OKLAHOMA DEPARTMENT OF ENVIRONMENTAL …...dryer positioned above each cylinder, a dryer which is...

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM March 15, 2018

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager

THROUGH: Rick Groshong, Environmental Manager, Compliance and Enforcement

THROUGH: Phil Martin, P.E., Manager, Existing Source Permits Section

THROUGH: Amalia Talty, P.E., Existing Source Permits Section

FROM: David Schutz, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 2017-1358-TVR3

Armstrong Flooring (Formerly Armstrong World Industries)

Vinyl Flooring Production Facility

Stillwater Plant (FAC ID 119)

4115 N. Perkins Road

Stillwater, Payne County, Oklahoma

Latitude 36.16392oN, Longitude 97.05044oW

SECTION I. INTRODUCTION

Armstrong Flooring (Armstrong) has requested renewal of the Title V operating permit for their

facility (SIC 3996). The facility is currently operating under Permit No. 2012-831-TVR2 (M-2)

issued January 3, 2017.

The application requested the following changes from the current permit:

- The Rotogravure Printing Press Line no longer uses a “still” to reclaim solvent from

wastes. There will be a slight decrease in VOC emissions from eliminating this operation.

(The solvents will remain in facility wastes now.)

- EUG-5, currently named “Scrap Handling Operations,” will be renamed “Scrap Handling

and Cutting Operations.”

- A new tile sawing process has been added to EUG-5. The sawing process vents to the

existing baghouse serving the Scrap Granulator. PM emissions from the new process are

less than 0.01 TPY, and will be treated as an “insignificant activity.”

- Equivalent control devices will now be required to achieve either 20 ppm VOC or 95%

control. This applies only if the regenerative thermal oxidizers would be replaced, and

addresses the inability of EPA methods to measure very low concentrations of VOC.

Since the facility emits more than 100 TPY of a regulated pollutant, it is subject to Title V

permitting requirements. Emission units (EUs) have been arranged into Emission Unit Groups

(EUGs) in Section III.

PERMIT MEMORANDUM 2017-1358-TVR3 2 DRAFT

SECTION II. PROCESS DESCRIPTION

There is a single significant operating scenario. The four primary systems (lines) for the

production of sheet flooring are the Calendar Process, Gel Line, the Rotogravure Printing Press

Line, and the Coating & Fusion Line. The plant also includes various auxiliary units for

receiving, storing, and blending inks and plastic coatings and their carrier solvents. Process heat

is supplied by two boilers (10.4 MMBTUH and 14.65 MMBTUH) and by several heaters (one

19.2 MMBTUH heater, one 5 MMBTUH heater, four 4 MMBTUH heaters and eighty-three 0.3

MMBTUH space heaters). All heaters are fired with commercial-grade natural gas.

Vinyl flooring is manufactured by printing a pattern on a web (which can be made of paper, felt,

fiber-glass, and other materials) and coating that web with vinyl. A maximum production rate of

105 million square yards of flooring per year is anticipated.

The web is first coated with a PVC / limestone blend, which is then dried. Coated web proceeds

to the “Gel Line” which places a vinyl coating on the web in preparation for printing of the

decorative pattern. The gel coating is also dried. Rolls of coated web are then transferred to the

Printing Operation, where the patterns are printed. Inks are dried in preparation of placing the

final coating layers, the wear surfaces. All products receive an outer layer of vinyl at the Coating

& Fusion Line.

Gel Line

The plastisol system can provide batch plastisol coating formulations to both the Gel Line and to

the Coating and Fusion Line. The system consists of equipment for liquid and dry materials

unloading, storage, conveying and weighing, batching, vacuum mixing and intermediate storage.

(Note: the term "plastisol" is used interchangeably with the gel coating applied to the base web

prior to printing and with the final coating applied as a protective layer.)

Volatile organic compounds from the Gel Line are vented to the “Large REECO” (LR). A

capture efficiency of 95% is anticipated.

Printing

The rotogravure press line consists of eight color printing press stations capable of a line speed of

242 ft/min. The line prints prepared substrates processed by the gel line. Each print station has a

dryer positioned above each cylinder, a dryer which is supplied with steam regulated to dry the

applied coating and maintain the web temperature at any press speed. Exhausts from these dryers

are ducted to a regenerative thermal oxidizer (RTO) designated “large REECO (LR).”

Ink components consist primarily of ink pigments, extenders, and solvents. No heavy metals are

used in the pigments. A confidential file summarizes materials utilized and includes MSDSs for

the raw materials. All ink used by the press is mixed to order on-site using pigment concentrate,

extender, and solvent blend in the "Red Label Area" of the plant.


This area consists of the ink pigment and extender bulk storage, day solvent tank and day ink

pigment module storage, and the make-ready room (parts washing, cleaning rag storage, drum

washing, and ink formulation). A drum and container washing machine and station are provided

in the make-ready room for ink concentrate containers, mixed ink drums, etc. The machine

utilizes solvent from the day tank and still. A fume evacuation hood at the washing area collects

and conveys VOC emissions to the 85,000 ACFM thermal oxidizer designated “LR” (“Large

Reeco”). Similarly, VOC emissions from a drum washing and two pump-washing stations are

collected and conveyed to the “LR” thermal oxidizer.

The Red Label area consists of several sections: make-ready, ink storage, "still" (distillation), ink

pigment pumps, and press. Air collection pipes (“floor sweeps”) in the red label area collect and

vent VOC emissions to the atmosphere. A steam-heated solvent reclaimer is capable of storing

250 gallons of dirty solvent from the washing operations and distilling the solvent at the rate of

50 gallons per hour. A total of 1,200,000 pounds of ink solvents are anticipated per year in this

process.

Coating & Fusion Line

The Coating & Fusion line is a continuous process line which applies and cures plastisol wear

coatings at a maximum rate of 150 ft/min. A coater continuously applies plastisol wear coating to

the web prior to the curing operation. A curing oven, consisting of twelve 10-feet long gas-fired

modules, is utilized to cure the plastisol coating. The modules can operate up to 475oF. The

Finish Coater is normally exhausted to a 20,000 SCFM capacity thermal oxidizer (designated

“Small REECO,” or “SR”), while the Clear Coater is vented to Calendar Process RTO,

designated “CP.” From the curing oven, material passes through a cooling section (driven

cooling drums). A collection hood is provided along the entire length of the cooling section and

is ventilated at about 10,000 ACFM to collect plastisol aerosols emitted from the product during

cool-down. The exhausted air is discharged through an ESP (“Smog Hog”) for particulate matter

removal.

Calendar Process

In the Calendar Process, PVC resin is applied to the web, then sealed by heat and pressure. The

Calendar Process includes two silos, one for receiving limestone and one for receiving PVC

resin. PM emissions from each silo are controlled by baghouses with emissions guarantees of

0.04 gr/DSCF. Materials from these silos are transferred to a blender unit served by a 20,000

SCFM baghouse with an emission guarantee of 0.04 gr/DSCF. The limestone/PVC mixture is

then blended with organic solvent carrier and is used to place an initial coating on the web. The

volatile organic compounds are then dried off the coated web. Off-gases from this process are

treated first by a baghouse with a PM emissions guarantee of 0.04 gr/DSCF, then by an RTO.

Since the PVC forms an impermeable layer, only a fraction of solvents used are emitted; the

balance is trapped in the product. Emissions from this unit have been determined by stack testing.


Back Coating / Finish Coating

Additional operations have been installed which can place “back coating” or “finish coating,”

additional layers on top and/or on bottom of vinyl on the present vinyl coating. The raw material

preparation operations and the coating placement and curing operations are identical to other

vinyl coating operations.

Other Operations

The facility includes numerous silos for receiving and storing PVC and limestone as well as

numerous small tanks for storing solvents.

Scrap handling is conducted by conveying chopped edge-trim to an open-top dumpster using a

blower and duct system. A six-foot diameter cyclone with a mesh screen over the outlet is

provided to minimize loss of scrap. Because of the large size of the scrap, minimal emissions of

particulate matter are expected from the scrap-handling operation. Cutting is done by a rotating

knife, not by any sawing. The facility was authorized under Permit No. 97-297-TV (M-3) to

install a “scrap granulator” which separates web from PVC, allowing recycling of the PVC.

Production operations are anticipated at 24 hours per day, seven days per week, 52 weeks per

year, 8,760 hours per year. Maximum production of flooring is 105 million square yards per year.

The maximum anticipated throughput of the Calendar Process is 70 million square yards per

year.

SECTION III. EQUIPMENT

EUG 1A: Gel and Printing Lines; Coating & Fusion Line Curing Section

Emission

Unit ID

Emission

Point ID EU Name/Model Process Rate

Construction

Date

1A-#1-1 LR Gel Line Hot Oil Drum 94.7 million yds2

per year 1987

1A-#4-2 LR Large Reeco regenerative

thermal oxidizer

85,000 SCFM /

17.63

MMBTUH

1987

1A-#2-3 LR Red Label Area ink handling

operations

1.98 million

pounds solvents

per year

1987

1A-#2-4 LR

Printing press operations,

including printing press

cleaning

1.98 million

pounds solvents

per year

1987


EUG 1B: Calendar Process

Emission

Unit ID

Emission


Construction

Date

1B-#1-2 CP Calendar Line and Reeco

Regenerative Thermal Oxidizer

10,820 square

yards per hour;

94.7 million

square yards per

year

1999

1C-#1-5 #1-5e DUO2: Calendar Process

materials mixing & baghouse

10,000 SCFM

(0.04 gr/DSCF) 2001

EUG 1C: Calendar Process Raw Material Receiving and Blending

Emission

Unit ID

Emission


Construction

Date

1C-#1-4 #1-4d

Calendar Process Raw

Materials Handling (Mixing,

Heating and Pressing, 20,000

SCFM baghouse DU01)

20,000 SCFM

(0.04 gr/DSCF) 2001

1C-#1-6 #1-6f Outside North Limestone Silo

BS14E 2,178 DSCFM 2001

1C-#1-7 #1-7g Outside West PVC Silo BS16B 681 DSCFM 2001

1C-#1-8 #1-8h Resin & Minor Ingredient

Receiver PT03 1,111 DSCFM 2001

1C-#1-9 #1-9i Limestone Receiver PT02 2,330 DSCFM 2001

1C-#1-10 #1-10j Mix Receiver PT04 1,111 DSCFM 2001

1C-#1-11 #1-11k Scrap Return Pneumatic System 1,111 DSCFM 2001

EUG 2: Coating & Fusion Lines

Emission

Unit ID

Emission


Construction

Date

2-#3-1

SH

(“Smog

Hog”)

