p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

73) 11-1-73 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:23 PM Sheet 73 of 114 
p ? 

1/21/97 15:51 S.0 4 558 1222 BV OAO ANNEI ft-l-J-5**- 141001 

© 

FAX TRANSMISSION 

WV OFFICE OF Am QUALITY 

I <5 I S WASHINGTON STREET. EAST 

CHARLESTON. VW 253 1 I 

(30-4) 558-OQ8S 

FAX: i30Ai SSS-1 2Z2 

-JllJJ: 

EPA AIR DOCKET 

To: Madeline Strum - EPA Date: November 21,1997 

Fax#: 919-541-56S9 Pages: 18, including this cover sheet. 

From: William (Bill) W. Morrelles, Jf: 

Subject: Info pertaining to WV Office of Air Quality Peraoit Rl 3-2006 for Afcer Plastics 

COMMENTS: 

Per our discussion, attached is a copy of a FAX and a letter that were transmitted to Bill 

Browne - USEPA Region III pertaining to tte subject permitting action. Also attached is a copy 

ofthe Engineering Evaluation and the approved Permit. I hope that some of this infonnation will 

be useful to you. Please advise if I may be of assistance. 
P.3 

11/21/97 15:51 ©304 558 1222 WV OAQ ANNEX ©00 2 

© 

FAX TRANSMISSION 

WV OFFICE OF Am QUALITY 

l © 15 W_V3HINOTON STREET. CAST 

CHARLESTON. WV 2S3 1 I 

(304) ssa-oaas 

TAX: 130-** S58-I22 2 

To: Bill Browne - USEPA Region Ht Date: June U, 1997 

Fax#: (215)566-2114 Pages: 17, including this cover sheet. 

From: William (Bill) W. MorrellcS,~Jr. 

Subject: Notice of Intent to Pennit Proposed Aker Plastics Co. Modification 

COMMENTS: 

The subject proposed pennit (Number Rl3-2006) will limit VOC emissions from the 

Aker facility to less than 54 tons per year versus the 189 tons per year that is currently permined. 

Reduclions in VOC emissions will be accomplished by the addition of control devices consisting 

of rotary concentrators (adsorption equipment) operating in conjunction with a thcnnol oxidizer. 

Based on air dispersion modeling studies, we anticipate that the controls in combination with a 

new sixty foot stacic will also facilitate a step change reduction in the incidence of odors in the 

vicinity of the Aker facility. 
, _____ ______ 

1/21/97 15:52 ®30 4 558 1222 WV OAQ ANNEX ©003 

DIVISION OF ENVIRONMENTAL PROTECTION 

CECILH. UNDERWOOD OFFICE OF AIR QUALITY JOHN E. CAFFRSY 

GOVERNOR DIRECTOR 

JOHN H. JOHNSTON, CHIEF 

June 11, 1997 

Bill Browne VIA FACSIMILE 

Permit Programs Section (3AT23) (215) 566-2114 

United States Environmental Protection Agency 

Region III 

841 Chestnut Building 

Philadelphia, PA 19107 _ RE: Notice of Intent to Permit 

Aker Plastics Company Modification 

Proposed Pennit No. R13-2006 

Plant ID No. 0030026 

Dear Mr. Browne: 

On April 27, 1994, West Virginia Office of Air Quality revised Legislative Rule 45CSR13 

- "Pennits For Construction, Modification, Relocation And Operation Of Stationary Sources Of 

Air Pollutants, Notification Requirements, Temporary Pennits, General Pennits, And Procedures 

For Evaluation" became effective. Section 6.4 of the revised rule states that the Chief (WVOAQ) 

shall, prior to the issuance of any permit, transmit to USEPA a fact sheet and a draft copy of the 

permit which is proposed for issuance. Concurrently a Class I legal advertisement, which serves 

to notify die public of the intent to issue a permit, is placed in a newspaper of general circulation 

in the area of the proposed new source. A thirty (30) day period, beginning with the date of the 

legal advertisement, is provided for the public and USEPA to make comments on the proposed 

permit. 

In accordance with 45CSR13 Section 6.4, enclosed is a copy of the fact sheet and draft 

permit. Absent any adverse comments from the public or the USEPA which could warrant 

changes to the draft permit, the Chief will sign the permit and thereby authorize Aker Plastics 

Company, Inc. to proceed with modification of a fiberglass bath unit manufacturing facility. The 

Class I legal advertisement is scheduled to be published in The Journal in Martinsburg, WV on 

June 13, 1997 which will commence the 30-day public comment period. If you have any 

comments, please submit them by July 11, 1997. I may be contacted at (304) 558-0885. 

Sincerely, 

yjjL±^yYirrjL.fi. 

William W. Morrelles, Jr. P. E. 

Engineer DI 

WWM/amw 

Enclosures 

cc: W. Leonard Womble 

Permit Program Manager 

PLANNING & PERMITTING 

u s s w»hinntnn Strait East Qiartaston. WV 25311-2539 P«on*»: (304) 558-083S Fax: (30*1 554-1222 
P.5 

Ll/21/97 15:52 ®304 558 1222 WV OAQ ANNEX QQ004 

® 

DIVISION OF ENVIRONMENTAL PROTECTION 

CECIL H. UNOERWOOO OFFICE OF AIR QUALITY JOHN E. CAFFREY 

GOVERNOR . OIRECTOR 

JOHN H. JOHNSTON. CHIEF 

ENGINEERING EVALUATION 

AKER PLASTICS COMPANY, INC. 

