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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
June 2, 2006
TO:
Dawson Lasseter, P.E., Chief Engineer, Air Quality
THROUGH:
Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits Section
THROUGH:
Peer Review, Hal Wright
FROM:
David Pollard, ROAT
SUBJECT:
Evaluation of Permit Application No. 2006-064-O
ACME Engineering & Manufacturing Corp.
1820 North York
Muskogee, Muskogee County, OK
INTRODUCTION
ACME Engineering & Manufacturing Corp. (applicant), a manufacturer of ventilating fans and
equipment (SIC 3499) located at 1870 North York Street, Muskogee, submitted a Title V permit
application on February 6, 2006, for the referenced facility. This application was submitted as a
requirement of Consent Order 05-446. Information received on April 19, 2005, indicated that a
new coating booth had the potential to emit 12.93 TPY of toluene, 12.32 TPY of xylene, and
10.84 TPY of MIBK, all Hazardous Air Pollutants (HAPs), thus making it a major source of
HAPs. The other five coating booths are permitted under Permit No. 95-209-O. The facility has
been in business since 1938. After Tier II processing, the permit will be issued as a synthetic
minor source.
EQUIPMENT AND PROCESS DESCRIPTION
The facility consists of one large building, located in a commercial district in Muskogee,
Oklahoma. The primary sources of air emissions are the coating and pallet/crate making
operations. A new coating booth and a wash booth were added and commenced operation in
September of 2001. The following tables illustrate equipment having emissions of concern for
this permit.
Fuel-Burning Equipment
EU# EU Name
Model
6
7
Paint Bake Oven
Boiler
Pyronics Nozzle Mix Burner #2501NM
Dunkirk Gas-Fired #D247
Process Rate
(MMBTUH)
Construct
Date
2.5
2.5
May 1980
Jan 2001
PERMIT MEMORANDUM 2006-064-O
Coating Operations
EU# EU Name
1
Paint Booth #1
(Primer Booth)
2
Paint Booth #2
(Primer Booth)
3
Paint Booth #3
(Hi Solids Booth)
4
Paint Booth #4
(Hi Solids Booth)
5
Paint Booth #5
(Special Booth)-EP
8
Paint Booth #6
(Special Booth)-IP
Model
Nordson Corporation
Pump, Model 64B
Nordson Corporation
Pump, Model 64B
Nordson Corporation
Pump, Model 360D
Nordson Corporation
Pump, Model 360D
Manual Spray Gun
Manual Spray Gun
DRAFT
2
Process Rate
10.8 gal/hr
Construct Date
1980
10.8 gal/hr
1980
4.32 gal/hr
1980
4.32 gal/hr
1980
2 gal/hr
May 1996
2 gal/hr
Sept 2001
The applicant operates six (6) coating booths. The Environmental Products (EP) booths are Paint
Booth #1 (Primer Booth), Paint Booth #2 (Primer Booth), Paint Booth #3 (High Solids Booth),
Paint Booth #4 (High Solids Booth), and Paint Booth #5 (Special Booth). Industrial Products
(IP) has one Special Paint Booth-Paint Booth #6 (Special Booth)-IP. Parts to be coated move
through the process on an automated conveyer. The process flow is as follows:











Soap Tank #1 - A cold dip to clean the parts
Water Tank #2 - Rinse
Phosphorus Tank #3 - A cold dip tank to prep the metal
Water Tank #4 - Rinse
Anti-Rust Tank #5 - A cold dip tank to coat the metal
Dryer - Point source of natural gas
Paint Booth #1 (Primer Booth) - Point source of solvent and primer
Paint Booth #2 (Primer Booth) - Point source of solvent and primer
Paint Booth #3 (Hi Solids Booth) - Point source of solvent and paint
Paint Booth #4 (Hi Solids Booth) - Point source of solvent and paint
Bake Oven - Point source of natural gas and volatile organic compounds (VOCs) from
painting operation
Parts are dried in a dryer after the washing steps and baked in an oven after coatings are applied.
Flow diagrams are included in the permit application as Appendix C. Special projects and touch
up jobs are primed and painted in Paint Booths #5 and #6 (Special Booths) EP and IP. These
booths are not served by the conveyor.
