DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
October 31, 2006
TO:
Dawson Lasseter, P.E., Chief Engineer, Permits Section
THROUGH:
Rhonda Jeffries, Environmental Programs Manager
THROUGH:
Kendall Stegman, Supervising Attorney
THROUGH:
Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits Section
THROUGH:
Peer Review, Herb Neumann, ROAT
THROUGH:
Peer Review, Hal Wright, ROAT
FROM:
David Pollard, P.E., ROAT
SUBJECT:
Evaluation of Permit Application No. 2006-226-O
G & H Decoys (G&H)
Duck Decoy Manufacturing Co.
Henryetta, OK (Lat. 35. 450º N; Long. -95.968º W)
Driving directions to facility: located on the west side of US Hwy 75 one
mile north of downtown Henryetta.
I.
INTRODUCTION
G&H Decoys (applicant) submitted a Title V renewal application dated August 24, 2006, and
received on August 31, 2006, for their duck decoy manufacturing facility (SIC Code 3089;
NAICS code 326199). The facility has been in operation since 1934 and was grandfathered until
issuance of Permit No. 2000-028-TV on August 23, 2001. The facility is currently operating
under Permit No. 2000-028-TV, issued on May 14, 2002, to modify the permitted coating and
thinner list. The applicant has requested that this permit be issued with an enforceable limit as a
synthetic minor source to avoid applicability of NESHAP Subpart PPPP and also the exemption
from coating limits allowed by OAC 252:100-37-25(c) for sources emitting no more than 100
pounds per day of volatile organic compounds (VOC).
II.
EQUIPMENT/PROCESS DESCRIPTION
The facility manufacturers decoys using two types of plastic material in their processes, High
Density Polyethylene (HDPE) and Acrylonitrile Butadiene Styrene (ABS) Plastics. The mixture
for each process is 50% regrind and 50% virgin material. The excess mold and scrap decoy parts
PERMIT MEMORANDUM # 2006-226-O
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2
are sent to the Grinder Room. This process consists of grinding up the material into small pieces
that are re-used in the molding process.
There are three processes used for molding. The description of each molding method follows.
1. Blow Molding Process: There are eight electrically powered blow-molding machines,
including one out-of-service. This process consists of blowing air into the mold and then
pressing the plastic out to form the molded part. This process uses only HDPE material.
2. Injection Molding Process: There are two electrically powered injection-molding machines,
including one out-of-service. This process consists of forcing the material into the mold by
pneumatic pressure to form the molded part. This process uses ABS Plastic material only.
3. Vacuum Forming Process: There are five electrically powered vacuum forming machines.
This process consists of using heat to pre-heat the mold and HDPE sheets of plastic. The
sheet of material is drawn into the machine and sucked down by air to form the molded part.
This process uses only HDPE plastic sheets.
The various mold parts are then taken to the Flame Treat Process. This process uses propane
torches to physically treat the plastic so that paint will adhere to the various decoy parts. There
is also a gas-fired oven for heating plastic sheets for the vacuum forming process. There was no
rating on the unit, but it appeared to be small, and the company stated in a fax that the oven will
not be operational past 2006. After that the plastic sheets will be electrically heated on an
existing machine.
All the various decoy parts are then taken to one of three Basecoat coating booths for application
of the base coat. These booths are a three-sided enclosure, the front open for entry and
placement of the object to be coated. The booths have dimensions of 8 feet wide x 4 feet deep x
7 feet tall. There is also a larger, fully enclosed booth that is out-of-service. Once the base coat
has been applied, the decoy parts are taken to one of the 30 Detail Coating Booths used for detail
and finish coating. Only six of these are in use and five are new but never completed for service.
The finish coat booths are either 4 or 5 feet wide x 4 feet deep x 7 feet tall. All coating booths
are vented outside the building through a 2-foot diameter pipe extending through the roof at a
discharge rate of 5,000 acfm. The vent ducts are 2 feet above the roofline, 22 feet above grade.
Once the decoy parts have dried, they are then taken to the Packing Department. This
department puts the various decoy parts together (this is a mechanical joining, not by gluing) to
form ducks or geese. Once the packing is complete, they are sent to the Shipping Department to
be delivered to the customers.
