p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

51)11-1-51 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:22 PM Sheet 51 of 114 
P.2 

State of Wisconsin 

Department of Natural Resources 

APPLICATION 

FACILITY IDENTIFICATION 

AIR POLLUTION CONTROL OPERATION PERMIT 

Form 4530-100 10-93 

1. Facility name and Name BRADY USA, INC-CAMERON AVENUE FACILITY 

mailing address Street or Route P.O.BOX 2999 

Chy, State, Zip Code MILWAUKEE, WI, 53201-2999 

2. Facility location Street Address 3328 W. CAMERON AVE 

City, County MILWAUKEE, MILWAUKEE 

3. Parent corporation Name W.H. BRADY CO. 

Street or Route 6555 W. GOOD HOPE RD. 

City, State, Zip Code MILWAUKEE, WI, 53223-2131 

Country (if not U.S.) 

4. Responsible official Name TOM J. FELMER 

Title GENERAL MANAGER 

Telephone (414)332-8100-3501 

5. Pennit contact person Name JANEEN E JACKSON 

Title ENVIRONMENTAL ENGINEER 

Telephone (414)332-8100-3408 

6. SIC code: 3993 

7. Facility identification number: 241270810 

8. Primary activity ofthe operating establishment: 

MANUFACTURE OF FIBERGLASS SIGNS. 

9. Type of permit 

[ ] Construction permit [•/] Operation Pennit 

Anticipated start date for construction: / / [/] Part 70 Source Application 

Anticipated start date for operation: / / [ ] Non - Part 70 Source Application 

[-] Synthetic Minor, Non - Part 70 

This application is requesting an expedited Source Application 

review (see instructions) 

[]Yes []N o 

[ ] Elective operation permit 

10. If facility is located in an area designated as 'nonattainment', indicate the pollutant for the 

nonattainment designation: Ozone 

11. List all air pollution permits and orders issued to this facility. 

AIR POLLUTION CONTROL PERMIT NO. 92-DAA-296 
P.3 

State of Wisconsin FACILITY PLOT PLAN 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-101 10-93 

In order for a comprehensive air quality analysis to be accomplished, a facility plot plan MUST be included with the 

permit 

application. This facility plot plan must include all ofthe following items or the permit application will be deemed 

incomplete: 

FOR DEPARTMENT USE ONLY 

COMPLETE INCOMPLETE NOT APPLICABLE 

[ ] [ ] I.A building layout blueprint, plan view including all buildings occupied by 

or located on the site ofthe facility. 

2. The maximum height of each building (excluding stack height). 

3. The location and numerical designation ofeach stack. Please ensure these 

designations correspond to the appropriate stacks listed on the other permit 

forms in this application. 

[ ] 4. The location of fenced property lines (if any). 

5. Identify direction 'North' on all submittals. 

6. All drawings shdl be to scale and shdl have the scale graphically depicted. 

7. An additional regional map depicting the facility location in relation to the 

surrounding vicinity (roads or other features) shall be included. 

Are there any outdoor storage piles on the facility site? [ ] Yes [••/] No 

Are there any dirt roads or unpaved parking lots on the [ ] Yes [\/] No 

facility site? 

[]. 

[] 

[] 

[] 

[] 

[] 

[] 

[] 

[] 

[] 

[] 

[] 

a 
P.4 

State of Wisconsin SOURCE AND SITE DESCRIPTIONS 

Department of Natural Resources AIR POLLUTION CONTROL PERMIT APPLICATION 

| Form 4530-102 10-93 

i 

1. Briefly describe the proposed project or existing Unit(s) to be permitted. Attach supplemental forms as needed. 

Brady USA, Inc. - Signmark Division operates a facility at 3328 West Cameron Avenue, in Milwaukee, 

Wisconsin, at which the company manufactures fiberglass sign products. Operations include a fabric coating 

operation (P30) which emits from three exhaust stacks (SIO), a screen printing operation (P35) with no actual stack 

(S30), and finishing equipment operations (P33). Dust from the finishing operation is collected and controlled by a 

dust collector which emits from one stack (S14). 

2. Site Description: 

The facility is located on a 1.23-acre parcel of land located in a residential area in the 3400 block of Cameron 

Avenue in Milwaukee, Wisconsin. Cameron Avenue is an east-west street located north of Hampton Avenue and 

south of Villard Avenue. The SOO Line railroad track runs adjacent to die east property line. The area is designated 

as a "severe ozone nonattainment area". 

3 
P.5 

State of Wisconsin SOURCE DESCRIPTION - SUPPLEMENTAL 

Department of Natural Resources AIR POLLUTION CONTROL PERMIT APPLICATION 

Form4530-102A 10-93 

3. List all significant existing or proposed air pollution Units at the facility. A short narrative ofthe inventory of air 

pollution emissions unit (e.g., boiler, printing line, etc.) followed by equipment specifications will suffice. If the 

facility consists of several individual emission units, present this information in an outline format (see instruction 

booklet for an example Unit description.) 

The facility is comprised ofthe following emission units: 

Stack SIO, Process P30 - O'Hare Fiberglass Sign Line 

The fabric coating line was manufactured by the W. H. Brady Co. and is referred to as the "O'Hare Line". It 

processes styrene based polyester resin, which is stored in a 6000 gallon underground storage tank. Maximum resin 

usage is 50 gallons per hour. The resin is pumped from the storage tank to two above ground indoor process tanks 

called "Day Tanks", each having a capacity of 180 gallons. The Day Tanks heat the resin to a usable temperature 

(87-93 deg. F.). The resin is subsequently fed into the O'Hare line where it is coated onto fiberglass webs. Graphics 

are fed into the package which is then cured in an electric oven to produce encapsulated graphic signs. 

The O'Hare Line has 3 stacks referred to as the Storage, Application and Oven stacks. The Storage stack serves 

the Day Tanks, the Application stack serves the resin application area ofthe O'Hare Line, and the Oven stack serves 

the O'Hare Line oven. These stacks have been combined as stack SIO on the application form. Emissions from mis 

process are uncontrolled. 

Stack S30, Process P35 - SP-5 Screen Press 

The screen printing press was manufactured by Medalist Industries and is referred to as the SP-5. It is a manual 

(sheet fed) press used to print large size (40" x 60") graphics on paper and plastic substrates. It utilizes solvent 

based inks (maximum = 0.64 gal/hr), thinner (maximum = 0.07 gal/hr), retarder (maximum = 0.02 gal/hr), and 

clean-up solvent (maximum = 0.5 gal/hr). Drying is accomplished through the use of open air (no oven). The SP-5 

does not have an actual stack and emissions are uncontrolled. 

Stack S14, Process P33 - Finishing Operations 

Dust producing finishing operations are performed with the following equipment: 

One round comer router (Brady ID # RCA-1) manufactured by W.H. Brady (equipment # 430216). It has a max. 

process rate of 500 signs per hour. 

One single-spindle drill press (Brady ID # DP-1) manufactured by Rockwell (Model # 15-665). It has a max. 

process rate of 150 signs per hour. 

7 
P.6 

State of Wisconsin SOURCE DESCRIPTION - SUPPLEMENTAL 

Department of Natural Resources AIR POLLUTION CONTROL PERMIT APPLICATION 

Form 4530-102A 10-93 

Continuation Page: 2 

3. List dl significant existing or proposed air pollution Units at the facility. A short narrative ofthe inventory of air 

pollution emissions unit (e.g., boiler, printing line, etc.) followed by equipment specifications will suffice. If 

the facility consists of several individual emission units, present this information in an outline format, (see 

instruction booklet for an example Unit description.) (Continued) 

Two multi-spindle drill presses (Brady ID #s' DP-2 and DP-3) manufactured by Clausing Corp. (model # 1657). 

They each have a max. process rate of 350 signs per hour. 

One shaping router (Brady ID # R-l) manufactured by Machine Works, Inc. - A subsidiary of Danly Machine 

Corp. (model # RO-117 H). It has a max. process rate of 30 signs per hour. 

Two beh sanders (Brady ID #s' SS-1 and SS-3). SS-1 was manufactured by Medalist (model # SS2-60). SS-3 

was manufactured by Advance (no model #). They each have a max. process rate of 500 signs per hour. 

Total max. dust production is 5.35 Ibs/hr before control. 

Dust emissions are controlled by a Torit Model 2DF12 99.9% efficient dust collector. 

5 
P.7 

State of Wisconsin SOURCE DESCRIPTION - SUPPLEMENTAL 

Department of Natural Resources AIR POLLUTION CONTROL PERMIT APPLICATION 

Form4530-102B 10-93 

4. Mark dl insignificant existing or proposed air pollution units, operations, and activities at the facility listed 

below. If not listed, provide a short narrative ofthe inventory of air pollution emissions units(e.g., boiler, printing 

line, etc.) followed by equipment specifications. If die facility consists of several individual emissions units, present 

this information in an outline format (see instruction booklet for an example Unit description.) 

[-/] Maintenance of Grounds, Equipment and Buildings (lawn care, painting, etc.) 

[•/] Boiler, Turbine, and HVAC System Maintenance 

[\/] Pollution Control Equipment Maintenance 

[</] Internal Combustion Engines Used for Warehousing and Material Transport 

[>/] Fire Control Equipment 

[/) Janitorial Activities 

[\/] Office Activities 

[••/] Convenience Water Heating 

[•/] Convenience Space Heating ( < 5 million BTU/hr Burning Gas, Liquid, or Wood) 

[] Fuel Oil Storage Tanks(, 10,000 gal.) 

