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BOEING COMMERCIAL AIRPLANES .. ~ City of Renton Planning Division LEGEND: ~ 737 RATE READINESS PROJECT LOCATIONS ~ --++--~------• (4) NEW SEAL BOOlliS • 4-20 BLDG LINE 6 PUll[I'-- PLAN VIEW SJll.[1·--4 ® •I•• ..... ,... 1\9911 ,.. I I IIA.11 • 1----·--... ,m1a11 ..--·" SEE SHEETS SEPA-11A a: SEPA-250 -----• NEW HORIZ. BUILD LINE (HBL) • 4-20 BLDG · LINE 4 SEE SHEET SEPA-1 IA ----• NEW WING RIVETER· 4-20 BLDG -LINE 5 SEE SHEET SEPA-1 IA ---• NEW WING TO BODY JOIN -4-a1-82 BLDG -LINE 2 SEE SHEET SEPA-11B REVISE EXIST MOVING LINE· 4-a1-82 BLDG· LINE 2 SEE SHEET SEPA-11 B NEW PAINT BOOTH • 4-86 BLDG SEE SHEETS SEPA-11 B & SEPA-250 REVISE PP8 PAINT BOOTH • 4-86 BLDG SEE SHEETS SEPA-11B a: SEPA-250 LEGAL DESCRIPTION -------cm«--cowr-::.,c,~=-~-~=-... ES.'!::..~~ ;:: ~.'t":.,. -....,,,.~.....,.Jl. CITP __ __ ... :=...-:to= ~..:'."t. ,=:,1:11... Ea ma: l.llllllii'iiiii,-..,t .. ..,, ... :11i..1:r.:1..-m,.:, .. --., ... -™W'~L_..,~ --.,.._ -cem: ~~~~_.. ........ .,.. E:::~~~ ..... ...... :11i..1:r~---.,,.._ E:"..:.~-:-.:.r...r~ -:.:=.~,, ---cm or -M cam ... ~---~_.. .......... .. c:i.=-, ...... ;;.-~~ ........ .... .... ....,. ,. Ullallll .... A-IIJIIJ, :s.a:::'.:l..'"'=YI. .. --., -- ~~..G:.:f1b1=-:1:=='-"' ~·~ ... -JI".,, .. ........................................ ~ I fa--··· · -I 1• K WM ~ -~, -- (Q) Md] -~ = ..... = Cl') Md] '+-C I ~ o ·c :z: ~~ => Md] -, ·-Cl. ~ 0 •. I z \ I ~ i 11 s • • I a.. II w t:: u, i.,, I ~- 11 I a.. ---- II II u IC. C: 0 C: ..... Q C: .!Q Cl) -~ ire ..... 0) 0 .s >. C: ~~ on. I ~ ..., __ ,.,.., .... z I I ~ i s a.. 11 • • I w I:: u U) ~L I ~-a.. 11 I II II u I • • D >----9+- ® -~fi ~~.~-~l:.QG -PROPOSED PAINT BOOTH FLOOR' PLAN ® !,_i,8.~~l:.QG -REVISE PPB PAINT BOOTH FLOOR PLAN ® II " " City of Renton Planning Division JUN -9 2011 lRi~CC~UW~[Q) __ L _ _l .,, . I I 1 1 • D, i,==::a ·' " I • " " " " " IIP JII I-I I -I I I -I I 11 Q ! ! f F k I g·-----~-: · ~---=-~ -=~--====:=== 11 i ":' - ti,2~r~,tg.G -(4) NEW SEAL BOOTHS FLOOR PLAN © • 111111 -·----·---~ ~ ,. JJr--••...w,.. 1t.a!Ml ..,.. ... n ~ _. ~.,:. I ~··•1.w11· -· --t...-=:-:-':=-===-----.------;i -~-.... (> () ...... e . .. 0.: r ~ -. .. -,.: -~ ... -~ ,• I ,, --: '" ,, { l ... f;' l I • fJ; I I I ·- C .Sa ©l C ."i§ f CZ, -~ -era I§§ .._ 0) 0) i@ 0 .s I ~g ~ ~ ·-SP -, OQ fl!!JJ @f: • • CITY OF RENTON DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT MEMORANDUM Date: December 13, 2011 To: City Clerk's Office From: Stacy M Tucker Subject: Land Use File Closeout Please complete the following information to facilitate project closeout and indexing by the City Clerk's Office Project Name: 737 Air Quality Program LUA (file) Number: LUA-11-042, ECF Cross-References: AKA's: j Project Manager: Vanessa Dolbee Acceptance Date: June 28, 2011 Applicant: Mark Clement, Boeing Owner: Boeing Corp. Contact: Same as applicant PID Number: 0723059001 ERC Approval Date: July 18, 2011 ERC Appeal Date: August 5, 2011 Administrative Denial: Appeal Period Ends: Public Hearing Date: Date Appealed to HEX: By Whom: HEX Decision: Date: Date Appealed to Council: By Whom: Council Decision: Date: I Mylar Recording Number: Project Description: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, Location: 737 Logan Avenue N Comments: • DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT DATE: TO: FROM: SUBJECT: M E M O R A N D U M September 26, 2011 Dave Pargas/Fire Department Lys Hornsby/Utility Systems Director Richard Perteet/Deputy PW Administrator -Transportation Leslie Betlach/Parks Director Jennifer Henning/CED Current Planning Manager Department of Ecology Proposed Air Quality Permit No. PSD-11-02 / Boeing Rrenton Attached is a copy of the subject Proposed Air Quality Permit. See the attached Notice for details. There are no required comments for this notice. Attachment cc: Gregg Zimmerman; Public Works Administrator • • RECEIVED SEP l 5 2011. STATE OF WASHINGTON DEPARTMENT OF ECOLOGY PO Box 47600 • Olympia, Wk98504-7600 • 360-407-6000 MAYOR'S OFFICE 711 for Washington Relay Service • Persons with a speech disa_bility can call 877-833-6341 September 13, 2011 Mayor Denis Law 1055 S. Grady Way Renton, WA 98057 Dear Mr. Law: Proposed Air Quality Permit No. PSD-11-02 for Boeing Renton The Washington State Department of Ecology (Ecology) has proposed to approve an air quality permit application submitted by the Boeing Company for the 737 production capacityfacrease project. I have enclosed a copy of the proposed air quality permit, which is called a Prevention of Significant Deterioration (PSD) permit. I have also enclosed a copy of the related technical support document and the public notice. Ecology has released the enclosed draft permit for public comment. Public notices announcing the public comment period will be published in the Seattle Times and the Daily Journal of Commerce on September 13, 2011. The public comment period closes on October 13, 2011. A public hearing on Boeing's proposal and Ecology's proposed decision may be held if Ecology determines during the public comment period that significant public interest exists. · If you have any comments regarding Boeing's proposal or our proposed decision, please send them to me at the address above, or electronically to david.ogulei@ecy.wa.gov. Should you have any questions, please contact me directly at (360) 407 6803. ; I Davi Ogulei, Ph.D., P. Project Manager do/te Enclosures: PSD-11-02 (draft) Technical Support Document for PSD-11-02 (draft) Notice of public comment period for PSD-11-02 cc: Michael Verhaar, Boeing (w/o attachments) • • RECEIVED SEP 15 2011 MAYOR'S OFFICE PREVENTION OF SIGNIF.ICANT DETERIORATION (PSD) PERMIT Issued To: Permit Number: Date of Original Permit Issuance: The Boeing Company Boeing Commercial Airplane Group -Renton 737 Logan Avenue North Renton, Washington 98055 PSD-11-02, DRAFT September 12, 2011 This PSD permit is issued under the authority of the W ashlngton State Clean Air Act, Chapter 70.94 Revised Code of Washington; the Washlngton State Department of Ecology regulations for the Prevention of Significant Deterioration of Air Quality as set forth in W ashlngton Administrative Code 173-400-700 through 750; and the agreement for the delegation of the federal Prevention of Significant Deterioration regulations by the United States Environmental Protection Agency to the Washlngton State Department of Ecology, dated February 23, 2005. REVIEWED BY: David Ogulei, Ph.D., P.E. Science and Engineering Section Air Quality Program · APPROVED BY: Stuart A. Clark Air Quality Program Manager Washington State Department of Ecology Date Date I I I I I I I I i I • ' • • TABLE OF CONTENTS PROJECT SUMMARY ................................................................................................................. iii APPROVAL CONDITIONS .......................................................................................................... I I. EFFECTIVE DATE OF PERMIT ................................................................................... I II. PERMIT EXPIRATION .................................................................................................. I III. PERMIT NOTIFICATION REQUIREMENTS .............................................................. I IV. BACT EMISSION LIMITS ............................................................................................. 2 V. SPECIFIC OPERA TING REQUIREMENTS ................................................................. 2 VI. COMPLIANCE MONITORING REQUIREMENTS ..................................................... 5 VIL RECORDKEEPING AND REPORTING REQUIREMENTS ....................................... 8 VIII. GENERAL RESTRICTIONS ON FACILITY OPERATIONS .................................... I 0 IX. MALFUNCTION AND EXCESS EMISSIONS REPORTING .................................... JO X. RIGHT OF ENTRY ....................................................................................................... 11 XI. TRANSFER OF OWNERSHIP ............................................... : ..................................... 12 XII. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS ......................................................................................... 12 XIII. APPEAL PROCEDURES .............................................................................................. 13 ACRONYMS AND ABBREVIATIONS ..................................................................................... I 4 II • • PROJECT SUMMARY The Boeing Company, herein referred to as "Boeing Renton" or "Permittee", proposes to make physical and operational changes to their airplane manufacturing facility in Renton, Washington, to enable an increase in the production rate of the 73 7 model airplane. The proposed project will enable an increase in 73 7 production at the Renton facility from a current average rate of about 374 airplanes per year to a projected maximum of about 504 airplanes per year (both based on a nominal 250 manufacturing days per year), and are described as follows: • Building 4-20: Boeing Renton intends to replace four existing wing panel spray booths in Building 4-20 with four new booths at another location in the same building to allow replacement of the vertical wing build line with a new horizontal wing build line. No other new or modified spray booths are planned, and no other emission units would be added or modified in Building 4-20 as part of this project. PSD Permit No. PSD-08-01 limits emissions of volatile organic compounds (VOC) from Buildings 4-20, 4-21, 4-81, and 4-82 to 118 tons per year (tpy). Boeing Renton is not seeking to change that limit with this application; however, the proposed physical and operational changes in Building 4-20 is expected to result in an increase in actual VOC emissions in Building 4- 20. This permit does not contravene any terms or conditions in PSD Permit No. PSD-08- 01. • Building 4-86: Boeing Renton intends to add one new booth (PB-4) in Building 4-86 that will paint the upper and lower sections of the wing with the wing in a vertical position. Also, to improve the quality of the paint finish, the exhaust rate on one existing inspar (vertical) wing booth (PP-8) would be increased. This change will allow additional wings to be painted in the boo.th. Condition 2 of PSD Permit No. PSD-97-2 limits VOC emissions from Building 4-86 to 242 tpy. Boeing Renton is not seeking to change that limit with this application. This permit does not"contravene any terms or conditions in PSD Permit No. PSD~97-2. • Additional changes: In addition to the changes described above, Boeing Renton intends to make other changes to 73 7 assembly operations that are not expected to involve changes to spray booths or other emission units. These changes include, but are not necessarily limited to, installing a new wing-riveter, a second horizontal wing build line and other miscellaneous assembly tooling. The proposed project is expected to result in a significant net e.missions increase of approximately 97 tpy ofVOC. Other regulated new source review pollutants will not experience a significant emissions increase. A full technical review of the project, including a Best Available Control Technology (BACT) analysis, and the project's effect on national ambient air quality standards, PSD increments, visibility, soils and vegetation, is included in a Technical Support Document prepared by the Washington State Department of Ecology (Ecology) on September 12, 2011. 111 I I I : I , I I ,· Boeing Commercial Airplan.oup -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 2011 APPROVAL CONDITIONS • Page I of 14 Based on the PSD permit application submitted by Boeing Renton on June 7, 2011, the additional information submitted on June 23, July 8, July 12, August 2, August 11, August 25, and September 8, 2011, and the technical review performed by Ecology, Ecology finds that all · requirements for issuance of this PSD permit have been satisfied. Approval of the project described above is granted subject to the following conditions: I. EFFECTIVE DATE OF PERMIT In accordance with 40 C.F.R. § 124.15 and§ 124.19, and the Washington Administrative Code (WAC) 173-400-730, the effective date of this PSD permit is one of the following dates: A. If no comments on the preliminary determination were received: the date of issuance; or B. If comments were received: thirty (30) days after the applicant and the commenters receive the final determination; or C. If a review of the final determination is requested pursuant to 40 C.F.R. § 124.13 and 40 C.F.R. § 124.19, the effective date of the permit is suspended until such time as the review and any subsequent appeal against the permit are resolved. II. PERMIT EXPIRATION Pursuant to 40 C.F.R. § 52.2l(r)(2), and unless an extension is granted by Ecology prior to expiration, this PSD permit will become invalid if construction: A. Has not commenced (as defined in 40 C.F.R. § 52.2l(b)(9)) within eighteen (18) months of the effective date of this permit; or B. Is discontinued for a period of eighteen ( 18) months or more; or C. Is not completed within a reasonable time. III. PERMIT NOTIFICATION REQUIREMENTS A. Permittee's requirements in this PSD permit to notify, report to, or acquire approval or agreement from "Ecology and/or the Puget Sound Clean Air Agency (PSCAA)" may be satisfied by providing such notification, reporting, or approval request to PS CAA if the conditions of this PSD permit have been incorporated into Boeing Renton's Title V Air Operating Permit issued pursuant to 40 C.F.R. Part 70. 1------------- 1 ' I Boeing Commercial Aiene Group -Rent~n Permit No.: PSD-11-02, Draft Issued: September 12, 2011 • Page 2 of 14 B. Permittee must notify Ecology and/or PSCAA, as specified in Condition III.A, in writing or electronic mail of the: 1. Date construction is commenced, postmarked or received within thirty (30) days of such date. 2. Anticipated date of initial start-up, as defined in 40 C.F.R. § 63.2, of each modified spray booth not more than sixty (60) days nor less than thirty (30) days prior to such date. 3. Actual date of initial start-up, as defined in 40 C.F.R. § 63.2, of each modified spray booth, postmarked or received within fifteen (15) days of such date. IV. BACT EMISSION LIMITS Consistent with the requirements of 40 C.F.R. § 52.210)(3), the following BACT limitations apply to VOC emissions from the four new 737 wing panel spray booths in Building 4-20, the new inspar wing spray booth and the modified inspar wing spray booth in Building 4-86: A. Permittee must comply with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on July 1, 2011. B. VOC emissions must not exceed 11.0 pounds per wing coated in the new wing panel spray booths in Building 4-20 on a twelve-month rolling average, AND a combined total of 8.3 tons of VOC in any twelve consecutive month period. C. VOC emissions must not exceed 65.0 pounds per wing coated in the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86 on a twelve-month rolling average, AND a combined total of23.7 tons for any twelve consecutive month period. D. · As used in this PSD permit, VOC means any compound defined as VOC in 40 C.F.R. § 51.IOO(s). V. SPECIFIC OPERATING REQUIREMENTS A. For cleaning and coating operations in the four new 737 wing panel spray booths in Building 4-20 and the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86, Boeing Renton must comply with all applicable VOC emission standards of the Aerospace NESHAP, 40 C.F.R. Part 63, Subpart GG (as in effect on July I, 2011), including but not limited to the following requirements, as applicable: Boeing Commercial Airplam.oup -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 2011 Page 3 of 14 I. Cleaning solvent-laden cloth, paper, or any other absorbent applicators used for cleaning will be deposited in bags or other closed containers upon completing their use to the extent required by 40 C.F.R. § 63.744(a)(l). 2. Fresh and spent cleaning solvents, except semi-aqueous solvent cleaners as defined in 40 C.F.R. § 63.742 must be stored in closed containers to the extent required by 40 C.F.R. § 63.744(a)(2). 3. Conduct the handling and transfer of cleaning solvents to or from enclosed systems and other cleaning operation equipment that hold or store fresh or spent cleaning solvents in a manner that minimizes spills to the extent required by 40 C.F.R. § 63.744(a)(3). 4. Hand-wipe cleaning solvents must comply with either Condition V.A.4.a. or Condition V.A.4.b. to the extent required by 40 C.F.R. § 63.744(b): a. A VOC composite vapor pressure not greater than 45 mm Hg at 20°C . ( determined in accordance with Condition VI.B.3); or b. The composition requirements in Table I of 40 C.F.R. § 63. 744. 5. To the extent required by 40 C.F.R. § 63.744(d), when conducting flush cleaning operations subject to 40 C.F.R. Part 63, Subpart GG (excluding those in which the cleaning solvents used either meet the composition requirements in Table 1 of 40 C.F.R. § 63.744 or are semi-aqueous as defined in 40 C.F.R. § 63.742), the Permittee shall empty the used cleaning solvent each time aerospace parts or assemblies, or components of a coating unit (with the exception of spray guns) are flush cleaned into an enclosed container or collection system that is kept closed when not in use or into a system with equivalent emission control. 6. The VOC content level in primers and topcoats must meet the following requirements: a. Exterior primers: Not greater than 5.4 lb VOC/gal, as applied, less water and exempt solvents to the extent required by 40 C.F.R. § 63.745(c)(2). b. All other primers: Not greater than 2.9 lb VOC/gal as applied, less water and exempt solvents to the extent required by 40 C.F.R. § 63.745(c)(2). c. Topcoats: Not greater than 3.5 lb VOC/gal, as applied, less water and exempt solvents to the extent required by 40 C.F.R. § 63.745(c)(4). 7. To the extent required by 40 C.F.R. § 63.745(t)(l), spray-applied primers and topcoats for wings must be applied using High Volume Low Pressure Boeing Commercial Ai.e Group -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 2011 • Page 4 of 14 (HVLP), electrostatic, or other spray coating application methods, as approved by Ecology and/or PSCAA, as specified in Condition III.A., with a transfer efficiency equivalent to or greater than HVLP or electrostatic spray application methods. 8. To the extent required by 40 C.F.R. § 63. 744, spray guns and hoses will be cleaned by one or more of the methods specified in Conditions V.A.8.a. through V.A.8.d., or equivalent methods that are approved by Ecology and/or PS CAA, as specified in Condition III.A.: a. Enclosed system --to the extent required by 40 C.F.R. § 63.744(c)(l): 1. Clean the spray gun in an enclosed system that is closed at all times except when inserting or removing the spray gun. n. Cleaning must consist of forcing solvent through the gun. b. Nonatomized cleaning --to the extent required by 40 C.F.R. § 63.744(c)(2): 1. Clean the spray gun by placing cleaning solvent in the pressure pot and forcing it through the gun with the atomizing cap in place. ii. No atomizing air is to be used. 111. Direct the cleaning solvent from the spray gun into a vat, drum, or other waste container that is closed when not in use. c. Disassembled spray gun cleaning --to the extent required by 40 C.F .R. § 63.744(c)(3): i. Disassemble the spray gun and clean the components by hand in a vat, which must remain closed at all times except when in use; or 11. Soak the components in a vat, which must remain closed during the soaking period and when not inserting or removing components. d. Atomized cleaning--to th~ extent required by 40 C.F.R. § 63.744(c)(4): 1. Clean the spray gun by forcing the cleaning solvent through the gun. ii. Direct the resulting atomized spray into a waste container that is fitted with a device designed to capture the atomized cleaning solvent emissions. ' '! I ' I I I I Boeing Commercial Airplan&up -Renton Permit No.: PSD-11-02, Dra1t"" ·• Page 5 of 14 Issued: September 12, 2011 B. In addition to complying with the VOC emission standards of the Aerospace NESHAP, 40 C.F.R. Part 63, Subpart GG (as in effect on July I, 2011) as required in Condition V.A., all wing cleaning solvents or solvent blends applied in the new and modified booths in Buildings 4-20 and 4-86 must be applied either manually or by low pressure applicators except in the following situations: I. Cleaning intricate surfaces; 2. Where access is limited to the extent that using a low pressure applicator is infeasible; or 3. Use of a cleaning solvent that either meets the composition requirements in Table I of 40 C.F.R. § 63. 744 or meets the definition of a semi-aqueous cleaning solvent as defined in 40 C.F.R. § 63.742 (as in effect on July I, 2011 ). C. The Permittee shall decommission the wing panel booths that are proposed for replacement in Building 4-20 within 180 days of commencing commercial operations in the new wing panel booths to be installed in Building 4-20. VI. COMPLIANCE MONITORING REQUIREMENTS A. Permittee must monitor compliance with Condition IV.B. (beginning the first calendar month that any of the four new 73 7 wing panel spray booths in Building 4-20 is first used for wing cleaning and coating) and Condition IV.C. (beginning the first calendar month that any of the new inspar wing spray booth (PB-4) in Building 4-86, or the modified inspar wing spray booth (PP-8) in Building 4-86 is first used for wing cleaning and coating) as follows: I. No later than 30 days after the end of each month, quantify the amount in gallons of each VOC-containing material used during that month in: a. the four new 737 wing panel spray booths in Building 4-20, and b. the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86. 2. Determine VOC content in pounds per gallon of each such VOC-containing material from the corresponding Material Safety Data Sheets (MSDSs) or other data supplied by the material's manufacturer or by another method approved by Ecology and/or PSCAA, as specified in Condition III.A. 3. Calculate VOC emissions in pounds for that month as follows: Boeing Commercial Ai4tne Group -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 2011 • Page 6 of 14 a. Multiply the gallons of each material obtained per Condition VI.A. I .a. by the VOC content in each corresponding material as obtained in Condition VI.A.2. Calculate total VOC emissions from all VOC-containing materials consumed in the four new 73 7 wing panel spray booths in Building 4-20. Permittee may subtract: 1. Any VOC that are included in the coating formulation as reactive components to the extent that they are incorporated into the final wing coating as verified by the coating's manufacturer documentation, or that are recovered for reuse, recycling or disposal; or ii. Any VOC discharged from Boeing Renton to wastewater or solid waste, from materials used in the four new 73 7 wing panel spray booths in Building 4-20. b. Multiply the gallons of each material obtained per Condition VI.A.Lb. by the VOC content in each corresponding material as obtained in Condition VI.A.2. Calculate total VOC emissions from all VOC-containing materials consumed in the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86. Permittee may subtract: 1. Any VOC that are included in the coating formulation as reactive components to the extent that they are incorporated into the final wing coating as verified by the coating's manufacturer documentation, or that are recovered for reuse, recycling or disposal; or 11. Any VOC discharged from Boeing Renton to wastewater or solid waste, from materials used in the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86. 4. Calculate VOC emissions in pounds for the most recent 12 month period as follows: a. Add total VOC emissions obtained per Condition VI.A.3.a. to the total VOC emissions from the four new 737 wing panel spray booths in Building 4-20 for the previous 11 months. Use the result of this calculation to verify compliance with Condition IV.B. For the purpose of this calculation, the amount of each VOC-containing material used in the 737 wing panel spray booths in Building 4-20 during the eleven (11) months preceding the first month in which any of those booths is first used for wing cleaning and coating, shall be considered zero. ' I ' Boeing Commercial Airplane.mp -Renton Permit No.: PSD-11-02, Draft · • Page 7 of 14 Issued: September 12, 2011 B. b. Add total VOC emissions obtained per Condition VI.A.3.b. to the total VOC emissions from the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86 for the previous 11 months. Use the result ohhis calculation to verify compliance with Condition IV .C. For the purpose of this calculation, the amount of each VOC-containing material used in the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86 during the eleven ( 11) months preceding the first month in which any of those booths is first used for wing cleaning and coating, shall be considered zero. 5. Quantify the total number of wings "oated in the four new 737 wing panel spray booths in Building 4-20 in the most recent 12-month period. Verify compliance with Condition IV.B. by dividing the value obtained per Condition VI.A.4.a. by the total number of wings coated in the four new 737 wing panel spray booths in Building 4-20. 6. Quantify the total number of wings coated in the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86 in the most recent 12-month period. Verify compliance with Condition IV. A.3. by dividing the value obtained per Condition VI.A.4.b. by the total number of wings coated in the new inspar wing spray booth and the modified inspar wing spray booth in Building 4-86. Beginning the first calendar month that any of the four new 73 7 wing panel spray booths in Building 4-20, the new inspar wing spray booth (PB-4) in Building 4- 86, or the modified inspar wing spray booth (PP-8) in Building 4-86 is first used . for wing cleaning and coating, Permittee must monitor compliance with Conditions V.A.l. through V.A.6.; V.A.8.; and V.B. by: I. Conducting inspections of the work practice activities in the four new 737 wing panel spray booths in Building 4-20 and the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4- 86 at least once per calendar year. 2. Randomly sampling work practices during each inspection, and observing for consistency with permit requirements. 3. To monitor compliance with Conditions V.A.4.a. and V.B.3., Permittee must determine, as applicable, each wing hand-wipe cleaning ~olvent's or solvent blend's VOC composite vapor pressure in accordance with: a. 40 C.F.R. § 63.750(b)(l) for single component hand-wipe cleaning solvents (as in effect on July I, 2011); or Boeing Commercial Aiae Group -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 2011 • Page 8 of 14 b. The equation in 40 C.F.R. § 63.750(b)(2) for blended hand-wipe cleaning solvents (as in effect on July I, 2011). 4. To monitor compliance with Condition V.A.4.b., Permittee must determine, as applicable, each wing cleaning solvent's or solvent blend's composition in accordance with 40 C.F.R. § 63.750(a) (as in effect on July I, 2011) or by another method approved by Ecology and/or PSCAA, as specified in Condition III.A. C. Permittee must monitor compliance with Condition V.A.6. by using the data maintained pursuant to Condition VI.A.2 .. D. Permittee shall comply with Condition V.C. by providing a written notice to Ecology and/or PSCAA, as specified in Condition III.A., within 15 days of decommissioning the wing panel booths that are proposed for replacement in Building 4-20. VII. RECORDKEEPING AND REPORTING REQUIREMENTS A. Beginning the first calendar month that any of the four new 737 wing panel spray booths in Building 4-20, the new inspar wing spray booth (PB-4) in Building 4- 86, or the modified inspar wing spray booth (PP-8) in Building 4-86 is first used for wing cleaning and coating, Permittee must keep the following records at the site (or electronically accessible at the site): I. Number of airplane wings processed through: a. the four new 737 wing panel spray booths in Building 4-20; and b. the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86. 