Reproduction of Permit Terms and Conditions

Transcription

1 Page 1 of 92 This version of facility specific terms and conditions was converted from a database format to an HTML file during an upgrade of the Ohio EPA, Division of Air Pollution Control's permitting software. Every attempt has been made to convert the terms and conditions to look and substantively conform to the permit issued or being drafted in STARS. However, the format of the terms may vary slightly from the original. In addition, although it is not expected, there is a slight possibility that a term and condition may have been inadvertently "left out" of this reproduction during the conversion process. Therefore, if this version is to be used as a starting point in drafting a new version of a permit, it is imperative that the entire set of terms and conditions be reviewed to ensure they substantively mimic the issued permit. The official version of any permit issued final by Ohio EPA is kept in the Agency's Legal section. The Legal section may be contacted at (614) In addition to the terms and conditions, hyperlinks have been inserted into the document so you may more readily access the section of the document you wish to review. Finally, the term language under "Part III" and before "I. Applicable Emissions Limitations..." has been added to aid in document conversion, and was not part of the original issued permit. Part II - Specific Facility Terms and Conditions a State and Federally Enforceable Section 1. The following insignificant emissions unit is located at this facility: Z001 - gas drying oven for painted plastic parts (PTI No ). This insignificant emissions unit must comply with all applicable State and federal regulations, as well as any emission limitations and/or control requirements contained within the identified permit to install for the emissions unit. The insignificant emissions unit listed above that is not subject to specific permit to install requirements is subject to one or more applicable requirements contained in the SIP-approved versions of OAC Chapters , , and [Authority for term: OAC rule (A)(13)] MACT REQUIREMENTS 2. The following emissions units located at this facility are subject to 40 CFR Part 63, Subpart WWWW-- National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composites Production: P001 - Old SMC Machine; P002 - SMC Paste Mixing Operations; P004 - New SMC Machine; P005 - BMC Mixer No. 2; P006 - BMC Mixer No.3; P007 - SMC Paste Mixing; P009 - Thermoset Compression Mold Press No. 2; P010 - Thermoset Compression Mold Press No. 5; P011 - Thermoset Compression Mold Press No. 11; P012 - Thermoset Compression Mold Press No. 14; P013 - Thermoset Compression Mold Press No. 23; P014 - Thermoset Compression Mold Press No. 38; P015 - Thermoset Compression Mold Press No. 39; P016 - Thermoset Compression Mold Press No. 40; P017 - Thermoset Compression Mold Press No. 41; P018 - Thermoset Compression Mold Press No. 42; P019 - Thermoset Compression Mold Press No. 43; P020 - Thermoset Compression Mold Press No. 44; P021 - Thermoset Compression Mold Press No. 45; P022 - Thermoset Compression Mold Press No. 47; P023 - Thermoset Compression Mold Press No. 48; P024 - Thermoset Compression Mold Press No. 49; P025 - Thermoset Compression Mold Press No. 50; P026 - Thermoset Compression Mold Press No. 51; P027 - Thermoset Compression Mold Press No. 52; P028 - Thermoset Compression Mold Press No. 53; P029 - Thermoset Compression Mold Press No. 54; T001-3,333-gallon Polyester Resin Storage Tank; and T002-3,333-gallon Polyester Resin Storage Tank. [Authority for term: 40 CFR and Table 2 of 40 CFR Part 63, Subpart WWWW] CFR Part 63, Subpart A - General Provisions Applicability to 40 CFR Part 63, Subpart WWWW The permittee is subject to the following requirements specified in 40 CFR Part 63, Subpart A as listed in Table 15 of 40 CFR Part 63, Subpart WWWW: Parts 63.1 (a)(1)-(4), 63.1(a)(6), 63.1 (a)(10)-(14), 63.1(b)(1), 63.1 (b)(3), 63.1 (c)(1) and (2), 63.1 (c)(5), 63.1 (e), 63.2, 63.3, 63.4, 63.5 (a)(1) and (2), 63.5(b)(1), 63.5(b)(3) and (4), 63.5 (b)(6), 63.5 (d)(1) and (2), 63.5 (d)(4), 63.5 (e)(1) - (5), 63.5 (f)(1) and (2), 63.6 (a)(1) and (2), 63.6 (b)(1)-(5), 63.6 (b)(7), 63.6 (c)(1) and (2), 63.6 (c)(5), 63.6 (e)(1) - (3), 63.6 (f)(2) and (3), 63.6 (g)(1) - (3), 63.6 (i)(1)-(14), 63.6 (i)(16), 63.6 (j), 63.7 (a) (1), 63.7 (a)(3), 63.7 (b)(1) and (2), 63.7 (c), 63.7 (d), 63.7(e), 63.7 (f), 63.7 (g), 63.7 (h), 63.8 (a)(1) and (2),

