p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

63) 11-1-63 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:23 PM Sheet 63 of 114 
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/. - 9V- Si 

X--T-63 

AIR POLLUTION CONTROL OPERATION PERMIT 

EI FACILITY NO. 241270810 PERMIT NO. 241270810-P01 

TYPE: Operation Permit, Major, Part 70 Source 

In compliance with the provisions of Chapter 144, Wis. Stats., and Chapters 

NR 400 to NR 499, Wis. Adm. Code, 

Name of Source: 

Street Address: 

BRADY U.S.A. - SignmarkR Division 

Cameron Avenue Facility 

3328 W. Cameron Avenue 

Milwaukee 

Milwaukee County 

Responsible Official, & Title: Tom J. Felmer 

General Manager 

is authorized to operate fiberglass sign manufacturing facility in conformity 

with the conditions herein, and in compliance with the provisions of Chapter 

285, Wis. Stats, (formerly ch. 144, Wis. Stats.), and Chapters NR 400 to 

NR 499, Wis. Adm. Code, 

THIS OPERATION PERMIT EXPIRES MARCH 12. 2002. A RENEWAL APPLICATION MUST 

BE SUBMITTED AT LEAST 12 MONTHS, BUT NOT MORE THAN 18 MONTHS, PRIOR TO THIS 

EXPIRATION DATE [s. NR 407.09(1)(b)1, Wis. Adm. Code]. 

No permittee may continue operation of a source after the operation permit 

expires, unless the permittee submits a timely and complete application for 

renewal of the permit [s. 285.66(3), Wis. Stats, (formerly s. 144.396(3), Wis. 

Stats.), and NR 407.04(2), Wis. Adm. Code]. 

This authorization requires compliance by the permit holder with the emission 

limitations, monitoring requirements and other terms and conditions set forth 

in Parts I and II hereof. 

Dated at Milwaukee, Wisconsin, March 12. 1997 

State of Wisconsin 

Department of Natural Resources 

For the Secretary 

By Daniel Schramm/s/ 03/12/97 

Daniel Schramm, P.E. 

Supervisor Air Management Engineering Section 

Southeast Regional Headquarters 

March 10, 1997 Page 1 
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PT-oawihl a 

An Asterisk "*" throughout this document denotes legal authority, limitations 

and conditions which are not federally enforceable. 

This permit supersedes air pollution control permit #92-DAA-296 

Active Construction Permits Expiration Date 

None Not Applicable 

Stack and Process Index 

Stack SIO, Process P30 

A process line to coat and cure fiberglass coated with a styrene-based resin. 

Stack S14, Process P33 

The miscellaneous finishing operations performed to machine the cured 

fiberglass composite into the finished product (industrial signs). 

Stack S30, Process P35 

A manual screen printing press and air-dried drying racks. 

This source is not subject to any New Source Performance Standards (NSPS). 

Permit Shield - Unless precluded by the Administrator of the USEPA, compliance 

with all emission limitations in this operation permit is considered to be 

compliance with all emission limitations established under ss. 285.01 to 

285.87, Wis. Stats, (formerly ss. 144.30 to 144.426, Wis. Stats.), and 

emission limitations under the federal clean air act, that are applicable to 

the source if the permit includes the applicable limitation or if the 

Department determines that the emission limitations do not apply. The 

following emission limitations were reviewed in the analysis and preliminary 

determination and were determined not to apply to this stationary source: 

s. NR 422.145, Wis. Adm. Coda - Under NR 422.03 (4m) (b), Wis. Adm. Code, screen 

printing facilities located in Milwaukee County with a Maximum Theoretical 

Emissions of VOCs from all screen printing units at the facility of less than 

25 tpy are exempt (Process P35). 

s. NR 424.03(2), Wis. Adm. Coda - Under NR 424.03(1)4, Wis. Adm. Code, process 

lines from which volatile organic compound emissions are never greater than 15 

pounds per day are exempt (Process P35). 

Part I — The headings for the areas in the permit are defined below. The 

legal authority for these limitations or methods follows them in [brackets] . 

Pollutant — This area will note which pollutant is being regulated by the 

permit. 

January 16, 1997 Page 2 

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Limitations — This area will list all applicable emission limitations that 

apply to the source, including case-by-case limitations such as Latest 

Available Control Techniques (LACT), Best Available Control Technology 

(BACT), or Lowest Achievable Emission Rate (LAER). It will also list any 

voluntary restrictions on hours of operation, raw material use, or 

production rate requested by the permittee to limit potential to emit. 

Compliance Demonstration — The compliance demonstration methods outlined 

in this area may be used to demonstrate compliance with the associated 

emission limit or work practice standard listed under the corresponding 

Limitations area. The compliance demonstration area contains limits on 

parameters or other mechanisms that will be monitored periodically to 

ensure compliance with the limitations. The requirement to test as well as 

initial and periodic test schedules, if testing is required, will be stated 

here. 

Reference Test Methods. Recordkeeping, and Monitoring Requirements — 

Specific EPA Reference test methods or other approved test methods will be 

contained in this area and are the methods that must be used whenever 

testing is required. A reference test method will be listed even if no 

testing is immediately required. Also included in this area are any 

recordkeeping requirements and their frequency and reporting requirements. 

Accuracy of monitoring equipment shall meet, at a minimum, the requirements 

of ss. NR 439.055(3) and (4), Wis. Adm. Code, as specified in Part II of 

this permit. 

Condition Type — This area will specify other conditions that are 

applicable to the entire facility that may not be tied to one specific 

pollutant. 

Conditions — Specific conditions usually applicable to the entire facility 

or compliance requirements. 

Compliance Demonstration « This area contains monitoring and testing 

requirements and methods to demonstrate compliance with the conditions. 

PART II — This section contains the general limitations that the permittee 

must abide by. These requirements are standard for most sources of air 

pollutants so they are included in this section with every permit. 

January 16, 1997 Page 3 

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PART I 

APPLICABLE LIMITATIONS AND SPECIFIC CONDITIONS 

Stack SIO, Process P30 - A custom designed process line to flow coat and 

temperature cure a fiberglass web coated with a styrene-based resin. 

The cured composite is used as the base substrate in the manufacturing 

of industrial signs. The process line was installed, or last modified, 

in March of 1978. Stack SIO represents the composite of three fixed 

exhaust stacks. 

Volatile Organic Compound (VOC) Emissions 

a. LIMITATIONS 

(1) The permittee may not cause, allow, or permit VOC emissions 

into the ambient air which exceed 1.35 pounds per gallon of 

resin delivered to the applicator, excluding water, [s. NR 

419.03, Wis. Adm. Code]. 

(2) The monthly usage of all resins, as delivered to the 

applicator, may not exceed 12,000 gallons, excluding water, 

averaged over the three most recent consecutive calendar 

months, [s. 285.65(7), Wis. Stats, (formerly s. 144.394(7), 

Wis. Stats.)] 

(3) The monthly usage of VOC may not exceed 330 pounds from the 

usage of cleanup solvents to clean equipment, [s. 285.65(7), 

Wis. Stats, (formerly s. 144.394(7), Wis. Stats.)] 

b. COMPLIANCE DEMONSTRATION 

(1) The permittee shall determine, prior to its application, 

either analytically or through the use of published 

literature (e.g., MSDS), the pounds of VOC per gallon, 

excluding water, emitted during the application and cure of 

each resin and of each equipment cleanup solvent used. [s. 

NR 407.09(4)(a)3b, Wis. Adm. Code] 

(2) The permittee shall determine, on monthly basis, the total 

volume of all resins delivered to the applicator each month 

in units of gallons, excluding water. ts. NR 

407.09(4)(a)3b, Wis. Adm. Code] 

(3) The permittee shall determine, on monthly basis, the total 

weight of VOCs used each month from the usage of cleanup 

solvents to clean equipment, in units of pounds. [s. NR 

407.09(4)(a)3b, Wis. Adm. Code] 

C. REFERENCE TEST METHODS, RECORDKEEPING AND MONITORING REQUIREMENTS 

(1) Whenever VOC content compliance testing of the cleanup 

solvents is required, USEPA Method 24 or Method 24A shall be 

used. [s. NR 439.06(3)(b), Wis. Adm. Code] 

January 16, 1997 Page 4 

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(2) The permittee shall maintain monthly records, or a database, 

of the following information: 

(a) A unique name or identification of each resin, as 

delivered to the applicator, and each cleanup solvent, 

as used to clean equipment; 

(b) The pounds of VOC per gallon, excluding water, emitted 

during the application and cure of each resin and the 

pounds of VOC per gallon, excluding water, of each 

equipment cleanup solvent used. The permittee shall 

determine, prior to its use, either analytically or 

through published literature (e.g., MSDS), the VOC 

emission of each resin delivered to the applicator and 

the VOC content of each equipment cleanup solvent 

used; 

(c) The total volume of all resins delivered to the 

applicator each month in units of gallons, excluding 

water; 

(d) The total volume of all resins delivered to the 

applicator each month in units of gallons, excluding 

water, averaged over the most recent three consecutive 

calendar months; and 

(e) The total weight of all VOCs used each month from the 

usage of cleanup solvents to clean equipment, in units 

of pounds. 

Records must be maintained such that the individual usage 

and cumulative usage of all resins delivered to the 

applicator and all VOCs used from the usage of equipment 

cleanup solvents can be readily and accurately determined on 

a monthly basis. The records shall be compiled by the 

fifteenth (15th) day of the following month. [ss. NR 

407.09(1) (c)lb, NR 439.04(1)(d) and NR 439.04(4)(a), (b), 

and (c), Wis. Adm. Code] 

January 16, 1997 Page 5 

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Stack S14, Process P33, Control Device C33 - The miscellaneous finishing 

operations performed to machine the cured fiberglass composite into the 

finished product (e.g., 1 corner router, 1 shaping router, 1 singlespindle drill press, 2 multi-spindle drill presses, and 2 belt sanders). 

