# Ohio Environmental ProtectionAgency John R
. Kasich, Governor Mary Taylor, Lt. Governor ScottJ
. Nally, Direc tor 

### February 14, 2012 Kaushal Gupta Air & 

### Radiation 'Branch U.S.EPA, Region V 77 W. Jackson Blvd Chicago, IL 60604 Dear Mr. Gupta: This letter is to provide you with the information you requested on the storage tanks exemption in rule 3734-31-03(A)(1 )(l)(iv) ofthe Ohio Administrative Code (OAC)

. Enclosed for your review is a study that illustrates that as a practical matter, permanently exempting storage tanks with a capacity less than 19,815 gallons (75 cubic meters) from having to apply for and obtain a permit-to-install or PTIO as required by OAC rule 3745-31-02 for the installation or modification, and operation of an air contaminant source of the organic liquids storage tanks from permitting has no negative impact on emissions and therefore no impact on ambient air quality
. Please review the enclosed documentation and let me know if you have any questions. Thank you for your consideration. Sincerely,

Michael E
. Hopkins, P.E Assistant Chief, Permitting Division ofAir Pollution Control

50 West Town Street, Suite 700 P
.O

. Box 1049 Columbus. OH 43216-1049 614 1 644 3020 614 1 644 3184 (fax) www.epa

_ ohio
.gov

## OHIO EPA 

# DIVISION OF AIR POLLUTION CONTROL 

# INTER-OFFICE MEMORANDUM
TO: Mike Hopkins, Assistant Chief, Permitting, Division ofAir Pollution Control (DAPC), Ohio EPA FROM : 

### Mike Mansour, Permitting, DAPC, Ohio EPA 

### SUBJECT: Measuring the effect ofthe exemption in OAC rule 3745-31-3(A)(1)(1)(1V) on VOC emissions. 

### DATE: 1/26/2012 

### CC: Andrew Hall, Manager, Permitting, DAPC



### Objective: This project was undertaken to evaluate the impact, on volatile organic compound (VOC) emissions, of permanently exempting storage tanks with a capacity less than 19,815 gallons (75 cubic meters) from having to apply for and obtain a permit-to-install or PTIO as required by rule 3745-31-02 of the Ohio Administrative Code for the installation or modification, and operation of an air contaminant source. Effective as of July 29, 2005, OAC rule 3745-31- 03(A)(1)(l)(iv) exempts from permitting "organic liquids" storage tanks with a capacity less than 75 cubic meters (19,815 gallons) that are equipped with submerged fill except gasoline storage tanks located at bulk gasoline plants

February 14, 2012 Ohio EPA

### Tank Exemption OAC rule 3745-31-03(A)(1)(1)(iv)


### which are subject to the requirements of OAC rule 3745-21-09(P) 1• 

### Please note that OAC rule 3745-31 -01 has no definition for "organic liquids," however; it defines "organic compounds" as any chemical compound containing carbon, excluding carbon monoxide, carbon dioxide, carbonic acid , metallic carbides, metallic carbonates, ammonium carbonate, non-landfill gas methane and ethane. Also, OAC rule 3745-21 -07(C)(4) describes "liquid organic material" as any organic material which is a liquid at standard conditions, and "organic material" as any chemical compound containing carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides, metallic carbonates, and ammonium carbonate
. Hence, the exemption in OAC rule 3745-31-03(A)(1)(l)(iv) applies (or will have applied) to all the emissions units that are (or would have been) subject to the following: OAC rule 3745-21-07(0) [for storage of volatile photochemically reactive materials2] , 

### OAC rule 3745-21-09(L) [for storage of petroleum liquids3 

### in fixed-roof storage tanks], OAC rule 3745-21-09(Z) [for storage of petroleum liquids in external floating roof tanks], and 40 CFR Part 60, Subpart K [applies to petroleum liquid4 

### storage tanks for which construction, reconstruction, or modification commenced after June 11, 1973, and priorto May 19, 1978], Subpart Ka [applies to petroleum liquid4 

### storage tanks for which construction , reconstruction, or modification commenced after May 18, 1978, and priorto July 23, 1984], and Subpart Kb [applies to petroleum liquid4 

### storage tanks for which construction, reconstruction , or modification commenced after July 23, 1984]. February 14, 2012 Ohio EPATank Exemption OAC rule 3745-31-03CA)(1)(1)(iv)



### Data Analysis: A list was generated of permits (initial installations and/or Chapter 31 modifications) issued within a year prior to the effective date of OAC rule 3745- 31-03(A)(1)(l)(iv) for storage tanks with a capacity of equal to or greater than 10,000 gallons and less than 19,815 gallons. The requirements of those permits
were examined for the purpose of measuring the effect of the aforementioned storage tanks exemption on the emissions ofVOCs.

The generated list included a total of 54 permits issued for organic liquids storage tanks as described above. There were a total of 33 storage tanks from the list of 54 permits that, if they were to be evaluated today, would have been subject to the current exemption in OAC rule 3745-31-03(A)(1)(l)(iv). [See Pie Chart I below.]

February 14, 2012 Ohio EPATank Exemption OAC rule 3745-31-03(A)(1)(1)(iv)


### Chart I

All of the 33 emissions units employed submerged fill (or control measures equivalent to submerged fill) as specified pursuant to best available technology (BAT) [OAC rule 3745-31-05(A)]

. The permits also established, under BAT, 

### OCNOC limitations that were based on maximum throughputs [see attached example permit]
. In three of the permits, BAT was established as only an 

### OCNOC emission limitation for each , which, again , was based on the maximum throughput of the storage tank
. The three permits, however, still required that submerged fill be employed
. The requirement to employ submerged fill was established pursuant to OAC rule 3745-21-07(0) [as effective 6/15/1999] (only if volatile photochemically reactive materials were employed) and was not BATdriven [see attached example permits nos. 14-02058, 14-02486, and 14-02539].

February 14, 2012 Ohio EPATank Exemption OAC rule 3745·31-03(A)(1)fl)(iv) 

### [See Pie Chart II below.]

Chart II

All of the storage tanks that would have been subject to the exemption in OAC rule 3745-31-03(A)(1 )(l)(iv) were also exempt from having to comply with any additional emission limitations/control requirements, including work practices, specified by OAC rule 3745-21-07(0), OAC rule 3745-21-09(L), OAC rule 3745- 21-09(Z), and/or 40 CFR Part Kb [with the exception of keeping certain records5 

### pursuant to 40 CFR Part 60, Subpart Kb]
.
Also, there were a total of21 permitted emissions units that would not have been subject to the exemption in OAC rule 3745-31-03 because of the applicability of

February 14, 2012 Ohio EPA

### Tank Exemption OAC rule 3745-31·03(A)(1)(1l(iv}


### federal regulation(s) [see attached example permit]. Some of these permits included control requirements other than submerged fill (either as stringent as, or more stringent than submerged fill) or in addition to submerged fill. These emissions units usually do not qualify for the exemption since they are subject to federal requirements as specified pursuant to OAC rule 3745-31-03(A)(1)6

. 

### For example, regardless of the size, the storage tanks exemption does not apply to emissions units subject to 40 CFR Part 61, the national emission standards for hazardous air pollutants (NESHAPs), or emissions units subject to 40 CFR Part 63, the NESHAPs for source categories, MACT standards,
...etc.
Conclusion:


### This study proves that as a practical matter, the exemption , which is applicable to storage tanks pursuant to OAC rule 3745-31-01(A)(1)(1)(iv), has absolutely no negative impact on air quality at all. As evidenced by all the permits examined, all of the storage tanks with a capacity less than 19,815 gallons employed submerged fill or equivalent as best available technology and contained no additional requirements (i.e., operational restrictions, emission limi tations, work practices
.. .etc.) established under BAT and/or specified by any other applicable OAC or federal rule cited in the permit. For all the permits examined, the only rules, besides BAT, that were applicable were: OAC rule 3745-21-09(L), OAC rule 3745-21-07(0) and/or 40 CFR Part 60, Subpart Kb, [OAC rule 3745-21- 07(0) has been rescinded and replaced by a cite-specific OAC rule 3745-21- February 14, 2012 Ohio EPATank Exemption OAC rule 37 45·31·03{A)(1 )(l)(iv) 

### 07(K).] However, as previously stated, all the emissions units, although they were subject to the rules mentioned above, were exempt from any additional requirements aside from the requirement to employ submerged fill. OAC rules 3745-21-09(L) and 3745-21 -09(Z) exempt all storage tanks with a capacity less than 40,000 gallons from any requirements
. Additionally, OAC rule 3745-21- 07(0) also exempted storage tanks from any requirements if the organic liquids being stored were not considered volatile photochemically reactive materials
. Further, OAC rule 3745-21-07(0)(2) only required submerged fill for storage tanks that stored volatile photochemically reactive materials and was less than 65,000 gallons in size. In short, the exemption established for storage tanks in OAC rule 3745-31-03(A)(1 )(l)(iv) is as stringent as or more stringent that any requirements that would have been established under BAT and any of the other applicable rules. Therefore, no increase ofVOC emissions is expected due to the storage tanks exemption per OAC rule 3745-31-03(A)(1 )(l)(iv).

1 Bulk gasoline plant 2Volatile photochemically reactive material" means any photochemically reactive material which has a vapor pressure of 1.5 pounds per square inch absolute or greater under actual storage conditions
. 3 0AC rule 3745-21-01(E) (15) define "Petroleum liquids" to mean crude oil, condensate, and any finished or intermediate products manufactured or extracted in a petroleum refinery. [OAC rules 21-09(L) and 21-09(Z)].
4

### 40 CFR Part 

### 60, Subpart K, Ka, or Kb define "Petroleum liquids" to mean petroleum, condensate, and any finished or intermediate products manufactured in a


### February 14, 2012 Ohio EPATank Exemption OAC rule 3745·31·03(A){1)(1)(iv) petroleum refinery but does not mean Nos. 2 through 6 fuel oils as specified in ASTM 0396-78, 89, 90, 92, 96, or 98, gas turbine fuel oils Nos. 2-GTthrough 4-GT as specified in ASTM 02880-78 or 96, gas tu rbine fuel oils Nos. 2-GT through 4-GT as specified in ASTM 02880-78 or 96, or diesel fuel oils Nos
. 2-0 and 4-0 as specified in ASTM 0975-78, 96, or 98a. (These three methods are incorporated by reference-see §60.17.) 5The permittee is only required to keep records showing the dimension ofthe storage vessel and an analysis showing the capacity ofthe storage vessel forthe life of the emissions unit.
6The following exemptions do not apply to emissions units subject to 40 CFR Part 61, the national emission standards for hazardous air pollutants (NESHAPs), with the exception of40 CFR Part 61, Subpart M, asbestos removal activities; or emissions units subject to 40 CFR Part 63, the NESHAPs for source categories, MACT standards, unless such standard either only requires submission of a notification, and written notification satisfying the MACT notification requirements has been or will be submitted to the Ohio environmental protection agency prior to the notification deadline imposed by the MACT, or such standard does not impose any requirements (i.e., notifications, emissions limits, record keeping, etc.) to the particular emissions unit ; or emissions units subject to the new source performance standards (NSPS) with the exception of40 CFR Part 60, Subpart AAA, residential wood heaters , 40 CFR Part 60, Subpart 000, nonmetallic mineral processing plants, and 40 CFR Part 60, Subpart I, hot-mix asphalt facilities.



### February 14, 2012 Ohio EPA

# List of Permits Issued In 2004 For Storage Tanks Which Were >= 10,000 and <19,815 gallons In SizeSubject to OAC rule 3745-21- BAT Subject to Exemption Permit Size Permit Effective Submerged Other OAC rule 3745-31- Facility ID Facility Name Class EIJid EU Description (gallons) No. Fill Additional Terms 07(0} 09(L} 09(Z} Submerged Fill requirements 03 Date emoloved? 0180010008 The Scotts Co. TV T012 Bifenthrin pesticide storage tank 16,000 01-08386 4-Mar-04 Yes This emissions unit is subject to 40 CFR No No No Yes oc 0.19TPY Yes Part 60 Subpart Kb (record keeping only) nd BAT. 02150203S6 HAYS OIL CO., INC. NTV T003 cylindrical, steel, diesel tank (T-4) 12,000 02-18857 18-Mar-04 Yes This emissions unit is subject to OAC rule No Exempt No Yes OC = 1.0 TPY (for Yes with fixed roof 3745-21-09(1) [exempt from any TOOl thru T006, requirements since the tank is less than combined) 40, 000 gallons] and 40 CFR Part 60 Subpart Kb [record keeping only since 0243000887 BP- CONCORD BULK NTV T012 Submerged fill above-ground 16,000 02-18928 27-Jan-04 Yes This emissions unit is subjectto OAC rule No exempt No Yes voc 1.0 Yes PLANT storage tank 3745-21-09(1) [exempt from any ton/year requirements since the tank is less than 140 000 ""' "' 0278080443 MARZANE PLANT NO 27 FEPTIO T002 no. 2 fuel oil/waste oil storage 15,000 02-18481 16-Mar-04 Yes This emissions unit is subject to OAC rule No Exempt No Yes voc 0.1 TPY Yes tank 3745-21-09(1) [exempt from any requirements since the tank is less than •n nnn. ""' 302020012 Lima Refining Company TV T203 above-ground, fixed roof organic 14,500 03 7545 7 Ju!-94 No This emissions unit is subject to OAC rule No Exempt No No VOC 0.1 TPY VOC No liquids storage tank with a 3745-21-09(1} [exempt from any {controlled by TO) capacity of {group 1 storage requirements since the tank is less than vessel) 40, 000 gallons], 40 CFR Part 60 Subpart Kb (record keeping only}, 40 CFR Part 63, Subpart CC, 40 CFR Part 61, Subpart FF, 40 CFR 63.123(a}, 40 CFR 63.654(i}(l}, 40 CFR 63.654(i}(l}(iv}, 40 CFR 63.654(i}(4} and 40 CFR Part 63, Subpart A. 0302020012 Lima Refining Company TV T204 above-ground, fixed roof organic 14,SOO 03-7545 7-Jul-94 No This emissions unit is subject to OAC rule No Exempt No No VOC 0.1 TPY No liquids storage tank with a 374S-21-09(1) [exempt from any (controlled by TO) capacity of (group 1 storage requirements since the tank is less than vessel) 40, 000 gallons], 40 CFR Part 60 Subpart Kb {record keeping only), 40 CFR Part 63, Subpart CC, 40 CFR Part 61, Subpart FF, 40 CFR 63.123{a), 40 CFR 63.654(i){1), 40 CFR 63.654(i){1){iv), 40 CFR 63.654{i)(4) and 40 CFR Part 63, Subpart A. 0302020260 PROCTER & GAMBLE FEPTIO T032 fixed-roofoutdoor storage tank 10,782 03-16222 21-Dec 04 Yes OAC rule 374S-21-09{L)is notapplicable No No No Yes oc 0.01 TPY. Yes MFG CO for storage of raw materials for b/c emissions unit does notstore formulation of liquid laundry petroleum liquids as defined in 3745-21- detergent. PTI #03-10040, #03- 01. 13988 and #03-16222 revoked 0302020260 PROCTER & GAMBLE FEPTIO T086 fixed roof outdoor storage tank 14,376 03 16222 21 Dec 04 Yes OAC rule 3745-21-09{L)is not applicable No No No Yes oc 0.13 TPY. Ye' MFGCO for storage of liquid laundry b/c emissions unit does not store detergent. PTI #03-13988 and #03 petroleum liquids as defined in 3745-21- 