2 Page 2 of (a)(4), 63.8 (b)(1) - (3), 63.8 (c)(1) - (4), 63.8 (c)(6) - (8), 63.8 (d), 63.8 (e)(1) - (4), 63.8 (e)(5)(i), 63.8 (f)(1) - (6), 63.8 (g)(1) - (5), 63.9 (a)(1)-(4), 63.9 (b)(1) and (2), 63.9 (b)(4)(i), 63.9 (b)(4)(v), 63.9 (b)(5), 63.9(c), 63.9 (d), 63.9 (e), 63.9 (g)(1), 63.9 (g)(3), 63.9 (h)(1) - (3), 63.9 (h)(5) and (6), 63.9 (i), 63.9(j), (a), (b)(1), (b)(2)(i) - (xiv), (b)(3), (c)(1), (c)(5) - (8), (c)(10) - (15), (d)(1) and (2), (d)(4) and (5), (e)(1) - (3), (f), 63.11, 63.12, 63.13, 63.14, and The following emissions units are subject to the aforementioned requirements: P001, P002, P004, P005, P006, P007, P009, P010, P011, P012, P013, P014, P015, P016, P017, P018, P019, P020, P021, P022, P023, P024, P025, P026, P027, P028, P029, T001 and T The permittee shall comply with the work practice standard to not use cleaning solvents that contain HAP, except that styrene may be used as a cleaner in closed systems, and organic HAP containing cleaners may be used to clean cured resin from application equipment. Application equipment includes any equipment that directly contacts resin. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 5. The permittee shall comply with the work practice standard to keep containers that store HAP-containing materials closed or covered except during the addition or removal of materials. Bulk HAP-containing materials storage tanks may be vented as necessary for safety. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] MONITORING AND RECORD KEEPING 6. The permittee must maintain a copy of the following records. a. The permittee must maintain a copy of each notification and report submitted to comply with Subpart WWWW of 40 CFR Part 63, including all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted. b. The permittee must maintain a certified statement of compliance with the work practice requirements in Table 4 to Subpart WWWW of 40 CFR Part 63. [Authority for term: 40 CFR ] 7. All applicable records must be maintained in such a manner that they can be readily accessed and are suitable for inspection according to 40 CFR 63.10(b)(1). The permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The permittee must keep each record onsite for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record. The records may be kept offsite for the remaining 3 years. Records may be kept in hard copy or computer readable form including, but not limited to, paper, microfilm, computer floppy disk, magnetic tape, or microfiche. [Authority for term: 40 CFR ] 8. a. The permittee shall maintain records which identify each HAP in each cleaning solvent employed. If any cleaning solvent contains styrene, the specific application shall also be documented. b. The permittee shall maintain records which document any time containers that store HAP containing materials were not kept closed or covered except during the addition or removal of materials. The records shall indicate how long the containers were not properly closed or covered and any actions taken to prevent a reoccurrence. [Authority for term: 40 CFR , 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] REPORTS AND NOTIFICATIONS 9. The permittee submitted an Initial Notification containing the information specified in 40 CFR 63.9 (b)(4) and (5) on August 11, If there is a change in any information submitted in the Initial Notification, the permittee must submit the changes in writing to the Administrator within 15 calendar days after the change. [Authority for term: 40 CFR (b)] 10. The permittee must submit semiannual compliance reports. a. The first compliance report must cover the period beginning on April 21, 2006, and ending on December 31, The first compliance report must be postmarked or delivered no later than January 31, b. Each subsequent compliance report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. Each semiannual compliance report shall be postmarked or delivered no later than January 31 and July 31, whichever date is the first date following the end of the semiannual reporting period. [Authority for term: 40 CFR ] 11. Each semiannual compliance report must contain the following information. a. The company name and address. b. A statement by a responsible official with that official's name, title and signature, certifying the truth, accuracy and completeness of the content of the report. c. The date of the report and the beginning and ending dates of the reporting period.