Coating and Fusion Line

Cooling Section

105 million sq.

yds/year / 10,000

SCFM

1987

2-#3-4 SR

Coating & Fusion Line (Drying

Section) and Reeco

Regenerative Thermal Oxidizer

20,000 SCFM 1987

2-#3-5 SR Finish Coater 70 million sq.

yds/year 2005

2-#3-6 CP Clear Coat Hot Oil Drum 105 million

sq.yds/year 2005

3A-#4-2 SR Coating & Fusion Line Curing

Heater 19.2 MMBTUH 1987


EUG 3A: Large Fuel-Burning Equipment

Emission

Unit ID

Emission


Construction

Date

3A-#4-3 B-1 Cyclo-Therm boiler 14.65

MMBTUH 1961

EUG 3B: Boiler Subject to NSPS Subpart Dc

Emission

Unit ID

Emission


Construction

Date

3B-#4-4 B-2 Holman boiler 10.4 MMBTUH 1999

EUG 3C: Small Fuel-Burning Equipment

Emission

Unit ID

Emission


Construction

Date

3C-#4-7 #4-7g Make-up air heater for Calendar 5 MMBTUH 1999

3C-#4-8 OH-1 Gel Line heater 4 MMBTUH 1987

3C-#4-9 OH-2 Calender hot oil heater 4 MMBTUH 1999

3C-#4-10 #4-11k Gas-fired space heaters 83 @ 0.3

MMBTUH each 1987

EUG 3D: Stationary Engines

Emission

Unit ID

Emission


Construction

Date

3C-#4-12 FP-2 John Deere diesel fire pump 150 HP 2005

3C-#4-13 EG-1 Kohler LSG8751 generator 210 HP (gas) 1964

3C-#4-14 EG-2 Kohler 4.3L 45RZG generator 75 HP (gas) 1999

3C-#4-15 EG-3 Kohler 4.3L 45RZG generator 75 HP (gas) 1999

3C-#4-16 EG-4 Cummins GGHG generator 113 HP (gas) 2003

EUG 3E: Stationary Engine Subject to NSPS Subpart IIII

Emission

Unit ID

Emission


Construction

Date

FP-1 FP-1 John Deere diesel fire pump 150 HP 2016


EUG 4A: Small Storage Tanks

Emission

Unit ID

Emission

Point ID Contents

Capacity,

Gallons

Construction

Date

4A-B1 B1 Plasticizer 8,000 1987






4A-A1 A1 Stabilizer 250 1987

4A-A2 A2 Gel plastisol 250 1987

4A-A3 A3 Stabilizer 250 1987

4A-A4 A4 Plasticizer 250 1987

4A-A5 A5 Plasticizer 500 1987

4A-A6 A6 Process aid 250 1987

4A-A7 A7 Plasticizer 1,000 1987

4A-A8 A8 Stabilizer 1,500 1987

4A-A9 A9 C & F plastisol 250 1987

4A-#2-1 TK-1 Solvent 5,000 1987

4A-#2-2 TK-2 Solvent 5,000 1987

4A-B8 B-8 Biocide 8,000 2004

4B-#1-5 TK-7 Plasticizer 12,000 gallons 2001

EUG 5: Scrap Handling and Cutting Operations

Emission

Unit ID

Emission


Construction

Date

5-#1-11 #1-11k Pneumatic scrap return 10 million lbs/year 1999

5-#3-2 #3-2b Hoffman blower HB-T2B07 10 million lbs/year 1987

5-#3-3 #3-3 Scrap granulator 10 million lbs/year 2005

5-#3-4 #3-3 Saw cutting 10 million lbs/year 2017


EUG 6: Raw Material Handling Operations

Emission

Unit ID

Emission


Construction

Date

6-#1-12 #1-12 l Inside limestone silo 4,084 DSCFM 1987

6-#1-13 #1-13 m Inside PVC silo 4,084 DSCFM 1987

6-#1-14 #1-14 n PVC silo 4,084 DSCFM 1987

6-#1-15 #1-15 o PVC silo 4,084 DSCFM 1987

6-#1-16 #1-16 p PVC silo 4,084 DSCFM 1987

6-#1-17 #1-17 q PVC silo 4,084 DSCFM 1987

6-#1-18 #1-18 r PVC silo 4,084 DSCFM 1987

6-#1-19 #1-19 s PVC silo 4,084 DSCFM 1987

6-#1-20 #1-20 t PVC silo 4,084 DSCFM 1987

6-#1-21 #1-21 u PVC silo 4,084 DSCFM 1987

6-#1-22 #1-22 v PVC silo 4,084 DSCFM 1987

6-#1-23 #1-23 w PVC silo 4,084 DSCFM 1987

6-#1-24 #1-24 x PVC silo 4,084 DSCFM 1987

Gel Surge Gel Surge Gel surge tank (in-process weighing) 4,084 DSCFM 1987

Receiver Receiver C&F surge tank (in-process weighing) 4,084 DSCFM 1987

6-#1-25 1-24 y Limestone silo 2,178 DSCFM 2005

SECTION IV. AIR EMISSIONS

Air emissions from the flooring production are primarily VOC, with lesser amounts of particulate

matter and combustion products.

Emissions from the Gel Line and Coating & Fusion Line are a function of the area of flooring

produced, not of the weight of solvent used. The initial curing process results in an impermeable

layer of plastic trapping solvents, all of which are low volatility. The processes include

enclosures to isolate the processes from outside contamination, thereby ensuring high capture

efficiency of VOC. Hourly emissions rates are conservatively high to be worst-case emissions for

modeling purposes.

The applicant has requested that the exact composition of several solvent-laden raw materials be

kept confidential. The permit will allow for a solvent tracking system to demonstrate that HAP

emissions are less than the 10 / 25 TPY thresholds.


EMISSION FACTOR REFERENCES

EU

ID EUG NAME EMISSIONS DATA

FACTOR

REFERENCE

1A-

#1-1 Gel Line stack emissions

8,000 lb VOC / million square yards

flooring, 95% capture*

stack tests + 40% safety

margin

1A-

#1-1

Gel Line uncaptured

emissions

8,000 lb VOC / million square yard

flooring, 5% uncaptured* mass balance

1A-

#4-2 Large Reeco RTO 17.63 MMBTUH, gas fuel


margin

1A-

#2-3 Red Label Area part of Large REECO emissions


margin

1A-

#2-3

Red Label Area

uncontrolled emissions

1.98 million lbs/yr per year VOC,

5% evaporation, 20% uncaptured*


margin

1A-

#2-4

Printing Presses (including

cleaning solvents)

1.98 million lbs/yr VOC, 95%

capture, 95% control* mass balance

1A-

#2-4

Printing Press uncaptured

emissions (including

cleaning solvents)

1.98 million lbs/yr VOC, 5%

uncaptured* mass balance

1B-#1-

2

Calendar Process stack

emissions 10,820 yd2/hr, 94.7 million yd2/yr


factor

CP Calendar Process RTO 8 MMBTUH, gas fuel stack tests + 25% safety

factor

1C-#1-

4

DUO1 Calendar Process

materials mixing 20,000 SCFM / 0.04 gr/DSCF PM

baghouse manufacturer

guarantees

1C-#1-

5

DUO2 Calendar Process

materials mixing 10,000 SCFM / 0.06 lb/hr stack tests

1C-#1-

6

Outside north limestone

silo BS14E 2,178 DSCFM / 0.006 gr/DSCF


guarantees

1C-#1-

7

Outside west PVC silo

BS16B 681 DSCFM / 0.006 gr/DSCF


guarantees

1C-#1-

8

Resin & Minor

Ingredients Receiver

PT03

1,111 DSCFM / 0.006 gr/DSCF baghouse manufacturer

guarantees

1C-#1-

9

Limestone Receiver

PT02 2,330 DSCFM / 0.006 gr/DSCF


guarantees

1C-#1-

10 Mix Receiver PT04 5,434 DSCFM / 0.006 gr/DSCF


guarantees

1C-#1-

11

Scrap return pneumatic

system 1,111 DSCFM / 0.006 gr/DSCF


guarantees

* performance testing was required to confirm capture efficiencies, showing 98.8%.


EU


FACTOR

REFERENCE

SR Coating & Fusion Curing

Section Part of SR emissions


factor

SH Coating & Fusion Cooling

Section

VOC: 4.41 lb/hr / 19.30 TPY

PM10: 1.60 lb/hr / 7.00 TPY

(hourly rates have 300% safety

factor applied)

stack testing

SR “Small Reeco” RTO 7.5 MMBTUH, gas fuel stack tests + 25% safety

factor

3A-

#4-2

Coating & Fusion curing

heater Part of SR emissions

stack test + 25% safety

factor

2B-#3-

5 Finish Coater Part of SR emissions

stack test + 25% safety

factor

2B-#3-

6 Clear Coat Hot Oil Drum Part of CP emissions


factor

B-1 Cyclo-Therm Boiler 14.65 MMBTUH, gas fuel AP-42 (7/98), Section 1.4

B-2 Holman Boiler 10.4 MMBTUH, gas fuel AP-42 (7/98), Section 1.4

3C-#4-

7

Calendar Process make-up

air heater 5 MMBTUH, gas fuel AP-42 (7/98), Section 1.4

OH-1 Gel Line Heater 4 MMBTUH, gas fuel AP-42 (7/98), Section 1.4

OH-2 Calendar hot oil heater 4 MMBTUH, gas fuel AP-42 (7/98), Section 1.4

4-7g Make-up air heater for

Calendar Process 5 MMBTUH AP-42 (7/98), Section 1.4

#4-10j Gas-fired space heaters 83 heaters, each 0.3 MMBTUH AP-42 (7/98), Section 1.4

