determination about the type of materia ls used in the Hexcel process, the airflow rate, or the emissions from the operation

. Based on this information, it could not be determined whether the Hexcel process was similar to Boeing’s process.

4.6.3. RTO with Concentrator

The VOCs released from the proc ess are drawn into a concentrator, which captures VOCs by adsorption

. Hot gas desorbs the VOCs, which are then fed to the thermal oxidizer for

incineration

. The overall efficiency for capture and control is estimated to be 90 to 95 percent.

Combination concentrators or carbon adsorbers and thermal oxidizers are intended for sources with high air flow and a high enough VOC emission rate (lb/hr) to make thermal oxidation

viable

. The emission rate needs to be high enough to produce a moderately concentrate d

emission from the outlet of the concentrator

. The crush core press flow rate and emission rate do

not meet either of these criteria

. Individually, combustion of the VOC emissions and carbon adsorption has additional issues which are discussed below.Technical Support Document Page 48 of 96 Boeing Everett 777X Project September 9, 2014

4.6.4. Th ermal Incineration

Hexcel uses a thermal oxidizer or regenerative thermal oxidizer to combust the VOC emissions from the process

. When using combustion units for VOC control, the VOC emissions in an air stream are injected into a burner or chamber that d estroys those emissions prior to release to the atmosphere through a stack.

The emission concentrations in the exhaust from the crush core press are low, approximately 8 x

10 - 8 lb VOC/dscf on average, with the balance of the emissions being ambient air

. Even without knowing the exact heat content of the VOCs, it is evident that the concentration of VOCs in the offgas are low, and therefore the heat content of the offgas will be low

. In addition, the concentration of the VOCs in the offgas is very low, conservatively as much as 15 parts per million ( ppm ) , but more likely near 7 ppm

. Thermal oxidizers have demonstrated poor destruction efficiencies when the inlet concentrations are very low

. The Bay Area BACT guidelines for an oxidizer or adsorber are typically:

• Less than 10 ppm at outlet; or

• Greater than 98.5 percent destruction/recovery efficiency if inlet VOCs are greater than 200 to less than 2,000 ppm; or

• Greater than 97 percent efficiency if inlet VOCs are greater than 200 to less t han 2,000 ppm; or

• Greater than 90 percent efficiency if inlet VOCs are less than 200 ppm.

Some EPA standards allow up to 20 ppm at the outlet

. The uncontrolled emission concentration for the crush core press is actually lower than the Bay Area BACT guide lines typical emission

limit.

The low heat content for the offgases and low concentration of VOCs make destruction of the offgases in a combustion device not a feasible option.

4.6.5. Carbon Adsorption

Carbon adsorption uses a filter bank of canisters that contain activated carbon, which adsorbs the VOC emissions from the air stream as it passes through the carbon before being released to the atmosphere

. Carbon adsorption has not been used in practice on any aerospace crush core press operation

. However, c arbon adsorption has been used on other low

- flow, low

- VOC sources.

4.6.6. Ranking of BACT by Control

Carbon adsorption is the only option that is feasible

. A well designed and operated carbon adsorption system can consistently demonstrate VOC removal efficienc ies over 95 percent.Technical Support Document Page 49 of 96 Boeing Everett 777X Project September 9, 2014

4.6.7. Cost

- Effectiveness Evaluation

Vendor information for carbon adsorption technology on the vacuum pumps for the composite layup and curing process was obtained from Thermal Recovery Systems

. Thermal Recovery Systems informed Boeing t hat based on the potential contaminants listed and their concentrations, the temperature of the emission, and the high humidity (3 percent by volume )

, they would expect between 5 and 10 percent weight capacity for the activated carbon

. If they used 8 perc ent as their target, they believe it would take 90 tons of carbon to control 7.2 tpy of

emissions

. The cost in carbon would be over $225,000 per year, or over $31,000 per ton operating costs

. This does not include capital cost or labor cost.