The process equipment was installed, or last modified, in August of 

197 9. Stack S14 is a fixed exhaust stack. Particulate emissions are 

controlled by a Torit fabric filter dust collector. The collection 

efficiency of the exhaust system is 70 percent, while the control 

efficiency of the control device is 99.9 percent. 

Particulate Matter (PM) Emissions 

a. LIMITATIONS 

(1) The emission of particulate matter may not exceed 3.40 

pounds per hour. [ss. NR 415.05(1)(o) and NR 415.05(2), 

Wis. Adm. Code] 

The allowable emission of PM is calculated by the use of 

equation E = 3.59 P0*

62 for process weight rates up to 60,000 

pounds per hour. E is the allowable emission in units of 

pounds per hour and P is the process weight rate expressed 

in units of tons per hour. 

(2) The permittee shall operate a particulate control device 

whenever any of the equipment described by process P33 

(e.g., 1 corner router, 1 surface router, 1 single-spindle 

drill press, 2 multi-spindle drill presses, and 2 belt 

sanders) is used. [s. 285.65(7), Wis. Stats, (formerly s. 

144.394(7), Wis. Stats.)] 

b. COMPLIANCE DEMONSTRATION 

The permittee shall monitor the pressure drop across the 

particulate collection device (i.e., Torit Downflo Model 2DF12 

Unit) at a minimum of once every eight (8) hours of operation or 

once per day, whichever yields the greater number of measurements, 

[s. 407.09(4)(a)3b., Wis. Adm. Code] 

C. REFERENCE TEST METHODS, RECORDKEEPING AND MONITORING REQUIREMENTS 

(1) Whenever PM.compliance emission testing is required, Method 

5 (including backhalf) or Method 17 in 40 CFR part 60, 

Appendix A, or Method 202 in 40 CFR part 51, Appendix M, 

shall be used. [s.NR 439.06(1), Wis. Adm. Code] 

(2) The permittee shall maintain daily records, or a database, 

of the pressure drop measurements across the particulate 

collection device (i.e., Torit Downflo Model 2DF12 Unit). 

All measurements shall be recorded in units of inches of 

water. Measurements shall be made, at a minimum, once every 

eight (8) hours of operation or once per day, whichever 

yields the greater number of measurements. [ss. NR 

407.09(1)(c)lb and NR 439.055(1)(a), and NR 439.055(2)(b)1, 

Wis. Adm. Code] 

January 16, 1997 Page 6 

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Visible Emissions 

a. LIMITATIONS 

Particulate matter emissions may not exceed 20 percent opacity or 

number 1 of the Ringlemann chart, [s. NR 431.04(2), Wis. Adm. 

Code] 

b. COMPLIANCE DEMONSTRATION 

See the compliance demonstration section for particulate matter in 

Section B.l.b. in Part I of this permit. 

c. REFERENCE TEST METHODS, RECORDKEEPING AND MONITORING REQUIREMENTS 

(1) Whenever visible emission testing is required, Method 9 in 

40 CFR part 60, Appendix A, shall be used. [s. NR 

439.055(9)(a)l, Wis. Adm. Code] 

(2)' See the recordkeeping and monitoring requirements in Section 

i B.l.c(2) in Part I of this permit. 

January 16, 1997i Page 7 

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Stack S30, Process P35 - A manual screen printing press and air-dried 

drying racks used to produce custom graphics. The process line was 

installed, or last modified, in November of 1992. Stack S30 represents 

the dummy stack. Air emissions are released as indoor fugitives. 

Volatile Organic Compound (VOC) Emissions 

a. LIMITATIONS 

(1) The permittee may not cause, allow, or permit organic 

compound emissions into the ambient air which substantially 

contribute to the exceeding of an air standard or cause air 

pollution, [s. NR 419.03, Wis. Adm. Code]. 

(2) The monthly usage of all inks, coatings, thinning solvents, 

and retarding agents delivered to the applicator may not 

exceed 3.0 gallons, excluding water, [s. 285.65(7), Wis. 

Stats, (formerly s. 144.394(7), Wis. Stats.)] 

(3) The monthly usage of VOC may not exceed 21.0 pounds from the 

usage of cleanup solvents to clean equipment and screens, 

[s. 285.65(7), Wis. Stats, (formerly s. 144.394(7), Wis. 

Stats.)] 

b. COMPLIANCE DEMONSTRATION 

(1) The permittee shall determine, prior to its application, 

either analytically or through the use of published 

literature (e.g., MSDS), the pounds of VOC per gallon, 

excluding water, and density (if needed) of each ink, 

coating, thinning solvent, retarding agent, and cleanup 

solvent used. [s. NR 407.09(4)(a)3b, Wis. Adm. Code] 

(2) The permittee shall determine, on daily basis, the total 

volume or weight of each ink, coating, thinning solvent, and 

retarding agent delivered to the applicator each day and 

each equipment and screen cleanup solvent used each day, in 

units of gallons (excluding water), pounds, or grams. If a 

weight measurement is used to record usage, the density of 

the material must be recorded in units sufficient to convert 

the weight measurement into units of gallons, excluding 

water. [s. NR 407.09(4)(a)3b, Wis. Adm. Code] 

(3) The permittee shall determine, on monthly basis, the total 

volume 6 f all inks',' coat ings", thinning" solvent s, and 

retarding agents delivered to the applicator each month, in 

units of gallons, excluding water. [s. NR 407.09(4)(a)3b, 

Wis. Adm. Code] 

(4) The permittee shall determine, on monthly basis, the total 

weight of all VOCs used each month from the usage of cleanup 

solvents used to clean equipment and screens, in units of 

pounds. [s. NR 407.09(4)(a)3b, Wis. Adm. Code] 

January 16, 1997 Page 8 
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c. REFERENCE TEST METHODS, RECORDKEEPING AND MONITORING REQUIREMENTS 

(1) Whenever VOC content or density compliance testing is 

required, USEPA Method 24 or Method 24A shall be used. [s. 

NR 439.06(3)(b), Wis. Adm. Code] 

(2) The permittee shall maintain daily records, or a database, 

of the following information: 

(a) A unique name or identification of each ink, coating, 

thinning solvent, retarding agent, and cleanup solvent 

used; 

(b) The VOC content of each ink, coating, thinning solvent 

and retarding agent delivered to the applicator, and 

each cleanup solvent used to clean equipment and 

screens, in units of pounds of per gallon, excluding 

water. The permittee shall determine, prior to its 

use, either analytically or through published 

literature (e.g., MSDS), the VOC content of each 

material used; and 

(c) The total volume or weight of each ink, coating, 

thinning solvent, and retarding agent delivered to the 

applicator each day and each equipment and screen 

cleanup solvent used each day, in units of gallons 

(excluding water), pounds, or grams. If a weight 

measurement is used to record usage, the density of 

the material must be recorded in units sufficient to 

convert the weight measurement into units of gallons, 

excluding water. 

[ss. NR 407.09(1) (c)lb, NR 439.04(1) (d), and NR 439.04(4) 

(a), (b), and (c), Wis. Adm. Code] 

The permittee shall maintain monthly records, or a database, 

of the following information: 

(a) A unique name or identification of each ink, coating, 

thinning solvent, retarding agent, and cleanup solvent 

used; 

(b) The total volume of all inks, coatings, thinning 

solvents, and retarding agents delivered to the 

applicator each month in units of gallons, excluding 

water; and 

(3) 

(c) The total weight of VOC used each month from the usage 

of all cleanup solvents to clean equipment and 

screens, in units of pounds. 

Records must be maintained such that the individual usage 

and cumulative usage of all inks, coatings, thinning 

solvents, and retarding agents delivered to the applicator 

and all VOCs used from the usage of equipment and screen 

cleanup solvents can be readily and accurately determined on 

a monthly basis. The records shall be compiled by the 

fifteenth (15th) day of the following month. [ss. NR 

407.09(1)(c)lb and NR 439.04(1)(d), Wis. Adm. Code] 

January 16, 1997 Page 9 

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D. OTHER CONDITIONS APPLICABLE TO THE ENTIRE FACILITY 

1. Monitoring Reports 

(a) The permittee shall submit the results of monitoring or a summary 

of monitoring results required by this permit to the Department 

every 6 months. 

(b) The time periods to be addressed by the submittals are January 1 

to June 30 and July 1 to December 31. 

(c) The report shall be submitted to the District or Area Office 

within 45 days after the end of each reporting period. 

(d) All deviations from and violations of applicable requirements 

shall be clearly identified in the submittal. 

(e) Each submittal shall be certified by a responsible official 

as to the truth, accuracy and completeness of the report. 

[s. NR 439.03(1)(b), Wis. Adm. Code] 

2. Compliance Certification 

(a) The permittee shall submit annual certification of compliance 

with the requirements of this permit to the Wisconsin Department 

of Natural Resources, Southeast Region, 2300 N. Dr. ML King Jr. 

Drive, P.O. Box 12436, Milwaukee, WI 53212, phone (414) 263-8500 

and to Compliance Data - Wisconsin, Air and Radiation Division, 

USEPA, 77 W. Jackson, Chicago, IL 60604. 

(b) The time period to be addressed by the report is January 1 to 

December 31. 

(c) The report shall be submitted to the Air Management Section, 

Wisconsin Department of Natural Resources, Southeast Region, 2300 

N. Dr. ML King Jr. Drive, P.O. Box 12436, Milwaukee, WI 53212 and 

U.S. EPA within 45 days after the end of each reporting period. 

(d) The information included in the report shall comply with the 

requirements of Part II Section N of this permit. 

(e) Each report shall be certified by a responsible official as to the 

truth, accuracy and completeness of the report. 