[ ] Stockpiled Contaminated Soils 

[•/] Demineralization and Oxygen Scavenging of Water for Boilers 

/ 

[•/] Purging of Natural Gas Lines \ 

I/] 3 Nat. gas boilers (0.8 MMBTU/hr); bldg. heat 

[</] 36 gd DBE soaktank(parts deaning) 

[•/] Miscellaneous clean-up emissions. 

[•/] 6000 gal underground resin storage tank 

[\/] Any other misc. emission producing activities 

fo 
P.8 

State of Wisconsin FACILITY HAZARDOUS AIR POLLUTANT SUMMARY 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-127 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number 241270810 

3. Complete the following emissions summary for dl hazardous air emissions at mis facility (as defined in ch. NR 

445, Wis. Adm. Code, and sec. 112,1990 Clean Air Act Amendments): 

i 

Pollutant CAS Actual Maximum theoretical emissions Potential to emit 

I Units Units' 

7 
P.9 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identificaton number 241270810 

3. This form supplements Form 4530-127 

4. Additional Information: 

See hardcopy attachment to Form 107 for calculations. 

9, 
P.10 

State of Wisconsin FACILITY EMISSIONS SUMMARY 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-129 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number 241270810 

3. Complete the following emissions summary for the listed emissions at this facility. 

Air Pollutant 

Particulate matter 

Volatile organic compo 

Actual 

TPY 

0.00099 

45.10360 

Maximum Theoretical 

Emissions 

TPY 

6.08557 

273.50800 

Potential to 

Emit 

TPY 

0.00222 

96.48230 

Maximum A 

TPY 

0.00222 

96.48230 

9 
P.11 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identificaton number 241270810 

3. This form supplements Form 4530-129 

4. Additiond Information: 

See hardcopy attachment to Form 107 for calculations. 

Actual Emissions: 

1. Ink: 

Normal hourly ink usage is 0.4 gal/hr 

As applied ink usage = (0.4 gal/hr x 10 lbs/gal) + 

5.5% tiiinner + 3.0% retarder = 0.74 lbs ink/hr 

0.74 lbs/hr x 55.75 wt% VOC = 0.4126 lbs VOC/hr 

Normal operation is approximately 12 hrs/yr 

12 hrs/yr x .4126 lbs VOC/hr = 4.95 lbs VOC/yr 

(0.00248 tpy) 

2. Clean-up solvent: 

Normal hourly usage - 0.3 gal/hr 

0.3 gal/hr x 7.16 lbs VOC/gal = 2.148 lbs VOC/hr 

Normal (1994) usage = 62.2 lbs/yr 

= 62;21bsVOC 

(0.0311 tpy) 

Total Actual VOC emissions: 

0.4126 lbs/hr + 2.148 lbs/hr = 2.56 lbs/hr 

0.00248 tpy + 0.0311 tpy = 0.0336 tpy 

Maximum Theoretical Emissions: 

1. Ink: 

See calculations attached to Form 108, S30, P35. 

Hourly MTE = 2.866 lbs 

IO 
P.12 

Annud MTE = 2.636 tons 

2. Clean-up solvent: 

See calculations attached to Form 108, S30, P35. 

Hourly MTE = 3.6 lbs 

Annual MTE = 6.232 tons 

Total Maximum Theoretical Emissions: 

2.866 lbs/hr + 3.6 lbs/hr = 6.466 Ibs/hr 

2.636 tpy + 6.232 tpy = 8.868 tpy 

Potential to Emit: 

1. Ink: 

Annual Potential to Emit is based on a permit limit of 

three gal/mo ink usage. 

3 gal/mo x 12 mo/yr = 36 gal/yr 

36 gal/yr x 10 lbs/gal = 360 lbs/yr 

360 lbs/yr + 10 max wt% tfiinner + 3 max wt% retarder = 406.8 lbs. 

406.8 lbs/yr x 55.75% VOC = 226.79 lbs VOC/yr (0.1134 tpy) 

2. Clean-up solvent: 

Annual Potentid to emit is based on a permit limit of 

3 gal/mo. 

3 gal/mo x 12 mo/yr = 36 gal/yr 

36 gal/yr x 7.16 lbs VOC/gal = 257.76 lbs VOC/yr 

(0.1289 tpy) 

Total Potentia] to Emit: 

0.1134 tpy + 0.1289 tpy = 0.2423 tpy 

Maximum Allowable: 

1. Ink: 

Hourly Maximum Allowable equals Hourly MTE 

Annual Maximum Allowable equals Annual Potential to Emit 

2. Clean-up solvent: 

Hourly Maximum Allowable equals Hourly MTE 

Annual Maximum Allowable equals Annud Potential to Emit 

/ / 
P.13 

State of Wisconsin 

FACILITY 

Department of Natural Resources 

APPLICATION 

CURRENT EMISSIONS REQUIREMENTS AND STATUS OF 

AIR POLLUTION CONTROL OPERATION PERMIT 

Form 4530-132 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number. 241270810 

3. Pollutant 

4. Wis. Adm. Code 

5. 

6. Threshold 

7. Compliance 

Wis. Stats., 

40 CFR 

Volatile organic compounds (Reactive organi 

Sec 144.394(7); 

Visible Emissions ss 

** Malodorous Emissions 

** Hazardous Substances 

Particulate matter NR 4 

8. Is mis facility subject to the provisions governing prevention of accidental releases of hazardous air contaminants 

contained in section 112(r)(7) ofthe Clean Air Act? [] Yes [\/] No 

If you answered yes, please describe how you will achieve compliance with these provisions, including the 

requirement to formulate a plan for preventing accidental releases (sec. 112(r)(7)(B)(ii)): 

9. Other requirements (e.g., malfunction reporting, special operating conditions from an existing pennit, etc.) 

State 

Only 

NR422.08(2)(a) 

NR 431.05 

NR 429.03(1) 

NR 445.03 

l5(l)(o); NR415.0i 

Value 

1.35 lbs VOC/gal resin 

20% opacity 

See attached 

* See attached 

i(2) See attached 

Status 

(in or out) 

In 

In 

In 

In 

In 

State Only 

NR419.03&.04 

Monthly resin usage limit of 12,000 gallons resin as a quarterly avg. 

Monthly clean-up solvent usage limit of 200 lbs. 

Monthly ink usage limit of 3 gallons. 

Daily ink usage limit of 2 gallons. 

Monthly clean-up solvent usage limit of 3 gallons. 

Pressure drop range of 1-6 inches across the dust collector. 

Compliance Status 

(in or out) 

In 

In 

In 

In 

In 

In 

In 

IA 
P.M 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identificaton number 241270810 

3. This form supplements Form 4530-132 

4. Additional Information: 

NR 422.08(2)(a) is the RACT limit for Fabric and Vinyl coating. 

The limit is 2.9 lbs VOC/gal as applied. 

NR 429.03(1) is a general limitation. 

NR 445.03 is a general limitation. 

NR415.05(l)(o): limit of 0.4 pounds of particulate matter per 1000 lbs of gas. 

NR 415.05(2): E=3.59P0.62 where E=the allowable emission rate in lbs/hr and P=the process throughput in tons 

per hour. 

NR 419.03 & .04 are general limitations. 

Specific ink and clean-up solvent materid usage limits were elected in order to avoid being subject to the emission 

limitations of Chapter NR 424, Wis.Adm. Code. 

The dust collector is equipped with a differential pressure gauge which indicates the pressure drop across die dust 

collector. 

The O'Hare line will also be affected by Section 112 of die Clean Air Act Amendments which requires the EPA to 

develop Maximum Achievable Control Technology (MACT) standards for the 189 Hazardous Air Pollutants (HAPs) 

that were identified in die amendments. Styrene is one ofthe 189 HAPs. The standard is scheduled to be 

promulgated during 1997. 

12, 
P.15 

State of Wisconsin FACILITY REQUIREMENTS COMPLIANTS PLAN 

Department of Natural Resources COMMITMENTS AND SCHEDULE 

AIR POLLUTION CONTROL PERMIT APPLICATION 

Form 4530-133 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number 241270810 

3. For Facilities that are presently in compliance with dl applicable requirements, including any enhanced 

monitoring and compliance certification requirements under section 114(a)(3) ofthe Clean Air Act that apply, 

complete the following. These commitments are part ofthe application for Part 70 permits. 

[*/] We will continue to operate and maintain this Facility to assure compliance for the duration ofthe permit. 

[>/] Form 4530 -130 includes new requirements that apply or will apply to this Facility during me term ofthe 

permit We will meet such requirements on a timely basis. 

4. For Facilities not presently fully in compliance, complete the following. These commitments are part of die 

application. 