FP-1 Fire water pump 150 HP diesel engine NSPS Subpart IIII limits &

AP-42 (10/96), Section 3.3

4-12l Fire water pump 150 HP diesel engine AP-42 (10/96), Section 3.3

4-13m Emergency generator 210 HP gas-fired engine AP-42 (10/96), Section 3.2

4-14n Emergency generator 75 HP gas-fired engine AP-42 (10/96), Section 3.2

4-15o Emergency generator 75 HP gas-fired engine AP-42 (10/96), Section 3.2

4-16p Emergency generator 113 HP gas-fired engine AP-42 (10/96), Section 3.2

B1 Plasticizer 8,000 gallons TANKS4.0






B8 Biocide 8,000 gallons TANKS4.0

A1 Stabilizer 250 gallons TANKS4.0

A2 Plastisol 250 gallons TANKS4.0

A3 Stabilizer 250 gallons TANKS4.0


EU


FACTOR

REFERENCE

A4 Plasticizer 250 gallons TANKS4.0

A5 Plasticizer 500 gallons TANKS4.0

A6 Process aid 250 gallons TANKS4.0

A7 Plasticizer 1,000 gallons TANKS4.0

A8 Stabilizer 1,500 gallons TANKS4.0

A9 Plastisol 250 gallons TANKS4.0

TK-1 Solvent 5,000 gallons TANKS4.0

TK-2 Solvent 5,000 gallons TANKS4.0

TK-7 Plasticizer 12,000 gallons TANKS4.0

#1-11k Pneumatic scrap return 1,111 DSCFM / 0.006 gr/DSCF baghouse manufacturer

guarantees

#3-2b Hoffman blower scrap

return 1,111 DSCFM / 0.006 gr/DSCF


guarantees

#3-3 Scrap granulator

VOC: 8.79 E-6 lb/yd2

PM: 2,500,000 lbs web, 97%

control of cyclone, 99.9% control at

scrap baghouse

VOC: stack tests in

Pennsylvania; PM mass

balance and cyclone/


guarantees

#3-4 Saw cutting

5,000,000 lbs planks, 97% control

by cyclone, 99.9% control at scrap

baghouse

PM mass balance and

cyclone/ baghouse

manufacturer guarantees

#1-12 l Inside limestone silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-13 m Inside PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-14 n PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-15 o PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-16 p PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-17 q PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-18 r PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-19 s PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees


EU


FACTOR

REFERENCE

#1-20 t PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-21 u PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-22 v PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-23 w PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-24 x PVC silo 4,084 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

#1-25 y Limestone silo 2,184 DSCFM / 0.01 gr/DSCF baghouse manufacturer

guarantees

Surge Gel surge tank (in-

process weighing) 4,084 DSCFM / 0.01 gr/DSCF


guarantees

Receiver C&F surge tank (in-

process weighing) 4,084 DSCFM / 0.01 gr/DSCF


guarantees

EUG 1A: Gel and Printing Lines

Emission

Unit ID

Emission

Point ID EU Name/Model

Emissions

Pollutant lb/hr TPY

1A-#1-1

1A-#4-2

1A-#2-3

1A-#2-4

1A-#2-4

LR

Gel Line Hot Oil Drum

Large Reeco RTO

Red Label Area ink handling

Printing press operations

Printing press cleaning

NOx 10.03 43.92

CO 12.37 55.51

VOC 4.72 20.66

SO2 0.01 0.05

PM10 0.13 0.59

1A-#1-1

building

ventilation

Gel & Printing uncaptured VOC VOC 3.82 16.75 1A-#2-4

1A-#2-3

1A-#2-4 Red Label Area uncaptured VOC VOC 2.91 12.74

1A-#1-1

1A-#4-2

1A-#2-3

1A-#2-4

1A-#2-4

LR Excess

Emissions


Large Reeco RTO

Red Label Area ink handling

Printing press operations

Printing press cleaning

VOC 89.68 0.22

CO 235.03 0.59

PM10 2.55 0.01



Emission

Unit ID

Emission

Point ID EU Name/Model Pollutant

Emissions

lb/hr TPY

1B-#1-2

1B-#1-3

1C-#1-5

CP

Calendar Process, Clear Coat HOD,

and Reeco regenerative thermal

oxidizer, DUO2 Calendar Process

materials mixing

NOx 3.47 15.21

CO 4.61 20.21

VOC 4.50 19.63

SO2 0.53 2.31

PM10 2.36 10.35

1B-#1-2

1B-#1-3

1C-#1-5

CP Excess

Emissions

Calendar Process, Clear Coat HOD,

and Reeco regenerative thermal

oxidizer, DUO2 Calendar Process

materials mixing

VOC 85.50 0.21

CO 87.59 0.22

PM10 11.4 0.03


Emission

Unit ID

Emission


PM10 Emissions

lb/hr TPY

1C-#1-4 #1-4d DOU1 Raw Materials Handling 6.857 30.034


BS14E 0.112 0.491

1C-#1-7 #1-7g Outside West PVC Silo BS16B 0.035 0.153

1C-#1-8 #1-8h Resin & Minor Ingredients PT03 0.057 0.250

1C-#1-9 #1-9i Limestone Receiver PT02 0.120 0.525

1C-#1-10 #1-10j Mix Receiver PT04 0.279 1.224

1C-#1-11 #1-11k Scrap return pneumatic system 0.057 0.250

TOTALS 7.518 32.928

EUG 2: Coating & Fusion Line

Emission

Unit ID

Emission


Emissions

lb/hr TPY

2-#3-1

SH

(“Smog

Hog”)

Coating and Fusion Line Cooling

Section

PM10 1.60 7.00

VOC 6.17 27.04

SR

3A-#4-1

3A-#4-2

SR

Reeco Regenerative Thermal

Oxidizer (7.5 MMBTUH);

Finish Coater

NOx 6.60 28.92

CO 3.17 13.88

VOC 5.90 25.81

SO2 0.58 2.52

PM10 4.95 7.65

SR

3A-#4-1

3A-#4-2

SR Excess

Emissions



Finish Coater

VOC 112.1 0.28

CO 47.5 0.12

PM10 93.97 0.23



Emission

Unit ID

Emission


Emissions

lb/hr TPY

3B-#4-3 B-1 Cyclo-Therm boiler (14.65

MMBTUH)

NOx 1.465 6.417

CO 1.231 5.390

VOC 0.081 0.353

SO2 0.009 0.039

PM10 0.111 0.488


Emission

Unit ID

Emission


Emissions

lb/hr TPY

3B-#4-4 B-2 Holman boiler (10.4 MMBTUH)

NOx 1.040 4.555

CO 0.874 3.826

VOC 0.057 0.251

SO2 0.006 0.027

PM10 0.079 0.346

EUG 3C: Small Fuel-Burning Equipment

Emission

Unit ID

Emission


Emissions

lb/hr TPY

3C-#4-8 OH-1 Gel Line heater (4 MMBTUH)

NOx 0.400 1.752

CO 0.336 1.472

VOC 0.022 0.096

SO2 0.002 0.011

PM10 0.030 0.133

3C-#4-9 OH-2 Calender hot oil heater (4

MMBTUH)

NOx 0.400 1.752

CO 0.336 1.472

VOC 0.022 0.096

SO2 0.002 0.011

PM10 0.030 0.133

3C-#4-11k #4-11k Gas-fired space heaters (83 heaters,

each 0.3 MMBTUH)

NOx 2.490 10.906

CO 0.336 1.472

VOC 0.022 0.096

SO2 0.002 0.011

PM10 0.030 0.133

3C-#4-7 #4-7g Make-up air heater for Calendar

process (5 MMBTUH)