Martinsburg, WV, Berkeley County 

Plant ID No.: 0030026 

Application Number R13-2006 

OAQ APPLICATION ADMINISTRATIVE INFORMATION 

Received: February 13. 1996 Complete: February 13,1996 Final Action Due 

By: July 14, 1997 

Type of Application: Modification 

Facility Location: Berkeley County 

Fee Paid: Yes a No O Date Paid: 02/22/96 Amount: S 1.000 

Aff. of Pub.: Yes a No a Pub. Date: 02/14/96 Newspaper: The Journal, 

Martinsburg. WV 

Engineer: William W. Mocrslles, Jr. Assigned: 02/15/96 Completed: July 14, 

1997 Approved: July 14, 1997 

NODs: 05/15/96. 08/19/96, 10/30/96. and 05/14/97 

OAQ Notice Pub. Data: June 13, 1997 Newspaper: The Journal, Martinsburg, 

WV 

Pennit Issued: July 14, 1997 

B ACKGROUNP INFORMATION 

On February 13,1996, Aker Plastics Company applied for a permit to modify a fiberglass 

baih unit manufacmring facility that is located near Martinsburg, West Virginia. This operation 

is currendy permitted by Pennit No. R13-844 which was approved on June 4, 1986. The 

proposed modification would authorize the increased usage of raw materials and the construction 

of a rotary concentrator and a thennal oxidizer for removal and combustion of at least 90 percent 

of the volatile organic compounds (VOCs) in the ventilation air exiting the manufacturing 

building. 

DESCRIPTION OF PROCESS 

Reinforced plastic bath tubs and shower enclosures are produced by spraying a polyesterbased gel coat onto a mold and applying laminating layers of fiberglass and polyester-based resin. 

Polymerization of the styrene monomer, which is present in the gel coat and the resin, is 

accomplished using a catalyst (methyl ethyl ketone peroxide). After the form "gels" and cures, 

the tub or shower is trimmed and finished (by sawing). The fabrication process emits VOCs, 

which consist primarily of styrene, and the trimming process generates particulate matter. Vapor 

PLANNING & PERMITTING 

.Sea Washington Street East Charleston. WV 25311-2S99 Phone: (304) SS8-0885 Fax: (304) 553-1222 
P.6 

1/21/97 15:53 ©30 4 558 1222 WV OAQ ANNEX ifiiuua 

te 

suppressed resins are utilized to reduce the magnitude of styrene emissions. The proposed rotary 

concentrator and thennal oxidizer will be designed to remove at least 90 percent of the VOCs 

in the ventilation air exiting the manufacturing building. The VOCs that are adsorbed on 

activated carbon in the rotary concentrator will be evolved during continuous regeneration with 

combustion in the oxidizer using natural gas as a supplementary fuel. 

SITE INSPECTION 

On April 3, 1997, Chris Arlington and Bill Morrellcs (WV Office of Air Quality) 

conducted a site inspection of the existing Aker manufacturing facility and the location of the 

proposed facility modification. The Aker facility is located adjacent to die Mid-Atlantic Parkway 

which is off U.S. Route Number 11 and in the vicinity of other manufacturing facilities. There 

are residential neighborhoods to the east of the Aker facility. The nearest residence is about 0.4 

of a mile from the proposed locadon of a new stack for discharge of building ventilation air that 

has passed through the proposed new control devices. 

ESTIMATE QF EMISSIONS BY REVIEWING ENGINEER 

See ATTACHMENT A 

W5QUIATQRY APPUCABIUTY 

The plastics manufacturing facility that is proposed for permitting under this application 

is subject to the following State of West Virginia regulations: 

45CSR4: "To Prevent and Control the Discharge of Air Pollutants into the Open Air 

Which Causes or Contributes to an Objectionable Odor or Odors" 

45CSR6: "To Prevent and Control Air Pollution from Combustion of Refuse" 

45CSR7: 'To Prevent and Control Air Pollution from Manufacturing Process Operations" 

45CSR13: "Pennits for Construction, Modification, Relocation and Operation of 

Stationary Sources of Air Pollutants, Notification Requirements, Temporary Pennits, 

General Permits, and Procedures for Evaluation" 

45CSR30: "Requirements for Operating Permits" 

The proposed modified facility is not subject to any of the requirements of 45CSR14, 

45CSR21, 45CSR25, or 40CFR60. Proposed emissions of volatile organic compounds (VOCs) 

include two chemicals (styrene and methyl methacrylate) which are hazardous air pollutants 

(HAPs). However, there are no cunent NSPS or MACT standards which apply to the proposed 

facility modification. Relatively small quantities of acetone and a water-based solvent, used in 

clean out operations, are also emitted. Acetone is not regulated as either a VOC or a HAP. 

R13-2006 

Aker Plastics Company, Inc. 

Page 2 of 6 
!

 •• — : P.7 

1/21/97 15:53 ®304 558 1222 WV OAQ ANNEI -_auuo 

The odor threshold for styrene is about 0.05 parts per million (216 Mg/m3). Air dispersion 

modeling studies indicate that use of the proposed rotary concentrator and thermal oxidizer in // M 

combination with a new sixty foot stack should reduce styrene concentrations to less than 100 {Jo J 

Mg/m3 in the ambient air beyond the boundaries of the Aker manufacturing facility (during a one ^*~"^ 

hour averaging period). Therefore, the proposed controls are expected to facilitate compliance 

with 45CSR4. 