[ ] This Facility is in compliance with all applicable requirements except for those indicated below. We will 

achieve compliance according to the following schedule: 

Non-complying 

Requirement Corrective Actions Deadline 

11 
P.16 

State of Wisconsin 

Department of Natural Resources 

APPLICATION 

INDEX OF AIR POLLUTION PERMIT APPLICATION FORMS 

AIR POLLUTION CONTROL OPERATION PERMIT 

Form 4530-134 10-93 

ADMINISTRATION Totd Number 

This application contains 40 forms as follows: of This Form 

[X] Form 4530-100, Facility Identification 1 

[X]Form 4530-101, Facility Plot Plan 1 

[X] Form 4530-102, Source and Site Description 1 

II. EMISSIONS SOURCE DESCRIPTION 

This application contains the following forms (one form for 

each facility boiler, printing operation, etc.): 

[X] Form 4530-103, Stack Identification 

[ ] Form 4530-104, Boiler or Furnace Operation 

[] Form 4530-105, Storage Tanks 

[ ] Form 453 0-106, Incineration 

[X] Form 4530-107, Printing Operations 

[X] Form 4530-108, Painting and Coating Operations 

[X] Form 4530-109, Miscellaneous Processes 

ffl. AIR POLLUTION CONTROL SYSTEM 

This application contains the following forms (one form for 

each control system in use at the facility): 

[ ] Form 4530-110, Miscellaneous 

[ j Form 4530-111, Condensors 

[ ] Form 4530-112, Adsorbers 

[ j Form 4530-113, Catalytic or Thermal Oxidation 

[ ] Form 4530-114, Cyclones/Setting Chambers 

[ ] Form 4530-115, Electrostatic Precipitators 

[ ] Form 4530-116, Wet Collection Systems 

[X] Form 4530-117, Baghouses/Fabric Filters / 

IV. COMPLIANCE DEMONSTRATION 

This application contains the following forms (one form for 

each facility boiler, printing operation, etc.): 

[X] Form 4530-118, Compliance Cert - Monitoring and Reporting 

[ ] Form 4530-119, Continuous Emission Monitoring 

[ ] Form 4530-120, Periodic Emission Monitoring 

[X] Form 4530-121, Control System Parameters 

[ ] Form 4530-122, Monitoring Maintenance Procedures 

[ ] Form 4530-123, Stack Testing 

[ ] Form 4530-124, Fuel Sampling and Analysis 

[X] Form 4530-125, Recordkeeping 

Total Number 

of This Form 

3 

0 

0 

0 

1 

1 

1 

Total Number 

of This Form 

0 

0 

0 

0 

0 

0 

0 

1 

Total Number 

of This Form 

5 

0 

0 

1 

0 

0 

0 

2 

V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION 

This application contains the following forms quantifying emissions, 

certifying compliance with applicable requirements, and developing Total Number 

a compliance plan. of This Form 

[X] Form 4530-126, Emission Unit Hazardous Air Emissions 2 

[X] Form 4530-127, Facility Hazardous Air Emissions 1 

[X] Form 4530-128, Emission Unit Emissions Summary 5 

iS 
P.17 

[X] Form 4530-129, Facility Emissions Summary 1 

[X] Form 4530-130, Current Emissions Requirements and Status 5 

[X] Form 4530-131, Compliance Plan-Commitments and Schedule 5 

[X] Form 4530-132, Facility Emissions Requirements and Status 1 

[X] Form 4530-133, Facility Requirement Compliance Plan 1 

i 

\ 

Ifr 
P.18 

VI. SIGNATURE OF RESPONSIBLE OFFICIAL: 

A. STATEMENT OF COMPLETENESS 

I have reviewed this application in its entirety and to die best of my knowledge, information and belief formed 

after reasonable inqury, the statements and infonnation contamed in mis application are true, accurate and complete. 

The status of diis facility's compliance wim all applicable air pollution control requirements, including die 

enhanced monitoring and compliance certification requirements ofthe federal Clean Air Act, is reported in this 

application dong with die mediods to be used for compliance demonstration. 

B. CERTIFICATION OF FACILITY COMPLIANCE STATUS (check one box only) 

THIS IN NOT A REQUIREMENT OF NON-PART 70 SOURCES. 

[v/] I certify mat die facility described in this air pollution permit application is fully in compliance with all 

applicable requirements. 

[ ] I certify tiiat die facility described in this air pollution permit application is fully in compliance with all 

applicable requirements except for the following emission unit(s): 

(list dl non-complying units) 

Printed or Typed Name: Tom J. Felmer Title: General Manager 

Signature: Date Signed: _ 

SEND ALL MATERIALS TO: 

WISCONSIN DEPARTMENT OF NATURAL RESOURCES 

BUREAU OF AIR MANAGEMENT 

PERMITS SECTION 

P.O. BOX 7921 

MADISON, WI 53707-7921 

in 
P.19 

State of Wisconsin STACK IDENTIFICATION 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-103 10-93 

I. Facility name: 2. Facility identification number 3. Stack identification number: 

BRADY USA, INC-CAMERON AVENUE FACILITY 241270810 SIO 

4. Exhausting Unit(s), use Unit Id number from appropriate Form(s) 4530-104,106,107,108, and/or 109 

Form Number Form Title Unit ID Number 

108 Painting and Coating Operations P30 

5. Identify mis stack on the plot plan required on Form 4530-101 

6. Indicate by checking: 

[</] This stack has an actual exhaust point [ ] This stack serves to identify fugitive emissions. 

Ifthis stack has an actual exhaust point, then provide the following stack parameters 

7. Discharge height above ground level: 29.5 (feet) 

8. Inside dimensions at outlet (check one and complete): 

[>/] Circular 1.57 (feet) [] Rectangular -1 lengdi (feet) -1 widtii (feet) 

9. Exhaust flow rate: 

Normd 2180 (ACFM) Maximum 2180 (ACFM) 

10. Exhaust gas temperature (normal): 84.0 (F) 

II. Exhaust gas moisture content: Nonnal-1.0 volume percent Maximum-1.0 volume percent 

12. Exhaust gas discharge direction: [•/] Up [ ] Down [ ] Horizontal 

13. Is this stack equipped with a rainhat or any obstruction to the free flow ofthe []Yes [*/]No 

exhaust gases from the stack? 

***** Complete the appropriate Air Permit Application Forms(s) 4530-104* 106,107,108, or 109 for each Unit 

***** 

exhausting through this stack. 

/& 
P.20 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-103 

4. Additional Information: 

Stack SIO represents 3 stacks which are connected to die O'Hare 

line fabric coater, Process P30. 

The 3 stacks are referred to as the storage stack, the application stack, and the oven stack. The storage stack 

serves the in line day tanks, the application stack serves the resin application area, and die oven stack serves the 

O'Hare line oven. 

Individual stack dimensions are as follows: 

Storage stack: Discharge Ht. above ground level = 25.5' 

Rectangular (8" x 12") 

Exhaust flow rate = 778 ACFM 

Exhaust gas temp. = 80 deg.F 

Discharge direction = Up 

Obstruction to free flow = No 

Application stack: Discharge Ht above ground level = 35' 

Circular (dia. = 23") 

Exhaust flow rate = 3947 ACFM 

Exhaust gas temp. = 80 deg.F 

Discharge direction = Up 

Obstruction to free flow - No 

Oven stack: Discharge Ht above ground level - 28' 

Rectangular (18" x22") 

Exhaust flow rate = 1816 ACFM 

Exhaust gas temp. = 91 deg.F 

Discharge direction = Up 

Obstruction to free flow =* No — 

Average stack parameters: 

Discharge Ht. above ground level = (25.5'+ 35'+ 28')/3 = 29.5' 

Shape = Circular (avg. of 3 stacks must be done using equivalent diameter. If using diameter, must choose 

circular shape). 

Diameter: 

Equivalent dia. of Storage stack = 11.06" 

Equivalent dia. of Oven stack = 22.45" 

Average diameter = (11.06"+ 23"+ 22.45") / 3 = 18.84" = 1.57' 

Exhaust flow rate - (778 + 3947 + 1816) / 3 = 2180 CFM 

Exhaust temp. = (80 + 80 + 91) / 3 =84 deg.F 

Exhaust direction = Up 

Obstruction to free flow = No 

ft 
P.21 

State of Wisconsin PAINTING AND COATING OPERATIONS 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-108 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number: 241270810 

3. Stack identification number SIO 

4. Process number P30 

4a. Unit description: 

O'Hare Fiberglass Sign Line, SIO, P30 

Manufacturer W.H. Brady Co. 

Flow coating of fiberglass webs widi styrene based resin to form fiberglass signs. 

Electric curing oven. 

Maximum product throughput = 678 lbs/hr 

5. Indicate the control technology status: [«/] Uncontrolled [] Controlled 

If the unit is controlled, enter the control device numbers) (use control device number from appropriate Form(s)) 

Form Number Form Title Device Number 

6. Application technique and transfer efficiency (%): Flow coating 100.00 

7. Date of construction or last modification: 03/00/78 

8. Normal operating schedule: 8hrs7day 5 days/wk. 250 days/yr. 

9. Oven curing (complete if applicable): 

Number of ovens 1 Specify oven fuels Currently, electric; may replace with natural gas. 

Total maximum energy input to each oven • 1.00 

10. Describe all ofthe coatings' and solvents' composition (as applied) that are used by mis unit. 

Name of coating/ct T Maximum Normal Solidds VOC Water Density 

Usage usage % % % Lbs VOC/ 

/. gallon less H20 

tjrifji-^ gal/hr gal/yr gal/yr W V W V W V lbs/gal 

Styrene/Polyester resin 

3-Cured Coating 285 49.980 394042.3 66783.8 85.9-1.0 14.1 -1.0 0.0-1.0 9.34 1.32 

Total Coatings: 49.980 394042.3 66783.8 

List die thinning solvents used wim the coatings identified above. 

Cl-up Solv Acetone 3.000 1569.0 330.0 0.0-1.0 100.0 -1.0 0.0-1.0 6.60 

***** For this emissions unit, identify the method of compliance demonstration by completing Form 4530-118, 

***** 

DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 4530-118 

and its attachments) to this form. This is not a requirement of non-Part 70 sources. 

3d 
P.22 

***** Please complete die Air Pollution Control Permit Application Forms 4530-126 and 4530-128 for this 

unit***** i 

31 
P.23 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-108 for emission unit P30 

4. Additional Information: 

See attached hardcopy flow diagram. 