Paint Booth #1 (Primer Booth) and Paint Booth #2 (Primer Booth)
Paint Booths #1 and #2 operate for each side of the part being coated. As the part travels on the
conveyer, Paint Booth #1 sprays one side of the part then the part passes through Paint Booth #2
which sprays the other side of the part. Each booth is equipped with particulate filters. Each of
the paint booths has two exhausts, each operating at a rate of 13,750 cfm, for a total of 27,500
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cfm for each booth. The booths exhaust approximately five feet above the roof. There are no
other pollution controls. Paint Booths #1 and #2 utilize a Nordson Corporation Pump, Model
64B, wall-mounted unit located in the area of operation. This pump operates at a 30:1 ratio with
input air pressure maintained at 50 PSI and usable output pressure ranging from 640-2560 PSI.
This pump operates at 10 cycles per minute, giving a delivery rate of 0.18 gallons per minute.
Coating is applied manually. There is one spray gun at each booth.
Paint Booth #3 (Hi Solids Booth) and Paint Booth #4 (Hi Solids Booth)
Like Booths #1 and #2, Paint Booth #3 and Paint Booth #4 operate for each side of the part as
well. Each booth is equipped with particulate filters and two exhaust fans, each operating at a
rate of 13,750 cfm, for a total of 27,500 cfm for each booth. The booths exhaust approximately
five feet above the roof. There are no other pollution controls. Paint Booths #3 and #4 utilize a
Nordson Corporation Pump, Model 360D, wall-mounted unit. This pump operates at a 32:1 ratio
with input air pressure maintained at 50 PSI and usable output pressure at 1,500 PSI. This pump
operates at 4 cycles per minute, giving a delivery rate of .072 gallons per minute. Coating is
applied manually. There is a spray gun at each booth.
Since Paint Booths #1, #2, #3, and #4 all require the full use of the conveyor, they are inoperable
at the same time. These four booths operate on two shifts, the first shift is 5:00 AM to 1:30 PM,
Monday through Friday and the second shift is 2:30 PM to 12:00 AM, Monday through
Thursday. Conveyor maintenance occurs 16 hours per month. Filter changes require 2-½ hours
per week. Maintenance therefore requires 7.7% of hours operated. Daily checks are required for
each booth. This includes hanging and removing parts as well as checking airflow on the booths.
This is estimated at 2-¼ hours per day. This process line is also used to clean aluminum.
Currently, aluminum cleaning occurs 16 hours per week or 20% of hours operated. The
conveyor moves at a speed of 8 feet per minute. The actual manual spray time on the line is 44%
of hours operated. Production ratio on this process is only 20% of hours of operation.
Paint Booth #5 (Special Booth)-EP
Paint Booth #5 is used to coat individual parts not processed on the conveyor line. This process
is independent of all other processes. The booth is equipped with particulate filters and two
exhaust fans, each operating at a rate of 13,750 cfm, for a total of 27,500 cfm. The booth
exhausts approximately five feet above the roof. There are no other pollution controls. Paint
Booth #5 (Special Booth)-EP utilizes an air pressure pot and spray gun. This booth uses a 15/85
solvent/paint blend for special projects and touch up. Coating is applied manually.
Approximately two gallons can be sprayed an hour. Coated parts are air dried in the booth.
Paint Booth #5 operates approximately once per week for 3 to 4 hours. Maintenance requires
3.1% of hours operated. Daily checks are required for this booth. This includes checking airflow
on the booth, estimated at 2 ¼ hours per day. Actual manual spray time is 44% of hours
operated.
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Paint Booth #6 (Special Booth)-IP
Paint Booth #6 is also used to coat individual parts not processed on the conveyor line. This
process is independent of all other processes. The booth is equipped with particulate filters and
one exhaust fan operating at a rate of 13,750 cfm. The booth exhausts approximately five feet
above the roof. There are no other pollution controls. Paint Booth #6 utilizes an air pressure pot
and spray gun. This booth uses a low HAP (hazardous air pollutant) air dry paint and primer,
ready to spray for special projects and touch up. Coating is applied manually. Approximately
two gallons can be manually sprayed an hour. Coated parts are air dried in the booth.
Paint Booth #6 operates approximately once every two weeks for 1-2 hours. Maintenance
requires 3.1% of hours operated. Daily checks are required for this booth. This includes
checking airflow on the booth, estimated at 2 ¼ hours per day. Actual manual spray time is 44%
of hours operated.
Paint Bake Oven
Natural gas is used to fire the Paint Bake Oven. Operating temperature for the Paint Bake Oven
ranges between 250 °F to 275 °F. Exhaust gas from the Paint Bake Oven is used to provide heat
to a drying tunnel where parts are dried after washing and prior to coating.