[s. NR 439.03(1)(c), Wis. Adm. Code] 

January 16, 1997 Page 10 

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Inspection Report TAZ 

06/26/96 

Page 1/2 

BRADY USA FID # 241270810 

Cameron Avenue Facility 

3328 W. Cameron Avenue 

Milwaukee, WI 

Attendants: Tom Zelinski -DNR 

Janeen Jackson - Brady 

? - Plant Manager 

On the morning of June 26, a meeting was held with Brady U.S.A. to discuss the 

status of their Title V permit and to conduct a brief walk through tour of their 

facility. 

A short meeting was held prior to the tour. The first item discussed was the 

purpose of the inspection. It was explained that the intent of the tour is 

limited. I wanted to review the list of insignificant units described in the 

application, to look at the particulate collection device, and to briefly tour 

the three significant emission units (P30, Fiber glass coating; P33, Finishing 

operations; and P35, Screen Printing). 

During the meeting, copies of the PD (06/19) and Draft Permit (06/25) were given 

to Janeen for her review. It was explained that these documents were generated 

based upon the information submitted with the permit application. I asked her 

to review these documents and to let me know of any errors or changes needed. 

We briefly reviewed each document. While reviewing the PD, I focused on the 

insignificant units. The 36-gallon soak tank is used to clean coating parts from 

the fiberglass coating line. Dibasic Ester is the cleaning solvent. An MSDS was 

provided. It is estimated that the maximum usage of solvent is approximately 

1000 pounds per year. The shop only operates 250 days per year. Based upon this 

number, and the fact one cleanup per day is only required whether or not the unit 

operates one or 24 hours, the MTE of Dibasic Ester is estimated at 1460 pounds 

per year [1000 gal/yr X (365 dy/yr / 250 dy/yr)]. The unit is insignificant. 

Although insignificant, the unit may still be subject to the rules for cold 

cleaning in Chapter NR 423. It was also mentioned that some solvent, presently 

Acetone, is used at the facility to periodically to spot clean equipment. The 

cleanup solvent, is stored in containers that prevent evaporation. The containers 

are stored in solvent storage cabnits. Solvent (e.g., Acetone) is received in 

55-gallon drums and dispensed from the drum into smaller containers. At the 

facility is also a 6000-gallon underground styrene resin storage tank. The 

existing tank is soon to be replaced with an above ground tank of similar size. 

VOC emission estimates from these tanks were done by the source. Using tank 

calculations the source estimated the maximum emission of styrene from the old 

and new tanks at 1185 lbs/yr and 1427 lbs/yr, respectively. The resin storage 

tank is a insignificant emission source. Another unit present at the facility, 

but not mentioned in the application, are the mechanical shears used to cut the 

cured fiberglass substrate. Little, if any, PM emissions are generated during 

the cutting process. No VOCs are emitted. 

After discussing the insignificant units in the PD, we briefly reviewed the 

conditions and compliance demonstration requirements in the draft permit (06/19 

version). At this time, it was explained the allowable VOC emissions from the 

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P.13 

remove pilot resin line, or 130 pounds per month, was being transferred to the 

Inspection Report TAZ 

06/26/96 

Page 2/2 

BRADY USA FID # 241270810 

allowable usage of cleanup solvents for the fiberglass coating line. It was also 

mentioned that cleanup usage limits were being changed from gallons of solvent 

used to pounds of VOC used. This is being done to allow the source more 

flexibility. They presently use acetone, a non-VOC, as a cleanup solvent. An 

item of contention was the emission limit used for the styrene coating line. The 

source feels the emission result obtained by the weight loss test overstates the 

true VOC emissions. It was mentioned that AP-42's emission factors are much 

lower. I explained I am suppose to use actual testing data over AP-42 emission 

factors, and that the emission limit of 1.35 is a carryover limitation from a 

previous permit. Existing permit conditions cannot be changed unless more 

information is available and the limitation is nolonger applicable. I mentioned 

to the source they alway have the option to repeat the study, if they believe the 

results overstate their true emissions. Janeen will further review the draft 

permit provided and let me know if there are any problems. She also mentioned 

that the electric curing oven has been replaced with a 1.2 mmBTU/hr natural gas 

fired oven. The oven blower has also changed. She will provide me with the 

changes in a letter. Included in the letter will be their acceptance to the 

changes I mentioned in their permit conditions. 

After our meeting a brief tour of the facility was made. Everything appeared in 

order. The particulate collection device has a gauge which measures the pressure 

drop. The screen printing press was not being used. All ink and solvent 

containers were sealed or stored in containers that prevent evaporation. The 

fiberglass coating line was operating. The process is very much like it was 

described in the application. The graphics are printed on paper sheets and 

encapsulated into the fiberglass composite before the cure. The cured sheet is 

manually cut into sheets and placed on carts. The finishing operations uses spot 

ventilation to collect the PM emissions. The facility is basically in good 

order. Fugitive sytrene is very apparent in the plant air. 

TAZ 

12 
P.M 

ANALYSIS. PRELIMINARY DETERMINATION AND DRAFT PERMIT 

for 

BRADY U.S.A. - Cameron Avenue Facility 

Located at 

3328 W. Cameron Avenue 

Milwaukee 

Milwaukee County, Wisconsin 

on the operation of 

Fiberglass Sign Production Facility 

This review was performed by the Wisconsin Department of Natural Resources in 

accordance with Sections 144.391 to 144.394, Wis. Stats., and Chapter NR 407, 

Wis. Adm. Code. This review is for a major Part-70 source located in an area 

which is designated nonattainment for Ozone and attainment/unclassified for 

all other criteria pollutants. 

Air Pollution Control Operation Permit 24127081O-P01 

Analysis, Preliminary Determination 

and Draft Permit prepared by: Thomas Zelinski/s/ Date August 27. 1996 

Approval Element 

'Preliminary 

Determination 

Document 

(including 

calculations) 

'Applicable 

Requirements 

'Compliance 

Demonstration Methods 

(compliance inspector concurrence) 

*Compliance Plan and 

Schedule 

^Federal 

Enforceability of 

Permit Conditions 

(for synthetic minor conditions) 

Initials and 

Date 

DHS /s/ 

09/12/96 

DHS /s/ 

09/12/96 

GAV /s/ 

09/06/96 

N/A TAZ /s/ 

08/27/96 

N?A TAZ Ys/ 

08/27/96 

Approved for Public Review and Comment: Daniel Schramm /s/ Data: 09/12/96 

cc: AM/7-0P 

Milwaukee Public Library 

814 W. Wisconsin Avenue 

Milwaukee, WI 53233 

August 27, 1996 Page 1 

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P.15 

INTRODUCTION 

Sources which are not exempt from the operation permit requirements under 

Section NR 407.03, Wis. Adm. Code, are required to obtain an air pollution 

control operation permit. Sources subject to the requirements must submit a 

permit application to the Department of Natural Resources by the date set 

forth in Sections 144.374(2)(a), Wis. Stats., and NR 407.04, Wis. Adm. Code. 

The application is then reviewed following the provisions set forth in 

Sections 144.3925, 144.393, and 144.3935, Wis. Stats., and Chapter NR 407, 

Wis. Adm. Code. 

Subject sources are to be reviewed for their air pollution control technology 

and for their impact upon the air quality. This is to insure compliance with 

all applicable rules and statutory requirements. The review will show why the 

source's operation should be approved, conditionally approved, or disapproved. 

It will encompass emission calculations and air quality analysis using U.S. 

EPA models, if applicable. Emissions from volatile organic compound (VOC) 

sources and small sources whose emissions are known to be insignificant are 

normally not modeled. As a precautionary note, the emission estimates may be 

based on U.S. -EPA emission factors (AP-42) or theoretical data and can vary 

from actual stack test data. 

This review is based on information contained within the application submitted 

for an air pollution control operation permit. An operation permit may be 

issued following the criteria set forth in Sections 144.393 and 144.3935, Wis. 

Stats., are met. 

A final decision on the operation permit will not be made until the public has 

had an opportunity to comment on the Department's analysis, preliminary 

determination and draft permit. The conditions proposed in the draft permit 

may be revised in any final permit issued based on comments received or 

further evaluation by the Department. 

Owner/Operator: W. H. Brady Company 

6555 W. Good Hope Road 

Milwaukee, WI 53223-2131 

Responsible Official: Tom J. Felmer 

General Manager 

(414)358-6600 

Permit Contact Person: Janeen E Jackson 

Environmental Engineer 

(414)358-6600 

Date of Administratively Complete Application: 05/24/95 

Dates of Submittal: May 24, 1995 (Application received at SED), June 26, 1996 

(Site inspection report), July 1, 1996 (S10 Stack 

information), July 26, 1996 (phone conversation), and 

July 26, 1996 (PTE limitations). 

August 27, 1996 Page 2 

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P.16 

SOURCE DESCRIPTION 

Brady U.S.A., Incorporated operates a facility known as their Signmark" 

Division (Cameron Avenue Facility). The facility manufactures fiberglass 

signs. 

Located within the facility are three significant air pollutant emission 

sources. These sources are: 

Process 

££U£££ Stack Unit 

O'Hare Fiberglass Sign Production Line SIO P30 

Miscellaneous Finishing Operations S14 P33 

Medalist Screen Printing Press S30 P35 

The O'Hare Line (process P30) is a custom-designed process line used to 

produce cured fiberglass sheeting. Woven fiberglass webbing is coated with a 

reactive styrene-based resin and oven cured. The bulk styrene resin is stored 

in a 6000-gallon underground storage tank. When needed, the day's resin 

requirement is transferred from the bulk tank to smaller indoor mixing tanks. 

In the smaller tanks, the resin is mixed and heated. The heated resin is 

mechanically applied to the sheets of fiberglass webbing and temperature 

cured. Graphics are applied between two sheets of the coated webbing prior to 

oven curing. The curing oven is natural gas fired. The indoor mixing tanks, 

the coating operations, and the curing oven are all separately exhausted to 

the outside ambient air through fixed stacks. Stack SIO*represents a 

composite of these three stacks. 