Maximum Finished Product Throughput: 

Max. line speed = 4.0 fpm 

Web width = 44" (3.67') 

Product wt = 0.77 Ibs/sq ft 

4 x 3.67 = 14.68 sq ft/min 

14.68 x 60 = 880.8 sq ft/hr 

880.8 x 0.77 = 678.2 lbs/hr 

O'Hare Line Emissions: 

The O'Hare line utilizes a styrene based polyester resin which is catalyzed just prior to entering the process. A 

portion of me styrehe is polymerized into polystyrene as the resin cures. In December of 1991, Signmark Division's 

R & D staff performed a weight by difference study to determine how much ofthe available styrene is polymerized 

verses how much is emitted. Styrene is the only volatile component of die resin, therefore, the difference in weight 

between materials entering the process and exiting the process was determined to be that amount of styrene which is 

actually emitted during the process. The remainder becomes polymerized as part ofthe final product. The data 

collected during the weight by difference study were as follows: 

Raw material weights: 

Resin added to the process = 26.98 gal. 

Runtime = 30 min. 

Density as tested = 9.34 lbs/gal 

Resin usage/hour = (26.98 gal/30min)(60 min/hr) = 53.96 gal/hr. 

(54 gal/hr) 

Resin lbs/hr = 54.0 gal/hr x 9.34 lbs/gal = 504.4 lbs/hr p 

Fiberglass veil =10.1 lbs/hr. 

Fiberglass mat = 94.0 lbs/hr. 

Paper liner = 25.1 lbs/hr. 

Catalyst => 3.3 lbs/hr. 

Finished Product Weight: 

Total pkg. finished product weight = 565.8 lbs/hr. 

<#? 
P.24 

Emissions: 

Cured resin wt = Finished prod wt - raw mat'l wt (except resin) 

= 565.8 - (10.1+94.0+25.1+3.3) = 433.3 lbs/hr 

Emissions = Wet resin wt - cured resin wt 

= 504.4-433.3 = 71.1 lbs/hr 

VOC lbs/gal -71.1 lbs/hr/ 54.0 gal/hr = 1.32 lbs/gal 

VOC % = 1.32 lbs VOC/gal / 9.34 lbs/gd = 14.1% 

•Note: 1. The percent solids was listed as 85.9% to account for the styrene which polymerizes into solid form. 

2. This study was done at a time when the process utilized a thicker fiberglass mat and consequently, 

more resin. We currently use a max. of 50 gallons of resin per hour. 

i Maximum Usage: 

Maximum Theoretical Usage: 

1. Resin: 

Data: Maximum speed = 4.0 fpm 

Web width = 44" (3.67') 

Wet resin wt = 0.53 lbs 

Maximum run time = 90% 

Can run a maximum of 15 hours before a mandatory shut-down for a raw material (liner) change. Shut 

down requires a 45 minute (0.75 hr) minimum clean-up and a 1 hour minimum set-up. This equates to a maximum 

run of 15 hrs for every 16.75 hrs or 90%. 90% of 8760 hrs possible per year = 7884 hrs. 

Resin wt/gal = 9.34 lbs/gal as tested 

Calculations: 

a. 4 fpm x 3.67 ft = 14.68 sq ft/min. 

b. 14.68 sq ft/min x 0.53 Ibs/sq ft = 7.78 Ibs/min 

c. 7.78 Ibs/min x 60 min/hr = 466.80 lbs/hr 

d. 466.80 lbs/hr / 9.34 lbs/gal = 49.98 gal/hr 

e. 49.98 gal/hr x 7884 hrs/yr = 394,042.32 gal/yr 

2. Clean-up Solvent: 

Data: Clean-up occurs after each run. 

Maximum clean-up solvent use = 3 gal/clean-up. 

The line can run a maximum of 15 hrs before shut-down. 

Clean-up takes 45 min. minimum. 

Set-up takes 1 hr minimum. 

Clean-up solvent is 100% VOC. 

Calculations: 

a. Based on die above clean-up can occur once every 16.75 hours. 

b. 8760 hrs /16.75 - 522.99 (523 clean-ups per yr) 

c. 523 clean-ups/yr x 3 gal/clean-up = 1,569 gal/yr 

Normal Usage: 

i 

Used 1994 usage as normal: 

3.S 
P.25 

Used 623,761 lbs of resin in 1994 (66,783.8 gal) 

Used 2,177 lbs clean-up solvent in 1994. 

2,177/6.6 lbs/gd = 330 gal 

Alternative Operating Scenarios: 

1. Tlie O'Hare Line currently utilizes an electric oven to cure product Plans for an oven replacement are . 

currently underway. It is unknown, at diis point, whether die oven will be electric or gas-fired. Instdlation of die 

new oven will not require a construction permit as the new oven will not increase the O'Hare Line emission capacity. 

If the oven is gas fired, die maximum natural gas usage will be approximately 4.0 MMBTU/hour. We wish to 

include natural gas as an alternative fuel for diis process. 

2. We currently use only one resin, however, in the event that this resin becomes unavailable or is replaced widi a 

newly developed resin or widi a lower VOC containing resin, we wish to have the option of processing this 

alternative resin. The alternative resin would be a direct replacement for 

3H 
P.26 

State of Wisconsin COMPLIANCE CERTIFICATION - MONITORING AND 

RECORDING 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-118 10-93 

All applicants except non-Part 70 sources are required to certify compliance widi all applicable air pollution 

permits requirements by including a statement withing the permit application of die mediods used for determining 

compliance (please see sec. NR 407.05(4)(i), Wis. Adm. Code.) This statement must mclude a description of die 

monitoring, recordkeeping, and reporting requirements and test methods. In addition, die application must include a 

schedule for compliance certification submittals during die permit term. These submittals must be no less frequent 

dian annually, and may need to be more frequent if specified by die underlying applicable requirement or by the 

Depaitment 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number 241270810 

3. Stack identification number SIO 

4. Unit identification number: P30 

5. This Unit will use die following method(s) for determining compliance with the requirements ofthe permit (check 

all that apply and attach the appropriate form(s) to this form). 

[ ] Continuous Emission Monitoring (CEM) - Form 4530-119 

Pollutants): 

[ ] Periodic Emission Minitoring Uinsg Portable Monitors - Form 4530-120 

Pollutants): 

[ ] Monitoring Control System Parameters or Operating Paramters of a Process - Form 4530-121 

Pollutants): 

[ ] Monitoring Maintenance Procedures - Form 4530-122 

Pollutants): 

[ ] Stack Testing - Form 4530-123 

Pollutants): 

[ ] Fuel Sampling and Andysis (FSA) - Form 4530-124 

Pollutants): 

[\/] Recordkeeping - Form 4530-125 

Pollutant(s): 

Volatile Organic Compounds 

6. Compliance certification reports will be submitted to the Department according to the following schedule: 

Start date: July 1 and every 12 months thereafter. 

Compliance monitoring reports will be submitted to theDepartment according to the following schedule: 

Start date: July 1 and every 6 months thereafter. 

Recordkeeping shall be acceptable as a compliance demonstration method provided mat a correlation between die 

parameter value recorded and die emission rate of a particular pollutant is established in the form of a curve or chart 

of emission rate versus parameter values. This correlation shall constitute the certification ofthe system. It should 

be attached for Department approval. If not attached, it shall be submitted within 60 days ofthe startup ofthe 

system. 

o25 
P.27 

State of Wisconsin COMPLIANCE DEMONSTRATION BY RECORDKEEPING 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-125 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number: 241270810 

3. Stack identification number SIO 

4. Unit identification number P30 

5. Pollutant that compliance status is being evduated: 

Volatile Organic Compounds 

6. Material or parameter being monitored and recorded: 

Resin and Clean-up Solvent Usage. 

7. Method of monitoring and recording: 

Daily weighing of clean-up solvent. 

Daily underground storage tank level readings to determine resin lusage (Petrometer gauge). 

Data input into VOC database program which calculates VOC emissions ibased on amount of material used. 

Data storage on computer network which is backed up daily. 

8. List any EPA mediods used: 

9. Is diis an existing method of demonstrating compliance: 

10. Installation date: 06/01/95 

[]Yes [>/]No 

11. Backup system: See attached. 

12. Compliance shall be demonstrated: [7] Daily [] Weekly [] Monthly [] Batch(not to exceed monthly) 

13. Indicate by checking: 

The monitoring shall be subject to appropriate performance specifications calibration requirements and 

quality assurance procedures. [ ] A quality assurance/quality control plan for die recordkeeping system is attached 

for Department approval. [ ] If the plan is not attached it shall be submitted widiin 60 days ofthe start-up ofthe 

recordkeeping program. [ ] If tiie plan has already been submitted to the department please indicate the date of 

submittal: 

***** The compliance records shall be available for Department inspection. The format for the compliance 

certification report and die excess emission report shall be approved by the department. A proposed format for the 

compliance certification report and excess emission report shall be submitted at the same time as the application 

***** The source shall record any malfunction which causes or may cause an emission limit to be exceeded. 

Malfunctions shall be reported to die department die next business day. Hazardous air spills shall be reported to die 

Department immediately. 
P.28 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identificaton number 241270810 

3. This form supplements Form 4530-125 for emission unit P30 

4. Additiond Infonnation: 

Backup system: 

Clean-up solvent usage amounts could be obtained through an inventory review. 

Resin usage amounts could be obtained by manually sticking the tank in die event of a petrometer failure. 

Resin usage amounts could dso be back calculated based on final product amounts. 

2* 
P.29 

State of Wisconsin EMISSION UNIT HAZARDOUS AIR POLLUTANT SUMMARY 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-126 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identification number 241270810 

3. Stack identification number SIO 

4. Unit identification number: P30 

5. Unit material description: Styrene/Polyester resin 

6. Complete the following summary of hazardous air emissions from diis unit Attach sample calculations and 

emission factor references. Attached? Y 

Pollutant CAS Actual Maximum theoretical emissions Potential to emit 

Units Units 

100-42-5 60.32000 lb/hr 65.82000 lb/hr 95.04000 TPY 

:2B 
P.30 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 

2. Facility identificaton number. 241270810 

3. This form supplements Form 4530-126 for emission unit P30 

4. Additional Information: 

The VOC emissions for die styrene based polyester resin are 14.1 wt% based on a weight by difference study 

which was performed in December of 1991. The results ofthis study are detailed in the attachment to Form 108, 

Stack SIO, Process P30. 