The maximum allowable particulate maner that may be discharged from any incinerator 

into the open air is limited by the requirements in 45CSR6. Maximum proposed emissions from 

the thermal oxidizer, that is part of the subject proposed facility, will comply with the "Emission 

Standards for Incinerators and Incineration" that are described in Section 4.1 of 45CSR6. 

An existing cyclone dust collector is used to remove fiberglass particulate matter from 

the ventilation air from trimming operations. Maximum proposed emissions of particulate matter, 

from the trimming operation dust collector, are estimated at 0.014 pounds per hour and 0.06 tons 

per year. These particulate emissions are well within the limitations imposed by 45CSR7 (based 

on a Source Operation Type 'd', process weight rates described in Aker's permit application, and 

the maximum allowable emission rates for specific process weight rates that are prescribed in 

Table 45-7A in 45CSR7). Gypsum (calcium sulfate) is currendy added to the polyester resin 

prior to use in the manufacturing process. The gypsum is handled in a closed conveying system-' 

and any fugitive dust from this operation would be emitted inside the manufacturing building. 

Some of this dust and any other fugitive particulate from over spray during coating operations 

could be present in the ventilation air from the manufacturing building (which would pass 

through prefilters prior to entering the proposed VOC control system). 

TOXICITY OF NON-CRITERIA REGULATED POLLUTANTS 

Emissions of VOCs from the proposed modified manufacturing facility include styrene 

and methyl methacrylate which are hazardous air pollutants (HAPs). These chemicals are present 

in the raw materials used in the manufacturing process. Aker Plastics has submitted toxicological 

information and Material Safety Data Sheers (MSDS) pertaining to the raw materials that are 

used in die process. Styrene has a TLV/TWA of 50 parts per million and methyl methacrylate 

has a TLV/TWA of 100 parts per million. The American Conference of Governmental Industrial 

Hygienists (ACGIH) has published a notice of intended change in the TWA for styrene (to 20 

parts per million). Based on air dispersion modeling studies, styrene concentrations are projected 

to be less than the odor threshold of about 0.05 parts per million (Less than 1/1000 of the cunent 

TLV/TWA) in the ambient air beyond the boundaries of the Aker manufacturing facility. Based 

on the modeling study results for styrene, methyl methacrylate concentrations are also expected 

to be much less than the odor threshold of about Q.20 parts per million (less than 1/500 of the 

TLV/TWA). 

AIR OUALITY IMPACT ANALYSIS 

The proposed facility modifications were modeled using the US EPA approved Industrial 

Source Complex Short Term (ISCST3) model. This model is capable of modeling facilities in 

both complex and simple tenain such as in the Martinsburg, WV area where the proposed facility 

modification is to be located. The purpose of the modeling study was to detennine if 

R13-2006 

Aker Plastics Company, Inc. 

Paae 3 of 6 
P_8_ 

'21/97 15:54 ®304 558 1222 WV OAQ ANNEX -^00" 

objectionable odors, from styrene emissions, would occur if a 45CSR13 permit is granted (as 

discussed above). />—•*«. ® 

MONITORING OF OPERATIONS 

Performance determinations to evaluate the emission of pollutants from the new sixty foot 

stack are recommended within one hundred twenty (120) days of the commencement of operation 

of the proposed rotary concentrator and thermal oxidizer control devices. Record keeping 

pertaining to raw material usage, continued routine inspection of the facility, and surveillance of 

the sunounding area for odors are also recommended. 

LEGAL ADVERTISEMENTS 

No comments were received by the Office of Air Quality in response to the Notice of 

Intent to Approve Construction and Operation that was published by the Office of Air Quality 

in The Journal in Martinsburg, WV on June 13, 1997. There were no comments from the 

USEPA in response to copies of a Fact Sheet and draft permit that were transmitted via a 

facsimile on June 11, 1997. Tiiere were two odor complaints and a comment letter from one of 

the complainants concerning odors from the Aker Plastics Company facility at about the same 

time that the applicant's legal advertisement was published in The Journal in Martinsburg, WV 

(February 14, 1996). These comments were addressed by the Northern Panhandle Office of Air 

Quality in letters to the complainants. 

RECOMMENDATION TO CHTF.F 

The granting of a permit to Aker Plastics Company for increased usage of raw materials 

and construction of the proposed rotary concentrator, tiiermal oxidizer, and new sixty foot stack 

is recommended along with the incorporation into this permit of those facilities previously 

permitted by Pennit No. R13-S44. 

William W. Monelles, Jr. / 

Engineer IU 

WWM/ 

R13-2006 

Aker Plastics Company, Inc. 

"O-arra A. r.'F £ 
• If***!: 

at 

cn 

ENGINEERING EVALUATION 

ron PERMITTING ACTION 

(Continued) 

Permit No.: R13-2006 

ATTACHMENT A 

Bmiaaions Sunyiarv 

Vt 

Ol 

Oa 

IO 

to 

ro 

Nam, of fraccsi Equipment : 

Source Vcnlcd to Coalrul 

Device anil i.(|ui*»n_cnl 

Idcnllrirfltlaa Number 

Gelcoii Gun GG t 

GcloaiiGunGG? 

Getcrul Gun GG ) 

Gclcoal Gun OG 4 

Chopper Gun CG 1 

Choppe* Guo CG I 

Clapper Gun CG ) 

Chopper Gun CG 4 

Chopper Gun CG 5 

Chopper Gun CG 6 

Choppe/Gun CG 7 

Chopper Gun CGS 

Name ol 

I'olliiUnt 

CfnlttB-l 

VOCs 

voc» 

VOCi 

VOCi 

VOCi 

VOCi 

VOC. 

VOC» 

voc* .. 