Several different finishing operations are performed to machine the cured 

fiberglass sheeting into the finished product, informational signs. Process 

P33 represents the combination of these miscellaneous finishing operations. 

Process P33 includes two routers (one for cornering and one for shaping), 

three drill presses (one single-spindle and two multi-spindle), and two belt 

sanders. The particulate emissions from these operations are exhausted to the 

outside ambient air through a fixed stack, Stack S33. A baghouse style 

control device is used to reduce the exhausted particulate emissions from this 

stack. 

A manually operated sheet fed screen printing press (process P35) is also 

available to custom manufacture graphics for the signs. The screen printing 

press is a small single sheet feed press. Only solvent-based inks are used. 

The printed materials are air dried within the facility on designated drying 

racks. The air emissions from the usage of inks, thinning agents, retarding 

agents, and cleanup solvents are not exhausted outside the building, but 

instead are released as indoor fugitives (Stack S30). 

Site Description: 

All manufacturing and converting operations are performed in a single building 

located on a 1.23-acre parcel of land in the City of Milwaukee. The facility 

is located at 3328 West Cameron Avenue, north of Hampton Avenue and south of 

Villard Avenue. Railroad tracks define the east property line. The 

surrounding area is residential. Milwaukee County is designated a severe 

ozone nonattainment area. 

August 27, 1996 Page 3 

ft 
P.17 

SIGNIFICANT EMISSION SOURCES: 

STACK INFORMATION 

Stack Identification Number: 

Exhausting Unit(s): 

This stack has an actual exhaust point: 

Discharge height above ground level (ft) 

Inside dimensions at outlet (ft): 

Exhaust flow rate (Normal) (ACFM): 

Exhaust gas temperature (Normal) (°F): 

Exhaust gas discharge direction: 

Stack equipped with any obstruction: 

Emission Unit Information 

Process number: 

Unit description: O'Hare fiberglass coating line, 

natural gas curing oven. 

Control technology status: 

Date of construction or last modification: 

=0= 

Raw materials 

=D= 

Maximum Usage 

Styrene Resin 

Cleanup Solvent 

r 

Product 

Signs 

392,250 gals/yr 

1,570 gals/yr 

T 

Maximum Output 

881 signs/yr 

SIO 

P30 

Yes (Composite) 

29.5 

Circular - 1.38 

1,908 

84 

Up 

No 

P30 

equipped with a 

Uncontrolled 

March 1978 

2. STACK INFORMATION 

Stack Identification Number: 

Exhausting Unit(s): 

This stack has an actual exhaust point: 

Discharge height above ground level (ft): 

Inside dimensions at outlet (ft): 

Exhaust flow rate (Normal)" (ACFM) r 

Exhaust gas temperature (Normal) (°F): 

Exhaust gas discharge direction: 

Stack equipped with any obstruction: 

A. Emission Unit Information 

S14 

P33 

Yes 

25.0 

Circular 

4,-800 

70 

Up 

No 

-1.30 

Process number: 

Unit description: 

P33 

Miscellaneous finishing operations: one single 

spindle drill press, two multi-spindle drill 

presses, one round corner router, one shaping 

router, and two belt sanders. 

August 27, 1996 Page 4 

lb 
P.18 

Control technology status: 

Date of construction or last modification: 

=D= 

Controlled 

August 1979 

Product 

0= 

Maximum Output 

Signs 500 signs/hr* 

The maximum production rate is dependent upon the specific operation being 

performed (Corner router and belt sander 500 signs/hr, multi-spindle drill 

press 350 signs/hr, single-spindle drill press 150 signs/hr, and shaping 

router 30 signs/hr). 

Control devices associated with this emissions unit 

Emission unit controlled: 

Control device number: 

Date of installation: 

Description of device: 

P33 

C33 

1986 

Particulate matter emissions are controlled with 

the use of a Torit Downflo Model 2DF12 

particulate control device manufactured by 

Donaldson Company, Inc. 

Pollutant(s) controlled 

Capture Hood(s) 

Particulate Matter (PM) 

Efficiency (%) 

70.0 

99.9 

Pressure drop across the filter (inches of H20) 

Filter medium or type of material: 

Maximum inlet gas flow rate (ACFM): 

Maximum inlet gas temperature (°F) : 

Number of cartridges: 

Dimensions of cartridges: 

STACK INFORMATION 

1 - 6 

Ultra-web 

4,800 

70 

12 

13.8 Dia x 26 

Stack Identification Number: 

Exhausting Unit(s): 

This stack has an actual exhaust point: 

S30 

P35 

No (Fugitive) 

A. Emission Unit Information 

Process number: P30 

Unit description: SP-5 sheet fed screen printing press with 

Air-dried drying racks. 

Operation type: 

Curing Oven: 

Control technology status: 

Date of construction or last modification: 

Screen Printing 

No 

Uncontrolled 

November 1992 

August 27, 1996 Page 5 

in 
P.19 

0 

Raw materials I Maximum Usage 

=0= 

Inks 

Thinning Agents 

Retarding Agents 

Cleanup Solvents 

1,185 gals/yr 

127 gals/yr 

39 gals/yr 

1,730 gals/yr 

INSIGNIFICANT EMISSION SOURCES: 

Maintenance of Grounds, Equipment, and Buildings 

Deminerization and Oxygen Scavenging of Water for Boilers 

Purging of Natural Gas Lines 

Boiler, Turbine, and HVAC System Maintenance 

Internal Combustion Engine Used for Warehouse and Material Transport 

Fire Control Equipment 

Janitorial Services 

Office Activities 

Convenience Water Heating (< 5 mmBtu/hr Burning Gas - 3-0.8 mmBtu/hr) 

Sanitary Sewer and Plumbing Venting 

Pollution Control Equipment Maintenance 

DBE Soak Tank (36-gallon parts cleaner) 

Miscellaneous Solvent Cleanup 

Resin Tank Storage (6000-gallon) 

Coating and Solvent Storage 

Composite Cutting Operation 

INSIGNIFICANT EMISSION SOURCE DESCRIPTION: 

The source identified several insignificant air emission units and activities 

other than those normally identified on form 4530-102B in the application. 

These emission units and activities are described below in greater detail. 

DBE Soak Tank (36-gallon parts cleaner) 

An organic solvent soak tank is used to clean residual resin from the coating 

heads of the O'Hare line. The soak tank is equipped with a flip-top lid. The 

tank is not vented. Solvent emissions are released as indoor fugitives. The 

organic solvent is Dupont Dibasic Ester (DBE) blend. The solvent blend does 

not contain any organic HAPs. The solvent blend has a relatively low 

evaporation fate," less than 0.10 (n-Butyl Acetate = l). The source estimates 

their yearly usage at 1,000 pounds per year. Since the coating line is 

cleaned once per day no matter if the line runs 1 hour or 23 hours, the line's 

MTE VOC is estimated at 1,460 pounds per year [1000 lbs/yr x (365 dys/yr .* 250 

dys/yr) •= 1,460 lbs/yr]. The emission unit is insignificant for the emission 

of VOC. 

Miscellaneous Solvent Cleanup 

Organic solvents (e.g., Acetone) are used throughout the plant to spot clean 

equipment. Actual cleanup solvent usage is quite low. The solvent is 

manually dispensed from the larger containers into individual squirt bottles 

or smaller personal containers. All containers are covered and designed to 

prevent evaporation into the atmosphere. Organic solvent emissions are 

insignificant (MTE is estimated at less than 100 lbs/yr). Acetone, a VOC 

exempt organic solvent, is presently used. 

August 27, 1996 Page 6 

ll 
P.20 

Resin Storage Tank (6000 gallons) 

An underground tank is located at the facility for the bulk storage of the 

styrene-based resin. Plans are to remove the underground tank and replace it 

with an above ground tank of similar size. Estimated tank emissions of VOCs 

are 1,185 pounds per year for the underground tank and 1,427 pounds per year 

for the proposed above ground tank. Tank emissions were estimated using 

standard tank calculations and provided by the source. The estimates are 

presumed to be the tanks' MTE estimates. 

Coating and Solvent Storage 

Various inks, coatings, and organic solvents are stored within the facility. 

The solvent and coating containers are sealed while being stored. Bulk 

solvent (e.g., Acetone) is also stored at times within the facility in 55-

gallon drums. Bulk solvent is dispensed from these drums to smaller 

containers (less than 1 gallon). The solvent is used for spot cleaning of 

equipment. VOC emissions are considered insignificant (MTE is estimated at 

less than 200 pounds per year). 

Composite Cutting Operations 

Mechanically the cured composite sheeting is cut (divided) into smaller 

pieces. The shearing process is rather slow and emits minimal particulate 

matter. No VOC1 emissions occur. The operation is an insignificant PM 

emission source. 

CROSS MEDIA IMPACTS 

The cross media impact of the facility and its operations were not analyzed in 

great detail. A minimal cross media impact is anticipated. Used cleaning 

solvent, ink, and coating containers and related liquid wastes are shipped 

off-site for disposal. The particulate matter waste collected from the sign 

machining operations is disposed of as nonhazardous waste. 

SOURCE SPECIFIC EMISSION LIMIT CALCULATIONS 

The facility manufactures industrial fiberglass signs. A fiberglass cured 

sytrene-based resin composite is the substrate for the signs produced. The 

source uses a custom built and designed coating line (O'Hare Line - Process 

P30) to manufacture the cured fiberglass/resin substrate. Between two layers 

of fiberglass webbing.the sign's graphics are inserted before the composite is 

cured. The O'Hare process line coats the fiberglass webs with resin, applies 

the graphic sheets (decals) and temperature cures the composite. The cured 

"'c"61iiposlte7~"6r~'^ub'stFat"e/ is then ''mamTalTy machined into the finished product 

(signs). A series of miscellaneous finishing operations is performed to 

machine the cured substrate. These finishing activities (Process P33) include 

hole drilling (one single-spindle drill press and two multi-spindle drill 

presses), shaping (one corner router and one shaping router) and sanding (two 

belt sanders). The graphics, or decals, are either purchased or manufactured 

in-house. The facility has on the site a small sheet fed screen printing 

press used to manufacture custom graphics (Process P35). The air emissions 

from Process P30 (fiberglass coating line) and Process P33 (finishing 

operations) are exhausted to the outside ambient air through fixed stacks. A 

baghouse style control device is used to control the particulate matter (PM) 

emissions generated from the miscellaneous finishing operations. Air 

emissions from the screen printing operation are not exhausted; they are 

released as indoor fugitives. 