2. The calculations and results pursuant to Condition VI.A. 3. An annually updated list of all VOC-containing materials used in the four new 737 wing panel spray booths in Building 4-20 and the new inspar wing spray booth (PB-4)and the modified inspar wing spray booth (PP-8) in Building 4- 86 within the immediate past twelve months. For the purpose of this record, the immediate past twelve (12) months shall not include any month prior to the month that any of the four new 73 7 wing panel spray booths in Building 4- 20, the new ins par wing spray booth (PB-4 ), or the modified inspar wing spray booth (PP-8) in Building 4-86 is first used for wing cleaning and coating. Boeing Commercial Airplan&up -·Renton Permit No.: PSD-11-02, DrarT" Issued: September 12, 2011 • Page 9 of 14 4. For materials containing VOC that were deducted pursuant to Conditions VI.A.3.a.i. or VI.A.3.b.i., manufacturer documentation verifying the quantity of reactive VOC incorporated into the final wing coating. 5. For VOC that were deducted pursuant to Conditions VI.A.3.a.ii. or VI.A.3.b.ii., inventory records verifying the quantity ofVOC recovered for reuse, recycling or disposal, or discharged from Boeing Renton to wastewater or solid waste from materials used in, as applicable: a. the four new 737 wing panel spray booths in Building 4-20; or b. the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86. B. Records must be retained for not less than five (5) years after their origination. I. At a minimum, the most recent two (2) years of data must be retained on-site (or be electronically accessible at the site). The remaining three (3) years of data may be retained off-site. 2. Records must be available for inspection by Ecology and PSCAA within ten ( I 0) days of request. C. Beginning the first calendar year that any of the four new 73 7 wing panel spray booths in Building 4-20, the new inspar wing spray booth (PB-4) in Building 4- 86, or the modified inspar wing spray booth (PP-8) in Building 4-86 is first used for wing cleaning and coating, Permittee must annually report in writing or electronic mail, postmarked or received by June 15 of each year, the following information to Ecology and/or PSCAA, as specified in Condition III.A.: I. The types and corresponding monthly and rolling 12-month total quantities of VOC-containing materials used in: a. the four new 737 wing panel spray booths in Building 4-20; and b. the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86. 2. The quantity of VOC in the VOC-containing materials reported pursuant to Condition VII.C. l. 3. For VOC that were deducted pursuant to Conditions VI.A.3.a.i. or VI.A.3.b.i., the monthly and rolling 12-month total quantity ofreactive VOC incorporated into the final wing coating in, as applicable: Boeing Commercial Ai6e Group -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 20 i 1 • Page 10 of 14 a. the four new 737 wing panel spray booths in Building 4:20; or b. the new inspar wing spray booth (PB-4) arid the modified inspar wing spray booth (PP-8) in Building 4-86. 4. For VOC that were deducted pursuant to Conditions VI.A.3.a.ii. or VI.A.3.b.ii.,.the monthly and rolling 12-month total quantity ofVOC recovered for reuse, recycling or disposal, or discharged from Boeing Renton to wastewater or solid waste, from materials used in, as applicable: a. the four new 737 wing panel spray booths in Building 4-20; or b. the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86. VIII. GENERAL RESTRICTIONS ON FACILITY OPERATIONS A. At all times; the Permittee must, to the extent practicable, maintain and operate the four new 737 wing panel spray booths in Building 4-20, the new inspar wing spray booth (PB-4) in Building 4-86, and the modified inspar wing spray booth (PP-8) in Building 4-86, including any associated VOC air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions. B. Determination of whether acceptable operating and maintenance procedures are being used for the four new 737 wing panel spray booths in Building 4-20, the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86, will be based on information available to Ecology, the U.S. Environmental Protection Agency (EPA), PSCAA and/or their authorized representatives, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. IX. MALFUNCTION AND EXCESS EMISSIONS REPORTING A. Prior to incorporation of the conditions of this PSD permit into Boeing Renton' s Title V Air Operating Permit issued pursuant to 40 C.F .R. Part 70, Permittee must report to Ecology and PSCAA, in writing or electronic mail, following the discovery of any malfunction of air pollution control equipment, process equipment, or of a process, which results in an increase in VOC emissions above the allowable emission limits stated in Sections IV. and V. of this permit, in accordance with WAC 173-400-107 and the following conditions: 1. As used in WAC 173-400-107(3), "as soon as possible" shall mean in no case later than twelve (12) hours following the discovery of any occurrence of Boeing Commercial Airplan&up -Renton Permit No.: PSD-11-02, DraiT"" Issued: September 12, 2011 • Page II of 14 excess VOC emissions above the allowable emission limits stated in Sections IV. and V. ofthis permit that represent a potential threat to human health or safety. 2. Permittee must notify Ecology and PSCAA, in writing or electronic mail, postmarked or received within thirty (30) days after the end of the month in which a malfunction is discovered, for any malfunction of air pollution control equipment, process equipment, or of a process, which results in an increase in VOC emissions above the allowable emission limits stated in Sections IV. and V. of this permit. This notification must include a description of the malfunctioning equipment, process equipment or process, the date and time of the initial malfunction (if known), the period of time over which emissions were increased due to the malfunction, the cause of the malfunction (if known), the estimated resultant emissions in excess of those allowed in Sections IV. and V ., and the methods utilized to mitigate emissions and restore normal operations. 3. For purposes of Condition IX.A., "malfunction" means any failure of air pollution control equipment, process equipment, or·of a process to operate in a normal manner. B. After the conditions of this PSD permit have been incorporated into Boeing Renton's Title V Air Operating Permit issued pursuant to 40 C.F.R. Part 70, Permittee shall report to PSCAA the discovery of any malfunction of air pollution control equipment, process equipment, or of a process, which results in an increase in VOC emissions above the allowable emission limits stated in Sections IV. and v: of this permit pursuant to the deviation reporting requirements and, if applicable, pursuant to the unavoidable excess emissions reporting requirements, of that Title V Air Operating Permit. C. Compliance with the malfunction notification requirements·ofConditions IX.A. or IX.B., as applicable, will not excuse or otherwise constitute a defense to any violation of this PSD permit or any law or regulation such malfunction may cause. X. RIGHT OF ENTRY Section I 14 of the federal Clean Air Act, 42 U.S.C. § 7414, the Revised Code of Washington (RCW) 70.94.200, and WAC 173-400-105(3) provide authorized representatives of EPA, Ecology, and PSCAA certain rights to enter and inspect the source. Refusal by the Permittee to allow such entry and inspection may be a violation of the federal Clean Air Act and/or the Revised Code of Washington subject to penalty as provided in those statutes. Pursuant to these statutes, authorized representatives of EPA, Ecology, and PSCAA, upon the presentation of credentials: Boeing Conunercial Aiene Group -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 2011 • Page 12 of 14 A. Have a right of entry to, upon, or through any premises of the Permittee or any premises in which any records this permit requires the Permittee to maintain are located. B. Have the right, at reasonable times, to access and copy any records this permit requires the Permittee to maintain. C. Have the right, at reasonable times, to inspect any monitoring equipment or method required by this permit. D. Have the right, at reasonable times, to sample any emissions that the Permittee is required to sample under this permit. XI. TJUNSFER OF OWNERSHIP In the event of any changes in control or ownership of facilities to be constructed, this PSD permit will be binding on all subsequent owners and.operators. The applicant must notify the succeeding owner and operator of the existence of this PSD permit and its conditions by letter, a copy of which must be forwarded to Ecology and/or PSCAA, as specified in Condition III.A. XII. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS A. Pursuant to 40 C.F.R. § 52.2l(r)(l), the Permittee must construct and operate the four new 737 wing panel spray booths in Building 4-20, the new inspar wing spray booth (PB-4) in Building 4-86, and the modified inspar wing spray booth (PP-8) in Building 4-86 in accordance with this PSD permit and the application on which this permit is based. · B. Pursuant to 40 C.F.R. § 52.2l(r)(3), this PSD permit shall not relieve the Permittee of the responsibility to comply fully with applicable provisions of the State Implementation Plan and any other requirements under local, state, or federal law. C. Any applicant who fails to submit any relevant facts or who has submitted materially incorrect relevant information in a permit application must, upon becoming aware of such failure, or incorrect submittal, promptly submit such supplementary facts or corrected information. D. To the extent provided by 40 C.F.R. § 52.12( c), for the purpose of establishing whether or not the Permittee has violated or is in violation of any requirement of this permit, nothing in this permit shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether the Permittee Boeing Commercial Airplan&up -Renton Permit No.: PSD-11-02, DratT"" Issued: September 12, 2011 • Page 13 of 14 would have been in compliance with applicable requirements if the appropriate performance or reference test or procedure had been performed. XIII. APPEAL PROCEDURES This PSD permit, or any conditions contained in it, may be appealed to: A. The Pollution Control Hearings Board (PCHB) as provided in Chapter 43.21B RCW and Chapter 371-08 WAC; and/or B. EPA's Environmental Appeals Board (EAB) as provided in 40 C.F.R. § 124.13 and 40 C.F.R. § 124.19. Boeing Commercial Ai.e Group -Renton Permit No.: PSD-11-02, Draft Issued: September 12, 2011 ACRONYMS AND ABBREVIATIONS • Page 14 of 14 Aerospace NESHAP National Emission Standards for Aerospace Manufacturing and Rework Facilities (40 C.F.R. Part 63, Subpart GG) BACT Boeing Renton C.F.R. EAB Ecology EPA gal HVLP lb mmHg MSDS NESHAP oc PCHB PSCAA PSD RCW tpy u.s.c. voe WAC Best Available Control Technology The Boeing Company, Boeing Commercial Airplanes Renton Facility Code of Federal Regulations Environmental Appeals Board Washington State Department of Ecology · United States Environmental Protection Agency Gallon(s) High Volume Low Pressure Pound(s) Millimeters of Mercury Column Material Safety Data Sheet National Emission Standards for Hazardous Air Pollutants Degrees Celsius Pollution Control Hearings Board Puget Sound Clean Air Agency . Prevention of Significant Deterioration of Air Quality Revised Code of Washington Tons per year United States Code Volatile Organic Compounds Washington Administrative Code ----, • • STATE OF WASHINGTON TECHNICAL SUPPORT DOCUMENT RECEIVED SEP 15 2011 MAYOR'S OFFICE FOR PREVENTION OF SIGNIFICANT DETERIORATION PERMIT PERMIT NO: PSD-11-02 The Boeing Company Boeing Commercial Airplanes 737 Production Capacity Increase Project Renton (King County), Washington Prepared by Air Quality Program Washington State Department of Ecology Olympia, Washington September 12, 2011 • • TABLE OF CONTENTS EXECUTIVE SUMMARY ........................................................................................................... iv 1. INTRODUCTION .................................................................................................................. I I. I. PSD Permitting Requirements ......................................................................................... 1 1.2. Site and Project Description ............................................................................................. 1 1.2.1. Site Description .............................................................................. :·························· 1 1.2.2. Project Description .................................................................................................... 3 2. PSD APPLICABILITY REVIEW .......................................................................................... 7 2.1. Overview and Permitting History .................................................................................... 7 2.1.1. Emissions Calculation Procedure ............................................................................. 8 2.1.2. Aggregation and Debottlenecking Analysis ........................................................... 10 2.1.2.1. Project Aggregation Analysis .......................................................................... 10 2.1.2.2. Debottlenecking ............................................................................................... 12 2.1.3. Baseline Actual Emissions ...................................................................................... 13 2.1.4. Projected Actual Emissions .................................................................................... 16 2.1.5. Project Emissions Increase ................................................... : ................................. 18 2.1.6. Contemporaneous Net Emissions Increase ............................................................. 19 ' 1 2.2. New Source Performance Standards and National Emission Standards for Hazardous I I Air Pollutants ............................................................................................................................ 19 I , 3. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) DETERMINATION ............ 20 3.1. Definitions and Policy Concerning BACT ......................................... : .......................... 20 3.2. BACT for VOC Emissions from Wing Spray Booths ........................................... : ....... 21 3.2.1. Thermal Oxidation ................ : ................................................................................. 21 3.2.2. Carbon Adsorption .................................................................................................. 22 3.2.3. Low-VOC Coatings, High Transfer Efficiency Paint-Spraying Equipment and Techniques, and Best Management Practices ....................................................................... 23 3.2.4. VOC BACT Determination .................................................................................... 23 3.3. Toxic Air Pollutants ....................................................................................................... 24 4. AMBIENT AIR QUALITY IMP ACTS ANALYSIS ........................................................... 24 4.1. · Regulatory Requirements ............................................................ , .................................. 24 4.2. Modeled Impacts from the 737 Production Capacity Increase Project.. ........................ 25 5. ADDITIONAL IMPACTS ANALYSIS ............................................................................... 25 5.1. Visibility, PM2.s, and Ozone Impacts in Class I Areas .................................................. 26 11 • • 5.2. Local Impacts on Soils, Vegetation, and Animals ................. : ....................................... 28 5.3. Construction and Growth Impacts ................................................................................. 28 6. ENDANGERED SPECIES ACT .......................................................................................... 28 7. STATE ENVIRONMENTAL POLICY ACT (SEPA) ......................................................... 29 8. PUBLIC INVOLVEMENT .............. , ................................................................................... 29 9. CONCLUSION ..................................................................................................................... 29 I 0. AGENCY CONT ACT ...................................................................................................... 30 ACRONYMS AND ABBREVIATIONS ..................................................................................... 31 LIST OF FIGURES Figure I. Boeing Renton plant layout.. .......................................................................................... 2 Figure 2. Current Building 4-20 Layout. ....................................................................................... 4 Figure 3. Future Building 420 Layout. .......................................................................................... 5 Figure 4. Building 4a86 Layout. .................................................................................................... 5 Figure 5. Building 4-86 Layout Detail.. ......................................................................................•.. 6 LIST OF TABLES Table I. Summary of the Proposed Project ................................................................................... 6 Table 2. Baseline Actual Emissions (TPY) ................................................................................. 15 Table 3. Projected Actual Emissions (TPY) ................................................................................ 17 Table 4. Project Emissions Change (TPY) • ................................................................................ 18 Table 5. New and Modified Emission Units ................................................................................ 20 Table 6. Summary ofVOC Control Technology Costs• ...................................................... : ...... 22 Table 7. "Class I" Within 200 km of the Boeing Renton Facility ............................................... 26 Table 8. Distances from Boeing-Everett to the Nearest Class I Areas ........................................ 27 iii ' I I I I • • EXECUTIVE SUMMARY The Boeing Company (Boeing) proposes to make changes to their airplane manufacturing facility in Renton, Washington, to enable an increase in the production rate of the 73 7 model airplane. The proposed project is intended to increase 737 production capacity at the Renton facility from a maximum production capacity of about 376 airplanes per year to a projected maximum production capacity of about 504 airplanes per year (based on a nominal 250 manufacturing days per year schedule). The project proponent, herein referred to as "Boeing Renton" proposes to replace four existing wing panel spray booths in Building 4-20 with four new booths at another location in Building 4- 20, and in Building 4-86 to add a new wing booth and increase the exhaust rate on one existing inspar (vertical) wing booth to improve the quality of the paint finish. Also in Building 4-86, one wing spray booth in which wing interiors are currently sealed will revert back to its original use of coating exterior surfaces of wings. Other changes related to this project include adding a new wing horizontal build line in Building 4-20 (some of which will occupy the space that the four current wing panel spray booths occupy), installing a new wing riveter, and installing other miscellaneous assembly tooling in Building 4-20. None of these other changes involve the modification ofVOC emission units. There are no other physical changes or changes in method of operation anticipated at the Renton facility as a result of this project. The proposed project will result in a significant net emissions increase of approximately 97 tons per year (tpy) of volatile organic compounds (VOC). Other pollutants that are regulated under state and federal Prevention of Significant Deterioration (PSD) rules will not experience a significant emissions increase. The Washington State Department of Ecology (Ecology) received the PSD application for the project on June 7, 2011. Additional information was received on June 23, July 8, July 12, August 2, August 11, August 25, and September 8, 201 I. Ecology determined the application to be complete on September 8, 2011. iv Technical Support Doc.nt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 1. INTRODUCTION 1.1. PSD Permitting Requirements · • Page I of 32 PSD permitting requirements in Washington are established in Title 40, Code of Federal Regulations (C.F.R.) § 52.21; Washington Administrative Code (WAC) 173-400-700 through 750; pursuant to the agreement for the delegation of the federal PSD regulations by the United States Environmental Protection Agency (EPA) to Ecology, dated February 23, 2005. Federal and state rules require PSD review of all new or modified air pollution sources that meet certain criteria. 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 limits degradation of air quality to that which is not considered "significant." It also sets up a mechanism for evaluating the effect that the proposed emissions might have on visibility, soils, and vegetation. PSD rules also require the utilization of Best Available Control Technology (BACT) for certain new or modified emission units, which is the most effective air pollution control equipment and procedures that are determined 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 an attainment or unclassifiable area. PSD rules apply to pollutants for which the area is classified as attainment with the National Ambient Air Quality Standards (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 (allowable increments and comparison with the NAAQS), and analysis of impacts of the project on visibility, vegetations, and soils. 1.2. Site and Project Description 1.2.1. Site Description The Boeing airplane manufacturing facility located in the city of Renton in King County, Washington (Boeing Renton) began operation in 1942. It occupies 339 acres, and currently manufactures and assembles parts for the 73 7 series airplane model. Boeing Renton is located in the south half of Section 18, Township 23N, Range 5, Willamette Meridian. It is bounded to the north by Lake Washington, to the south by Airpqrt Way, to the east by Logan Avenue, and to the west by the Renton Airport. Figure I shows a plant layout of the Renton facility. Technical Support Documen. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 From '""' ...... ~· A 0 ..... ••• Figure 1. Boeing Renton plant layout i • Page 2 of32 • Employeegate, • AMS Turnstile gates ---Fence tines El Boeing propirty IZI) General pa""'1J ~ Restricmd parking @ 8Usstlll) 9 Hellstop I • (Source: Boeing's PSD application, Fig. 1-1, received August 25, 2011) Technical Support Doc.nt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 3 of32 Model 737 assembly operations primarily occur in Buildings 4-20, 4-21, 4-42, 4-81, 4-82, and 4- 86 and can be grouped as follows: • Wing Assembly Operations include assembling the upper and lower wing panels. These operations primarily occur in Buildings 4-20 and 4-21. • Wing Clean, Seal, Test, and Paint Operations include cleaning the complete wing assemblies, sealing them --including the interior surfaces of the fuel tank, applying corrosion inhibiting compounds, testing the fuel tank for leaks, correcting any leaks, and painting the exterior surfaces. These activities only occur in Building 4-86. • Final Assembly Operations include joining the wings and tail assemblies to the fuselage and adding the necessary electrical systems, hydraulic systems, and interiors. These operations occur in Buildings 4-81 and 4-82. • Delivery Operations include final paihting, any necessary depainting, and preparing the airplane for delivery. These operations occur in Building 4-42 and the paint hangars in Buildings 4-41 and 5-50. Some airplanes are flown offsite for painting because Boeing Renton does not have the capacity to apply the final exterior coating to all the airplanes produced at the Renton facility. • Combustion Operations include the boilers and heaters and backup diesel generators. The boilers are located in Buildings 4-89 and 5-50. These operations include the assembly of various sub-assemblies (e.g., wing spars and wings) from their component parts; the installation of various airplane systems (e.g., hydraulic, fuel, electrical) in the sub-assemblies; final assembly of a complete airplane structure and integration of the airplane systems; the installation of landing gear, engines, and interior components (e.g., seats, sidewalls, partitions); and functional testing. The main body sections (fuselages) are assembled in Wichita, Kansas and are delivered to Boeing Renton by rail. Air emissions primarily occur from activities such as spray coating, sealing, hand-wipe and flush cleaning, and the use of miscellaneous adhesives, resins, and other products that contain volatile organic compounds. Boeing Renton is located in a Class II area that is designated as "attainment or unclassifiable" for the purpose of PSD permitting for all pollutants. · 1.2.2. Project Description Boeing Renton proposes to make changes to the Renton airplane manufacturing facility that will enable it to increase the maximum production capacity from the current rate of about 376 airplanes per year to a projected maximum production capacity of about 504 airplanes per year (based on a nominal 250 manufacturing days per year schedule). To enable a 737 production rate of approximately 504 airplanes per year, certain changes to the 73 7 wing assembly and painting operations will be made. ': , I I. Technical Support Document. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 4 of32 Model 737 wings have two major wing panels, the upper and lower surfaces of the wing. Before assembling the two panels together, the wing panels are cleaned, sealed, and coated with protective coatings. As part of this project, Boeing intends to replace four existing wing panel spray booths (covered under the existing PSD Permit No. PSD-08-01) in Building 4-20 with four new booths at another location in Building 4-20 (Figures 2 and 3). This will allow replacement of the vertical wing build line with a new horizontal wing build line (HBL). No other new or modified spray booths are planned, and no other emission units would be added or modified in Building 4-20 as part of this project. Copyright C 2007 Boeulg. All rights reserved. Figure 2. Current Building 4-20 Layout. In Building 4-86 (Figure 4 and Figure 5), Boeing paints wings that are mostly assembled. Boeing intends to add one new inspar booth (PB-4) that will paint the upper and lower sections of the wing with the wing in a vertical position. To improve the quality of the paint finish, the exhaust rate on one existing inspar wing booth (PP-8) would be increased; this would also increase the capacity of the booth. · Technical Support Doc.nt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Figure 3. Future Building 420 Layout. ' ······r ' ' I Figure 4. Building 4-86 Layout. Page 5 of32 Technical Support Document. • Page 6 of32 Boeing Renton 73 7 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 -- Figure S. Building 4-86 Layout Detail. ---- In addition to the changes described above, Boeing intends to make other changes to 73 7 assembly operations that are not expected to involve changes to spray booths or other emission units. These changes include, but are not necessarily limited to, installing a new wing-riveter, a second HBL, and other miscellaneous assembly tooling. Table 1 summarizes the proposed actions for each building. Table I. Summary of the Proposed Project • 4 replacement wing panel booths • Decommissioning of 4 existing wing panel booths. 