The crush c ore press emission concentration of 8 x 10 - 8 lb VOC/ dscf is significantly lower, and the air flow is significantly higher at 7,500 cfm than the emissions from the autoclave vacuum pumps (7.5 x 10 - 5 lb VOC/dscf and air flow of 100 to 600 cfm)

. Because one of the mechanisms in the adsorption of compounds on carbon is the concentration gradient, or the difference between the concentration of the VOCs in the offgas and the concentration of the compound in the carbon, lower concentrations tend to ha ve a negative effect on the weight capacity of the

carbon

. Increases in air flow may also lead to a decrease in the weight capacity of the carbon

. Based on the $31,000 per ton operating cost for carbon on the composite layup and curing vacuum pumps, and the expected even lower weight capacity and potential increase in operating cost for the crush core process, Boeing concluded that carbon adsorption is not cost

- effective

. Ecology agrees with this assessment

. In addition, the inlet concentration is less than the Bay Area BACT typical emission limit of 10 ppm VOC.

4.6.8. BACT Selection

Because no control technologies have been demonstrated to be effective in practice on a crush core press, and a cost estimate for just the carbon needed for a carbon adsorption s ystem exceeds $31,000 per ton of VOC removed, Boeing does not consider any of the identified add

- on control technologies in Table 26 to be technically or economically feasible for Boeing Everett

. Ecology agrees with this conclusion

. Boeing will continue to implement the use of low

- VOC emitting prepreg materials to minimize VOC emissions from the process.

4.7. BACT for Open Floor Emissions

Open floor emissions are also known as fugitive emissions, and are typically emissions that result from hand application of cleaners, sealants, and coatings that are not done in a confined area such as a paint booth

. These activities occur throughout the manufacturing process and in very large buildings

. The emissions exit the buildings via various openings (e.g., hangar d oors, roll

- up doors, vents

, and general building air handling systems )

. The VOC emissions result from the VOCs in the various solvents or coatings

. This BACT analysis considers those technologies that reduce fugitive VOC emissions from the open floor act ivities that will take place in the new wing component fabrication process

. Open floor activities that will take place as part of wing assembly, body section assembly, airplane assembly, and other related operations are notTechnical Support Document Page 50 of 96 Boeing Everett 777X Project September 9, 2014

addressed here because these op erations will take place in existing buildings where these open floor activities already occur.

4.7.1. Wing Component Fabrication

The wings of the 777X will be primarily made of composite material

. The main wing components include front and rear spars, uppe r and lower panel stringers, and upper and lower panels

. The manufacturing process of each of these parts is similar and involves the following major steps:

• Wing component part layup

• Curing in an autoclave

• Trimming and drilling

• Washing

• Non

- destructive inspection

• Preparation for priming (e.g., abrading, solvent cleaning)

• Priming

• Wing component part build

- up

Fugitive VOC emissions can be generated by the following activities.

Part layup : Part layup involves the manual or automated layup of composite ma terial (in the form of resin pre

- impregnated tape or sheets) onto a mandrel which is preformed into the shape of the part being fabricated

. Emissions associated with the part layup primarily occur from preparing the mandrel prior to the actual part layup process

. Preparing the mandrel involves cleaning the surface with solvent, applying a mold release compound, and applying a tackifier

solution.

Wing component cleaning : Open floor emissions from wipe cleaning primarily occur during the part buildup process, but can occur throughout the manufacturing process.

Sealing and touch up coating : Open floor emissions from the application of sealant and miscellaneous coatings will primarily occur during the part buildup process, but can occur throughout the manufacturing process

. Most of the coating of the wing components will take place in the spray booths and will not result in open floor emissions.

Open floor VOC emissions from the wing component fabrication building are estimated to be

128 tpy

.