3 Page 3 of 92 d. If there are no deviations from any organic HAP emission limit and from any work practice standards in this subpart, a statement that there were no deviations from the organic HAP emissions limitations or work practice standards during the reporting period. e. For each deviation from any organic HAP emission limit and for each deviation from the requirements for work practice standards, the compliance report must contain the total operating time of each emissions unit during the reporting period and information on the number, duration, and cause of deviations (including unknown cause, if applicable), and the corrective action taken; and [Authority for term: 40 CFR ] 12. Each affected source that has obtained a Title V operating permit pursuant to 40 CFR Part 70 or 71 must report all deviations as defined in 40 CFR Part 63, Subpart WWWW in the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). If an affected source submits a compliance report pursuant to Table 14 of 40 CFR Part 63, Subpart WWWW or pursuant to 40 CFR Subpart PPPP along with, or as part of, the semiannual monitoring report required by 40 CFR Part 70.6(a)(3)(iii)(A) or 40 CFR Part 71.6(a)(3)(iii)(A), and the compliance report includes all required information concerning deviations from any organic HAP emissions limitation (including any operating limit) or work practice requirement in 40 CFR Part 63, Subpart WWWW, submission of the compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. However, submission of a compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permitting authority. [Authority for term: 40 CFR Part (g)] 13. If there is a change in any information submitted in any notification, the change must be submitted in writing to the Administrator within 15 calendar days after the change. [Authority for term: 40 CFR (b)] COMPLIANCE AND TESTING 14. Initial Compliance Demonstration a. For the work practice standard that the permittee not use cleaning solvents that contain HAP, the permittee has demonstrated initial compliance if a certified statement is included in the notice of compliance status that all cleaning materials, except styrene contained in closed systems, or materials used to clean cured resin from application equipment contain no HAP. b. For the work practice standard the permittee keep containers that store HAP-containing materials closed or covered, the permittee has demonstrated initial compliance if a certified statement is included in the notice of compliance status that all HAP-containing storage containers are kept closed or covered except when adding or removing materials, and that any bulk storage tanks are vented only as necessary for safety. [Authority for term: 40 CFR (a) and Table 9 of 40 CFR Part 63, Subpart WWWW] 15. Beginning on April 19, 2007, the following emissions unit located at this facility is subject to 40 CFR Part 63, Subpart PPPP-- National Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface Coating of Plastic Parts and Products: R001 - spray painting fiberglass reinforced plastic parts. [Authority for term: 40 CFR and OAC rule (A)(3)] CFR Part 63, Subpart A - General Provisions Applicability to 40 CFR Part 63, Subpart PPPP Beginning on April 19, 2007, the permittee is subject to the following requirements specified in 40 CFR Part 63, Subpart A as listed in Table 2 of 40 CFR Part 63, Subpart PPPP: Parts 63.1 (a)(1) - (14), 63.1(b)(1) - (3), 63.1 (c)(1), 63.1 (c)(4) - (5), 63.1 (e), 63.2, 63.3 (a) - (c), 63.4 (a)(1) - (5), 63.4 (b) - (c), 63.5 (a), 63.5(b)(1) - (6), 63.5 (d), 63.5 (e), 63.5 (f), 63.6 (a), 63.6 (b)(1) - (7), 63.6 (c)(1) - (5), 63.6 (e)(1) - (2), 63.6(e)(3), 63.6 (f)(1), 63.6 (f)(2) - (3), 63.6 (g)(1) - (3), 63.6 (i)(1) - (16), 63.6 (j), 63.7 (a) (1), 63.7(a)(2), 63.7 (a)(3), 63.7 (b) - (e), 63.7 (f), 63.7 (g) - (h), 63.8 (a)(1) - (3), 63.8 (b), 63.8 (c)(1) - (3), 63.8 (c)(7), 63.8 (f)(1) - (5), 63.9 (a) - (d), 63.9 (e), 63.9 (h), 63.9 (i), 63.9 (j), (a), (b)(1), (b) (2)(i) - (v), (b)(2)(vi) - (xi), (b)(2)(xii), (b)(2)(xiv), (b)(3), (c)(1) - (6), (c)(9) - (15), (d)(1), (d)(2), (d)(4), (d)(5), (e)(4), (f), 63.12, 63.13, 63.14, and The following emissions unit is subject to the aforementioned requirements: R001. MONITORING AND RECORD KEEPING 17. Beginning April 19, 2007, the permittee shall maintain a current copy of information provided by materials suppliers or manufacturers, such as manufactures's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the mass fraction of coating solids for each coating. If testing was conducted to determine mass faction of organic HAP, density or mass fraction or coatings solids, a copy of the complete test report shall be maintained. If information provided by the manufacturer or supplier of the material that was based on testing was used, a the summary sheet of results provided by the manufacturer or supplier must be maintained. The test report or other supporting documentation from the manufacturer or suppler is not required to be obtained. [Authority for term: 40 CFR (b)]

4 Page 4 of Beginning April 19, 2007, the permittee shall maintain a copy of the following information. a. A record of the name and mass of each coating, thinner and/or additive, and cleaning material used during each compliance period. b. If an allowance was claimed for recycling and/or reuse the following information must be kept: i. the name and address of each TSDF to which waste materials were sent; ii. iii. iv. the date of each shipment; identification of each emissions unit producing waste materials included in each shipment and the month or months in which the allowance for these materials was used in Equation 1 of Attachment A; and the methodology used to determine the total amount of waste materials sent to or the amount collected, stored and designated for transport to a TSDF each month and the methodology used to determine the mass of organic HAP contained in these waste materials. This must include the sources for all data used in the determination, methods used to generate the data frequency of testing or monitoring and supporting calculations and documentation, including the waste manifest for each shipment c. A record of the date, time and duration of each deviation must be maintained. d. The permittee must maintain a copy of each notification and report submitted to comply with subpart PPPP, including all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted. [Authority for term: 40 CFR ] 19. a. Records must be maintained in a form suitable and readily available for expeditious review, according to 40 CFR 63.10(b)(1). Where appropriate, the records may be maintained as electronic spreadsheets or as a database. b. As specified in 40CFR 63.10(b)(1), each record must be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or record. c. Each record must be kept on-site for at least 2 years after the date of occurrence, measurement, maintenance, corrective action, report or record according to 40 CFR 63.10(b)(1). Records may be kept offsite for the remaining 3 years. [Authority for term: 40 CFR ] REPORTS AND NOTIFICATIONS 20. The permittee submitted an Initial Notification containing the information specified in 40 CFR 63.9 (b)(4) and (5) on August 22, If there is a change in any information submitted in the Initial Notification, the permittee must submit the changes in writing to the Administrator within 15 calendar days after the change. [Authority for term: 40 CFR 63.9(b) and 40 CFR ] 21. The permittee shall submit an initial notification of compliance status for Subpart PPPP. The report shall cover the period beginning on April 30, 2007, and ending on April 30, This report must be postmarked or delivered no later than May 30, 2008, and shall containing the following information: a. company name and address; b. statement by a responsible official certifying the truth, accuracy, and completeness of the content of the report (officials name, title, and signature); c. the date of the report and beginning and ending dates of the initial compliance reporting period; d. identification of compliance option(s) for each emissions unit (i.e., emission rate without add-on controls option) during the initial compliance period; e. statement of whether the affected source achieved the emission limitations for the initial compliance period; and f. if there was a deviation during the initial compliance period, a description of the deviation and statement of the cause and all calculations used to determine the lb organic HAP emitted per lb coating solids used. g. For each of the items listed in 21.g.i - iv below, include an example of how the value was determined, including calculations and supporting data. Supporting data may include a copy of the information provided by the supplier or manufacturer of the example coating or material, or a summary of the results of testing conducted according to (a)(b) or (c). Copies of test results do not need to be submitted. i. mass fraction of organic HAP for one coating, one thinner or additive, and one cleanup/purge material; ii. iii. iv. the mass fraction of coating solids for one coating; density for one coating, one thinner or additive, and one cleanup/purge material; the amount of waste materials and mass of organic HAP contained in the waste materials for which a recovery credit is applied; h. the calculation of lb organic HAP emitted per lb coating solids used. Provide the calculation of the total mass of organic HAP emissions for each month, the calculation of the total mass of coatings solids used each month; and the calculation of the 12-month organic HAP emission rate using