### '"" '""loin' lo,

1 of 7 2/12/2012 tanks_2004 %28working copy%29 YES.xlsxSubjectto OAC rule**3745~21-** BAT Subject to Exemption Permit Size Permit Effective Submerged Other OAC rule**3745~31·** Facility ID Facility Name Class EUid EU Description (gallons) Fill Additional Terms 07(0} 09(l} 09(Z} Submerged Fill requirements 03 No. Date employed? 0180010008 The Scotts Co. TV T012 Bifenthrin pesticide storage tank 16,000**01~08386** 4-Mar-04 Yes This emissions unit is subject to 40 CFR No No No Yes oc 0.19 TPY Yes Part 60 Subpart Kb (record keeping only) land BAT 0302020260 PROCTER & GAMBLE FEPTIO T087 fixed roofoutdoor storage tank 14,376 03-16222**21-Dec~04** Yes OAC rule 3745-21-09(L)is notapplicable No No No Yes OC-0.13 TPY. Yes MFG CO for storage of liquid laundry b/c emissions unitdoes notstore detergent. PTI #03-13988 and #03 petroleum liquids as defined in 3745-21- 1e??? ok 111/R/nR lm 0302020260 PROCTER & GAMBLE FEPTIO T088 fixed roof outdoor storage tank 14,376 03-16222 21-Dec-04 Yes OAC rule 3745-21-09(L)is not applicable No No No Yes OC-0.13TPY. Yes MFGCO for storage of liquid laundry b/c emissions unit does notstore detergent. PTI #03-13988 and #03 petroleum liquids as defined in 3745-21- 1R??? >n111RinR ln1 0302020260 PROCTER & GAMBLE FEPTIO T089 fixed roof outdoor storage tank 14,376 03-16222**21-Dec~04** Yes OAC rule 3745-21-09(L)is not applicable No No No Yes OC- 0.13 TPY. Yes MFGCO for storage of liquid laundry b/c emissions unit does notstore detergent. PTl #03-13988 and #03 petroleum liquids as defined in**3745~21-** 

### '""' >n 11/R/nR 01 0302020260 PROCTER & GAMBLE FEPTIO T090 fixed roof outdoor storage tank 14,376 03 16222**21-Dec~04** Yes OAC rule 3745-21-09(L)is not applicable No No No Yes oc 0.13 TPY. Yes MFGCO for storage of liquid laundry b/c emissions unit does notstore detergent. PTI #03-13988 and #03 petroleum liquids as defined in**3745~21-** 

## ""' 111/R/Oh n1 0302020260 PROCTER & GAMBLE FEPTIO T094 fixed roof underground storage 10,782 03-16222 21-Dec-04 No OAC rule 3745-21-09(L)is notapplicable No No No No DC 0.003 TPY. No MFGCO tank for storage of raw materials b/c emissions unit does not store for formulation of liquid laundry petroleum liquids as defined in 3745-21-

. 01 0302020260 PROCTER & GAMBLE FEPTIO T095 fixed roof underground storage 10,782 03-16222 21-Dec-04 No OAC rule 3745-21-09(L)is not applicable No No No No oc 0.003 TPY. No MFG CO tank for storage of raw materials b/c emissions unit does notstore for formulation of laundry petroleum liquids as defined in 3745-21- 0302020343 ISP TV T097 butanedio! organic waste storage 12,000 03-11250 28-0ct-04 No This emissions unit is subjectto OAC rule No No No No VOCooQ.22 TPY, No tank 3745-21·09(00} [LDAR], 40 CFR Part 60 internal floating Subpart Kb (record keeping only), 40 CFR, roof.

. h' ,, 

### '"' 0302020343 ISP TV T098 thermal oxidizer wastewater feed 12,000 03-11250 28-0ct-04 No This emissions unit is subject to OAC rule No No No No VOC- 0.22 TPY, No tank**3745-21~09(00)** [LDAR], 40 CFR Part 60 internalfloating Subpart Kb (record keeping only), 40 CFR, roof. Ip,rt 61 ,, "" 0302020371 lneos USA LLC TV · T097 fixed roof butanedio! organic 12,000 03-13628**23~Sep-04** Yes· This emissions unit is Subject to OAC rules Yes No No Yes OC 0.26 TPY, No waste storage tank with internal**3745~21-09{00)** and OAC 3745-21-07(0), annual materia! floating roof (Tank 63) 40 CFR Part 60, Subpart Kb, sections throughput rate of (Administrative modification to 60.116b(a) & (b) [record keeping only], 40 4,500,000 gallons PT!**03~13628,** issued on 9-23-04, CFR Part 60, Subpart VV. and internal to a!low for change in terms and floating roof. conditions of permit and a!low for

2 of7 2/12/2012 tanks_2004 %28working copy%29 YES.xlsxPermit Size Permit Effective Facility 10 Facility Name Class EU ld EU Description {gallons) No. Date 0180010008 The Scotts Co. TV T012 Bifenthrin pesticide storage tank 16,000 01-08386 4-Mar-04

0372030070 H.J. Heinz, L.P. TV T004 above ground fixed roof alcohol 12,000 03-13946 30-Dec-04 storage tank (modification to existing storage tank to increase throughput)

0666000050 PORTSMOUTH NTV T104 X-627 Equalization Tank TA-lA, 15,000 06-07283 13-Jan-04 GASEOUS DIFFUSION 15,000 gallon storagetank with PLANT- DOE submerge fill
0666000050 PORTSMOUTH NTV nos X-627 Equalization TankTA-1B, 15,000 06-07283 13-Jan-04 GASEOUS DIFFUSION 15,000 gallon storage tank with PLANT- DOE submerge fill

0701000070 Ershigs Temporary FRP TV TOOl resin storage tank 10,000 07-00547 5-May-05 Production Facility (DP&L-Stuart) 0701000070 Ershigs Temporary FRP TV T002 10,000 gallon resin storage tank 10,000 07-00547 5-May-05 Production Facility (DP&L-Stuart) 0701000070 Ershigs Temporary FRP TV T003 resin**stor;:~ge** tank 10,000 07-00547 5-May-05 Production Facility (OP&L-Stuart) 0773000080 Sunoco Inc (R&M) TV T059 hydrogenation feed tank (Alpha 11,844 07-00451 4 Nov 04 Methyl Styrene Hydrogenation Feed Tank)

1431010054 INEOS ASS (USA) TV T023 fixed roof storage tank -storing 10,500 14-02058 12-0ec-90 Corporation tertiary dodecyl mercaptan

1431010054 INEOS ABS (USA) TV T024 fixed roof storage tank- storing 10,500 P0097773 Corporation methyl ethyl ketone

3 of? Subjectto OAC rule 3745·21· Submerged Fill Additional Terms 07 (D) 09(l) 09(Z) employed? Yes This emissions unit is subject to 40 CFR No No No Part 60 Subpart Kb (record keeping only) and BAT Yes This emissions unit is subject to OAC rule No Exempt No 3745-21-09(L) [but is exempt from L (1) since the storage capacity is less than 40,000 gallons] and 40 CFR Part 60, Subpart Kb, section 60.116b (a) & (b) [record keeping only]. BAT= Yes This emissions unit is subject to OAC rule No Exempt No 3745-21-09(L) [but is exemptfrom L (1) since the storage capacity is less than 40,000 gallons] and 40 CFR Part 61,


# .. Yes This emissions unit is subject to OAC rule No Exempt No 3745-21-09(L) [but is exempt from L (1) since the storage capacity is less than 40,000 gallons] and 40 CFR Part 61, 

## • Yes This emissions unit is subject to OAC rule Yes No No 3745-21-09(D) (2) [submerged fill requirement] and 40 CFR Part 63 Subpart Yes This emissions unit is subject to OAC rule Yes No No 3745-21-09(D) (2) [submerged fill requirement] and 40 CFR Part 63 Subpart Yes This emissions unit is subject to OAC rule Yes No No 3745-21-09(0) (2) [submerged fill requirement] and 40 CFR Part 63 Subpart Yes This emissions unit is subject to the HON No No No group 1\ storage vessels [40 CFR Part 63, Subparts A, F, and G] and 40 CFR Part 60 Subpart Kb) record keeping only). Yes This emissions unit is subject to OAC rule Yes No No 3745-21-09(0).

Yes This emissions unit is subject to 40 CFR Yes No No Part 63, SubpartJJJ, and OAC rule 3745- 21-09(0). Not subject to BAT. Submerged fill is required to be employed per OAC rule 3745-21-07(0). No BAT established (existing source).
2/12/2012 BAT
Other Submerged Fill requirements Yes DC 0.19 TPY

Yes annual throughput =

420,000 gallons (i.e., maximum annual throughput), OC = 0.14 TPY. Yes OC -1.18TPY (0.27 lb/h,).

Yes OC -1.18TPY (0.27 lb/h,).

Yes VOC- 0.022TPY (0.005 lb/h,).
Yes VOC- 0.022TPY (0.005 lb/h,).
Yes VOC - 0.022 TPY (0.005lb/h,).
Yes vent condenser, VOC = 1.111 TPY.

No OC-0.13TPY (employs submerged fill which is 21-07(D) None (not subject None (not subject to BAT) to BAT) Subjectto Exemption OAC rule 3745·31· 03 Yes

Yes

No

No

No

No

No

No

Yes

No s fiubmerged

II is07(D) riven d

e xisting EU

tanks_2004 %28working copy%29 YES.xlsxPermit Size Permit Effective Submerged Facility ID Facility Name Class EU!d EU Description (gallons) Date Fill Additional Terms No. emoloved? 0180010008 The Scotts Co. TV T012 Blfenthrln pesticide storage tank 16,000 01·08386**4~Mar-04** y., This emissions unit is subject to 40 CFR Part 60 Subpart Kb (record keeping only) and BAT. 1431010054 INEOS ABS (USA) TV T025 fixed roofstorage tank- storing 11,000 14-02058 12-0ec-90 Yes This emissions unit is subject to OAC rule Corporation dibutylfumarate 3745-21-09{0)(1) [in addition to other things, 0{1) requires submerged fill] and 40 CFR Part 60 Subpart Kb [record

. 

### "'·· 1431010054 INEOS ABS {USA) TV T027 storage tank storing methyl ethyl 12,000 14-02058 12-Dec-90 Yes This emissions unit is subject to the HON Corporation ketone group II storage vessels [40 CFR Part 63, Subpart JJJ] and OAC rule 3745-21-09(0) [in addition to otherthings, 0(1) requires 

## '"'" - 14310100S4 INEOS ABS {USA) TV T036 fixed roofstorage tank -storing 10,000 P0097773 Yes This emissions unit is subject to OAC rule Corporation terpinolene**3745-21~09(0).** Submerged fill is required to be employed per OAC rule 3745-21- 07(0). No BAT established (existing 

# ., 1431010054 INEOS ABS (USA) TV T037 fixed roof storage tank -storing tris 10,000 P0097773 Yes This emissions unit is subject to OAC rule Corporation nonyl phenol phosphite 3745-21-09{0). Submerged fill is required (INORGANIC LIQUID) to be employed per OAC rule 3745-21- 07(0). No BAT established (existing 

## "' 1431010054 INEOS ABS (USA) TV T044 fixed roofstorage**tank~** storing 10,000 14--02486 27-Nov-91 Yes This emissions unit is subject to OAC rule Corporation secondary Butanol**3745-21~09(0).** Submerged fill is required to be employed per OAC rule 3745-21- 07{0). 1431010054 INEOS ABS {USA) TV T045 fixed roof storage tank storing 10,000 14-02539 28-May-92 Yes This emissions unit is subject to OAC rule Corporation isobutanol 3745-21-09(0).