4.7.2. Availa ble Control Technologies

The open floor activities listed above are addressed and regulated under 40 CFR 63

, Subpart GG, Aerospace NESHAP

. In addition, the VOC emission standards for uncontrolled use of cleaning solvents and coatings are defined in 40 CF R 63

, Subpart GG

, Aerospace NESHAP

. TheseTechnical Support Document Page 51 of 96 Boeing Everett 777X Project September 9, 2014

requirements will be applied to these activities

. Because of the nature of these open floor activities and the fugitive emissions generated by the activities (e.g., numerous locations, low VOC concentrations, and low emission rates), and the fact that they may occur anywhere in the manufacturing process

, capture and control of the fugitive emissions is not feasible

. This conclusion is supported by the fact that in developing the Aerospace NESHAP, EPA has

determin ed that work practices rather than emission standards are the only practical way to regulate these open floor emissions.

Boeing uses good work practices ( Table 27 ) to minimize VOC emissions, including storing coatings and solvents in closed containers and bagging solvent hand wipe cleaning rags when not

in use

. The Aerospace NESHAP regulation require s low

- VOC cleaners and coatings, and these work practices

. Therefore, these techniques are considered the base case for BACT.

Table 27 . Summary of Aerospace NESHAP VOC Emission Standards Applicable to the New and Modified Emission Units of the 777X Project

Production Activity Control Technology

Low

- VOC primers Large commercial aircraft component exteriors: 5.4 lb VOC/gal. All other applications: 2.9 lb VOC/gal

Low

- VOC topcoats 3.5 lb VOC/gal

Low

- VOC cleaning solvents Hand wipe cleaning solvent: vapor pressure less than 45 mm Hg at 20°C or solvent meets composition requirements in Table 1 in 40 CFR 63.744. Flush cleaning: use collection system to capture flushed

solvent.

High

- transfer

- efficiency spray coating equipment HVLP, electrostatic, or other equivalent spray coating equipment
Paint gun cleaning, waste solvents, and rags Capture and closed containment

4.7.3. BACT Feasibility Review

The use of low

- VOC cleaners and coatings, and good work practices in compliance with the 40

CFR 63

, Subpart GG

, Aerospace NESHAP requirements have been demonstrated and achieved in practice and are therefore considered feasible technologies to implement for the open floor activities in the new wing component fabrication building

. Boeing believes this is the base c ase for BACT, and uses these techniques for its current operations.

Boeing will implement all of the base case BACT techniques. Thus, further review of economic environmental and energy impacts is unnecessary.

4.7.4. BACT Selection

Boeing will continue to im plement the use of low

- VOC coatings and cleaners, and good work practices to minimize fugitive VOC emissions in compliance with the 40 CFR 63

, Subpart GG

, Aerospace NESHAP

.

Based on this information, Ecology believes the proposed limits meet BACT require ments.Technical Support Document Page 52 of 96 Boeing Everett 777X Project September 9, 2014

4.8. Toxic Air Pollutants

PSD rules require the applicant to consider emissions of TAPs during the course of a BACT analysis, but specifically exempt all pollutants subject to regulation under Section 112 of the federal Clean Air Act from regulation und er the PSD program.

The emissions of TAPs will be covered in the PSCAA NOC approval for this project.

5. AMBIENT AIR QUALITY IMPACTS ANALYSIS

5.1. Regulatory Requirements

For PSD, an ambient Air Quality Impacts Analysis (AQIA) is required for all pollutants that are emitted in significant quantities to determine the ambient impacts associated with the construction and operation of the proposed modifications. The main purpose of the air quality analysis is to demonstrate that new emissions emitted from the pr oposed major stationary source or major modification will not cause or contribute to a violation of any applicable NAAQS or

PSD increment.

The AQIA starts with preliminary modeling for each pollutant to determine whether an applicant can forego detailed a nalysis and preconstruction monitoring. If the projected ambient concentration increase for a given pollutant is below the PSD Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMCs) for each averaging period, no further analysis of the ambient impact is required for that pollutant.

For those pollutants with averaging periods that have impacts greater than the SIL, a full impact analysis is used to demonstrate compliance with NAAQS and PSD increments.