VOCs 

VOCi. 

VOCi 

Macinuin 

Source 

Embslan 

IUU (lb*/|.r. 

If.l 

• B.I 

18.1 

U.I 

6.1 

6.1 

a.i 

6.1 

6.1 

6.1 

6.1 

6.1 

Era Uii on 

Point 

IdealMcftllon 

Number 

sr-i 

ST-1 

ST-1 

ST-1 

sr-i 

ST-I 

ST-1 

ST-1 

ST-1 

ST-1 

ST-1 

ST-1 

Conlrol 

Dcylcc 

IdealMkrWlon 

Number 

RTOI 

RTOI 

RTOI 

RTOI 

HTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTDI 

RTOI 

RTOI 

Conlrol Derlcc 

Description 

Thermal Oxidizer 

Thennal Oxidizer 

Thennal Oxidizer 

The-nial Oxidizer 

TbciiD-ilOiililiicr 

Themal Oxidizer 

Theftn*-) Oxidizer 

TtiermiiaKldJur 

Tlteimat Oxidizer 

1 tic mul Oxidizer 

Thermit Oxidizer 

Thermal Oxidizer 

Efficiency 

o.Control 

Device 

(Pcrccoi) 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

Maximum 

AUowible Hour* 

1

 pf Operallfto 

<i>«/yo 

0760 

8760 

8760 

6760 

8760 

1760 

8760 

8760 

8760 

8760 

8760 

8760 

Mixi_nuat Allowable 

FolluUnI Erolalom 

Ihiilir 

1.81 

I.BI 

1.81 

1.81 

0.61 

0.61 

0.61 

061 

0.61 

0.61 

OM 

0M 

toaityr 

7.91 

7.9_» 

7.93 

7J9] 

2-67 

2.67 

2.67 

2.67 

2.67 

2.67 

3.67 

2.67 

% 

o 

> 

tD 

M 

Page 5 of 6 

R13-2006 

Aker Plastics Company, Inc. 

o 

OQ 
CO 

- I 

ENGINEERING EVALUATION 

FOR PERMITTING ACTION 

(CODtinued) 

Permit No.: R13-2006 

ATTACHMENT A 

Emissions SummaTv IContinued) 

en 

c-t 

Ca 

O 

cn 

cn 

oo 

Name of Process Equipment 

Source Ven led to Control 

Device and Equlpo-enl 

Identification Number 

Trimming Saws 

Ktsin Tank HTI 

R tsin Tank IIT2 

lies In Tank HT J 

Name ol 

Poltuiaot 

Eraltleel 

Particulate 

Mailer 

VOCs 

VOCi . 

VOCs 

Mailiauin 

Source 

Embilan 

Rate (IM i r) 

12.9 

0.006 

0.006 

0.006 

Emission 

Paint 

ltSenlitlHtlon 

Nuoibir 

ST-l 

ST-J 

srr-4 

ST-J 

Control 

Derlcc 

l-taiUOcatlan 

Number 

D O 

N/A 

N/A . 

N/A 

Centrnl Device 

Description 

Cyclone Dusc 

Collector 

N/A 

WA 

N/A 

Efficiency 

ol Coat rol 

Device 

(Pertenl) 

W W 

WA 

N/A 

WA 

Maximum 

Allowable llourn 

orOpcralloo 

(lirs/yr) 

8760 

8760 

8760 

8760 

Mailmun Allowable 

Pollutant Kmissiona 

Ibi/hr 

OOM 

0.006 

0.006 

0.006 

tois/yr 

0.Q6I 

0.026 

0.D26 

0.026 

ro 

Name ol Bmillion Source 

and Identification Number 

Thermal Oxidizer 

Conlrol Device 

Thennal Oxidizer 

Control Device 

Thermal Oxidizer 

Conuol Device 

Thennal Oxidizer 

Centro! Device 

Name of 

Pollultol 

Ernllted 

Paniculate 

Matter 

Sulfur 

DioocUe 

Caibon 

Monoxide 

Nitrogen 

Oxides 

Maximum 

Source 

Emission 

Rale (Ibrilir) 

0.15 

0.0062 

10.01 

2.47 

Emlirba 

Point 

Idcnll Ilea Man 

Number 

ST-1 

ST-1 

ST-1 

ST-i 

Control 

Device 

Idea lllk allon 

Number 

Not 

Applicable 

Not 

Applicable 

Not 

Applicable 

Not 

Applicable 

Control Device 

Deicrlptioa 

Nal 

Applicable 

Nal 

Applicable 

Ncl 

Applicable 

Not 

Applicable 

Efficiency 

of Control 

llcvice 

(Percent) 

Noi 

Applicable 

Noi 

Applicable 

Noi 

Applicable 

Not 

Applicable 

Maximum 

Allowable Hours 

of Operat kta 

(hexfyr) 

8760 

6760 

8760 

8760 

Maximum Allowable 

Pollutant Enttsitoni 

IbiAir 

0.1) 

0.0062 

10.01 

2.47 

toai/yr 

OJ657 

OJ0272 

43.13 

10.12 

a 

o 

© i 

Page S ot 6 

R13-2006 

Aker Plastics Company, Inc. 