4-20 • New wing horizontal build line • New wing-riveter • Miscellaneous assembly tooling 4-86 • 1 new inspar (vertical) wing booth • Install new fan( s) in an existing ins par wing booth The cleaning and coating operations that are planned for the modified wing booths are as follows: • Wing cleaning and conversion coating ~ Before the exterior of the wing can be coated, it first must be cleaned and prepped for priming. • Wing priming -Priming provides corrosion protection and ensures the necessary bond between the surface of the wing and the topcoat. Technical Support Doc.nt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 7 of32 • Wing topcoat -The topcoat is the final coating of the normally visible surfaces of the wing, top and bottom. The topcoat not only provides the final protection of the wing surface but also provides the decorative color to the top and bottom of the wing. • Wing corrosion-inhibiting compound -Portions of the wing that are not normally visible often need a special coating to further protect them from corrosion. This corrosion-inhibiting compound is applied to the wing assembly before the wing is transported to the main assembly line for attaching to the fuselage of the airplane. • Spray 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. Increased 73 7 production enabled by the project is expected to result in increased emissions from the 737 assembly operations, Building 4-41 paint hangar,' and related combustion from boilers and heaters. The increased emissions are primarily due to debottlenecking of the assembly operations through the increased capacity of the wing assembly operations in Building 4-20 and Building 4-86. Details of the emission estimates are shown later in this document. VOC emissions from all 737 assembly operations at Boeing Renton, excluding painting of completed aircraft, average about 0.46 ton per airplane. Of the 0.46 ton per airplane, the projected potential VOC emissions from each of the wing panel booths in Building 4-20 are about 22 poun_ds per airplane, or about 2.08 tons per year (tpy) per booth. The new and modified booths in Building 4-86 would each emit 130 pounds ofVOC per airplane for a potential VOC emission rate of 11.86 tpy per booth. 2. PSD APPLICABILITY REVIEW 2.1. Overview and Permitting History Boeing Renton is an existing major stationary source under the PSD permitting program because it has the potential to emit (PTE) greater than 250 tpy ofVOC. 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 "inajor stationary source," or is a major stationary source unto itself. The Renton facility currently operates under multiple PSD permits issued by Ecology, including the following permits: 'The Building 5-50 paint hangar modification was permitted under PSD Permit No. PSD-08-0 I, Amendment I. The Building 5-50 paint hangar became operational in June 2011, before the permitting of this project. Boeing did not evaluate emission increases at the Building 5-50 paint hangar because its operation and emissions have already been permitted under a recent PSD permit issued by Ecology. ' I I \ ' I . . I I . Technical Support DocumentO Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 20 II Page 8 of32 • PSD-08-01, Amendment 1, for the Boeing Renton Site, Building 5-50 Paint Hangar and Buildings 4-20, 4-21, 4-81, and 4-82. PSD-08-01, Amendment 1, limits the VOC emissions from Buildings 4-20, 4-21, 4-81, and 4-82 to 118 tons per year (tpy). • PSD-97-02 for the Boeing Renton Site, Building 4-86. Condition 2 of PSD-97-02 limits voe emissions from Building 4-86 to 242 tpy. • PSD-88-4 for the Boeing Renton Site, Building 4-41 Paint Hangar. Condition I of PSD- 88-4 limits volatile organic compound emissions from Building 4-41 to 124 tpy. Boeing Renton is not seeking to change any of these existing PSD emission limits. 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 increase 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 Significant Emission Rate (SER) threshold for that regulated pollutant. The changes being made to increase 73 7 production capacity will require a PSD permit if both the project's emissions increase and the net contemporaneous emissions increase caused by the project exceed the PSD significance levels for VOC of 40 tpy. This PSD applicability review examines both the project's emissions increase and the net emissions increase. The emissions increase obtained through the PSD applicability review is used in the BACT and air quality analyses described in later sections. 2.1.1. Emissions Calculation Procedure To determine whether the project is a major modification, Boeing Renton used the procedure described in 40 C.F .R. § 52.21 and associated guidance to calculate emissions. That procedure can be summarized as follows: 1. Calculate project emission increases . a. For existing emissions units, the increase in emissions is calculated as the difference between projected actual emissions and baseline actual emissions. b. For new emissions units, the increase in emissions is equal to the PTE of the unit. c. Boeing Renton calculated the increase in emissions for: 1. New emissions units; 11. Existing emissions units that will be physically or operationally modified; Technical Support Doc.nt • Page 9 of32 Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 f iii. Existing emissions units that will not be physically or operationally modified but will have an associated increase in emissions as a result of the project; and 1v. Existing emissions units from any past or future projects that must be aggregated with the current project. 2. Calculate net contemporaneous and creditable emission increases and decreases. a. For all pollutants that will have a project emissions increase from Step 1 that is greater than the SER, a further analysis is used to determine the creditable emissions increases and decreases that occurred during the contemporaneous period for purposes of determining the "net emissions increase" of that pollutant associated with the project. Only VOC emissions exceeded the SER in Step I. b. An increase or decrease in actual emissions is contemporaneous with the increase from the project only if it occurs between: i. The date five years before construction on the project commences; and ii. The date that the increase from the project occurs. 2 c. An increase or decrease in actual emissions is creditable only if:3 1. EPA or Ecology has not relied on it in issuing a PSD permit for the source, which permit is in effect when the increase in actual emissions from the project occurs; and n. As it pertains to an increase or decrease in fugitive emissions (to the extent quantifiable), it occurs at an emissions unit that is part of one of the source categories listed in 40 C.F.R. § 52.2l(b)(l)(iii), or it occurs at an emissions unit that is located at a major stationary source that belongs to one of the listed source categories. d. A decrease in actual emissions is creditable only to the extent that it is enforceable as a practical matter at and after the time that actual construction on the particular change begins. 2 See 40 C.F.R. § 52.2l(b)(3)(ii). 3 See 40 C.F.R. § 52.2I(b)(3) for a detailed list of creditability criteria. 40 C.F.R. § 52.2J(b)(3)(iii)(b) also states that the increase or decrease should not have occurred at a Clean Unit. However, that requirement does not apply because EPA removed the Clean Unit provisions from 40 C.F.R. § 52.21 through rulemaking at 72 FR 32526, June 13, 2007. ,, ' ,, ', ' ' I ' \ I. Technical Support Document. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 3. Determine the net emissions increase. • Page 10 of32 a. The emissions increase from the project alone is added to the net contemporaneous emissions change to determine the net emissions increase of a pollutant. b. If the net emissions increase is less than the respective SER, PSD permitting is not triggered for that particular pollutant. 2.1.2. Aggregation and Debottlenecking Analysis 2.1.2.1. Project Aggregation Analysis To better understand the relatively complex issue of"project aggregation," it is important to provide verbatim a summary ofEPA's explanation of the issue. The following paragraphs are quoted from 75 FR 19567 (April I 5, 20 I 0), with footnotes omitted: When undergoing a physical or operational change, a source determines major NSR applicability through a two-step analysis that first considers whether the increased emissions from a particular proposed change alone are significant, followed by a calculation of the change's net emissions increase considering all contemporaneous increases and decreases at the source (i.e., source-wide netting calculation) to determine if a major modification has occurred. See, for example, 40 C.F.R. § 52.2l(b)(2)(i). The term "aggregation" comes into play in the first step (Step 1 }, and describes the process of grouping together multiple, nominally-separate but related physical changes or changes in the method of operation ("nominally-separate changes") into one physical or operational change, or "project." The emission increases of the nominally-separate but related changes must be combined in Step 1 for purposes of determining whether a significant emissions increase has occurred from the project. See, for example, 40 C.F.R. § 52.21(b)(40). When undertaking multiple nominally-separate changes, the source must consider whether NSR applicability should be determined collectively (i.e., "aggregated") or whether the emissions from each of these changes should separately undergo a Step 1 analysis. Neither the CAA nor current EPA rules specifically address the basis upon which to aggregate nominally-separate changes for the purpose of making NSR applicability determinations. Instead, our aggregation policy developed over time through statutory and regulatory interpretation and applicability determinations in response to a need to deter sources.from attempting to expedite construction by permitting several changes separately as minor modifications. When related changes are evaluated· separately, the source may circumvent the purpose of the NSR program by showing a less than significant emission increase for Step I of the applicability analysis, that could result in avoiding major NSR permitting requirements. This, in turn, could result in increases of emissions of air pollutants from the facility that would be higher than the increases would be had the changes been subject to NSR control requirements. The associated emissions increases could endanger the air quality health standard and adversely affect public health. Technical Support DocAnt Boeing Renton 73 7 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 201 1 • Page I I of32 As explained above, the intent ofEPA'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 emissions units that are subject to PSD review (including an evaluation of projects that have previously been permitted as minor modifications yet they should be considered part of the present project). To identify those emissions units and activities that should be reviewed as part of the 737 production capacity increase project, Ecology directed Boeing Renton to carefully review past, current, and planned projects to determine whether any should be considered and aggregated with the proposed 737 production capacity increase project. Boeing Renton summarized the results of their review in an e-mail to Ecology dated June 23, 2011, which included the following discussion: Boeing uses an internal company document called a Program Directive to authorize and change both "protection" rates and actual production rates for all of its commercial airplane models looking ahead several years. Protection rates are the maximum production rates for which tools, facility support, capital equipment, and raw materials are to be acquired or maintained to achieve. Boeing Renton is not authorized by The Boeing Company to expend resources for the purpose of securing production capacity above the protection rate. The protection rate established in Program Directives for the 737 model in 1998 was 31.5 airplanes per month. The actual 73 7 production rate has been at 31.5 per month from September 2009 until Present. A decision to increase the 737 protection rate and production rate to 35 per month was made in June, 2010. The increase in production to 35 per month is scheduled for January 2012. A decision to increase the 737 production rate to 38 per month (beginning.April 2013) and to increase the protection rate 42 per month was made in September, 2010. It is the increase in the protection rate to 42 per month which necessitates the second horizontal wing build line, the replacement/relocation of the four wing panel booths, and the construction of the additional wing paint booth which are the subject of the present PSD application. Prior to these decisions, any changes made to the 73 7 factory had been governed by the requirement to "protect" a 73 7 production rate capacity of 31.5 airplanes per month. Any changes prior to these decisions to increase the production capacity above 31.5 airplanes per month would not have been authorized and therefore not undertaken. The 5-50 paint hangar refurbishment authorized by PSD 08-0 I was necessary to sustainable maintain the 31.5 production rate while being able to properly maintain the paint hangars serving the 737 program. The additional ASA Ts and A WFIS authorized by Amendment I to PSD 08-0 I were necessary to achieve the 3 5 per month production rate. Therefore, there are no previous changes to the 737 factory that should be aggregated with the current project to increase the 737 production rate'capacity to 42 airplanes per month. i: 'I 'I Technical Support Document. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 12 of32 In addition, additional factors that you indicated would be potentially relevant to an aggregation analysis (in your April 29, 2011 email to Frank Migaiolo of Boeing Everett regarding that facility's "777 rate increase project") are discussed as follows: (a) Any minor source applications filed since the last PSD-approved project was completed at the facility. No minor new source application has been filed in the last five years.4 In conjunction with our discussion of the production capacity planning process, above, we believe [that any project] that occurred at the facility more than five years ago would not be closely related enough to the currently proposed project to support aggregation. (b) Any funding information indicating one project. According to the 737 Program Management Office, they are not aware of any funding information that would indicate a previous project should be aggregated with the current project. Funding decisions for the current project are made under the authority of the September 2010 Program Directive and are separate from and independent of the funding decisions for the prior projects which relied on earlier Program Directives for their authority. Each prior project was determined to be economically viable without regard to any potential future 737 rate increases. The proposed project is not necessary to meet any obligations to Boeing customers entered into prior to the September 2010 Rate Directive. (c) The relationship of the changes to the current project and the overall basic purpose of the plant. The overall basic purpose of the plant is to produce commercial airplanes for delivery to airline customers. As discussed above, none of the previous changes to the 73 7 factory have been for the purpose of achieving a production rate capacity greater than 35 airplanes per month. As discussed above, Boeing Renton has determined that there are no past projects that need to be considered and aggregated when performing the PSD applicability analysis for the 737 production capacity increase project. Based on Ecology's review of Boeing Renton's analysis, Ecology finds no reason to dispute this conclusion. 2.1.2.2. Debottlenecking Once the scope of the project has been identified, including aggregation ofrelated activities or projects, if applicable, the source must then determine whether the project, as a whole, will result in a significant emissions increase from the modified and any affected emissions units. Affected units are those units upstream or downstream from the unit(s) undergoing a physical change or change in the method of operation that will experience an emission increase as a result of the project. Affected units include "debottlenecked units" and units that experience an "increase in 4 PSD Permit No. PSD-08-01 was issued in 2008 and amended in 2010. Technical Support DocAnt Boeing Renton 73 7 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 13 of32 utilization" as a result of the project.5 The current EPA rules permit emissions increases from debottlenecked units (and any other unit that increases its utilization as a result of the project) to be calculated using an actual-to-projected-actual applicability test.6 · The primary changes to be made at the Boeing Renton facility in order to enable the projected 42 airplanes per month production rate (504 airplanes per year) involve the replacement of four wing panel booths in Building 4-20, the addition of one new wing booth in Building 4-86, and the modification of one existing wing booth in Building 4-86. Other changes to 73 7 manufacturing operations to achieve the 42 per month production rate do not involve changes to spray booths or other emission units. As directed by Ecology, Boeing Renton evaluated all existing emissions units that will be "debottlenecked" by the 73 7 production capacity increase project and that will experience an emission increase as a result of the project. The analysis indicates that the project will debottleneck the following airplane parts manufacturing operations: Wing Assembly Operations; Wing Clean, Seal, Test, and Paint Operations; Final Assembly Operations; Delivery Operations; and Combustion Operations. 2.1.3. Baseline Actual Emissions For an existing 7 emissions unit (other than an electric utility steam generating unit), baseline actual emissions are 8 the average rate, in tpy, at which the emissions unit actually emitted the pollutant during any consecutive 24-month period selected by the owner or operator within the I 0-year period immediately preceding either: a. The date the owner or operator begins actual construction of the project, or b. The date a complete permit application is received by Ecology, whichever is earlier. The calculation of baseline actual emissions for each emissions unit that will undergo an emissions increase must: a. Include emissions associated with start-ups, shutdowns, and malfunctions; b. Include fugitive emissions (to the extent quantifiable); 5 To address the "confusion over [EPA's] past policies for calculating emissions from debottleriecked units and from units experiencing an "increase in utilization," EPA proposed changes to the debottlenecking rule provisions that would "apply to any unchanged unit at a source that increases its utilization following a change elsewhere at the source." 71 FR 54238, Sept. 14, 2006. . 6 EPA does not require that sources use projected actual emissions to calculate their emissions increases. If a source prefers, it can calculate its emissions increases by comparing its past actual emissions to its future potential to emit. See 71 FR 54238 and footnote 7, Sept. 14, 2006. 7 For a new emissions unit, the baseline actua] emissions for purposes of determining the emissions increase that wil1. result from the initial construction and operation of such unit shall equal zero. 8 See 40 C.F.R. § 52.2I(b)(48)(ii). Technical Support Documen. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 14 of32 c. Adjust downward to exclude any noncompliant emissions that occurred while the source was operating above an emission limitation that was legally enforceable during the consecutive 24-month baseline period; · d. Adjust downward to exclude any emissions that would have exceeded an emission limitation with which the major stationary source must currently comply, had such major stationary source been required to comply with such limitations during the consecutive 24-month period;9 e. Use only one consecutive 24-month period to determine the baseline actual emissions for all the emissions units being changed, but can use a different consecutive 24-month period for each regulated PSD pollutant; and f. Not be based on any consecutive 24-month period for which there is inadequate information for determining annual emissions, in tpy, and for adjusting this amount if required by 40 C.F.R. § 52.21(b)(48)(ii)(b) and (c). Boeing Renton addressed each of the above requirements in calculating baseline actual emissions for the 73 7 production capacity increase project. Boeing Renton calculated the actual emissions based on the annual emission reports submitted to and accepted by Puget Sound Clean Air Agency (PSCAA). The emission rates.were based on actual production and consumption rate, material safety data sheets (MSDSs ), and/or EPA emission factors. Baseline actual emissions and the selected baseline periods are summarized in Table 3. Boeing Renton selected the calendar years 2009 and 2010 as the baseline period for all pollutants except for C02e which was calendar years 2006 and 2007. Average 737 production for 2009 and 2010 was 374 airplanes per year. Although Table 3 reports baseline actual emissions for the four Building 4-20 wing panel booths that will be shut down with the project, Boeing Renton is not taking credit for emission reductions resulting from shutting down those units. Boeing Renton will decommission these booths within 180 days of starting up the new booths and will notify Ecology and PSCAA as required by the PSD permit. Therefore, any emission reductions resulting from shutting down those units may continue to be creditable for future permitting actions provided other creditability criteria are met. During the baseline period, Boeing Renton 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 this application. 1 · Therefore, no adjustments are required under 40 C.F.R. § 52.21(b)(48)(ii)(b) or (c). ' ' ' ' I I 9 In Washington State, this adjustment does not currently apply to MACT limits per 40 C.F.R. § 52.2l(b)(48)(ii)(c) because the state has not taken credit for such emissions reductions in an attainment demonstration or maintenance plan consistent with the requirements of40 C.F.R. §51.165(a)(3)(ii)(G). Technical Support Doc.nt Boeing Renton 737 Production Capacity Increase Project PermitNo. PSD-11-02 September 12, 2011 • Table 2. Baseline Actual Emissions (TPY) Baseline Period Wing Assembly Wing Coating Final Assembly Paint Han~ars/ Flightline 737 Assembly' Combustion d Miscellaneous Sources of Ozone Depleting Substances (ODS) Building 4-20 wing . panel booths (4 booths, to be shut down) Building 4-20 Wing panel booths ( 4 new booths) Building 4-86 new wing booth (PB-4) Building 4-86 inspar vertical wing booth (PP-8) TOTAL EMISSIONS 2009- 2010 1.3 0 0 0 ::,2.3 2009- 2010 1.3 0 0 0 ::,2.3 ' 2009- 2010 1.3 0 0 0 ::,2.3 2009- 2010 · 0 0 0 0 0.1 0 0 0 0.1 2009- 2010 0 2009- 2010 58.6 0 76.0 0 14.3 0 36.2 34.2 0.9 0 0 3.3' 0 0 0 0 3.3' 34.2 186.0 2009- 2010 0 0 0 0 2009- 2010 0 0 0 0 13.3 0.0001 0 0 0 0 0 0 13.3 0.0001 • Total PM, S02, NOx, CO, Lead emissioris from non-combustion sources were less than l tpy. b Includes emissions from Building 4-41 paint hangar but not Building 5-50 paint hangar. c All C02e emissions are accounted for in 737 Assembly. d AH combustion-related emissions are accounted for in Combustion. Page 15 of32 2009- 2010 0 0 0 0 2006- 2007 0 0 0 2,714 0 22,039 0 0 0 0 0 0 0.0 24,753 e Boeing does not wish to take credit for these reductions at this time so they are not included in the project total. fThese emissions are also included in the Wing Coating baseline total of 76 tons so, to prevent double-counting, they are not included in the total. CO = carbon monoxide NOx = nitrogen oxides PM = particulate matter SOx = sulfur oxides CO,e = carbon dioxide equivalents ' ' ' ' ' ' Technical Support Documen. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 · 2.1.4. Projected Actual Emissions • Page 16 of32 Projected actual emissions are determined by projecting what the existing emission unit will emit once regular operation occurs following the project, as follows: • Over a 5-year period following the project if there is not an increase in the emission unit's design capacity or PTE, or • Over a IO-year period following the project if there is an increase in the emission unit's design capacity or PTE.10 , The 737 production capacity increase project will involve an increase in the design capacity of one existing inspar (vertical) wing booth (PP-8). Therefore, projected actual emissions are based on a IO-year projection. Boeing Renton is projecting the maximum 737 production rate over the Io' years following the project at a level below the design capacity (i.e. below the production capacity assuming a 365 manufacturing days per year schedule) resulting from the project. When estimating projected actual emissions, Boeing Renton: 11 . a. Considered all relevant information regarding the intended operation of the 73 7 production line in the configuration that will exist after the proposed project, including but not limited to, historical operational data, the company's own representations, the company's expected business activity and the company's highest projections of business activity, the company's filings with the state or federal regulatory authorities, and compliance plans under the approved State Implementation Plan; · b. Included emissions associated with start-ups, shutdowns, and malfunctions, and quantifiable fugitive emissions, where applicable; and c. Did not exclude any emissions that existing units could have accommodated during the consecutive 24-month period used to establish the baseline actual emissions and that are unrelated to the proposed project. Table 3 shows the adjusted projected actual emissions reported by Boeing Renton. For new units (i.e., the four wing panel booths in Building 4-20 and the new inspar vertical wing booth in Building 4-86), the projected actual emissions are equal to the units' potential to emit (PTE). Boeing Renton normally operates two production shifts per day and the projected production rate of 504 airplanes per year is based on two shifts per day. However, the new booths will be physically capable of operating three shifts per day; hence, the PTE for the new booths is based on three shifts per day operation. The potential emissions from all the four new booths in 4-20 10 See 40 C.F.R. § 52.2l(b)(4l)(i). 