5 Page 5 of 92 equations 1 and 1A in Attachment A. [Authority for term: 40 CFR ] 22. The permittee must submit a compliance report semiannually. The first compliance report for Subpart PPPP must cover the period beginning on January 1, 2008, and ending on June 30, Each subsequent semiannual compliance report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. The first semiannual compliance report must be postmarked or delivered no later than July 31, Each subsequent semiannual compliance report shall be postmarked or delivered no later than January 31 and July 13 thereafter. [Authority for term: 40 CFR and OAC rule (A)(3)] 23. Each semiannual compliance report must contain the following information: a. the company name and address; b. a statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; c. the date of the report and the beginning and ending dates of the reporting period; d. identification that the compliance option used during the reporting period was the emission rate without add-on control equipment option; e. the calculation results for each rolling, 12-month organic HAP emission rate during the 6-month reporting period; f. if there were no deviations from the emission limitations, the report must include a statement that there were no deviations from the emission limitation during the reporting period; and g. if there were deviation(s) from the emission limitation, the report must include the beginning and ending dates of each compliance period during which the 12-month organic HAP emission rate exceeded the applicable limitation and the calculations used to determine each such 12-month organic HAP emission rate. The calculations for Equations 1, 1A, 1B, 1C, 2 and 3 from Attachment A must be submitted, and if applicable, the calculation used to determine mass of organic HAP in waste materials. [Authority for term: 40 CFR ] 24. Each affected source that has obtained a Title V operating permit pursuant to 40 CFR Part 70 or 71 must report all deviations as defined in 40 CFR 63, Subpart PPPP in the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). If an affected source submits a compliance report pursuant to 40 CFR Subpart PPPP along with, or as part of, the semiannual monitoring report required by 40 CFR Part 70.6(a)(3)(iii)(A) or 40 CFR Part 71.6(a)(3)(iii)(A), and the compliance report includes all required information concerning deviations from any organic HAP emissions limitation (including any operating limit), submission of the compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. However, submission of a compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permitting authority. [Authority for term: 40 CFR (a)(2)] 25. If there is a change in any information submitted in any notification, the change must be submitted in writing to the Administrator within 15 calendar days after the change. [Authority for term: 40 CFR (b)] COMPLIANCE AND TESTING 26. The initial compliance demonstration for 40 CFR Part 63, Subpart PPPP must be completed for the initial compliance period according to the requirements of 40 CFR The initial compliance period begins on April 30, 2007, and ends April 30, Determine the mass of organic HAP emissions and mass of coating solids used each month and then calculate an organic HAP emission rate at the end of the initial compliance period. The initial compliance demonstration includes the calculations according to 40 CFR and supporting documentation showing that during the initial compliance period the organic HAP emission rate was equal to or less than the applicable emission limit of 0.16 lb organic HAP per lb coating solids. [Authority for term: 40 CFR ] b State Only Enforceable Section 1. The following insignificant emissions units located at this facility are exempt from permit requirements because they are not subject to any applicable requirements (as defined in OAC rule (H)) or because they meet the "de minimis" criteria established in OAC rule : T001 - tank No. 1, a 3333-gallon capacity above ground storage tank for polyester resin; and T002 - tank No. 2, a 3333-gallon capacity above ground storage tank for polyester resin.