All coating wastes generated from cleaning of the spray guns and rags are collected in 55-gallon
drums and are stored in Warehouse 4 area for proper shipment and disposal.
PERMIT MEMORANDUM # 2006-226-O
III.
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3
EMISSIONS
The facility has three air emission points; plastic grinding, propane combustion, and decoy
coating. VOC and particulate matter (PM) emitted during the coating processes are the
emissions of concern. Some of the VOC are hazardous air pollutants (HAP). PM generated
from grinding, and combustion emissions are insignificant.
Coatings are applied using high-volume low-pressure spray guns for better coating efficiency.
Each paint booth is fitted with dry type disposal filters (one on each booth). The decoy grinding
area is located inside the facility and uses a process similar to a totally enclosed abrasive blasting
booth. There are two 250-gallon propane bullet type storage tanks which have no emissions.
VOC Emissions
No calculations were submitted in the application for this renewal permit. The facility uses
coatings having VOC content in excess of the Subchapter 37 limits and therefore requests the
100 lb/day exemption, which equates to 18.25 tons per year (TPY) if the facility operated 365
days per year. Based on 2,080 hours of operation (two-hundred sixty 8-hour days) for the year
2005, emissions would be 13 TPY.
The following table illustrates the analysis of VOC emissions presented for the applicant’s
existing permit. Since some thinners are also used as solvents/cleaners, there is some duplication
in the calculated emissions. Although the numbers in the table are more representative of
previously projected actual emissions, it also illustrates how easily the facility could approach
emissions at major source levels, even with a limited number of the coating booths in operation.
This permit will limit HAP emissions to less than 10 TPY per single HAP and no more than
18.25 TPY of combined HAP.
Chemical
Name
Xylene
Methyl Propyl Ketone
Toluene
VM&P
Ethyl Acetate
Ethanol
4-hydroxy-4-methyl 4-pentan-2-one
Naphtha
2-Butoxyethanol
Methyl Ethyl Ketone
Primary Amyl Acetate
Isopropyl Alcohol
Methyl Isobutyl Ketone
1-Methoxy 2-propyl Acetate
Total HAP
Total VOC
CAS No.
HAP
1330207
107879
108883
64742898
141786
64175
123422
64742887
111762
78933
628637
67630
108101
108656
Y
N
Y
N
N
N
N
N
Y
N
N
N
Y
N
EMISSIONS
PPH
TPY
1.47
3.63
3.98
9.80
6.51
7.34
0.85
1.95
0.80
1.86
0.28
0.63
0.80
0.40
0.54
0.27
0.24
0.12
6.72
11.28
0.13
0.01
1.24
0.12
3.63
6.12
0.69
0.13
17.21
43.66
PERMIT MEMORANDUM # 2006-226-O
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4
The facility continues to use acrylic and lacquer coatings as already permitted, but because
restrictions on coating brand and type are no longer necessary with the replacement of Part 5 of
Subchapter 41, this memorandum does not reference coating categories or quantities.
PM Emissions
The molding processes at the facility consumed 208,000 pounds of new HDPE during the
previous year. The molding processes use a 50/50 blend of new HDPE and recycled HDPE.
Borrowing an emission factor of 0.0013 lbs/lb used to estimate emissions from a plastic film
process in another permit, AQD made the following calculation for particulate matter.
2
x 208,000 lbs resin
year
x
0.0013 lbs PM
lb resin
x
1 ton
2,000 lbs
= 0.27 tons
The applicant estimated PM emissions from the coating process of 122.65 pounds per year based
on 4,056 gallons of coating used during the year 2005 having an average solids content of 5.305
pounds/gallon and a filter efficiency of 99.43%.
IV.
FEDERAL REGULATIONS
PSD, 40 CFR Part 52
[Not Applicable]
PSD does not apply. Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the 28 specific industries with an emission threshold
of 100 TPY.
NSPS, 40 CFR Part 60
[Not Applicable]
There are no affected facilities or sources at this site covered under any subpart.
NESHAP, 40 CFR Part 61
[Not Applicable]
There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium,
coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of
benzene.