Typically, the AQIA includes an analysis of impacts to local areas that are within 50 kilometers (km) of the project, and a regional air quality impact assessment for impacts beyond 50 km. For projects in Washington State, this latter analysis usually includes impacts on Cla ss I areas.

5.2. Impacts on Class I Areas

Because the proposed emission increase in VOCs from the Boeing Everett 777X project would exceed 100 tpy, there must be a demonstration that the project would not cause or significantly

contribute to a violation of th e ozone NAAQS

. Furthermore, PSD rules require an analysis of air quality related values (AQRVs) on federally designated Class I areas

. Federally mandated Class I areas are defined in the Clean Air Act as having special national or regional value from a

n atural, scenic, recreational, or historic perspective

. Class I areas include national parks over 6,000 acres and wilderness areas and memorial parks over 5,000 acres as of 1977

. The impacts to these areas are stringently regulated because they have remai ned relatively untouched by development

. Therefore, in addition to tighter PSD increment standards for criteria airTechnical Support Document Page 53 of 96 Boeing Everett 777X Project September 9, 2014

pollutants, additional analyses of air quality impacts on Class I areas are required. Class I areas within 200 km of the Boeing Everett facility are listed in Table 28

.

Table 28 . Class I Areas within 200 KM of the Boeing Everett Facility

Area Distance from Boeing Everett
to Class 1 Area (km) VOC Emissions Increase (Qty.) Divided by Distance (Q/D) (tons VOC/km) Allowable VOC Emissions Increase (Qty.) Divided by Distance (Q/D) (tons VOC/km)

Alpine Lakes Wilderness Area 60 6.9 5.7

Glacier Peak Wilderness Area 70 5.9 4.9

Mount Baker Recreation Area 90 4.6 3.8

Olympic National Park 91 4.6 3.7

North Cascades National Park 108 3.9 3.2

Mount Rainier National Park 123 3.4 2.8

Goat Rocks Wilderness Area 205 2.0 1.7

AQRVs include impacts on visibility, soil, flora, fauna, and aquatic resources within the Class I

area

. The Federal Land Managers’ (FLMs) guidance on evaluating impacts of major projects on

Class I areas is the F ederal Land Managers’ Air Quality Related V alues Work Group (FLAG) Phase I Report

– revised (2010) (National Park Service, 2010)

. In FLAG, the FLMs have developed a tool to screen out projects that would not have a significant impact on AQRVs based

on annual emissions and distance from a Class I a rea

. This screening tool is called the Q/D Method, which is to divide the amount of emission increases in tons per year (Q) by the distance to a federal Class I area in km (D)

. FLAG states that “The FLM role within the regulatory

context consists of cons idering whether emissions from a new source, or emission increases from a modified source, may have an adverse impact on AQRVs and providing comments to permitting authorities (States or EPA)

. Therefore, the agencies will consider a source locating

greate r than 50 km from a Class I area to have negligible impacts with respect to Class I AQRVs

if its total SO 2 , NO

x , PM 10 , and H 2 SO 4 (sulfuric acid) annual emissions (in tons per year, based

on 24

- hour maximum allowable emissions), divided by the distance (in km) from the Class I area (Q/D) is 10 or less

. The agencies would not request any further Class I AQRV impact analyses from such sources.” For the 777X project, the only pollutant that would have a significant increase is VOC. VOC is not among the polluta nts that the FLMs recommend including in the calculation of Q

. While VOCs and NO

x are recognized as precursors to the formation of ground level ozone, which is regulated as a criteria pollutant, the FLAG guidance states that “current

information indicates most FLM areas are NO

x limited” with respect to the formation of ground

level ozone

. A NO

x limited region is one where the concentration of ozone depends on the amount of NOx in the atmosphere. This occurs when there is a lack of Nitrogen Dioxides, thus inhibiting ozone titration when oxygen mixes with VOCs. In these regions, controlling NO

x would reduce ozone concentrations. A VOCs limited region is one where concentration of ozone depends on the amount of VOCs in the atmosphere. In these regions, co ntrolling VOCs would

reduce ozone concentrations. The FLAG guidance further states that “until there is enoughTechnical Support Document Page 54 of 96 Boeing Everett 777X Project September 9, 2014

information available for FLAG to determine whether ozone formation in each FLM area is primarily limited by NO

x or VOC emissions, we will assum e all FLM areas are NOx limited and

will focus on control of NO

x emissions” (FLAG Executive Summary and Section 3.4.5)