NOx 0.500 2.190

CO 0.420 1.840

VOC 0.028 0.120

SO2 0.003 0.013

PM10 0.038 0.166



Emission

Unit ID

Emission


Emissions

lb/hr TPY

3C-#4-13 FP-2 150-HP diesel engine

NOx 4.650 1.163

CO 1.002 0.251

VOC 0.377 0.094

SO2 0.308 0.077

PM10 0.330 0.083

3C-#4-14 EG-1 210-HP gas-fired emergency

generator

NOx 8.027 2.007

CO 13.547 3.387

VOC 0.108 0.027

SO2 0.002 0.001

PM10 0.070 0.018


generator

NOx 1.326 0.332

CO 2.238 0.560

VOC 0.018 0.004

SO2 0.001 0.001

PM10 0.012 0.003


generator

NOx 1.326 0.332

CO 2.238 0.560

VOC 0.018 0.004

SO2 0.001 0.001

PM10 0.012 0.003


generator

NOx 1.998 0.500

CO 3.372 0.843

VOC 0.027 0.006

SO2 0.001 0.001

PM10 0.018 0.005


Emission

Unit ID

Emission


Emissions

lb/hr TPY

FP-1 FP-1 150-HP diesel engine

NOx 4.63 1.16

CO 1.00 0.25

VOC 0.37 0.09

SO2 0.01 0.01

PM10 0.33 0.08


EUG 4A: Small Storage Tanks

Emission

Unit ID

Emission


VOC Emissions

lb/hr TPY

4A-B1 B1 8,000-gallons plasticizer 0.01 0.01






4A-A1 A1 250-gallons stabilizer 0.01 0.01

4A-A2 A2 250-gallons plastisol 0.01 0.01

4A-A3 A3 250-gallons stabilizer 0.01 0.01

4A-A4 A4 250-gallons plasticizer 0.01 0.01

4A-A5 A5 500-gallons plasticizer 0.01 0.01

4A-A6 A6 250-gallons process aid 0.01 0.01

4A-A7 A7 1,000-gallons plasticizer 0.01 0.01

4A-A8 A8 1,500-gallons stabilizer 0.01 0.01

4A-A9 A9 250-gallons plastisol 0.01 0.01

4A-#2-1 TK-1 5,000-gallons solvent 0.01 0.01

4A-#2-2 TK-2 5,000-gallons solvent 0.01 0.01

4A-B8 B-8 8,000-gallons biocide 0.01 0.01

4B-#1-5 TK-7 12,000-gallons plasticizer 0.01 0.01

TOTALS 0.19 0.19

EUG 5: Scrap Handling and Cutting Operations

Emission

Unit ID

Emission


PM10 VOC

lb/hr TPY lb/hr TPY

5-#1-11 #1-11k Pneumatic scrap return 0.057 0.250 -- --

5-#3-2 #3-2b Hoffman blower HB-T2B07 0.057 0.250 -- --

5-#3-3 #3-3 Scrap granulator 0.043 0.188 0.01 0.01

5-#3-4 #3-3 Saw cutting 0.01 0.01 -- --

TOTALS 0.17 0.69 0.01 0.01


EUG 6: Raw Material Handling Operations

Emission

Unit ID

Emission


PM10 Emissions

lb/hr TPY

6-#1-12 #1-12 l Inside limestone silo 0.350 1.533

6-#1-13 #1-13 m Inside PVC silo 0.350 1.533

6-#1-14 #1-14 n PVC silo 0.350 1.533

6-#1-15 #1-15 o PVC silo 0.350 1.533

6-#1-16 #1-16 p PVC silo 0.350 1.533

6-#1-17 #1-17 q PVC silo 0.350 1.533

6-#1-18 #1-18 r PVC silo 0.350 1.533

6-#1-19 #1-19 s PVC silo 0.350 1.533

6-#1-20 #1-20 t PVC silo 0.350 1.533

6-#1-21 #1-21 u PVC silo 0.350 1.533

6-#1-22 #1-22 v PVC silo 0.350 1.533

6-#1-23 #1-23 w PVC silo 0.350 1.533

6-#1-24 #1-24 x PVC silo 0.350 1.533

6-#1-25 #1-24 y Limestone silo 0.112 0.490

Surge Surge Gel surge tank (in-process weighing) 0.350 1.533

Receiver Receiver C&F surge tank (in-process weighing) 0.350 1.533

TOTALS 5.363 23.489


CRITERIA POLLUTANT EMISSIONS BY POINT

Point

ID Emission Unit Name

NOx CO VOC SO2 PM10

lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

LR


Red Label Area

Printing Presses

10.03 43.92 12.37 55.51 4.72 20.66 0.011 0.046 0.134 0.587

Emissions During Start-up/

Shutdown/Malfunction -- -- 247.4 0.62 94.4 0.24 -- -- 2.68 0.01

Fug Gel / Printing Uncaptured VOC -- -- -- -- 3.82 16.75 -- -- -- --

Fug Red Label Uncaptured VOC -- -- -- -- 2.91 12.74 -- -- -- --

CP

Calendar Process / DUO2

Baghouse 3.47 15.21 4.61 20.21 4.50 19.63 0.53 2.30 2.36 10.35



#1-4d DUO1 Raw Materials -- -- -- -- -- -- -- -- 6.857 30.034

#1-6f North Limestone BS14E -- -- -- -- -- -- -- -- 0.112 0.491

#1-7g West PVC Silo BS15B -- -- -- -- -- -- -- -- 0.035 0.153

#1-8h Resin & Minor Ingredients

PT03 -- -- -- -- -- -- -- -- 0.057 0.250

#1-9i Limestone Receiver PT02 -- -- -- -- -- -- -- -- 0.120 0.525

#1-10j Mix Receiver PT04 -- -- -- -- -- -- -- -- 0.279 1.224

#1-11k Scrap return pneumatic

system -- -- -- -- -- -- -- -- 0.057 0.250

SH C&F Cooling -- -- -- -- 6.17 27.04 -- -- 1.600 7.000

SR

C&F Finish Coat Oven

Small Reeco 6.60 28.91 3.17 13.88 5.90 25.81 0.58 2.52 4.946 7.647



B-1 14.65 MMBTUH boiler 1.465 6.417 1.231 5.390 0.081 0.353 0.009 0.039 0.111 0.488

B-2 10.4 MMBTUH boiler 1.040 4.555 0.874 3.826 0.057 0.251 0.006 0.027 0.079 0.346

OH-1 Gel Line heater 0.400 1.752 0.336 1.472 0.022 0.096 0.002 0.011 0.030 0.133

OH-2 Calendar hot oil heater 0.400 1.752 0.336 1.472 0.022 0.096 0.002 0.011 0.030 0.133

#4-11K Space heaters 2.490 10.906 2.092 9.161 0.137 0.600 0.015 0.065 0.189 0.829

#4-7g Calendar Process heater 0.500 2.190 0.420 1.840 0.028 0.120 0.003 0.013 0.038 0.166

FP-1 150-HP diesel engine 4.63 1.16 1.00 0.25 0.37 0.09 0.01 0.01 0.33 0.08

4-13m 150-HP diesel engine 4.650 1.162 1.002 0.251 0.377 0.094 0.308 0.077 0.330 0.083

4-14n 210-HP emergency gen 6.510 1.628 1.403 0.351 0.527 0.132 0.431 0.108 0.462 0.116

4-15o 75-HP emergency gen 1.326 0.332 2.238 0.560 0.018 0.004 0.001 0.001 0.012 0.003

4-16p 75-HP emergency gen 1.326 0.332 2.238 0.560 0.018 0.004 0.001 0.001 0.012 0.003

4-17q 113-HP emergency gen 1.998 0.500 3.372 0.843 0.027 0.006 0.001 0.001 0.018 0.005

B1 8,000-gallons Plasticizer -- -- -- -- 0.01 0.01 -- -- -- --






A1 250-gallons Stabilizer -- -- -- -- 0.01 0.01 -- -- -- --

A2 250-gallons Plastisol -- -- -- -- 0.01 0.01 -- -- -- --

A3 250-gallons Stabilizer -- -- -- -- 0.01 0.01 -- -- -- --

A4 250-gallons Plasticizer -- -- -- -- 0.01 0.01 -- -- -- --


CRITERIA POLLUTANT EMISSIONS BY POINT - Continued

Point

ID Emission Unit Name

NOx CO VOC SO2 PM10


A5 500-gallons Plasticizer -- -- -- -- 0.01 0.01 -- -- -- --

A6 250-gallons Process aid -- -- -- -- 0.01 0.01 -- -- -- --

A7 1,000-gallons Plasticizer -- -- -- -- 0.01 0.01 -- -- -- --

A8 1,500-gallons Stabilizer -- -- -- -- 0.01 0.01 -- -- -- --

A9 250-gallons Plastisol -- -- -- -- 0.01 0.01 -- -- -- --

B8 8,000-gallons Biocide -- -- -- -- 0.01 0.01 -- -- -- --

TK-1 5,000-gallons Solvent -- -- -- -- 0.01 0.01 -- -- -- --

TK-2 5,000-gallons Solvent -- -- -- -- 0.01 0.01 -- -- -- --

TK-7 12,000-gallons Plasticizer -- -- -- -- 0.01 0.01 -- -- -- --

#1-11k Pneumatic scrap return -- -- -- -- -- -- -- -- 0.057 0.250

#3-2b Hoffman blower HB-T2B07 -- -- -- -- -- -- -- -- 0.057 0.250

#3-3 Scrap granulator & saw -- -- -- -- 0.01 0.01 -- -- 0.05 0.20

#1-12 l Inside limestone silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-13 m Inside PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-14 n PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-15 o PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-16 p PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-17 q PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-18 r PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-19 s PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-20 t PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-21 u PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-22 v PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-23 w PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

#1-24 x PVC silo -- -- -- -- -- -- -- -- 0.350 1.533

Surge Gel surge tank (in-process

weighing) -- -- -- -- -- -- -- -- 0.350 1.533

Receiver C&F surge tank (in-process

weighing) -- -- -- -- -- -- -- -- 0.350 1.533

1-25 y Limestone silo -- -- -- -- -- -- -- -- 0.112 0.49

TOTALS 46.84 120.73 426.29 116.56 332.30 125.45 1.91 5.23 137.33 85.37

To keep the composition of various raw materials confidential, the facility will utilize a Solvent

Tracking System to determine HAP emissions.

HAZARDOUS AIR POLLUTANT EMISSIONS

Hazardous Air Pollutant C A S Number Emissions

lb/hr TPY

Butyl cellosolve 111762 0.08 0.33

Methyl isobutyl ketone 108101 0.68 2.99

Toluene 108883 0.07 0.21

Vinyl chloride 75014 0.02 0.06


There is a total of 3.59 TPY Title III HAPs. At this emission level, the facility is an “area” (non-

major) source of HAPs. The application estimated a maximum of 0.27 TPY additional HAPs

resulting from 20 events of electric power loss, which maintains area source status.

GREENHOUSE GAS (GHG) EMISSIONS

Greenhouse gas emissions have been stated as a potential of 13,830 TPY CO2e.

There are 16 primary discharge points for air emissions at the facility tabulated following.

SIGNIFICANT DISCHARGE POINTS

Point

ID Process / Unit

Height

Feet

Diameter

Inches

Flow Rate

ACFM

Temperature oF

SR 20,000 SCFM RTO (Coating

& Fusion Line) 53 48 38,702 565

LR 85,000 SCFM RTO (Printing

Line) 60 90 147,728 461

CP 60,000 SCFM RTO (Calendar

Process) 75 60 116,106 300

B-1 10.4 MMBTUH Boiler 38 24 6,300 600

B-2 14.65 MMBTUH Boiler 38 25 10,500 580

OH-1 Gel Line Heater 40 20 863 715

OH-2 Calendar Hot Oil Heater 57 24 863 715

EF-2 Red Label Area 45 27 4,000 ambient

#1d 20,000 SCFM Baghouse 20 30 20,000 70

#1f Outside Limestone Silo

Baghouse 105 30 x 40 2,178 ambient

#1g Outside Resin Silo Baghouse 75 30 x 40 681 ambient

#1h Pneumatic Limestone System 53 6 x 12 1,111 ambient

#1i Limestone Conveyance 85 6 x 12 2,330 ambient

#1j Pneumatic system: Blender 1

into Blender 2 75 6 x 12 5,434 ambient

#1k Scrap Return System 28 6 x 12 1,111 ambient

SH Coating & Fusion ESP 46 26 10,000 100


SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application and listed in OAC 252:100-

8, Appendix I, are listed below. Recordkeeping for activities indicated with “*” is listed in the

Specific Conditions.

1. Space heaters, boilers, process heaters and emergency flares less than or equal to 5

MMBTUH heat input (commercial natural gas). There are several 4 MMBTUH heaters

and 83 space heaters with a capacity each of 0.3 MMBTUH.

2. * Storage tanks with less than or equal to 10,000 gallons capacity that store volatile

organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum

storage temperature. All of the tanks in EUG 4A are in this category.

3. * Emissions from storage tanks constructed with a capacity less than 39,984 gallons

which store VOC with a vapor pressure less than 1.5 psia at maximum storage

temperature. This category re-states the tanks in the previous category.

4. Cold degreasing operations utilizing solvents that are denser than air. None is identified

but may be in the future.

5. Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per

year of electrodes. These are part of the facility maintenance activities, which are actually

“trivial activities,” therefore recordkeeping will not be required in the Specific

Conditions.

6. Torch cutting and welding of under 200,000 tons of steel fabricated. These are part of the

facility maintenance activities, which are actually “trivial activities,” therefore

recordkeeping will not be required in the Specific Conditions.

7. Sanitary sewage collection and treatment facilities other than incinerators and Publicly

Owned Treatment Works (POTW).

