Synthetic Minor Operating Permit Revision ENGINEERING EVALUATION REPORT APPLICATION 14029


Pacific Steel Casting
Plant 22605
1333 2nd Street
Berkeley, CA 94710
June 25, 2018

Prepared by: Nicholas C. Maiden, P.E. Principal Air Quality Engineer, BAAQMD
Reviewed by: Greg A. Stone
Supervising Air Quality Engineer, BAAQMD Pamela J. Leong
Director of Engineering, BAAQMD

Executive Summary
Pacific Steel Casting operates a steel foundry in the City of Berkeley, California. Pacific Steel Casting has three physically separate buildings designated Plants # 1, # 2, and # 3 by the facility. Each plant differs in the size of castings it produces as well as the materials and process it uses to make casting molds.

As PSC predates Regulation 2, Rule 6 (adopted November 3, 1993) – the regulation implementing Title V of the federal Clean Air Act as amended in 1990 – each plant was originally permitted as a separate facility and given unique District facility numbers: 187 (Plant # 1), 703 (Plant # 2), and 1603 (Plant # 3).

In 2002, Pacific Steel Casting obtained a Synthetic Minor Operating Permit (SMOP) that covered operations at Plants # 2 and # 3. At the time, the two plants were considered “contiguous” per Regulation 2, Rule 6 (Major Facility Review) whereas Plant # 1 was not.

In 2005, the District reviewed the facility’s operations and determined that Plant # 1 was considered “adjacent” to Plant # 2 and # 3. At this time, the District treated all three plants as one facility but maintained the separate District site numbers to aid the District’s Compliance and Enforcement Division responding to air quality complaints.
As a result of the District’s determination, Pacific Steel Casting was required to submit a permit application to revise their existing SMOP to include Plant # 1 sources.

(Note: It is difficult to learn from your history/mistakes if the BAAQMD is not willing to own up to them. MOREOVER, the Bay Area Air Quality Management District owes our West Berkeley community more than a mere apology for over twenty-five years of abandoning their legally-mandated responsibility for a fair regulatory process, one that should have been based on an honest application of permitting, engineering and air science, and not one of managerial discretion or political expediency. Most importantly, they need to acknowledge the harm that the air district and its handful of self-serving managers who callously impacted the health and wellbeing of more than one generation of downwind residents, including our children. Berkeley Citizen)

Through 2008 to 2013, the District and Pacific Steel Casting conducted extensive ambient air quality monitoring, source stack testing, and a comprehensive review of emissions estimation methodologies, assumptions, and emission factors on an individual source basis.

In 2014, PSC filed for bankruptcy and then was acquired by a new owner. As is customary with all transfers of ownership, the District assigned a new site number (District Facility 22605). At this time, the District re- numbered PSC’s sources to aid the District’s Compliance and Enforcement Division.

In 2015, the District became aware that Pacific Steel Casting’s pouring, cooling, and shake operations could potentially be large sources of carbon monoxide emissions, which were previously unknown. Although carbon monoxide emissions from other facility sources were accounted for, the District did not have emission estimates for carbon monoxide emission estimates for four permitted sources. The District and Pacific Steel Casting discussed how to account for these emissions, and ultimately agreed to accept a conservative emission factor to be source tested in the future.

This SMOP revision incorporates Plant # 1 sources as well imposes substantial new requirements and limits on an individual source basis to ensure that emissions remain and can be demonstrated to remain below the SMOP facility-wide emission limits.

To review this document: <ENGINEERING EVALUATION REPORT>

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