August 27, 1996 Page 7 

19 
P.21 

In the permit application, the maximum raw material usage rates or the maximum 

production capacities are specified for each process. A supplement section 

was provided with the original application detailing how these rates and 

capacities were determined. These calculations have been reviewed and found 

to be consistent with the emissions from similar industrial operations. This 

permit supplement is available upon request. 

To estimate the source's maximum emissions one takes into account not only the 

equipment's physical limitations, but also any limitations due to the chemical 

nature of the raw materials used. From these maximum usages or production 

capacities the units' Maximum Theoretical Emissions (MTEs) can be estimated. 

An operational year of 8760 hours is assumed. As part of the 8760 hours of 

operation, the average hours per year spent setting up and cleaning up 

equipment, between production runs, are included. Both fiberglass coating 

(Process P30) and screen printing (Process P35) have setup and cleanup times 

associated with them. When the equipment's usage is limited by the 

availability of raw material, a different approach is needed. In this 

facility, some of the equipment used to perform the miscellaneous finishing 

operations, or activities, are limited not by the design capacity of the 

individual equipment, but by the availability of cured fiberglass substrate. 

Since all cured fiberglass substrate is produced internally and the finishing 

equipment is used solely for the machining of the cured fiberglass, the 

production of cured fiberglass from the coating line (process P30) can be 

emission limiting. 

Below, in Table 1, the MTEs of particulate matter (PM), volatile organic 

compounds (VOCs), and hazardous air pollutants (HAPs) are summarized for not 

only the individual emission units, but for the facility. The air pollutant 

emissions are estimated using supplier information (Material Safety Data 

Sheets) ahd internal test results. Emissions from accessory equipment (e.g., 

curing ovens) and activities (e.g., cleanups) are included. 

Table 1 Maximum Theoretical Emissions (lbs/yr): 

PpUutant; 

PM 

voc 

Ethyl Benzene 

Styrene 

Toluene 

Xylene 

Resin Coating 

Process P30 

0 

528,000 

0 

518,000 

0 

0 

Sign Finishing 

Process P33 

33,100 

0 

0 

0 

0 

0 

Screen Printing 

Process P35 

0 

18,300 

124 

0 

7,560 

1,960 

Total 

Facility 

33,100 

546,300 

124 

518,000 

7,560 

1,960 

When estimating the fiberglass coating line's emissions (Process P30), the 

reactive nature of the styrene-based monomer is considered;The coating resin 

is 28 - 33 percent styrene monomer, but styrene is also temperature reactive. 

Some of the monomer is polymerized as part of the temperature curing process. 

A weight by difference study was conducted by the source's R&D staff to 

determine the actual amount of VOC, or styrene, lost during coating and curing 

of the resin (Process P30). The test results showed, under normal operating 

conditions, 1.32 pounds of VOC, or styrene, per gallon of resin applied is 

lost. VOCs from process P30 are released as both fugitive and stacked 

emissions. Because of the fugitive nature of some of the emissions, the 

source originally underestimated the emissions of VOC, or styrene, from,the 

fiberglass coating line (0.8 pounds per gallon). This emission estimate was 

used as a basis in Permit 90-DAA-227. However, as a result of the weight-loss 

test became known, the allowable emission limitation was changed to 1.35 

pounds of VOC per gallon of resin applied and a new permit was issued (Permit 

92-DAA-296). Permit 92-DAA-296 superseded Permit 90-DAA-227. When estimating 

styrene emissions, the worst case is assumed; all process P30 VOC emissions 

August 27, 1996 Page 8 

•3.D 
P.22 

are assumed to be styrene-monomer. The emission rate of 1.32 pounds of VOC, 

or styrene, per gallon applied is used to calculate the coating line's MTE of 

both VOC and styrene. The process P30's curing oven is a small natural gas 

fired oven (1.2 mmBTU/hr); therefore, the oven's air emissions are assumed to 

be insignificant and ignored. 

The MTE calculations for the miscellaneous sign finishing activities (Process 

P33), or PM emissions, are based directly upon the average amount of material 

removed from the cured fiberglass substrate during machining. The worst case 

is assumed. The weight of particulate matter emitted is equal to the weight 

of material removed. The maximum availability of cured fiberglass composite 

is also taken into account when determining the operation's MTE. Depending 

upon the specific activity being performed (e.g., sanding, drilling, 

cornering, and shaping), the MTE is either limited by the maximum production 

rate of the specific piece of equipment or the availability of composite. No 

distinction is made whether or not all finishing operations are normally 

performed on a single sign. The worst case is assumed; all signs are drilled, 

sanded, and either shaped or cornered. Shaping refers to making the sign 

round; therefore, a sign that is shaped cannot be cornered and vice versa. 

Shaping and cornering cannot be performed on the same sign. 

Estimation of the screen printing operation's MTE (Process P35), both VOC and 

HAPs, is relatively straightforward. PM emissions are insignificant and VOC 

emissions equal the amounts of VOC contained in the inks applied. The source 

takes into account any physical restrictions when determining the process 

line's MTE. The process line's maximum output is limited ultimately by the 

amount of available drying rack space available. A minimal two hours of air 

drying is required between runs. However, the equipment can still be solvent 

cleaned while the screen prints are drying. 

Condensible PM emissions are considered insignificant for Process P30 and 

Process P35. Both processes are coating operations; the processing 

temperatures used are relatively low; no visual condensible emissions were 

apparent during an on-site visit of the facility; and the facility's case file 

history does not mention any previous problems with PM or visual emissions. 

Based upon the results in Table 1 and the individual pollutant inclusion 

levels published in Chapter NR 407, Table 2, Wis. Adm. Code, the facility is 

significant for the emission of PM, VOC, and Styrene. Each significant air 

pollutant has an MTE greater than the 2,000 pounds per year for a single 

emission unit and greater than 10,000'pounds per year for the facility (5 

times the unit's inclusion level). Only those pollutants which are 

significant and have applicable emission limits need to be addressed in Part I 

of the permit. The emission of insignificant pollutants and those significant 

pollutants without any applicable emissipn.limits are addressed in Part II of 

the permit. Ethyl BehzeTie, Toluene, and Xylene are insignificant pollutants. 

To fully address all applicable emission limitations or usage restrictions, 

each significant pollutant will be discussed separately, PM, VOC, and Styrene. 

This discussion will address, but is not limited to, existing emission 

limitations, conditions carried over from previous permits, changes being made 

to the carried over conditions, possible modeling restrictions, and the 

permit's impact on the source's Potential to Emit (PTE). 

Particulate Matter (PM) 

Only one emission source is significant for the emission of solid PM, 

processes P33 (Finishing operations). The other two significant emission 

units (fiberglass coating and screen printing) are insignificant for PM 

emissions, but significant for VOC emissions. Condensible PM emissions can be 

a concern with some VOC sources, but considering the fact that these 

August 27, 1996 Page 9 

y?i 
P.23 

operations involve low overspray application techniques (e.g., flow coating 

and printing), the operating temperatures are relatively low, fugitive 

emissions are significant, no visual emissions were detected during an on-site 

inspection, and PM and visual emissions have not been a problem in the past, 

they are considered insignificant and will not be included in part I of this 

permit. 

A "worst case" analysis is used when estimating Process P33's PM emissions, 

whatever amount of material is removed from the composite during processing 

is, or could be, released as PM. The MTE of PM for the P33 operation is 

represented by the sum of the MTEs for the various activities described by 

process P33. Each activity needs to be looked at individually. Each 

activity, or piece of equipment, has its own maximum production rate. Not all 

signs are processed in the identical fashion. Some require more processing. 

Others require less. The basis of an average sign is ultimately established 

to simplify this issue. For each finishing operation, the maximum production 

rate, or output, and the average amount of material removed, or PM emitted, 

are established on a per average sign basis. An average sign is described as 

1.0 square feet of composite weighing 0.77 pounds. Another factor, when 

estimating emissions over a year, is whether or not the supply of cured 

composite indirectly limits the emissions from these activities. Based upon 

the maximum production capacity of the 0'Hare fiberglass coating line, the 

maximum sign output rate of composite is 881 signs per hour. If a specific 

finishing operation's output capacity exceeds the availability of composite 

material, the availability of composite then becomes emission limiting when 

determining the activity's MTE. Table 2, below, summarizes not only the MTE 

of PM for the individual finishing operations, but also some of the major 

assumptions made. 

Table 2 Maximum Theoretical Emissions of PM (Process P33 - Finishing 

Operations) 

Operation 

Corner Router 

Multi spindle Drill 

Single-spindle Drill 

Shaping Router 

Belt Sander 

Number 

of 

Units* 

1 

2 

1 

1 

2 

Maximum 

Usage 

(sions/hr) 

500 

350 

150 

30 

500 / 

i 

Amount* 

Removed 

(ftZ/sign) 

0.00156 

0.00104 

0.00104 

0.03306 

0.00488 

Maximum Theoretical 

Emissions 

(lbs/hr) 

0.602 

0.559 

0.120 

0.764 

3.75 

.. 5.80 

Of PM 

Ubs/yj*;) 

5,260 

•4,450** 

1,050 

6,690 

20,900** 

33,090*** 

* The average surface density of the sign composite is 0.77 lbs/ft2. 

The annual emission calculations take into account the maximumoperating parameters of the P30 coating line [881 signs/hr, 6307 hrs/yr 

(15 hrs of coating/16.75 hrs & 20% scrap] or 5,556,000 signs per year. 