Actual Emissions: 

Normd (1994) usage = 66,783.8 gal/yr 

66783.8 gal/yr x 9.34 lbs/gal - 623,761 lbs/yr 

623,761 lbs/yr / 1458 hrs (1994) = 427.82 lbs/hr 

427.82 lbs/hr x 14.1 wt% VOC - 60.32 lbs VOC/hr 

Maximum Theoretical Emissions: 

Maximum web speed = 4.0 fpm 

Web width = 44" (3.67") 

Wet resin wt = 0.53 lbs/sq ft 

Maximum run time = 15 hrs of every 16.75 available or 90% 

1. 90% x 8760 = 7884 hrs/yr 

2. 4.0 x 3.67 = 14.68 sq ft/min 

3. 14.68x0.53 =7.78 Ibs/min 

4. 7.78x60 = 466.8 lbs/hr 

5. 466.8 x 14.1 wt% VOC = 65.82 lbs VOC/hr 

Potential to Emit: 

Pennit limit is 12,000 gallons of resin per month. 

1. 12,000 gallons/mo x 12 mo/yr = 144,000 gal/yr 

2. 144,000 gal/yr x 1.32 lbs VOC/gal = 190,080 lbs VOC/yr (95.04 tpy) 

-..yq 
P.31 

State of Wisconsin EMISSION UNIT SUMMARY 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-128 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number 

241270810 

3. Stack identification number. SIO 4. Unit identification number P30 

5. Complete the following emissions summary for the following pollutants. Attach sample calculations and emission 

factor references. Attached? Y 

Air Pollutant Actual Maximum theoretical emissions Potential to emit Maximum allowable 

U TPY U TPY U TPY 

Volatile organic compo 69.03000 1 45.07000 85.62000 1 264.64000 96.24000 TPY 85.62000 1 

96.24000 

Units (U) should be entered as follows: 

1 = lb/hr 

2 = lb/mmBTU 

3 = grains/dscf 

4 = lb/gallon 

5 = ppmdv 

6 = other(specify) 

7 = other(specify) 

8 = other(specify) 

2P 
P.32 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number 

241270810 

i 

3. This form supplements Form 4530-128 

4. Additional Information: 

Styrene is die only volatile component of styrene based resin used on the O'Hare Line. The VOC emissions for 

the resin are 14.1 wt% based on a weight by difference study which was performed in December of 1991. The 

results of this study are detailed in the attachment to Form 108, Stack S10, Process P30. 

Actual Emissions: 

1. Resin: 

Normd (1994) usage = 66,783.8 gal/yr 

66783.8 gal/yr x 9.34 lbs/gal - 623,761 lbs/yr 

623,761 lbs/yr/ 1458 hrs (1994) = 427.82 lbs/hr 

427.82 Ibs/hr x 14.1 wt% VOC - 60.32 lbs VOC/hr 

9.34 lbs/gal x 14.1 wt% = 1.32 lbs VOC/gd 

623,761 lbs/yr x 14.1 wt% = 87,950.30 lbs/yr 

87,950.30 lbs/yr / 2000 lbs/ton = 43.98 tpy 

2. Clean-up solvent: 

Normd (1994) usage = 2,177 lbs/yr 

250 clean-ups per year avg. 

2,177/250 = 8.71 lbs/clean-up / 

Clean-up takes 0.75 -1.0 hrs. \ 

8.71 lbs/hr 

2,177/2000 = 1.09 tpy 

Total Actual Emissions: 

60.32 lbs/hr + 8.71 lbs/hr - 69.03 lbs/hr 

43.98 tpy + 1.09 tpy = 45.07 tpy 

Maximum Theoretical Emissions: 

1. Resin: 

Maximum tpy is calculated as follows: 

Maximum web speed = 4.0 fpm 

Web width = 44" (3.67) 

Wet resin wt = 0.53 lbs/sq ft 

Maximum run time = 15 hrs of every 16.75 available or 90% 

SI 
P.33 

90% x 8760 = 7884 hrs/yr 

4.0 x 3.67 = 14.68 sq ft/min 

14.68x0.53 =7.78 Ibs/min 

7.78 Ibs/min x 60 = 466.8 lbs/hr 

466.8 x 14.1 wt% VOC = 65.82 lbs VOC/hr 

65.82 x 7884 = 518,924.88 lbs VOC/yr 

= (259.46 tpy) 

2. Clean-up solvent: 

Maximum clean-up solvent use is 3.0 gal/clean-up 

Clean-up takes 0.75 - 1.0 hrs 

3.0 gal/hr x 6.6 lbs/gal = 19.8 lbs/hr 

Clean-up occurs after each run. 

The line can run 15 hrs before a mandatory shut-down for liner change. Clean-up and set-up must occur after 

a shut-down. Clean-up takes a minimum of 0.75 hrs. Set-up takes a minimum of 1.0 hrs. Based on this info., 

clean-up can occur once every 16.75 hours. 

8760 / 16.75 = 523 clean-ups max. per year. 

523 clean-ups/yr x 19.8 lbs/clean-up = 10,335.4 lbs/yr (5.18 tpy) 

Total Maximum Theoretical Emissions: 

65.82 lbs/hr + 19.8 lbs/hr = 85.62 lbs/hr 

259.46 tpy + 5.18 tpy = 264.64 tpy 

Potential to Emit: 

1. Resin: 

Pennit limit is 12,000 gdlons of resin per month. 

12,000 gal/mo x 12 mo/yr = 144,000 gal/yr \ 

144,000 gallons/yr x 1.32 lbs/gal = 190080 lbs VOC/yr 

(95.04 tpy) 

2. Clean-up solvent: 

Permit limit is 200 lbs/mo. 

200 lbs/mo x 12 mo/yr = 2400 lbs/yr 

(1.20 tpy) 

Total Potential to Emit: 

95.04 tpy + 1.20 tpy = 96.24 tpy 

Maximum Allowable: 

Lbs/hr equals MTE lbs/hr. 

Tpy equals Potential to Emit tpy. 
P.34 

State of Wisconsin CURRENT EMISSIONS REQUIREMENTS AND STATUS OF UNIT 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-130 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number SIO 4. Unit identification number P30 

5. Pollutant 6. Wis. Adm. Code 7. 8. Limitation 9. Compliance 

Wis. Stats., State Status 

40 CFR Only (in or out) 

Volatile organic compounds (Reactive organi Sec 144.394(7);NR 422.08(2)(a) 1.35 lbs VOC/gal 

In 

Visible Emissions ss.NR431.05 20% Opacity In 

** Malodorous Emissions NR-429.03(1) See attached In 

** Hazardous Substances NR-445.03 * See attached In 

10. Odier requirements (e.g., malfunction reporting, specid operating conditions from an State Only 

Compliance 

existing permit etc.) Status 

(in or out) 

Monthly resin usage limit of 12,000 gallons as a quarterly average. In 

Monthly clean-up solvent usage limit of 200 lbs. In 
P.35 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number. 

241270810 

3. This form supplements Form 4530-130 for emission unit P30 

4. Additional Information: 

NR 422.08(2)(a) is the RACT limit for Fabric and vinyl coating. 

The limit is 2.9 lbs VOC/gal as applied. 

NR 429.03( 1) is a general limitation. 

NR 445.03 is a general limitation. 

The O'Hare line will also be affected by Section 112 of the Clean Air Act Amendments which requires the EPA to 

develop Maximum Achievable Control Technology (MACT) standards for the 189 Hazardous Air Pollutants (HAPs) 

that were identified in the amendments. Styrene is one of die 189 HAPs. The standard is scheduled to be 

promulgated during 1997. 

34 
P.36 

State of Wisconsin EMISSION UNIT COMPLIANCE PLAN 

Department of Natural Resources COMMITMENTS AND SCHEDULE 

AIR POLLUTION CONTROL PERMIT APPLICATION 

Form 4530-131 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number 

241270810 

3. Stack identification number SIO 4. Unit identification number: P30 

5. For Units that are presently in compliance with dl applicable requirements, including any enhanced monitoring 

and compliance certification requirements under section 114(a)(3) of die Clean Air Act diat apply, complete die 

following. 

These commitments are part ofthe application for Part 70 permits. 

[•/] We will continue to operate and maintain this Unit to assure compliance for the duration of die pennit 

[/j Form 4530 -130 includes new requirements that apply or will apply to diis Unit during die term of die permit. 

We will meet such requirements on a timely basis. 

6. For Units not presently fully in compliance, complete the following. These commitments are part ofthe 

application. 

[ ] This Unit is in compliance wim dl applicable requirements except for those indicated below. We will achieve 

compliance according to the following schedule: 

Non-complying 

Requirement Corrective Actions Deadline 
State of Wisconsin STACK IDENTIFICATION 

Depaitment of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-103 10-93 

I. Facility name: 2. Facility identification number 3. Stack identification number 

BRADY USA, INC-CAMERON AVENUE FACILITY 241270810 S14 

4. Exhausting Unit(s), use Unit Id number from appropriate Form(s) 4530-104,106,107,108, and/or 109 

Form Number Form Title Unit ID Number 

109 Miscellaneous Processes P33 

5. Identify this stack on the plot plan required on Form 4530-101 

6. Indicate by checking: 

[V] This stack has an actual exhaust point [ ] This stack serves to identify fugitive emissions. 