6 Page 6 of 92 Go to Part III for Emissions Unit P001 Go to Part III for Emissions Unit P002 Go to Part III for Emissions Unit P004 Go to Part III for Emissions Unit P005 Go to Part III for Emissions Unit P006 Go to Part III for Emissions Unit P007 Go to Part III for Emissions Unit P009 Go to Part III for Emissions Unit P010 Go to Part III for Emissions Unit P011 Go to Part III for Emissions Unit P012 Go to Part III for Emissions Unit P013 Go to Part III for Emissions Unit P014 Go to Part III for Emissions Unit P015 Go to Part III for Emissions Unit P016 Go to Part III for Emissions Unit P017 Go to Part III for Emissions Unit P018 Go to Part III for Emissions Unit P019 Go to Part III for Emissions Unit P020 Go to Part III for Emissions Unit P021 Go to Part III for Emissions Unit P022 Go to Part III for Emissions Unit P023 Go to Part III for Emissions Unit P024 Go to Part III for Emissions Unit P025 Go to Part III for Emissions Unit P026 Go to Part III for Emissions Unit P027 Go to Part III for Emissions Unit P028 Go to Part III for Emissions Unit P029 Go to Part III for Emissions Unit R001 Part III - Terms and Conditions for Emissions Units Facility ID: Emissions Unit ID: P001 Issuance type: Title V Proposed Permit A. State and Federally Enforceable Section Emissions unit P001 is the old sheet mold compound (SMC) machine. SMC paste and chopped fiber glass roving are cast onto a continuous nylon carrier film and are then covered by a nylon film for later use in the FRP molding presses. OAC rule (A)(3) (PTI , effective October 16, 1986) The Best Available Technology determination was compliance with the requirements of OAC rule (G)(2). OAC rule (G)(2) Emissions of organic compounds (OC) shall not exceed 8 pounds per hour and 40 pounds per day, excluding non-photochemically reactive cleanup materials. 40 CFR Part 63, Subpart WWWW See sections A.I.2.a and A.I.2.b below. See Part II, sections A.2 through A.14.

7 Page 7 of 92 a. The permittee shall close or cover the resin delivery system to the doctor box. The doctor box itself may be open. (a) [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] b. The permittee shall use a nylon containing film to enclose SMC. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 1. The permittee shall collect and record the following information each day: a. the company identification of each SMC paste employed; b. the weight, in pounds, of each SMC paste employed; c. the OC content, in percent by weight, of each SMC paste employed; d. the OC emissions for each SMC paste employed, calculated as (b) x (c) x the emission factor of 0.347% of the OC, derived from emission testing conducted on emissions unit P004 on 09/18/2006; e. the total daily OC emissions, in pounds, calculated by summing the emissions from (d) for each SMC paste employed; f. the hours SMC paste was employed; and g. the OC emissions, in average pounds per hour, calculated as (e)/(f). Should this emissions unit be tested in the future, the emission factor determined from the emissions testing of this SMC machine shall be used to calculate the emissions. [Authority for term: OAC rule (C)(1)] 2. The permittee shall conduct daily inspections of this emissions unit and maintain a log of these inspections. The log shall indicate the compliance status of each work practice standard identified in sections A.I.2.a and A.I.2.b and shall contain the following information: a. whether the emissions unit was in operation; b. whether the resin delivery system to the doctor box was closed or covered; and c. whether a nylon containing film was employed to enclose the SMC. [Authority for term: OAC rule (C)(1)] 3. The records specified in section A.III.2 shall also include information on the duration and cause of each deviation and the corrective action taken. These records shall be maintained as specified in Part II, section A.6. [Authority for term: OAC rule (C)(1), 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 1. The permittee shall submit quarterly deviation (excursion) reports that include an identification of each day during which the average OC emissions exceeded 8 pounds per hour, and the actual OC emissions for each such hour. [Authority for term: OAC rule (C)(1)] 2. The permittee shall submit quarterly deviation (excursion) reports that include an identification of each day during which the OC emissions exceeded 40 pounds, and the actual OC emissions for each such day. [Authority for term: OAC rule (C)(1)] 3. The deviation reports required pursuant to the record keeping specified in sections A.III.2 and A.III.3 shall be submitted in accordance with the requirements specified in Part II. [Authority for term: OAC rule (C)(1) and 40 CFR (g)]

8 Page 8 of Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in accordance with the following methods: a. Emission Limitation: Emissions of OC shall not exceed 8 pounds per hour. Compliance shall be demonstrated based upon the record keeping requirements specified in section A.III.1.g. b. Emission Limitation: Emissions of OC shall not exceed 40 pounds per day. Compliance shall be demonstrated based upon the record keeping requirements specified in section A.III.1.e. [Authority for term: OAC rule (C)(1)] 2. The permittee must demonstrate initial compliance with the work practice standard to close or cover the resin delivery system to the doctor box. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that resin delivery system is closed or covered. [Authority for term: OAC rule (C)(1), 40 CFR (a) and Table 9 of 40 CFR Part 63, Subpart WWWW] 3. The permittee must demonstrate initial compliance with the work practice standard to use a nylon containing film to enclose the SMC. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that that a nylon-containing film is used to enclose the SMC. [Authority for term: OAC rule (C)(1), 40 CFR (a) and Table 9 of 40 CFR Part 63, Subpart WWWW] Facility ID: Emissions Unit ID: P001 Issuance type: Title V Proposed Permit B. State Enforceable Section