11 See 40 C.F.R. § 52.2l(b)(4l)(ii). Technical Support DocAnt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 17 of32 would be 8.3 tpy ofVOC.12 The PTE of the new and modified 4-86 booths combined would be approximately 23.7 tpy ofVOC, with each unit having a PTE of about 11.9 tpy ofVOC. Table 3. Projected Actual Emissions (TPY) Wing Assembly 0 0 79.0 0 0 0 Wing Coating 0 0 102.5 0 0 0 Final Assembly 0 0 19.3 0 0 0 Paint Han~ars/ Flightline 0 0 48.7 0 0 0 0 0 0 737 Assembly' 3,855 Combustion ' 2.3 2.3 2.3 0.3 62.9 1.6 24.4 0.0002 0 35,553 Miscellaneous Sources of Ozone Depleting 0 0 0 0 0 0 0 0 0 0 Substances (ODS) Building 4-20 wing panel booths ( 4 booths, 0 0 0 0 0 0 0 0 0 0 to be shut down) Building 4-20 Wing panel booths ( 4 new 8.3 booths)' Building 4-86 new 0.1 0.1 0.1 0 0 11.9 0 0 0 0 wing booth (PB-4) Building 4-86 inspar vertical wing booth 0.1 0.1 0.1 0 0 11.9 0 0 0 0 (PP-8) TOT AL EMISSIONS S3.5 S3.5 S3.5 0.3 62.9 283.3 24.4 0.0002 0.0 39,408 1 Total PM, S02, NOx, CO, and Lead emissions from non-combuStion ·sources will be less than I tpy. b Includes emissions from Building 4-41 paint hangar but not Building 5-50 paint hangar. e All C02e emissions are accounted for in 737 Assembly d All combustion-related emissions are accounted for in Combustion eProjected actual emissions for new units are equal to the units' PTE. Each new wing panel booth has a PTE of approximately 2.1 mv voe 12 Boeing's application explains that the "four new Wing Panel Booths to be located in Building 4-20 will be capable of accommodating up to 756 airplanes per year. Since each wing has two panels. and each airplane has two wings, this represents a total of3,024 panels per year." Therefore, potential emissions from the four 4-20 booths have been calculated based on a maximum production rate of756 planes per year. See Table D-6 of the application. ·Regarding the 4-86 booths, Boeing states that the "new and modified lnspar Wing Booths will have the capacity of painting one wing per day, 365 wings per year." Therefore, potential emissions from the 4-86 booths have been calculated based on 182.5 planes per year per booth. See Table D-7. ' ' ' I I Technical Support Documen. Boeing Renton 73 7 Production Capacity Increase Project • Page 18 of32 Permit No. PSD-11-02 . September 12, 2011 Since PSD Permit No. PSD-08-01 accounted for Renton's paint hangars (i.e., Buildings 5-50 and 4-41 paint hangars) and assembly operations emissions for a total of 492 airplanes per year, paint hangar emissions resulting from the production of up to 492 airplanes per year have not been evaluated as part of this project. Although Boeing has not decided where to apply the final exterior coating on the additional 12 airplanes per year (the difference between 504 and 492 airplanes per year), it is physically possible that those 12 additional airplanes per year will be coated at the Boeing Renton facility Building 4-41 paint hangar. To estimate the emissions from painting 12 additional airplanes per year at the Building 4-41 paint hangar, Boeing multiplied the baseline emissions from the Building 4-41 paint hangar by the ratio of future to baseline airplane production (i.e., 504/374). This resulted in a projected maximum VOC emissions increase at the Building 4-41 paint hangar of 12.57 tons per year. To demonstrate that this was a conservative estimate of the expected emissions increase at the paint hangars, Boeing reviewed the Building 4-41 paint hangar emissions from 2007 to 2009. For the year with the greatest emissions per airplane, 2008, the average VOC emissions for exterior coating of completed 737s at Renton was 0.406 ton per airplane. If all 12 additional airplanes were coated in Renton, the result would be an additional 4.9 tons ofVOC per year. This is considerably less than the estimated 12.57 tons per year estimated increase using the ratio of increased airplane production of 504/374. Therefore, the estimated 12.57 tons per year increase in Paint Hangar emissions more than accounts for the potential increase. 2.1.S. Project Emissions Increase The project emissions increase is calculated by subtracting the baseline actual emissions from the projected actual emissions. As shown in Table 5, VOC emissions from the project exceed the PSD SER for VOC. Therefore, a "netting" analysis was conducted for VOC. No further analysis is required for other pollutants since emission increases from the project do not exceed the applicable PSD SER for those pollutants. Table 4. Project Emissions Change (TPY) • . . .. ., ,, ( .r.·. ,' . ·• ... , .. , .... ·.1--~--,···.·· l ,. ,, ,. '" · ~olluia~t ·• .• · I'Mti ··so·· )'10~ ~. ' ''" k '-."' CClft\ : .. ·. i .. :' . PM . PM!Oi•· VOC', .co:· •1:lleac:I 'OD.ll . ' I.::,~·-· ~-•. ::f'.i,,., .,: ' '\ ,~: ,._;:.?'. : ::,c __ ::~ ·: · ... : ... ·;. "/".· -:.\. ~ j \'.:" .. -• .• ~, ,. ' u,·· .. i.;·_, .. « :,. " ' ...,;:,. -.-~" ._..,;.. . .. Significant Emission Rate 25 15 10 40 40 40 100 0.6 100' 75,000 Baseline Actual Emissions S2.3 S2.3 S2.3 0.1 34.2 186.0 13.3 0.0001 0.0 24,753 Projected Actual Emissions S3.5 S 3.5 S3.5 0.3 62.9 283.3 24.4 0.0002 0.0 39,408 Project Emissions Increase S 1.2 S 1.2 S 1.2 0.2 28.7 '', t.i1ii: 11.1 0.0001 0.0 14,655 Is the Project Emissions No No No No No ,, 'iit~:::i No No No No Increase Significant? .. ::::;; ,., 8 Emissions increase calculation does not include the expected emissions decrease from shutting down the four existing wing panel booths in Building 4-20. b See WAC l 73-400-720(4)(b)(iii)(B). -------------------------- Technical Support Doc.nt Boeing Renton 73 7 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 2.1.6. Contemporaneous Net Emissions Increase • Page 19 of32 Because the VOC emissions increase due to the project alone exceeds the VOC SER, Boeing Renton conducted a "netting" analysis for VOC emissions as directed by Ecology. The "netting" analysis involves adding all creditable increases and decreases in actual emissions that are contemporaneous with the proposed change (i.e., occurring during the period beginning on the date 5 years before construction commences on the proposed project and ending on the date that the emission increase from the proposed project occurs). See 40 C.F.R. § 52.2l(b)(2)(ii). Creditable increases do not include any increases that Ecology or EPA has relied on in issuing a PSD permit; see 40 C.F.R. § 52.2l(b)(3)(iii)(a). In the past 5 years, the following projects have or may have caused VOC emission increases as a result of debottlenecking operations: • Reconfiguration and refurbishment of existing Paint Hangar 1 (Pl) in Building 5-50. • Installation of additional automated spar assembly tools and a metal shim wet milling machine in Building 4-21. • Installation of an additional automatic wing fastener. • Installation of additional assembly tooling and support equipment in Buildings 4-20, 4- 21, 4-81, and 4-82. · Ecology has relied on the VOC emission increases from those changes listed above when Ecology approved PSD Permits No. PSD-08-01 and PSD-08-01, Amendment I, and Boeing Renton has complied with the emission requirements of that permit. Other increases in emissions over the past five years have been due to demand growth and were able to be accommodated by existing capacity and changes that Ecology has approved under PSD Permit No. PSD-97-2 for Building 4-86 or PSD-88-4 for Building 4-41 Paint Hangar. In addition, Boeing is not seeking changes to any of the PSD permit conditions; therefore, there have not been any other increases in actual emissions at Boeing Renton that are contemporaneous with this particular change and are.otherwise creditable. Furthermore, Boeing Renton is not taking credit in the netting analysis for any contemporaneous emission decreases. Therefore, the net _emission increase for the project is the same as the emission increase for the project: approximately 97 tpy ofVOC. 2.2. New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants New Source Performance Standards (NSPS) apply to certain types of equipment that are newly constructed, modified, or reconstructed after a given applicability date. There are no NSPS that apply to the proposed 73 7 production capacity increase project. The National Emission Standards for Hazardous Air Pollutants (NESHAPs) apply to categories of equipment with hazardous air pollutant emissions. 40 C.F.R. Part 63, Subpart GG, also . I : I I I I I I I I I I I • I I ! I Technical Support Documen. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 20 of32 known as the "Aerospace NESHAP", applies to facilities that are engaged in the manufacture or rework of commercial, civil, or military aerospace vehicles or components. and that are major sources of hazardous air pollutants. All aerospace manufacturing and rework operations at the Boeing Renton facility, including those associated with the 737 production capacity increase project, must comply with the Aerospace NESHAP requirements . 3. BEST AVAILABLE CONTROL TECHNOLOGY (BACT) DETERMINATION 3.1. 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 degree of reduction for each pollutant subject to regulation, emitted from any proposed major stationary source or major modification, on a case-by-case basis, taking into account cost-effectiveness, economic, energy, environmental and other impacts (40 C.F.R. § 52.2l(b)(l2)). BACT is only applied to emission units that are new or existing and undergo a physical or operational change that results in the increased emissions. In the case of the 73 7 production capacity increase project, the only new emission units would be four new wing panel spray booths in Building 4-20 and one new wing booth in Building 4-86, as shown in Table 5. In addition, one wing booth in Building 4-86 will undergo a physical change or change in the method of operation. Therefore, BACT is triggered for VOC emissions from these six booths. VOC emission increases that result from increased utilization of existing emission units due to debottlenecking are not subject to BACT requirements. Table 5. New and Modified Emission Units Building 4-20 Wing Panel Booth 4 New 2.08 50,600 Building 4-86 Wing Booth (PB-4) New 11.86 140,000 Building 4-86 Wing Booth (PP-8) Modified 11.86 140,000 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. The "top down" BACT process starts by considering the most stringent form of emissions reduction technology possible, then determines if that technology is technically feasible and economically justifiable. If the technology is proven infeasible or unjustifiable based on technical and economical feasibility or energy or other environmental considerations, then the next less stringent level of Technical Support Doc.nt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 21 of32 reduction is considered. The most stringent level of emissions control that is not successfully ruled out by the applicant is selected as BACT. Ultimately, the burden is on the applicant to prove why the most stringent level of control should not be used. 3.2. BACT for VOC Emissions from Wing Spray Booths Boeing Renton submitted a review of relevant available technology including research on prior BACT determinations listed and described in EPA's RACT/BACT/LAER Clearinghouse (RBLC) and control technology determinations found in the South Coast Air Quality Management District (SCAQMD) and the California Air Resources Board (CARB) databases. Boeing Renton found the following control technologies for VOC to have been successfully applied in spray-piiinting operations. Based on our independent research, Ecology believes this is a substantially complete list. 3.2.1. Thermal Oxidation Thermal oxidation involves heating the VOC-laden air stream up enough that the VOCs will oxidize to CO2 and water. A thermal oxidizer introduces the VOC emissions in an air stream to a burner that destroys those emissions prior to release to the atmosphere. This control technology has been improved upon over the years to include preheating the incoming air stream to obtain additional fuel efficiencies. Vendor information for thermal oxidizers with and without preheaters was obtained from Callidus and John Zink. The thermal oxidizer control technology overall cost-effectiveness in dollars per ton ofVOC removed is shown in Table 6. Large exhaust air systems general use a process called regenerative thermal oxidation (RTO). An RTO uses two or more chambers containing heat-absorbing material. The heat of combustion from oxidizing the VOCs, along with whatever supplementary heat, in the first chamber in the flow train is absorbed by the subsequent chambers. When the next chamber in the train is hot enough to oxidize the VOCs, flow is diverted to it, and it becomes the combustion chamber as it releases its heat to the exhaust gas. Overall, the system cycles back and forth between chambers. Up to about 95 percent of the heat load can be recovered, or in other words, the net heat load may be as low as five percent of the "direct heat" requirement. To improve fuel efficiency, the RTO can be augmented by the addition of a concentrator "wheel." The wheel provides for a more concentrated VOC content in a smaller air stream for burning. Boeing Renton obtained vendor information for the RTO with concentrator control technology from Anguil. Even though Anguil advised not to use a regenerative thermal oxidizer with a concentrator on the wing panel booths, estimated overall cost-effectiveness for the RTO with a concentrator, in dollars per ton VOC removed, is shown in Table 6 for both Buildings 4- 20 and 4-86. Based on the control cost estimates shown in Table 6, Ecology considers the cost of this control option to be unjustifiable for BACT purposes. ' ' t ' , I ·\ ' I ' I I I Technical Support Documen. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 22 of32 Table 6. Summary ofVOC Control Technology Costs• Thennal Oxidizer Callidus 98.9% $622,394 $420,745 $4,430,462 $2,769,040 35.4% Thennal Oxidizer John Zink 98.9% $342,475 $390,572 $7,384,104 $12,922,182 59.1% with Preheater ThCnnaJ Oxidizer Callidus 98.9% $426,192 $225,408 $7,384,104 · $5,538,078 59.1% with Preheater Thermal Carbon Adsorption· Recovery 99.3% $142,721 $54,062 $2,086,732 $1,059,412 16.7% Systems Regenerative Thermal Oxidizer Anguil 99.3% $150,662 $81,643 $3,175,165 $5,538,078 25.4% IRTQ) RTOwith Anguil 93.2% $449,780' $167,597 $2,584,436 $5,168,872 20.7% Concentrator Estimated Project Cost Without Add-on Controls $12,500,000 $20,000,000 9.2% 43.1% 14.5% 3.5% 18.5% 17.2% • Compliance with the Aerospace NESHAP requirements (including the use of low-VOC coatings, high transfer efficiency paint-spraying equipment and techniques, and Best Management Practices) is not addressed in this table because that control option was selected as BACT. b Costs for Building 4-20 are based on a preliminary exhaust flow estimate of25,000 ac:frn. The current design calls for an exhaust flow rate of 50,600 acfm; therefore, cost per ton of VOC controlled would be greater than the values shown. 'Ammil advised not to use a reQenerative thermal oxidizer with a concentrator on the wing oanel booths. 3.2.2. Carbon Adsorption Carbon adsorption uses a filter bank of canisters that contain activated carbon or zeolite. The VOC-laden exhaust air is passed through granular adsorbents. Some of the VOC are attracted to and attach themselves to the surface of the adsorbent, occupying available "active sites." When the active sites are all occupied, the adsorbent is saturated. The VOC must be removed to reactivate the adsorbent for repeated use. This is usually done by heating the adsorbent in situ with either hot air or steam. If the VOC can be stripped from the adsorbent at a sufficient concentration, they may be concentrated for recovery. Otherwise, the control technology must use an additional disposal method. Vendor information for the carbon adsorption technology was obtained from Thermal Recovery Systems. Estimated overall cost-effectiveness for carbon adsorption, in dollars per ton VOC removed, is shown in Table 6. · ---------------------------~ Technical Support Doc.nt Boeing Renton 73 7 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 23 of32 Based on the control cost estimates shown in Table 6, Ecology considers the cost of this control option to be unjustifiable for BACT purposes. 3.2.3. Low-VOC Coatings, High Transfer Efficiency Paint-Spraying Equipment and Techniques, and Best Management Practices· The use of low-VOC coatings, high transfer efficiency paint-spraying equipment and techniques, and best management practices are specified and required in the Aerospace NESHAP ( 40 C.F .R. Part 63, Subpart GG). Boeing Renton already uses low-VOC coatings that meet specifications required by the Aerospace NESHAP for airplane coating operations. Boeing Renton also uses liigh 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 coating job. In addition, Boeing Renton uses good work practices to minimize VOC emissions, including storing coatings and solvents in closed containers, 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 of cleaning solvents and coatings as defined in 40 C.F.R. Part 63, Subpart GG, Aerospace NESHAP and PSCAA Regulation II, 3.09 will be applied in this operation. Ecology recognized these as BACT and required their application in previous PSD permits issued to Boeing Renton. No cost analysis was performed because Boeing Renton has selected this option as BACT. 3.2.4. VOC BACT Determination Ecology determines that BACT for VOC emissions from the four new 737 wing panel spray booths in Building 4-20 and the new inspar and the modified inspar wing spray booths in Building 4-86 consists of the following: o Compliance with all applicable VOC emission standards of the National Emission Standards for Aerospace Manufacturing and Rework Facilities, 40 C.F.R. Part 63, Subpart GG (Aerospace NESHAP), as in effect on July I, 2011. o Limiting VOC emissions to 11.0 pounds per wing coated in the new wing panel spray booths in Building 4-20 on a twelve-month rolling average, and a combined total of 8.3 tons ofVOC in any twelve consecutive month period. o Limiting VOC emissions to 65.0 pounds per wing coated in the new inspar wing spray booth (PB-4) and the modified inspar wing spray booth (PP-8) in Building 4-86 on a twelve-month rolling average, and a combined total of23.7 tons for any twelve consecutive month period. Note that the above BACT determination only applies to the new or modified emission units (the four new wing panel booths proposed for Building 4-20 and the new inspar booth (PB-4) and the modified wing booth (PP-8) in Building 4-86), and the activities within those booths, because '· ' I ,. I Technical Support Document. Boeing Renton 737 Production Capacity Increase Project • Page 24 of32 Permit No. PSD-11-02 . September 12, 2011 those are the only emission units that are new or undergoing a physical change or change in method of operation and require a BACT analysis. For example, much of the other airplane manufacturing operations in Renton, such as attaching the wings to the main body, will not undergo a physical change or change in operation. They will only experience an increase in utilization. Under the PSD requirements, an increase in utilization, that does not otherwise require a physical or operational change and is not otherwise prohibited, does not require application ofBACT. Finally, most of the other airplane manufacturing activities are already subject to the requirements of the Aerospace NESHAP. 3.3. Toxic Air Pollutants PSD rules require the applicant to consider emissions of toxic air pollutants during the course of a BACT analysis. One reason for this requirement is to ensure that the source does not employ an emissions control technique that controls the main pollutant of concern, but emits a new toxic air pollutant in large quantities. PSCAA will issue one or more Notice of Construction (NOC) approvals for this project. The NOC approval(s) will govern emissions of toxic air pollutants. 4. AMBIENT AIR QUALITY IMP ACTS ANALYSIS 4.1. Regulatory Requirements The PSD permitting program requires that an ambient Air Quality Impacts Analysis (AQIA) be conducted for those pollutants that are subject to PSD review. As discussed in Section 3 of this Technical Support Document, only VOC emissions are subject to PSD review. The AQIA starts with preliminary modeling for each pollutant to determine whether an applicant can forego detailed analysis and preconstruction monitoring. If the projected ambient concentration increase for a given pollutant is below the modeling significance level (MSL) for each averaging period as given in 40 C.F.R. Part 51, Appendix S, no further analysis of the ambient impact is required for that pollutant. For those pollutants and averaging periods that have impacts greater than the MSL, a NAAQS analysis is used to determine if the proposed project will cause or contribute to an exceedance of aNAAQS. The PSD increment analysis is used to determine if the change in the air quality since the applicable baseline dates is greater than the Class I and Class II PSD Increment Levels. There is no PSD increment for ozone, or by extension for VOC. Typically, the AQIA includes an analysis of impacts to local areas that are within 50 kilometers of the project, and a regional air quality impact assessment for impacts beyond 50 kilometers. For projects in Washington State, this latter analysis usually includes impacts on Class I areas. Technical Support DocAnt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • 4.2. Modeled Impacts from the 737 Production Capacity Increase Project Page 25 of32 There is no MSL defined for ozone, or by extension forVOC. Instead, EPA has defined a policy that modeling for ozone is required for a ~reposed project only if the net emissions of either VOCs or NOx are I 00 tpy or more.13 • 14 • 1 As shown in Section 3, the net increase in VOC emissions from the 737 production capacity increase project is approximately 97 tpy. Since the project's net emissions increase ofVOC and NOx are both less than 100 tpy, no preliminary modeling is required for the proposed project. However, Boeing recently conducted ozone modeling of a project that involved a potential VOC increase of 297 tpy at its Everett facility (see PSD Permit No. PSD-05-02) and found no significant contribution to any ozone NAAQS exceedance. Similar results would be expected for this project if modeling was required. In addition, for this project, Boeing is not requesting a change in PSD·Permit No. PSD-08-01 Amendment I, which limits VOC emissions from Building 5-50 to 40.8 tons per year (Condition 3.1) and limits VOC emissions from the Wing Buildup and Final Assembiy operation in Buildings 4-20, 4-21, 4-81, and 4-82 to 118 tons per year. 5. ADDITIONAL IMPACTS ANALYSIS PSD regulations and guidance require an additional impacts analysis 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. Class I areas are areas of special national or regional value from a natural, scenic, recreational, or historic perspective and are afforded the highest level of protection under the PSD rules. They include most national parks, national wilderness areas, and national memorial parks. The additional impacts analysis also evaluates the effect of the project on growth in the area surrounding the project. The impacts analysis includes an assessment of increment consumption and impacts to Air Quality Related Values (AQRVs) in Class I areas. AQRVs include regional 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 effects asso.ciated with secondary aerosol formation. The Federal Land Managers (FLMs) for the National Park Service (NPS), U.S. Fish and Wildlife Service (USFWS), and U.S. Forest Service (USFS) have the responsibility of ensuring AQRVs in the Class I areas are not adversely affected. 13 Table I-C-4, NSR Workshop Manual, October 1990. 14 "Interim guidance on New Source Review (NSR) Questions Raised in Letters Dated September 9 and 24, 1992," Stanley Meiburg, Director, Air, Pesticides and Toxics, Division, EPA Region VI to Mr. William R. Campbell, Executive Director Texas Air Control Board, November 19, 1992. 15 Also see 40 C.F.R. § 52.21(i)(5)(i). '' ': I ' ' ' Technical Support Document. . Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 5.1. Visibility, PM2.s, and Ozone Impacts in Class I Areas • Page 26 of32 PSD rules require an analysis of impacts on federal Class I areas. Federal Class I areas are areas of special national or regional value from a natural, scenic, recreational, or historic perspective. They are afforded the highest level of air quality protection by PSD rules. Class I areas within 200 kilometers (km) of the Boeing Renton facility include the national parks arid national wilderness areas listed in Table 7. Air quality-related values include impacts on visibility from a federal Class I area and impacts on soil, flora, fauna, and aquatic resources within the Class I area. One screening tool that has been used by Ecology, EPA, and the FLMs to screen out projects that will likely not have a significant impact on air quality-related values, is to divide the expected emission increase in tons per year (Q) by the distance to a federal Class I area in kilometers (D). If the result is less than 10, a project is normally considered to not have a significant impact on air quality-related values in the Class I area. As shown in Table 7, the Q/D is much less than 10 for all nearby Class I areas. Table 7. "Class I" Within 200 km of the Boeing Renton Facility Alpine Lakes Wilderness Area 45.5 2.1 Mt. Rainier National Park 58.9 1.6 Olympic National Park 72.1 1.3 Glacier Peak Wilderness Area 94.5 1.0 Goat Rocks Wilderness Area 104 0.9 North Cascades National Park 139 0.7 Mt. Adams Wilderness Area 140 0.7 Boeing Renton's 4-86 Building Upgrade Project (PSD Permit No. PSD-97-02) evaluated the facility-wide emission increases that would result from increasing production from 32 to 41 airplanes per month (i.e., a potential facility-wide increase in VOC emissions ofup to 366 tpy). Because Boeing is not requesting changes to that limit, and the projected VOC emissions associated with the current project are less than the levels evaluated in PSD-97-02, it is reasonable to expect that the current project would not have significant adverse additional impacts. Boeing Renton previously modeled air quality impacts of the Boeing-Everett 787 project at seven (7) Western Washington Class I areas (shown in Table 8), using the Community Multi- ~--------------------------------------------------------- TechnicaJ·Support Doc.nt Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 27 of32 scale Air Quality (CMAQ) modeling system.16 The CMAQ modeling was performed in support of the application for Permit No. PSD-05-02, issued October 10, 2005. Impacts on ambient ozone concentrations and visibility were simulated using CMAQ. ' The CMAQ analysis concluded that the increase in PM2.s concentrations due to a voe emissions increase of297 tpy at Boeing-Everett was very small (about 0.14 percent over the base case - 2000 and 200 I) and would not cause nor significantly contribute to an exceedance of the PM2.s · NAAQS over a Class I area .. The largest percentage ozone increases of interest, -30 parts per trillion (ppt) or 0.03 percent near Mt. Rainier NP and-70 ppt or 0.1 percent at North Cascades NP, occurred briefly on July 15, 1996. The ozone increases were less than 100 ppt at any Class I area, which is less than 0.2 percent of the ozone NAAQS. Table 8. Distances from Boeing-Everett to the Nearest Class I Areas Glacier Peak Wilderness Area 70 East Alpine Lakes Wilderness Area 60 Southeast North Cascades National Park 108 Northeast Olympic National Park 91 West Mount Rainier National Park 123 Southeast Goat Rocks Wilderness Area 205 Southeast Mount Baker Recreation Area* 93 North *Mount Baker is not a designated Class I area, but it was evaluated at the request of Ecology and the FLMs. Boeing also evaluated the 24-hr average percentage increase in extinction coefficient against a five percent increase criterion, as recommended by the 2000 Federal Land Managers' Air Quality Related Values Workgroup (FLAG) guidance. The modeled extinction coefficient showed a fleeting maximum 0.1 percent hourly increase, about 1150th of the FLAG threshold without considering the difference in averaging time. Larger averaging times would result in lower estimates of extinction. The CMAQ simulations indicated that an increase of297 tons per year ofVOC at Boeing- Everett presents no significant effects on PM2.s, ozone, extinction coefficient, deciview, or visual range. Based on those findings, and because the projected increase in voe emissions from the \ ' 16 CMAQ Models-3 User Manual, EPA/600/R-98/069b, National Exposure Research Laboratory, Research Triangle Park, North Carolina, 1998. · Technical Support Documen. