PERMIT APPLICATION

REVIEW SUMMARY

NH Department of Environmental Services

Air Resources Division

P.O. Box 95, 29 Hazen Drive

Concord, NH 03302-0095

Phone: 603-271-1370 Fax: 603-271-7053

Facility: Canam Steel Corp. through one of its divisions, Structal Bridge Engineer: PRN

Location: 386 River Rd., Claremont

AFS #: 3301990135 Application #: 10-0193 Date: January 5, 2011 Page 1 of 3

PROJECT DESCRIPTION

Temporary Permit to construct a metalizing booth and install up to four thermal spraying systems.

CHANGES FROM PREVIOUS PERMIT

NA – temporary permit

FACILITY DESCRIPTION/PERMIT HISTORY

Canam Steel Corp. through one of its divisions, Structal Bridge (“Structal”), purchased the property from Grissom & River LLC in

November 2009. Structal conducts steel fabrication operations which include cutting, welding, blasting, and spray painting. The

facility also has a permit for 2 boilers.

Device/Process Permit Number Permit Issued Permit Expires Status

two 13.5 MMBtu/hr oil fired boilers1 SP-0057 09/1709, amended 01/28/10 09/30/2014 current

Structural steel fabrication operations TP-0048 05/13/2010 11/30/2011 current

PROCESS/DEVICE DESCRIPTION

The structural steel product manufacturing plant consists of a concrete building, and two recently erected temporary tents. The tents

will be used for blasting and painting of large structural steel pieces. Preparation, cutting, welding, and some painting of the structural

steel takes place within the building. The new metalizing booth will perform thermal spray operations. This process produces a

protective coating of zinc on the surface of the metal piece/part to inhibit corrosion.

Device/Process Description

Metalizing booth [EU03] Four (4) Thermion Precision Arc 4.8 thermal spraying systems spraying zinc wire; [SNs to be determined]

Process rate: 200 pounds of wire/ hour; Wire: SHG zinc wire [99.99%] 0.1875” diameter

POLLUTION CONTROL EQUIPMENT

Cyclone with cartridge-type dust collector – estimated combined collection efficiency of both units = 99.9%

Control Device Description

Cyclone [PCE01] Mfg: Ducon Technoliogies Inc. Model: 700-150 SN: C09-5046

Capture Effec: 100% Control eff: 98.2%2

Cartridge dust collector [PCE02] Mfg: American Air Filter Model: 5RC40 SN: OP100013

Capture eff: 100% Control eff: 99.9%2

EMISSION CALCULATIONS

Structal submitted facility-wide emissions calculations with the permit application. The calculations were checked for accuracy and

found to be acceptable. The facility requested a permit to limit VOC and HAP potential to less than the major source threshold for the

spray painting operations3. The other operations at the facility (welding, grinding & blasting) do not require a permit. The emissions

for new thermal spray process were based on a deposition rate of 65% [35% emitted], spraying 200 lb wire/hour. Structal estimates

they will use approximately 368,000 lb wire/year.

1 Structal has disconnected the fuel supply, and has removed these two boilers. A request for termination of SP-0057 has been submitted. SP-0057 will be terminated

following receipt of the 2010 annual emission summary report and associated fees. 2 Vendor specifications, submitted with control device monitoring plan Dec 6, 2010. 3 Structal has removed the paint bay [EU02] from the facility and will not be reinstalling it. They will be constructing paint booths inside the building, and will submit

an application for a TP when engineering and design specifications are finalized.

PERMIT APPLICATION REVIEW SUMMARY

Facility: Canam Steel Corp. through one of its divisions, Structal Bridge Engineer: PRN

Location: 386 River Rd., Claremont

AFS #: 3301990135 Application #: 10-0193 Date: January 5, 2011 Page 2 of 3

HAPs

Potential uncontrolled emissions from spray painting and controlled emissions from the metalizing booth [cadmium & lead] were

calculated to be:

HAP CAS Lb/yr TPY HAP CAS Lb/yr TPY

Xylene 1330-20-7 5,340 2.67 Ethyl benzene 100-41-4 1,850 0.927

HDI 822-06-0 1.16 0.000582 Methyl methacrylate 80-62-6 224 0.112

Cumene 98-82-8 31.8 0.0159 Toluene 108-88-3 3,850 1.92

Antimony 7440-36-0 0.191 4.7E-05 Arsenic 7440-38-2 2.38 5.9E-04

Cadmium 7440-43-9 0.0575 1.4E-05 Chromium 7440-47-3 2.31 5.69E-04

Cobalt 7440-48-4 0.072 1.8E-05 Lead 7439-92-1 0.332 8.2E-05

Manganese 1313-13-9 0.074 1.8E-05 Nickel 7440-02-0 2.04 5.0E-04

Phosphorus 12185-10-3 1.61 4.0E-04 Selenium 7782-49-2 0.178 4.4E-05

HAP emissions were estimated to equal 5.7 tpy (less than the major source threshold of 25tpy), with xylene emissions as the highest at

2.7 tpy (less than the 10 tpy major source threshold). These estimated emissions are based on the coating [one spray painting area],

welding, cutting, and the proposed metalizing processes and do not account for possible formulation changes in the future. The

facility has a 10/25 tpy facility wide HAP cap for synthetic minor status in TP-0048.

