Rev 08/2004 j:\fops\guidance\sob 082004.wpdStatement of Basis For Title V PermitPart I - GeneralCompany Name Summitville Tiles, Inc.Premise Number 02 10 00 0047What makes this facility a Title V facility? SO2 and PM10Has each insignificant emissions unit beenreviewed to confirm it meets the definition inOAC rule 3745-77-01 (U)?YesWere there any “common control” issuesassociated with this facility? If yes, provide asummary of those issues and explain how theDAPC decided to resolve them.NoPlease identify the affected unit(s) andassociated PTI, if applicable, along with a briefdescription of any changes to the permitdocument that qualify as a minor permitmodification per OAC rule 3745-77-08(C)(1)N/APlease identify the affected unit(s) andassociated PTI, if applicable, along with a briefdescription of any changes to the permitdocument that qualify as a significant permitmodification per OAC rule 3745-77-08(C)(3)N/APlease identify the affected unit(s)andassociated PTI, if applicable, along with a briefdescription of any changes to the permitdocument that qualify as a reopening per OACrule 3745-77-08(D)N/ARev 08/2004 j:\fops\guidance\sob 082004.wpdPlease identify the affected unit(s) andassociated PTI, if applicable, along with a briefdescription of any changes to the permitdocument resulting from a renewal per OACrule 3745-77-08(E)Language has been updated. The authority for terms has been added.PTI No. 02-00387 for emissions units P009 and P010 was modified during the term of the original TVpermit. The hourly limit for each unit of 5.65 poundsPE was not changed, however, the annual limit, 1.04tpy, was based upon only 368 hours of operation per year. The PTI was modified to allow for 8760 hoursof operation. The modified annual permit limits were put into the renewal TV permit.PTI No. 02-1570 for emissions unit P011was modifiedto allow for 2.12 lbs PE/hour and 9.3 tpy. The newlimits are based upon the PTE for theunit, considering the use of the baghouse. The modified limits wereput into the renewal permit.PTI No. 02-22684 was issued for new emissions unit P012 during the term of the original TV permit.Emissions unit P012 is included in the renewal TV permit.In the original TV permit, the allowable PE emissionslimitations for emissions units P001 - P008 werebased upon Table I in OAC Rule 3745-17-11. However,per OAC rule 3745-17-11(A)(2)(b)(ii), Table I ofOAC rule 3745-17-11 does not apply to this facility.These allowable emissions limitations wererecalculated based upon Curve P-2 of Figure II of the rule.The original TV permit included emissions testingrequirements for PE emissions at emissions unitsP001 and P002 and P005 and testing for SO2 emissions inP005. The results of the emissions testingdemonstrated actual emissions are a small fraction ofthe allowable emissions. The testing requirementswere not included in the renewal permit.NOTE: This facility has been reviewed and determined tobe an area source for HAPs. This facility is notsubject to any MACT rule.Rev 08/2004 j:\fops\guidance\sob 082004.wpdPart II (State and Federally Enforceable Requirements)Term and Condition(paragraph)BasisCommentsSIP(3745- )OtherCInstructions for Part II:Each paragraph in Part II must be identifiedand the remainder of the table completed.If the SIP (not including 31-05) is thebasis for the term and condition,identify the specific rule.If the SIP is not the basis for the term and condition, place an “N” in the column under “SIP.”If the basis for the term and conditionis something other than the SIP, including 3745-31-05, NSPS or MACT, a “Y” should be noted in the “Other” column, and if not, an “N” should be noted.Whether the basis for the term and condition is the “SIP” or “Other,” an explanation of each term and condition in Part II mustbe provided in the “Comments”section.Part III (Requirements Within the State and Federally Enforceable Section)Any unusual requirements or aspects of the terms and conditionsin Part III that are not self-explanatory should be explained in the appropriate commentfield or in a paragraph following the table for Part III.EU(s) Limitation Basis ND ORM St ENF R St Rp St ET Misc CommentsSIP(3745- )OtherP001P002Seecomment17-11(B)N N Y Y N N Y N Y N N N Limitation of 28.9 lbs PE/hr is a combined limit forP001 and P002.OR - pressure drop across baghouse is specifiedET - Compliance is demonstrated by M, R, RpRev 08/2004 j:\fops\guidance\sob 082004.wpdP001P002P003P004P005P006P007P008P009P010P011P01220%opacity17-07(A)(2)N N Y Y N N Y N Y N N N OR - pressure drop across baghouse is specifiedET - RM 9, if requestedP003 9.7 lbsPE/hour17-11(B)N N Y Y N N Y N Y N N N OR - pressure drop across baghouse is specifiedET - Compliance is demonstrated by M, R, RpP004 8.0 lbsPE/hour17-11(B)N N Y Y N N Y N Y N N N OR - pressure drop across baghouse is specifiedET - Compliance is demonstrated by M, R, RpP005P006P007P0086.5 lbsPE/hour17-11(B)N N Y Y N N Y N Y N N N OR - combust only natural gas in the kilnET - Compliance is demonstrated by M, R, RpP005P006P007P00846.1 lbsSO2/hr18-06(E)(2)N N N N N N NN N N N N ET - Compliance is to be demonstrated by emissionstesting, if requiredP009P0105.65 lbsPE/ hr &24.7 TPY31-05(A)(3)N N Y Y N N Y N Y N N N OR - pressure drop across baghouse is specifiedET - Compliance is demonstrated by M, R, RpP011P0122.12 lbsPE/ hrand 9.3TPY31-05(A)(3)N N Y Y N N Y N Y N N N OR - pressure drop across baghouse is specifiedET - Compliance is demonstrated by M, R, RpEU = emissions unit IDND = negative declaration (i.e., term that indicates that a