NESHAP, 40 CFR Part 63
[Not Applicable]
Subpart MMMM, “National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Surface Coating of Miscellaneous Metal Parts and Products,” establishes emission standards for
miscellaneous metal parts and products surface coating facilities and requirements to
demonstrate initial and continuous compliance with the emission limitations. This subpart
applies to new, reconstructed, or existing affected sources, as defined in §63.3882, that use 946
liters (250 gallons) per year, or more, of coatings that contain hazardous air pollutants (HAP) in
the surface coating of miscellaneous metal parts and products and that is a major source, is
located at a major source, or is part of a major source of emissions of HAP. Miscellaneous metal
parts and products include, but are not limited to, metal components of the following types of
products as well as the products themselves: motor vehicle parts and accessories, bicycles and
sporting goods, recreational vehicles, extruded aluminum structural components, railroad cars,
PERMIT MEMORANDUM # 2006-226-O
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5
heavy duty trucks, medical equipment, lawn and garden equipment, electronic equipment,
magnet wire, steel drums, industrial machinery, metal pipes, and numerous other industrial,
household, and consumer products. The facility does not meet the applicability criteria and is
therefore not subject to this subpart.
Subpart PPPP, “National Emission Standards for Hazardous Air Pollutants for Surface Coating
of Plastic Parts and Products,” establishes emission standards for new, reconstructed, or existing
plastic parts and products surface coating facilities that use 100 gallons per year or more of
coatings that contain hazardous air pollutants (HAP) and that are a major source of HAP. Area
sources are not subject to this subpart. The facility will take an enforceable limit on HAP
emissions to remain an area source.
Chemical Accident Prevention Provisions, 40 CFR Part 68
[Not Applicable]
This facility does not process or store more than the threshold quantity of any regulated
substance (Section 112r of the Clean Air Act 1990 Amendments). More information on this
federal program is available on the web page: www.epa.gov/ceppo
Stratospheric Ozone Protection, 40 CFR Part 82
[Subpart A and F 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).
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. This facility does not
utilize any Class I & II substances.
PERMIT MEMORANDUM # 2006-226-O
V.
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6
OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions)
Subchapter 1 includes definitions but there are no regulatory requirements.
[Applicable]
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.
OAC 252:100-4 (New Source Performance Standards)
[Not Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they existed on
September 1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16),
Subpart B, Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart
BBBB, Subpart DDDD, Subpart HHHH and Appendix G. NSPS requirements are addressed in
the “Federal Regulations” section.
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. Fees were paid for previous years as required but this year’s emission
inventory was submitted late.
OAC 252:100-7 (Permits for Minor Facilities)
[Applicable]
Subchapter 7 sets forth the permit application fees and the basic substantive requirements of
permits for minor facilities. Since criteria pollutant emissions are less than 100 TPY for each
pollutant, and emissions of Hazardous Air Pollutants (HAP) will not exceed 10 TPY for any one
HAP or 25 TPY for any aggregate of HAP, the facility is defined as a minor source. Permit
conditions limiting VOC-containing and HAP-containing material usage are appropriate to
ensure the source remains minor.
OAC 252:100-9 (Excess Emissions Reporting Requirements)
[Applicable]
In the event of any release which results in excess emissions, the owner or operator of such
facility shall notify the Air Quality Division as soon as the owner or operator of the facility has
knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10)
working days after the immediate notice is given, the owner or operator shall submit a written
report describing the extent of the excess emissions and response actions taken by the facility.
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 (PM))
[Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with
emission limits based on maximum design heat input rating. Appendix C specifies a PM
emission limitation of 0.60 lbs/MMBTU for all equipment at this facility with a heat input rating
PERMIT MEMORANDUM # 2006-226-O
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of 10 Million BTU per hour (MMBTUH) or less. Fuel-burning equipment is defined in OAC
252:100-19 as any internal combustion engine or gas turbine, or other combustion device used to
convert the combustion of fuel into usable energy. The space heaters at the facility do not meet
the definition of fuel-burning equipment as defined in this subchapter and therefore are not
affected facilities.
Section 19-12 limits particulate emissions from emission points in an industrial process based on
process weight rate, as specified in Appendix G. Based on estimated maximum annual coating
usage of 40,560 pounds and HDPE usage of 208,000 pounds for the year of 2005, and operating
hours of 2,080 hours, the Appendix G allowable is 0.62 lbs/hr. From the emissions section of
this memorandum, the calculated PM emissions from coating are 0.32 lbs/hr. Therefore the
facility is in compliance.