*** The sum for process P33 does not included the annual MTE emissions from 

the corner router. Since each sign is either shaped or cornered, the 

operation with the greatest annual MTE emissions (i.e., Shaping) is 

included when determining the process line's total annual emissions. 

Based upon these results, and the fact that no limitations exist that limits 

the facility's PTE PM to less than the MTE rate on hourly basis, the finishing 

operations, or Process P33, has a maximum uncontrolled emission rate of 5.80 

pounds of PM per hour. Process P33's emissions are exhausted through a fixed 

stack. The stacked emissions are controlled by a baghouse style particulate 

control device, a Torit Downflo system (Model 2DF4). The source reports a 70 

percent capture efficiency of the exhaust hood system and a PM control 

efficiency of 99.9 percent. Based upon these conditions, the operation has 

August 27, 1996 Page 10 

aa 
P.24 

PTE PM emissions of 1.74 pounds per hour of fugitives and 0.004 pounds per 

hour of stack emissions. Since the process operation was last modified, or 

constructed, in August of 1979 and the facility is not located in, or near, a 

TSP nonattainment area, the process weight equation PM emission limitation 

applies [s. NR 415.05(2), Wis. Adm. Code]. If the process weight emission 

limit is less restrictive than the fixed emission limit established in s. NR 

415.05(1), Wis. Adm. Code, the emission limit given in s. NR 415.05 (l)(o), 

Wis. Adm. Code, applies (0.40 pounds of particulate matter per 1,000 pounds of 

gas). Assuming each sign weighs 0.77 pounds and on an hourly basis and a 

maximum of 2,380 signs can be processed per hour, the process weight equation 

gives a maximum emission rate of 3.40 pounds per hour [3.59 x (2,380 signs/hr 

x 0.77 lbs/sign -5- 2000 lbs/ton)0-

62 = 3.40 lbs/hr]. Assuming an air density of 

0.075 pounds per cubic foot of exhaust gas at 70 degrees F and an exhaust flow 

rate of 4,800 acfm from Stack S14, the fixed emission limit is equivalent to a 

maximum PM emission limit of 8.64 pounds per hour [(0.40 lbs/1031bs of gas + 

1000 lbs of gas/1031bs of gas) x (0.075 lbs/ft3 x 4,800 ft3/min x 60 mins/hr) 

=-•8.64 lbs/hr]. Based upon these calculations, the process weight emission 

limitation is the most restrictive and the process is in compliance with the 

PM emission limit as long as the hood system and PM collection device are 

operating. To demonstrate compliance with the process equation PM emission 

limit the source will operate the baghouse style particulate control device. 

As specified under s. NR 439.055(2)(b), Wis. Adm. Code, the source must 

measure and record once for every eight (8) hours of operation or once per 

day, whichever yields the greater number of measurements, the pressure drop 

across the collection device in units of inches of water. The normal pressure 

drop across the system is 1 to 6 inches of water. Since this is a particulate 

source, and the opportunity for a visual emission is likely. Under s. NR 

431.05, Wis. Adm. Code, the source is required to limit their emissions to a 

shade or density no greater than number 1 of the Ringleman chart or 20 percent 

opacity. To demonstrate compliance with the visual emission limit the same 

compliance demonstration method used to comply with the PM emission limits 

will be used, the source will be required to operate the PM collection device 

whenever PM is being generated from Process P33. 

Based upon the usage of the PM collection (hood) and PM control (Downflo) 

systems and the fact that the operation of a particulate control device will 

be made federally enforceable by this permit, the source's PTE PM is less than 

its MTE level. In addition, in an existing permit (Permit 92-DAA-296) the 

source is limited to using only 12,000 gallons of styrene-based resin per 

month to produce composite material. Considering this limit, the fact that 

the production rate of the P30 coating line is 881 signs per hour at the 

maximum coating usage rate of 50 gallons per hour, and the process experiences 

a 20 percent scrap rate, the source is indirectly limited to producing only 

2,537,000 signs per year [12,000 gals/mon x 12 mons/yr x (881 signs/hr -r 50 

gals/hr) x (1 - 0.20 scrap) = 2,030,000 signs/yr]. From this annual number of 

sighs produced arid estimated 'amounts"of material removed per operation" per 

sign (Table 2), the unit's PTE PM with and without PM control can be 

determined. As stated earlier, only 70 percent of the PM emissions are 

collected by the hood system. That means 30 percent of the PM is released as 

fugitive emissions. Of the 70 percent that is captured, the control device is 

99.9 percent efficient at removing PM. Without controls and usage limits, the 

source has an MTE of PM of 33,100 pounds per year, or 16.6 tpy, for Process 

P33 (finishing operations). With the 12,000 gallons per month usage limit on 

the resin, the unit's PTE PM drops to 17,500 pounds per year, or 8.8 tpy. 

With the additional use of the PM collection and control systems, the unit's 

PTE PM is further reduced to 5,250 pounds per year, or 2.63 tpy. See Table 3, 

below, for more detail. 

August 27, 1996 Page 11 

<53 
P.25 

Table 3 Potential to Emit PM (Process P33, Finishing Operations) 

Number Maximum Amount* Potential to Emit PM 

of 

Operation Units 

Corner Router 1 

Multi spindle Drill 2 

Single-spindle Drill 1 

Shaping Router 1 

Belt Sander 2 

Usage 

(sons/hrl 

500 

350 

150 

30 

500 

Removed 

(ft2/sgn) 

0.00156 

0.00104 

0.00104 

0.03306 

0.00488 

w/o Control w/Control 

(M-P/Y-O** (lbs/yr.)*** 

2,440 733 

2,110 634 

1,050   316 ** ** 

6,690   2,010 ** ** 

7,630 2,290 

. 17,500 ***** 5,250 **** 

* The average surface density of the sign composite is 0.77 lbs/ft2. 

** PM emissions are indirectly limited by the gallons of resin used [12,000 

gals/mon x 12 mons/yr x (881 signs/hr + 50 gals/hr) x (1 - 0.20) = 

2,030,000 signs/yr]. 

*** 70 percent capture and 99.9 percent control. 

  Emissions are limited by the design capacity of the equipment. 

** *** The "totals" do not include emissions from the cornering operation since 

the emissions from the shaping operation are included. 

Based upon the unit's MTE, and considering this is the only unit significant 

for the emission of PM, the source is a natural minor for PM, less than 100 

tpy of PM-10. PM or TSP is not normally modeled by the department. Instead, 

the department relies upon the code, or PM emission limitations, to protect 

the PM ambient air quality standards. With the carry-over of the resin usage 

limit from Permit 92-DAA-296 and the required usage of the PM collection and 

control devices, the unit should be in compliance with the applicable PM 

emission limitations. 

Volatile Organic Compounds (VOCs) 

Two emission units are significant for the emission of volatile organic 

compounds (VOCs), Process P30 (Fiberglass coating) and Process P35 (Screen 

Printing) . Each unit has an individual MTE of VOC greater than 2000 pounds 

per year and a combined MTE greater than 10,000 pounds per year. 

When estimating an emission unit's emissions one must look at the complete 

operation of the process line. The time spent setting up and cleaning 

equipment must be included. During fiberglass coating a certain amount of 

time is spent setting up and cleaning the process line. When these operations 

are being performed, the system cannot be producing cured composite. The same 

is also true with screen printing. A certain amount of time is spent setting 

up equipment, thinning inks, mixing in ink retarders, cleaning the equipment 

and "screens',' and waiting for the printed sheets to dry. Although the time 

spent applying resin and ink may be limited, other VOC emitting activities can 

be performed (i.e., solvent cleaning equipment). The units' MTEs represents 

the sum of all VOC emitting activities. Overall, the units' MTEs are based 

upon maximum run sizes (13,200 square feet of composite every 16.75 hours and 

40 printed every 2.53 hours) and 8760 hours of operation per year. From this 

information, one is able to estimate the VOC emissions for each operation per 

process unit. The pertinent information is provided in an application 

supplement supplied by the source. Highlights are summarized below in Table 

4. 

August 27, 1996 Page 12 

M 
Table 4 Maximum Theoretical Emissions of Volatile Organic Compounds (VOCs) 

Fiberglass Coating (Process P30) : 

Time 

Operation (hrs/cvcle)(hrs/yeaff) 

Resin coating and curing 15.00 7845 

Equipment setup 1.00 523 

Equipment cleanup 0.75 392 

Screen Printing (Process P35) 

Operation 

Ink Application 

Thinning 

Retarding 

Equipment Cleanup 

Equipment Setup 

Time 

.hrs/cvcle, [______$_) 

0.53 

0.53 

0.53 

1.00 

1.00 

1835 

1835 

1835 

3462 

3462 

MTE Emission Rates 

(crcq/hg) (IbaVOC/hr) .lbsVOC/yr) 

50.0 66.0 518,000 

0.0 0.0 0 

4.0 26.4 10.000 

Subtotal 528,000 

MTE Emission Rates 

(__l___) (lbsVOC/hr) (lbsVOC/yr) 

0.644 2.64 4,850 

0.069 0.46 836 

0.021 0.14 254 

0.500 3.58 12,400 

0.0 0.0 a 

Subtotal 18,300 

Total 546,300 

Based upon these calculations, both fiberglass coating and the screen printing 

are significant for the emission of VOC. However, because the operations of 

the two VOC units differ, different emission limits apply. 