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 28 of32 Renton 737 production capacity increase project is significantly lower (97 tpy vs. 297 tpy), an additional air quality impact analysis was not conducted for the 737 production capacity increase project. 5.2. Local Impacts on Soils, Vegetation, and Animals According to EPA guidance, 17 for most types of soils and vegetation, ambient concentrations of criteria pollutants below the secondary NAAQS will not result in harmful effects. Only the VOC emissions from the 737 production capacity increase project are subject to PSD review. VOC is regulated as a precursor to ozone; however, ozone has no secondary NAAQS. Additionally, the expected VOC emissions from the project do not trigger a detailed ambient air quality impact analysis as discussed above. Consequently, Ecology concludes that the impacts on local soils, vegetation, and animals attributable to the 73 7 production capacity increase project will be negligible. FLAG guidance does not provide a specific VOC impact on vegetation in the Pacific Northwest. The National Park Service has established monitors for ozone in three Class I Areas in Washington State: Mount Rainer National Park; Olympic National Park, and North Cascades National Park. As discussed above, Boeing Renton estimated that the incremental increase in ozone concentrations directly attributable to the larger Everett 787 project are less than I 00 ppt. Ecology concludes that the increase in ozone from this project is not likely to cause harm to vegetation in any Class I area. 5.3. Construction and Growth Impacts Employment at Boeing Renton is expected to increase to a modest extent in association with this project. However, an increase in congestion on Washington's roads and highways as a result of the project is not expected. Therefore, the proposed project is not expected to cause adverse construction and growth-related impacts. 6. ENDANGERED SPECIES ACT Pursuant to Section V .A. of the agreement for the delegation of the federal PSD regulations by EPA to Ecology, dated February 23, 2005, 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 C.F.R. 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 C.F.R. 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. 17 Draft EPA New Source Review Workshop Manual, Chapter D, § IIC, 1990. Technical Support Doc.nt Boeing Renton 73 7 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 • Page 29 of32 On frnseri\P~!fl, the EPA notified Ecology that they have satisfied their obligations under the Endangered Species Act and the Magnuson-Stevens Act relative to this permitting action. No further ESA or MSA consultation was undertaken relative to this action. 7. 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 SEP A review has been completed for the project. The City of Renton is the lead agency for SEPA review. On July 22, 2011, the City of Renton published a Determination ofNon-Significance (DNS) under application number LUAl 1-042, ECF, for the 737 production capacity increase project. The DNS became final on August 5, 2011. Ecology concludes that the applicant has adequately demonstrated compliance with SEP A requirements. 8. PUBLIC INVOLVEMENT This permitting action is subject to a minimum 30-day public comment period under WAC 173- 400-740. Newspaper public notices announcing the public comment period m!I\li~,.R~R!i~.li!!.~. in the Seattle Times and the Daily Journal of Commerce on September 13, 2011. The public comment period £12~£~i'!iRi@{!~.Q~!'.I~]i{Q)l. In accordance with WAC 173-400-740(2)(a), application materials and other related information were made available for public inspection at: Washington State Department of Ecology Air Quality Program 300 Desmond Drive Lacey,.WA 98503 Phone: (360) 407-6803 Renton Main Library Attn: Reference Desk 100 Mill Avenue South Renton, 98057 Phone: ( 425) 226-6043 9. CONCLUSION Puget Sound Clean Air Agency Attn: Stella Nehen 1904 Third A venue, Suite I 05 Seattle, WA 9810 I Phone: (206) 689-4011 The project will have no significant adverse impact on air quality. The Washington State Department of Ecology finds that the applicant, The Boeing Company, has satisfied all requirements for issuance of a PSD permit. Technical Support Documen. Boeing Renton 73 7 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 10. AGENCY CONTACT David Ogulei, Ph.D., P.E. Washington State Department of Ecology Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600 (360) 407-6803 david.ogulei@ecy.wa.gov • Page 30 of32 Technical Support Doc.nt ' • Page 31 of32 Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 September 12, 2011 ACRONYMS AND ABBREVIATIONS Aerospace NESHAP National Emission Standards for Aerospace Manufacturing and Rework Facilities (40 C.F.R. Part 63, Subpart GG) AQIA AQRVs BACT . Boeing Renton CARB cfm C.F.R. CIC CAA. co C02e CMAQ DNS EAB Ecology EDC EIS EPA ESA ESRC FLAG. FLM gal hr HVLP Km LAER lb µg/m3 mmHg MSA MSDS MSL Air Quality Impacts Analysis Air Quality Related Values Best Available Control Technology The Boeing Company, Boeing Commercial Airplanes-Renton facility California Air Resources Board Cubic feet per minute Code of Federal Regulations Corrosion-inhibiting compound Clean Air Act Carbon monoxide Carbon dioxide equivalents Community Multiscale Air Quality Modeling System Determination of Non-Significance Environmental Appeals Board Washington State Department of Ecology Renton Delivery Center Environmental Impact Statement United States Environmental Protection Agency Endangered Species Act Electrical Systems Responsibility Center Federal Land Managers' Air Quality Related Values Workgroup Federal Land Manager Gallon(s) Hour(s) High Volume Low Pressure Kilometer(s) Lowest Achievable Emission Rate Pound(s) . Microgram per cubic meter Millimeters of Mercury Column Magnuson-Stevens Act Material Safety Data Sheet . Modeling Significance Level I I . Technical Support Document. Boeing Renton 737 Production Capacity Increase Project Permit No. PSD-11-02 • Page 32 of32 September 12, 2011 NAAQS NESHAP NOC NOx NP NPS NSPS NSR oc ODS PM PM2.s PM10 PCHB ppt PSCAA PSD PIE RACT RBLC RCW RIO SCAQMD SEPA SER S02 TPY ortpy u.s.c. USFS USFWS voes WAC National Ambient Air Quality Standards National Emission Standards for Hazardous Air Pollutants Notice of Construction Nitrogen oxides National Park National Park Service New Source Performance Standards New Source Review Degrees Celsius Ozone Depleting Substances Particulate Matter Particulate matter with aerodynamic diameter less than or equal to 2.5 micrometers Particulate matter with aerodynamic diameter less than or equal to I 0 micrometers Pollution Control Hearings Board Parts per trillion Puget Sound Clean Air Agency Prevention of Significant Deterioration of Air Quality Potential to emit Reasonably Available Control Technology EP A's RACT /BACT /LAER Clearinghouse Revised Code of Washington Regenerative Thermal Oxidizer South Coast Air Quality Management District State Environmental Policy Act Significant Emission Rate Sulfur dioxide Tons per year United States Code U.S: Forest Service U.S. Fish and Wildlife Service Volatile Organic Compounds Washington Administrative Code ------------------------------ • • Notice of Opportunity for Public Comment RECEIVED Department of Ecology Draft Prevention of Significant Deterioration Permit Permit Applicant: The Boeing Company Boeing Commercial Airplanes -Renton Facility 737 Logan Avenue North Renton, Washington 98055 What project is proposed for approval? SEP 15 2011 MAYOR'S UFFICE:. The Boeing Company (Boeing) proposes to make changes to their airplane manufacturing facility in Renton, Washington, to enable an increase in the production rate of 73 7 model airplanes. The project is intended to increase 73 7 production capacity at the Renton facility from a maximum of about 376 airplanes per year to a projected maximum of about 504 airplanes per year. Boeing will replace four existing wing panel spray booths in Building 4-20 with four new booths at another location in Building 4-20. In Building 4-86, Boeing will add a new wing booth and increase the exhaust rate on one existing spar spray booth to improve the quality of the paint finish. Other changes related to this project include adding a new wing horizontal build line in Building 4-20 (some of which will occupy the space that the four current wing panel spray booths occupy), installing a new wing riveter, and installing other miscellaneous assembly tooling in Building 4-20. There are no other physical changes or changes in method of operation anticipated at the Renton facility as a result of this project. Boeing's Renton facility is a major source of volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). The project will increase annual emissions from the Boeing Renton facility, including from the new and modified spray booths as well as from the existing boilers which supply steam to certain process equipment used in 737 manufacturing. Annual VOC emissions are estimated to increase by up to approximately 97 tons. A Prevention of Significant Deterioration (PSD) permit is required from the Department of Ecology (Ecology) because the net VOC emission increase from this project exceeds 40 tons per year. The type and magnitude of the project also necessitates a Notice of Construction Order of Approval (NOC) permit from the Puget Sound Clean Air Agency (PSCAA). An NOC will be obtained from PSCAA as a separate action. What is Ecology proposing to do? Ecology is proposing to approve the project. The agency has made a preliminary determination that this project satisfies all of the requirements for a PSD permit. ' I. I ' • • How can you review the draft permit? You can review copies of the draft permit and all supporting materials by contacting: Washington State Department of Ecology Air Qua] i ty Pro gram 300 Desmond Drive SE Lacey, WA 98503 Phone: (360) 407-6803 Renton Main Library Attn: Reference Desk I 00 Mill A venue South Renton, WA 98057 Phone: ( 425) 226-6043 Puget Sound Clean Air Agency Attn: Stella Nehen 1904 Third Avenue -Suite 105 Seattle, WA 98101 Phone: (206) 689-4011 You can also find.copies on Ecology's website at: http://www.ecy.wa.gov/programs/air/psd/psd__publiccomments.html How can you comment on the draft approval? Ecology will accept comments on this project until October 13, 2011. Send written comments to: David Ogulei Washington State Department of Ecology Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600 Or e-mail: david.ogulei@ecy.wa.gov Anyone (including the applicant) who objects to any condition of the draft approval must raise all issues and submit all arguments supporting their position by the end of the comment period. You must submit all supporting materials in full. Materials cannot be incorporated by reference, unless they are already part of the administrative record in the same proceeding or are generally available reference materials. Will there be a public hearing? A public hearing may be held if Ecology determines within the 30-day public comment period that significant public interest exists. Additionally, any member of the public may request within the 30-day public comment period that a public hearing be held for the project. Such requests must include reasons for requesting the hearing. If a public hearing is held, Ecology will notify the public of the date, time and venue for the hearing no earlier than 30 days prior to the hearing date. • • When will Ecology make a final decision? Following the close of the public comment period (October 13, 2011) or shortly after the public hearing (if one is held), Ecology will make a final determination about the project and send copies ofit to everyone who submitted comments. We will also file the final determination at the locations listed above for public review. Can a decision be appealed? Yes. Within 30 calendar days after the final decision, the PSD permit may be appealed. Anyone who commented on a draft PSD permit may appeal the final PSD permit to the Environmental Protection Agency (EPA) under 40 C.F.R. § 124.19, or to the State of Washington Pollution Control Hearings Board (PCHB). Anyone who did not file comments or participate in the public hearing may petition for administrative review only on the changes made between the draft approval and the final approval. For more information contact: Sarne contacts as listed under "How can you comment on the draft approval?" This Notice is published pursuant to WAC 173-400-171. The PSD permit is being processed in accordance with WAC 173-400-700 through 740. City a.ton Department of Community & Economic.elopment ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: ~QY(\ I(. ~ COMMENTS oufjULY 12, 2011) APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNt ,n, LU > APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: 737 Air Quality Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/ A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturin Facility, 737 Logan Avenue. All proposed development would occur w1thm ex1stmg buildings located at t e subject s1 e. e new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code} COMMENTS Element of the Probable Probable More Environment Minor Mo/or Informotlon lmpocts Impacts Necessary Element of the Probable Probable More Environment Minor Mo/or Information Impacts Impacts Necessary Earth Housinri Air Aesthetics Water UnhtfG/ore Plants Recreation Land/Shoreline Use Utilities Animals Transnortotion Environmental Health Public Services Energy/ Natural Resources Historic/Cultural Preservation Airport Environment 10,000 Feet 14 000 Feet C. CODE-RELATED COMMENTS We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional information is needed to properly assess this proposal. Denis Law .Mayor • Department of Community and Economic Dev.elopment . · Alex Pietsch, Administrator August 30, 2011 · Mark Clement · · Boeing Co. 737 Logan Avenue N . Renton, WA 98055 · SUBJECT:· 737 Air Quality Program LUAll-042; ECF . . Dear Mr. Clement:. This letter is to inform-you that the appeal· period ·ended August 5, 2011 for the Environmental Review Committee's (ERC) Determination of Non-Significa·nce for _the · above-referenced project. · · · · · .· No appeals were filed on the '{RC determination therefore, this 'decision is final and application for the appropriately required permits may proceed. The applicarit must . comply _with the Advisory Notes listed in. the Environmental Committee. Repbrtdated July 18, 2011. - If you have ;ny questions, please feel free to contact me at (425) 430-7314. · For the Environmental Reviev/Committee, ' . . . ~-Do/be_()__. Vanessa Dolbee · Senior Pl.anner Renton-City Hall •·. 1055 South Grady Way • Renton,Washington 98057 •. rentonwa.gov .. STATE OF WASHINGTON, COUNTY OF KING } AFFIDAVIT OF PUBLICATION PUBLIC NOTICE Linda M Mills, being first duly sworn on oath that she is the Legal Advertising Representative of the Renton Reporter a weekly newspaper, which newspaper is a legal newspaper of general circulation and is now and has been for more than six months prior to the date of publication hereinafter referred to, published in the English language continuously as a weekly newspaper in King County, Washington. The Renton Reporter has been approved as a Legal Newspaper by order of the Superior Court of the State of Washington for King County. The notice in the exact form annexed was published in regular issues of the Renton Reporter (and not in supplement fonn) which was regularly distributed to its subscribers during the below stated period. The annexed notice, a: Public Notice was published on July 22, 2011. The full amount of the fee charged for said foregoing publication is the sum of $91.00. ' -- vt. Mills ~-//?~6= ~ Legal Advertising Representative, Renton Reporter Subsc.ril.ied and swoi;11,.to me this 25th day of July, 2011. r the State of Washington, Residing NOTICE OF ENVIRONMENTAL DETERMINATION ENVIRONMENTAL REVIEW COMMITTEE RENTON, WASHINGTON The Environmental Review Committee has issued a Determi- nation of Non-Significance for the following project under the authority of the Renton Municipal Code. 737 Air Quality Program LUA! 1-042, ECF Location: 737 Logan Avenue N Renton, WA 98055. The appli- cant has requested for Environ- mental Review for the replace- ment of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility. All proposed development would occur within existing. buildings located at the subject site. Appeals of the environmental detennination must be filed in writing on or before 5:00 p.m. on August 5, 2011. Appeals must be filed in writing together with the required fee with: Hearing Examiner, City of Renton, I055 South Grady Way, Renton, WA 98057. Appeals to the Examiner are governed by City of Renton Municipal Code Section 4-8-110.B. Additional informa- tion regarding the appeal process may be obtained from the Renton City Clerk's Office, (425) 430- 6510. Published in the Renton Reporter on July 22, 2011. #509541. ''''""'"' I 11 ,, ,, .:;,-' :-.( DALS~ ,,, ~ .t0 ~.-,,,,.,\\\,\1::,, 0 ,,, =: ~, §~.,uN E:)(,:. ·1111 '/. ;3 \Y'.?~0 .. "(A~,. '"l;._/11,, 'l -~ .7:~ 0 r 1.,) ~ ~ :;; ~o ~ .. :.'. z ~ .... ,. . .. ,.. .,., ,;; ?;v V :° 0 .,.. 1 \ ~us"'' "'.::· 1--E '/ t.,O 11;. 1 -4.C\~"'$:::-,0 = '/ ,A •ti 0-I-=> ,, ~ - ,11 -<Ir f/111,1"\"''''',..~ ~ 1111 f:-oF WP.."' ,,.:c-11 ,, I\\\\\\\\\\'-' • • • NOTICE OF ENVIRONMENTAL DETERMINATION ISSUANCE OF A DETERMINATION OF NON-SIGNIFICANCE (DNS) POSTED TO NOTIFY lNTt.RESTEO PERSONS Of AN ENVIRONMENTAL ACTION PROJECT NAME: PROJECT NUMIIER: 737 Air Qu1llty 1>ro1r1m lUAU-042, ECF tOCATlON: 737 lo1on ,b•nue N DESCRIPTION: Th• 1ppllcant ha, ,..,quutad EnW'Onm1ntal R........, for tho replacomonl of I wln1 Hlf booths ond I new point boolh located at lh• n...in1 Mani.rlitetur1n1 Fx11lty, 737 Lopn ... ..., •• All propoHd d1v1lopm1nl would occur wllhln ulstlf\( bulldlnp loaHd at 1111 ,ubjut 1111. Th• new pa(nl and 1ul booth, would rosult In 11, quality Impact,, how.vu, th1 1ppllean11, ,..,qui rod to compry with l'll1et Sound Cl.an Air A11ncv 111ndar1b and !hi D1partm1nt ol !col"l'f 811tAv1!1abl1 Cantrol T1cllnolo1V roqulrements. THE CITY OF RENTON ENVIRONMENTAL REVIEW COMMITTEE {ERC) HAS OffERMINED THAT THE PROPOSED ACTION ODES NOT HAVE A SIGNIFICANT ADVERSE IMPACT ON THE ENVIRONMENT. Ap11ul1 of th• 1nvlronment1I d1termln1tlon must b• nl.d In wrltln1 on or before s,o,o p.m. on Au1ust S, 2011. AppHlt mu•t ba filed In wrltln1 to1ether with th• requlr1d fH with: H•1rln1 fumlnar, City of R1nlon, 1055 South Grady Way, Renton, WA 980S7. AppHls to th1 Eumln1r 1r1 100/i!med by City of Rinton Munklpal Codt 51ctlon 4-11-110.8. Addltlonal Information r .. ardln1 th1 appHI procu, may ha obta!n•d from tht Renton City dirk's Office, (425j 430·6510. IF THE ENVIRONMENTAL DETERMINATION 15 APPEALED, A PUBLIC HEARING WILL BE SET ANO ALL PARTIES FOR FURTHER INFORMATION; PLEASE CONTACT THE CITY OF RENTON, DEPARTMENT OF COMMUNITY & eCONOMIC DEVELOPMENT AT (425) 430-7200. DO NOT REMOVE THIS NOTICE WITHOUT PROPER AUTHORIZATION Please Include the project NUMBER when calling for proper flla ldentlflcatlon. CERTIFICATION I, tk&SS{f o~ /b-e-e . hereby certify that S copies of the above document were posted in S conspicuous places or nearby the described property on Date: J/2_2._/J I Signed:vf-tf~«CU,,{bg( STATE OF WASHINGTON ss COUNTY OF KING I certify that I know or have satisfactory evidence that \I a.r,e ss c.. )?0 \\:,f:f signed this instrument and acknowledged it to be his/her/their free and voluntary act for the uses and purposes mentioned in the instrument. Nota~bt\n ~}rd %1t't,e State of Washington Notary (Print): \-\ A. C1 c0k:ec My appointment expires: 4,_,,.,,,-5 .\-;)'{ ~013 ·--"""'"'""' 0""""""--"''--';.,....,==.,__ ______ _ ~-------- ·. ·• • • "'.·~··········c:~mf#RE~fo?r,l' .,,.,~~'. ·~t' ,,.,, ,,. DEPARTMENT OF COMMUNITY iECO.NOMIC DEVELOPMENT -Pl..ANNING•DIVISION ... .·. . ~ .-·-.-. . . AFFIDAVIT OF SERVICE BY MAILING ', v.' ti'. On the 20th day of July, 2011, I deposited in the mails of the United States, a sealed envelope containing ERC Determination documents. This information was sent to: Rel!~esenting Agencies See Attached Mark Clement, Boeing Owner/Applicant/Contact STATE OF WASHINGTON ) ) ss mentioned in the instrument. Dated: ~'.201 ao\\ Notary (Print): ___ ..... ~.!.a·'-'A:..i..:...-..,,&<-01..e"'-=>h"'er"--------------- My appointment expires: A-.\-a ., , 7 ~ I;.<;, cl -,1 o<.0 V template -affidavit of service by malling ·. Dept. of Ecology* Environmental Review Section PO Box47703 Olympia, WA 98504-7703 WSDOT Northwest Region • Attn: Ramin Pazooki King Area Dev. Serv., MS-240 PO Box 330310 Seattle, WA 98133-9710 US Army Corp. of Engineers • Seattle District Office , Attn: SEPA Reviewer PO Box C-3755 Seattle, WA 98124 Boyd Powers * Depart. of Natural Resources PO Box 47015 Olympia, WA 98504-7015 KC Dev. & Environmental Serv. Attn: SEPA Section 900 Oakesdale Ave. SW Renton, WA 98055-1219 Metro Transit Senior Environmental Planner Gary Kriedt 201 South Jackson Street KSC-TR-0431 Seattle, WA 98104-3856 Seattle Public Utilities Real Estate Services Attn: SEPA Coordinator 700 Fifth Avenue, Suite 4900 PO Box 34018 Seattle, WA 98124-4018 • AGENCY (DOE) LETTER MAILING (ERC DETERMINATIONS) WDFW -Larry Fisher* 1775 12th Ave. NW Suite 201 Issaquah, WA 98027 Duwamish Tribal Office • 4717 W Marginal Way SW Seattle, WA 98106-1514 KC Wastewater Treatment Division • Environmental Planning Supervisor Ms. Shirley Marroquin 201 S. Jackson ST, MS KSC-NR-050 Seattle, WA 98104-3855 City of Newcastle Attn: Steve Roberge Director of Community Development 13020 Newcastle Way Newcastle, WA 98059 Puget Sound Energy Municipal Liaison Manager Joe Jainga PO Box 90868, _MS: XRD-OlW Bellevue, WA 98009-0868 • Muckleshoot Indian Tribe Fisheries Dept. * Attn: Karen Walter or SEPA Reviewer 39015 -172"' Avenue SE Auburn, WA 98092 Muckleshoot Cultural Resources Program • Attn: Ms Melissa Calvert 39015 172"' Avenue SE Auburn, WA 98092-9763 Office of Archaeology & Historic Preservation* Attn: Gretchen Kaehler PO Box 48343 Olympia, WA 98504-8343 City of Kent Attn: Mr. Fred Satterstrom, AICP Acting Community Dev. Director 220 Fourth Avenue South Kent, WA 98032-5895 City of Tukwila Steve Lancaster, Responsible Official 6200 Southcenter Blvd. Tukwila, WA 98188 *Note: If the Notice of Application states that it is an "Optional DNS", the marked agencies and cities will need to be sent a copy of the checklist, Site Plan PMT, and the notice of application. template -affidavit of service by mailing • • OF ENVIRONMENTAL DETERMINATION ISSUANCE OF A DETERMINATION OF NON-SIGNIFICANCE (DNS) POSTED TO NOTIFY INTERESTED PERSONS OF AN ENVIRONMENTAL ACTION PROJECT NAME: PROJECT NUMBER: 737 Air Quality Program LUAll-042, ECF LOCATION: 737 Logan Avenue N DESCRIPTION: The appl!cant has requested Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quallty impacts, however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Ava!lable Control Technology requirements. THE CITY OF RENTON ENVIRONMENTAL REVIEW COMMITIEE (ERC) HAS DETERMINED THAT THE PROPOSED ACTION DOES NOT HAVE A SIGNIFICANT ADVERSE IMPACT ON THE ENVIRONMENT. Appeals of the environmental determination must be filed In writing on or before 5:00 p.m. on August 5, 2011. Appeals must be filed In writing together with the requlred fee with: Hearing Examiner, City of Renton, 1055 South Grady Way, Renton, WA 98057. Appeals to the Examiner are governed by City of Renton Munlclpal Code Section 4-8-110.B. Additional information regarding the appeal process may be obtained from the Renton City Clerk's Office, (425} 430-6510. IF THE ENVIRONMENTAL DETERMINATION IS APPEALED, A PUBLIC HEARING WILL BE SET AND ALL PARTIES NOTIFIED. FOR FURTHER INFORMATION, PLEASE CONTACT THE CITY OF RENTON, DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT AT (425) 430-7200. DO NOT REMOVE THIS NOTICE WITHOUT PROPER AUTHORIZATION Please include the project NUMBER whe~ calling for proper file identification. Denis Law Mayor July 20, 201,1· Mark Clement Boeing Co. _. 737 Logan Avenue N Renton, WA 98055 • SUBJECT: ENVIRONMENTAL THRESHOLD'(SEPA) DETERMINATION 737_Air Q.uaHty Program, LUAll-042, ECF Dear Mr. Clement: _ This letter.is written on behalf of the Environmental Review Committee (ERC) and is to inform you _that they have completed th_eir review of the environmental impacts of the above- referenced pr.oject. The Committee, on July 18, 2011, decided thatyour project will be.is·sued a Determination of Non-Significance. Please see the enclosed ERC: Report and Decision for more -details; · The City of Renton ERC has determined'that it does not have~ probable significant adv~rse impact on the environment. An Environmental Impact Statement (EIS) is not required under RCW 43.21C.030(2)(c). This decision was made.by the ERC under the authority of Section 4-6-6, Renton Munic:ipal Code, after review ;fa completed ·environmental checklist and-other. information, on file with the lead agency. Thi_s information is available to the public on request. - ' . • r . . _-Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. · on August 5, 2011. Appeals must be filed in writing together with the required.feewith: Hearing Examiner, City of Renton, 1055 South G~ady Way, Renton, WA 98057: Appeals to the . Examiner are governed by City of Renton Municipal Code Section 4-8-110.B. Additional_ information regarding.the appeal process may be obtairied from the Renton City Clerk's Office,: ~25)~~6510. . -. . . .. . ·. ·1f the Environmerital Determination is ·appealed, a public hearing elate will be set and aU p·arties - notified. lfy~u have any questions or desire clarification of the above, please call me at (425) 430-7314. For the Environmental Review Committee, ~-Dolke_o_ Vanessa Dolbee Senior Planner Enclosure Renton City Hall • 1055 South Grady Way ~ Renton. Washington 98057 • rentonwa.gov · Denis Law May~r , July 20, 2011 . •• Wa_shington State · ·Department of Ecology Envirnnm,ental Review Section PP Box 4 7.703 . Olympia, WA 98504-7703 . . ' ' ' . Department of .Community and Economic Development . Alex Pietsch, Administra.tor ! . . ' ·subject: ENVIRONMENTAL (SEPAi DETERMINATION Transmitted herewith is a copy of the Environmental Determination for the following project reviewed by the Environmental Review Committee (ERC) on July 18, 2011: . . . DETERMINATION OF NON-SIGNIFICANCE PROJECT NAME: 737 Air Qualitv Program PROJECT NUMBER: LUAll-042, ECF • . LOCATION: 737 Logan· Avenue N ! • DESCRIPTION: The applicant has requested Environmental Review for the replacement of 4 wing seal booths and a new ·paint booth located at the Boeing Manufacturing· Facility, 737 Logan Avenue: All proposed development .. would occur within existing buildings located at the subject site. The new pairit . and seal booths would result in air:"quality impacts, however, the applicant is required to comply with Puget, Sound Clea~ Air Agency standards and the . . . . . . Department of Ecology Best Available Control Technology requirements. Appeals of the environmental determination must b~ filed in writing on or before S:00 ·. p.m. on August S, 2011. Appeals must be filed in writing togett,er with the required fee with: Hearing Examiner, City of Renton, 1055 South.Grady Way, R.enton, WA 98057. · .. Appeals to the Examiner are goyerned by City of Renton Municipal Code Section 4-8- . 