1431010054 INEOS ABS {USA) TV T054 fixed roof storage tank- storing 18,500 14--04703 4--Aug-99 Yes This emissions unit is subjecttothe HON Corporation ethyl benzene group J! storage vessels [40 CFR Part 63, SubpartJJJ] and OAC rule 3745-21-09(0) [in addition to otherthings, 0{1} requires if;ll\ 1431390137 PMC Specialties Group, TV TOOl 16500 Gallon f1xed roof methanol 16,500 14-1703 3 May 00 Yes This emissions unit is subject to OAC rule Inc. storage tank with submerged fill; 3745-21-09(0) and 40 CFR Part 60 Modification of PTI14-1703. Subpart Kb [record keeping only]. 1431393170 GRAND VISTA OIL NTV T013 fixed roof wastewater storage 15,000 14--04213 17-Jun-04 Yes This emissions unit is subject to OAC rule tank 3745-21-09(1) [exempt from any requirements since the tank is less than 40,000 gallons] and 40 CFR Part 60 

## ""' 

# '"'

4 of7 2/12/2012 Subject to OAC rule**3745w21~** 07{0) 09{L) 09{Z) No No No

Yes No No

Yes No No

Yes No No

Yes No No

Yes No No

Yes No No

Yes No No

exempt No No

No exempt No BAT Other Submerged Fill requirements Yes OC=0.19 TPY
No OC -0.89 TPY

No vent condenser, OC=0.32TPY.

None (not subject None (not subject to BAT) to BAT}

None (not subject None (not subject to BAT) to BAT)

No OC

### = 0.13 TPY (employs submerged fill which is 21-07(0)

. 

### _, No OC- 0.65 TPY (employs submerged fill which is 21-07(0) ""' No oc 0.12 TPY (employs submerged fill which is 21-07(0) Yes oc 1.56TPY

Yes OC 0.00014TPV. Subject to Exemption OAC rule**3745~31~** 03 Yes

Yes

No

N/A

N/A

Yes

y.,

No

Yes

Yes s fil ubmerged I is07{0) riven d

s fil ubmerged I is07{D) riven d

s fiubmerged

II is07(D) riven d

s fiubmerged

II is07{D) riven d

s fiubmerged

II is 07(0) riven d

tanks_2004 %28working copy%29 YES.xlsxSubject to OAC rule**3745~21~** BAT Subject to Exemption Permit Size Permit Effective Submerged Other OAC rule**3745~31-** Facility ID Facility Name Class EUid EU Description (gallons) No. Date Fill Additional Terms 07(0) 09 (L) 09(Z) Submerged Fill requirements 03 emoloved? 0180010008 The Scotts Co. TV T012 Bifenthrin pesticide storage tank 16,000 01-08386**4~Mar~04** Ye> This emissions unit is subject to 40 CFR No No No Ye> OC- 0.19 TPY Ye> Part 60 Subpart Kb (record keeping only) and BAT. 1652050184 VEOLIA ES TECHNICAL NTV TOOl (new)- Storage Tank number 1**~** 19,815 16-02365 9-Sep-04 No This emissions unit is subject to OAC rule No exempt No No oc 2.39 TPY. Ye> SOLUTIONS, L.L.C. 19,815 gallon vertical fixed roof 3745-21-09(1) [exempt from any steel tank storing gasoline requirements since the tank is less than 40 ooo, ""' ,, 1652050184 VEOLIA ES TECHNICAL NTV T002 (new)- Storage Tank number2- 19,815 16-02365**9~Sep-04** No This emissions unit is subject to OAC rule No exempt No No OC- 2.39 TPY. Ye> SOLUTIONS, L.LC. 19,815 gallon vertical fixed roof 3745-21-09(1) [exempt from any steel tank storing gasoline requirements since the tank is less than 40ooo, ""' 0247120476 KOKOSING MATERIALS, NTV T002 vertical fixed roof storage tank for 15,000 02-14584 18-Sep-01 Ye> This emissions unit is subject to OAC rule No exempt No Ye> OC= 0.01 TPY. Ye> INC.- Plant 503 no. 4 on-spec used oil. 3745-21-09(1) [exempt from any requirements since the tank is less than 40,000 gallons] and 40 CFR Part 60

..h <h ,, H. •oolvl. 0302020015 lneos USA LLC NTV T097 internal floating roof storage tank 12,000 03-11250 28-0ct-04 No This emissions unit is subject to AOC rule Ye> No No No fixed tank in No organic waste storage tank 3745-21-09(00), PSO and 40 CFR Part 60, combination with w/internal floating roof (tank no Subpart VV. an internal floating 63.) roof, maximum throughput= 4,500,000,voc = 0.22 TPY



### - 0302020015 lneos USA LLC NTV T098 internal floating roof storage tank 12,000 03-11250 28-0ct-04 No This emissions unit is subject to AOC rule Ye> No No No f1xed tank in No organic waste storage tank 3745-21-09(00}, PSD and 40 CFR Part 60, combination with w/internal floating roof {tank no SubpartVV. an internal floating 64.) roof, maximum throughput= 4,500,000, VOC= 0.22 TPY 1318170314 ALCOA-Cleveland Works TV T01S Fuel Oil AGST- Tank No.1 12,000 13-2824 2-Jun-94 Ye> This emissions unit is subject to OAC rule Ye> No No Ye> VOC- 0.04TPY
. Ye> 3745-21-09(0) and 40 CFR Part 60 [Submerged fill is Subpart Kb [record keeping only]. also required to be employed per OAC rule 3745-21- 1318170314 ALCOA-Cleveland Works TV T016 Fuel Oil AGST- Tank No.2 12,000 13-2824 2-Jun-94 Ye> This emissions unit is subject to OAC rule Ye> No No Ye> VOC- 0.04TPY. Ye> 3745-21-09(0) and 40 CFR Part 60 [Submerged fill is Subpart Kb [record keeping only]. also required to be employed per OAC rule 3745-21- 1409040653 COLUMBIA OlL NTV T024 underground diesel fuel storage 12,000 14-05483 9-Sep-03 Ye> This emissions unit is subject to OAC rule No exempt No Ye> VOC = 0.04TPY. Ye> COMPANY tank 3745-21-09(1) [exempt from any requirements since the tank is less than 40,000 gallons] and 40 CFR Part 60 

## '""'' i k.,o;oo onlvl. 5 of? 2/12/2012 tanks_2004 °/o28working copy%29 YES.xlsxSubject to OAC rule 3745·21· BAT Subject to Exemption Permit Size Permit Effective Submerged Other OAC rule 3745·31· Facility ID Facility Name Class EUid EU Description (gallons) Date Fill Additional Terms 07(0) 09(l) 09(Z) Submerged Fill requirements 03 No. employed? 0180010008 The Scotts Co. TV T012 Bifenthrin pesticide storage tank 16,000 01-08386 4-Mar-04 Yes This emissions unit is subject to 40 CFR No No No Yes oc 0.19 TPY Yes Part 60 Subpart Kb {record keeping only) nd BAT. 1431071208 VALVOLINE OIL NTV T067 fixed roof storage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom-fill inlet Yes B ottom fill COMPANY 3745-21-09(1) [exempt from any piping, VOC = 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60

.

## '"'· 1431071208 VALVOLINE OIL NTV T068 fixed roofstorage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom-fill inlet Yes bottom fill COMPANY 3745-21-09(1) [exempt from any piping, VOC"" 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60 ovh r, n'" 1431071208 VALVOLINE OIL NTV T069 fixed roof storage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom-fill inlet Yes B ottomfill COMPANY 3745-21-09(1) [exempt from any piping, VOC = 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60

. 

### ··' 1431071208 VALVOUNE OIL NTV T070 fixed roof storage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom-fill inlet Yes B ottom fill COMPANY 3745-21-09(1} [exempt from any piping, VOC-= 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60 Vh <0. 

## "' 1431071208 VALVOLINE OIL NTV T071 fixed roofstorage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom fill inlet Yes B attorn f1ll COMPANY 3745-21-09(1) [exempt from any piping, VOC = 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60

"h ort Kh [,. 1431071208 VALVOLINE OIL NTV T072 fixed roof storage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom-fill inlet Yes B ottom fill COMPANY 3745-21-09(1) [exempt from any piping, VOC = 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60

••h "'· ""'
. 1431071208 VALVOUNE OIL NTV T073 fixed roof storage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom fill inlet Yes B ottomfill COMPANY 3745-21-09(1) [exempt from any piping, VOC = 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60 >Kh ,, 

## '"' 1431071208 VALVOLINE OIL NTV T074 fixed roof storage tank 15,000**14~05088** 14·Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom-fill inlet Yes B attorn fill COMPANY 3745-21-09(1) [exemptfrom any piping, VOC = 0.85 requirements since the tank is less than TPY. 40,000 gallons] and 40 CFR Part 60 Kh [, 1431071208 VALVOLINE OIL NTV T075 fixed roof storage tank 15,000 14-05088 14-Jun-04 Yes This emissions unit is subject to OAC rule No exempt No Yes bottom-fill inlet Yes B ottom fill COMPANY 3745-21-09(1) [exempt from any piping, VOC = 0.85 requirements since the tank is less than TPY. 40, 00 gallons] and 40 CFR Part 60 Vh ,, "'""
6 of? 2/12/2012 tanks_2004 %28working copy%29 YES.xlsxSubject to OAC rule 3745-21- BAT Subject to Exemption Permit Size Permit Effective Submerged Other OAC rule 3745-31- Facility ID Facility Name Class EUid EU Description (gallons) No. Date Fill Additional Terms 07 (D) 09(l) 09(ZJ Submerged Fill requirements 03 employed? 0180010008 The Scotts Co. TV T012 Bifenthrin pesticide storage tank 16,000 01-08386 4-Mar-04 Ye' This emissions unit is subjectto 40 CFR No No No Ye' oc 0.19TPY Ye' Part 60 Subpart Kb (record keeping only) nd BAT. 1431071208 VALVOLINE OIL NTV T076 fixed roofstorage tank 15,000 14-05088 14-Jun-04 Ye' This emissions unit is subject to OAC rule No exempt No Ye' bottom-fill inlet y_, B attorn fill COMPANY 3745-21-09(1) [exempt from any piping, VOC = 0.85 requirements sincethetank is less than TPY. 40,000 gallons] and 40 CFR Part 60 

### ""· 

## ·"' 1431071208 VALVOLINE OIL NTV T081 fixed roof storage tank- Modified 15,000 14-05088 14-Jun-04 No This emissions unit is subject to OAC rule No exempt No No fill pipe that No wall flow fill COMPANY 3745-21-09{1) [exempt from any directs the flow of requirements since the tank is less than material to the 40,000 gallons] and 40 CFR Part 60 wall ofthe tank, Subpart Kb [record keeping only]. VOC. VOC = 0.85 TPY 1431071208 VALVOL!NE OIL NTV T082 fixed roofstorage tank- Modified 15,000 14-05088 14-Jun-04 No This emissions unit is subjectto OAC rule No exempt No No fill pipe that No wall flow fill COMPANY 3745-21-09(1) [exempt from any directs the flow of requirements since the tank is less than material tothe 40,000 gallons] and 40 CFR Part 60 wall ofthe tank, Subpart Kb [record keeping only]. VOC = 0.85 TPY 1431071208 VALVOLINE OIL NTV T083 fixed roof storage tank- Modified 15,000 14-05088 14-Jun-04 No This emissions unit is subject to OAC rule No exempt No No fill pipe that No wall flow fill COMPANY 3745-21-09(1) [exempt from any directs the flow of requirements since the tank is less than material to the 40,000 gallons] and 40 CFR Part 60 wall ofthe tank, Subpart Kb [record keeping only]
. VOC = 0.85 TPY

..