OAC 252:100-25 (Visible Emissions and Particulates)
[Applicable]
No discharge of greater than 20% opacity is allowed except for short-term occurrences that
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. There are no issues related to opacity at this time.
OAC 252:100-29 (Fugitive Dust)
[Applicable]
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. The facility is surrounded by gravel access roads and parking
areas. A water/oil emulsion is used to control emissions.
OAC 252:100-31 (Sulfur Compounds)
[Applicable]
Part 5 limits sulfur dioxide emissions from new petroleum or natural gas process equipment
(constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lbs/MMBTU heat input
averaged over 3 hours. For fuel gas having a gross calorific value of approximately 1,000
BTU/SCF, this limit corresponds to fuel sulfur content of approximately 1,200 ppmv. The space
heaters are the only gas fuel-burning equipment in service at the facility. The facility requires
the use of consumer grade natural gas to ensure compliance with Subchapter 31.
OAC 252:100-33 (Nitrogen Oxides)
[Applicable]
This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or
equal to 50 MMBTUH to emissions of 0.20 lbs of NOX per MMBTU, three-hour average. There
are no equipment items that exceed the 50 MMBTUH threshold.
OAC 252:100-35 (Carbon Monoxide)
[Not Applicable]
None of the following affected processes are located at this facility: gray iron cupola, blast
furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic
reforming unit.
OAC 252:100-37 (Volatile Organic Compounds)
[Parts 5 & 7 Applicable]
Part 5 limits the VOC content of coatings used in coating lines and operations. The paints
currently in use have a maximum VOC content of 5.57 ppg, which is in compliance with the
PERMIT MEMORANDUM # 2006-226-O
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standard of 6.0 ppg for acrylics and 6.4 ppg for lacquers, except when thinners and solvents are
included. The permit contains a compliance schedule to address this issue. Sources that emit
less than 100 pounds of VOC per 24-hour day are exempt from the requirements of Seciton 3725 and the VOC content limits. Permit conditions ensure that this threshold is not exceeded.
Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC
emissions. Temperature and available air must be sufficient to provide essentially complete
combustion. The space heaters are designed to provide essentially complete combustion of
organic materials.
OAC 252:100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Not Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties. The facility is
located in Okmulgee County.
OAC 252:100-41 (Hazardous Air Pollutants)
[Not Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted
by reference as they exist on September 1, 2005, with the exception of Subparts B, H, I, K, Q, R,
T, W and Appendices D and E, all of which address radionuclides. In addition, General
Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control
Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, L, M, N, O, Q,
R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS,
TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO,
PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF, GGGG,
HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT,
UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE,
FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP,
QQQQQ, RRRRR, SSSSS, and TTTTT are hereby adopted by reference as they exist on
September 1, 2005. These standards apply to both existing and new sources of HAPs. These
requirements are covered in the “Federal Regulations” section.
Part 5 was a state-only requirement governing sources of toxic air contaminants that have
emissions exceeding a de minimis level. However, Part 5 of Subchapter 41 has been superseded
by OAC 252:100-42, effective June 15, 2006.
OAC 252:100-42 (Toxic Air Contaminants (TAC))
[Applicable]
Part 5 of OAC 252:100-41 was superceded by this subchapter. 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 Area of
Concern (AOC) has been designated anywhere in the state, 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
PERMIT MEMORANDUM # 2006-226-O
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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.
VI.
COMPLIANCE
Inspection
On October 5, 2006, the facility was inspected by David Pollard of AQD, accompanied by Stony
Taber of G&H Decoys, Inc. The facility was found to be constructed as currently permitted. As
noted in the previous discussion, numerous equipment is out-of-service or not in use. The facility is
keeping track of total coating and thinner usage. The facility used 4,056 gallons of coatings and
1,155 gallons of thinner for the year 2005. Based on this material usage, emissions are well below
the limits of the existing permit.
Tier Classification and Public Review
The applicant requested, by means of the Title V renewal application, a synthetic minor source
operating permit. Therefore, this application has been determined to be a Tier II based on a
significant modification, as described in 252:100-8-7.2(b)(2), of a Title V operating permit that is not
based on an underlying construction permit processed under Tier II or III, and 252:100-8-8. The
applicant 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 certified that the applicant owns the real
property.