8. Surface coating operations which do not exceed a combined total usage of more than 60

gallons per month of coatings, thinners, or clean-up solvents at any one emission unit.

These are part of the facility maintenance activities, which are actually “trivial activities,”

therefore recordkeeping will not be required in the Specific Conditions.

9. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including

hazardous waste satellite (accumulation) areas. The facility includes an ink blending area

and chemical storage area.

10. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used

for spot cleaning and/or degreasing in ozone attainment areas.

11. Activities having the potential to emit no more than 5 TPY of any criteria pollutant. The

scrap handling units in EUG 5 and the raw material silos in EUG 6 are in this category.


SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable]

This subchapter incorporates by reference applicable provisions of Title 40 of the Code of

Federal Regulations. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these

standards. In addition, modeled emissions from the proposed facility demonstrate that the facility

would not have a significant impact on air quality.

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable]

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission

inventories annually, and pay annual operating fees based upon total annual emissions of

regulated pollutants. Emission inventories were submitted and fees paid for previous years as

required.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requirements for part 70 permits. Any planned

changes in the operation of the facility which result in emissions not authorized in the permit and

which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior

notification to AQD and may require a permit modification. Insignificant activities mean

individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual

calendar year emissions do not exceed the following limits:

5 TPY of any one criteria pollutant

2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any

threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emissions limitations have been incorporated from the previously-issued permits and the latest

permit application.


OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator

of an air contaminant source from which excess emissions have occurred shall submit a report

for each excess emission event describing the extent of the event and the actions taken by the

owner or operator of the facility in response to this event. Request for mitigation, as described in

OAC 252:100-9-8, shall be included in the excess emission event report. Additional reporting

may be required in the case of ongoing emission events and in the case of excess emissions

reporting required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter) [Applicable]

Subchapter 19 specifies PM emissions limitations based on heat input capacity. Each unit is rated

at less than 10 MMBTUH, so the applicable standard is 0.60 lb/MMBTU. AP-42 (7/98), Chapter

1.4, lists natural gas TPM emissions to be 7.6 lb/million SCF or about 0.0076 lb/MMBTU which is

in compliance with this subchapter. AP-42 (10/96), Chapter 3.3, lists diesel TPM emissions to be

0.31 lb/MMBTU which is also in compliance with this subchapter. The permit will require the use

of natural gas or No. 2 diesel for all fuel-burning equipment.

Process Process Weight Rate

TPH Allowable Emissions

lb/hr Permitted Emissions

lb/hr Gel Line 20.97 31.5 0.134

Coating & Fusion 19.42 29.92 1.600 Calendar Process 3.50 9.49 2.36 Scrap Handling 0.35 2.03 0.002

Saw Cutting 0.35 2.03 0.01

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences which

consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed

three such periods in any consecutive 24 hours. In no case shall the average of any six-minute

period exceed 60% opacity. When burning natural gas, the fuel-burning equipment has very little

possibility of exceeding opacity standards, therefore no periodic observation is necessary. As

long as thermal oxidizer temperatures are maintained at or above the minima specified, the

presses also will not exceed opacity limitations. The permit provides for monitoring and

recording operating temperatures to ensure emissions limitations are complied with.


OAC 252:100-29 (Fugitive Dust) [Applicable]

Subchapter 29 prohibits the handling, transportation, or disposition of any substance likely to

become airborne or windborne without taking “reasonable precautions” to minimize emissions of

fugitive dust. No person shall cause or permit the discharge of any visible fugitive dust emissions

beyond the property line on which the emissions originate in such a manner as to damage or to

interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to

interfere with the maintenance of air quality standards. Under normal operating conditions, this

facility will not cause a problem in this area, therefore it is not necessary to require specific

precautions to be taken.

OAC 252:100-31 (Sulfur Compounds) [Applicable]

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,

1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input averaged over 3 hours. For fuel

gas having a gross calorific value of 1,000 BTU/SCF, this limit corresponds to fuel sulfur content

of 1,203 ppmv. For liquid fuels, the limit is 0.8 lbs/MMBTU. AP-42 (7/98), Section 1.4, lists

SO2 emissions at 0.0006 lb/MMBTU for gas fuel and AP-42 (10/96) lists SO2 emissions from

diesel-powered engines at 0.29 lb/MMBTU. NSPS Subpart IIII limits the new engine FP-1 to 500

ppm sulfur. The permit requires the use of commercial pipeline-grade natural gas or No. 2 diesel

for all fuel-burning equipment to ensure compliance with Subchapter 31.

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]

Subchapter 33 affects fuel-burning equipment with a rated heat input of 50 MMBTUH or more.

All fuel-burning equipment is rated below this threshold.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

None of the following affected processes are part of this project: gray iron cupola, blast furnace,

basic oxygen furnace, petroleum catalytic reforming unit, or petroleum catalytic cracking unit.

OAC 252:100-37 (Volatile Organic Compounds) [Applicable]

Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons

or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a

permanent submerged fill pipe or with an organic vapor recovery system. All storage tanks are

equipped with submerged fill pipes.

Part 3 requires loading facilities with a throughput equal to or less than 40,000 gallons per day to

be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the

vehicle is greater than 200 gallons. This facility does not have the physical equipment (loading

arm and pump) to conduct this type of loading. Therefore, this requirement is not applicable.

Part 5 limits the VOC content of coatings used in coating operations. Any paint operation will

involve maintenance coatings of building and equipment and emit less than 100 pounds per day

of VOCs and so is exempt. The inks are not among the types of coatings regulated by this

section: acrylics, alky primers, epoxies, vinyls, NC lacquers, and specialty coatings. It is not clear

whether the vinyl coating would be subject to Part 5, but processing emissions from vinyl layer

application by RTOs would yield an effective VOC content of approximately 0.3 lb/gal, which is

in compliance with Part 5.


Part 7 requires fuel-burning equipment to be operated and maintained to minimize emissions of

VOC. The equipment at this location is subject to this requirement.

Part 7 requires effluent water separators which receive water containing more than 200 gallons

per day of any VOC to be equipped with vapor control devices. There is no effluent water

separator at this location.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]

This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in

areas of concern (AOC). Any work practice, material substitution, or control equipment required

by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a

modification is approved by the Director. Since no AOC has been designated there are no

specific requirements for this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.

To determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant

source. All required testing must be conducted by methods approved by the Air Quality Director

and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol

shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.

Emissions and other data required to demonstrate compliance with any federal or state emission

limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and

submitted as required by this subchapter, an applicable rule, or permit requirement. Data from

any required testing or monitoring not conducted in accordance with the provisions of this

subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive

use, of any credible evidence or information relevant to whether a source would have been in

compliance with applicable requirements if the appropriate performance or compliance test or

procedure had been performed.

The following Oklahoma Air Pollutant Control Rules are not applicable to this facility:

OAC 252:100-11 Alternative Reduction Not eligible

OAC 252:100-15 Mobile Sources Not in source category

OAC 252:100-17 Incinerators Not type of emission unit

OAC 252:100-23 Cotton Gins Not type of emission unit

OAC 252:100-24 Feed & Grain Facility Not in source category

OAC 252:100-39 Nonattainment Areas Not in a subject area

OAC 252:100-47 Landfills Not type of source category


SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

Total potential emissions of all criteria pollutants are less than the significance level of 250 TPY,

and this facility is not among the 26 industries defined as a “major source” at an emission level

of 100 TPY.

NSPS, 40 CFR Part 60 [Subparts Dc and IIII Applicable]

Subpart Dc (Small Industrial Boilers) affects boilers which commenced construction,

reconstruction, or modification after June 9, 1989, and which have a capacity of 10 MMBTUH or

more. Boiler B-2 is subject to Subpart Dc. The only standard applicable to gas-fired boilers is a

requirement to keep records showing the fuel used.

Subpart Kb (Organic Liquids Storage Vessels) affects tanks which commenced construction,

reconstruction, or modification after July 23, 1984, and which have a capacity of 19,813 gallons

or more. Subpart Kb was changed on October 15, 2003, from a minimum size of 10,567 gallons

to 19,813 gallons. TK-7 is no longer subject to this regulation.

Subpart QQ (Publication Rotogravure Printing) affects facilities involved in printing and

publishing. Printing of resilient flooring is specifically exempted from this subpart.

Subpart FFF (Flexible Vinyl and Urethane Coating and Printing) also specifically exempts

flooring production facilities.

Subpart VVV (Polymeric Coating of Supporting Substrates) affects polymer coatings facilities

which commenced construction, reconstruction, or modification after April 30, 1987. This

facility commenced construction just before the effective date of Subpart VVV. The Calendar

Process, installed after the effective date of Subpart VVV, coats paper (felt), therefore is not

among the types of operations affected.

Subpart IIII (Stationary Compression Ignition Internal Combustion Engines) affects stationary

compression ignition (CI) internal combustion engines (ICE) based on power and displacement

ratings, depending on date of construction, beginning with those constructed after July 11, 2005.

For the purposes of this subpart, the date that construction commences is the date the engine is

ordered by the owner or operator. The existing emergency engines at this facility pre-date

Subpart IIII. The fire pump engine, FP-1, is subject to requirements for emergency fire pump

engines.

Subpart JJJJ, Stationary Spark Ignition (SI) Internal Combustion Engines (ICE). This subpart

was proposed on June 12, 2006. For the purposes of this subpart, the date of construction is the

date the engine is ordered by the owner or operator. The existing emergency engines at this facility pre-date Subpart JJJJ or are compression ignition engines.

NESHAP, 40 CFR Part 61 [Not Applicable]

None of the eight pollutants subject to NESHAP will be emitted: arsenic, asbestos, benzene,

beryllium, mercury, coke oven emissions, radionuclides, or vinyl chloride.


NESHAP, 40 CFR Part 63 [Subparts KK and ZZZZ Applicable]

Subpart KK (Printing and Publishing Industry) specifies standards for major and area sources of

HAPs for printing facilities. Area sources are only required to keep records showing that

emissions of HAPs are below the 10/25 TPY thresholds.