7 of? 2/12/2012 tanks_2004 %28working copy%29 YES.xlsx

# Example OfA permit Issued in 2004 That Would not Have Been Subject To The Exemption Pursuant to OAC Rule 3745-31-03(A)(1)(l)(iv)State ofOhio Environmental Protection Agency 

### RE: PERMIT TO INSTALL REGISTRATION CERTIFIED MAIL Permit to

## InltN\fe~RWt\IJ'**st~And** 

### Conditions 122 S. Front Street Lazarus Gov. CenterTELE: (614) 644-3020 FAX: (614) 644-2329 

### Application No: 02-18928 DATE: 1/27/2004 BP Concord BulkPlant FrankA. Marsek 4850 E. 49th St., MBCl-122 CuyahogaHeights, OH44125 Mailing Address: LaZarus Gov. Center P.o. Box 1049



### Enclosed please find an Ohio EPA Permit to Install Registration which will allow you to iostall the descnbed source(s) io a manner iodicated io the permit. Because this permit registration contaios several conditions and restrictions I urge youto read it carefully. The Ohio EPA is 

### urging companies to iovestigate pollution prevention and energy conservation. Not only will this reduce pollution and energy consumption, but it can also save you money. Ifyou would like to learn ways you can save moneywhile protectiog the environment, please contact our Office ofPollution Prevention at (614) 644-3469. You are herebynotified that this action bythe Director is 

### final and may be appealed to the Ohio Environmental Review Appeals Commission pursuant to Chapter 3745.04 ofthe Ohio Revised Code. The appeal must be io writiog and set forth the action cornplaioed ofand the grounds upon which the appeal is 

### based. It 

### must be filed within thirty (30) days after the notice ofthe Directors action. A copy of the appeal must be served on the Director ofthe Ohio Environmental Protection Agency within three (3) days offiliog with the Commission. Ao 

### appealmaybe filed withthe Environmental Review Appeals Commission at the followiog address:

Siocerely, Environmental Review Appeals Commission 309 SouthFourth Street, Room222 Columbus, Ohio 43215

### N..-tdu/v~ Michael W. Ahern, Supervisor Field Operations and Permit Section Division ofAirPollution Control
CC: NEDO



### STATE OF OHIO ENVIRONMENTAL PROTECTION AGENCY PERMIT TO INSTALL REGISTRATION

### ApplicationNumber: APS PremiseNumber: PermitFee: Name ofFacility: Personto Contact: Address: 02-18928 0243000887 $200 

### BP Concord BulkPlant Frank A. 

### Marsek 4850 E. 49th St., MBCl-122 Cuyahoga Heights, OH 44125 Location ofproposed air contaminant source(s) [emissions unit(s)]: 7669 Crile Road Painesville, Ohio 

### Description ofproposed emissions unit(s): 16,000 gallon above ground storage tank. 

### Date oflssuance: Effective Date: 1127/2004 1/27/2004 The above named entity is hereby granted a Permit to Install Registration for the above described source(s) pursuant to Chapter 3745-31 ofthe Ohio Administrative Code. Issuance ofthis permit does not constitute expressed orimplied approval or agreementthat, if

### constructed ormodified in accordance with the plans included in the application, the above described source(s) ofenvironmental pollutants will operate in compliance with applicable State and Federal laws andregulations, and does not constitute expressed or implied assurance that if constructed or modified in accordance with those plans and specifications, the above described source(s) of pollutants willbe grantedthenecessarypermits to operate (air) 

### orNPDES permits as applicable. This permitis granted subject to the conditions attachedhereto. Ohio Environmental Protection Agency

Director

# ' 3 

### BP Concord BulkPlant PTIApplication: 

### 02-18928 Issued: 1127/2004 Facility ID: 

### 0243000887

Part I- GENERAL TERMS AND CONDITIONS A. 

### Permit to Install General Terms and Conditions 1. 

### Compliance Requirements The emissions unit(s) identified in this 

### Permit to Install shall remain in full compliance with all applicable State laws and regulations and the terms and conditions ofthis permit. 

### 2. Reporting Requirements The permittee shall submit requiredreports inthe following manner:
a. Reports ofany required monitoring and/or recordkeeping information shall be submitted to the appropriate Ohio EPADistrict Office or local air agency. b. 

### Except as otherwise may be provided in the terms and conditions for a specific emissions unit, quarterly written reports of(a) any deviations (excursions) from emission limitations, operational restrictions, and control device operating parameter limitations that have been detected by the testing, monitoring, and recordkeeping requirements specified in this permit, (b) 

### the probable cause of such deviations, and (c) any corrective actions or preventive measures which have been or will 

### be taken, shall be submitted to the appropriate Ohio EPADistrict Office or local air 

### agency. Ifno deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter. The reports shall be submitted quarterly, i.e., by January 31, April30, July 31, and October 31 ofeach year and shall cover the previous calendar quarters. (These quarterly reports shall exclude deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.) 

### 3. Records Retention Requirements Each record ofany monitoring data, testing data, and support information required pursuant to this permit shall be retained for a period offive years from the date the record was created. Support information shall include, but not be limited to, all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies ofall reports requiredbythis permit. Such records maybe maintained in computerized form. 

### 4. Inspections and Information Requests The Director ofthe Ohio EPA, or an authorized representative ofthe Director, may, subject to the safetyrequirements ofthe permittee and without undue delay, enter upon the premises ofthis source at any reasonable time for purposes ofmaking inspections, conducting tests, examining records or reports pertaining to any emission of air 

### contaminants, and determining compliance with any applicable State air pollution laws and regulations and the terms and conditions ofthis permit. The permittee shall furnish to the Director of the Ohio EPA, or an authorized

# • 4 

### BP Concord BulkPlant 

### PTIApplication: 02-18928 Issued: 1/27/2004 

### FacilityID: 0243000887


### representative ofthe Director, upon receipt ofa written request and within areasonable time, any information that may be requested to detennine whether cause exists for modifYing, reopening or revoking this permit or to determine compliance with this permit. Upon verbal or written request, the permittee shall also furnish to the Director ofthe Ohio EPA, or an authorized representative ofthe Director, copies ofrecords required to be kept by this permit. 5. Scheduled Maintenance/Malfunction Reporting 

### Any scheduled maintenance ofair pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745-15-06. The malfunction of any emissions units or any associated air pollution control system(s) shall be reported to the appropriate Ohio EPA District Office or local air agency in accordance with paragraph (B) 

### ofOACrule 3745-15-06. Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown ofthe emissions unit(s) that is (are) served by such control system(s). 6. Permit Transfers

7. 

### Any transferee ofthis 

### permit shall assume the responsibilities ofthe prior permit holder. The appropriate Ohio EPA District Office or local air agency must be notified in writing of any transfer ofthis permit
. Air Pollution Nuisance 

### The air 

### contaminants emittedbythe emissions units coveredbythis permit shall not cause a public nuisance, in violation ofOACrule 3745-15-07. 8. Termination ofPermit to Install 

### This Permit to Install shall terminate within eighteen months ofthe effective date ofthe Permit to Install if 

### the owner or operator has not undertaken a continuing program of installation or modification or has not entered into a binding contractual obligation to undertake and complete within a reasonable time a continuing program ofinstallation or modification. This deadline may be extended by up to 12 months if

### application is made to the Director within a reasonable time before the termination date and the party shows good cause for any such extension. 9. Construction ofNew Sources(s) 

### The proposed emissions unit(s) shall be constructed in 

### strict accordance with the plans and application submitted for this permit to the Director of the Ohio Environmental Protection Agency. There may be no deviation from the approved plans without the express, written approval ofthe Agency. Any deviations from the approved plans or the above conditions may lead to such sanctions

# • 5 

### BP Concord BulkPlant PTI Application: 

### 02-18928 Issued: 1127/2004 Facility ID: 

### 0243000887

10.

11. and penalties as provided under Ohio law. Approval of these plans does not constitute an assurance that the proposed facilities will operate in compliance with all Ohio laws and regulations. Additional fucilities shall be installed upon orders of the Ohio Environmental ProtectionAgency ifthe proposed sources cannot meet the requirements ofthis permit or cannot meet applicable standards. Ifthe construction ofthe proposed emissions unit(s) has already begun or has been completed prior to the date the Director of the Environmental Protection Agency approves the permit application and plans, the approval does not constitute expressed or implied assurance that the proposed facility has been constructed in accordance with the approved plans. The action of beginning and/or completing construction prior to obtaining the Director's approval constitutes a violation of OAC rule 3745-31-02. Furthermore, issuance of the Permit to Install does not constitute an assurance that the proposed source 

### will operate in compliance with all Ohio laws and regulations. Approval ofthe plans in any case is not to be construed as an approval ofthe facility as constructed and/or completed. Moreover, issuance ofthe Permit to Install is not to be construed as a waiver of any rights that the Ohio Environmental Protection Agency (or other persons) mayhave against the applicant for starting construction prior to the effective date ofthe permit. Additional fucilities shall be installed upon orders ofthe Ohio Environmental Protection Agency ifthe proposed fucilities cannot meet the requirements of this permit or cannot meet applicable standards. 

### Public Disclosure The fucility is hereby notified that this permit, and all agencyrecords concerning the operation of this permitted source, are subject to public disclosure in accordance with OAC rule 3745-49-03. 

### Applicability This Permit To Installis applicable onlyto the emissions unit(s) identified in the Permit To Install Separate Permit To Install for the installation or modification ofany other emissions unit(s) are required for any emissions unit for which a Permit To Install is required. 

### 12. Best Available Technology As specified in OAC Rnle 3745-31-05, all new sources must employ Best Available Technology (BAT). Compliance withthe terms and conditions ofthis permit 

### will

### fulfill this requirement. 

### 13. Source Operation and Operating Permit Requirements After Completion ofConstruction This facility is permitted to operate each source described by this Permit to Install for a period of up to one year from the date the source commenced operation. This permission to operate is granted only if the fucility complies with all requirements contained in this permit and all applicable air pollution laws, regulations, and policies. Pursuant to OAC Chapter 3745-35, the permittee shall submit a complete operating permit application within ninety (90) days after commencing operationofthe emissions unit(s) coveredby

### this permit.

# t 6 

### BP ConcordBulk

### Plant PTI Application: 02-18928 Issued: 1127/2004 FacilityID: 02430008877 

### BPConcord BulkPlant PTI Application: 02-18928 

### Issued: 1127/2004 FacilityID: 0243000887

14. 

### Construction Compliance Certification The applicant shallprovide Ohio EPAwith a written certification (see enclosed form) thatthe facility has been constructed in accordance with the Permitto Install application and the terms and conditions ofthe Permit to Install. The certification shall be provided to Ohio EPA upon completion ofconstructionbutpriorto startup ofthe source. 

### 15. Fees The permittee shall pay fees to the Director ofthe Ohio EPA in accordance with ORC section 3745.11 and OAC Chapter 3745-78. Thepermittee shall pay all applicable Permitto Install fees within 30 days afterthe issuance ofthis Permitto Install. 

### B. Permitto Install SummaryofAllowable Emissions The following information summarizes the total allowable emissions, bypollutant, basedon the individual allowable emissions ofeach air contaminant source identifiedinthis permit. SUMMARY (for informationalpurposes only) 

### TOTALPERMIT TO INSTALLALLOW ABLEEMISSIONS Pollutant



# voc Tons PerYear 0.108 BP Concord BulkPlant**PTIAr-1:~~...:"".....** n., 1IOR"tO FacilityID: 0243000887 Issued EmissionsUnitID: T012 PART II- SPECIAL TERMS AND CONDITIONS FORSPECIFIC EMISSIONS UNIT(S) A. Applicable Emissions Limitations and/or ControlRequirements 1. The specific operations(s), property, and/or equipmentwhich constitutethis emissions unit are listed in the following table along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from this unit shall not exceedthe listedlimitations, andthe listed control measures shallbe specified innarrative form following the table. Operations, Property,

and/or Equipment Aoolicable Rules/Requirements Applicable Emissions Limitations/ControlMeasures T012

- Submerged fill 16,000 OAC rule 3745-31-05 (A)(3) gallon above-ground storage tank VOC: 0.10 tonperyear ControlRequirements (see A.2.a) OAC rule 3745-21-09(L) Exempt (see A.2.b) 2. Additional Terms and Conditions 2.a The "Best Available Technology" (BAT) control requirements for this emissions unit has beendetermioed to be the use ofa submerged fillpipe. 2.b In accordance with OAC rule 3745-21-09(L)(2), this storage tank is exempt from the requirements of OAC rule 3745-21-09(L) because the tank has a capacity of less than 40,000 gallons. B. OperationalRestrictions None C. Monitoring and/orRecordkeeping Requirements 

### 1. The owner and operator ofthis emissions unit shall keep readily accessible records showing the diroension of the storage vessel and an analysis showing the capacity of the storage vesselfor 

### the life ofthe emissions unit. D. ReportingRequirements

4752.wpd

# f 9 BPCu 

### PTIAJ Issued: 1/27/2004 None

4752.wpd 

### Enrissions Unit ID: T01210 BPCu 

### PTIAJ 

### Issued: 1!27 /2004 E. Testing Requirements 1. Emission Limitation: 0.10 ton ofVOCper year Applicable Compliance Method: Emissions Unit ID: 

### T012

The permittee may use U.S. EPA Tanks 4.0 programto demonstrate compliance with the annual limit ofO.lO tonper year for organic compound. 

### F. Miscellaneous Requirements None

4752.wpd

# J· State ofOhio EnvironmentalProtection Agency RE: FINAL PERMIT TO INSTALL CERTIFIED MAIL COLUMBIANA COUNTY Street Address: 122 S. Front Street Lazarus Gov. CenterTELE: (614) 644-3020 FAX: (614) 644-2329 Application No: 02-18857 DATE: 3/18/2004 Hays OilCo., Inc. JerryEarly 1080 Elmwood Street EastLiverpool, OH 43920 Mailing Address: Lazarus Gov. Center P.O. Box 1049

Enclosed please find an Ohio EPA Permit to Install which will allow you to install the descnbed source(s) io a manner iodicated io the permit. Because this permit contaios several conditions aod restrictions, I urge you to read it carefully. The Ohio EPA is urgiog companies to iovestigate pollution prevention and energy conservatiorL Not only will this reduce pollution and energy consumption, but it can also save you money. Ifyou would like to learn ways you can save moneywhile protectiog the environment, please contact our Office ofPollutionPrevention at (614) 644-3469. You are hereby notified that this action bythe Director is final and may be appealed to the Ohio Environmental Review Appeals Commission pursuant to Chapter 3745.04 ofthe Ohio Revised Code. The appeal must be io writiog and set forth the action complaioed ofand the grounds upon which the appeal is based. It must be filed within thirty (30) days after the notice of the Directors actiorL A copy of the appeal must be served on the Director ofthe Ohio Environmental Protection Agency withio three (3) days of:filing with the Commission. 