. Because there has not been a demonstration that ozone formation in the Puget Sound region’s

Class I areas is not NO

x - limited and VOC is the only pollutant that is expected to have a significant increase as a result of the 777X project, there is no need to perform the Q/D analysis and it is presumed that the 777X project will have no significant adverse impacts on Class I

areas. 2

5.3. Ozone Im pacts

VOCs are a precursor to ozone

. Boeing’s proposed increase in VOC emissions is greater than 100 tpy and therefore requires an analysis of the effect that the proposed increase in emissions of

VOCs would have on the area’s ozone levels

. The analysis of the 777X project is discussed

below.

EPA has set primary and secondary ozone standards to protect human health and welfare

. On March 12, 2008, EPA revised the primary and secondary ozone standards to 0.075 ppm for an 8

- hour average.

Ozone is formed in the troposphere when sunlight causes complex photochemical reactions involving oxides of nitrogen (NO X ), VOCs, and carbon monoxide (CO) that originate chiefly form gasoline engines and burning of other fossil fuels

. Woody vegetation is another major

s ource of VOC emissions to NO X emissions within the surrounding airshed, and the relative reactivities of the VOC species

. NO X and VOCs can be transported long distances by regional weather patterns before they react to create ozone in the atmosphere, wher e it can persist for

several weeks

. Because ozone is a regional pollutant, precursor sources both near and far can

contribute to ozone formation.

Breathing ozone can trigger a variety of health problems for humans, including chest pain, coughing, throat irritation, and congestion

. It can worsen bronchitis, emphysema, and asthma

. Elevated levels of ozone can also reduce lung function by inflaming the linings of the lungs

. Repeated exposure to elevated concentrations of ozone may permanently scar lung ti ssue

. Ozone is also phytotoxic, causing damage to a variety of vegetation (Ashmore et al., 2004)

. Ozone pollution has been shown to reduce plant growth, alter species composition, and predispose trees

to insect and disease attack

. Ozone also causes dire ct foliar injury to some plant species

. Ozone affected leaves are marked with discoloration and lesions, and they age more rapidly than normal leaves (EPA, 2007 )

.

2 Nonetheless, for informational purposes the 777X project’s Q/D fo r all Class I areas within 200 km are shown in

column 3 of Table 28 where Q is that annual emission rate of VOC. A s shown in column 3 of Table 28 , the ratio of Q/D would be less than 10 for all the Class I areas and

, according to the FLAG guidance

, it co uld be presumed that the project would have no significant adverse impacts on Class I areas. Table 28 also shows that the combined proposed increases in the annual VOC emissions limits in the existing PSD permits 91

- 06, 05

- 02, and 11

- 01, would

also result in Q/ D being less than 10.Technical Support Document Page 55 of 96 Boeing Everett 777X Project September 9, 2014

Ozone enters plants through leaf stomata, causing changes in biochemical and physiological

process

. The mesophyll cells under the upper epidermis of leaves are the most sensitive to ozone, and those are the first cells to die

. The adjacent epidermal cells then die, forming a small

black or brown interveinal necrotic lesion that becomes visible on the upper surface of the leaf

. These lesions, termed oxidant stipple, are quite specific indicators that the plant has been exposed to ozone

. There are other plant symptoms that can result from exposure to ozone

. However, these symptoms are non

- spec ific for ozone since other stressors can also cause them to

occur

. In general, the most reliable indicator that ozone has impacted vegetation is oxidant stipple.