110.B. Additional .information regarding the appeal process ~ay be obtaine.a from the' Renton City Clerk's Office, (425) 430-6510. Please·refer to the en.closed Notice of Environmental Determination for complete details. If you have questions, please call me.at (425) 430-7314. . . . For the Environmental Review Committee, ··~-Doi~ Vanessa Dolbee Senior Planner Renton City Hall • 1055 South Gr~dy Way • Renton, Washington 98057 • rentonwa.gov • Washington State DePaitinent of Ecology Page 2.of 2 July 20, 2011 E'ndosure cc: King Cou.nty Wastewater Treatment Division Boyd Powers, Department of Natural Resou~ces Karen Walter, Fisheries, MuckleshoOt Indian Tribe Meliss'a Calvert,· Mucklfshoot Cultural Resources Program . :Gretchen Kaehler, Office of Archaeology & Historic Preservati~ri . . . ' ' . ,, -~ ----···--~·--- • , ·Ramin Pazooki, WSDOT, NW Region Larry Fi.sher, WDFW_ Duwamish Tribal Office US Army Corp. of Engineers -, • • DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT DETERMINATION OF NON-SIGNIFICANCE-MITIGATED ADVISORY NOTES APPLICATION NUMBER: APPLICANT: PROJECT NAME: LUAll-042, ECF Mark Clement 737 Air Quality Program DESCRIPTION OF PROPOSAL: The applicant has requested Environmental Review for the replacement of4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts, however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. LOCATION OF PROPOSAL: LEAD AGENCY: 737 Logan Avenue N The City of Renton Department of Community & Economic Development Planning Division Advisory Notes to Applicant: The following notes are supplemental information provided in conjunction with the environmental determination. Because these notes are provided as information only, they are not subject to the appeal process for environmental determinations. Planning: 1. RMC section 4-4-030.C.2 limits haul hours between 8:30 am to 3:30 pm, Monday through Friday unless otherwise approved by the Development Services Division. 2. Commercial, multi-family, new single family and other nonresidential construction activities shall be restricted to the hours between seven o'clock (7:00} a.m. and eight o'clock (8:00} p.m., Monday through Friday. Work on Saturdays shall be restricted to the hours between nine o'clock {9:00} a.m. and eight o'clock (8:00} p.m. No work shall be permitted on S_undays. Fire: 1. The applicant shall meet all building and fire code requirements per 2009 International Building and Fire Codes. Separate plans and permits are required for all fire suppression systems. ERC Advisory Notes Page 1 of 1 • DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT • ENVIRONMENTAL (SEPA) DETERMINATION OF NON-SIGNIFICANCE (DNS} APPLICATION NUMBER: APPLICANT: PROJECT NAME: LUAll-042, ECF Mark Clement 737 Air Quality Program DESCRIPTION OF PROPOSAL: The applicant has requested Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts, however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. LOCATION OF PROPOSAL: 737 Logan Avenue N LEAD AGENCY: City of Renton Environmental Review Committee Department of Community & Economic Development This Determination of Non-Significance is issued under WAC 197-11-340. Because other agencies of jurisdiction may be involved, the lead agency will not act on this proposal for fourteen (14) days. Appeals of the environmental determination must be filed In writing on or before 5:00 p.m. on August 5, 2011. Appeals must be filed in writing together with the required fee with: Hearing Examiner, City of Renton, 1055 South Grady Way, Renton, WA 98057. Appeals to the Examiner are governed by City of Renton Municipal Code Section 4-8- 110.B. Additional information regarding the appeal process may be obtained from the Renton City Clerk's Office, (425) 430-6510. PUBLICATION DATE: DATE OF DECISION: SIGNATURES: Gregg Zimmerm Public Works Depart Terry Higashiyama, Administrator Community Services Department July 22, 2011 July 18, 2011 , h B/i, Date ministrator Fire & Emergency Services ~.i.A-le-x~P-ie-ts_c_,h,._A_d_m_,i"'-st-r-at_o_r _ __,_ __ :! le,/ L { Department of Community & Economic Development • DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT ENVIRONMENTAL REVIEW COMMITTEE REPORT ERC MEETING DATE: Project Name: Owner: Applicant/Contact: File Number: Project Manager: Project Summary: Project Location: Exist. Bldg. Area SF: Site Area: STAFF RECOMMENDATION: July 18, 2011 737 Air Quality Program Boeing Corporation, 737 Logan Avenue N, Renton, WA 98055 Mark Clement, 737 Logan.Avenue N, Renton, WA 98055 LUAll-042, ECF Vanessa Dolbee, Senior Planner The applicant has requested Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts, however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. 737 Logan Avenue N Renton, WA 98055 716,272 SF Proposed New Bldg. Area (footprint): Proposed New Bldg. Area (gross): 151.95 Acres Total Building Area GSF: N/A N/A 716,272 SF Staff Recommends that the Environmental Review Committee issue a Determination of Non-Significance (DNS). Project Location Map ERC ReportLUA11-042.doc • • City of Renton Department of Community & Economic Development Environmental Review Committee Report 737 AIR QUALITY PROGRAM LUAll-042, E CF Report of July 18, 2011 Page 2 of 4 PART ONE: PROJECT DESCRIPTION/ BACKGROUND The applicant is requesting SEPA Environmental Review for the replacement of four wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing Boeing buildings, Building 4-20 and Building 4-86, located at the subject site. The site is located north of N 6th Street and west of Logan Ave. N. The City of Renton and The Boeing Company entered into a development agreement ("2002 agreement") on June 28, 2002, by Resolution No. 3568 which, among other things, established baseline trip counts, redevelopment credit and vesting of land use regulations under certain circumstances for ongoing Renton Plant operations and potential redevelopment, as such this project will be reviewed under Heavy Industrial (IH) zoning from 2002. Pursuant to the Renton Municipal Code in effect in 2002, Site Plan Review applied to all development in the zones listed under RMC 4-9-200B.1 did not include the IH zone. Therefore, the subject proposal does not require Site Plan Review. However, environmental review under SEPA is required. Historically, this site has been used for aircraft manufacturing and is the location of The Boeing Company's 737 airplane manufacturing plant. The surrounding uses of the proposed location is primarily aircraft manufacturing; west of the site is The Renton Municipal Airport and the Cedar River, directly south is Boeing buildings #4-17, #4-04, ar:id #4-21, east is Puget Sound Power property, the South Port development, and the Landing shopping center, and north is Lake Washington. The applicant has proposed the following improvements to Boeing Building 4-20; replace four existing wing panel spray booths with four new booths at another location in the same building. This would allow replacement of th:e vertical wing build line with a new horizontal wing build line. No other new or modified spray booths are planned, and no other emission units would be added or modified in the Building as a part of the proposed project. After completion of construction of the new seal booths, demolition of the old booths is proposed. In Boeing Building 4-86 the applicant has proposed to add one new paint booth that would provide a facility to paint the upper and lower sections of the wing. In addition, the applicant has proposed to modify the existing paint booth (PP-7) to change painting the leading and trialing edges and wing spars while the wing is in a horizontal position. The final improvement proposed in the 4-86 building, is to improve the quality of the paint finish by increasing the exhaust rate on the existing inspar wing painting booth (PP-8). In addition, to the above internal changes, the applicant intends to make other changes to the 737 assembly operations that are not expected to involve changes to spray booths or other emission units. These changes include, but are not limited to, installing a new wing- riveter, a second Wing Horizontal Build Line and other miscellaneous assembly tooling. Because all the proposed development would be located within existing buildings and no exterior work is proposed, the result is no change in impervious surface, grade and fill, or parking and access. The proposed improvements would allow the Boeing Company to increase the production capacity from the current rate of about 372 737 airplanes per year. The Washington Department of Ecology (DOE) has issued several Prevention of Significant Deterioration (PSD) permits for the Renton Boeing manufacturing facility in the past, including but not limited to the following: • PSD-08-01 which included Building 4-20 and the existing four wing seal booths located in this building. This PSD permit limited the Voltaic Organic Compound (VOC) emission from Building 4-20 ERC ReportLUAll-042.doc City of Renton Deportment of Community .anomic Development 737 AIR QUALITY PROGRAM Env.entof Review Committee Report LUAll-042, ECF Report of July 18, 2011 Page 3 of 4 to 118 tons per year (tpy). Pursuant to the application materials the applicant is not seeking to change that limit with the application; however the project would result in physical and operational changes in Building 4-20 to replace the 4 existing seal booths with four new seal booths. • PSD-97-2 includes Building 4-86. Condition 2 of the PDS permits limited VOC emission from Building 4-86 to 242 tpy. Pursuant to the application materials the applicant is not seeking to change that limit however, the proposed new paint booth and other improvements would result in physical and operational changes to Building 4-86. ~ PART TWO: ENVIRONMENTAL REVIEW In compliance with RCW 43.21C.240, the following environmental (SEPA) review addresses only those project impacts that are not adequately addressed under existing development standards and environmental regulations. A. Environmental Threshold Recommendation Based on analysis of probable impacts from the proposal, staff recommends that the Responsible Officials: Issue a DNS with a 14-day Appeal Period. B. Mitigation Measures 1. None C. Exhibits Exhibit 1 Exhibit 2 Exhibit 3 Exhibit 4 Exhibit 5 Exhibit 6 Exhibit 7 Boeing Owned Properly Site and Neighborhood Detail Map Building 4-20 Site Plan Building 4-81, 82 & 4-86 Site Plan Partial Floor Plans of Building 4-20 and 4-86 Photo of Building 4-20, 21 Photo of Building 4-81, 82 Photo of Building 4-86 D. Environmental Impacts The Proposal was circulated and reviewed by various City Departments and Divisions ta determine whether the applicant has adequately identified and addressed environmental impacts anticipated to occur in conjunction with the proposed development. Stoff reviewers have identified that the proposal is likely to have the following probable impacts: 1. Air Impacts: The production of 737 aircrafts at the Boeing manufacturing facilities requires such activates to occur such as spray coating, sealing, hand-wipe and flush cleaning, and the use of miscellaneous adhesives, resins, and other products that contain voltaic organic compounds. These activities are the primary source of air emission from the manufacturing facility. Overall voe emissions from all 737 assembly operations at Boeing include painting of completed aircrafts, average about 0.77 ton per airplane. Of the 0.77 ton per airplane, the projected voe emissions from each of the wing panel booths in Building 4-20 are about 17.6 pounds per airplane ERC ReportLUAll-042.doc • • City of Renton Department of Community & Economic Development Environmental Review Committee Report 737 AIR QUALITY PROGRAM LUAll-042, ECF Report of July 18, 2011 Page 4 of 4 or about 1.11 tpy per booth. The new and modified booths in Building 4-86 would each emit 104 pound of VOCs per airplane for a total of 6.55 tpy per booth. The proposed new paint and seal booths would result in air quality impacts, however, the applicant has proposed to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. Mitigation for these air impacts includes filtration of inorganic hazardous air pollutants from paint booth exhaust and limitations on the concentration of VOC and organic hazardous air pollutants in the coatings. Furthermore, the four new seal booths are replacing four old seal booths which would reduce the potential impacts that would occur from an additional four new booths. However, the new paint booth is an addition to the overall facilities air emissions. Mitigation Measures: No further mitigation measures required. Nexus: Not Applicable E. Comments of Reviewing Departments The proposal has been circulated to City Department and Division Reviewers. Where applicable, their comments have been incorporated into the text of this report and/or "Advisory Notes to Applicant." ./ Copies of all Review Comments are contained in the Official File and may be attached to this report. Environmental Determination Appeal Process: Appeals of the environmental determination must be filed in writing on or before 5:00 PM, August 5, 2011. Renton Municipal Code Section 4-8-110.B governs appeals to the Hearing Examiner. Appeals must be filed in writing at the City Clerk's office along with the required fee. Additional information regarding the appeal process may be obtained from the City Clerk's Office, Renton City Hall -7th Floor, 1055 5. Grady Way, Renton WA 98057. ADVISORY NOTES TO APPLICANT The following notes are supplemental information provided in conjunction with the administrative land use action. Because these notes are provided as information only, they are not subject to the appeal process for the land use actions. Planning: 1. RMC section 4-4-030.C.2 limits haul hours between 8:30 am to 3:30 pm, Monday through Friday unless otherwise approved by the Development Services Division. 2. Commercial, multi-family, new single family and other nonresidential construction activities shall be restricted to the hours between seven o'clock (7:00) a.m. and eight o'clock (8:00) p.m., Monday through Friday. Work on Saturdays shall be restricted to the hours between nine o'clock (9:00) a.m. and eight o'clock (8:00) p.m. No work shall be permitted on Sundays. Fire: 1. The applicant shall meet all building and fire code requirements per 2009 International Building and Fire Codes. Separate plans and permits are required for all fire suppression systems. ERC ReportLUAll-042.doc l'UIIET-1111111 A, ......... , ,.,,,--.......... City of Renton Pla nning Div isi on LEGEND: I~ BOEING COMMERCIAL AIRPLANES PLAN VIEW 9fA.L" ,._ J/111-o* ® EXHIBIT 1 ,.._, .Aaa I I aAt ,~,4Nla' -·· .. Y ~ ~ 737 RATE READINESS PROJECT LOCATIONS ,--+1-+-1-------• (4) NEW SEAL BOOTHS· 4-20 BLDG LINE 6 SEE SHEETS SEPA-11A & SEPA-250 -----• NEW HORIZ. BUILD LINE (HBL) • 4-20 BLDG· LINE 4 ~8 i~ 1; SEE SHEET SEPA-1 lA NEW WING RIVETER· 4-20 BLDG • LINE 5 SEE SHEET SEPA-11A NEW WING TO BODY JOIN· 4-81-82 BLDG· LI NE 2 SEE SHEET SEPA-11 B REVISE EXIST MOVING LINE· 4-81-82 BLDG· LINE' SE£ SHEET SEPA-118 NEW PAINT BOOTH· 4-86 BLDG SEE SHEETS SEPA-118 & SEPA-250 REVISE PPS PAINT BOOTH· 4-86 BLDG SEE Slm'S SEPA-118 & SEPA-250 LEGAL DESCRIPTION ~ ----.,. « --CIMAt -=...--=-~~~-=-"-t"C~°$'C==~~-=~~~ ...... iiilti ---CIXW-MPMZJ. ... ~. -~-."t.~:r... r::i= ...... ,_-~.--... ......,.1,. ~=--.~--..._..K....._ ~'Fm'a"':.n&l:n£•-U:----sm m: -• caerr .,....._... .................... _. ... F::... £1:;""""lr.ia. ~.:;:.-1-~ ~=...'"'=Yl.·--·-- ~~.,r&v~· ---cm « IOCIW N AIIGX i:a:--:"i:.= ~..::'~:r... .... ,::::; ft"1a. UilAIII --... ' &:::rA,.-='l,,ll·--·-- ~~~~ ~ · ·--~'V .. .. __, .,,,.,,.oo~ .., .......................... ~ ....... I ,.-:::=__. ~~= ,;;a.~sM-~::0.jw B 1• -·" ~ I---· .. ·-I • 1• -• HJffllM _~.w _ ___,., C 0 .... C: ·-ci Q,) -~ ...... a: 0 O') \fa-0 I 0 s z C :::> ~c -, ... cu ·-a.. C,) • IQ) . ~: Ml] ~ = Ml] g Ml) ©b \ ® z ~ .. ~- a.. N 1-.... ca .... :c >< w II --1 II I 1, t II II I! I! C: 0 C: {Q) ...... Q ~ -~ lJ1JlJ a: 6 ~ .... 0, c:::::::, ,l 0 .§ fJd1[J ~- al al ,._. C g ~I: ·-~ ..- (.) Q. lll!lJ !~ @I: = w en z D\.----111--~~~-~--=---~ ® -~W ti,B.~_~!_pG -PROPOSED PAINT BOOTH FLOOR" PLAN ® !;:-£B~~~G -REVISE PPB PAINT BOOTH FLOOR PLAN ® •lrir•-··----1u.1NI ua EXHIBIT 4 (ji..111.1/!'INII" .:: 1: II ' 1 1 . ',, i:== J ' ' ' ' ' ' City of Renton Plann ing Division JUN -9 2011 ~~(G~UW~[Q) L_ HI I I • 8 · 1 1 -1 I I i I (1Q ! i rr-~ -u· :· -' _// "'--' ------------- ~:----~-==-====~ "=" - ti:,2~t~,Lg_c -(4) NEW SEAL BOOTHS FLOOR PLAN @ e ~ 113G'1SN ... ,, --· ..... BUILDIN GS 04--020 & 04-086 -- e I - j Ln 1-t-t ca t-t ::c >< w U) ... .... r::a .... { 0 ::c >< w 0 l :r :, r City of Re! Department of Community & Economic Dev,pment ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNE 28, 2011 APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee JUN 2 9 2011 _:_P:.:RO::J::E:.::C::_T..:.T:.:IT:.::L::E:c_.:..:73:.:7:_:Ac::i::...r .::Oe:u=al.:.:it"-y-'-P:..:ro::.sg::_ra:.:m.:.:.._ _______ -1-::...P:.:RO=:J:.:E:.::CTc.:.::...R:::EV::...l:.:E::...W:.:E:::R::_: ::_K:.:a.!.:yr:.::e:..:n::_K.:.:it:::tr.:.:ic:::k ____ .g45:p~'i\-,I-I!;; D SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code) COMMENTS Element of the Probable Probable More En11ironment Minor Major Information Impacts Impacts Necessary Element of the Probable Probable More En11/ronment Minor Major Information Impacts Impacts Necessary Earth Housina Air Aesthetics Water Liaht!Glore Plants Recreation Land/Shoreline Use Utilities Animals Transnortation Environmental Health Public Services Energy/ Historic/Cultural Natural Resources Preservation Airport Environment 10,000 Feet 14 000 Feet B. POL/CY-RELATED COMMENTS C. C0DE-RELA6~ 1 ~a.---l ~ ~ ~~. We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas wher dditional information is needed to properly assess this proposal. / Date City of Re! Department of Community & Economic Dev,pment ENVIRONMENTAL & DEVELOPMENT APPL/CATION REVIEW SHEET REVIEWING DEPARTMENT: COMMENTS DUE: JULY 12, 2011 • V DATE CIRCULATED: JUNE 28, 2011 APPLICATION NO: LUAll-042, ECF APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: 737 Air Quality Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/ A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code} COMMENTS Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Earth Houslno Air Aesthetics Water (f(JtitlGJare Plants Recreation Land/Shoreline Use Utilities Animals TransMortation Environmental Health Public Services Energy/ Natural Resources Historic/Cultural Preservation Airport Environment 10,000 Feet 14 000 Feet 8. POLICY-RELATED COMMENTS We have reviewed this application with particular attention to those oreas in which we have expertise and have identified areas of probable impact or areas where additional informati ded.to_properly assess this proposal . .---·· ' \ Date I.; • • City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: f-2:t.vll<; 'f'p_ci COMMENTS DUE: JULY 12, 2011 • APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNE 28, 2011 APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: 737 Air Quality Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code) COMMENTS Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Element of the Probable Probable More Environment Minor Mo/or Information Impacts Impacts Necessary Earth Housinn Air Aesthetics Water Liaht/Gfare Plants Recreation Lani:i/Shareline Use Utilities Animals Transaortation Environmental Health Public Services Energy/ Historic/Cultural Natural Resources Preservation Airport Environment 10,000 Feet 14 ODO Feet B. POLICY-RELA TEO COMMENTS C. CODE-RELATED COMMENTS We have reviewed this application with particular attention to those areas in which we have expertise and hove identified areas of probable impact additional information · eeded to properly assess this proposal. (p-3{)-// Date 'f • • • City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REv1Ew1NG DEPARTMENT: Ara,. 1 COMMENTS DUE: JULY 12, 2011 • APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNE 28, 2011 APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: 737 Air Quality Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code) COMMENTS Element of the Probable Probable More Element of the Probable Probable More Environment Minor Major Information Environment Minor Major lnfcirmatlon Impacts Impacts Necessary Impacts Impacts Necessary Earth Housinn / Air Aesthetics ,/ Water L0ht/Glare / Plants Recreation / Land/Shoreline Use Utilities ; Animals Transoortation ,/ Environmental Health Public Services ,/ Energy/ Historic/Cultural / Natural Resources Preservation , Airport Environment / 10,DDD Feet 14 000 Feet B. POL/CY-RELATED COMMENTS c. CODE-RELAT COMMENTS We have re ewe this application with particular attention to those areas in which we have expertise and have identified areas of probable impact ditional informati eded to properly assess this proposal. Signatu Date City of Re! Department of Community & Economic Dev!pment EN VI R O NM EN TA L & DE V E.L OP MEN T A PPL IC A TIO N RE VIE W SHEET REVIEWING DEPARTMENT: COMMENTS DUE: JULY 12, 2011 APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNE 28, 2011 APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: 737 Air Quality Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/ A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code) COMMENTS Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Earth Housinn Air Aesthetics Water LinhtfGlare Plants Recreation Land/Shoreline Use Utilities Animals Transnortation Environmental Health Public Services Energy/ Natural Resources Historic/Cultural Preservation Airport Environment 10,000 Feet 14 000 Feet 8. POL/CY-RELATED COMMENTS C. CODE-RELATED COMMENTS We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional in or ation is needed to properly assess this proposal. Signature of Director or Authorized Representative Date Accounts Receivable • · • eL-21nv::oic:.e ---~mt~rni1t@ITll AR Account No. 1002 1055 South Grady Way Renton, WA 98057 (425) 430-6897 BOEING COMPANY MARK CLEMENT, PERMIT/LAND USE PO BOX 3707, MS 1 W-09 SEATTLE, WA 98124 26238 06/14/2011 1,030.00 07/19/2011 f tmountlEffBloseaf Make Checks Payable to the CITY OF RENTON Please include your AR account number ------------When paying by check, detach and return the above with payment. --------· CITY OF RENTON Environmental Review Fees LUA11-042 Permit Amount 1030.00 Technology Fee CCOUNT NO. 1002 lilESGRIP.ffilC!lN Total Amount Due: TO AV01D INTEREST AND/OR PENAL TY CHARGES PLEASE REMIT PAYMENT BY DUE DATE 1,000.00 30.00 1,030.00 1,030.00 Please Remit to: CITY OF RENTON ATTN: FINANCE/ AR 1055 S. GRADY WAY RENTON, WA 98057 • • City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: COMMENTS DUE: JULY 12, 2011 APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNE 28, 2011 APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: 737 Air Quality Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant ls required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code} COMMENTS Element of the Probable Proboble More Environment Minor Major Information Impacts Impacts Necessary Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Earth Housinn Air Aesthetics Water Linht!Glare Plants Recreation Land/Shoreline Use Utilities Animals Transnortotion Environmental Health Public Services Energy/ Natural Resources Historic/Cultural Preservation Airport Environment 10,000 Feet 14 000 Feet B. POL/CY-RELATED COMMENTS C. CODE-RELATED COMMENTS /1,,et,,f t>,J( f,., ii}.~ o..,,.,/ ~ ec,k fUlt,d/hL~ ~e,,r_ zoc>'j ;t:,.;J.e,..J".<.-~I B.,ll)~ o,,_,--c/ ;:;'.lk CoJer. Set~~ f'lc..,..,/'c..~ f e-,r..-/ ~ /2-~-~t:Y !,v,_} J),, "-o,.f( ~ ..,.,/I',.,_._,.....,-/'(}w .sj ~J-.,;,..._,r, We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional information is needed to properly assess this proposal. ('1'-7~ 61?1 !tr I ; Signature of Director or Authorized Representative Date COMMENTS DUE: JULY 12, 2011 APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNE 28, 2011 APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee PROJECT TITLE: 737 Air Quality Program PROJECT REVIEWER: Kayren Kittrick SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/ A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code) COMMENTS Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Earth Housina Air Aesthetics Water linht!Glore Plants Recreation land/Shoreline Use Utilities Animals Transnortation Environmental Health Public Services Energy/ Historic/Cultural Natural Resources Preservation Airport Environment 10,000 Feet 14.000 Feet 8. POLICY-RE LA TED COMMENTS C. CODE-RELATED COMMENTS We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional · iformation is needed to properly assess this proposal. Dat{ • • City of Renton Department of Community & Economic Development ENVIRONMENTAL & DEVELOPMENT APPLICATION REVIEW SHEET REVIEWING DEPARTMENT: COMMENTS DUE: JULY 12, 2011 APPLICATION NO: LUAll-042, ECF DATE CIRCULATED: JUNE 28, 2011 APPLICANT: Mark Clement PROJECT MANAGER: Vanessa Dolbee _:__:PR.:.:O:::J::.E::.CT.:....:.Tl:..:T.:.LE::.::_7:..:3:..:7...:A.::i:...r Q=ua:::l:;ityr..:...Pr:..:o:s,g:;ra::.m:.:..._ _______ +:...PR.:.:O:::J::.E::.CT.:...:.:R.:.EV:.:l.:.EW=Ec:.:R:...: .:.:K.:.ay'-'r.:.e:..:n.:.:K:;itt::.r:.::ic:::.k ___ -1-Ju..~!.l!=,JUIL.l!~D SITE AREA: 6,618,761 square feet EXISTING BLDG AREA (gross): 716,272 square feet LOCATION: 737 Logan Avenue N PROPOSED BLDG AREA (gross) N/A SUMMARY OF PROPOSAL: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. A. ENVIRONMENTAL IMPACT (e.g. Non-Code} COMMENTS Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Element of the Probable Probable More Environment Minor Major Information Impacts Impacts Necessary Earth Housin" Air Aesthetics Water Liaht!Glare Plants Recreation Land/Shoreline Use Utilities Animals Tronsrlortotion Environmental Health Public Services Energy/ Natural Resources Historic/Cultural Preservation Airport Environment 10,000 Feet 14 000 Feet 8. POL/CY-RELATED COMMENTS C. CODE-RELATED COMMENTS ~~ We have reviewed this application with particular attention to those areas in which we have expertise and have identified areas of probable impact or areas where additional in ormation is needed to properly assess this proposal. • ~ ~ NOTICE OF APPLICATION AND PROPOSED DETERMINATION OF NON-SIGNIFICANCE (DNS) OATl: I.AND USl NUMIER: Juno 18, 1011 LU"11-0U,fCF H7AlrQu1ll1yP,"1~"' PROJ(C! DlSClUPTION: Tho 1ppllc1nt hu requo,tod lo• f""l•onmont,I R11Yl•w for tho repluom1ntof • wln1 seal bootl\s Ind I"""' point boolh k>cl11d It lh• llo1in1 M1nu!o<1urln1 hclllty, 737 Lo11n A,1nu1. All pn,po,,d dovolopm1nt W<>uld occur within e,l1t1n1 bulldln1• loc1t1d ,t tho ,ubjttt ,lte. Tho new pal,,t ,nd 1ul booth., would ruul.t In ok quollty Impacts;,.,_...,, IM 1pplic1nt Is r,rqulrod to c<>mpl-/ wl!h P111et Sound aun AlrAl•""l' ,tand•ftl• · ind the D1p1Mm1nt cl !"color; Best A,1il1blo Control Ter.hnolo('I requl~mont, PROJlCT WCATION: OPllONAI. 0Uf.RM1NATION OF NON-SIGNIFICANCE, Mm GAUD (ONS): .... th, load .ll••cv. 1h; City or Renton ha, do1orm1Md that 1l1nfll<ant ,,,.lro,,m,nt,I Impact, ••• ..,,rr,,ly to •U'-"t r.om 11,o QfOIIOHd p,0J1c1. Thtrelot'O, u permlne<I undor tM RCW 43.UC.110, 111• Oty of ~onton 1, u11n1 ti'to Optloo1I oi;s prot1H to 1101 r.ollto thot IONS r. Uk•ly to bo t.suod. Common\ porlod, for 1ho projott tr>d tho propoHd ONS "" IM1.,.11od ltlto , ,lngi<, common\ period. There will be r,o comm1nt period followln1 th• l11u,nco of tho Thr11hold Ootormlnatlon of Non•Sl1nllk.1nte· Mltl111ted lDNS). A 14·d•Y appHI p-,lod will follow tho lu.u,nco of tho DNS. PE~MIT APPUCATION OIi.TE, NOTICE OF COMPUTE APPLICATION: Juno 9, 2011 Juno 25,lOH 11.PPLltllNT /PROJECT CONTACT PERSON, Mork 01m1nt aooln1; 737 L"I'.•• A .. nu1 N; Ronlon, WA ,10S5; Emt: ma,k,<1.<11,...r,1•-"l·com Otho, Pormlb which may be roqul,od: N/A Lo,:,tlon whu11ppHc.tlon may be r1'111w1d: Oo~1rtm1nt ol Community• Economic 0Holopmo"t !CEOI-Pl1nnl"I DIYlllon, SMII ,1oor ~on!..,, Clty H,11, 1055 South Grady Way, Ronlon, WA 91051 PUIUC KEMlNG: C0NSllnNCt' OYUYl[W: Zonlnt/land UIO: ,,. Tho ,ubjMI ,Ito 1, dH!footod Urban (1ntor North (UC·NI on !ho Qty of~onton · Compn,hon1~ L,ond ll10 ~ap1r>d Ul'WnC.nt•r H<>rth 2 (1/C·Nll<>n ti,. Ot(• lonln1Map. If you wuuld Ill« to b• mode I porty of record to retolvw fur1hor Information on thl, propo'"d project, e,,mplot• thll lo,m 1r>d return to: Cltyol R•nlon, CEO -Plann"'f; OMlk>n, 10SS So.Grady Way, R.,.l..,,, Wll 98057. N1mo/Fllo No.: 7H AlrQuollty Pro~ram/lUAl!