© 
P.11 

1/21/97 15:55 ®304 558 1222 WV OAQ ANNEX IU1U 

CECIL H. UN06RWOOO 

GOVERNOR 

DIVISION OF ENVIRONMENTAL PROTECTION 

OFFICE OF AIR QUALITY 

JOHN H. JOHNSTON. CHIEF 

JOHN E. CAFFREY 

DIRECTOR 

PERMIT TO MODIFY A FIBERGLASS BATH UNIT MANUFACTURING FACILITY 

IN ACCORDANCE WITH THE WEST VtRGINIA AIR POLLUTION CONTROL LAW (W. Va. Coda §§22-S-1 ____}, AND 

REGULATIONS PROMULGATED THEREUNDER. THE FOLLOWING PERMITTEE IS AUTHORIZED TO CONSTRUCT, SUBJECT 

TO THE TERMS ANO CONDITIONS OF THIS PERMIT. THE SOURCE DESCRIBED BELOW. 

This permit supersedes and replaces-'Permit No. R13-844 dated June 4.1986. 

Name of Permittee: AKER PLASTICS COMPANY, INC. 

Permit No.: R13-2006 

Plant ID No.: 0030026 

Effective Date of Permit 

Name of Facility: 

Facility Mailing Address: 

Nearest City 

or Town: 

County: 

UTM Coordinates: 

Directions to 

Exact Location: 

Type of Facility 

or Modification: 

July 14,1997 

Aker Plastics Company. Inc. Martinsburg Division 

2011 Mid Atlantic Industrial Parkway 

Martinsburg. WV 25401 

Martinsburg, WV 

Berkeley 

Easting: 762.25 Northing: 4376.5 Zone: 18 

When traveling north on Route 11. turn left onto the mid 

Atlantic Industrial Parkway; Aker Plastics is located 

approximately one-half mile on the left at the top of the hill. 

Modification of a Fiberglass Bath Unit Manufacturing Facility 

AS A RESULT OF THE GRANTING OF THIS PERMIT. THE SOURCE IS SUBJECT TO 45CSR30. THE TTTLS V APPUCATION WILL 86 DUE WITHIN 

TWELVE OZ) MONTHS AFTER THE DATE OF THE COMMENCEMENT OF THE OPERATION OR ACTIVITr* (OR ACTIVITIES. AUTHORIZED 3Y THIS 

PERMIT. 

PLANNING & PERMITTING 

1558 Washington Street East, Charleston, WV 2S311 -2599 Phons: (304) 558-0885 Fax: (304) 558-1222 
— — P.12 

1/21/97 IS:55 ©30 4 558 1222 WV OAQ ANNEX -21011 

IN ACCORDANCE WITH THE PERMIT APPLICATION AND ITS AMENDMENTS, THIS 

PERMIT IS LIMITED AS FOLLOWS: 

A. SPECIFIC REQUIREMENTS 

1. This permit (R13-2006) supersedes and replaces Permit Number R13-844 which 

was approved on June 4,1986. The conditions and limitations ih Permit Number 

R13-844, shall remain in effect until the new volatile organic compound (VOC) 

control devices (rotary concentrators and thermal oxidizer) that are authorized 

by this permit (Number R13-2006) are operational (commissioning complete). 

The conditions and limitations of Permit Number R13-844, which shall remain in 

effect until the completion of commissioning of the new VOC control devices, 

shall include the following limitations on maximum raw material usage quantities: 

Polyester Gel Coat 1,255,380 Pounds per Year 

Polyester Resin 5,067,636 Pounds per Year 

Methyl Ethyl Ketone Peroxide 146,400 Pounds per Year 

Acetone 131,716 Pounds per Year 

2. Following the completion of commissioning of the new VOC control devices 

(rotary concentrators and thermal oxidizer), maximum emissions to the 

atmosphere from the manufacturing facility shall not exceed the hourly and 

annual limitations set forth in Attachment A of this permit. Other conditions 

described in Attachment A shall also be requirements of this permit. 

3. Total emissions of volatile organic compounds (VOCs) from the manufacturing 

facility shall not exceed 12.14 pounds per hour or 53.2 tons per year. 

4. Following the completion of commissioning of the new VOC control devices 

(rotary concentrators and thermal oxidizer), raw material usages in the 

manufacturing process shall not exceed the following quantities: 

Polyester Gel Coat 3,000,000 Pounds per Year 

Polyester Resin 12,000,000 Pounds per Year 

Methyl Ethyl Ketone Peroxide 300,000 Pounds per Year 

Acetone 60,000 Pounds per Year 

Unisolve Water-Based Solvent 100.000 Pounds per Year 

Gypsum (Calcium Sulfate) 18.000.000 Pounds per Year 

5. All Polyester Resin used at the facility shall be of the vapor suppressed type. 

6. The weight percent of volatile organic compounds in ail Polyester Gel Coat and 

Polyester Resin used in the manufacturing process shall not exceed 36%. 

R13-2006 

Aker Plastics Company, Inc. 

Page 2 of 9 
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1/21/97 15:56 ©304 553 1222 WV OAQ ANNEX (ffl012 

B. OTHER REQUIREMENTS © 

1. In accordance with 45CSR30 - "Requirements for Operating Permits", enclosed 

with this permit is a Certified Emissions Statement registration form. Please 

complete the Certified Emissions Statement and return it to the West Virginia 

Division of Environmental Protection, Office of Air Quality (OAQ), along with the 

appropriate fee, if any is due, within thirty (30) days. If you have already 

submitted a Certified Emissions Statement to the OAQ please disregard this 

requirement. 

2. Following the completion of commissioning of the new VOC contror devices 

(rotary concentrators and thermal oxidizer), manufacturing operations are to be 

suspended (shutdown) as expeditiously as possible whenever control device 

system outages or malfunctions occur in a way that permitted VOC emission 

limitations may be exceeded*. Manufacturing operations are not to be initiated 

(restarted) until such time as the VOC control device system is capable of 

reducing VOC emissions to quantities which are within permitted limitations. 