The fiberglass coating operation (Process P30) was constructed (March of 1978) 

before Milwaukee County was designated an ozone nonattainment area. After 

Milwaukee was designated an ozone nonattainment area, the source elected resin 

and cleanup solvent usage limitations to limit the source's emissions of VOC 

to synthetic minor status, less than 100 tpy of VOC. These limits were 

incorporated into an air pollution control permit (Permit #90-DAA-227). This 

permit assumed a VOC emission factor of 0.8 pounds of VOC emitted per gallon 

of resin applied. Later in 1992 the source found the emission factor used in 

the permit may be understating the source's actual VOC emissions. An in-house 

study indicated the actual VOC emissions to be possibly as high as 1.32 pounds 

per gallon of resin applied. The older VOC emission limitation in Permit 90-

DAA-227 could not be met. The source proposed to change the VOC emission 

limitation to 1.50 pounds of VOC per gallon of resin applied. Ultimately, an 

emission limitation, or factor, of 1.35 pounds of VOC per gallon of resin 

applied was adopted. At the same time the new emission limitation was being 

changed from 0.8 to 1.35 pounds of VOC per gallon of resin applied, the source 

submitted a permit application to remove several existing emission units (two 

pultrusion lines and one solvent degreaser) and to add a pilot fiberglass 

coating line (Process P36) and the screen printing line (Process P35). The 

source proposed thisr'combination of changes to make the permit 'revision' "a 

minor source modification. In all, the facility's allowable emissions of VOC 

increased by less than 25 tpy and the total allowable VOC emissions for the 

facility were less than lOOtpy. However, between the time the permit 

application was received and the new permit was issued, the major VOC source 

threshold level for Milwaukee County was reduced from 100 tpy to 25 tpy. The 

facility could no longer be a synthetic minor source, it was now considered a 

major VOC source. The source still retained their originally proposed 

limitations in the permit application to keep the permit revision a minor 

modification of a major source (less than a 25 tpy increase in allowable VOC 

emissions). Since the purpose of the elected limitations in Permit 92-DAA-296 

was to avoid making the addition of the screen printing and pilot fiberglass 

coating line a major modification of a major source, these conditions remain 

applicable and must be carried over into the new permit. Under s. NR 

407.09(2)(d), Wis. Adm. Code, any permit issued to a stationary source that 

has an existing air pollution control permit must have provisions in the new 

August 27, 1996 Page 13 

2*> 
P.27 

permit consistent with the original conditions, as long as the conditions in 

the older permit are still applicable to the source. The original permit 

conditions in Permit #92-DAA-296 are summarized below. 

O'Hare Fiberglass Coating Line (Process P30) 

1) The VOC content of any coating (resin) used may not exceed 1.35 pounds 

per gallon, less water. 

2) The monthly usage of resins may not exceed 12,000 gallons, averaged over 

the three most recent consecutive calendar months. 

3) The monthly usage of cleanup solvent may not exceed 200 pounds. 

O'Hare Pilot Fiberglass Coating Line (Process P36) 

1) The VOC content of any coating (resin) used may not exceed 1.35 pounds 

per gallon, less water. 

2) The monthly usage of resins may not exceed 22 gallons. 

3) The monthly usage of cleanup solvent may not exceed 100 pounds. 

Screen printing Press (Process P35) 

1) The monthly usage of ink may not exceed 3 gallons. 

2) The daily usage of ink may not exceed 2 gallons. 

3) The monthly usage of cleanup solvent may not exceed 3 gallons. 

Since Permit 92-DAA-296 was issued, the pilot fiberglass coating line (Process 

P36) has been removed. Because the pilot fiberglass line's allowable VOC 

emissions were used when determining and establishing the existing permit 

conditions, its allowable VOC emissions may be transferred over to the 

remaining units without changing the original basis for issuing Permit 92-DAA296. In other words, the usage limitations for the O'Hare fiberglass coating 

line and/or screen printing line may be increased. The increase in allowable 

VOC emissions may not exceed the amount allowed under Permit 92-DAA-296, or 

130 pounds of VOC per month [22 gal/mon x 1.35 lbsVOC/gal (Resin) + 100 

lbsVOC/mon (Cleanup) = 130 lbs/month]. The source elects to increase their 

allowable VOC emissions from the usage of cleanup solvents on the fiberglass 

coating line by 130 pounds of VOC per month. In addition, the source requests 

the conditions regarding the usage of cleanup solvents be changed from pounds 

used to pounds of VOC used. The source presently uses acetone, a non-VOC 

solvent""," as a cleanup solvent and feels the current wording of the condition 

unfairly penalizes them. 

In addition to the usage limitations, the VOC emission limitation from Permit 

92-DAA-296, limiting the allowable amount of VOC that can be emitted per 

gallon of resin applied, must be carried over into the new permit. The 

fiberglass coating line's usage of coating resins is also subject to a RACT 

emission limitation in s. NR 422.08(2)(a), Wis. Adm. Code. Under this 

section, a fabric coating line may not emit VOCs in excess of 2.9 pounds of 

gallon, excluding water, delivered to each applicator. This emission limit is 

not as restrictive as the permit emission limitation being carried over (1.35 

pounds of VOC emission per gallon of coating (resin), excluding water, as 

applied) from Permit 92-DAA-296. But the more restrictive permit limitation 

must be carried over. At the time this emission limitation was elected, the 

company elected a more restrictive emission limitation to keep the addition of 

the new line a minor modification to a major source. Under s. 144.394(7), 

August 27, 1996 Page 14 

X 0 
P.28 

Wis. Stats., the permittee is allowed to elect more stringent emission 

limitations than otherwise required. Since this election was made as part of 

Permit 92-DAA-296, it must be carried over into this permit. 

The only other significant VOC emission source at the facility is the screen 

printing operation (Process P35). The process line was relocated to this 

facility from their Glendale facility. The unit is rarely used. Because of 

its low utilization, the source elected rather restrictive raw material usage 

limitations to exempt the unit from Chapter NR 424, Wis. Adm. Code, emission 

limitations and to allow its relocation to be permitted as a minor 

modification to a major source (Permit 92-DAA-296). Because permit 92-DAA-296 

is still in effect and the limits are still applicable, the permit conditions, 

or monthly usage limits, must be carried over into this permit. The 

conditions in Permit 92-DAA-296, pertaining to the screen printing unit, are 

as follows: 

Screen Press SP-5 (Process P35) 

1) The monthly usage of ink may not exceed 3 gallons per month. 

2) The monthly usage of cleanup solvent may not exceed 3 gallons per month. 

3) The daily usage of ink may not exceed 2 gallons per day. 

Again, some minor revisions to these permit conditions are being made in this 

permit. First, the monthly limit on the usage of ink is being changed to read 

3.0 gallons, excluding water, as applied. This change is being made so the 

source is not penalized for using water-based inks and to insure the usage of 

thinning and retarding agents is included. Second, the category of ink is 

being expanded to read inks, coatings, thinning solvents, and retarding 

agents. Third, the condition regarding the usage of cleanup solvent is being 

changed from a gallon limit to pounds of VOC used limit. The new VOC usage 

limit will be 21 pounds per month [3 gal/mon x 7.16 lbsVOC/gal = 21 

lbsVOC/mon]. This way, the source is not penalized for using non-VOC cleaning 

solvents or water-based cleaning solvents. In the old permit, the 2-gallon 

coating limit was elected by the source so its daily VOC emission never 

exceeded 15 pounds per day. By keeping the screen printing line's actual VOC 

emissions below 15 pounds per day, the process line remains exempt from the 

emission limitations of s. NR 424.03(2), Wis. Adm. Code, under s. NR 

424.03(1)(a)4, Wis. Adm. Code. Instead, the unit is subject to the general 

VOC emission limitation given in s. NR 419.03, Wis. Adm. Code. As written, 

the 2-gallon limit on the usage of ink is insufficient to insure not more than 

15 pounds of VOC,is emitted. Since the exemption from Chapter NR 424, Wis. 

Adm. Code, is based on actual emissions, limiting the source's daily PTE 

doesn't seem to make much sense. Either way, the source is required to 

maintain daily" records demonstrating' their actual emissions of VOCs" afe less" 

than 15 pounds. There isn't any compelling reason to maintain the daily limit 

of 2 gallons of ink. This condition will not be carried over into the new 

permit. 

Combined, the fiberglass coating line (Process P30) and the screen printing 

line (Process P35) have a PTE VOC of 16,570 pounds per month, or 99.4 tpy. 

Since the facility is located in an area which is designated a severe ozone 

nonattainment area (Milwaukee County), the major source threshold level is 25 

tpy,of VOC. The facility is a major Part-70 source. Summarized below in 

Table 5 are the PTE VOC estimates for these two units. 

August 27, 1996 Page 15 

21 
P.29 

Table 5 Potential to Emit Volatile Organic Compounds (VOCs) 

Fiberglass Coating (Process P30) 

Operation 

Resin 

Cleanup Solvent 

Monthly 

Usage Limit 

12,000 gals 

330 lbs 

Screen Printing (Process P35): 

Operation 

Ink, Retarder, Thinning 

Cleanup Solvent 

Monthly 

Usage Limit 

3.0 gals 

3.0 gals 

Maximum 

VOC Content 

1.35 lbsVOC/gal 

1.00 lbsVOC/lb 

Subtotal 

VOC Emissions 

(lbs/month) (£gy) 

16,200 97.2 

22Q ___L_£ 

. 16,530 99.2 

Maximum 

VOC Content 

6.60 lbsVOC/gal 

7.16 lbsVOC/gal 

Subtotal 

VOC Emissions 

(lbs/month) (£py) 

19.8 0.12 

2JLu_t __IZ 

. . . 41.2 0.24 

Total 16,570 99.4 

The facility was not modeled for the emission of VOC. VOC is not normally 

modeled by the department. Instead, the department relies upon the code, or 

VOC emission limitations, to protect the ambient air quality standards. 

Hazardous Air Pollutants (HAPs) 

Based upon the information contained in the permit application (See Table 1), 

the facility is significant for the emission of only one HAP, styrene. 