-042, ECF NAMt: --------------------------- MlllllNG AOORUS: lttEPttONENO· (nvlronme.,.,I Document> that E-.lu,to tho Propoo,d p,ol«t: Oovelopmont Ro1ul,tlon1 Uud for J>rolo<t MltlpUon: Prop<>Hd Mltl1•tlon Moa1utH: • Envlronm•nt1I (SEPA) Chockll,t n.. prol«1 will bl ,ubjetl to tl>o at(,SEP• ordlnlnco, RMC•·,.070 and otho• ,pplicobl• codes and <el"lllio"' H •ppr~pr11te. TM tollowln1 Mltl111ton M!UurH will llko'f be lmpoHd <>n tOo P'OP<>Hd projoct. Thuo ,re,,mmendod Mllla•tlon MoHutrl odd,,,. P<Ol•<t lmpatU "ot covorri l:7y olst1n1 tad•• 1nd ,01ula\lons n ,;ited tbov•. Common!> on tho ,1,o,, ,ppllatlon mun bl 1Ytlml\tO<I In"'"""' IO Yonn11 Dolllff, S.nlor Planner. tfll -Plannl"C oi.i,lon, 105, south Grady Way, Ronton, WR 930$7, by J:00 PM on July 12, 2011, II you h1•,o quo,tlons about thl1 p<opoul. or will> lo b• .....te a porty o! rocord and ,..,...., ..id~tonol notlflutlon bt' rn&U, contact lll• Proje<\ Man•I."· Myono who 1ubmlts wrlU•n comm•nU wlll automatlc.lly bocome • por1y ol reeortl ond wlll be nOtlft•d of any docl,.on on\h11pr0Joct. CONTACT PERSON: Vanessa Dolbee, Senior Planner; Tel: {425) 430-7314; Eml: vdolbee@rentonwa.goV PLEASE INCLUDE THE PA.OJECT NUMBER WHEN CAlUNG FDA. PROPER FIL£ IOENTIFlCATLON CERTIFICATION I, /Jr,es; tit. ---Oo /J,ee , hereby certify that "s copies of the above document were posted in _3___ conspicuous places or nearby the described property on Date: &?/28/(f Signe~Jl))q ~ , STATE OF WASHINGTON ss COUNTY OF KING I certify that I know or have satisfactory evidence that Van-es S"\. J:?a \ laee signed this instrument and acknowledged it to be his/her/their free and voluntary act for the uses and purposes mentioned in the instrument. Notary Public in a;forthe State of Washington Notary (Print): 1-1 A. My appointment expires:_~A'-'-'~'*"'1.._15 ..... f:'---'&=-'-q 1 ,....,.;;,"-'oo;,,J,.,..?'------- ,---------------------------- , . . , • • · · · · · __ ·_ ··· ' ',~t~(8iR:~~fc!N'r~''~7~ 11~fi:·~~~";!I ···_"! -~T,("' DEPARTMENT-oF'coMMUNrri&i(Z~l'Jb~IC:D~fe.:oi>'r.nfNf:~\p~~Nltil_m-Qj\1~1oril· iFFIRAiliilo~:~E·Rv1c:esvtM~i~if£t . _ -- On the 28th day of June, 2011, I deposited in the mails of the United States, a sealed envelope containing Acceptance Letter, NOA, Environmental Checklist, Site Plan documents. This information was sent to: Re11~esenting Agencies See Attached Mark Clement -Accpt Ltr Owner/Applicant/Contact 300' Surrounding Property Owners -NOA only See attached (Signature of Sender): STATE OF WASHINGTON ) ss ) 1 ~JJJ I certify that I know or have satisfactory evidence that Stacy M. Tucker \-o, !,~j COUNTY OF KING signed this instrument and acknowledged it to be his/her/their free and voluntary act for tn~~~\~!e-lltfSoses mentioned in the instrument. Dated: Notary Pub~in and for the State of Washington Notary (Print): ____ -"H"-. -'-A-'--. -"G"-· '-'"'1-:"""b""er,__ ___________ _ My appointment expires: .4,,._0<.,~ 4 ol. q 1 :;:t0{3 737 Air Quality Program template -affidavit of service by mailing ... ,. Dept. of Ecology • Environmental Review Section PO Box 47703 Olympia, WA 98504-7703 WSDOT Northwest Region ' Attn: Ramin Pazooki King Area Dev. Serv., MS-240 PO Box 330310 Seattle, WA 98133-9710 US Army Corp. of Engineers • Seattle District Office Attn: SEPA Reviewer PO Box C-3755 Seattle, WA 98124 Boyd Powers • Depart. of Natural Resources PO Box 47015 Olympia, WA 98504-7015 KC Dev. & Environmental Serv. Attn: SEPA Section 900 Oakesdale Ave. SW Renton, WA 98055-1219 Metro Transit Senior Environmental Planner Gary Kriedt 201 South Jackson Street KSC-TR-0431 Seattle, WA 98104-3856 Seattle Public Utilities Real Estate Services Attn: SEPA Coordinator 700 Fifth Avenue, Suite 4900 PO Box 34018 Seattle, WA 98124-4018 • AGENCY (DOE) LETTER MAILING (ERC DETERMINATIONS) WDFW -Larry Fisher• 1775 12th Ave. NW Suite 201 Issaquah, WA 98027 Duwamish Tribal Office • 4717 W Marginal Way SW Seattle, WA 98106-1514 KC Wastewater Treatment Division • Environmental Planning Supervisor Ms. Shirley Marroquin 201 s. Jackson ST, MS KSC-NR-050 Seattle, WA 98104-3855 City of Newcastle Attn: Steve Roberge Director of Community Development 13020 Newcastle Way Newcastle, WA 98059 Puget Sound Energy Municipal Liaison Manager Joe Jainga PO Box 90868, MS: XRD-OlW Bellevue, WA 98009-0868 • Muckleshoot Indian Tribe Fisheries Dept. • Attn: Karen Walter or SEPA Reviewer 39015-172"' Avenue SE Auburn, WA 98092 Muckleshoot Cultural Resources Program • Attn: Ms Melissa Calvert 39015 112°' Avenue SE Auburn, WA 98092-9763 Office of Archaeology & Historic Preservation• Attn: Gretchen Kaehler PO Box48343 Olympia, WA 98504-8343 City of Kent Attn: Mr. Fred Satterstrom, AICP Acting Community Dev. Director 220 Fourth Avenue South Kent, WA 98032-5895 City of Tukwila Steve Lancaster, Responsible Official 6200 Southcenter Blvd. Tukwila, WA 98188 *Note: If the Notice of Application states that it is an "Optional DNS", the marked agencies and cities will need to be sent a copy of the checklist, Site Plan PMT, and the notice of application. template -affidavit of service by mailing ~ .... 722550010507 1995 MANN LIMITED FAMILY PA C/0 D MANN 17437 SE 102ND ST RENTON WA 98059 722450034003 BROTTEN LANNETTE C 524 BURNETT AVE N RENTON WA 98055 722550008501 DUNLAP BAPTIST CHURCH 330 SW 43RD ST #K293 RENTON WA 98057 722550008006 HOOT CHERYLL 16434 SE 235TH ST KENT WA 98042 722550009509 MEAD ROBERT C 432 BURNETT AVE N RENTON WA 98055 722450034508 PEDEFERRI ERIC 12427 NE 87TH ST KIRKLAND WA 98033 722450033500 SCHULTZ NORMAN CORP 7634 S SUNNYCREST RD SEATTLE WA 98178 722550007503 TAYLOR THOMAS L+DORIS S 16383 SE 48TH DR . BELLEVUE WA 98006 088660004008 TRANSWESTERN HARVEST LKSHOR C/0 THOMSON REUTERS PO BOX 06019 CHICAGO IL 60606 • 082305902700 BNSF PO BOX 961089 FORT WORTH TX 76161 722550010002 CRECELIUS LEWIS 428 BURNETT N RENTON WA 98055 072305908500 FACILITIES & OPERATIONS CTR OFFICE OF THE EXECUTIVE DIR 300 SW 7TH ST RENTON WA 98055 722450031504 JEFF'S AUTO REPAIR INC 21701 HIGHWAY 99 #A LYNNWOOD WA 98036 722550011000 MOORE RUTH REUTIMANN 7025 116TH AVE SE NEWCASTLE WA 98056 082305917807 PUGET SOUND ENERGY/ELEC PROPERTY TAX DEPT PO BOX 90868 BELLEVUE WA 98009 082305921601 SOUTHPORT LLC 1083 LAKE WA BLVD N #50 RENTON WA 98056 722450036503 THOMPSON HEATHER 702 N 5TH ST RENTON WA 98055 722450032502 VIDELL VICTOR E+LANCE M 536 BURNETT AVE N RENTON WA 98055 • 088661009006 BOEING COMPANY THE PROPERTY TAX DEPT PO BOX 3707 M/C 2000 SEATTLE WA 98124 722450036008 CUTTING LARRY D 10042 RAINIER AVES SEATTLE WA 98178 072305909805 FEDERAL RECOVERY OF WA PO BOX 1435 TACOMA WA 98401 722450035505 LEE JERRY W 514 BURNETT AVE N RENTON WA 98055 722450035000 MUNAGLIA DOMINIC A & TERR M 518 BURNETT AVE N RENTON WA 98055 082305919100 PUGET SOUND ENERGY/ELEC PROPERTY TAX DEPT PO BOX 90868 BELLEVUE WA 98009 052305907504 SOUTHPORT ONE LLC 1083 LAKE WASHINGTON BLVD N #50 RENTON WA 98056 722550009004 TRAN PHUOC+THI NUOI FANG TU 438 BURNETT AVE N RENTON WA 98057 722550011505 ZURCHER ELIZABETH C+PHILIP 420 BURNETT AVE N RENTON WA 98055 • • NOTICE OF APPLICATION AND PROPOSED DETERMINATION OF NON-SIGNIFICANCE {DNS) DATE: LAND USE NUMBER: PROJECT NAME: June 28, 2011 LUA11-042, ECF 737 Air Quality Program PROJECT DESCRIPTION: The applicant has requested for Environmental Review for the replacement of 4 wing seat booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal ·booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. PROJECT LOCATION: 737 Logan Avenue N OPTIONAL DETERMINATION OF NON-SIGNIFICANCE, MITIGATED (DNS): A:s the Lead Agency, the City of Renton has determined that significant environmental impacts·are unlikely to result from the proposed project. Therefore, as permitted under the RCW 43.21C.110, the City of Renton is using the Optional DNS pr<;>cess to give notice that a DNS is likely to be issued. Comment periods for the project and the proposed DNS are integrated into a single comment period. There will be no comment period following the issuance of the Threshold Determination of Non-Significance· Mitigated (DNS). A 14-day appeal period will follow the issuance of the DNS. PERMIT APPLICATION.DATE: NOTICE OF COMPLETE APPLICATION: June 9, 2011 June 28, 2011 APPLICANT/PROJECT CONTACT PERSON: Mark Clement, Boeing; 737 Logan Avenue N; Renton, WA 98055; Eml: mark.d.c1ement@boeing.com Permits/Review Requested: Other Permits which may be required: Requested Studies: Location where application may be re\llewed: PUBLIC HEARING: CONSISTENCY OVERVIEW: Zoning/Land Use: Environmental (SEPA) Review N/A N/A Department of Community & Economic Development (CED) -Planning Division, Sixth Floor Renton City Hall, 1055 South Grady Way, Renton, WA 98057 N/A The subject site is designated Urban Center North (UC-N) on the City of Renton Comprehensive Land Use Map and Urban Center North 2 (UC-N2) on the City's Zoning Map. If you would like to be made a party of record to receive further information on this proposed project, complete 'this form and return to: City of Renton, CED-Planning Division, 1055 So. Grady Way, Renton, W~ 98057. Name/File No.: 737 Air Quality Program/LUAll-042, ECF NAME:------------------------------------ MAILING ADDRESS: TELEPHONE NO.: • Environmental Documents that · Evaluate the Proposed Project: Development Regulatlons Used For Project Mitigation: Proposed Mitigation Measures: • Environmental (SEPA) Checklist The project will be subject to the City's SEPA ordinance, RMC 4·9-070 and other applicable codes and regulations as appropriate. The following Mitigation Measures will likely be imposed on the proposed project. These recommended Mitigation Measures address project impacts not covered by existing codes and regulations as cited above. Comments on the above applicatJon must be submitted in writing to Vanessa Dolbee, Senior Planner, CED -Planning Division, 1055 South Grady Way, Renton, WA 98057, by 5:00 PM on July 12, 2011. If you have questions about this proposal, or wish to be made a party of record and receive additional notification by mail, contact the Project Manager. Anyone who submits written comments wW automatically become a party of record and wiU be notified of any decision on this project. CONTACT PERSON: Vanessa Dolbee, Senior Planner; Tel: (425) 430-7314; Eml: vdolbee@rentonwa.gov PLEASE INCLUDE THE PROJECT NUMBER WHEN CALLING FOR PROPER FILE IDENTIFICATION ~-----------------------------------------------------------------• • NOTICE OF APPLICATION AND PROPOSED DETERMINATION OF NON-SIGNIFICANCE (DNS} DATE: LANO USE NUMBER: PROJECT NAME: June 28, 2011 LUA11-042, ECF 737 Air Quality Program PROJECT DESCRIPTION: The applicant has requested for Environmental Review for the replacement of 4 wing seal booths and a new paint booth located at the Boeing Manufacturing Facility, 737 Logan Avenue. All proposed development would occur within existing buildings located at the subject site. The new paint and seal ·booths would result in air quality impacts; however, the applicant is required to comply with Puget Sound Clean Air Agency standards and the Department of Ecology Best Available Control Technology requirements. · PROJECT LOCATION: 737 Logan Avenue N OPTIONAL DETERMINATION OF NON-SIGNIFICANCE, MITIGATED (DNS): As the Lead Agency, the City of Renton has determined that significant environmental impacts are unlikely to result from the proposed project. Therefore, as permitted under the RCW 43.21C.110, the City of Renton is using the Optional DNS process to give notice that a DNS is likely to be issued. Comment periods for the project and the proposed DNS are integrated into a single comment period. There will be no comment period following the issuance of the Threshold Determination of Non-Significance- Mitigated (DNS). A 14-day appeal period will follow the issuance of the DNS. PERMIT APPLICATION DATE: NOTICE OF COMPLETE APPLICATION: June 9, 2011 June 28, 2011 APPLICANT/PROJECT CONTACT PERSON: Mark Clement, Boeing; 737 Logan Avenue N; Renton, WA 98055; Eml: mark.d.clement@boelng.com Permits/Review Requested: Other Permits which may be required: Requested Studies: Location where application may be reviewed: PUBLIC HEARING: CONSISTENCY, OVERVIEW: Zoning/Land Use: Environmental (SEPA) Review N/A N/A Department of Coml'Tlunity & Economic Development (CED) -Planning Division, Sixth Floor Renton City Hall, 1055 South Grady Way, Renton, WA 98057 N/A The subject site is designated Urban Center North (UC-NJ on the City of Renton Comprehensive Land Use Map and Urban Center North 2 (UC-N2) on the City's Zoning Map. If you would like to be made a party of record to receive further information on this proposed project, complete this form and return to: City of Renton, c·ED-Planning Division, 1055 So. Grady Way, Renton, Wf.: 98057. Name/File No.: 737 Air Quality Program/LUAll-042, ECF NAME:------------------------------------ MAILING ADDRESS: TELEPHONE NO.: • Environmental Documents that Evaluate the Proposed Project: Development Regulations Used For Project Mitigation: Proposed Mitigation Measures: • Environmental (SEPA) Checklist The project will be subject to the City's SEPA ordinance, RMC 4-9-070 and other applicable codes and regulations as appropriate. The following Mitigation Measures wilt likely be imposed on the proposed project. These recommended Mitigation Measures address project impacts not covered by existing codes and regulations as cited above. Comments on the above application must be submitted in writing to Vanessa Dolbee, Senior Planner, CED -Planning Division, 1055 South Grady Way, Renton, WA 98057, by 5:00 PM on July 12, 2011. If you have questions about this proposal, or wish to be made a party of record and receive additional notification by mail, contact the Project Manager. Anyone who submits written comments will automatically become a party of record and will be notified of any decision on this project. CONTACT PERSON: Vanessa Dolbee, Senior Planner; Tel: (425) 430-7314; Eml: vdolbee@rentonwa.gov PLEASE INCLUDE THE PROJECT NUMBER WHEN CALLING FOR PROPER FILE IDENTIFICATION Denis Law • Mayor Department of Community and Economic Development June 28, 2011 Mark Clement _Boeing 737 Logan Avenue N Renton, WA98055 ·· Alex Pietsch, Administrator Subject: Notice ofcomplete Application . 737 Air Quality Program, LUAll-042, ECF Dear Mr. Clement: The .Pla~ning Division of the Cityof Renton ha_s determined that the subject 'applk~tion: . is complete according to"submittar"requirements and, therefore, is accepted for review. ~ ·. . . . It is tentatively scheduled for consideration by the Environmental Review Committee on July 19, 2011. Prior to that review, you will be .notified if any additional information is .. required to continue processing your applicati~n. Please contact me at (425) 430-7314 if you have any questions. · Sincerely,· .. . . · . . ~~o/~ Vanessa Dolbee Senior Planner . Renton City Hali •·· 1055 S?uth Grady Way • Renton, Washington_ 98057 • · rent~n¥/~.gov· • City of Renton LAND USE PERMIT c· ityof Ptann· Flento m90 . n tv/s. ton MASTER APPLICATIO JUN -9 lOr, ~/f1l PROPERTY OWNER(S) TELEPHONE NUMBER AND E-MAIL ADDRESS: 206 617- 2944 NAME: Boeing Corp. Mark.d.clement®boeina.com ADDRESS: 737 Logan Ave n. PROJECT INFORMATION PROJECT OR DEVELOPMENT NAME 737 rate readiness&, CITY: Renton ZIP: air quality program 98055 PROJECT/ADDRESS{S)/LOCATION AND ZIP TELEPHONE NUMBER: (206 617-2944) 737 Logan Ave n Renton WA 98055: APPLICANT (if other than owner) NAME: Mark Clement KING COUNTY ASSESSOR'S ACCOUNT NUMBER{S): COMPANY {if applicable): Boeing 0723059001 EXISTING LAND USE{S): Manufactoring ADDRESS: 737 Logan Ave n. PROPOSED LAND USE{S): Manufactoring CITY: Renton ZIP: 98055 EXISTING COMPREHENSIVE PLAN MAP DESIGNATION: TELEPHONE NUMBER 206 617-2944 UCN PROPOSED COMPREHENSIVE PLAN MAP DESIGNATION CONTACT PERSON {if applicable): NA NAME: Mark Clement EXISTING ZONING Urban Center north 2 . ,.,,,... -.;,., COMPAN\~~~'8,9eing Co. ~' .. '!l!..l111f J £.'1, G,; "'!:.~ :\ "' l "!:.. .... - PROPOSED ZONING {if applicable): same as existing SITE AREA (in square feet): 6,618,761 sq. ft ~ f'j rf J>f~~~ --ADDR,~' • ~Q a }~er· ;; ;_ _... '~"' .f I-; ~ SQUARE FOOTAGE OF PUBLIC ROADWAYS TO BE DEDICATED:none CITY: '=-'o ·wra 1~f-:l· t f ZIP: "":. "> a.,,,''o ... ~ --;. V , ... , -"' ,,· 98055 -,.,...,.. ~'H2P.\.N .,11 /~/ ,. 11 SQUARE FOOTAGE OF PRIVATE ACCESS EASEMENTS: PROPOSED RESIDENTIAL DENSITY IN UNITS PER NET ACRE {if applicable): NA Q:web/pw/dcvscrv/fonns/planning/masterapp.doc 06106111 PR.CT INFORMATION (continAo ___________ ___:....:....:===..:_:..:..:.:......:::.;;.; ;..:...=:...:-C-'=====:.L...----------- NUMBER OF PROPOSED LOTS (if applicable): NA NUMBER OF NEW DWELLING UNITS (if applicable): NA l~----------l I NUMBER OF EXISTING DWELLING UNITS (if applicable): I SQUARE FOOTAGE OF PROPOSED RESIDENTIAL I BUILDINGS (if applicable): NA I SQUARE FOOTAGE OF EXISTING RESIDENTIAL I BUILDINGS TO REMAIN (if applicable): NA SQUARE FOOTAGE OF PROPOSED NON-RESIDENTIAL BUILDINGS (if applicable): SQUARE FOOTAGE OF EXISTING NON-RESIDENTIAL , BUILDINGS TO REMAIN (if applicable): NA if----------------------l : NET FLOOR AREA OF NON-RESIDENTIAL BUILDINGS (if , applicable): NA NUMBER OF EMPLOYEES TO BE EMPLOYED BY THE NEW PROJECT (if applicable): 400. PROJECT VALUE: 28 million IS THE SITE LOCATED IN ANY TYPE OF ENVIRONMENTALLY CRITICAL AREA, PLEASE INCLUDE SQUARE FOOTAGE (if applicable): IJ AQUIFER PROTECTION AREA ONE IJ AQUIFER PROTECTION AREA TWO IJ FLOOD HAZARD AREA IJ GEOLOGIC HAZARD IJ HABITAT CONSERVATION IJ SHORELINE STREAMS AND LAKES IJ WETLANDS ___ sq.fl. ___ sq.fl. ___ sq.fl. ___ sq.fl. ___ sq.fl. LEGAL DESCRIPTION OF PROPERTY ·1----·'·A:::tta=c::;h:..:l:::e11aa:::l:..:d:.:e:::s:::c.:.:rl.c.:;,D'tio:::n;.;..:o.:.:n.;:s:::ez;::.Da:.:ra:.:te:..::s:.:he:;e:.:t:..:w.:.:l:::th.:.t::.h:::e:..:f:::o:.:llo;:;.w;::.:ln;,s1a1,;i::.:n::.:fo:.:rm.::.::a:::ti:::o::.:n..:i:.:n:::cl:::u:::d:::ed:.ll1.-__ --I i SITUATE IN THE _ne QUARTER OF SECTION 7_, TOWNSHIP _23n_, RANGE_5e_, IN 1 THE CITY OF RENTON, KING COUNTY, WASHINGTON. lr---------------------------------------1 i ' TYPE OF APPLICATION & FEES List all land use applications being applied for: 1. __ X_Environmental plan review . 3. 1 2. _X_ SEPA CHECKLIST Staff will calculate applicable fees and postage: $ Billed_ AFFIDAVIT OF OWNERSHIP I, (Print Name/s) IV\ A 'v ,j._ C) Cf'> f" _Jr , declare that I am (please check one) _ the current owner of the property involved in this application or .:::::::L._ the authorized representative to act for a corporation (please attach proof of authorization) and that the foregoing statements and answers herein contained and the information herewith are in all respects true and correct to the best of my knowledge and belief. I certify that I know or have satisfactory evidence,.l!tttl,. M ~" I( CI r f'l r ,r[" signed this instrument and acknowledged 1t to be~er/their lr«'--~wtary act for the 1·-··--·--· uses and purposes mentioned in the instrument. s~t!tr.~ R ~ 1111 ., . ~~1,, -·-~ "t 1~ .,,.... ~\ --, ~ ~ f ~ i<n1 ..... " i ~ ~ " 49. "·~\fl :: t ~ -.,,;~ ·09.14 cf ff I ! 1 -------------- I (Signature of Owner/Represantative) , Q:web/pw/devserv/fonns/planning/mastempp.doc ' Notary Public in and for the Slate of Washington 2 ,,,, Op"''"'"\\\' OA;. ~ 11 ,, 1 WAsl'I\~ ,..,,..:- •111,"""''" 06/06/tt .OJECT INFORMATION (continu. Notary (Print) S/.i. S m,..J R. /-b /1\ E '-I cf..__ My appointment expires:. __ . ..:{):....:;~1-/.,::tJ_q,._,/c.:/_tJI----- Q:web/pw/dcvserv/fonns/planninglmasterapp.doc 3 06/06/11 . PLANNING DIVISION WAIVEa,F SUBMITTAL REQUIF8'JIENTS FOR LAND USE APPLICATIONS • Traffic Study 2 rr~~¢yMim~ffln~•qi~~r'rw~mi~r~•••• Applicant Agreement. Statement 2 AND 3 Inventory of Existing Sites 2 AND 3 Lease Agreement, Draft 2 AND 3 Map of Existing Site Conditions 2 AND 3 Map of View Area 2 AND 3 Photosimulalions 2 AND 3 CityofA Piannin _enton g Division JU - This requirement may be waived by: 1. Property Services 2. Public Works Plan Review 3. Building PROJECT NAME: 7.37 Ai ( Gwdi~ m9 i' u,trJ DATE: GJ!l//1 • • 4. Planning H:\CED\Oata\Forms-Templates\Setf.Help Handouts\Planning\waiverofsubmittalreqs.x!s 06/09 PLANNING DIVISION . .. ·' 'f' WAIVEAJF SUBMITTAL RE.QU1141v1ENTS FOR LAND USE APPLICATIONS ::::::iJANtf Use!PERMtt:SUBMlttAlli'••• 'THHE @qt;JIR$M$tftin Calculations 1 . '~ ·• " Drainage Report 2 I Floor Plans 3 ANO 4 .. 1 @~miillimi~'R~#mij~~M~~ i " Grading Plan, Conceptual 2 ' I Legal Description 4 I I This requirement may be waived by: 1. Property Services 2. Public Works Plan Review 3. Building 1'"7 I\. < iJv.,--' PROJECT NAME: ...:..,a,,le.,c..._;f-:...-,.,,1/r_· _,,U..,'U4,.' ('J ... a .... :.L>q"J,-+Jtm~e!J.r...,(;._.YY1..._ DATE: -'G,"'-1/c.::.2+-/-'-'//'-------4. Planning H:\CED\Data\Forms-Templates\Self-Help Handouts\Planning\waiverofsubmittalreqs.xls 06/09 ·,,~, • Cityo~nt Plannin9'fivisio~n JUN -9 2011 A ,?.'T~o,, , C 12 ,•rvroN JUN 09 'vf2D BUILD 20/J _1._P_r.,....o""-je_c_t _D_es_c_r....;;..i p_ti_o_n __ fR?_0 -=~-© ...... fe.i-;Ol'#!'-HJJ£~ffJ"7!----'rv_G_o,v,810rv Boeing Commercial Airplanes' Renton facility (Boeing Renton) pmduces single-aisle airplanes and is located in Renton, King County, Washington (Figure 1-1). Boeing manufactures the 737 model airplane in Renton and proposes to make changes to the facility that will enable it to ino·ease the production capacity from the CU1Tent rate of about 372 737 airplanes per year to a maximum of about. 737 airplanes per year. The "\V ashington Department of Ecology (Ecology) has issued several Prevention of Significant Deterioration (PSD) permits for Boeing Renton. These include the following: • PSD-08-01 for the Boeing Renton Site, 5-50 Paint Hangar and Buildings 4-20, 4-21, 4- 81, and 4-82. PSD-08-01 limits the VOC emissions from Buildings 4-20, 4-21, 4-81, and 4-82 to 118 tons per year (tpy). Boeing is not seeking to change that limit with this application; however, the project will result in physical and operational changes in Building 4-20. • PSD-88-4 for the Boeing Renton Site, 4-41 Paint Hangai·. PSD-88-4 Condition 1 of that permit limits volatile organic compound (VOC) emissions from Building 4-41 to 124 tpy. TI1ere will be no physical or operational chailges to Building 4-41 because of this project and Boeing is not seeking a11y chai1ges to the limits. • PSD-97-2 for the Boeing Renton Site, Building 4-86. PSD-97-2 Condition 2 limits VOC emissions from Building 4-86 to 242 tpv. Boeing is not seeking to change that limit with this application; however, the project will result in physical a11d operational chai1ges in Building 4-86. l\lodel 737 assembly operations primaiilv ot·cm in Buildings 4-20, 4-21, 4-42, 4-81, 4-82, ai1d 4- 86. 111ese operations include the assembly oi vai"ious sub-assemblies (e.g., wing spars and wings) from then· component parts; the installation oi various a.iJ:plai1e systems (e.g., hvd.raulic, fuel, electrical) in the sub-assemblies; final assembly oi a complete airplai1e structui·e a11d integration oi the airplane systems; the installation of landing gea.r, engines, and interior components (e.g., seats, sidewalls, partitions); and ftmctional testing. TI1e main body sections (fuselages) ai·e assembled in Kansas ai1d a.re delivered to Boeing Renton bv rail. Afr emissions primarilv occU1· from activities such as sprav coating, sealing, hand-wipe ai1d flush cleaning, and the use of nliscellaneous adhesives, resins, and other products that contain volatile org<ulic compo,mds. As part of this pl'Oject, Boeing intends to replace four existing wing pa11el sp1:ay booths (covered m1der the existing PSD 08-01) in Building 4-20 (Figmes 1-2 ai1d 1-3) ,..,-;th four new booths at another location in Building 4-20 to allow replacement of the vertical wing build line with a new horizontal wing build line (HBL). No other new or modified sprav booths are plaimed, ai1d no other emission unHs would be added or modified in Building 4-20 as part oi this project. l\Iodel 737 wings have two major wing panels. the upper ai1d lower sU1·iaces oi the wing. Before :1.s~e1nbling the t,\·0 r1,u1el:: tc1gether, the ,d.ng p,u1els ,u·ti de,u1':'d, -:e:\led. ,u1d coated 1...-ith ' • • PSD AP PUCA TION FOR CHANGES RELATED TO 737 PRODUCTION C.APACllY INCREASE protective coatings. TI1ese cleaning, sealing, and coating operations are the somce of voe emissions. In Building 4-86 (Figmes 1-4 and 1-5), Boeing paints wings that ,ue mostly assembled. Boeing intends to add one new booth (PB-4) that will paint the upper and lower sections of tl1e ,,:ing with the wing in a vertical position. An existing bootl1 (PP-7) tllilt is cm-rently used to apply a con·osion-inhibition compound to the wing surface would llilve an operational change to painting the leading and trailing edges and wing spru·s while the wing is in a horizontal position. Finally, to improve the quality of tl1e paint finish, tile exhaust rate on one existing inspar (vertical) wing bootll (PP-8) would be increased. h1 addition to tile changes described above, Boeing intends to make otl1er changes to 737 assembly operations tl1at ru·e not expected to involve chru1ges to spray bootl1s or other emission units. These chru1ges include, but are not necessarily limited to, installing a new wing-tiveter, a second Wing Horizontal Build Line ru1d otl1er miscellru1eous assembly tooling. Table 1-1 summai.izes tl1e proposed actions for each building. TABLE 1-1 Summarv of Pro="" Proiect Bulldlng Changes 4-20 4 replacement wing panel booths New Wing Horizontal Bulld Line New Wing-riveter Miscellaneous assembly t9ollng 4-86 1 new lnspar (vertical) wing booth Change In operation of an existing spar (horizontal) booth Install new fan(s) In an existing lnspar wing booth voe emissions from all 737 assembly operations at Boeing Renton, including painting of completed aircraft, average about 0.77 ton per airplai.1e. Of the 0.77 ton per airplane, the projected VOC emissions from each of tl1e wing panel booths iI1 BuildiI1g 4-20 are about 17.6 potmds per airplane, or about 1.11 tpy per bootl1. The new and modified booths in BuildiI1g 4-86 would each emit 104 pounds of voes per aiiplane for a total oi 6.55 tpy per bootl1. \ ~· 1) ·.