If mis stack has an actual exhaust point then provide die following stack parameters 

7. Discharge height above ground level: 25.0 (feet) 

8. Inside dimensions at outlet (check one and complete): 

[•/] Circular 1.30 (feet) [] Rectangular -1 lengdi (feet) -1 width (feet) 

9. Exhaust flow rate: 

Normal 4800 (ACFM) Maximum 4800 (ACFM) 

10. Exhaust gas temperature (normal): 70.0(F) 

II. Exhaust gas moisture content: Normal -1.0 volume percent Maximum -1.0 volume percent 

12. Exhaust gas discharge direction: [•/] Up [ ] Down [ ] Horizontal 

13. Is this stack equipped with a rainhat or any obstruction to the free flow of the []Yes [/|No 

exhaust gases from the stack? 

***** Complete"theappropriate Air Permit Application Forms(s) 4530-104,106r107j 108, or109 for each Unit 

***** 

exhausting through diis stack. 

' 5& 
P.38 

State of Wisconsin MISCELLANEOUS PROCESSES 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Fonn 4530-109 10-93 

I. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number S14 4. Process number P33 

4a. Unit description: 

Finishing operations consisting of one single spindle drill press, two imulti-sp indie drill 

presses, one round comer router, one shaping Irouter, and two belt sanders. 

5. Indicate the control technology status: [] Uncontrolled [•/] Controlled 

If the unit is controlled, enter the control device numbers) (use control device number from appropriate Form(s)) 

Form Number Form Title Device Number 

117 Control Equip-Baghouse/Fabric Filters C33 

6. Source Classification Code (SCC): 

7. Date of construction or last modification: 08-00-79 

8. Normd operating schedule: 8 hrs./day 5 days/wk. 250 days/yr. 

9. Describe this process (please attach a flow diagram of me process). Attached? Y 

Sign finishing involves rounding corners, drilling holes, smoothing ledges, and routing custom 

shapes. 

10. Are raw materials used in this process? N 

Ifyes, list die types and amounts of raw materials used in diis process: 

Materid Storage/material handling process Average usage Units Maximum usage 

Units 

II. Are finished products used in this process? Y 

Ifyes, list the types and amounts of finished products: 

Material Storage/material handling process Average amount Units Maximum Units 

produced amount produced 

Fiberglass signs Finishing 480.00 sg/hr 500.000 sg/hr 

12. Are fuels used in this process? N 

If yes, identify process fuel usage: 

Type of fuel Maximum heat input to Average usage Units Maximum usage Units 

process 

million BTU/hr. 

13. Describe any fugitive emissions associated with diis process, such as outdoor storage piles, Attached? 

unpaved roads, open conveyors, etc.: 

***** po r m j s emissions unit identiify the method(s) of compliance demonstration by completing Form 4530-118, 

***** 

***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 4530-118 

***** and its attachment(s) to this form. 

***** pi eas e complete the Air Pollution Control Permit Application Forms 4530-126 and 4530-128 for this Unit 

***** 

l l -
P.39 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number 

241270810 

3. This form supplements Form 4530-109 for emission unit P33 

4. Additional Infonnation: 

1. sg/hr is signs per hour. 
P.40 

State of Wisconsin | CONTROL EQUIPMENT-BAGHOUSE/FABRIC FILTERS 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-117 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number: S14 4. Unit identification number P33 

5. Control device number C33 

6. Name of manufacturer: Donaldson Co., Inc. Model number Torit 2DF12 

7. Date of Installation: 00/00/86 

8. Describe in detail the device in; use. Attach a diagram of die system. Attached? YES 

Dust collected from each finishing operation is transported, via ivacuum 

tubes, to the dust collector (See attached hardcopy blueprint). 

During normd operation, dust laden air enters the Downflo dust Icollector through the top inlet 

and passes through the filter ielements. Dust is collected on the outside surfaces ofthe 

filters land die filtered clean air flows through die center ofthe elements iinto die clean air 

plenum. The clean air then exits dirough the iclean air outlet (See hardcopy attachment of 

figure 2) 

During filter cleaning (purging), a control time automatically iselects die pair of elements to 

be cleaned and activates a solenoid ivdve which opens an air diaphragm vdve. High pressure 

air pulses Idirectly into center ofthe selected filter elements for 100 imilliseconds. This 

burst of air blows the collected dust off of die ifilter elements. The dust is swept downward 

into the collection drum iby the prevailing air flow and by gravity. (See hardcopy attachment 

lof figure 3) 

9. List of pollutants to be controlled by this equipment and the expected control efficiency for each pollutant. 

[•/] Documentation is attached? 

Pollutant Inlet pollutant Outlet pollutant Efficiency (%) 

concentration efficiency concentration 

gr/acf ppmv gr/acf ppmv 

Particulate matter 0.026 -1 0.000 -1 99.900 

10. Discuss how collected material will be handled for reuse or disposal: 

Collected material is transferred into plastic lined cardboard boxes land disposed of widi die 

normd refuse. 

3V 
P.41 

State of Wisconsin CONTROL EQUIPMENT-BAGHOUSE/FABRIC FILTERS 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION > 

Form 4530-117 10-93 

Continuation Page: 2 

11. Pressure drop across filter 1 - 6 inches 

12. Prepare a malfunction prevention and abatement plan (if required under 

s. NR 439! 11) for this pollution control system. Include the following: 

a. Identification of die individuals(s), by title, responsible for 

inspecting, maintaining and repairing diis device. 

b. Bag cleaning techniques and frequency of cleaning or replacement 

c. Operation variables diat will be monitored in order to detect a 

malfunction or breakthrough, the correct operating range of diese 

variables, and a detailed description of monitoring or surveillance 

procedures mat will be used to show compliance. 

schedule for filters. 

d. An inspection schedule and items or conditions mat will be 

inspected. 

e. A listing of materials and spare parts that will be maintained in inventory. 

f. Is this plan available for review?YES 

Section B 

The following questions must be answered by sources installing new equipment or existing Units 

which cannot document control efficiency of diis device by odier means. 

13. Filter medium or type of fabric material (if fabric, indicate whedier 

felt or woven): 

14. Maximum inlet gas flow rate: -1.0 

15. Maximum inlet gas temprature: -1.00 

16. Number of bags if applicable: -1 

17. Dimensions of bags/filters: 

18. Air to cloth ratio: 

Hb 
P.42 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-117 for emission unit P33 

4. Additional Information: 

During normd operation, dust is collected and routed from each 

finishing machine to the dust collector through vacuum lines. 

The capture efficiency is 70 % 

Inlet pollutant concentration = 0.02569 gr/acf 

Outlet pollutant concentration = 0.00002569 gr/acf 

See attached hardcopy calculations. 

All applicants except non-Part 70 sources are required to certify compliance with all applicable air pollution 

permits requirements by including a statement withing the permit application of die methods used for determining 

compliance (please see sec. NR 407.05(4)(i), Wis. Adm. Code.) This statement must include a description ofthe 

monitoring, recordkeeping, and reporting requirements and test mediods. In addition, die application must include a 

schedule for compliance certification submittals during die permit term. These submittals must be no less frequent 

than annually, and may need to be more frequent if specified by die underlying applicable requirement or by the 

Department 

/. <4 
P.43 

State of Wisconsin COMPLIANCE CERTIFICATION - MONITORING AND 

RECORDING 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-118 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number S14 4. Unit identification number: P33 

5. This Unit will use the following method(s) for determining compliance with the requirements ofthe permit (check 

all that 

apply and attach the appropriate form(s) to this form). 

[ ] Continuous Emission Monitoring (CEM) - Form 4530-119 

Pollutant(s): 

[ ] Periodic Emission Minitoring Uinsg Portable Monitors • Form 4530-120 

Pollutant(s): 

[/| Monitoring Control System Parameters or Operating Paramters of a Process - Form 4530-121 

Pollutants): 

Particulate matter 

[ ] Monitoring Maintenance Procedures - Form 4530-122 

Pollutants): 

[ ] Stack Testing - Form 4530-123 

Pollutant(s): 

[ ] Fuel Sampling and Analysis (FSA) - Form 4530-124 

Pollutant(s): 

[ ] Recordkeeping - Form 4530-125 

Pollutant(s): 

6. Compliance certification reports will be submitted to the Department according to die following schedule: 

Start date: July 1 

and every 12 months thereafter. 

Compliance monitoring reports will be submitted to theDepartment according to the following schedule: 

Start date: July 1 

and every 6 months thereafter. 

The monitoring of a control system parameter or a process shall be acceptable as a compliance demonstration 

method provided that a correlation between the parameter value and the emission rate of a particular pollutant is 

established in the form of a curve of emission rate versus parameter values. At least three sets of stack test data, that 

bracket die emission limit if possible, shdl be used to define the emission curve. This correlation shall constitute die 

certification of die system. It should be attached for Department approval. If it is not attached, it shdl be submitted 

widiin 60 days of die startup ofthe system 
P.44 

State of Wisconsin COMPLIANCE DEMONSTRATION BY MONITORING CONTROL 

SYSTEM 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-121 10-93 

I. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number 

241270810 

3. Stack identification number S14 4. Unit identification number: P33 

5. Pollutant being monitored: Particulate matter 

6. Name of manufacturer: Dwyer Instruments 7. Model number: Series 3000 

8. Is this an existing system: [•/] Yes [ ] No 9. Installation date: 01/01/86 

10. Mediod of monitoring description: 

Dwyer Instruments Photohelic pressure gauge will be used to read die Ipressure drop across the 

baghouse in inches of water. 

Typical is 1 - 6 inches. 

Value will be taken once per week. 