In addition to effecting individual plants, ozone can also affect entire ecosystems

. Plants growing in areas with high exposure to ambient ozone may undergo natural selection for ozone tolerance (EPA, 2007)

. The final result could be the elimination of the most ozone sensitive genotypes from the area (National Park Service, 2010).

In the Clas s I areas closest to Boeing Everett, several species are known to be sensitive to ozone, including quaking aspen ( Populus tremuloides ), spreading dogbane ( Apocynum androsaemifolium ), subalpine fir ( Abies lasiocarpa ), black cottonwood ( Populus trichocarpa ), and ponderosa pine ( Pinus ponderosa ) (Brace et al., 1998)

. These sensitive species have been systematically evaluated and no ozone injury has been documented in the parks.

In a previous PSD permit application for the 787 project (PSD 05

- 02), Boeing repo rted that 297 tpy of VOC emissions would not cause or significantly contribute to an exceedance of any NAAQS or PSD increment

. The study reported a projected maximum increase in ozone concentration of about 0.1 parts per billion (ppb) from a 297 tpy incre ase in V OC emissions

. This is a small fraction of the national ambient air quality standard for ozone of 75 ppb for an 8

- hour average

. Similarly, for the 737 MAX project in Renton (PSD 12

- 01), Boeing noted that a 384 tpy increase from Boeing’s Renton fac ility would not cause or significantly contribute to an exceedance of any NAAQS or PSD increment and in the worst case would only increase the maximum ozone concentration by less than 0.35 ppb

. As shown in Table 7, Boeing is proposing to increase Boeing E verett’s allowed VOC emissions by 308.2 tpy

. This is within the range that Ecology previously review ed and determined will not have a significant adverse impact on air quality

. Therefore, an additional air quality impact analysis addressing the impact of VOC emissions from the 777X project is not required.

6. ADDITIONAL IMPACTS ANALYSIS

6.1. Air Quality Related Values (AQRV)

PSD regulations and guidance require an evaluation of the effects of the 777X project’s emissions on visibility, local soils, and vegeta tion in Class I and II areas, the effect of increased air pollutant concentrations on flora and fauna in the Class I areas, and the effect of the project on construction and population growth in the area surrounding the project. The analyses assess

incre ment consumption and impacts on AQRVs in Class I areas. AQRVs include regionalTechnical Support Document Page 56 of 96 Boeing Everett 777X Project September 9, 2014

visibility or haze, the effects of primary and secondary pollutants on sensitive plants, the effects of pollutant deposition on soils and receiving water bodies, and other effe cts associated with secondary aerosol formation. The FLMs for the National Park Service, U.S. Fish and Wildlife Service, and U.S. Forest Service have the responsibility of ensuring AQRVs in the Class I areas are not adversely affected.

PSD regulations and guidance require additional impact analyses to evaluate the effects of the project’s emissions on visibility, local soils, and vegetation in Class I and II areas, and the effect of increased air pollutant concentrations on flora and fauna in the Class I areas. The additional impact analyses are also used to evaluate the effect of the project on growth in the area surrounding the project.

6.2. Growth Analysis

6.2.1. Construction and Growth Impacts

Employment at Boeing Everett is expected to increase by no more than 3,000 employees as a result of the 777X project

. This growth is less than 10 percent of the potential 45,000 employees at the Boeing Everett facility that were added in the S outhwest Everett EIS and Planned Action (City of Everett, 1997)

. Additional ly, there will not be a significant increase in congestion on Washington’s roads and highways as a result of the project

. The details of the congestion discussion may be found in SEPA Addendum #1 (Revised) S outhwest Everett Planned Action

EIS SEPA #13

- 019 in Appendix E

. Therefore, the proposed 777X project is not expected to cause adverse construction and growth related impacts.