-·. :(j • • Project narrative BOEING COMMERCIAL AIRPLANE GROUP . RENTON WASHINGTON 737 Rate Readiness and Air quality program 737 Logan avenue north Renton WA 98055 Main Boeing Renton manufacturing plant The lot size is 6618761 sq ft Master use permit, Environmental Checklist. Zoning designation is Urban Center north 2 The Cedar River & Lake Washington are the Special site features Sandy silt loam is the soil type. Drainage to Lake Washington from private storm water system to multiple outfalls to Lake Washington Project Scope Boeing is increasing Rate of the 737 Airplane program at the Renton manufacturing plant, The below project narratives will allow the company to achieve this. Wing Riveter Building 4-20 Rate increase initiative requires the design and construction of new foundations for a new Wing Riveter machine. The foundation is located in Building 4-20 manufacturing Line S between Grids 5-7. The new foundation will include imbedded rail beds to support the new machine. In addition the existing foundations will be removed and replaced by new slab-on-grade. The project also entails the installation of new utilities trench to be routed from adjacent trenches. Horizontal Build Line (HBL) Building 4-20 As part of the rate increase initiative The Boeing Company is proposing the design and construction of a series of infrastructure that will eventually build the wing structure for the 737 program. These groups of projects will be located in Building 4-20 manufacturing Line 4. Currently the "Lower Panel" tool, Seal Booth, and the "Wing Major" structures are in operation in that space. I I I I I I \ I I ! I I I I • • The current operations will be replaced by the new horizontal wing assembly structures starting with Positions 1 thru 7 from Grid line 10 to Grid line 1. Positions 1, 2, and 3 will be founded on piles due to its load and deflection requirements. A series of assembly tools will represent the super structure for these positions. Positions 4,5,6, 7 will be supported by the existing foundations. Wing to Body Join Building 4-81 As part of the rate increase projects The Boeing Company is proposing the design and construction of foundation for the WBJ tool to be located in Building 4-81. The tool is part of the final assembly function attaching the wing to fuselage. The project also includes new utilities for each tool. The foundation mat is supported above existing sub grade. Revise Existing Moving Line As part of the moving line revision, 2 new support cells will be added. These will include electrical, fiber, floor coatings and saw cutting floor for these new utilities Seal Booth Building 4-20 The Boeing Company is requiring the design A&E team to develop design drawings and construction documents to construct four new seal booths inside Building 4-20 located at its Renton, Washington campus. The new seal booths will be located in production Line 6 North of Grid line 11 transportation aisles; once constructed it will replace the functions of the existing seal booths currently located in Line 3 of this building scheduled to be removed from production. This project is part of the new ~37 aircraft "Rate Increase" initiative. The ~roposed booth buildings will house the "seal" function of the wing panels. The wing panels will be transported inside each booth by a series of fixed monorails entering from the south. Once inside, a movable monorail will place the panels on a stand. identified as "FME" tool for the start of the seal process. Each booth shall have the ability to perform the seal function for both the upper and lower panel. The panels are stabilized on "FME" tool based on "wet" or "dry" side of the panel. Each ·booth includes three mobile lifts, two on the wet side and one on the dry side of the panel. The terms wet and dry refer to interior and exterior sides of each panel respectively; wet refers to the side that is manufactured to be in contact with fuel upon'completion of the wing assembly. Paint Booth & PPS Building 4-86 Paint Booth Construction of one new 4000sq ft paint booth that will include new pit area, metal stud and metal interior finish, supply and exhaust fans, duct work and filter banks, electrical, air and sprinkler supplies and misc other minor construction to clear the area. ', ~ 'h• . ·. . ' • • PPS: Remodel of the existing paint position booth to provide new supply and exhaust fans including new filter bank for painting the wings. Paint Booth & PPS Building 4-86 The total cost for is approx. $ 28. Million Access to the property is by 3 guard gates, two on the east and one on the south No change to plant vegetation or parking. All work is internal to the building or on the roof. No views will be obstructed by the proposed project • • ENVIRONMENTAL CHECKLIST A. BACKGROUND 1. Name of proposed project, if applicable: 737 Rate Readiness & Air quality program. 2. Name of applicant The Boeing Company P.O. Box 3707, M/S 1W-09 Seattle, WA 98124-2207 3. Address and phone number of applicant and contact person: Mark Clement Facilities Permits/Land use The Boeing Company P.O. Box 3707, M/S 1W-09 Seattle, WA 98124-2207 Ph [206 617-2944] 4. Date checklist prepared: June 2011 5. Agency requesting checklist: City of Renton, Department of Ecology, PSCAA, 6. Proposed timing or schedule (including phasing, if applicable): Oct 2011 to Oct 2013 7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. None planned at this time. 8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. 9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, Explain. Past emission calculations / estimates of future emissions and evaluations of best available control technology (BACT) have been completed in support of PSD permit application to WDOE and NOC application to PSCAA. ENVIRONMENTAL CHECKLIST 1 619/2011 I I I I I I I I I I I I I I I I I I I I I I I I _J_ - • • 10. List any government approvals or permits that will be needed for your proposal, if known. Federal: NA State of Washington: Potential Department of Ecology Prevention of Significant Deterioration Permit King County: None known at this time City of Renton/Local: State Environmental Policy Act Review, PSCAA, Renton Building & utilities Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information on project description Project description Wing Riveter Building 4-20 Rate increase initiative requires the design and construction of new foundations for a new Wing Riveter machine. The foundation is located in Building 4-20 manufacturing Line 5 between Grids 5-7. The new foundation will include imbedded rail beds to support the new machine. In addition the existing foundations will be removed and replaced by new slab-on-grade. The project also entails the installation of new utilities trench to be routed from adjacent trenches. Horizontal Build Line (HBL) Building 4-20 As part of the rate increase initiative The Boeing Company is proposing the design and construction of a series of infrastructure that will eventually build the wing structure for the 737 program. These groups of projects will be located in Building 4-20 manufacturing Line 4. Currently the "Lower Panel" tool, Seal Booth, and the "Wing Major" structures are in operation in that space. The current operations will be replaced by the new horizontal wing assembly structures starting with Positions 1 thru 7 from Grid line 10 to Grid line l. Positions ENVIRONMENTAL CHECKLIST 2 6/9/2011 • • 1, 2, and 3 will be founded on piles due to its load and deflection requirements. A series of assembly tools will represent the super structure for these positions. Positions 4,5,6,7 will be supported by the existing foundations. Wing to Body Join Building 4-81 As part of the rate increase projects The Boeing Company is proposing the design and construction of foundation for the WBJ tool to be located in Building 4-81. The tool is part of the final assembly function attaching the wing to fuselage. The project also includes new utilities for each tool. The foundation mat is supported above existing sub grade. Revise Existing Moving Line As part of the moving line revision, 2 new support cells will be added. These will include electrical, fiber, floor coatings and saw cutting floor for these new utilities Seal Booth Building 4-20 The Boeing Company is requiring the design A&E team to develop design drawings and construction documents to construct four new seal booths inside Building 4-20 located at its Renton, Washington campus. The new seal booths will be located in production Line 6 North of Grid line 11 transportation aisles; once constructed it will replace the functions of the existing seal booths currently located in Line 3 of this building scheduled to be removed from production. This project is part of the new 737 aircraft "Rate Increase" initiative. The proposed booth buildings will house the "seal" function of the wing panels. The wing panels will be transported inside each booth by a series of fixed monorails entering from the south. Once inside, a movable monorail will place the panels on a stand identified as "FME" tool for the start of the seal process. Each booth shall have the ability to perform the seal function for both the upper and lower panel. The panels are stabilized on "FME" tool based on "wet" or "dry" side of the panel. Each booth includes three mobile lifts, two on the wet side and one on the dry side of the panel. The terms wet and dry refer to interior and exterior sides of each panel respectively; wet refers to the side that is manufactured to be in contact with fuel upon completion of the wing assembly. Paint Booth & PPS Building 4-86 Paint Booth Construction of one new 4000sq ft paint booth that will include new pit area, metal stud and metal interior finish, supply and exhaust fans, duct work and filter banks, electrical, air and sprinkler supplies and misc other minor construction to clear the area. ENVIRONMENTAL CHECKLIST 3 61912011 • • PPS: Remodel of the existing paint position booth to provide new supply and exhaust fans including new filter bank for painting the wings. Paint Booth & PPS Building 4-86 12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, Including a street address, if any, and section, township, and range, if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist. Site address: 737 Logan ave. north Renton, Washington Refer to Neighborhood Map; and Site Plan for project location. Refer to Neighborhood Map for Legal Description B. ENVIRONMENTAL ELEMENTS 1. Earth a. General description of the site (circle one): Flat, rolling, hilly, steep slopes, mountainous, other ...... Flat; b. What is the steepest slope on the site (approximate percent slope)? 1%; c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any prime farmland. Sandy silt loam d. Are there surface Indications or history of unstable soils in the immediate vicinity? If so, describe. ENVIRONMENTAL CHECKLIST 4 619/2011 • • Yes, Liquefaction zone e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. Indicate source of fill. None f. Could erosion occur as a result of clearing, construction, or use? ff so, generally describe. No g. About what percent of the'site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)? 98% h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: Temporary erosion control measures will be used by contractor 2. Air a. What types of emissions to the air would result from the proposal (i.e., dust, automobile, odors, and industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities if known. Dust smoke, from construction equip. during normal construction activities. When project is completed, VOCs -Volatile organic Compounds, particulate · matter from spray coating b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe. No c. Proposed measures to reduce or control emissions or other impacts to air, if any: Mitigation measures will be implemented as required to meet or exceed all applicable standards as required by the Puget Sound Clean Air Agency and the Department of Ecology, including meeting Best Available Control Technology (BACT) requirements. Mitigation for these air impacts includes filtration of inorganic hazardous air pollutants from paint booth exhaust and limitations on the concentration of volatile organic compounds and organic hazardous air pollutants in the coatings. Additional potential mitigation measures to reduce emissions ENVIRONMENTAL CHECKLIST 5 6191201 t • • include ensuring that machines and equipment used during construction are well maintained. 3. Water a. Surface: 1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river It flows into. Cedar River which flows into Lake Washington 2) Will the project require any work over, In, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. No 3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. None. 4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. No 5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan. No 6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. No b. Ground: ENVIRONMENTAL CHECKLIST 6 61912011 • • 1) Will ground water be withdrawn, or will water be discharged to ground water? Give general description, purpose, and approximate quantities if known. Possible de watering through settling tanks and discharged to sanitary sewer. If duct size requires excavation to ground water table 2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: Domestic sewage; industrial, containing the following chemicals ... ; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve. None c. Water runoff (including storm-water): 1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (Include quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe. NA 2) Could waste materials enter ground or surface waters? If so, generally describe. NA d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any: All storm water drain inlets in and around the proposed construction operations and staging areas will be covered I . 4. Plants a. Check or circle types of vegetation found on the site: deciduous tree: alder, maple, aspen o e reen tree: fir, cedar, pine, the ru , gra asture, crop or m, wet soil p ants: cattail, buttercup, but/rush, skunk cabbage, other water plants: water Illy, eelgrass, mi/foil other types of vegetation b. What kind and amount of vegetation will be removed or altered? None ENVIRONMENTAL CHECKLIST 7 61912011 i I I I I I i • • c. List threatened or endangered species known to be on or near the site. Migratory Salmon, steelhead in Cedar River d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any: None 5. Animals a. Circle any birds and animals, which have been observed on or near the site or are known to be on or near the site: See 2003 Boeing EIS. Birds and animals which have been observed on or near the site are listed below: Birds: seagulls, crows, eagles, Blue heron Mammals: Fish: none Coho salmon, Chinook salmon sockeye salmon steelhead and cutthroat trout, native char (bull trout) and long fin smelt b. List any threatened or endangered species known to be on or near the site. Puget Sound Steelhead and their status are under ESA, the species is listed as "threatened," as are Puget Sound Chinook salmon and coastal/Puget Sound bull trout c. Is the site part of a migration route? ff so, explain. Yes Pacific Flyway; see 2003 Boeing EIS. d. Proposed measures to preserve or enhance wildlife, if any: None, 6. Energy and natural resources a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc. Electric power, steam b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe. No ENVIRONMENTAL CHECKLIST 8 61912011 • • c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any: None \ 7. Environmental Health a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe. Yes, See Air section. Fire, explosion, spills 1) Describe special emergency services that might be required. None 2) Proposed measures to reduce or control environmental health hazards, if any: . Fire, explosion, spills, will be mitigated by using best design practices and following code. b. Noise 1) What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other)? None, Renton airport nearby 2) What types and levels of noise would be created by or associated with the project on a short-term cir a long-term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site. None. 3) Proposed measures to reduce or control noise impacts, if any: NA 8. Land and shoreline use a. What is the current use of the site and adjacent properties? The site is fully developed as an aircraft manufacturing and final assembly facility. Renton Airport on adjacent side ENVIRONMENTAL CHECKLIST 9 619/2011 • • b. Has the site been used for agriculture? If so, describe. No c. Describe any structures on the site. The Renton Plant is a large airplane manufacturing and final assembly facility, consisting of many buildings and ancillary uses .. The City of Renton boathouse is adjacent to the site WIii any structures be demolished? If so, what? No e. What is the current zoning classlficatlon of the site? UCN-2 f. What is the current comprehensive plan designation of the site? UCN-2 g. If applicable, what is the current shoreline master program designation of the site? Urban Center north 2 h. Has any part of the site been classified as an "environmentally sensitive" area? If so, specify. Cedar River i. Approximately how many people would reside or work In the completed project? 400 j. Approximately how many people would the completed project displace? None k. Proposed measures to avoid or reduce displacement Impacts, if any: None I. Proposed measures to ensure the proposal are compatible with existing and projected land uses and plans, if any: NA ENVIRONMENTAL CHECKLIST 10 6/9/2011 • • 9. Housing a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing. None b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing. None c. Proposed measures to reduce or control housing Impacts, if any: None 10. Aesthetics a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building materfal(s) proposed? Interior work only b. What views in the immediate vicinity would be altered or obstructed? None c. Proposed measures to reduce or control aesthetic impacts, if any: None 11. Light and glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur? None b. Could light or glare from the finished project be a safety hazard or interfere with views? No c. What existing off-site sources of light or glare may affect your proposal? N/A. d. Proposed measures to reduce or control light and glare impacts, if any: ENVIRONMENTAL CHECKLIST 11 61912011 I I I I I I I I ' I I I I I ! • • None 12. Recreation a. What designated and Informal recreational opportunities are In the Immediate vicinity? The Cedar River shoreline trail and park are within the general area of the Renton Site. Kayak club Renton City Boathouse b. Would the proposed project displace any existing recreational uses? If so, describe. None. b. Proposed measures to reduce or control Impacts on recreation, including recreation opportunities to be provided by the project or applicant, If any: NA 13. Historic and Cultural Preservation a. Are there any places or objects listed on, or proposed for, national, state, or local preservation registers known to be on or next to the site? If so, generally describe. None known b. Generally describe any landmarks or evidence of historic, archaeological, scientific, or cultural importance known to be on or next to the site. None have been identified on the project site. c. Proposed measures to reduce or control impacts, if any: If artifacts are uncovered, work in that area will be halted pending notification and response from appropriate agencies. 14. Transportation a. Identify pub/le streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any. The site has access to North 61h Street and Logan Avenue North. ENVIRONMENTAL CHECKLIST 12 618/2011 • • b. Is site cu"ently served by public transit? If not, what is the approximate distance to the nearest transit stop? Yes Metro. 150 yards c. How many parking spaces would the completed project have? How many would the project eliminate? No changes to existing parking d. Will the proposal require any new roads or streets, or improvements to existing roads or streets, not including driveways? If so, generally describe (indicate whether public or private). No e. Will the project use (or occur In the immediate vicinity of) water, rail, or air transportation? If so, generally describe. Yes, Renton Municipal Airport, Rail spur f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur. None g. Proposed measures to reduce or control transportation impacts, if any: NA 15. Public Services a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe. None is anticipated. b. Proposed measures to reduce or control direct impacts on public services, if any. None 16. Utilities JJ,--Gl!_cle u · · · cu"~llable at the_~~ natural~, ~~ fuse service, e~e, ~r, septic syst m,ottier. ENVIRONMENTAL CHECKLIST 13 6/912011 • • b. Describe the utilities that are proposed for the project, the utility providing the service and the general construction activities on the site or in the immediate vicinity, which might be needed. Electrical power for construction equipment. Metro Sewer, City of Seattle water, PSE. C. SIGNATURE The above answers are true and complete to the best of my knowledge. Understand that the~d:gency '5elying on them to make its decision. Signature: ~ 0 , ct.di Mark D. Clement Date Submitted: ___ b_-__ 9_-_f _) ____ _ ENVIRONMENTAL CHECKLIST 14 619/2011 • • CONSTRUCTION MITIGATION DESCRIPTION Boeing Commercial Airplane Group Renton, WA 737 Rate Radiness & Air quality program Proposed Construction Dates & Times: City of ti P nenton tanning 0 ... ,v,s,on JUN -9 l011 In conformance with federal and state regulations, the proposed construction schedule will begin on OCT 2011 and complete on or prior to OCT 2013. No late night hours are proposed for any ruction hauling activities. Potential Saturday hours may be required. Construction Description & Work Plan: All Construction is interior of buildings or on roof. Boeing will employ Mayes testing for Special inspections, unless other inspection agencies are requested by the city. Project description Wing Riveter Building 4-20 Rate increase initiative requires the design and construction of new foundations for a new Wing Riveter machine. The foundation is located in Building 4-20 manufacturing Line S between Grids S-7. The new foundation will include imbedded rail beds to support the new machine. In addition the existing foundations will be removed and replaced by new slab-on-grade. The project also entails the installation of new utilities trench to be routed from adjacent trenches. Horizontal Build Line (HBL) Building 4-20 As part of the rate increase initiative The Boeing Company is proposing the design and construction of a series of infrastructure that will eventually build the wing structure for the 737 program. These groups of projects will be located in Building 4-20 manufacturing Line 4. Currently the "Lower Panel" tool, Seal Booth, and the "Wing Major" structures are in operation in that space. The current operations will be replaced by the new horizontal wing assembly structures starting with Positions 1 thru 7 from Grid line 10 to Grid line 1. Positions 1, 2, and 3 will be founded on piles due to its load and deflection requirements. A series of assembly tools will represent the super structure for these positions. Positions 4,5,6, 7 wiH be supported by the existing foundations. Wing to Body Join Building 4-81 • • As part of the rate increase projects The Boeing Company is proposing the design and construction of foundation for the WBJ tool to be located in Building 4-81. The tool is part of the final assembly function attaching the wing to fuselage. The project also includes new utilities for each tool. The foundation mat is supported above existing sub grade. Revise Existing Moving Line As part of the moving line revision, 2 new support cells will be added. These will include electrical, fiber, floor coatings and saw cutting floor for these new utilities Seal Booth Building 4-20 The Boeing Company is requiring the design A&E team to develop design drawings and ci:mstruction documents to construct four new seal booths inside Building 4-20 located at its Renton, Washington campus. The new seal booths will be located in production Line 6 North of Grid line 11 transportation aisles; once constructed it will replace the functions of the existing seal booths currently located in Line 3 of this building scheduled to be removed from production. This project is part of the new 737 aircraft "Rate Increase" initiative. The proposed booth buildings will house the "seal" function of the wing panels. The wing panels will be transported inside each booth by a series of fixed monorails entering from the south. Once inside, a movable monorail will place the panels on a stand identified as "FME" tool for the start of the seal process. Each booth shall have the ability to perform the seal function for both the upper and lower panel. The panels are stabilized on "FME" tool based on "wet" or "dry" side of the panel. Each booth includes three mobile lifts, two on the wet side and one on the dry side of the panel. The terms wet and dry refer to interior and exterior sides of each panel respectively; wet refers to the side that is manufactured to be in contact with fuel upon _completion of the wing assembly . . I Paint Booth & PPS Building 4-86 Paint Booth Construction of one new 4000sq ft paint booth that will include new pit area, metal stud and metal interior finish, supply and exhaust fans, duct work and filter banks, electrical, air and sprinkler supplies and misc other minor construction to clear the area. PPS: Remodel of the existing paint position booth to provide new supply and exhaust fans including new filter bank for painting the wings. Paint Booth & PPS Building 4-86 l •• . \ ' I .. ~ r 1{) I • • Construction Mitigation Measures & Best Practices: All activities will begin with the implementation and installation of Best Management Practices (BMP)). These practices include: Proposed Hauling/ Transportation routes Contractors will apply for their own hauling permits related to this project. And will follow a city approved route. Construction. The actual Construction will be accomplished by a Construction contractor. The contractor will call for all required inspections as well as a pre site construction meeting. The contractor will keep written records of special inspections Snow, Ice, dirt and mud removal Contractor shall remove snow and ice to the extent necessary to perform the work. The use of calcium chloride or other chemicals will not be permitted to remove snow or ice. Contractor shall assure· that vehicles are constructed, loaded, maintained and covered as necessary to prevent the deposition of dirt, mud or other debris on public roadways. Dirt mud or debris shall be removed on continual basis. Any dirt, mud or debris dropped by vehicles shall be removed immediately. Dust Control Through the entire construction period the Contractor shall take all necessary steps to dust control all working area and unpaved roads. The use of calcium chloride or other chemicals will not be permitted for dust control. The Contractor will accomplish dust control by watering and sprinkling to satisfactorily settle the dust. Contractor shall comply with any requirements imposed by law to prevent fugitive dust emissions. All demolished materials and debris will be stockpiled in a lined waste container on site to prevent dust and sedimentation from migrating onto roadways. Contractor vehicles that are transporting materials to and from the site will be required to have tires washed prior to leaving the site. This will prevent dust and sedimentation from entering nearby roadways. • CITY OF RENTON 1055 S. Grady Way Renton, WA 98055 • City of A PJann;n enton 9 D1v1s;0 n Printed: 06-09-2011 JUN -9 ZOii Land Use Actions RECEIPT lftl~rc~o~~@ Payment Made: Permit#: LUA11-042 06/09/2011 01 :29 PM Receipt Number: R1102122 Total Payment: 1,030.00 Payee: Boeing Bill Mark Clement 96237 Current Payment Made to the Following Items: Trans Account Code Description Amount ---------------------------------------------------------------------- 3080 503.000000.004.322 Technology Fee 5010 000.000000.007.345 Environmental Review Payments made for this receipt Trans Method Description Amount ------------------------------------------------------------ Payment BILL 96327 1,030.00 Account Balances 30.00 1,000.00 Trans Account Code Description Balance Due --------------------------------------------------------------------- 3021 303.000000.020.345 Park Mitigation Fee 3080 503.000000.004.322 Technology Fee 5006 000.000000.007.345 Annexation Fees 5007 000.000000.011.345 Appeals/Waivers 5008 000.000000.007.345 Binding Site/Short Plat 5009 000.000000.007.345 Conditional Use Fees 5010 000.000000.007.345 Environmental Review 5011 000.000000.007.345 Prelim/Tentative Plat 5012 000.000000.007.345 Final Plat 5013 000.000000.007.345 PUD 5014 000.000000.007.345 Grading & Filling Fees 5015 000.000000.007.345 Lot Line Adjustment 5016 000.000000.007.345 Mobile Home Parks 5017 000.000000.007.345 Rezone 5018 000.000000.007.345 Routine Vegetation Mgmt 5019 000.000000.007.345 Shoreline Subst Dev 5020 000.000000.007.345 Site Plan Approval 5021 000.000000.007.345 Temp Use, Hobbyk, Fence 5022 000.000000.007.345 Variance Fees 5024 000.000000.007.345 Conditional Approval Fee 5036 000.000000.007.345 Comprehensive Plan Amend 5909 000.000000.002.341 Booklets/EIS/Copies 5941 000.000000.007.341 Maps (Taxable) 5954 650.237.00.00.0000 DO NOT USE -USE 3954 5998 ooo . .000000.000.231 Tax Remaining Balance Due: $0.00 .00 .00 .00 .00 .00 .00 .oo .oo .00 .oo .00 .00 .00 .00 .00 .00 .00 . .oo .00 .00 .00 .00 .00 .00 .00