9 Page 9 of 92 Part III - Terms and Conditions for Emissions Units Facility ID: Emissions Unit ID: P002 Issuance type: Title V Proposed Permit A. State and Federally Enforceable Section Emissions unit P002 is a sheet molding compound (SMC) paste and bulk molding compound (BMC) mixing operation, including 2 Hockmeyer and 1 Cowles mixers for portable batch tanks. OAC rule (A)(3) (PTI , effective October 16, 1986) OAC rule (G)(2) The Best Available Technology determination was compliance with the requirements of OAC rule (G)(2). This emissions unit is exempt from the requirements of OAC rule (G)(2). See section A.I.2.d below. 40 CFR Part 63, Subpart WWWW See sections A.I.2.a, A.I.2.b and A.I.2.c below. a. The permittee shall employ mixer covers with no visible gaps present in the mixer covers, except that

10 Page 10 of 92 gaps of up to 1 inch are permissible around mixer shafts and any required instrumentation. (a) [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] b. The permittee shall keep the mixer covers closed while mixing except when adding materials or changing covers to the mixing vessels. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] c. The permittee shall close any mixer vents when mixing, except that venting is allowed during addition of materials, or as necessary prior to adding materials or opening the cover for safety. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] d. This emissions unit shall be employed only for the mixing of raw materials, where no chemical reactions occur between any of the raw materials. 1. The permittee shall conduct daily inspections of this emissions unit and maintain a log of these inspections. The log shall include the compliance status of the work practice standards identified in sections A.I.2.a, A.I.2.b and A.2.c and shall contain the following information: a. whether the emissions unit was in operation; b. whether the mixer cover was employed each time a mixer was in operation, except when adding materials or changing covers to the mixing vessels; c. whether there was a visible gap present in the mixer cover, except that gaps of up to 1 inch are permissible around mixer shafts and any required instrumentation when the mixer cover was properly employed; and d. whether the mixer vent was closed each time a mixer was in operation, except that venting is allowed during addition of materials, or as necessary prior to adding materials or opening the cover for safety. [Authority for term: OAC rule (C)(1)] 2. The records specified in section A.III.1 shall also include information on the duration and cause of each deviation and the corrective action taken. These records shall be maintained as specified in Part II, section A.6. [Authority for term: OAC rule (C)(1), 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 1. The deviation reports required pursuant to the record keeping requirements specified in sections A.III.1 and A.III.2 shall be submitted in accordance with the requirements specified in Part II. [Authority for term: OAC rule (C)(1) and 40 CFR (g)] 1. The permittee must demonstrate initial compliance with the work practice standard to use mixer covers. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that mixer covers are closed during mixing except when adding materials to the mixers, and that gaps around mixer shafts and required instrumentation do not exceed 1 inch. [Authority for term: OAC rule (C)(1), 40 CFR (a) and Table 9 of 40 CFR Part 63, Subpart WWWW] 2. The permittee must demonstrate initial compliance with the requirement to not actively vent mixers to the atmosphere while the mixing agitator is turning. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that mixers are not actively vented to the

11 Page 11 of 92 atmosphere when the agitator is turning, except when adding materials or as necessary for safety. [Authority for term: OAC rule (C)(1), 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 3. The permittee must demonstrate initial compliance with the requirement to keep the mixer covers closed during mixing except when adding materials to the mixing vessels. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that the mixer covers are kept closed except when adding materials to the mixing vessels. [Authority for term: OAC rule (C)(1), 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] Facility ID: Emissions Unit ID: P002 Issuance type: Title V Proposed Permit B. State Enforceable Section

12 Page 12 of 92 Part III - Terms and Conditions for Emissions Units Facility ID: Emissions Unit ID: P004 Issuance type: Title V Proposed Permit A. State and Federally Enforceable Section Emissions unit P004 is the new sheet molding compound (SMC) machine. SMC paste and chopped fiber glass roving are cast onto a continuous nylon carrier film and are then covered by a nylon film for later use in the FRP molding presses. OAC rule (A)(3) (PTI , effective October 16, 1986) The Best Available Technology determination was compliance with the requirements of OAC rule (G)(2). OAC rule (G)(2) Emissions of organic compounds (OC) shall not exceed 8 pounds per hour and 40 pounds per day, excluding non-photochemically reactive cleanup materials. 40 CFR Part 63, Subpart WWWW See sections A.I.2.a and A.I.2.b below. See Part II, sections A.2 through A.14. a. The permittee shall close or cover the resin delivery system to the doctor box. The doctor box itself may be open. (a) [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] b. The permittee shall use a nylon containing film to enclose SMC. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 1. The permittee shall collect and record the following information each day: a. the company identification of each SMC paste employed; b. the weight, in pounds, of each SMC paste employed;