Styrene is both a federal and state HAP. Assuming the worst case situation, 

all VOC emitted from the resin used on fiberglass coating line (Process P30) 

is styrene, the facility has the PTE 16,200 pounds per month of styrene, or 

97.2 tpy. Based upon its PTE styrene, the facility is a major source for the 

emission of federal HAPs. The threshold level for a major source is 10 tpy of 

a single federal HAP. Although the source elects to limit their usage of 

styrene resins on a monthly basis, the facility still has the capability to 

emit styrene at its MTE rate on an hourly basis. As summarized in Table 4, 

the facility has an MTE of 66.0 pounds of VOC per hour during the coating and 

curing of resins. Assuming all VOC is emitted as styrene monomer, the 

facility has the capability to emit 66.0 pounds of styrene per hour. The air 

emissions from the fiberglass coating line are exhausted to the outside 

ambient air through three fixed stacks. All stacks are greater than 25 feet 

in height. Styrene is listed as a Chapter NR 445, Table 1, Wis. Adm. Code, 

air contaminants with a de minimus level of 75.192 pounds per hour from a 

stack greater than or equal to 25 feet in height. Since the facility's MTE 

for styrene is de minimus level published in Chapter NR445, 

Table 1, Wis. Adm. Code, the facility does hot heedto be modeled for the 

emission of styrene. Therefore, no modeling or usage restrictions apply. 

Since no applicable restrictions or limitations exist, or are required, for 

the emission of styrene, styrene does not need to be mentioned in Part I of 

the permit. 

CONTROL TECHNOLOGY REVIEW 

The facility employs a Torit Downflo system to control the emission of 

particulates from the stack exhausting the finishing operations emissions 

(process P33). The system contains twelve (12) fabric filter cartridges. 

Each cartridge is sequentially pulsed with compressed air to remove the 

particulate filter cake buildup. The collection efficiency of the hood system 

is reported as 70 percent, while the control device is reported as 99.9 

percent efficient. 

August 27, 1996 Page 16 

Jtt 
P.30 

In addition to the particulate control device, the facility elects usage 

limitations and emission limitations to control their VOC emissions. With 

these limitations, the source reduces their MTE of VOC from 273 tpy to a PTE 

VOC to 99.4 tpy. 

AIR OUALITY REVIEW 

The facility is significant for the emission of PM, VOC, and one HAP, styrene. 

It is departmental policy not to model PM and VOC. Instead the facility 

relies upon the emission limitation in the administrative code to protect the 

ambient air quality standards. As for styrene, the facility has an MTE below 

the de minimus level published in Chapter NR 445, Table 1, Wis. Adm. Code. 

Air contaminants with an MTE below the published threshold values are not 

typically modeled. The ambient air quality standards are assumed to be 

protected. 

FACILITY EMISSIONS 

Actual emissions are the total emissions generated by the emission sources 

identified below over the specified time period taking into account any 

reductions made by a control device or technique. Maximum theoretical 

emissions are the quantity of air contaminants that theoretically could be 

emitted by the emissions sources identified below, without considering 

emission control devices, based on the design capacity of the source. 

Potential to emit is the maximum capacity of the emission sources identified 

below to emit any air contaminant under its physical and operational design. 

Any physical or operational limitation on the capacity of a source to emit an 

air contaminant shall be treated as part of its design if the limitation is 

Federally enforceable. 

A. STACK EMISSIONS 

1. Stack #, Unit #: SIO P30 

Unit description: The styrene resin coating of woven fiberglass. The line 

is equipped with a heating tank for the resin, an 

applicator head, and a curing oven. The line is 

identified internally as the O'Hare process line. 

Pollutant 

Volatile Organic 

Compounds (VOCs) 

Actual Emissions 

60.3 

Units 

lb/hr 

TPY 

45.2 

Maximum Theoretical 

66.0 

Units 

lb/hr 

TPY 

264 

P.T.E. 

TPY 

99.2 

HAZARDOUS AIR POLLUTANT EMISSIONS FOR STACK: SIO 

Pollutant 

Styrene, 

monomer 

100-42-5 

Actual 

Emissions 

60.3 

Units 

lb/hr 

Maximum 

Theoretical 

66.0 

Units 

lb/hr 

Potential to Emit 

TPY 

97.2 

August 27, 1996 Page 17 

M 
P.31 

2. Stack #, Unit #: S14 P33 

Unit description: Miscellaneous finishing operations: one single-spindle 

drill press, two multi-spindle drill presses, one round 

corner router, one shaping router, and two belt sanders. 

Pollutant 

Particulate 

Matter (PM) 

Actual Emissions 

0.45 

Units 

lb/hr 

TPY 

0.43 

Maximum Theoretical 

5.80 

Units 

lb/hr 

TPY 

16.6 

P.T.E. 

TPY 

2.63 

3. Stack #, Unit #: S30 P35 

Unit description: SP-5 sheet fed screen printing press with a curing oven. 

Pollutant 

Volatile Organic 

Compounds (VOCs) 

Actual Emissions 

2.56 

Units 

lb/hr 

TPY 

0.04 

Maximum Theoretical 

3.58 

Units 

lb/hr 

TPY 

9.17 

P.T.E. 

TPY 

0.24 

HAZARDOUS AIR POLLUTANT EMISSIONS FOR STACK: S10 P13 

Pollutant 

Ethyl Benzene 

100-41-4 

Toluene 

108-88-3 

Xylene 

1330-20-7 

Actual 

Emissions 

0.02 

1.31 

0.25 

Units 

lb/hr 

lb/hr 

lb/hr 

Maximum 

Theoretical 

0.04 

2.18 

0.29 

Units 

lb/yr 

lb/hr 

lb/hr 

Potential to Emit 

TPY 

0.001 

0.078 

0.010 

B. Facility Emissions 

Pollutant 

Particulate Matter (PM) 

Volatile Organic 

Compounds (VOCs) 

Actual Emissions 

TPY 

0.43 

45.2 

Potential to Emit 

TPY 

2.63 

99.4 

Total Facility Hazardous Air Pollutant Emissions 

August 27, 1996 Page 18 

J?) 
P.32 

Pollutant 

Ethyl Benzene 

100-41-4 

Styrene, 

monomer 

100-42-5 

Toluene 

108-88-3 

Xylene 

1330-20-7 

Actual 

Emissions 

0.02 

60.3 

1.31 

0.25 

Units 

lb/hr 

lb/hr 

lb/hr 

lb/hr 

Maximum 

Theoretical 

0.04 

66.0 

2.18 

0.29 

Units 

lb/hr 

lb/hr 

lb/hr 

lb/hr 

P.T.E 

TPY 

0.00 

97.2 

0.08 

0.01 

Threshold Value 

36.228 

75.192 

912,636 

31.231 

84,157 

0.2082 

Units 

lb/hr 

lb/hr 

lb/yr 

lb/hr 

lb/yr 

lb/hr 

FACILITY STATUS UNDER PART 70 

The facility, even with the limitation carried over from an existing permit 

(92-DAA-296), has a PTE of 99.4 tpy of VOC and 97.2 of styrene, a federal HAP. 

The threshold values for a facility located in Milwaukee County are 25 tpy of 

VOC and 10 tpy of any single federal HAP. The source is a major source, and 

must be permitted as a major, Part-70 source. 

COMPLIANCE DEMONSTRATION MONITORING METHODS 

To demonstrate compliance, the source must submit to the department semiannual monitoring reports. The time periods covered by these reports are 

January 1 to June 30 and July 1 to December 31. The summary reports must be 

submitted within 45 days from the end of each reporting period. The reports 

must be signed by the responsible official as to the truth, accuracy, and 

completeness of each report. 

The monitoring results must summarize the following items: 

1) The names of the resins delivered to the O'Hare line applicator per month 

and the VOC emission rates of these resins in units of pounds of VOC per 

gallon, excluding water, emitted during their application and cure. 

2) The monthly volume and the monthly volume averaged over the most recent 3 

consecutive months of all resins delivered to the O'Hare line applicator per 

month in units of gallons, excluding water. 

3) The total monthly weight of VOC used per month from the usage of cleanup 

solvents to clean the O'Hare process line in units of pounds. 

4) A statement stating that the exhaust collection and the particulate 

control devices were operated whenever any equipment described by process P33 

(e.g., 1 corner router, 1 surface router, 1 single-spindle drill press, 2 

multi-spindle drill presses, and 2 belt sanders) was used and that the 

pressure drop across the particulate collection device was measured and 

recorded at a minimum of once every eight (8) hours of operation or once per 

day, whichever yielded the greater number of measurements. 

5) The names of all inks, coatings, thinning solvents, and retarding agents 

delivered to the screen press per month, the VOC content of these materials in 

August 27, 1996 Page 19 

^ ) 
P.33 

units of pounds of VOC per gallon, excluding water, as used, and the monthly 

total volume or weight of each material used per month in units of gallons, 

excluding water. If a weight measurement is used to record usage, the density 

of the material must be recorded. 

6) The total monthly volume of all inks, coatings, thinning solvents, and 

retarding agents delivered to the screen printing press per month in units of 

gallons, excluding water. 

7) The total monthly weight of VOC used per month from the usage of cleanup 

solvents to clean the printing press and screens. 

All records shall be maintained for at least the previous five years and be 

available to the department for inspection upon request. 

In addition, the source must submit to the department and USEPA annual 

compliance certification reports. The time period covered by each report is 

January 1 to December 31. Compliance certification must be submitted within 

45 days from the end of each reporting period. Each report must be signed by 

the responsible official as to the truth, accuracy, ahd completeness of each 

report. 

FACILITY COMPLIANCE STATUS 

The Department finds that: 

1. The source will meet applicable emission limits and other requirements. 

2. The source will not cause nor exacerbate a violation of an ambient air 

quality standard or ambient air increment. 

PRELIMINARY DETERMINATION 

The Wisconsin Department of Natural Resources has reviewed the permit 

application and other materials submitted by Brady U.S.A. and hereby makes a 

preliminary determination that an operation permit may be issued with the 

following Draft Applicable Limits and Draft Permit Conditions. 

August 27, 1996 Page 20 

?a