Welding
Welding is performed on aluminum and steel alloys and may result in small amounts of metal
oxides (from the alloys or welding wire) being released. There are sixteen welding booths.
Solvent Degreasers
The facility has one cold solvent degreaser. It is equipped with a cover and a drain that drains the
solvent back into a closed container. Used solvent is returned to the vendor for recycling.
Wood Pallet and Crate Manufacturing
The facility manufactures their own wooden pallets and crates for packing and shipping of
products manufactured at the facility. There are four work stations, each having a saw equipped
with a sock filter.
EMISSIONS
Air emissions result primarily from the coating operations and gas-fired equipment and from the
wood pallet and crate manufacturing operations.
Criteria Pollutants
Paint spraying creates particulate matter (PM) emissions as well as VOC emissions. The paint
booths are actually a filter wall, having no sides or roof. Paint is sprayed manually onto the parts in
the direction of the filter wall so as to facilitate recovery of the airborne paint by the filter. Air
emissions from the operations are a function of coating usage (volume, density, and solvent
content). From Permit No. 95-209-O, emissions of VOCs and PM have been estimated by
PERMIT MEMORANDUM 2006-064-O
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multiplying the VOC and solids content of the paints by the annual usage of each. PM emissions
calculations are further refined assuming 40% overspray, 50% capture efficiency, and 90%
efficiency of dry-filter controls.
For this application, the applicant submitted emissions of VOCs to be 6.04 lbs/hr and 25.21 TPY
with a PTE of 75.81 TPY. No justification was provided in the application. The applicant has
considered in their calculations, operational restrictions on the run time of the conveyor system
as discussed above. The application indicates that maximum spray gun rates are 10.8 gallons/hr,
10.8 gallons/hr, 4.32 gallons/hr, 4.32 gallons/hr, 2 gallons/hr, and 2 gallons/hr for the six coating
booths. No performance data was submitted for the spray guns. Assuming an average coating
VOC content of 7.0 lbs/gallon, and no restrictions on the coating process, the PTE for VOCs
would be 1,050 TPY.
Annual inventories submitted for 2004 and 2005 provide emissions of 14.2 TPY and 6.4 TPY
respectively, based on mass balance. Therefore, AQD assumes the numbers in the application
were based on material balance and estimated projected actual coating usage. These values are
not important other than forming the basis for the new permit limits. Compliance will be
documented by material balance. VOC emissions are typically based on 100% evaporation.
Using 25.21 TPY of VOC emissions, assuming an average solids content of 50%, and
incorporating the same assumptions as in Permit No. 95-209-O, i.e., 40% overspray, 50% capture
efficiency, and 90% efficiency of dry-filter controls, AQD estimated emissions of particulate
matter to be approximately 0.5 TPY controlled and 5.0 TPY uncontrolled.
The applicant submitted emissions of combustion products as illustrated in the following tables.
No justification was provided in the application. The numbers appear to be based on emission
factors from AP-42, Table 1.4-1, for small boilers rated at less than 100 MMBTUH, with a
contingency factor of 32%. These values are not important other than forming the basis for the
permit limits.
EU Name
Paint Bake Oven - 2.5 MMBTUH
Boiler - 2.5 MMBTUH
TOTALS
NOX
(TPY)
1.42
1.42
2.84
CO
(TPY)
1.19
1.19
2.38
VOC
(TPY)
0.08
0.08
0.16
SO2
(TPY)
0.01
0.01
0.02
PM10
(TPY)
0.03
0.03
0.06
Welding
Consumption of welding wire for the past six months was approximately 7,500 pounds. From
AP-42, 12.19 Table 12.19-1 (1/95), Electric Arc Welding, the highest emissions factor for
particulate matter, all welding types considered is 57 lbs/103 lbs. This equates to roughly 0.2
TPY.
Wood Pallet and Crate Manufacturing
The facility receives, on average, 23,500 board feet of wood each week. Based on a conservative
assumption that 1% of all wood throughput is converted to particulate emissions from sawing
and that the sock filters have 0% collection efficiency for particulate matter having an
PERMIT MEMORANDUM 2006-064-O
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areodymamic particale diameter of 10 microns or less (PM10), annual emissions of particulate
matter are calculated as follows:
23,500 board-feet x 52 weeks x 0.0833 ft3 x 34.96 lbs x 0.01 PM x 1 ton
= 17.8 TPY
week
year
board-feet
ft3
2,000 lbs
Hazardous Air Pollutants
The following table illustrates the applicant’s breakdown of HAPs in the coating emissions.