Subpart JJJJ (Paper and Other Web Coatings) specifies standards for major sources of HAPs for

printing facilities. This facility is an area source, therefore not subject to this regulation. The

permit will specify use of a solvent tracking system to ensure that HAP emissions are less than

the major source thresholds.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart previously

only affected RICE with a site-rating greater than 500 brake horsepower that are located at a

major source of HAP emissions. The EPA published a final rule that promulgates standards for

new and reconstructed engines (after June 12, 2006) with a site rating of less than or equal to 500

HP located at major sources, and for new and reconstructed engines (after June 12, 2006) located

at area sources. Owners and operators of new engines and reconstructed engines at area sources

and of new or reconstructed engines with a site rating of equal to or less than 500 HP located at a

major source (except new or reconstructed 4-stroke lean burn engines with a site rating of greater

than or equal to 250 HP and less than or equal to 500 HP located at a major source) must meet

the requirements of either 40 CFR Part 60 Subpart IIII (for CI engines) or 40 CFR Part 60

Subpart JJJJ (for SI engines). Owners and operators of new or reconstructed 4SLB engines with

a site rating of greater than or equal to 250 HP and less than or equal to 500 HP located at a

major source are subject to the same MACT standards previously established for 4SLB engines

above 500 HP at a major source, and must also meet the requirements of 40 CFR Part 60 Subpart

JJJJ, except for the emissions standards for CO. The fire pump engine (FP-1) is subject to NSPS

Subpart IIII and is required to comply only with that regulation.

On March 3, 2010, EPA finalized additional requirements for stationary CI RICE located at area

sources. A summary of these requirements for the emergency generator engine and the existing

fire pump engine (FP-2) located at this facility are shown below.

Engine Category Normal Operation @ 15% O2

Existing Emergency CI & Black Start

CI

Change oil and filter every 500 hours of operation

or annually, whichever one comes first;

Inspect air cleaner every 1,000 hours of operation

or annually, whichever one comes first; and

Inspect all hoses and belts every 500 hours of

operation or annually, whichever one comes first

and replace as necessary.

Sources have the option to utilize an oil analysis program in order to extend the specified oil

change requirements of this subpart. Initial compliance demonstrations must be conducted

within 180 days after the compliance date. Owners and operators of a non-operational engine

can conduct the performance test when the engine is started up again.


Other applicable requirements include:

1) The owner/operator must operate and maintain the stationary RICE and after-treatment

control device (if any) according to the manufacturer’s emission-related written instructions

or develop their own maintenance plan which must provide to the extent practicable for the

maintenance and operation of the engine in a manner consistent with good air pollution

control practice for minimizing emissions.

2) Existing emergency stationary RICE located at an area source of HAP emissions must

install a non-resettable hour meter if one is not already installed.

On August 20, 2010, EPA finalized the requirements for stationary SI RICE located at area

sources. There are no standards applicable to existing 4SLB emergency engines located at an

area source of HAPs.

Subpart JJJJJJ for Industrial, Commercial, and Institutional Boilers Area at area sources of

HAPs. The boilers at this facility burn natural gas. Subpart JJJJJJ does not affect gas-fired

boilers.

Compliance Assurance Monitoring, 40 CFR Part 64 [Applicable]

Compliance Assurance Monitoring, as published in the Federal Register on October 22, 1997,

applies to any pollutant specific emission unit at a major source, that is required to obtain a Title

V permit, if it meets all the following criteria:

It is subject to an emission limit or standard for an applicable regulated air pollutant.

It uses a control device to achieve compliance with the applicable emission limit or

standard.

It has potential emissions, prior to the control device, of the applicable regulated air

pollutant of 100 TPY.

Requirements for CAM have been incorporated into the permit for the various RTOs and the

ESP.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

This facility does not store any regulated substance above the applicable threshold limits. More

information on this federal program is available at the web site: http://www.epa.gov/rmp/.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subparts A and F are Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential

products containing ozone-depleting substances (Subparts A & C); control servicing of motor

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require warning labels on products made with or

containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon

disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons

(Subpart H).

http://www.epa.gov/rmp/


Subpart A identifies ozone-depleting substances and divides them into two classes. Class I

controlled substances are divided into seven groups; the chemicals typically used by the

manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform

(Class I, Group V). A complete phase-out of production of Class I substances is required by

January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are

hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.

Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,

scheduled in phases starting by 2002, is required by January 1, 2030.

Subpart F requires that any persons servicing, maintaining, or repairing appliances except for

motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air

conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and

recycling and recovery equipment comply with the standards for recycling and emissions

reduction.

The standard conditions of the permit address the requirements specified at §82.156 for persons

opening appliances for maintenance, service, repair, or disposal; §82.158 for equipment used

during the maintenance, service, repair, or disposal of appliances; §82.161 for certification by an

approved technician certification program of persons performing maintenance, service, repair, or

disposal of appliances; §82.166 for recordkeeping; § 82.158 for leak repair requirements; and

§82.166 for refrigerant purchase records for appliances normally containing 50 or more pounds

of refrigerant.

SECTION VIII. COMPLIANCE

Performance Testing

Stack testing was conducted on the three RTOs on January 16-18, 2018. Results of the testing are

listed following. All RTOs were shown to be in compliance with applicable VOC emissions

limits.

Unit VOC Emissions, lb/hr

Permit Limit Test Result

Small Reeco 5.90 1.03

Calendar Process 4.50 0.73

Large Reeco 4.72 3.60

Tier Classification and Public Review

This application has been determined to be Tier II based on being the request for a renewal of a

major source operating permit.

The applicant published the “Notice of Filing a Tier II Application” on September 1, 2017, in the

Stillwater News-Press, a daily newspaper in Payne County. The notice stated that the application

was available for review at the Stillwater Public Library, 1107 S. Duck Street. The draft permit

will also be made available for public review by another published announcement in the

Stillwater News-Press. The “proposed” permit will bes submitted to EPA for a 45-day review

period.


The facility is not located within 50 miles of the Oklahoma border.

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any

operation upon land owned by others without their knowledge. The affidavit certifies that the

applicant owns the property.

Information on all permit actions is available for review by the public in the Air Quality section

of the DEQ Web page:http://www.deq.state.ok.us.

Fees Paid

Part 70 permit renewal fee of $7,500.

SECTION IX. SUMMARY

The facility was constructed as described in the permit application. There is no currently active

Air Quality Compliance / Enforcement issue for the facility. Issuance of the operating permit is

recommended, contingent on public and EPA review.

PART 70 PERMIT AIR QUALITY DIVISION

STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit Number: 2017-1358-TVR3

Armstrong Flooring Stillwater Plant,

having complied with the requirements of the law, is hereby granted permission to operate

a vinyl flooring manufacturing plant at 4115 N. Perkins Road, Stillwater, Payne County,

Oklahoma subject to standard conditions dated June 21, 2016, and specific conditions, both

attached.

This permit shall expire five (5) years from the issuance date, except as authorized under

Section VIII of the Standard Conditions.

_________________________________

Division Director, Air Quality Division Date

DEQ Form #100-890 Revised 10/20/06

Armstrong Flooring

Attn: Mr. Brian Speizer

4115 N. Perkins Road

Stillwater, OK 74075

SUBJECT: Permit No. 2017-1358-TVR3

Vinyl Flooring Manufacturing Plant (FAC ID 119)

Stillwater, Payne County, Oklahoma

Dear Mr. Speizer:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this

permit is issued subject to standard and specific conditions, which are attached. These conditions

must be carefully followed since they define the limits of the permit and will be confirmed by

periodic inspections.

Also note that you are required to annually submit an emissions inventory for this facility. An

emissions inventory must be completed on approved AQD forms and submitted (hardcopy or

electronically) by April 1st of every year. Any questions concerning the form or submittal

process should be referred to the Emissions Inventory Staff at (405) 702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact our

office at (405)702-4198.

Sincerely,

David Schutz, P.E.

New Source Permit Section

AIR QUALITY DIVISION

Enclosures

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Armstrong Flooring Stillwater Plant Permit No. 2017-1358-TVR3

Stillwater Flooring Manufacturing Plant

The permittee is authorized to operate in conformity with the specifications submitted to Air

Quality on August 11, 2017. The Evaluation Memorandum dated March 15, 2018, explains the

derivation of applicable permit requirements and estimates of emissions; however, it does not

contain limitations or permit requirements. Continuing operations under this permit constitutes

acceptance of, and consent to the conditions contained herein:

1. Applicable Emissions Limitations for the Facility: [OAC 252:100-8-6(a)]

EUG 1A: Gel and Printing Lines

Point

ID Emission Unit

NOx CO VOC SO2 PM10


LR


Red Label Area

Printing Presses

10.73 43.92 12.37 55.51 4.72 20.66 0.011 0.046 0.134 0.587



Fug Gel and Printing Lines

Uncaptured VOC -- -- -- -- 3.83 16.75 -- -- -- --

Fug Red Label Uncaptured VOC -- -- -- -- 2.91 12.74 -- -- -- --

A. Except during up to 20 start-up/shutdown events per year, not to exceed 15 minutes per

event, all stack discharges from the Gel Line and Printing Operations shall be vented to a

thermal oxidizer or equivalent air pollution control device (95% or greater VOC emission

control efficiency or 20 ppm or less VOC). The Reeco regenerative thermal oxidizer

“LR” shall be operated at a temperature of at least 1,500oF when processing emissions

from the Gel Line and Printing Operations.

B. A “start-up/shutdown” event shall include any time when the “LR” is operated below

1,500oF while the associated process operations are discharging VOC to the unit. The

permittee shall keep records of the duration, cause, and magnitude of emissions during

start-up/shutdown events.

C. The operating temperature of “LR” shall be continuously (at least once every 15 minutes

of operation) recorded during operations.

SPECIFIC CONDITIONS PERMIT 2017-1358-TVR3 2

DRAFT

D. Uncaptured emissions from the Gel Line, Red Label Area, and Printing Operation shall

be calculated as at least 1.8% of the volatile organic materials handled.

E. Total solvent usage for the Printing Operation (including cleaning solvents) shall not

exceed a net usage of 1.98 million pounds per year (12-month rolling total). Solvents

recovered (i.e., excess cleaning solvents) may be subtracted from the usage totals.

F. Annual throughput of the Gel Line shall not exceed 94.7 million square yards of flooring

per year (12-month rolling total).


Point

ID Emission Unit

NOx CO VOC SO2 PM10


CP

Calendar Process, Clear

Coat HOD, Reeco

regenerative thermal

oxidizer, and DUO2

pneumatic raw materials

receiving system

3.47 15.21 4.61 20.21 4.50 19.63 0.53 2.30 2.36 10.35

Emissions During Start-

up/ Shutdown/Malfunction -- -- 92.2 0.23 90.0 0.23 -- -- 12.0 0.03

A. Except during start-up/shutdown events, not to exceed 20 events per year or 15 minutes

per event, all VOC-handling operations in the Calendar Process shall be conducted in

total enclosures with all air discharges vented to a thermal oxidizer or equivalent air

pollution control device (95% or greater VOC emission control efficiency or 20 ppm or

less VOC). The “CP” regenerative thermal oxidizer shall be operated at a temperature of

at least 1,500oF when processing emissions from the Calendar Process.