Since the “Notice of Filing a Tier II Application” was not provided with the application, it will be
done concurrently with the “Notice of Tier II Draft Permit.” This facility is not located within 50
miles of the border of Oklahoma and any other state.
Information on all permit actions is available for review by the public in the Air Quality section of the
DEQ Web page at http://www.deq.state.ok.us.
Fee Paid
The applicant paid the Title V renewal application fee of $1,000 but requested at submittal that the
permit be issued as a synthetic minor source. The fee for a significant modification is $1,000.
VII.
SUMMARY
The facility was constructed as described in the application. There are no active Air Quality
compliance or enforcement issues concerning this facility. Issuance of the permit is recommended,
pending public comment and EPA review.
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
G & H Decoys, Inc.
Duck Decoy Manufacturing Plant
Permit No. 2006-226-O
The permittee is authorized to operate in conformity with the specifications submitted to Air Quality
on August 31, 2006. The Evaluation Memorandum dated October 27, 2006, explains the derivation
of applicable permit requirements and estimates of emissions; however, it does not contain operating
limitations or permit requirements. Continuing operation under this permit constitutes acceptance of
and consent to the conditions contained herein.
1. Emissions of volatile organic compounds shall not exceed 100 pounds per 24-hour day, 18.25
tons per year (TPY). Hazardous Air Pollutants (HAP) shall not exceed 9.9 TPY of any individual
HAP or 18.25 TPY of total HAPs combined from all materials used. Compliance with the daily limit
may be determined:
a. Daily, based on actual daily material usage; or
b. Monthly, as a daily average based on monthly material usage and the actual number of
workdays. When this daily average exceeds 75 pounds per day, the frequency for
determining compliance shall revert to daily.
2. The permittee shall be authorized to operate the coating line at the facility up to 7 days per week,
24 hours per day, and 8,760 hours per year.
3. Coating hoods/booths shall be equipped with a capture/discharge pollution control system and
filter media. The pollution control system shall be in operation during all coating operations. The
capture system and the housing for the filters shall be operated and maintained such that essentially
no bypass of unfiltered emissions occurs. The particulate filter media shall be replaced on a
frequency recommended by the manufacturer, or sooner if fouling occurs.
4. All containers having VOC materials shall be tightly covered and kept in the designated storage
area when not in use. Wastes shall be stored, handled, and disposed of in accordance with
all
applicable federal, state, and local rules and regulations.
5. The following records shall be maintained on-site. All such records shall be made available
regulatory personnel upon request. These records shall be maintained for a period of at
least
years after the time they are made.
to
two
a. Quantity of coatings, thinners and solvents (monthly and 12-month rolling cumulative).
b. A current material safety data sheet (MSDS) which documents the volatile organic solvent
content expressed in pounds of VOC per gallon of coating less water and exempt solvents,
percentage of water by weight, solids percent by weight, solvent density, and percentage of
exempt solvents by weight (if any), of each coating.
6. This permit supersedes all previous Air Quality permits for this facility, which are null and void.
MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(September 1, 2005)
A. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act. The permit does not relieve the holder of the obligation to comply
with other applicable federal, state, or local statutes, regulations, rules, or ordinances. This
specifically includes compliance with the rules of the other Divisions of DEQ: Land Protection
Division and Water Quality Division.
B. A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252:100-7-15(g)) 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 252:100-7-15(f)]
C. The recipient of a construction permit shall apply for a permit to operate (or modified
operating permit) within 60 days following the first day of operation.
[OAC 252:100-7-18(a)]
D. Unless specified otherwise, the term of an operating permit shall be unlimited.
E. Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 10 days after such date.
A new permit is not required.
[OAC 252:100-7-2(f)]
F.
The following limitations apply to the facility unless covered in the Specific Conditions:
1.
No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility.
[OAC 252:100-3]
All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory. Instructions and forms are available on the
Air Quality section of the DEQ web page. www.deq.state.ok.us
[OAC 252:100-5]
All excess emissions shall be reported to the Director of the Air Quality Division as soon as
practical during normal office hours and no later than the next working day following the
malfunction or release. Within ten (10) business days further notice shall be tendered in
writing containing specific details of the incident.