CAS #
14808-60-7
100-42-5
111-76-2
100-41-4
108-10-1
108-88-3
1330-20-7
78-93-3
98-82-8
98-86-2
Total HAPs
Pollutant
Quartz
Styrene
Ethylene Glycol Butyl Ether
Ethyl Benzene
Methyl Isobutyl Ketone
Toluene
Xylene
Methyl Ethyl Ketone
Cumene Hydroperoxide
Acetophenone
Emissions (TPY)
0.02
0.00
0.00
0.01
1.77
3.17
3.45
0.00
0.00
0.00
8.42
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
Subparts K, Ka, Kb
There are no storage tanks for the storage of petroleum liquids or VOCs.
[Not Applicable]
The following NSPS subparts affect surface coating operations. However, none of these subparts
affects a facility which manufactures and coats oilfield pipe.
Subpart EE - Standards of Performance for Surface Coating of Metal Furniture, each metal
furniture surface coating operation in which organic coatings are applied. The facility does not
manufacture or coat furniture.
Subpart SS - Standards of Performance for Industrial Surface Coating: Large Appliances, applies
to each surface coating operation in a large appliance surface coating line. Large appliance
product is defined as any organic surface-coated metal range, oven, microwave oven,
refrigerator, freezer, washer, dryer, dishwasher, water heater, or trash compactor manufactured
PERMIT MEMORANDUM 2006-064-O
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for household, commercial, or recreational use. The facility does not manufacture or coat any of
these products.
Subpart TT - Standards of Performance for Metal Coil Surface Coating, applies to each prime
coat operation, each finish coat operation, and each prime and finish coat operation combined
when the finish coat is applied wet on wet over the prime coat and both coatings are cured
simultaneously in a metal coil surface coating operation. The facility does not manufacture or
coat metal coils.
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. Subpart J, Equipment Leaks of Benzene, concerns only process streams that contain
more than 10% benzene by weight. Benzene is present only in trace amounts in any material at
this site.
NESHAP, 40 CFR Part 63
[Not Applicable]
Section 63.43 of Subpart B requires that any facility not included in a listed source category (or
for which a standard has not been promulgated under Section 112c of the CAA prior to May 15,
2002) that constructs or reconstructs a major source of HAPs after June 29, 1998, is subject to a
case-by-case MACT determination. This “112g” MACT determination may be superseded by
any subsequently promulgated MACT requirement promulgated under Section 112c of the CAA.
This facility will be permitted as a synthetic minor source.
NESHAP, 40 CFR Part 63
[Not Applicable]
Subpart MMMM - affects miscellaneous metal parts and products surface coating facilities at
new, reconstructed, or existing affected sources, as defined in §63.3882, that use 946 liters (250
gallons (gals)) per year, or more, of coatings that contain hazardous air pollutants (HAP) in the
surface coating of miscellaneous metal parts and products defined in paragraph (a) of this
section; and are a major source, located at a major source, or are part of a major source of
emissions of HAP. This facility is an existing source. The equipment manufactured and coated
at the subject facility may meet the definition of “Miscellaneous metal parts and products,” but
compliance date would be January 2, 2007. The facility will not be a major source of HAPs once
this synthetic minor source permit is issued. Therefore the facility will not be subject to this
subpart.
Subpart NNNN - affects facilities that apply coatings to large appliance parts or products, and is
a major source, is located at a major source, or is part of a major source of emissions of
hazardous air pollutants (HAP). Equipment manufactured and coated at the subject facility does
not likely meet the definition of “large appliance” and will not be a major source of HAPs once
this synthetic minor source permit is issued. Therefore the facility will not be subject to this
subpart.
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
PERMIT MEMORANDUM 2006-064-O
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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.
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 exist on July 1, 2002,
except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart
C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix
G. These requirements are covered 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. Emission inventories were submitted and fees paid for previous years as
required.
PERMIT MEMORANDUM 2006-064-O
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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 HAPs will not exceed 10 TPY for any one HAP or 25 TPY for any
aggregate of HAPs, the facility is defined as a minor source. As such, BACT and public review
are not required. Permit conditions that limit material usage will ensure the facility remains a
minor source.
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 fuel-burning equipment. Particulate emission
limits are 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 of 10
MMBTUH or less. The total heat input ratings for the bake oven and boiler are 2.5 MMBTUH
each. AP-42 (7/98), Table 1.4-2 lists PM emissions for natural gas combustion from heaters,
boilers, etc., to be 0.0076 lbs/MMBTU. Therefore the facility is in compliance.