### An appeal maybe filed with the EnvironmentalReview Appeals Commission atthe following address:

Siocerely,

### PCAdu/V.~ EnvironmentalReview Appeals Commission 309 SouthFourth Street, Room222 Columbus, Ohio 43215

MichaelW. Ahern, Supervisor Field Operations and Permit Section Division of

### Air Pollution Control cc: USEPA NEDO

# ••



# • STATE OF OIDO ENVIRONMENTALPROTECTION AGENCY 

### PermitTo Install Terms and Conditions Issne Date: 3/18/2004 Effective Date: 3/18/2004 FINAL PERMITTO INSTALL 02-18857 ApplicationNumber: APS PremiseNumber: P=itFee: Narne ofF acility: Personto Contact: Address: 02-18857 0215020356 

### $800 Hays Oil Co., Inc. Jerry Early 1080 Elmwood Street EastLiverpool, OH43920 Location ofproposed aircontaminant source(s) [emissions unit(s)]: 

### 1080 Elmwood Street EastLiverpool, Ohio Description ofproposed emissions unit(s): 

### Loadingrackwith four loading arms, six storage tanks, roadways andparking areas.
The above named entity is hereby granted a Permit to Install for the above described emissions unit(s) pursuantto Chapter 3745-31 ofthe Ohio Administrative Code. Issuance ofthis permit does not constitute expressed or implied approval or agreementthat, ifconstructed ormodified in accordance with theplans included in the application, the above described emissions unit(s) ofenvironmentalpollutants will operate in compliance with applicable State andFederallaws and regulations, and does not constitute expressed orimplied assurance that if constructed or modified 

### in accordance with those plans and specifications, the above described emissions unit(s) ofpollutants willbe grantedthe necessarypermitsto operate (air) orNPDES permits as applicable. This permitis granted subject to the conditions attachedhereto.

### ~otection Agency

Director3 

### Hays Oil 

### Co., Inc. FacilityID: 0215020356 PTIApplication: 02-18857 Issued: 3/18/2004 PartI- GENERAL TERMS AND CONDITIONS A. Permitto Install GeneralTerms and Conditions 1. Compliance Requirements The emissioru; unit(s) identified in this Permit to lru;tall shall remain in full 

### compliance with all 

### applicable State laws andregulatioru; and tbe terms and conditioru; ofthispennit. 

### 2. ReportingRequirements The permittee shall submit requiredreports in the following manner:
a. Reports ofany required monitoring and/or recordkeeping information shall be submitted to the appropriate Ohio EPADistrict Office or local 

### air agency. b. Except as otherwise may be provided in the terms and conditioru; for a specific emissioru; unit, quarterlywrittenreports of(a) any deviatioru; (excursioru;) from emission limitatioru;, operational restrictioru;, and 

### control device operating parameter limitatioru; that have been detected by the testing, monitoring, and recordkeeping requirements specified in this permit, (b) the probable cause of such deviatioru;, and (c) any corrective actioru; or preventive measures which have been or 

### will be taken, shall be submitted to the appropriate Ohio EPADistrict Office or local air agency. Ifno deviatioru; occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviatioru; occurred during that quarter. The reports shall be 

### submitted quarterly, ie., by 

### January 31, Apri130, July 31, and October 31 ofeach year and shall cover the previous calendar quarters. (These quarterly reports shall exclude deviatioru; resulting from malfunctioru; reported in accordance with OAC rule 3745-15-06.) 

### 3. Records Retention Requirements Each record of any monitoring data, testing data, and support information required pursuant to this pennit shall be retained for a period of five years from the date the record was created. Support information shall include, but not be limited to, all cahbration and maintenance records and all original strip-chartrecordings for continuous monitoring instrumentation, and copies ofall 

### reports requiredbythis permit. Suchrecords maybemaintained in computerized form 

### 4. Inspections and Information Requests The Director ofthe Ohio EPA, or an authorized representative ofthe Director, may, subject to the safetyrequirements ofthe permittee and without undue delay, enter uponthe premises ofthis source at any reasonable time for purposes ofmaking inspectioru;, conducting tests, examining records or reports pertaining to any emission of air contaminants, and determining compliance with any applicable State 

### air pollution laws and regulations and the terms and conditioru; ofthis pennit. The permittee shall furnish to the Director of the Ohio EPA, or an authorized

### ' 4 Hays Oil Co., Inc. FacilityID: 0215020356 PTI Application: 02-18857 Issued: 3/18/2004 representative ofthe Director, uponreceipt ofa writtenrequest and within a reasonable time, any information that maybe requested to determine whether cause exists for modifying, reopening or revoking this permit orto determine compliance withthis permit. Uponverbal or writtenrequest, the permittee shall also furnish to the Director ofthe Ohio EP**~** or an authorized representative ofthe Director, copies ofrecords required to be kept bythis permit. 5. Scheduled Maintenance/Malfunction Reporting Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745-15-06. The malfunction of any emissions units or any associated air pollution control system(s) shall be reported to the appropriate Ohio EPA District Office or local air agency in accordance with paragraph (B) ofOAC rule 3745-15-06. Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown ofthe emissions unit(s) that is (are) servedby such control system(s). 6. Permit Transfers Any transferee ofthis permit shall assume the responsibilities ofthe prior permit holder. The appropriate Ohio EPA District Office or local air agency must be notified in writing of any transfer ofthis permit. 7. 

### AirPollution Nuisance 

### The air contaminants emitted bythe emissions units coveredbythispermit shallnot cause a public nuisance, inviolation ofOAC rule 3745-15-07. 8. Termination ofPermitto Install This Permit to Install shall terminate within eighteen months ofthe effective date ofthe Permit to Install if the owner or operator has not undertaken a continuing program of installation or modification or has not entered into a binding contractual obligation to undertake and complete within a reasonable time a continuing program ofinstallation or modification. This deadline may be extended by up to 12 months if application is made to the Director within a reasonable time before the termination date and the party shows good cause for any such extension. 9. Construction ofNew Sources(s) The proposed emissions unit(s) shall be constructed in strict accordance with the plans and application submitted for this permit to the Director of the Ohio Environmental Protection Agency. There may be no deviation from the approved plans without the express, written approval ofthe Agency. Any deviations from the approved plans or the above conditions may leadto such sanctions5 

### Hays Oil Co., Inc. FacilityID: 0215020356 PTI Application: 02-18857 Issued: 3/18/2004 and penalties as provided under Ohio law. Approval of these plaos does not constitute an assurance that the proposed facilities will operate in compliance with all Ohio laws and regulations. Additional facilities shall be installed upon orders of the Ohio Environmental Protection Agency if

### the proposed sources canoot meet the requirements ofthis permit or canoot meet applicable standards. Ifthe construction ofthe proposed emissions unit(s) has already begun or has been completed prior to the date the Director of the Environmental Protection Agency approves the permit application and plaos, the approval does not constitute expressed or implied assurance that the proposed facility has been constructed in accordance with the approved plaos. The action of begioning and/or completing construction prior to obtaining the Director's approval constitutes a violation of OAC rule 3745-31-02. Furthermore, issuance of the Permit to Install does not constitute an assurance that the proposed source 

### will operate in compliance with all Ohio laws and regulations. Approval ofthe plaos in aoy case is not to be construed as an approval ofthe facility as constructed and/or completed. Moreover, issuance ofthe Permit to Install is not to be construed as a waiver of aoy rights that the Ohio Environmental Protection Agency (or other persons) may have against the applicant for starting constructionprior to the effective date ofthe permit. Additional facilities shall be installed upon orders ofthe Ohio Environmental Protection Agency if

### the proposed facilities canoot meet the requirements of this permit or canoot meet applicable standards. 

### 10. PublicDisclosure The facility is hereby notified that this permit, aod 

### all agencyrecords concerning the operation of this permitted source, are subject to public disclosure inaccordance with OAC rule 3745-49-03. 

### 11. Applicability This Permit To Install is applicable only to the emissions unit(s) identified inthe P=it To Install. Separate P=it To Install for the installation or modification of any other emissions unit(s) are required for any emissions unit for which a Permit To Install is required. 

### 12. Best Available Technology As 

### specified in OAC Rule 3745-31-05, all new sources must employ Best Available Technology (BAT). Compliance withthe terms and conditions ofthis p=it

### will fulfill

### this requirement. 

### 13. Source Operation and OperatingPermitRequirements After Completion ofConstruction This facility is p=ittedto operate each source descnbed by this Permit to Install for a period of up to one year from the date the source commenced operation. This 

### pennission to operate is granted only if 

### the facility complies with all requirements contained in this permit and all applicable air pollution laws, regulations, and policies. Pursuant to OAC Chapter 3745-35, the permittee shall submit a complete operating permit application within ninety (90) days after co=encing operation ofthe emissions unit(s) coveredbythis 

### p=it.6 

### Hays Oil 

### Co., Inc. FacilityID: 0215020356 PTIApplication: 02-18857 Issued: 3/18/2004

14. Construction Compliance Certification The applicant shallprovide Ohio EPAwith a written certification (see enclosed form) that the facility has been constructed io accordance with the Permitto Install application andtheterms and conditions ofthe Permit to Install. The certification shall be provided to Ohio EPA upon completion ofconstructionbutpriorto startup ofthe source. 

### 15. Fees The permittee shall pay fees to the Director ofthe Ohio EPA io accordance with ORC section 3745.11 and OAC Chapter 3745-78. Thepermittee shall pay all applicable Permitto Install fees withio 30 days after the issuance ofthis Permitto Install. 

### B. Permitto InstallSummary ofAllowable Emissions Thefollowiog information summarizes the total allowable emissions, bypollutant, basedontheiodividual allowable emissions ofeach air contaminant source identified iothis permit. SUMMARY (forinformationalpurposes only) 

### TOTALPERMIT TO INSTALLALLOW ABLEEMISSIONS Pollutant PM 

# oc Tons PerYear 1.0 2.020 Hays Oil Co., Inc. FacilityID: 0215020356 PTIAnnlication: 02-18857 Issued EmissionsUnit ID: T003 PART II- SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S) A. ApplicableEmissions Limitations and/or ControlRequirements 1. The specific operations(s), property, and/or equipment which constitute this emissions unit are listed in the following table along withthe applicable rules and/or reqillrements and withthe applicable emissions limitations and/or control measures. Emissions from this unit shallnot exceed the listed limitations, and the listed control measures shallbe specified innarrative form following thetable. Operations, Property,

and/or Equipment Applicable Rules/Regillrements Applicable Emissions Limitations/ControlMeasures T003

- 12,000 gallon, cylindrical, steel, dieseltank (T-4) 

### with fixed roof OACrule 3745-31-05(A)(3) OACrule 3745-21-09(L) See Sections A.2.a andb. Exempt. See SectionA.2.c. 40 CFR 60, Subpart Kb Exempt. See SectionA.2.d. 2. Additional Terms and Conditions 2.a Combined emissions from emissions units TOOl, T002, T003, T004, T005 and T006 (tanks T-1, T-2, T-4, T-5, T-9 and T-10) shallnot exceed 1.0 ton organic compounds peryear. 2.b This emissions unit shalluse a submerged fillpipe. 2.c Inaccordance with OAC rule 3745-21-09(L)(2), this storage tankis exempt fromthe reqillrements ofOAC rule 37 45-21-09(L )(1) because the tankhas a capacity ofless than 40,000 gallons. 2.d Inaccordance with 40 CFR 60.110b(a), this storage tankis exempt from the requirements ofSubpart Kb because the tankhas a capacity less than 75m 3 (19,815 gallons). B. OperationalRestrictions 

### 1. This storage tank shall contain only diesel (distillate fuel oilno. 2) with a maximumvapor pressure no greater than 15.0kPa (2.176 psi). C. Monitoring and/or RecordkeepingRequirements

4466.wpd21 Hays ( 

### PTIA Emissions Unit ID: T003 Issued: 3/18/2004 1. Thepermittee shall maintainmonthlyrecords documenting 1) the throughput of**diese~** in gallons permonth; and 2) the throughput ofdiesel to date for the calendar year, in gallons per year. 2. The permittee shallkeep readily accessible records showing the dimension ofthe storage vessel and an analysis showing the capacity ofthe storage vessel for the life ofthe emissions unit. 

### D. Reporting Requirements 1. 

### The permittee shall a deviationreport to the Ohio EPA, Northeast District Office, 

### ifthe storage tank is filled with any other liquid other than diesel (distillate fuel oilno. 2) within 30 days ofthe occurrence. 2. The permittee shall a deviationreport to the Ohio EPA, Northeast District Office, 

### ifthe storage tank is filled by any othermeans other thanby a submerged fill pipe. 3. The permittee shall submit a deviationreport to the Ohio EPA, Northeast District Office, 

### ifthe combined organic compound emissions from TOOl, T002, T003, T004, TOOS and T006 exceeds 1.0 tonper year. This report shallbe submitted byJanuary 31, covering the previous calendar year. 