Outages of the thermal oxidizer for up to twenty-four (24) hours and anaccompanying delay In the regeneration schedule for the rotary concentrators 

are allowable if permitted VOC emissions will not be exceeded. Outages of two 

of the four rotary concentrators for regeneration and maintenance activities are 

also allowable if permitted VOC emissions will not be exceeded. 

3. Records of raw material receipts and usage for operations in the permitted 

process shall be retained by the permittee for a period of at least five (5) years 

and such records shall be made available to the Chief or his duly authorized 

• representative upon request. For all receipts of Polyester Gel Coat and 

Polyester Resin, information shall be recorded and retained which Identifies the 

manufacturer, the date of receipt, the quantity received (in pounds), the volatile 

organic compound (VOC) content by weight, and in the case of Polyester.Resin 

a confirmation that the resin contains vapor suppressants. For all receipts of 

methyl ethyl ketone peroxide, acetone, Lfnisolve water-based solvent, and 

gypsum, information shall be recorded and retained concerning the date of 

receipt and the quantity received (in pounds). Records concerning thermal 

oxidizer outages (the reason for the outage, the duration of the outage, and the 

status of each ofthe rotary concentrators during the outage) shall be maintained. 

4. The pertinent sections of 45CSR13 applicable to this facility include, but are not 

limited to, the following: 

§45-13-8.2 

The Chief may suspend or revoke a permit if, after six (6) months from the date 

of issuance, the holder of the permit cannot provide the Chief, at the Chiefs 

request, with written proof of a good faith effort that construction, modification, 

or relocation, if applicable, has commenced. Such proof shall be provided not 

later than thirty (30) days after the Chiefs request. If construction or modification 

R13-2006 

Aker Plastics Company, Inc. 

Page 3 of 9 
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11/21/9 7 15:58 ©30 4 558 1222 WV OAQ ANNEX 161013 

© 

of a stationary source is discontinued for a period of eighteen (18) months or 

longer, the Chief may suspend or revoke the permit. 

§45-13-8.3 

The Chief may suspend or revoke a permit if the plans and specifications upon 

which the approval was based or the conditions established in the permit are not 

adhered to. 

5. In accordance with the provisions of 45CSR6, there shall be no burning of any 

refuse for the purpose of volume reduction, elimination, or product recovery. 

Particulate emissions from the thermal oxidizer shall riot exceed the emission 

limitations that are described in Section 4.1 of 45CSR6. 

6. The permitted facility shall comply with all applicable requirements of 45CSR7 

and any more stringent requirements set forth under (A) above. The principle 

provisions of 45CSR7, applicable to the permitted facility, are: 

a. No person shall cause, suffer, allow or permit emission of smoke and/or 

particulate matter into the open air from any process source operation which 

is darker in shade or appearance than that designated as No. 1 Ringelmann 

or twenty (20) percent opacity, except as noted in (B)6.b. 

b. The provisions of subsection (B)6.a. shall not apply to smoke and/or 

particulate matter emitted from any process source operation which is less 

than No. 2 Ringelmann or forty (40) percent opacity for any period or periods 

aggregating no more than five (5) minutes In any sixty (60) minute period. 

c. No person shall cause, suffer, allow, or permit emissions of smoke and/or 

particulate matter into the open air from any storage structure associated with 

any manufacturing process. 

d. Any stack serving any process source operation or air pollution control 

equipment on any process source operation shall contain flow straightening 

devices or a vertical run of sufficient length to establish flow patterns 

consistent with acceptable stack sampling procedures. 

e. No person shall cause, suffer, allow, or permit any manufacturing process 

generating fugitive particulate matter to operate that is not equipped with a 

system to minimize the emissions of fugitive particulate matter. To minimize 

means that a particulate capture or suppression system shall be installed to 

ensure the lowest fugitive particulate emissions reasonably achievable. 

f. The owner or operator of a plant shall maintain dust control of the plant 

premises, and plant owned, leased or controlled access roads, by paving, 

application of asphalt, chemical dust suppressants or other suitable dust 

control measures. Good operating practices shall be implemented and when 

R13-2006 

Aker Plastics Company, Inc. 

Page 4 of 9 
,>-=, ... , P.15 

11/21/97 15:57 ©304 558 1222 WV UAU AHMtA nawx* 

© 

necessary dust suppressants shall be. applied in relation to stockpiling and 

general material handling to prevent dust generation and atmospheric 

entrainment. 

7. Performance determinations (a "stack test') shall be conducted within onehundred twenty (120) days following the completion of commissioning ofthe new 

volatile organic carbon (VOC) control devices (rotary concentrators and thermal 

oxidizer) to determine the pounds per hour of VOCs, particulate matter, carbon 

monoxide, and nitrogen oxides that are being discharged from Emission Point 

Number ST-1. This test shall be conducted, if feasible, during operation ofthe 

facility at maximum anticipated rates. 