13 Page 13 of 92 c. the OC content, in percent by weight, of each SMC paste employed; d. the OC emissions for each SMC paste employed, calculated as (b) x (c) x the emission factor of 0.347% of the OC, derived from emission testing conducted on this emissions unit on 09/18/2006; e. the total daily OC emissions, in pounds, calculated by summing the emissions from (d) for each SMC paste employed; f. the hours SMC paste was employed; and g. the OC emissions, in average pounds per hour, calculated as (e)/(f). [Authority for term: OAC rule (C)(1)] 2. The permittee shall conduct daily inspections of this emissions unit and maintain a log of these inspections. The log shall indicate the compliance status of each work practice standard identified in sections A.I.2.a and A.I.2.b and shall contain the following information: a. whether the emissions unit was in operation; b. whether the resin delivery system to the doctor box was closed or covered; and c. whether a nylon containing film was employed to enclose the SMC. [Authority for term: OAC rule (C)(1)] 3. The records specified in section A.III.2 shall also include information on the duration and cause of each deviation and the corrective action taken. These records shall be maintained as specified in Part II, section A.6. [Authority for term: OAC rule (C)(1), 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 1. The permittee shall submit quarterly deviation (excursion) reports that include an identification of each day during which the average OC emissions exceeded 8 pounds per hour, and the actual OC emissions for each such hour. [Authority for term: OAC rule (C)(1)] 2. The permittee shall submit quarterly deviation (excursion) reports that include an identification of each day during which the OC emissions exceeded 40 pounds, and the actual OC emissions for each such day. [Authority for term: OAC rule (C)(1)] 3. The deviation reports pursuant to the record keeping specified in sections A.III.2 and A.III.3 shall be submitted in accordance with the requirements specified in Part II. [Authority for term: OAC rule (C)(1) and 40 CFR (g)] 1. Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in accordance with the following methods: a. Emission Limitation: Emissions of OC shall not exceed 8 pounds per hour. Compliance shall be demonstrated based upon the record keeping requirements specified in section A.III.1.g. b. Emission Limitation: Emissions of OC shall not exceed 40 pounds per day. Compliance shall be demonstrated based upon the record keeping requirements specified in section A.III.1.e. [Authority for term: OAC rule (C)(1)] 2. The permittee must demonstrate initial compliance with the work practice standard to close or cover the resin

14 Page 14 of 92 delivery system to the doctor box. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that resin delivery system is closed or covered. [Authority for term: OAC rule (C)(1), 40 CFR (a) and Table 9 of 40 CFR Part 63, Subpart WWWW] 3. The permittee must demonstrate initial compliance with the work practice standard to use a nylon containing film to enclose the SMC. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that that a nylon-containing film is used to enclose the SMC. [Authority for term: OAC rule (C)(1), 40 CFR (a) and Table 9 of 40 CFR Part 63, Subpart WWWW] Facility ID: Emissions Unit ID: P004 Issuance type: Title V Proposed Permit B. State Enforceable Section

15 Page 15 of 92 Part III - Terms and Conditions for Emissions Units Facility ID: Emissions Unit ID: P005 Issuance type: Title V Proposed Permit A. State and Federally Enforceable Section Emissions unit P005 is a bulk molding compound (BMC) mixer. OAC rule (A)(3) (PTI effective 06/02/2005) OAC rule (G)(2) Organic compound (OC) emissions shall not exceed 8 pounds per hour, 32 pounds per day and 5.84 tons per year, including cleanup. This emissions unit is exempt from the requirements of OAC rule (G)(2). See section A.I.2.d below. 40 CFR Part 63, Subpart WWWW See sections A.I.2.a, A.I.2.b and A.I.2.c below. a. This emissions unit shall employ mixer covers with no visible gaps present in the mixer covers, except that gaps of up to 1 inch are permissible around mixer shafts and any required instrumentation. (a) [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] b. The permittee shall keep the mixer covers closed while mixing except when adding materials or changing covers to the mixing vessels. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] c. The permittee shall close any mixer vent when mixing, except that venting is allowed during addition of materials, or as necessary prior to adding materials or opening the cover for safety. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] d. This emissions unit shall be employed only for the mixing of raw materials, where no chemical reactions occur between any of the raw materials.