### E. TestingRequirements 1. Emission Limitation: Combined emissions from emissions uuits TOOl, T002, T003, T004, TOOS and T006 (tanks T-1, T-2, T-4, T-5, T-9 and T-10) shall not exceed 1.0 ton organic compounds (OC) peryear. Applicable Compliance Method: To demonstrate compliance with the annual limit of 1.0 tonperyear ofOC emissions, the permittee shall calculate the annual OC emissions 

### intonperyear using the latest version ofU.S. EPA's TANKS software (currently TANKS 4.0). 

### F. Miscellaneous Requirements None

4466.wpd

# Example OfA permit Issued in 2004 That Would not Have Been Subject To The Exemption Pursuant to OAC Rule 3745-31-03(A)(1)(l)(iv)State ofOhioEnvironmental ProtectionAgency 

### RE: FINAL PERMIT TO INSTALL CERTIFIED MAIL ADAMS COUNTY Street Address: 122 S. Front Street Lazarus Gov. CenterTELE: (614) 644-3020 FAX: (614) 644-2329 

### Application No: 07-00547 Fac ID: 070I000070 

### DATE: 5/5/2005 Ershigs, Inc. Bruce Smith 742 Marine Drive Box 1707 Bellingham, WA 98227 Mailing Address: r:azarus Gov. Center P.O. Box 1049

Enclosed please find an Ohio EPA Permit to Install which 

### will allow you to install the descnbed source(s) in a manner indicated in the permit. Because this permit contains several conditions and restrictions, I urge you to readit carefully. The Ohio EPA is urging companies to investigate pollution prevention and energy conservation. Not only 

### will this reduce pollution and energy consumption, but it can also save you money. Ifyou would like to learn ways you can save moneywhile protecting the environment, please contact our Office ofPollution Prevention at (614) 644-3469. You are hereby notified that this action by the Director is final and maybe appealed to the Ohio Environmental Review Appeals Commission pursuant to Chapter 3745.04 ofthe Ohio Revised Code. The appeal must be in writing and set forth the action complained ofand the grounds upon which the appeal is based. It must be filed within thirty (30) days after the notice 

### ofthe Directors action. A copy of the appeal must be served on the Director ofthe Ohio Environmental Protection Agency within three (3) days offiling with the Commission. An appealmaybe filed with the Environmental Review Appeals Commission at the following address:

Sincerely, 

# 7¥...Ldul'1,/

### ~ EnvironmentalReviewAppeals Commission 309 SouthFourth Street, Room222 Columbus, Ohio 43215

Michael

### W. Ahern, Manager Permit Issuance and DataManagement Section Division of

### AirPollution Control cc: USEPA PCHD

### STATE OF OIDO ENVIRONMENTAL PROTECTION AGENCY Permit To Install Terms and Conditions Issue Date: 5/5/2005 Effective Date: 5/5/2005 FINAL PERMIT TO INSTALL 07-00547 ApplicationNumber: 07-00547 FacilityID: 0701000070 PermitFee: $900 Name ofFacility: Ersbigs, Inc. Person to Contact: Bruce Smith Address: 742 Marine Drive Box 1707 Bellingham, W A 98227 Location ofproposed air contaminant source(s) [emissions unit(s)]: 745 US Highway 52 Manchester, Ohio Description ofproposed emissions unit(s): Ershigs Inc. will construct and operate a temporary manufactnring facility for(FRP) chimney liners and jetbubbling reactors for DPLJ.M. Stuart Station.
The above named entity is hereby granted a Permitto Install for the above described emissions unit(s) pursuant to Chapter 3745-31 ofthe Ohio Administrative Code. Issuance ofthis permit does not constitute expressed or implied approval or agreement that, ifconstructed or modified in accordance with the plans included in the application, the above described emissions unit(s) ofenviromnentalpollutants will operate in compliance with applicable State andFederal laws andregulations, and does not constitute expressed or implied assurance that if constructed ormodified in accordance with those plans and specifications, the above described emissions unit(s) ofpollutants willbe grantedthe necessarypermits to operate (air) orNPDES permits as applicable. This permitis granted subject to the conditions attachedhereto. Ohio Enviromnental ProtectionAgency



# Jrff-JJ!

Director3 

### Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005 Part I- GENERAL TERMS AND CONDITIONS A. State and Federally Enforceable Permit To Install General Terms and Conditions 1. Monitoring and Related Recordkeeping and Reporting Requirements

a. Except as may otherwise beprovidedin the terms and conditions for a specific emissions unit, the permittee shall maintainrecords that include the following, where applicable, for anyrequiredmonitoring under this permit: i. The date, place (as defined inthe permit), and time ofsampling ormeasurements.
n. The date(s) analyses wereperformed.

m. The company or entitythat performed the analyses.
IV. The analyticaltechniques ormethods used.

v. The results ofsuch analyses.
VI. The operating conditions existing at the time ofsampling ormeasurement. b. Eachrecord ofanymonitoring data, testing data, and support informationrequired pursuant to this permit shallberetained for a period offive years from the date the record was created. Support information shall include, butnotbe limited to, all cahbration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies ofallreports requiredbythis permit. Suchrecords maybe maintained incomputerizedform.
c. Except as may otherwise beprovidedin the terms and conditions for a specific emissions unit, the permittee shall submit required reports inthe following manner:
1. Reports ofanyrequired monitoring and/or recordkeeping offederally enforceable information shallbe submittedto the appropriate Ohio EPADistrict Office or local air agency. 

### ii. Quarterlywrittenreports of(i) any deviations from federally enforceable emission limitations, operationalrestrictions, and control device operating parameter limitations, excluding deviations resulting frommalfunctions reported in accordance with OAC rule 3745-15-06, thathave beendetectedbythe testing, monitoring andrecordkeeping requirements specified in this permit, 

### (ii) the probable cause ofsuch deviations, and (iii) anycorrective actions orpreventive measures taken, shallbe made to the appropriate Ohio EPA District Office or local air agency. The writtenreports shallbe submitted quarterly, i.e., byJanuary 31, April30, July 31, and October 31 ofeachyear and shall cover the previous4 

### Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005 calendar quarters. See B.9 below ifno deviations occurred duriog the quarter.
m. Writtenreports, which identifY any deviations from the federally enforceable monitoring. recordkeeoing, andreporting requirements contained inthis permit shallbe submitted to the appropriate Ohio EPADistrict Office orlocal air agency every six months, i.e., byJanuary 31 and July 31 ofeachyear for the previous six calendar months. Ifno deviations occurred duriog a six-monthperiod, the permittee shall submit a semi-annualreport, which states that no deviations occurred duriog that period.
IV. Eachwrittenreport shallbe signedby a responsible official certifYing that, based oninformation andbeliefformed afterreasonable inquiry, the statements and information in the report are true, accurate, and complete. 

### 2. Scheduled Maintenance/MaHunction Reporting Anyscheduled maiotenance ofair pollution controlequipment shallbeperformedio accordance withparagraph (A) ofOACrule 3745-15-06. The malfunction, i.e., upset, ofany emissions units or any associated air pollution control system(s) shallbe reported to the appropriate Ohio EPA District Office orlocal air agencyioaccordance withparagraph (B) ofOAC rule 3745-15-06. (The definition ofanupset condition shallbethe same as thatusedio OAC rule 3745-15-06(B)(1) for a malfunction.) The verbal and writtenreports shallbe submittedpursuantto OAC rule 3745-15-06. Except asprovided io thatrule, any scheduled maiotenance ormalfunctionnecessitatiog the shutdownorbypassing ofanyair pollution control system(s) shallbe accompanied bythe shutdown ofthe emissionunit(s) that is (are) served by such control system(s). 

### 3. RiskManagement Plans Ifthe permittee is requiredto develop and register a riskmanagement planpursuantto section 112(r) ofthe Clean 

### Air Act, as amended, 42 U.S.C. 7401 et seq. ("Act"), the permittee shall complywiththe requirement to register such a plan. 

### 4. Title IV Provisions Ifthe permittee is subject to therequirements of40 CFRPart 72 concerning acid rain, the permittee shall ensure that any affected emissions unit complies withthose requirements. Emissions exceeding any allowances that are lawfullyheldunder Title IV ofthe Act, or any regulations adopted thereunder, are prohibited. 

### 5. Severability Clause A determinationthat anytermor condition ofthis permit is iovalid shall not iovalidate the force or effect ofanyother term or condition thereof; except to the extent that any other termor condition depends iowhole or iopart for its operation or implementationuponthe term or condition5 

### Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005 declared invalid. 

### 6. General Requirements
a. The permittee must complywith all terms and conditions ofthis permit. Any noncompliance withthe federally enforceable terms and conditions ofthis permit constitutes a violation ofthe Act, and is grounds for enforcement action or for permit revocation, revocation andreissuance, or modification, or for denial ofa permit renewal application. b. It 

### shall notbe a defense for the permittee in an enforcement actionthat it would have been necessaryto halt orreduce thepermitted activity in orderto maintain compliance with the federally enforceable terms andconditions ofthis permit.
c. This 

### permit maybe modified, reopened, revoked, orrevoked and reissued, for cause. The filing ofa request bythe permittee for a permit modification, revocation and reissuance, or revocation, or ofa notification ofplanned changes or anticipated noncompliance does not stayanyterm and condition ofthis permit. d. This 

### permit does not convey anypropertyrights ofany sort, or anyexclusive privilege.
e. The permittee shall furnish to the Director ofthe Ohio EPA, or an authorized representative ofthe Director, uponreceipt ofa writtenrequest and within a reasonable time, anyinformationthat maybe requestedto determine whether cause exists for modifying, reopening or revoking this permit orto determine compliance with this permit. Uponrequest, the permittee shall also furnish to the Director oran authorized representative ofthe Director, copies ofrecords requiredto be kept by

### this permit. For information claimed to be confidentialinthe submittalto the Director, if

### the Administrator oftheU.S. EPArequests suchinformation, the permittee may furnish suchrecords directlyto the Administrator along with a claim ofconfidentiality. 

### 7. Fees The permittee shallpayfees to the Director ofthe Ohio EPAin accordance with ORC section 3745.11 and OAC Chapter 3745-78. The permittee shallpayall applicable Permit To Install fees within 30 days after the issuance ofthis Permit To Install. 

### 8. Federal and State Enforceability Onlythose terms and conditions designated in

### this permit as federally enforceable, that are requiredunder the Act, or any ofits applicable requirements, including relevant provisions designed to limit the potential to emit ofa source, are enforceable bythe Administrator ofthe U.S. EPA, the State, and citizens under the Act. All other terms and conditions ofthis permit shall notbe federally enforceable and shallbe enforceable under State law only.6 

### Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005 9. Compliance Requirements
a. Anydocument (including reports) required to be submitted and requiredbya federally applicable requirement in 

### t:lris permit shall include a certification bya responsible official that, based oninformation and beliefformed after reasonable inquiry, the statements in the document are true, accurate, and complete. b. Uponpresentation ofcredentials and other documents as maybe requiredbylaw, the permittee shall allow the Director ofthe Ohio EPA or an authorized representative ofthe Director to:
1. 

### Atreasonable times, enter uponthe permittee's premises where a source is located orthe emissions-related activity is conducted, orwhere records must be kept under the conditions ofthis permit.
n. Have access to and copy, at reasonable times, anyrecords that must be kept under the conditions ofthis permit, subject to the protectionfrom disclosure to the public ofconfidential information consistent with ORC section 3704.08. 

### iii. Inspect at reasonable times any fucilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated orrequiredunder this permit.
IV. 

### As authorizedbythe Act, sample ormonitor at reasonable times substances or parameters for the purpose ofassuring compliance with the permit and applicable requirements.
c. The permittee shall submit progressreports to the appropriate Ohio EPADistrict Office or local air agencyconcerning any schedule ofcompliance for meeting an applicable requirement. Progress reports shallbe submitted semiannually, ormore frequently if 

### specified inthe applicable requirement orbythe Director ofthe Ohio EPA. Progress reports shall containthe following:
1. 

### Dates for achieving the activities, milestones, or compliance required in any schedule ofcompliance, and dates when such activities, milestones, or compliance were achieved.
11. 

### Anexpla!lation ofwhy any dates in any schedule ofcompliance were not or

### will not bemet, and anypreventive or corrective measures adopted.7 

### Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005 10. Permit To Operate Application

a. Ifthe permitteeis required to apply for a Title V permit pursuant to OAC Chapter 3745-77, thepermittee shall submit a complete Title V permit application or a complete Title V permit modilication applicationwithintwelve (12) months after commencing operation ofthe emissions units coveredbythis permit. However, ifthe proposednew or modified source(s) wouldbeprohibitedbythe terms and conditions ofan existing Title V permit, a Title V permit modificationmust be obtainedbefore the operation ofsuchnew ormodilied source(s) pursuant to OAC rule 3745-77-04(D) and OAC rule 3745-77-08(C)(3)(d). b. Ifthe permittee is required to apply for permit(s) pursuant to OAC Chapter 3745-35, the source(s) identified in this Permit To Install is (are) permittedto operate for a period ofup to one year fromthe date the source(s) commenced operation. Permissionto operate is granted only ifthe facility complies with all requirements contained inthis permit and all applicable air pollution laws, regulations, andpolicies. Pursuantto OAC Chapter 3745-35, the permittee shall submit a complete operating permit applicationwithinninety (90) days after commencing operation ofthe source(s) coveredbythis permit. 

### 11. Best Available Technology As specified in OAC Rule 3745-31-05, allnew sources must employBest Available Technology (BAT). Compliance withthe terms and conditions ofthis permit will 

### fulfill this requirement. 

### 12. Air 

### Pollution Nuisance The air contaminants emittedbythe emissions units covered bythis permit shall not cause a public nuisance, in violation ofOAC rule 3 745-15-07.8 

### Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005 B. State Only Enforceable Permit To Install General Terms and Conditions 1. 

### Compliance Requirements The emissions unit(s) identified inthis Permitto Install shallremain in full compliance with all applicable State laws andregulations andtheterms and conditions ofthis permit. 

### 2. Reporting Requirements The permittee shall submit required reports inthe following manner:
a. Reports ofanyrequired monitoring and/or recordkeeping ofstate-only enforceable information shallbe submitted to the appropriate Ohio EPADistrict Office orlocal air agency. b. Except as otherwise maybeprovided in the terms and conditions for a specific emissions unit, quarterlywrittenreports of(a) any deviations (excursions) from state-onlyrequired emission limitations, operationalrestrictions, and control device operatingparameter limitations that have been detectedbythe testing, monitoring, andrecordkeeping requirements specified inthis permit, (b) the probable cause ofsuch deviations, and (c) any corrective actions orpreventive measures whichhave been orwillbetaken, shallbe submitted to the appropriate Ohio EPADistrict Office or local air agency. Ifno deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter. Thereports shallbe submitted quarterly, i.e., byJanuary 31, April30, Jnly 31, and October 31 ofeachyear and shall cover the previous calendar quarters. (These quarterlyreports shall exclude deviations resulting from malfunctions reported in accordance with OACrule 3745-15-06.) 