[OAC 252:100-9]
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]
No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 0.6 lbs/MMBTU.
[OAC 252:100-19]
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.
[OAC 252:100-25]
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
2.
3.
4.
5.
6.
7.
MINOR SOURCE STANDARD CONDITIONS
September 1, 2005
2
properties, or cause air quality standards to be exceeded, or interfere with the maintenance
of air quality standards.
[OAC 252:100-29]
8. No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2
lbs/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur
dioxide.
[OAC 252:100-31]
9. 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 an
organic material vapor-recovery system.
[OAC 252:100-37-15(b)]
10. 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]
G. Any owner or operator subject to provisions of NSPS shall provide written notification as
follows:
[40 CFR 60.7 (a)]
1. A notification of the date construction (or reconstruction as defined under §60.15) of an
affected facility is commenced postmarked no later than 30 days after such date. This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form.
2. A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies, unless that change
is specifically exempted under an applicable subpart or in §60.14(e). This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change, present and proposed
emission control systems, productive capacity of the facility before and after the change, and
the expected completion date of the change. The Administrator may request additional
relevant information subsequent to this notice.
3. A notification of the actual date of initial start-up of an affected facility postmarked within 15
days after such date.
4. If a continuous emission monitoring system is included in the construction, a notification of
the date upon which the test demonstrating the system performance will commence, along
with a pretest plan, postmarked no less than 30 days prior to such a date.
H. Any owner or operator subject to provisions of NSPS shall maintain records of the
occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected
facility or any malfunction of the air pollution control equipment.
[40 CFR 60.7 (b)]
I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file
suitable for inspection. This file shall be retained for at least five years following the date of
such measurements, maintenance, and records.
[40 CFR 60.7 (d)]
J. Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s). Test(s) shall be conducted
within 60 days after achieving the maximum production rate at which the facility will be
operated, but not later than 180 days after initial start-up.
[40 CFR 60.8]
PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N. ROBINSON, SUITE 4100
P.O. BOX 1677
OKLAHOMA CITY, OKLAHOMA 73101-1677
Permit Number: 2006-226-O
G & H Decoys, Inc.,
having complied with the requirements of the law, is hereby granted permission to operate
all sources within the boundaries of their facility located in SEC 6-T11N-R13E, Okmulgee
County, OK,
subject to the Standard Conditions dated September 1, 2005, and Specific Conditions, both
attached.
_________________________________
Director, Air Quality Division
Date
G & H Decoys, Inc.
Attn: Mr. Dick Gazalski, Owner
P.O. Box 1208
Henryetta, OK 74437
Re:
Evaluation of Permit Application No. 2006-226-O
G & H Decoys (G&H)
Duck Decoy Manufacturing Co.
Henryetta, OK
Dear Mr. Gazalski:
Air Quality Division has completed the initial review of your permit application referenced
above. This application has been determined to be a Tier II. In accordance with 27A O.S. § 214-302 and OAC 252:4-7-13, the enclosed draft permit is now ready for public review. The
requirements for public review include the following steps that you must accomplish:
1. Publish at least one legal notice (one day) in at least one newspaper of general circulation
within the county where the facility is located (Instructions enclosed). Since you will be
publishing notice of the application and draft permit concurrently, include the underlined text
below with the stock language for when you notice the draft permit.
“In response to the application, DEQ has prepared a draft permit (Permit Number: 2006226-O), which may be reviewed, along with the Permit Application, at the [list the location
and address in the county] or at the Air Quality Division's main office (see address below).
The proposed permit is also available for review in the Air Quality Section of DEQ's Web
Page: http://www.deq.state.ok.us/AQDnew/permitting/pubreview.htm”
2. Provide for public review (for a period of 30 days following the date of the newspaper
announcement) a copy of this draft permit and a copy of the application at a convenient
location within the county of the facility.
3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any
additional comments or requested changes that you may have on the draft permit.
G & H Decoys (G&H)
page -2Thank you for your cooperation in this matter. If we may be of further service, please contact
me at (918) 293-1617 or by mail at DEQ Regional Office at Tulsa, 3105 East Skelly Drive, Suite
200, Tulsa, Oklahoma, 74105.
Sincerely,
David Pollard, P.E., Professional Engineer III
AIR QUALITY DIVISION
Enclosures