6.3. Soils and Vegetation Analysis

EPA guidance 3 for most types of soils and vegetation, ambient concentrations of criteria polluta nts below the secondary NAAQS will not result in harmful effects

. Only the VOC emissions from the 777X project are subject to PSD review

. VOC is regulated as a precursor to

ozone

. However, ozone has no secondary NAAQS

. In addition, the expected VOC emi ssions from the 777X project do not trigger a detailed AQIA for Class I area

. The incremental increase in ozone concentrations directly attributable to the 777X project would be less than about 0.4 ppb on an hourly average

. Consequently, the impacts on l ocal soils, vegetation, and animals attributable to the 777X project will be negligible.

FLAG guidance does not indicate a specific BOC impact on vegetation in the Pacific Northwest.

The National Park Service has established monitors for ozone in three C lass I areas in the s tate of Washington. The three sites are Mount Rainer National Park, Olympic National Park, and North Cascades National Park. As previously discussed in the TSD, in the past Boeing demonstrated

that similar incremental concentrations less than about 0.4 ppb on an hourly average which is a

3 Draft EPA New Source Review Workshop Manual, Chapter D, § IIC (EPA, 1990).Technical Support Document Page 57 of 96 Boeing Everett 777X Project September 9, 2014

very small fraction of the NAAQS of 75 ppb on an 8

- hour average. Therefore, the increase in ozone from the 777X project is not likely to harm vegetation or animals.

Project emissions that have the most potential to affect soils and vegetation are those that contain either sulfur or nitrogen. SO 2 and NO X are not subjected to PSD review for this project because their emissions are less than their respective SERs. As a result, no deposition analysis was required, but this analysis was conducted and is included in the application.

7. ENDANGERED SPECIES ACT

Pursuant to Section V.A. of the Agreement f or t he Delegation o f t he Federal Prevention of Significant Deterioration Program from the United States Environmental Protection Agency to the Washington State Department of Ecology, dated December 10, 2013, Ecology shall not issue a PSD permit until EPA has notified Ecology in writing that EPA has satisfied its obligations, if any, under Section 7 of the Endangered Species Act (ESA), 16 U.S.C. § 1531 et seq., and 50 CFR Part 402, Subpart B (Consultation Procedures), and with Section 305(b)(2) of the Magnuson

- Stevens Fishery and Conservation Act (Magnuson

- Stevens Act, MSA), 16 U

. S

. C

. § 1801 et seq., 50 CFR Part 600, Subpart K (EFH Coordination, Consultation, and Recommendations), for federal PSD permits, regarding essential fish habitat. Therefore, the final PSD permit will not be issued for this project until EPA has notified Ecology that this consultation has been completed.

On August 19, 2014, EPA notified Ecology that they have satisfied their obligations under the

ESA and the M SA relative to this permitting action. No furt her ESA or MSA consultation was

undertaken relative to this action.

8. STATE ENVIRONMENTAL POLICY ACT (SEPA)

Under Washington State rules, a final PSD permit shall not be issued for a project until the applicant has demonstrated that SEPA review has been completed for the project. The City of

Everett is the lead agency for SEPA.

On December 10, 2013, the City o f Everett Approved SEPA Addendum #1 (Revised) Southwest Everett Planned Action EIS, SEPA #13

- 019

. Ecology concludes that the applicant has adequately demonstrated compliance with SEPA requirements.

9. PUBLIC INVOLVEMENT

This PSD permitting action is subjec t to a minimum 30

- day public comment period under WAC

173

- 400

- 740

. A newspaper public notice announcing the public comment period was published in the Daily Herald on August 1 , 2014

. In accordance with WAC 173

- 400

- 740(2)(a), application

materials and oth er related information were made available for public inspection at:Technical Support Document Page 58 of 96 Boeing Everett 777X Project September 9, 2014

City of Everett Main Library 2702 Hoyt Avenue Everett, WA 98201

Washington State Department of Ecology Air Quality Program

300 Desmond Drive SE Lacey, WA 98503

A public meeting and hearing on the proposed PSD permit was held at 6:30 PM PDT on September 2, 2014, at the Future of Flight Aviation Center in the Forward Cabin Conference Room, 8415 Paine Field Boulevard, Mukilteo, Washington 98275. No comments were

submitted at the hearin g.