### 3. Permit Transfers Anytransferee ofthis permit shall assume the responsibilities ofthe priorpermit holder. The appropriate Ohio EPADistrict Office or local air agencymust benotified inwriting ofany transfer ofthis permit. 

### 4. Termination ofPermit To Install This permit to install shallterminate within eighteenmonths ofthe effective date ofthe permit to install ifthe owner or operatorhas notundertaken a continuing programofinstallation or modificationorhas not entered into a binding contractual obligation to undertake and complete9 

### Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005 within a reasonable time a continuing programofinstallation ormodification. This deadline may be extendedbyup to 12 months ifapplicationis made to the Directorwithin a reasonable time before the terminstion date andthe party shows good cause for any such extension.



### 5. Construction ofNew Sources(s) Theproposed emissions unit(s) shallbe constructed in strict accordance with the plans and application submitted for this permit to the Director ofthe Ohio EnvironmentalProtection Agency. There maybe no deviation from the approvedplans without the express, written approval ofthe Agency. Any deviations fromthe approvedplans or the above conditions may lead to such sanctions and penalties as provided under Ohio law. Approval ofthese plans does not constitute an assurance that the proposed facilities 

### will operate in compliance with all Ohio laws andregulations. Additional facilities shallbe installed upon orders ofthe Ohio EnvironmentalProtectionAgency ifthe proposed sources cannot meet the requirements ofthis permit or cannot meet applicable standards. Ifthe construction ofthe proposed emissions unit(s) has alreadybegun orhas been completed priorto the date the Director ofthe EnvironmentalProtectionAgencyapproves the permit application andplans, the approval does not constitute expressed or implied assurance that the proposedfucility has beenconstructedin accordance withthe approvedplans. The action of beginning and/or completing constructionpriorto obtaining the Director's approvalconstitutes a violation ofOACrule 3745-31-02. Furthermore, issuance ofthe Permit to Install does not constitute an assurance that the proposed source 

### will operate in compliance with all Ohio laws andregulations. Approval ofthe plans in anycase is not to be construed as an approval ofthe facility as constructed and/or completed. Moreover, issuance ofthe Permit to Install is notto be construed as a waiver ofanyrights that the Ohio EnvironmentalProtectionAgency (or other persons) mayhave against the applicant for starting constructionpriorto the effective date ofthe permit. Additional fucilities shallbe installed upon orders ofthe Ohio EnvironmentalProtection Agency ifthe proposed fucilities cannot meet the requirements ofthis permit or cannot meet applicable standards. 

### 6. Public Disclosure The facility is herebynotifiedthat this permit, and all agencyrecords concerning the operation of this permitted source, are subject to public disclosure in accordance with OACrule 3745-49-03. 

### 7. Applicability This Permit to Installis applicable onlyto the emissions unit(s) identified inthe Permit To Install. Separate applicationmustbe made to the Director for the installation ormodification ofany other emissions unit(s). 

### 8. Construction Compliance Certification10 Ershigs, Inc. Facility ID: 0701000070 PTI Application: 07-00547 Issued: 5/5/2005
Ifapplicable, the applicant shall provide Ohio EPAwith a written certification (see enclosed form ifapplicable) thatthe facility has been constructedin accordance with the PermitToInstall application andthe terms and conditions ofthe Permit to Install. The certification shall be providedto Ohio EPAupon completion ofconstructionbutpriorto startup ofthe source. 9. Additional Reporting Requirements When There Are No Deviations ofFederally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations (See Section A ofThis Permit) Ifno deviations occurred during a calendar quarter, thepermittee shall submit a quarterly report, which states that no deviations occurred during that quarter. Thereports shallbe submitted quarterly, i.e., byJanuary 31, April30, July 31, and October 31 ofeachyear and shall coverthe previous calendar quarters. C. Permit To Install Summary ofAllowable Emissions Thefollowing information summarizes the total allowable emissions, bypollutant, based onthe individual allowable emissions ofeach air contaminant source identifiedinthis permit. 

### SUMMARY (for informationalpurposes only) 

### TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS Pollutant



## voc Tons Per Year 39.7712 

### Ershigs, Inc. PTIApplication: 07-00547 Issued: 5/5/2005 Part II- FACILITY SPECIFIC TERMS AND CONDITIONS Facility ID: 0701000070

A. State and Federally Enforceable Permit To Install Facility Specific Tenus and Conditions 

### 1. 40 CFR- CHAPTER I-PART 63 Subpart WWWW- National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production [The following emissions units contained inthis permit are subject to 40 CFR 63, SubpartWWWW: POOl, P002, P003, TOOl, T002, T003.] 

### §§ 63.5780 What is the purpose ofthis subpart? This subpart establishes national emissions standards for hazardous airpollutants (NESHAP) for reinforced plastic composites production. This subpart also establishes requirements to demonstrate initial and continuous compliance withthe hazardous airpollutants (HAP) emissions standards. 

### §§ 63.5785 Am

### I subject to this subpart? (a) You are subject to this subpart ifyou ownoroperate a reinforcedplastic composites productionfucility that is located at a major source ofHAP emissions. Reinforced plastic composites production is limitedto operations inwhichreinforced and/or nomeinforcedplastic composites orplastic molding compounds are manufuctured using thermoset resins and/or gel coatsthat contain styrene to produce plastic composites. The resins and gel coats may also containmaterials designedto enhance the chemical, physical, and/or thermalproperties ofthe product. Reinforced plastic composites production also includes cleaning, mixing, HAP-containing materials storage, andrepair operations associated withthe production ofplastic composites. 

### (b) You are not subject to this subpart ifyour fucility onlyrepairs reinforced plastic composites. Repair includes the non-routine manufacture ofindividual components orparts intendedto repair a larger item as definedin §§ 63.5935 (c) You are not subject to this subpart ifyour fucility is a research and development facility as defined in section 112(c)(7) ofthe Clean

### Air Act (CAA). (d) You are not subject to this subpart ifyourreinforcedplastic composites operations use less than 1.2tons per year (tpy) ofthermosetresins and gel coats that contain styrene combined. 

### §§ 63.5787 What if

### I also manufacture fiberglass boats or boatparts? (a) Ifyour source meets the applicability criteria in§§ 63.5785, and is not subject to the Boat Manufacturing NESHAP (40 CFRpart 63, subpart VVVV), you are subject to this subpart regardless ofthe final use ofthe parts you manufacture. 

### (b) Ifyour source is subject to 40 CFRpart 63, subpart VVVV, and all thereinforced plastic composites you manufacture are usedinmanufacturing yourboats, you are not subject to this subpart. (c) Ifyou are subject to 40 CFRpart 63, subpartVVVV, andmeetthe applicability criteria in§§ 63.5785, and producereinforcedplastic composites that are notused in fiberglass boatmanufucture atyour facility, all operations associatedwiththe manufacture ofthereinforcedplastic composites parts that are notusedin124**Ershi~** 

### PTIA Issued: 5/5/2005 Emissions UnitID: TOOl


### Part 

### ill- SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S) A. State and Federally Enforceable Section I. Applicable Emissions Limitations and/or Control Requirements 1. The specific operations(s), property, and/or equipment which constitute this emissions unit are listed io the followiog table along with the applicable rules and/orrequirements and with the applicable emissions limitations and/or controlmeasures. Emissions from this unit shallnot exceed the listed limitations, andthe listed controlmeasures shallbe specified io narrative form followiog the table. Operations, Property, and/or Equipment TOOl

- Storage Tank 1 - 10,000 gallon fixed roof resio storage tankwith permanent submerged fill ptpe. Applicable Rules/Requirements OAC rule 3745-31-05 (A)(3)

OAC rule 3745-21-07 (D)(2) 40 CFRPart 63 Subpart WWWW ReinforcedPlastic Composites Production



### 2. Additional Terms and Conditions Applicable Emissions Limitations/Control Measures Volatile Organic Compound (VOC)* emissions fromthe emissions unit shallnot exceed 0.005 lb/hr and 0.022 tpy. See sectionA.2.bbelow

See sectionA.2.abelow. SeeFacility Specific Terms and Conditions, Part II, A.l
* Forthe purposes ofthis permit, all Organic Compound (OC) emissions and HAP emissions are consideredVOC emissions. VOC emissions ioclude HAPs, Styrene and MEK.



### 2.a The storage vessel shallbe equippedwith a permanent submerged fillpipe. 

### 2.b Thehourly and annual allowables represent the maximumproduction capacity ofthis125**Ershi~** 

### PTIA Issued: 5/5/2005 Emissions Unit ID: TOOl
emissions unit; therefore, no monitoring orrecordkeeping is requiredto demonstrate compliance.126**Ershi~** 

### PTIA Emissions Unit ID: TOOl 

### Issued: 5/5/2005 II. Operational Restrictions None ill. 

### Monitoring and/or Recordkeeping Requirements None 

### IV. Reporting Requirements None 

### V. Testing Requirements 1. Compliance with the allowable emission limitations inthis permit shallbe determined according to the following methods:
a. Emissions Limitation VOC emissions fromthis emissions unit shall not exceed 0.005 lbslhr and 0.022 tpy. Applicable Compliance Method: The permittee shall demonstrate compliance using the potentialto emit ofthis emissions unit as calculated in the PTI application. The potential to emit is basedupon the latest version of the TANKS program, the maximumtankmaterialthroughput, and the assumptionthe tank contains 100% styrene. The annual emissions shallbe multipliedby 2000 lb/ton and divided by 8760 hr/yr to obtain the hourly emission limitation. 

### VI. Miscellaneous Requirements None.127**Ershi~** 

### PTIA Issued: 5/5/2005 B. State Only Enforceable Section Emissions UnitID: TOO1



### I. Applicable Emissions Limitations and/or Control Requirements 1. The specific operations(s), property, and/or equipment which constitute this emissions unit are listed in the following table along with the applicable rules and/or requirements andwiththe applicable emissions limitations and/or controlmeasures. Emissions fromthis unit shallnot exceed the listed limitations, andthe listed controlmeasures shallbe specified innarrative form following the table. Operations, Property, and/or Equipment TOO1 - Storage Tank 1 - 

### 10,000 gallon fixed roof resin storage tankwith permanent submerged fill p1pe. Applicable Rules/Requirements



### 2. Additional Terms and Conditions 2.a None 

### ll. 

### Operational Restrictions None 

### ill. 

### Monitoring and/orRecordkeeping Requirements None 

### IV. Reporting Requirements None 

### V. Testing Requirements None 

### VI. Miscellaneous Requirements Applicable Emissions Limitations/Control Measures128 

### Ershigs, Inc. FacilityID: 0701000070 PTI**A--l.:-~.....:--~** tv,**nn~"""'** 

### Issued Emissions UnitID: TOO1 None129 

### Ershi! PTIA Issued: 5/5/2005 Emissions UnitID: T002


### Part ill- 

### SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S) A. State and Federally Enforceable Section I. Applicable Emissions Limitations and/or Control Requirements 1. The specific operations(s), property, and/or equipment which constitute this emissions unit are listed in the following table along with the applicable rules and/or requirements andwiththe applicable emissions limitations and/or controlmeasures. Emissions fromthis unit shall not exceed the listed limitations, and the listed controlmeasures shallbe specified in narrative form following the table. Operations, Property, and/or Equipment T002

- Storage Tank 2 - 10,000 gallon fixed roof resin storage tankwith permanent submerged fill p1pe. APPlicable Rules/Requirements OAC rule 3745-31-05 (A)(3)

OAC rule 3745-21-07 (D)(2) 40 CFRPart 63 Subpart WWWW Reinforced Plastic Composites Production



### 2. Additional Terms and Conditions Applicable Emissions Limitations/Control Measures Volatile Organic Compound (VOC)* emissions from the emissions unit shall not exceed 0.005 lb!hr and 0.022 tpy. See sectionA.2.b below

See sectionA.2.a below. See Facility Specific Terms and Conditions, Part II, A.l 

## * Forthe purposes ofthis permit, all Organic Compound (OC) emissions and HAP emissions are consideredVOC emissions. VOC emissions include HAPs, Styrene and MEK..



### 2.a The storage vessel shallbe equipped with a permanent submerged fill pipe. 

### 2.b Thehourly and annual allowables represent the maximumproduction capacity ofthis130 

### Ershi! PTIA Issued: 5/5/2005 Emissions Unit ID: T002
emissions unit; therefore, no monitoring orrecord keeping is 

### requiredto demonstrate compliance.131**Ershi~** 

### PTIA Emissions UnitID: T002 

### Issued: 5/5/2005 IT. Operational Restrictions None 

### ill. 

### Monitoring and/or Recordkeeping Requirements None 

### IV. Reporting Requirements None 

### V. Testing Requirements 1. Compliance with the allowable emission limitations inthis pennit shallbe detennined according to the following methods:

a. Emissions Limitation VOC emissions from this emissions unit shallnot exceed 0.005 lbslbr and 0.022 tpy. Applicable Compliance Method: The pennittee shall demonstrate compliance using the potentialto emit ofthis emissions unit as calculated 

### in the PTI application. The potentialto emit is based uponthe latest version of the TANKS program, the maximumtankmaterialthroughput, and the assumptionthe tank contains 100% styrene. The annual emissions shallbe multipliedby 2000 lb/ton and divided by 8760 br/yrto obtainthe hourly emissionlimitation. 