II. Backup system: None 

12. Indicate by checking: 

The monitoring shdl be subject to appropriate performance specifications cdibration requirements and quality 

assurance procedures. [ ] A quality assurance/quality control plan for the monitoring system is attached for 

Department approval. [ ] If the plan is not attached it shall be submitted within 60 days of die start-up ofthe 

Monitoring program. [ ] If the plan has already been submitted to the department please indicate die date of 

die submittal: 

13. The applicant shall propose an appropriate averaging period (i.e., a particular number of continuous hours) for 

the purpose of defining excess emissions. The department may approve the proposed averaging period, or other 

period which die Department determines to be appropriate. Provide die proposed averaging period(s) below: 

Parameter Averaging Period 

na \ na 
P.45 

State of Wisconsin EMISSION UNIT SUMMARY 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-128 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number: S14 4. Unit identification number: P33 

5. Complete die following emissions summary for the following pollutants. Attach sample calculations and emission 

factor references. Attached? Y 

Maximum theoretical emissions Potential to emit Maximum allowable 

U TPY U TPY 

0.00099 3.75000 1 6.08557 0.00222 TPY 0.00375 1 

Air Pollutant 

Particulate matter 

0.00222 

Actual 

U TPY 

0.00106 1 

Units (U) should be entered as follows: 

1 = lb/hr 

2 = lb/mmBTU 

3 = grains/dscf 

4 = lb/gallon 

5 = ppmdv 

6 = other(specify). 

7 = otiier(specify) _ 

8 = other(specify). 
P.46 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-128 

4. Additional Information: 

See attached calculations. 

State of Wisconsin CURRENT EMISSIONS REQUIREMENTS AND STATUS OF UNIT 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-130 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number S14 4. Unit identification number: P33 

5. Pollutant 6. Wis. Adm. Code 7. 8. Limitation 9. Compliance 

Wis. Stats., State Status 

40 CFR Only (in or out) 

Particulate matter NR415.05(l)(o);NR 415.05(2) See attached. In 

Visible Emissions NR 431.05 20% Opacity In 

** Malodorous Emissions NR 429.03(1) See attached. In 

10. Otiier requirements (e.g., malfunction reporting, special operating conditions from an State Only 

Compliance 

existing permit etc.) Status 

(in or out) 

Pressure drop range of 1-6 inches of water across the dust collector In 

•4S~ 
P.47 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-130 for emission unit P33 

4. Additional Information: 

NR415.05(l)(o): limit of 0.4 pounds of particulate matter per 

1000 lbs. of gas. 

NR 415.05(2): E=3.59P0.62 where E=the allowable emission rate in 

lbs/hr and P=the process throughput in tons per 

hour. 

NR 429.03(1) is a general limitation. 

The dust collector has a differential pressure gauge which 

indicates die pressure drop across die dust collector. 

State of Wisconsin EMISSION UNIT COMPLIANCE PLAN 

Department of Natural Resources COMMITMENTS AND SCHEDULE 

AIR POLLUTION CONTROL PERMIT APPLICATION 

Form 4530-131 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number: S14 4. Unit identification number: P33 

5. For Units that are presently in compliance widi all applicable requirements, including any enhanced monitoring 

and compliance certification requirements under section 114(a)(3) of die Clean Air Act that apply, complete the 

following. 

These commitments are part of the application for Part 70 permits. 

[•/] We will continue to operate and maintain this Unit to assure compliance for die duration ofthe permit. 

[ ] Form 4530 -130 includes new requirements mat apply or will apply to this Unit during the term ofthe permit. 

We will meet such requirements on a timely basis. 

6. For Units not presently fully in compliance, complete the following.' These commitments are part ofthe 

application. 

[ ] This Unit is in compliance widi all applicable requirements except for those indicated below. We will achieve 

compliance according to the following schedule: 

Non-complying 

Requirement Conective Actions Deadline 
P.48 

State of Wisconsin STACK IDENTIFICATION 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-103 10-93 

I. Facility name: 2. Facility identification number: 3. Stack identification number: 

BRADY USA, INC-CAMERON AVENUE FACILITY 241270810 S30 

4. Exhausting Unit(s), use Unit Id number from appropriate Form(s) 4530-104,106,107,108, and/or 109 

Form Number Form Title Unit ID Number 

107 Printing Operations P35 

5. Identify this stack on the plot plan required on Form 4530-101 

6. Indicate by checking: 

[ ] This stack has an actual exhaust point. [•/] This stack serves to identify fugitive emissions. 

Ifthis stack has an actual exhaust point, dien provide die following stack parameters 

7. Discharge height above ground level: -1.0 (feet) 

8. Inside dimensions at outlet (check one and complete): 

[] Circular -1 (feet) [] Rectangular -1 length (feet) -1 width (feet) 

9. Exhaust flow rate: 

Nonnal -1 (ACFM) Maximum -1 (ACFM) 

10. Exhaust gas temperature (normal): -1.0(F) 

II. Exhaust gas moisture content Normd -1.0 volume percent Maximum -1.0 volume percent 

12. Exhaust gas discharge direction: [ ] Up [ ] Down [ ] Horizontal 

13. Is this stack equipped with a rainhat or any obstruction to the free flow of the []Yes []No 

exhaust gases firom the stack? 

***** Completethe appropriate Air Permit Application Forms(s) 4530-104; 106, 107,108, or 109 for each Unit 

***** 

exhausting through this stack. 

6\ 4 
P.49 

State of Wisconsin PRINTING OPERATIONS 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-107 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number: S30 4. Process number: P35 

4a. Unit description: 

SP-5 Screen Press P35, S30 

Manufacturer: Medalist Industries 

Screen printing of paper and plastic substrates. 

Air drying rack with capacity for 40 printed sheets; no oven; no istack. 

. Maximum "as applied" ink usage = 0.644 gal/hr. 

Maximum "as applied" ink VOC emissions = 2.866 lbs/hr. 

Maximum clean-up solvent usage = 0.50 gal/hr. 

Maximum clean-up solvent VOC emissions = 3.60 lbs/hr. 

5. Indicate the control technology status: [>/] Uncontrolled [] Controlled 

If the unit is controlled, enter the control device numbers) (use control device number from appropriate Form(s)) 

Form Number Form Title Device Number 

6. Operation type: [ ] Flexographic [ ] Web-offset [ ] Web-offset (non-heatset) [ ] Packaging Rotogravure 

[ ] Publication Rotogravure [/) Screen printing [ ] Odier (specify) 

7. Date of construction or last modification: 11-01-92 

8. Normal operating schedule: 1 hrs./day 1 days/wk. 22 days/yr. 

9. Oven curing (complete if applicable): 

Number of ovens -1 Specify oven fuels 

Total maximum energy input to each oven -1.00 

10. Describe all ofthe inks' and solvents' composition (as applied) diat are used by this Unit. 

Name of ink 

a. 

59000 Series Inks 

Total Inks: 

Maximum usage Normal Solids VOC Water Density Pounds 

usage % % % VOC/ 

gallon 

b. c. d. e. f. g. less/H20 

gal/hr gal/yr gal/yr W V W V W V lbs/gal h. 

0.644 1185.4 5.0 44.2-1.0 55.8-1.0 0.0-1.0 7.98 4.45 

List the thinning solvents used wim the inks identified above. 

5500 Thinner 0.069 126.9 0.4 0.0 -1.0 100.0 -1.0 0.0 -1.0 6.60 

5550 Retarder 0.021 38.6 0.2 0.0 -1.0 100.0 -1.0 0.0 -1.0 6.60 

Cl-up Solv Screenwash 2342 0.500 1731.0 10.0 0.0-1.0 100.0-1.0 0.0-1.0 7.16 

***** For mis emissions unit, identify the method of compliance demonstration by completing Form 4530-118, 

DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 4530-118 and its 

attachment(s) to this form. This is not a requirement of non-Part 70 sources. 

***** pieaSe complete the Air Pollution Control Permit Application Forms 4530-126 and 4530-128 for this 

unit***** 

<^'-> 
P.50 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION ! 

1

 Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number 

241270810 ! 

I 

3. This fonn supplements Fonn 4530-107 for emission unit P35 

4. Additiond Information: 

See hardcopy attachment for calculations and flow diagram. 

Please note diat ink data is "as applied" data. This means that thinner and retarder additions are already calculated 

and ink composition and usage data includes diem. 

All applicants except non-Part 70 sources are required to certify compliance with all applicable air pollution 

permits requirements by including a statement withing the permit application ofthe mediods used for determining 

compliance (please see sec. NR 407.05(4)(i), Wis. Adm. Code.) This statement must include a description of die 

monitoring, recordkeeping, and reporting requirements and test mediods. In addition, the application must include a 

schedule for compliance certification submittals during the permit term. These submittals must be no less frequent 

dian annually, and may need to be more frequent if specified by the underlying applicable requirement or by the 

Department * 

tCAf? 
P.51 

State of Wisconsin COMPLIANCE CERTIFICATION - MONITORING AND 

RECORDING 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-118 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number S30 4. Unit identification number: P35 

5. This Unit will use the following method(s) for determining compliance with die requirements ofthe pennit (check 

all that 

apply and attach the appropriate form(s) to this form). 

[ ] Continuous Emission Monitoring (CEM) - Form 4530-119 

Pollutants): 

[ ] Periodic Emission Minitoring Uinsg Portable Monitors - Form 4530-120 

Pollutant(s): 

[ ] Monitoring Control System Parameters or Operating Paramters of a Process - Form 4530-121 

Pollutant(s): 

[ ] Monitoring Maintenance Procedures - Form 4530-122 

Pollutants): 

[ ] Stack Testing - Fonn 4530-123 

Pollutants): 

[ ] Fuel Sampling and Analysis (FSA) - Form 4530-124 

Pollutants): 

[S\ Recordkeeping - Form 4530-125 

Pollutant(s): 

Volatile Organic Compounds. 