The public comment period closed on September 3, 2014, at 5 PM PDT

. No comments were

submitted.

10. AGENCY CONTACT

Marc Crooks, P.E. Washington State Department of Ecology Air Quality Program

P.O. Box 47600 Olympia, WA 98504

- 7600 (360) 407

- 6803 marc.crooks@ecy.wa.govTechnical Support Document Page 59 of 96 Boeing Everett 777X Project September 9, 2014

APPENDIX A. BACKGROUND PSD APPLICABILITY ANALYSIS FOR THE 777X

AND PRODUCTION RATE INCREASETechnical Support Document Page 60 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 61 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 62 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 63 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 64 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 65 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 66 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 67 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 68 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 69 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 70 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 71 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 72 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 73 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 74 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 75 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 76 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 77 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 78 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 79 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 80 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 81 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 82 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 83 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 84 of 96 Boeing Everett 777X Project September 9, 2014

APPENDIX B. ESTIMATE OF NON

- SIGNIFICANT PSD POLLUTANT EMISSIONS

INC REASES FROM THE 777X PROJECTTechnical Support Document Page 85 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 86 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 87 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 88 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 89 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 90 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 91 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 92 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 93 of 96 Boeing Everett 777X Project September 9, 2014Technical Support Document Page 94 of 96 Boeing Everett 777X Project September 9, 2014

REFERENCES

Ashmore, M., Karlsson, P.E., and H . Pleije

, New directions: a new generation of ozone critical

levels for the protection of vegetation in Europe (correspondence)

, Atmospheric

Environment , 38: 2213

- 2214, 2004

.

Brace, S.

, Peterson, D. L., and D. Horner

, Diagnosing Ozone Injury in Vascular Plants of the Pacific Northwest, U.S. Department of Agriculture, Forest Service, Paci fic Northwest Research Station, 1998

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ACRONYMS AND ABBREVIATIONS

° F degrees Fahrenheit

μ g/m 3 micrograms per cubic meter

ALW Alpine Wilderness

AQIA Air Quality Impacts Analysis

AQRV Air Quality Related Values

BACT Best Available Control Technology

CARB California Air Resources Board

CFR Code of Federal Regulations

CO carbon monoxide

CO 2 e carbon dioxide equivalent

Ecology Washington State Department of Ecology

EPA United States Environmental Protection Agency

ESA Endangered Species Act

FLAG Federal Land Managers’ Air Quality Relative Values Workgroup

FLM Federal Land Manager

FR Federal Register

GHG greenhouse gas

H 2 SO 4 sulfuric acid mist

HAPs hazardous air pollutants

hr/yr hours per year

kW kilowatt

MACT maximum achievable control technology

MSA Magnuson

- Stevens Act

NAAQS National Ambient Air Quality Standards

NESHAP National Emission Standards for Hazardous Air Pollutants

NOC Notice of Construction

NO X nitrogen oxides

NPS National Park ServiceTechnical Support Document Page 96 of 96 Boeing Everett 777X Project September 9, 2014

NSR N ew S ource R eview

PM particulate matter

PM 10 particulate matter less than 10 micrometers in diameter

PM 2.5 particulate matter less than 2.5 micrometers in diameter

ppb parts per billion

ppm parts per million

PSD Prevention of Significant Deterioration

PSCAA Puget Sound Clean Air Agency

PTE potential to emit

Q/d emissions to distance

RBLC RACT/BACT/LAER Clearinghouse

SCR selective catalytic reduction

SEPA State Environmental Policy Act

SER significant emission rate

SIL significant impact level

SO 2 sulfur dioxide

SO X sulfur oxides

TAP toxic air pollutant

tpy tons per year

VOC v olatile organic compound

WAC Washington Administrative Code