### VI. Miscellaneous Requirements None.132**Ershi~** 

### PTIA 

### Issued: 5/5/2005 B. State Only Enforceable Section Emissions Unit ID: T002



### I. Applicable Emissions Limitations and/or ControlRequirements 1. The specific operations(s), property, and/or equipment which constitute this emissions unit are listed in the following table along with the applicable rules and/or requirements and withthe applicable emissions limitations and/or controlmeasures. Emissions fromthis unit shallnot exceedthe listed limitations, and the listed controlmeasures shallbe specified innarrative form following the table. Operations, Property, and/or Equipment T002- Storage Tank 2 - I0,000 gallon fixed roof resin storage tankwith permanent submerged fill pipe. Applicable Rules/Requirements



### 2. Additional Terms and Conditions 2.a None 

### II. OperationalRestrictions None 

### ill. Monitoring and/or Recordkeeping Requirements None 

### IV. Reporting Requirements None 

### V. Testing Requirements None 

### VI. Miscellaneous Requirements Applicable Emissions Limitations/Control Measures133**Ershi~** 

### PTIA Issued: 5/5/2005
None Emissions UnitID: T002134**Ershi~** 

### PTIA Issued: 5/5/2005 Emissions UnitID: T003


### Part ill- SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S) A. State and Federally Enforceable Section I. Applicable Emissions Limitations and/or Control Requirements 1. The specific operations(s), property, and/or equipment which constitute this emissions unit are listed in the following table along withthe applicable rules and/orrequirements andwith the applicable emissions limitations and/or controlmeasures. Emissions from this unit shallnot exceedthe listed limitations, and the listed controlmeasures shallbe specified in narrative form following the table. Operations, Property, and/or Equipment T003

- Storage Tank 3 - 10,000 gallon fixed roof resin storagetank with permanent submerged fill ptpe. Applicable Rules/Requirements OAC rule 3745-31-05 (A)(3)

OAC rule 3745-21-07 (D)(2) 40 CFRPart 63 Subpart WWWW ReinforcedPlastic Composites
. Production



### 2. Additional Terms and Conditions Applicable Emissions Limitations/Control Measures Volatile Organic Compound (VOC)* emissions from the emissions unit shall not exceed 0.005 lblhr and 0.022 tpy. See section A.2.b below

See sectionA.2.abelow See Facility Specific Terms and Conditions, Part II, A.! * Forthe purposes ofthis permit, all Organic Compound (OC) emissions and HAP emissions are consideredVOC emissions. VOC emissions include HAPs, Styrene and MEK



### 2.a The storage vessel shallbe equippedwith a permanent submerged fillpipe. 

### 2.b The hourly and annual allowables represent the maxinmmproduction capacityofthis emissions unit; therefore, no monitoring orrecord keeping is required to demonstrate135 

### Ershigs, Inc. PTI A--"--"'--· Issued compliance. 

### Facility ID: 0701000070

Emissions Unit ID: T003


### II. Operational Restrictions None


### ill. 

### Monitoring and/or Recordkeeping Requirements None 

### IV. Reporting Requirements None 

### V. Testing Requirements 1. Compliance withthe allowable emissionlimitations inthis permit shallbe determined according to the following methods:
a. Emissions Limitation: VOC emissions from this emissions unit shallnot exceed 0.005 lbslhr and 0.022 tpy. Applicable Compliance Method: Thepermittee shall demonstrate compliance using the potentialto emit ofthis emissions unit as calculated inthe PTI application. Thepotentialto emit is baseduponthe latest version of the TANKS program, the maximumtankmaterialthroughput, and the assumptionthe tank contains 100% styrene. The annual emissions shallbe multipliedby 2000 lb/ton and dividedby 8760 hr/yr to obtainthe hourly emission limitation. 

### VI. Miscellaneous Requirements None136**Ershi~** 

### PTIA Issued: 5/5/2005 B. State Only Enforceable Section Emissions UnitID: T003

I. 

### Applicable Emissions Limitations and/or ControlRequirements 1. The specific operations(s), property, and/or equipment which constitute this emissions unit are listed in the following table along with the applicable rules and/or requirements andwiththe applicable emissions limitations and/or controlmeasures. Emissions fromthis unit shallnot exceed the listed limitations, andthe listed controlmeasures shallbe specified in narrative form fo!lowing the table. Operations, Property, and/or Equipment T003

- Storage Tank 3 - 10,000 gallon fixed roof resin storage tank with permanent submerged fill p1pe. Applicable Rules/Requirements



### 2. Additional Terms and Conditions 2.a None 

### ll. OperationalRestrictions None 

### ill. 

### Monitoring and/or Recordkeeping Requirements None 

### IV. Reporting Requirements None 

### V. Testing Requirements None 

### VI. Miscellaneous Requirements Applicable Emissions Limitations/Control Measures137**Ershi~** 

### PTIA Issued: 5/5/2005
None Emissions Unit ID: T003

# Examples Of Permits Issued in 2004 Where BAT Did Not Require Submerged FillFacility Name: LANXESS CORPORATION ADDYSTON, OH PLANT Facility ID: 14-31-111-11054 Emissions Unit:**A~25** TANK (T023) 

### Part Ill ·Terms and Conditions for Emissions Units Emissions Unit ID: Activity Description: A-25 TANK (T023) TANK

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements 1. The specific operation(s), property, and/or equipmentwhich constitute this emissions unit are listed in the following table along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed limitations, and the listed control measures shall be employed. Additional applicable emissions limitations and/or control measures (if any) may be specified in narrative form following the table. Operations, Property,

and/or Equipment 1 0,500-gallon, fixed roof storage tank, storing tertiary dodecyl mercaptan
2. Additional Terms and Conditions None II. Operational Restrictions Applicable Rules/ Requirements OAC rule 3745-31-05(A)(3) (PTI 14-2058) OAC rule 3745-21-07(0) Applicable Emissions Limitations/Control Measures 1.23 tpy of organic compounds
See section A.ll.1 below.

1. Ifthe permittee stores a volatile photochemically reactive material, as defined in OAC rule 3745-21-01 (C)(7) in this emissions unit the permitteee shall comply with the requirements of OAC rule 3745-21-07(0). Ill. Monitoring and/or Record Keeping Requirements 1. The permittee shall maintain the following information for each material stored in this emissions unit: a. the identification ofthe material stored: and b. whether or not the material stored is a volatile photochemically reactive material, as defined in OAC rule 3745-21-01 (C)(7). IV. Reporting Requirements 1. The permittee shall notify the Hamilton County Department of Environmental Services of any volatile photochemically reactive material stored in this emissions unit. The notification shall be submitted within thirty days after the commencement ofthe storage ofa volatile photochemically reactive material. V. Testing Requirements 1. Compliance with the emission limitation in section A.l.1 ofthese terms and conditions shall be determined in accordance with the following method:

ntle V Final Permit Page 251 Terms and Conditionsfor Emissions UnitsV. Testing Requirements (continued) 1.a Emission Limitation: 1.23 tpy of organic compounds Applicable Compliance Method: Facility Name: Facility ID: LANXESS CORPORATION ADDYSTON, OH PLANT 14-31-111-11054 Emissions Unit: A-25 TANK {T023)

The permittee may demonstrate compliance by using emission factors from USEPA reference document AP-42, fifth edition, Section 7.1, organic liquid storage tanks (September 1997). VI. Miscellaneous Requirements None

Title V Final Permit Terms and Conditions for Emissions Units Page 252Facility Name: LANXESS CORPORATION ADDYSTON, OH PLANT Facility ID: 14·31-111-0054 Emissions Unit: AR28 TANK (T025) 

### Part Ill -Terms and Conditions for Emissions Units Emissions Unit ID: Activity Description: A-28 TANK (T025) TANK

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements 1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in the following table along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed limitations, and the listed control measures shall be employed. Additional applicable emissions limitations and/or control measures (if any) may be specified in narrative form following the table. Operations, Property,

and/or Equipment 11 ,000-gallon fixed roof storage tank, storing dibutyl fumarate

2. Additional Terms and Conditions None II. Operational Restrictions Applicable Rules/ Requirements OAC rule 3745-31-05{A)(3) (PTI 14-02058) 40 CFR Part 60, Subpart Kb OAC rule 3745-21-07(0) Applicable Emissions Limitations/Control Measures 0.89 tpy of organic compounds None See section A.ll.1 below.

1. Ifthe permittee stores a volatile photochemically reactive material, as defined in OAC rule 3745-21-01(C)(7), in this emissions unit, the permittee shall comply with the requirements of OAC rule 3745-21-07(0)(1). Ill. Monitoring and/or Record Keeping Requirements 1. The permittee shall keep readily accessible records showing the dimensions ofthe storage vessel and an analysis showing the capacity ofthe storage vessel. [40 CFR 60.116b(a) and (b)] 2. The permittee shall maintain the following information for each material stored in this emissions unit: a. the identification ofthe material stored; and b. whether or notthe material is a volatile photochemically reactive material as defined in OAC rule 3745-21-01 (C)(7). 3. Pursuant to OAC rule 3745-77-07(A)(3)(a){ii), the following monitoring and record keeping requirements are as stringent as or more stringent than the monitoring and record keeping requirements contained in Permit to Install #14-02058, issued on December 12, 1990: sections A.lll.1 and A.lll.2. The monitoring and record keeping requirements contained in the above-referenced Permit to Install are subsumed into the monitoring and record keeping requirements ofthis operating permit, so that compliance with these requirements constitutes compliance with the underlying monitoring and record keeping requirements in the Permit to Install.

Title V Final Permit Page 257 Terms and Conditions for Emissions UnitsFacility Name: Facility ID: Emissions Unit: IV. Reporting Requirements LANXESS CORPORATION ADDYSTON, OH PLANT**14-31~1~054** A-28 TANK (T025)
1. The permittee shall notify the Hamilton County Department of Environmental Services ofany volatile photochemically reactive material stored in this emissions unit. The notification shall be submitted within thirty days after the commencement ofthe storage ofa volatile photochemically reactive material. V. Testing Requirements 1. Compliance with the emission limitation in section A.l.1 ofthese terms and conditions shall be determined in accordance with the following method: 1.a Emission Limitation: 0.89 tpy oforganic compounds Applicable Compliance Method: The permittee may demonstrate compliance by using emission factors from USEPA reference document AP-42, fifth edition, Section 7.1, organic liquid storage tanks (March, 1998). VI. Miscellaneous Requirements None

Title V Final Permit Terms and Conditions for Emissions Units Page 258Facility Name: LANXESS CORPORATION ADDYSTON, OH PLANT Facility ID: 14·3HI1-Q054 Emissions Unit: SEC BUOH TANK (T044) 

### Part Ill -Terms and Conditions for Emissions Units Emissions Unit 10: Activity Description: SEC BUOH TANK (T044) TANK

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements 1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in the following table along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed limitations, and the listed control measures shall be employed. Additional applicable emissions limitations and/or control measures (if any) may be specified in narrative form following the table. Operations, Property,

and/or Equipment 10,000-gallon fixed roof storage tank, storing secondary butanol
2. Additional Terms and Conditions None II. Operational Restrictions Applicable Rules/ Requirements OAC rule 3745·31·05(A)(3) (PTI 14-02486) OAC rule 3745-21·07(0) Applicable Emissions Limitations/Control Measures 0.13 tpy of organic compounds See section A. II. 1 below.

1. Ifthe permittee stores a volatile photochemically reactive material, as defined in OAC rule 3745-21-01 (C)(7), in this emissions unit, the permittee shall comply with the requirements of OAC rule 3745-21-07(0)(1). Ill. Monitoring and/or Record Keeping Requirements 1. The permittee shall keep readily accessible records showing the dimensions ofthe storage vessel and an analysis showing the capacity ofthe storage vessel. 2. The permittee shall maintain the following information for each material stored in this emissions unit: a. the identification ofthe material stored; and b. whether or not the material is a volatile photochemically reactive material as defined in OAC rule 3745-21-01 (C)(7). 3. Pursuant to OAC rule 3745-77-07(A)(3)(a)(ii), the following monitoring and record keeping requirements are as stringent as or more stringent than the monitoring and record keeping requirements contained in Permit to Install #14-02486, issued on November 27, 1991: sections A.lll.1 and A.lll.2. The monitoring and record keeping requirements contained in the above-referenced Permit to Install are subsumed into the monitoring and record keeping requirements ofthis operating permit, so that compliance with these requirements constitutes compliance with the underlying monitoring and record keeping requirements in the Permit to Install. IV. Reporting Requirements 1. The permittee shall notify the Hamilton County Department of Environmental Services of any volatile photochemically reactive material stored in this emissions unit. This notification shall be submitted within thirty days after the commencement ofthe storage of a volatile photochemically reactive material.

Title V Final Permit Terms and Conditions for Emissions Units Page 276Facility Name: Facility ID: Emissions Unit: V. Testing Requirements LANXESS CORPORATION ADDYSTON, OH PLANT 14-31-()1-Q054 SEC BUOH TANK (T044)
1. Compliance with the emission limitation in section A.l.1 ofthese terms and conditions shall be determined in accordance with the following method: 1.a Emission Limitation: 0.13 tpy of organic compounds Applicable Compliance Method: The permittee may demonstrate compliance by using emission factors from USEPA reference document AP-42, fifth edition, Section 7.1, organic liquid storage tanks (March, 1998). VI. Miscellaneous Requirements None

Title V Final Permit Terms and Conditions for Emissions Units Page 277