B. A “start-up/shutdown” event shall include any time when the “CP” is operated below

1,500oF while the associated process operations are discharging VOC to the unit. The



C. The operating temperature of “CP” shall be continuously recorded (at least once every 15

minutes of operation) during operations.

D. Annual throughput of the Calendar Process shall not exceed 94.7 million square yards per

year, 12-month rolling total.


DRAFT


Emission

Unit ID

Emission


PM10 Emissions

lb/hr TPY

1C-#1-4 #1-4d DUO1 Raw Materials Handling 6.857 30.034


BS14E 0.112 0.491

1C-#1-7 #1-7g Outside WestPVC Silo BS16B 0.035 0.153

1C-#1-8 #1-8h Resin & Minor Ingredients PT03 0.057 0.250

1C-#1-9 #1-9i Limestone Receiver PT02 0.120 0.525

1C-#1-10 #1-10j Mix Receiver PT04 0.279 1.224

1C-#1-11 #1-11k Scrap return pneumatic system 0.057 0.250

A. All discharges from the above units shall be processed by fabric filters (baghouses) prior

to discharge. The filters shall achieve 0.04 gr/DSCF or less particulate matter emissions.

B. The filters shall be operated at a pressure differential in accordance with manufacturer

specifications. The operating pressure shall be monitored and recorded at least once

during each day when the units are operated.

EUG 2: Coating & Fusion Line

Point

ID Emission Unit

NOx CO VOC SO2 PM10


SH Coating & Fusion Cooling -- -- -- -- 6.17 27.04 -- -- 1.600 7.000

SR



Saturation Dryer

6.60 28.91 3.17 13.88 5.90 25.81 0.58 2.52 4.946 7.647



A. Except during start-up/shutdown events, not to exceed 20 events per year or 15 minutes

per event, all stack discharges from the drying section of the Coating and Fusion Line

shall be vented to a thermal oxidizer or equivalent air pollution control device (95% or

greater VOC emission control efficiency or 20 ppm or less VOC).

B. The thermal oxidizer shall be operated at a temperature of at least 1,500oF when

processing emissions from the printing ovens.

C. The operating temperature of the thermal oxidizer shall be continuously recorded (at least

once every 15 minutes of operation) during operations.


DRAFT

D. Except during start-up/shutdown/malfunction events, not to exceed 20 events per year or

15 minutes per event, all stack discharges from the Curing Section of the Coating and

Fusion Line shall be vented to an electrostatic precipitator or equivalent air pollution

control device (90% or greater PM emission control efficiency). The “Smog Hog” shall

be operated at a minimum voltage per manufacturer specifications as shown in Specific

Condition No. 10.

E. Annual throughput of the Coating & Fusion Line shall not exceed 105 million square

yards of flooring per year (12-month rolling total).

F. The permittee shall conduct daily Method 9 or Method 22 visual observations of the

“Smog Hog” exhausts for at least 12 minutes and keep a record of these observations. If

visible emissions are detected, then the permittee shall conduct a thirty-minute opacity

reading in accordance with EPA Reference Method No. 9.

i. When four consecutive daily visible emission observations or Method 9 six-minute

average show no visible emissions, or no emissions of a shade or density greater than

twenty (20) percent equivalent opacity, respectively, the frequency may be reduced to

weekly visual observations, as above. Upon any showing of non-compliance the

observation frequency shall revert to daily.

ii. If a Method 9 six-minute average exceeds 20% opacity the permittee shall conduct

at least two additional Method 9 observations within the next 24-hours.

iii. If more than one six-minute Method 9 average exceeds 20% opacity in any

consecutive 60 minutes; or more than three six-minute Method 9 observations in any

consecutive 24 hours exceeds 20% opacity; or if any six-minute Method 9

observation exceeds 60% opacity; the owner or operator shall comply with the

provisions for excess emissions during start-up, shut-down, and malfunction of air

pollution control equipment. [OAC 252:100-25]

G. A “start-up/shutdown” event shall include any time when the “SR” is operated below

1,500oF while the associated process operations are discharging VOC to the unit or when

the “SH” is operated below manufacturer recommended voltages while the Curing

Section of the Coating and Fusion Line is being operated and generating emissions. The




DRAFT


Point

ID Emission Unit

NOx CO VOC SO2 PM10


B-1 Cyclo-Therm boiler 1.465 6.417 1.231 5.390 0.081 0.353 0.009 0.039 0.111 0.488


Point

ID Emission Unit

NOx CO VOC SO2 PM10


B-2 Holman boiler 1.040 4.555 0.874 3.826 0.057 0.251 0.006 0.027 0.079 0.346

A. The permittee shall keep daily records of fuels used in the Holman Boiler, or the

permittee may follow the alternate fuel recording procedures of 40 CFR Part 60.48c(g)(2)

or (3). [40 CFR 60.48c(g)]

EUG 3C: Small Fuel-Burning Equipment: The following equipment items are insignificant

since criteria pollutant emissions are less than 5 TPY.

Emission

Unit ID

Emission

Point ID EU Name/Model Capacity

3C-#4-7 #4-7g Make-up air heater for Calendar 5 MMBTUH

3C-#4-8 OH-1 Gel Line heater 4 MMBTUH

3C-#4-9 OH-2 Calendar hot oil heater 4 MMBTUH

3C-#4-10 #4-11k Gas-fired space heaters 83 heaters, 0.3 MMBTUH each


Emission

Unit ID

Emission


3C-#4-12 FP-2 John Deere fire pump 150 HP

3C-#4-13 EG-1 Kohler LSG8751 generator 210 HP (gas)

3C-#4-14 EG-2 Kohler 4.3L 45RZG generator 75 HP (gas)

3C-#4-15 EG-3 Kohler 4.3L 45RZG generator 75 HP (gas)

3C-#4-16 EG-4 Cummins GGHG generator 113 HP (gas)

A. The diesel fire pumps shall be fueled only with No. 2 diesel with a sulfur content of 0.5%

by weight or less sulfur. [OAC 252:100-31]

B. As of the compliance date of Subpart ZZZZ, the owner/operator shall comply with all

applicable requirements of the NESHAP: Reciprocating Internal Combustion Engines,

Subpart ZZZZ, for each affected facility including but not limited to:

[40 CFR 63.6580 through 63.6675]


DRAFT

1. § 63.6580 What is the purpose of subpart ZZZZ?

2. § 63.6585 Am I subject to this subpart?

3. § 63.6590 What parts of my plant does this subpart cover?

4. § 63.6595 When do I have to comply with this subpart?

5. § 63.6603 What emission limitations and operating limitations must I meet if I

own or operate an existing stationary RICE located at an area source of HAP

emissions?

6. § 63.6605 What are my general requirements for complying with this subpart?

7. § 63.6625 What are my monitoring, installation, operation, and maintenance

requirements?

8. § 63.6630 How do I demonstrate initial compliance with the emission

limitations and operating limitations?

9. § 63.6640 How do I demonstrate continuous compliance with the emission

limitations and operating limitations?

10. § 63.6650 What reports must I submit and when?

11. § 63.6655 What records must I keep?

12. § 63.6660 In what form and how long must I keep my records?

13. § 63.6665 What parts of the General Provisions apply to me?

14. § 63.6670 Who implements and enforces this subpart?

15. § 63.6675 What definitions apply to this subpart?


Emission

Unit ID

Emission


FP-1 FP-1 John Deere diesel fire pump 150-hp

A. The permittee shall comply with all applicable requirements of 40 CFR Part 60, Subpart

IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion

Engines and shall comply with all applicable requirements including but not limited to

the following:

1. § 60.4200 Am I subject to this subpart?

2. § 60.4201 What emission standards must I meet for non-emergency engines if I am

a stationary CI internal combustion engine manufacturer?

3. § 60.4202 What emission standards must I meet for emergency engines if I am a

stationary CI internal combustion engine manufacturer?

4. § 60.4203 How long must my engines meet the emission standards if I am a

stationary CI internal combustion engine manufacturer?

5. § 60.4204 What emission standards must I meet for non-emergency engines if I am

an owner or operator of a stationary CI internal combustion engine?

6. § 60.4206 How long must I meet the emission standards if I am an owner or

operator of a stationary CI internal combustion engine?

7. § 60.4207 What fuel requirements must I meet if I am an owner or operator of a

stationary CI internal combustion engine subject to this subpart?

8. § 60.4209 What are the monitoring requirements if I am an owner or operator of a

stationary CI internal combustion engine?


DRAFT

9. § 60.4210 What are my compliance requirements if I am a stationary CI internal

combustion engine manufacturer?

10. § 60.4211 What are my compliance requirements if I am an owner or operator of a

stationary CI internal combustion engine?

11. § 60.4212 What test methods and other procedures must I use if I am an owner or

operator of a stationary CI internal combustion engine with a displacement of less

than 30 liters per cylinder?

12. §60.4214 What are my notification, reporting, and recordkeeping requirements if I

am an owner or operator of a stationary CI internal combustion engine?

13. § 60.4217 What emission standards must I meet if I am an owner or operator of a

stationary internal combustion engine using special fuels?

14. § 60.4218 What parts of the General Provisions apply to me?

15. § 60.4219 What definitions apply to this subpart?

EUG 4A: Small Storage Tanks: The following equipment items are insignificant since criteria

pollutant emissions are less than 5 TPY.

Emission Unit

ID

Emission Point

ID EU Name/Model Capacity, Gallons

4A-B1 B1 Plasticizer 8,000






4A-A1 A1 Stabilizer 250

4A-A2 A2 Plastisol 250

4A-A3 A3 Stabilizer 250

4A-A4 A4 Plasticizer 250

4A-A5 A5 Plasticizer 500

4A-A6 A6 Process aid 250

4A-A7 A7 Plasticizer 1,000

4A-A8 A8 Stabilizer 1,500

4A-A9 A9 Plastisol 250

4A-#2-1 TK-1 Solvent 5,000

4A-#2-2 TK-2 Solvent 5,000

4A-B8 B-8 Biocide 8,000

4B-#1-5 TK-7 Plasticizer 12,000


DRAFT

EUG 5: Scrap Handling and Cutting Operations The following equipment items are

insignificant since criteria pollutant emissions are less than 5 TPY.