8. For determinations concerning compliance with the emission rate limitations set 

forth under Specific Requirements A(2) and A(3) of this permit, the following test 

methods shall be utilized unless otherwise approved by the Chief: 

a. Particulate Matter 45CSR7A/TP-4 - "Compliance Test Procedures for 

Regulation 7 - To Prevent and Control Particulate Air Pollution from 

Manufacturing Process Operations". 

b. Sulfur Dioxide EPA Method 6C 

c. Carbon Monoxide EPA Method 10 

d. Nitrogen Oxides EPA Method 7E 

e. Volatile Organic 

Compounds EPA Method 25A 

9. The permittee shall assure that the product manufacturing building is under 

negative pressure anytime that manufacturing operations are underway or 

anytime that VOCs are being emitted. Within ninety (90) days following 

completion of commissioning of the new VOC control devices (rotary 

concentrators and thermal oxidizer) a test shall be conducted to establish that 

the quantity of air that is exhausted from the product manufacturing building is 

equivalent to at least 110% ofthe quantity of air that is supplied to the product 

manufacturing building. Additional tests may be required by the Chief in 

situations which may include but are not limited to identifiable changes in 

facilities design or indications that building pressure control or vapor capture 

efficiency have deteriorated. 

C. GENERAL REQUIREMENTS 

1. In accordance with 45CSR22 - "Air Quality Management Fee Program", the 

permittee shall not operate nor cause to operate the permitted facility or other 

R13-2006 

Aker Plastics Company, Inc. 

Page 5 of 9 
P.16 

Ll/21/97 15:57 ©304 558 1222 WV OAQ ANNEX . ©015 

associated facilities on the same or contiguous sites comprising the plant without 

first obtaining and having in current effect a Certificate to Operate. Such 

Certificate to Operate shall be renewed annually, shall be .maintained on the 

premises for which the Certificate has been issued, and shall be made 

immediately available for inspection by the Chief or his duly authorized 

representative. 

2. Approval of this permit does not relieve the permittee herein ofthe responsibility 

to apply for and obtain all other permits, licenses, and/or approvals from other 

agencies; i.e., local, state, and federal, which may have jurisdiction over the 

construction and/or operation ofthe source(s) and/or facility herein permitted. 

3. The permitted facility shall be constructed and operated in accordance with 

infonnation filed in Permit Application R13-2006 and any amendments thereto. 

The Chief may suspend orcevoke a permit if the plans and specifications upon 

which the approval was based are not adhered to. 

4. At such reasonable time(s) as the Chief may designate, the permittee shall, 

conduct or have conducted test(s) to determine compliance with the emission 

limitations established in the permit application and/or applicable regulations. 

Test(s) shall be conducted in such a manner as the Chief may specify or 

approve and shall be filed in a manner acceptable to the Chief. The Chief, or his 

duly authorized representative, may at his option witness or conduct such test. 

Should the Chief exercise his option to conduct such test(s), the operator shall 

provide all the necessary sampling connections and sampling ports to be located 

in such manner as the Chief may require, power for test equipment, and the 

required safety equipment such as scaffolding, railings, and ladders to comply 

with generally accepted good safety practices. For any tests to be conducted by 

the permittee, a test protocol shall be submitted to the OAQ by the permittee at 

least thirty (30) days prior to the test and shall be approved by the Chief. The 

Chief shall be notified at least fifteen (15) days in advance of the actual dates 

and times during which the test will be conducted. 

5. In the event the permittee should deem it necessary to suspend, for a period in 

excess of sixty (60) consecutive calendar days, the operations, either in whole 

or in part, authorized by this permit, the permittee shall notify the Chief, in 

writing, within two (2) calendar weeks of the passing of the sixtieth (60) day of 

the suspension period. 

6. The provisions of this permit are severable and should any provision(s) be 

declared by a court of competent jurisdiction to be invalid or unenforceable, ail 

other provisions shall remain in full force and effect. 

7. The permittee shall notify the Chief, in writing, within fifteen (15) calendar days 

ofthe commencement ofthe construction, modification, or relocation activities 

authorized under this permit. 

R13-2006 

Aker Plastics Company, Inc. 

Page 6 of 9 

© 
P.17 

1/21/97 15:58 ©304 558 1222 WV OAQ ANNEX Itf] 01 6 

8. 

@ 

The permittee shall notify the Chief, in writing, at least fifteen (15) calendar days 

prior to actual startup of the operations authorized under this permit. 

This permit is transferable in accordance with the requirements outlined In 

Section 8.1 of45CSR13. 

10. Violations of any of the conditions contained in this permit, or incorporated herein 

by reference, may subject the permittee to civil and/or criminal penalties for each 

violation and further action or remedies as provided by West Virginia Code 22-5-

6 and 22-5-7. 

11. On or before July 1st of each calendar year, the permittee herein shall prepare 

and submit an emission inventory for the previous calendar year, addressing the 

emissions from the facility and/or process(es) authorized herein, in accordance 

with the emission inventor/subrnittal requirements of the Office of Air Quality. 

7-/Y-9 7 

ISSUED BY: S 

J0KN H. JOHN§£0N; CHIEF " 

./WV DIVISION OF ENVIRONMENTAL PROTECTION 

OFFICE OF AIR QUALITY 

DATE SIGNED: / / / 

s^ 

R13-2006 

Aker Plastics Company, Inc. 