VOCs

The facility has a permit limit to restrict VOC emissions to less than the major source threshold of 50 tpy, and there are no VOC

emissions from the proposed new thermal spray process.

RTAPs

The lb/day emission rates listed in the table below are based on MSDS4 information, and projected use rates as submitted with this

permit application. The vendor filter efficiency of 99.84%5 was used for the spray paint operations and 99.9% for the thermal spray

control devices. Emissions from the painting area, welding [SMAW 7018] activities, and five [5] plasma cutters were included along

with the emissions of metal fume emitted from the proposed new metalizing booth to determine facility-wide compliance.

RTAP CAS# Lb/hr Compliance RTAP CAS# Lb/hr Compliance

Aluminum 7429-90-5 0.0076 Adj In-stack Antimony 7440-36-0 2.2E-05 Adj In-stack

Arsenic 7440-38-2 0.00027 Adj In-stack Barium 1304-28-8 0.00093 Adj In-stack

Cadmium 7440-43-9 6.6E-06 Adj In-stack Chromium, VI 7440-47-3 2.7E-05 Adj In-stack

Chromium, total 7440-47-3 0.00024 Adj In-stack Copper 1317-39-1 0.0016 Adj In-stack

Cobalt 7440-48-4 8.2E-06 Adj In-stack Iron 1309-37-1 0.17 Adj In-stack

Lead 7439-92-1 3.8E-05 Adj In-stack Magnesium 1309-48-4 0.0062 Adj In-stack

Manganese 1313-13-9 8.5E-06 Adj In-stack Molybdenum 7439-98-7 2.3E-05 Adj In-stack

Nickel 7440-02-0 0.00023 Adj In-stack Phosphorus 12185-10-3 0.00018 Adj In-stack

Selenium 7782-49-2 2.0E-05 Adj In-stack Silver 7440-22-4 6.7E-06 Adj In-stack

Tin [oxide/inorganic] 7440-31-5 0.00028 Adj In-stack Thallium 7440-28-0 3.5E-06 Adj In-stack

Zinc [as zinc oxide fume] 7440-66-6 0.35 Adj In-stack

MODELING

March 17, 2010 – Modeling was performed by Aries Engineering, reviewed and accepted by DES, for RTAPs from the spray painting

areas that did not pass the in-stack concentration method .

Modeling was not required for the addition of the metalizing booth.

4 The MSDS’ are in the confidential file for any metal constituents contained in the paint used. 5 The filter removal efficiency is not considered control pursuant to Env-A 1403.03(b) for spray painting processes.

PERMIT APPLICATION REVIEW SUMMARY

Facility: Canam Steel Corp. through one of its divisions, Structal Bridge Engineer: PRN

Location: 386 River Rd., Claremont

AFS #: 3301990135 Application #: 10-0193 Date: January 5, 2011 Page 3 of 3

EMISSION TESTING

None has been performed, and none will be required in this permit term.

COMPLIANCE STATUS

Site Visits/Inspections

Compliance inspection December 17, 2009 – in compliance

Reports & Fees

Annual report and emissions fee received late [April 22, 2010]

REVIEW OF REGULATIONS

State Regulations

Env-A 600 – Permitting (effective 04-22-09)

• 607.01(n) – Applicable – limiting PTE for HAPs to <10/25 TPY

• 607.01(v) – Applicable – the facility requires a permit pursuant to Env-A 1400;

Env-A 800 – Testing and Monitoring Procedures (effective 10/31/10)

• 810.01(b) – Applicable – control devices required for metalizing booth to comply with AALs;

Env-A 1400 – Regulated Toxic Air Pollutants (effective 11-25-09)

• 1402.01(a) – the facility has processes that emit RTAPs;

Env-A 2100 – Process, Manufacturing, & Service-based Industries (effective 11-24-04)

• 2102.01 – Applicable – the thermal spray processes emits particulate matter;

• 2103.02 – Applicable – < 20% opacity for thermal spray emissions;

Federal Regulations

40 CFR Part 60 – No applicable processes

40 CFR Part 61 – No applicable processes

40 CFR Part 63 – Subpart XXXXXX – Metal Fabrication and Finishing

Applicable

• Facility is taking an enforceable permit limit for synthetic minor status for HAPs;

• This standard covers dry abrasive blasting, welding, dry grinding; and painting; DES has not taken delegation of this rule

and as a result no specific requirements will be placed into the permit; The facility will be notified that they are subject to

this rule in the cover letter that accompanies the final permit, and in this engineering summary; It is the responsibility of the

facility to determine their obligations under this rule.