6. Compliance certification reports will be submitted to die Department according to the following schedule: 

Start date: July 1 

and every 12 months thereafter. 

Compliance monitoring reports will be submitted to theDepartment according to die following schedule: 

Start date: July 1 

and every 6 months thereafter. 

Recordkeeping shall be acceptable as a compliance demonstration method provided that a correlation between the 

parameter value recorded and die emission rate of a particular pollutant is established in die form of a curve or chart 

of emission rate versus parameter values. This conelation shall constitute the certification ofthe system. It should 

be attached for Department approval. If not attached, it shall be submitted widiin 60 days ofthe startup of die 

system. 

:&> 
P.52 

State of Wisconsin COMPLIANCE DEMONSTRATION BY RECORDKEEPING 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-125 10-93 

I. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number S30 4. Unit identification number: P35 

5. Pollutant diat compliance status is being evaluated: 

Volatile Organic Compounds. 

6. Materid or parameter being monitored and recorded: 

Ink usage. 

Clean-up solvent usage. 

7. Method of monitoring and recording: 

Daily weighing of all inks and solvents used at die press. 

Data input into VOC database program which calculates VOC emissions ibased on weight of material 

used. ' 

Data storage on computer network which is backed up daily. 

8. List any EPA methods used: 

9. Is this an existing mediod of demonstrating compliance: 10. Installation date: 11/01/92 

ry]Yes[jNo 

II. Backup system: See attached. 

12. Compliance shdl be demonstrated: [/| Daily [ ] Weekly [ ] Monthly [ ] Batch(not to exceed monthly) 

13. Indicate by checking: 

The monitoring shall be subject to appropriate performance specifications calibration requirements and 

quality assurance procedures. [ ] A qudity assurance/quality control plan for the recordkeeping system is attached 

for Department approval. [ ] If die plan is not attached it shall be submitted widiin 60 days of die start-up of die 

recordkeeping program. [ ] If the plan has already been submitted to die department please indicate die date of 

submittal: 

***** -phg compliance records shall be available for Department inspection. The format for the compliance 

certification report and the excess emission report shall be approved by the department. A proposed format for the 

compliance certification report and excess emission report shall be submitted at die same time as die application 

***** The source shall record any malfunction which causes or may cause an emission limit to be exceeded. 

Malftmctions shall be reported to the department the next business day. Hazardous air spills shall be reported to the 

Department immediately. 

,-Vi«- & 
P.53 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-125 for emission unit P35 

4. Additional Information: 

Backup system: 

Clean solvent and ink amounts could be obtained from an inventory 

review. 

Ink amounts could also be back calculated based on final product 

amounts. 

L„J>£— 
P.54 

State of Wisconsin > EMISSION UNIT HAZARDOUS AIR POLLUTANT SUMMARY 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Fonn 4530-126 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number: S30 4. Unit identification number P35 

5. Unit materid description: Screenwash 2342 

6. Complete the following summary of hazardous air emissions from diis unit. Attach sample calculations and 

emission 

factor references. Attached? Y 

Pollutant CAS Actual Maximum theoretical emissions Potential to emit 

Units Units 

108-88-3 1.31028 lb/hr 2.18380 lb/hr 0.07862 TPY 

:

ty~z 
P.55 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-126 for emission unit P35 

4. Additional Information: 

See hardcopy attachment to Form 107 for calculations. 
P.56 

State of Wisconsin EMISSION UNIT SUMMARY 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-128 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number 

241270810 

3. Stack identification number S30 4. Unit identification number. P35 

5. Complete die following emissions summary for die following pollutants. Attach sample calculations and emission 

factor references. Attached? Y 

Air Pollutant Actual Maximum theoretical emissions Potential to emit Maximum allowable 

U TPY U TPY U TPY 

Volatile organic compo 2.56000 1 0.03360 6.46600 1 8.86800 0.24230 TPY 6.46600 1 

0.24230 

Units (U) should be entered as follows: 

1= lb/hr 

2 = lb/mmBTU 

3 = grains/dscf 

4 = lb/gallon 

5 = ppmdv 

6 = omer(specify) _ 

7 = other(specify). 

8 = other(specify). 

\L*^J> 
P.57 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-128 

4. Additional Information: 

See hardcopy attachment to Form 107 for calculations. 

Actual Emissions: 

1. Ink: 

Nonnal hourly ink usage is 0.4 gal/hr 

As applied ink usage = (0.4 gal/hr x 10 lbs/gal) + 

5.5% diinner + 3.0% retarder = 0.74 lbs ink/hr 

0.74 lbs/hr x 55.75 wt% VOC - 0.4126 lbs VOC/hr 

Normal operation is approximately 12 hrs/yr 

12 hrs/yr x .4126 lbs VOC/hr - 4.95 lbs VOC/yr 

(0.00248 tpy) 

2. Clean-up solvent: 

Normd hourly usage = 0.3 gal/hr 

0.3 gal/hr x 7.16 lbs VOC/gal = 2.148 lbs VOC/hr 

Normal (1994) usage = 62.2 lbs/yr 

= 62.2 lbs VOC 

(0.0311 tpy) 

Total Actual VOC emissions: 

0.4126 lbs/hr + 2.148 lbs/hr = 2.56 lbs/hr 

0.00248 tpy + 0.0311 tpy = 0.0336 tpy 

Maximum Theoretical Emissions: 

1. Ink: 

See calculations attached to Form 108, S30, P35. 

Hourly MTE = 2.866 lbs 

Annual MTE = 2.636 tons 

m* 
P.58 

2. Clean-up solvent: 

See calculations attached to Form 108, S30, P35. 

Hourly MTE = 3.6 lbs 

Annud MTE = 6.232 tons 

Total Maximum Theoretical Emissions: 

2.866 Ibs/hr + 3.6 lbs/hr = 6.466 lbs/hr 

2.636 tpy + 6.232 tpy = 8.868 tpy 

Potential to Emit: 

1. Ink: 

Annual Potential to Emit is based on a permit limit of 

three gal/mo ink usage. 

3 gal/mo x 12 mo/yr = 36 gal/yr 

36 gal/yr x 10 lbs/gal = 360 lbs/yr 

360 lbs/yr + 10 max wt% thinner + 3 max wt% retarder = 406.8 

lbs. 

406.8 lbs/yr x 55.75% VOC - 226.79 lbs VOC/yr 

(0.1134 tpy) 

2. Clean-up solvent: 

Annual Potential to emit is based on a pennit limit of 

3 gal/mo. 

3 gal/mo x 12 mo/yr = 36 gal/yr 

36 gal/yr x 7.16 lbs VOC/gal = 257.76 lbs VOC/yr/ 

(0.1289 tpy) \ 

Total Potential to Emit: 

0.1134 tpy+ 0:1289 tpy = 0:2423 tpy 

Maximum Allowable: 

1. Ink: 

Hourly Maximum Allowable equals Hourly MTE 

Annual Maximum Allowable equals Annual Potential to Emit 

2. Clean-up solvent: E 

Hourly Maximum Allowable equals Hourly MTE 

Annual Maximum Allowable equals Annual Potential to Emit 

y 
P.59 

State of Wisconsin CURRENT EMISSIONS REQUIREMENTS AND STATUS OF UNIT 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-130 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number: S30 4. Unit identification number: P35 

5. Pollutant 6. Wis. Adm. Code 7. 8. Limitation 9. Compliance 

Wis. Stats., State Status 

40 CFR Only (in or out) 

Volatile organic compounds (Reactive organi NR 419.03 & .04 See attached In 

** Malodorous Emissions NR 429.03(1) See attached In 

10. Odier requirements (e.g., malfunction reporting, special operating conditions from an State Only 

Compliance 

existing permit etc.) Status 

(in or out) 

Monthly ink usage limit of 3 gallons. In 

Ddly ink usage limit of 2 gallons. In 

Montiily clean-up solvent usage limit of 3 gallons. In 
P.60 

State of Wisconsin SUPPLEMENTAL INFORMATION - Text 

Department of Natural Resources AIR POLLUTION CONTROL OPERATION PERMIT 

APPLICATION 

Form 4530-135 10-93 

1. Facility Name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identificaton number: 

241270810 

3. This form supplements Form 4530-130 for emission unit P35 

4. Additiond Information: 

NR 419.03 & .04 are general limitations. 

NR 429.03(1) is a general limitation. 

Specific materid usage limits were elected in order to avoid 

being subject to die emission limitations of Chapter NR 424, 

Wis.Adm. Code. 

-t^TS1 
P.61 

State of Wisconsin EMISSION UNIT COMPLIANCE PLAN 

Department of Natural Resources COMMITMENTS AND SCHEDULE 

AIR POLLUTION CONTROL PERMIT APPLICATION 

Form 4530-131 10-93 

1. Facility name: BRADY USA, INC-CAMERON AVENUE FACILITY 2. Facility identification number: 

241270810 

3. Stack identification number S30 4. Unit identification number: P35 

5. For Units diat are presently in compliance widi all applicable requirements, including any enhanced monitoring 

and 

compliance certification requirements under section 114(a)(3) of die Clean Air Act that apply, complete the 

following. 

These commitments are part of the application for Part 70 permits. 

[•*/] We will continue to operate and maintain this Unit to assure compliance for the duration ofthe permit. 

[ ] Form 4530 -130 includes new requirements mat apply or will apply to this Unit during the term of die permit. 

We 

will meet such requirements on a timely basis. 

6. For Units not presently fully in compliance, complete die following. These commitments are part of die 

application. 

[ ] This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve 

compliance according to die following schedule: 

Non-complying 

Requirement Corrective Actions Deadline 

Ks0pl0hl2v3T 

'&C.