Page 7 of 9 
PERMIT NO.: R13-2006 (Continued) 

ATTACHMENT A 

Emfcslopg Stiromnry 

_________-— — 

Nunc of Praccia Eqaipraenl 

Source Vcalcd (o Co-ttvol 

Dtvlce wid EfulpmcM 

IdertlMcadaiiNun-bir 

Gel Caul Gun GG 1 

GclCralGunGGI 

Gel CO M Gun GG ) 

Gel Coal Gun GG 4 

Chopper Gun CG I 

Chopper Gun CG I 

Chopper Gun CG I 

Chopper Gun CG 4 

Chopper Gun CO i 

Chopper Gun CG 6 

Chopper O w CG I 

Chopper aim CG 8 

Nameol 

PoBulxcl 

Emitted 

V O O 

VOC* 

VOCs 

VOCi 

VOCi 

voc» 

voc* 

VOCi 

VOCs 

VOCi 

V O Q 

voc» 

Maximum 

Soirtc 

Ewhdoa 

Rale (Ita/lu) 

II. I 

18.1 

11.1 

18.1 

6.1 

6.1 

•S.l 

6.1 

6.1 

6.1 

6.1 

(-minion 

Point 

Idnililittllon 

Number 

SfTI 

ST-1 

ST-1 

ST-1 

ST-1 

ST-l 

ST-1 

ST-1 

ST-1 

ST-1 

ST-1 

6.1 \ ST-1 

Control 

Devke 

Minllftc ition 

Number 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

RTOI 

Conlrol Device 

Description 

Thermal Oxidizer 

Thcmi-I Oxidizer 

Thennal Oxidizer 

Thennal Oxidizer 

Thermal Oxidizer 

The-rmsl Oxidizer 

Thermal Oxidizer 

Tticimal Oxidizer 

Thermal Oxidizer 

Ihcrmil Oxidizer 

Thermit Oxidizer 

Thermal Oxidizer 

Edlcliaty 

ol Control 

Device 

(Pineal) 

90 

SO 

' ; 90 

90 

SO 

90 

90 

90 

90 . 

90 

90 

90 

Mailn-im 

Allowable lloun 

oropcxaiion 

(hrt/y«) 

8760 

8760 

$760 

1760 

8760 

8160 

8760 

6760 

3160 

1760 

8760 

Maximum Allowable 1 

Pollutant E-mluhuti 

Ibi/lir 

1.81 

1.11 

... 1 J t 

I.BI 

0.61 

0.61 

0.61 

0.61 

OJ6I 

0.61 

oust 

8760 j 0.61 

lom/yr 

7.91 

7.9J 

1.9> 

7.93 

7AT 

2.S1 

267 

2.61 

2.67 

2J87 

2J6T 

2AT 

CO 

- I 

en 

CJO 

0 

CJ 

o 

cn 

Ol 

OS 

• J 

1-4 

ro 

33 

< 

O 

> 

M 

Pago B of 9 

R13-2006 

Aker Plastics Company, Inc. 

© 
- I 

PERMIT NO.: R13-2006 (Continued) 

ATTACHMENT A (ConUnued) 

Emissions Summary (Continued) 

Name ol Prcccs* Equipment 

Source Veiiled m Coairol 

Device and Equipment 

McetlflcaUoa Number 

Trimming Saw* 

Reiiit Tank HTI 

R«inTankUT2 

Reiin Tank IITI 

Name ol 

Pollutant 

Bmilled 

Paniculate 

Matter 

VOCi 

VOCi 

VOCi 

Mailroun 

Source 

Eminioa 

B«le(lba/kr) 

12.9 

0.006 

0.006 

0.O06 

Embilan 

Polat 

Idenliniailoa 

Number 

ST-2 

STO 

ST-4 

ST-J 

Conlfttl 

Device 

ldcatif.calk>a 

Nambcr 

DCI 

N/A 

MIA 

N/A 

Control Devloe 

Pijczlplloii 

Cyclone Dust 

Collector 

WA 

WA 

N/A 

Efficiency 

of Control 

Device 

(Percent) 

99.89 

R'A 

N/A 

N>A 

Maxlmuui 

Allowable Haun 

of Opera tlaa 

(fcn/Jr) 

8160 

8160 

8760 

B760 

Maitmura Allowable 

Pollutant Craliilooi 

Itu/hr 

O.0I4 

0.006 

0.006 

0.006 

loni/yr 

0.061 

0.026 

0.016 

0.026 

Oi 

to 

0 

Ci 

o 

VI 

C-I 

OO 

i-o 

ro 

r j 

Nirne of Emission Source 

and Idcull-tcadc-a Number 

Tlieinul Oxidizer 

Control Device 

Thermal Oxidizer 

Control Di vice 

Thermal Oxidizer 

Control Device 

Tbcmul Oxidizer 

Control Device 

Name of 

PoUutant 

Emitted 

Particulate 

Matter 

Sulfur 

Dioxide 

CSubon 

. Monoxide 

Nitrogen 

Cwtdti 

Maximuiti 

Soarce 

Enlnioti 

Ratc(lbi/br) 

0.15 

0*1062 

10 01 

2.47 

Einiiilan 

Point 

Identification 

Number 

ST-1 

ST-1 

ST-1 

S M 

Conlrol 

Device 

Idcoliflcitloa 

Number 

Noc 

Applicable 

Not 

Applicable 

Not 

Appliciblc 

Not 

Applicable 

Control Device 

Description 

Noi 

Applicable 

Not 

Applicable 

Not 

Applicable 

Hoi 

Applicable 

CMcliacy 

ol Control 

Device 

(Pcrceot> 

Not 

Applicable 

Not 

Applicable 

Noi 

Applicable 

. Noi 

Applicable 

Maximum 

Allowable Uours 

of Opera lion 

Oin/yr) 

8760 

8760 

B760 

8760 

Maximum Allocable 

Pollulani Emiuloot 

tbl/tir 

0.1$ 

0.0062 

10.01 

2.47 

lonx/yr 

0.657 

0.0272 

45.85 

10.82 

o 

_D 

H 

Page 9 of 9 

R13-2006 

Akar Plastics Company, Inc. 

o 

»-» 

OS 

CX)