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
(and/or) emission points in an industrial process to limits specified in Appendix G in units of
lb/hr, based on process weight. Based on the type of operations/processes conducted at the facility,
emissions of particulate are small compared to material throughput and, if calculated, would likely
be in compliance with this requirement.
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.
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 originated 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 has
negligible potential to violate this requirement; therefore it is not necessary to require specific
precautions to be taken.
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OAC 252:100-31 (Sulfur Compounds)
[Applicable]
Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972). For
gaseous fuels the limit is 0.2 lbs/MMBTU heat input. Fuel-burning equipment at this facility
uses commercial natural gas. AP-42 (7/98), Table 1.4-2, lists an emissions factor for SO2 of 0.6
lbs/scf, which equates to approximately 0.0006 lbs/MMBtu. The use of commercial grade
natural gas for all fuel-burning equipment ensures compliance with this part.
OAC 252:100-33 (Nitrogen Oxides)
[Not Applicable]
This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or
equal to 50 MMBTUH to emissions of 0.2 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 and 7 Applicable]
Part 5 limits the VOC content of coatings used in coating lines and operations. The facility is
subject to these limits.
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 facility is subject to this rule. The bake oven and boiler 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. This facility is
located in Muskogee County.
OAC 252:100-41 (Hazardous Air Pollutants)
[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, 2004, 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, J, 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, 2004. These standards apply to both existing and new sources of HAPs. These
requirements are covered in the “Federal Regulations” section.
PERMIT MEMORANDUM 2006-064-O
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Part 5 is a state-only requirement governing toxic air contaminants. Part 5 regulates 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. The Air Quality Council approved
Subchapter 42 for permanent rulemaking on April 20, 2005. The Environmental Quality Board
approved Subchapter 42 as both a permanent and emergency rule on June 21, 2005. The
emergency Subchapter 42 was sent for Gubernatorial signature on June 30, 2005, and became
effective by emergency August 11, 2005. Subchapter 42 is expected to become permanently
effective on June 15, 2006. Because Subchapter 41, Part 5 has been superseded, the
requirements of Part 5 will not be reviewed in this memorandum. Should Subchapter 42 fail to
take effect, this permit will be reopened to address the requirements of Subchapter 41, Part 5.
OAC 252:100-42 (Toxic Air Contaminants (TAC))
[Not Applicable]
All parts of OAC 252:100-41, with the exception of Part 3, shall be superseded 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.
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.
COMPLIANCE
Inspection
On May 11, 2006, David Pollard of the Air Quality Division inspected the facility, accompanied
by Mr. Larry Templeton of ACME Engineering & Manufacturing Corp., and found it to be as
represented in the application. Records of material usage and material safety data sheets are kept
at the facility and were made available during the inspection. No other records were requested.
PERMIT MEMORANDUM 2006-064-O
DRAFT
12
Tier Classification And Public Review
Consent Order 05-446 notes that construction and start-up on Paint Booth #6 (Special Booth)-IP
and the Power Wash Booth had been completed by September 1, 2001. As noted in the
introduction, information received on April 19, 2005, indicated that the IPD Special Paint Booth
had the potential to emit of 12.93 TPY of toluene, 12.32 TPY of xylene, and 10.84 TPY of
MIBK, all HAPs, thus making the new booth a major source of HAPs. The applicant was
required to file a Part 70 operating permit application and did so on February 6, 2006.
This application has been determined to be a Tier II based on the request for an operating permit
for a synthetic minor source for which a Title V operating permit application was required to
have been submitted. 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 land.
The applicant published a “Notice of Filing a Tier II Application,” but did not make it available
at a location convenient for the public. Therefore, it will be noticed again, 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
A fee in the amount of $2,000 for a Title V permit application was submitted. Penalties assessed
by the Consent Order were handled separately.
SUMMARY
This facility was constructed as described in the application. There are no active Air Quality
compliance or enforcement issues that would affect the issuance of this permit. Issuance of the
operating permit is recommended, pending public and EPA review.
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
ACME Engineering & Manufacturing Corp.
Coating Facility
Permit No. 2006-064-O
The permittee is authorized to operate in conformity with the specifications submitted to Air
Quality on February 6, 2006. The Evaluation Memorandum dated June 2, 2006, explains the
derivation of applicable permit requirements and estimates of emissions; however, it does not
contain operating limitations or permit requirements. Continuing operations under this permit
constitutes acceptance of, and consent to, the conditions contained herein.