particular rule(s) is (are) not applicable to a specific emissionsunit)OR = operational restrictionM = monitoring requirementsSt = streamlining term used to replace a PTI monitoring, recordkeeping, or reporting requirementwith an equivalent or more stringent requirementENF = did noncompliance issues drive the monitoring requirements?R = record keeping requirementsRp = reporting requirementsET = emission testing requirements (not including compliance method terms)Rev 08/2004 j:\fops\guidance\sob 082004.wpdMisc = miscellaneous requirementsCInstructions for Part III:CAll non-insignificant EUs must be included in this table. Foreach EU, or group of similar EUs, each emission limitation and control requirementspecified in section A.I.1 and A.I.2 of the permit mustbe identified and the remainderof the table completed.CIf the SIP (not including OAC rule 3745-31-05) is the basis forthe term and condition, identify the specific rule. If the SIP is not the basis for the termand condition, place an “N” in the column under “SIP.” If thebasis for the term and condition issomething other than the SIP, including OAC rule3745-31-05, NSPS or MACT, a “Y” should be noted in the “Other” column, and if not, an “N” should be noted. If the basis for the term and condition is“Other,” an explanation of the basis mustbe provided in the “Comments” section. IfOAC rule 3745-31-05 is cited in the “Other”column, pleaseindicate in the “Comments” section whether or not allof the requirements have been transferred from the permit to install.• To complete the remainder of the table after “Basis,” except for the “Comments” section, simply specify a “Y” for yes or an “N” for no. For the “M,” “R,”“Rp,” and “ET” columns, if “N” is specified, there should be a brief explanation in the “Comments” section as to why there areno requirements. If abrief explanation is provided in the “Comments” section, please do not simply indicatethat monitoring or testing requirementsare not necessary. Anexplanation of why a requirement isnot necessary should be specified.When periodic monitoring requirements are established to satisfy the provisions ofOAC rule 3745-77-07(A)(3)(a)(ii), the basisfor the requirementsmust be explained. Whenever Engineering Guides have been used toestablish the periodic monitoring requirements, the applicableEngineeringGuide may be referenced in the “Comments” section. An example that should be clarified wouldbe the situation where it has been determined thatcontrol equipment parametric monitoringwill be used to evaluate ongoing compliance in lieu of performing frequent emission tests. In this situation,Engineering Guide #65 would be referenced alongwith the fact that the parametric monitoring range (or minimum value) corresponded to the range(or minimum value) documented during the most recent emission tests that demonstrated that the emissions unit was in compliance. If streamlininglanguage is included in the “Monitoring,” “Record Keeping,” or “Reporting” requirements sections of the permit, explain which requirements are beingstreamlined (mark appropriate column above) and provide a brief explanation of why the streamlined term is equal to or more stringent than the“Monitoring,” “Record Keeping,” or “Reporting”requirements specified in the permit toinstall. If Engineering Guide #16 was used as the basis forestablishing an emission test frequency, a simple note referencing the Engineering Guidein the “Comments” section would be sufficient.Also, if a “Y” is noted under “OR,” “Misc,” “St,” “ND,” or “ENF”an explanation of the requirements must be provided in the “Comments” section. Inaddition to a general explanation of the “OR,” “Misc,” “St,” “ND,” and/or “ENF” the following must be provided:1. For an operational restriction, clarifyif appropriate monitoring, record keeping, and reporting requirements have been specified for theoperational restriction and indicate whether or not CAM is currently applicable.2. If a control plan and schedule is included in the “Miscellaneous Requirements” section of thepermit, provide an explanationin the“Comments” section of the violation,basis for the violation, and the company’s proposed control plan and schedule.3. If the “ND” column above is marked, please identify the particular rule(s) that is(are) not applicable to the specified emissions unit.2. If the “ENF” column above is marked, please provide a brief explanation of the noncompliance issue(s) which prompted the useof thespecified monitoring requirement.An explanation is not required if an “N” is noted inthe “OR,” “Misc,” “St,” “ND,” or “ENF” columns.CAdditional information for modifications- Several types of modifications, as defined by rule, may be processed concurrently. Please provide enough ofRev 08/2004 j:\fops\guidance\sob 082004.wpda description for someone wishing to review the changes to the permit language to be able to identify where the change is madein the permit document.This brief description should be identified in the appropriate row inthe first table of this form by replacing the “N/A” in the applicable row(s). Please alsoindicate if the modification is being initiated by an appeal by including the ERAC case number inthe “Comments” area. Please update the term-specific textin the SOB as warranted (full insertion orreplacement is acceptable; bold italicand strike out is not needed). Note all modification/reopening rows shouldremain “N/A” when developing the SOB during the initial permit development. Note: APA’s and Off-permit changes do not need to be noted in the SOB.