Emission

Unit ID

Emission


Construction

Date

5-#1-11 #1-11k Pneumatic scrap return 10 million

pounds/year 1999

5-#3-2 #3-2b Hoffman blower HB-T2B07 10 million

pounds/year 1987

5-#3-3 #3-3 Scrap granulator 10 million

pounds/year 2005

5-#3-4 #3-3 Saw cutting 10 million

lbs/year 2017

A. All air discharges from pneumatic scrap handling systems shall be processed by fabric

filters and cyclonic separators or other particulate matter control device with 0.006

gr/dscf or less particulate matter emissions from the scrap handling operations.

EUG 6: Raw Material Handling Operations The following equipment items are insignificant

since criteria pollutant emissions are less than 5 TPY.

Emission

Unit ID

Emission


6-#1-12 #1-12 l Inside limestone silo 100,000 lbs

6-#1-13 #1-13 m Inside PVC silo 25,000 lbs

6-#1-14 #1-14 n PVC silo 25,000 lbs

6-#1-15 #1-15 o PVC silo 25,000 lbs

6-#1-16 #1-16 p PVC silo 25,000 lbs

6-#1-17 #1-17 q PVC silo 25,000 lbs

6-#1-18 #1-18 r PVC silo 25,000 lbs

6-#1-19 #1-19 s PVC silo 25,000 lbs

6-#1-20 #1-20 t PVC silo 25,000 lbs

6-#1-21 #1-21 u PVC silo 25,000 lbs

6-#1-22 #1-22 v PVC silo 25,000 lbs

6-#1-23 #1-23 w PVC silo 25,000 lbs

6-#1-24 #1-24 x PVC silo 25,000 lbs

Surge Surge Gel surge tank (in-process weighing) 25,000 lbs

Receiver Receiver C&F surge tank (in-process weighing) 25,000 lbs

6-#1-25 #1-25 y Limestone silo 250,000 lbs


DRAFT

2. The facility is subject to 40 CFR Part 63, Subpart KK, as an Area Source. Total emissions

of Hazardous Air Pollutants (HAPs) shall not exceed 25 TPY of all HAPs or 10 TPY or

any one HAP. The facility shall keep monthly records showing emissions of Title III

hazardous air pollutants. [40 CFR Part 63.820(a)(3) and 63.829(d)]

3. The permittee shall be authorized to operate the facility continuously (24 hours per day,

every day of the year). [OAC 252:100-8-6(a)]

4. Except for the stationary diesel-powered engines, all fuel-burning equipment shall be

fueled with commercial-grade natural gas. Diesel powered engines shall be fueled with

No. 2 diesel with a sulfur content of 0.5% or less. Compliance can be shown by the

following methods: for pipeline grade natural gas, a current gas company bill; for other

gaseous fuel, a current lab analysis, gas contract, tariff sheet, etc. Compliance shall be

demonstrated at least once annually. [OAC 252:100-31]

5. The following records shall be maintained on-site. All such records shall be made

available to regulatory personnel upon request. These records shall be maintained for a

period of at least five years after the time they are made. [OAC 252:100-43]

A. Amount of inks, cleaning solvents, and plasticizers used (monthly and 12-month

rolling averages).

B. Chemical composition of each ink, cleaning solvent, and plasticizer (e.g., a Material

Safety Data Sheet).

C. Operating temperature of each thermal oxidizer (at least every 15 minutes when

operating).

D. Flooring production, square yards (monthly and 12-month rolling totals).

E. Usage of volatile organic materials in Finish Coater.

F. Throughput (million square yards per year) of the Calendar Process and Coating &

Fusion Lines.

G. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition

No. 4.

H. CAM records as required by Specific Condition No. 9.

I. Fuel usage records as required by 40 CFR Part 60.48c(g).

J. Records of each start-up/shutdown/malfunction event: duration and cause (e.g., “loss

of electrical power from utility”).

K. Records as required by NESHAP Subpart ZZZZ.


DRAFT

L. Records as required by NSPS Subpart IIII.

6. The following records shall be maintained on-site to verify Insignificant Activities. All

such records shall be made available to regulatory personnel upon request. These records

shall be maintained for a period of at least five years after the time they are made.

[OAC 252:100-8-6(a)]

A. Tanks 10,000 gallons or smaller capacity: records of capacity and vapor pressures of

contents.

7. No later than 30 days after each anniversary date of the issuance of the initial Title V

operating permit (January 29, 2003), the permittee shall submit to Air Quality Division of

DEQ, with a copy to the US EPA, Region 6, a certification of compliance with the terms

and conditions of this permit. [OAC 252:100-8-6 (c)(5)(a)&(d)]

8. The Permit Shield (Standard Conditions, Section VI) is extended to the following

requirements that have been determined to be inapplicable to this facility.

[OAC 252:100-8-6(d)(2)]

A. OAC 252:100-11 Alternative Emissions Reduction

B. OAC 252:100-15 Mobile Sources

C. OAC 252:100-23 Cotton Gins

D. OAC 252:100-24 Grain Elevators

E. OAC 252:100-33 Nitrogen Oxides

F. OAC 252:100-35 Carbon Monoxide

G. OAC 252:100-47 Landfills


DRAFT

9. Compliance Assurance Monitoring requirements and specifications: [40 CFR Part 64]

Thermal Oxidizers “Smog Hog” ESP

Indicator Operating temperature Voltage across unit

Measurement Approach Temperature shall be monitored

using a Type K thermocouple or

equivalent

High voltage tester or

equivalent

Indicator Range An excursion is defined as a 1-

hour average temperature below

1,500oF. Excursions trigger an

inspection, corrective actions,

and a reporting requirement.

SH cells and ionizers, in

horizontal groups of three (A-C-

E and B-D-F) must have at least

2 of the 3 be operated at a

voltage of at least 2.1 V and 2.5

V, respectively

Data Representativeness

Performance Criteria

The thermocouple monitors the

thermal oxidizer operating

temperature downstream

combustion zone of the thermal

oxidizer.

Voltage signal is read for each

cell and ionizer while in

operation

QA/QC Practices and

Criteria

Accuracy + 3%; annual

calibration or replacement of

thermocouples

Voltage testing performed on

unit at least annually

Monitoring Frequency temperature is monitored at

least once every 15 minutes

Voltage of unit is monitored

and recorded at least every 15

minutes of operation

Data Collection Procedure Data are recorded by computer Data are recorded by computer

Averaging Period 1-hour 1-hour

10. Upon issuance, Permit No. 2017-1358-TVR3 replaces and supersedes Permit No. 2012-831-

TVR (M-2), which will be cancelled.

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(June 21, 2016)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal

Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement

action, permit termination, revocation and reissuance, or modification, or for denial of a permit

renewal application. All terms and conditions are enforceable by the DEQ, by the Environmental

Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act

(excluding state-only requirements). This permit is valid for operations only at the specific

location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)

MAJOR SOURCE STANDARD CONDITIONS June 21, 2016 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,

the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the time of sampling or measurement.

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

original Part 70 operating permit or alternative date as specifically identified in a subsequent Part

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this

permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,

Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this

permit shall be certified by a responsible official. This certification shall be signed by a

responsible official, and shall contain the following language: “I certify, based on information

and belief formed after reasonable inquiry, the statements and information in the document are

true, accurate, and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]


G. Any owner or operator subject to the provisions of New Source Performance Standards

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least

five years as required by Paragraph A of this Section, and shall include records of the occurrence

and duration of any start-up, shutdown, or malfunction in the operation of an affected facility,

any malfunction of the air pollution control equipment; and any periods during which a

continuous monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit

to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods

approved by the Division Director. All tests shall be made and the results calculated in

accordance with standard test procedures. The use of alternative test procedures must be

approved by EPA. When a portable analyzer is used to measure emissions it shall be setup,

calibrated, and operated in accordance with the manufacturer’s instructions and in accordance

with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document

or an equivalent method approved by Air Quality.

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing

or calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]


SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a

certification of compliance with the terms and conditions of this permit and of any other

applicable requirements which have become effective since the issuance of this permit.

[OAC 252:100-8-6(c)(5)(A), and (D)]

B. The compliance certification shall describe the operating permit term or condition that is the

basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting

authority may require to determine the compliance status of the source.

[OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official, and

shall contain the following language: “I certify, based on information and belief formed after

reasonable inquiry, the statements and information in the document are true, accurate, and

complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall

resemble and be at least as stringent as that contained in any judicial consent decree or

administrative order to which the emissions unit or stationary source is subject. Any such

schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the

applicable requirements on which it is based, except that a compliance plan shall not be required

for any noncompliance condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8-6(c)(6)]


SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]

SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees

based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date

of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely

and complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified

operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]


SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon

which the equipment is located and does not release the permittee from any liability for damage

to persons or property caused by or resulting from the maintenance or operation of the equipment

for which the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the

DEQ may request to determine whether cause exists for modifying, reopening, revoking,

reissuing, terminating the permit or to determine compliance with the permit. Upon request, the

permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such

and shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and

shall be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.

Except as provided for minor permit modifications, the filing of a request by the permittee for a

permit modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such

reopening is required if the effective date of the requirement is later than the expiration

date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke


and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,”

as defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the

permittee shall allow authorized regulatory officials to perform the following (subject to the

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(17)

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, or

operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of the

exceedance, any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]


B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to exceed a

technology-based emission limitation under this permit, due to unavoidable increases in

emissions attributable to the emergency. An emergency shall not include noncompliance to the

extent caused by improperly designed equipment, lack of preventive maintenance, careless or

improper operation, or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]

(1) an emergency occurred and the permittee can identify the cause or causes of the

emergency;

(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop

and register with the appropriate agency a risk management plan by June 20, 1999, or the

applicable effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

if it meets the criteria below or is included on the insignificant activities list.


(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year

for single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

requirement applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the

permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the

DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,

and any permit term or condition that is no longer applicable as a result of the change. The

permit shield provided by this permit does not apply to any change made pursuant to this

paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility

unless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]


(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure to

meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or

greater under actual conditions shall be equipped with a permanent submerged fill pipe or

with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and


(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions

reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is

not inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if

the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

will be incorporated into the Title V permit through the administrative amendment

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.


(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by DEQ

as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

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