16 Page 16 of Pursuant to OAC rule (A)(3)(a)(ii), the following monitoring and record keeping requirements are as stringent as or more stringent than the monitoring and record keeping requirements contained in Permit to Install # , issued on June 2, 1995: A.III.2. The monitoring and record keeping requirements contained in the above-referenced Permit to Install are subsumed into the monitoring and record keeping requirements of this operating permit, so that compliance with these requirements constitutes compliance with the underlying monitoring and record keeping requirements in the Permit to Install. 2. The permittee shall collect and record the following information each day for the BMC mixing operation: a. the company identification of each mold compound and each cleanup material employed; b. the weight of each mold compound employed, in pounds per day; c. the OC content of each mold compound, in percent by weight; d. the volume of each cleanup material employed, in gallons; e. the OC content of each cleanup material, in pounds per gallon; f. the volume of each waste cleanup material collected for reuse or disposal in gallons; g. the volume of each evaporated cleanup material, which is calculated by subtracting the volume of waste cleanup material employed from the volume of cleanup material reused or disposed of, in gallons; h. the number of hours the emissions unit was operated; i. the OC emissions from cleanup in pounds per day, calculated as A.III.2.g x A.III.2.e; j. the OC emissions from each mold compound in pounds per day, calculated as specified below; E = WT x OC x EF where: E = OC emissions, in pounds per day; WT = total weight of each material employed in the mixer as recorded in section A.III.2.b; OC = OC content of each material mixed, in percent by weight; and EF = emission factor of 0.25%. (The emission factor of 0.25% of available HAP is taken from Table 5-2 "Average HAP Emission Equations by Process" in US EPA's document "Hazardous Air Pollutant Emissions from the Production of Reinforced Plastic Composites Background Information Document for Proposed Standards".) Formulation data or USEPA Method 24 shall be used to determine the OC contents of the BMC materials. k. the total OC emissions from all mold compounds in pounds per day, calculated by summing the emissions determined in section A.III.2.j for each mold compound used; l. the total OC emissions from the use of mold compound and cleanup in pounds per day, calculated by summing the emissions calculated in sections A.III.2.i and A.III.2.k; m. the average hourly OC emissions, calculated by dividing the emissions determined in section A.III.2.l by the hours of operation as recorded in section A.III.2.h; and n. the tons OC per year emitted from the mixing operation, calculated by summing the daily emissions in section A.III.2.l for the year and multiplying by 1 ton / 2000 pounds. The calculations required in sections A.III.2.a through A.III.2.n shall be completed no later than 10 calendar days following the end of each month, except the cleanup emissions shall be calculated no later than 10 calendar days following receipt of the recycle/recovery information. [Authority for term: OAC rule (C)(1) and PTI ] 3. The permittee shall conduct a daily inspection of this emissions unit and maintain a log of these inspections. The log shall include the compliance status of each work practice standard identified in sections A.I.2.a, A.I.2.b and A.I.2.c and shall contain the following information: a. whether the emissions unit was in operation; b. whether the mixer cover was employed, except when adding materials or changing covers to the mixing vessels; c. whether there was a visible gap present in the mixer cover, except that gaps of up to 1 inch are permissible around mixer shafts and any required instrumentation; and d. whether the mixer vent was open, except that venting is allowed during addition of materials, or as necessary prior to adding materials or opening the cover for safety. [Authority for term: 40 CFR and Table 4 of 40 CFR Part 63, Subpart WWWW] 4. The records specified in section A.III.3 shall also include information on the duration and cause of each deviation and the corrective action taken. These records shall be maintained as specified in Part II, section A.6. [Authority for term: OAC rule (C)(1)]

17 Page 17 of Pursuant to OAC rule (A)(3)(a)(ii), the following reporting requirements are as stringent as or more stringent than the reporting requirements contained in Permit to Install # , issued on June 2, 1995: A.IV.2. The reporting requirements contained in the above-referenced Permit to Install are subsumed into the reporting requirements of this operating permit, so that compliance with these requirements constitutes compliance with the underlying reporting requirements in the Permit to Install. 2. The permittee shall submit quarterly deviation (excursion) reports that include the following information: a. an identification of each day during which the average hourly OC emissions exceeded 8 pounds per hour, and the actual hourly OC emissions for each such day; and b. an identification of each day during which the OC emissions exceeded 32 pounds per day, and the actual OC emissions for each such day. The quarterly deviation (excursion) reports shall be submitted in accordance with the General Terms and Conditions of this permit. [Authority for term: OAC rule (C)(1)] 3. The record keeping requirements specified in sections A.III.3 and A.III.4 shall be submitted in accordance with the requirements specified in Part II. [Authority for term: 40 CFR (g)] 1. Pursuant to OAC rule (A)(3)(a)(ii), the following testing requirements are as stringent as or more stringent than the testing requirements contained in Permit to Install # , issued on June 2, 1995: A.V.2. The testing requirements contained in the above-referenced Permit to Install are subsumed into the testing requirements of this operating permit, so that compliance with these requirements constitutes compliance with the underlying testing requirements in the Permit to Install. 2. Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in accordance with the following methods: a. Emission Limitation: OC emissions shall not exceed 8 pounds per hour, including cleanup. Compliance shall be demonstrated based upon the record keeping requirements specified in section A.III.2.m. b. Emission Limitation: OC emissions shall not exceed 32 pounds per day, including cleanup. Compliance shall be demonstrated based upon the record keeping requirements specified in section A.III.2.l. c. Emission Limitation: OC emissions shall not exceed 5.84 tons per year, including cleanup. Compliance shall be demonstrated based upon the record keeping requirements specified in section A.III.2.n. [Authority for term: OAC rule (C)(1)] 3. The permittee must demonstrate initial compliance with the work practice standard to use mixer covers. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that mixer covers are closed during mixing except when adding materials to the mixers, and that gaps around mixer shafts and required instrumentation do not exceed 1 inch. [Authority for term: OAC rule (C)(1), 40 CFR (a) and Table 9 of 40 CFR Part 63, Subpart WWWW] 4. The permittee must demonstrate initial compliance with the requirement to not actively vent mixers to the atmosphere while the mixing agitator is turning. Initial compliance has been demonstrated if the permittee submits a certified statement in the notice of compliance status that mixers are not actively vented to the atmosphere when the agitator is turning, except when adding materials or as necessary for safety.