1. Points of emissions and emission limitations for each point:
EU Name
Paint Bake Oven
Boiler
EU Name
Paint Booth #1
Paint Booth #2
Paint Booth #3
Paint Booth #4
Paint Booth #5
Paint Booth #6
Process Rate
(MMBTUH)
2.5
2.5
Construction
Date
May 1980
Jan 2001
Model
Nordson Corporation Pump, Model 64B
Nordson Corporation Pump, Model 64B
Nordson Corporation Pump, Model 360D
Nordson Corporation Pump, Model 360D
Manual Spray Gun
Manual Spray Gun
Construction Date
1980
1980
1980
1980
May 1996
Sept 2001
a. Emissions of volatile organic compounds (VOCs) shall not exceed 25.21 TPY, 12-month
rolling cumulative.
b. Emissions of Hazardous Air Pollutants (HAP) shall not exceed 10 TPY of any individual
HAP or 25 TPY of total HAPs combined from all materials used, 12-month rolling
cumulative.
c. Emissions of particulate matter from pallet and crate manufacturing shall not exceed 20
TPY.
2. Permittee shall maintain records and calculations necessary to document compliance with the
emission limits. Permittee shall calculate total emissions of VOCs, HAPs, and particulate
matter emitted to the atmosphere from the coating operations.
a. VOC and HAP emissions from coatings and associated materials shall be calculated as
the product of material usage and the VOC content, assuming 100% evaporation of
VOCs, 12-month rolling cumulative.
SPECIFIC CONDITIONS 2006-064-O
DRAFT
2
b. Particulate matter shall be calculated as the product of material usage and the solids
content, accounting for 40% overspray, 50% capture, and 90% filter efficiency.
c. Permittee shall be responsible for identifying all VOC, HAPs, and solids contained in
coating materials used at the facility.
3. Permittee shall comply with all applicable requirements of OAC 252:100-37, Part 5.
a. Permittee shall comply with the coating VOC content limits for each coating type.
b. Emissions from thinners and solvents associated with the coating processes shall be
included as VOC when determining compliance with the coating VOC content limits.
4. All containers having VOC materials shall be tightly covered and kept in the designated
storage area when not in use. Cleaning rags or wipes must be discarded in covered
containers for proper disposal. Wastes shall be stored, handled, and disposed of in
accordance with all applicable federal, state, or local rules and regulations.
5. 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.
6. All pollution control equipment and filters associated with the coating processes shall be
maintained and properly operating during coating operations.
a. Filters shall sustain an efficiency of no less than 90%, and may be replaced only by filters
having an equivalent or greater efficiency capable of sustaining this level of efficiency
until time for replacement. The filter shall be replaced on a frequency recommended by
the manufacturer, or sooner if necessary.
b. Readings of pressure drop across the filters shall be obtained and recorded weekly.
7. The following records shall be maintained on-site, in monthly and 12-month rolling
cumulative format. All such records shall be made available to regulatory personnel upon
request. These records shall be maintained for a period of at least two years after the time
they are made.
a. Quantity of coatings, thinners, solvents, and other VOC materials used.
b. Calculations required to demonstrate compliance with Specific Condition Nos. 1, 2 and 3.
c. A 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.
d. Records of inspections, including pressure monitoring, and maintenance performed on the
air pollution control equipment.
8. This permit shall supersede all previously issued air quality permits for this facility.
Lee Buddrys, President
ACME Engineering & Manufacturing Corp.
P.O. Box 978
Muskogee, OK 74402
SUBJECT: Operating Permit No. 2006-064-O
Facility:
Muskogee Manufacturing Plant
Location: 1820 North York, Muskogee, OK 74402
Dear Mr. Buddrys:
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. § 2-14-302 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).
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. The facility is not generally considered to be a convenient location
for public review.
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.
Thank 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 II
AIR QUALITY DIVISION
Enclosure
cc: DEQ Office, Muskogee County
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]
2.
3.
4.
5.
6.
MINOR SOURCE STANDARD CONDITIONS
September 1, 2005
2
7.
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]
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 No. 2006-064-O
ACME Engineering & Manufacturing Corp.,
having complied with the requirements of the law, is hereby granted permission to operate
the coating facilities located within the boundaries of their property located at 1820 North
York, Muskogee, Muskogee County, Oklahoma,
subject to the following conditions attached:
[X] Standard Conditions dated September 1, 2005
[X] Specific Conditions
_
Director, Air Quality Division
Date