p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

80) 11-1-81 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:24 PM Sheet 80 of 114 
P.2 

HAROLD G. STROHMEYER 

6 3 0 MARKET STREET, POST OFFICE BOX 102 8 

STEUBENVILLE, OHIO 4395 2 

740-282-4 5 I 3 

FAX: 740-282-628 5 

June 3, 1998 

-n*tv « <S' 'f;';'"*, 

EPA AIR DOCKET 

Robert M. Jemison 

Contractor 

Pacific Environmental Services, Inc. 

Post Office Box 12077 

Research Triangle Park, NC 27709-2077 

RE: American Standard, Inc. Salem Plant file request 

Dear Mr. Jemison: 

I am in receipt of my copy of your letter to Dennis Bush Ohio EPA NEDO date May 21, 1998 regarding 

your infonnation request for specific records associated with MACT development for fiberglass 

reinforced plastics industry. In accordance widi your letter please find attached copies of the following 

permits: 

American Standard, Inc.'s Ohio EPA Permits to Install numbered 17-439, 17-1327, 17-1493. 

American Standard, Inc.'s Ohio EPA Permit to Operate emission unit R008. 

The requested stack emission test report for the performance ofthe Polyad System is not on file at this 

office. This report had been submitted to Ohio EPA Central Office for review and acceptance. A copy of 

this report may be obtained by contacting Pat Haines by telephoning 614-644-4838 and writing to him at 

the following address: Ohio EPA DAPC, Post Office Box 1049, Columbus, Ohio 43216-1049. 

If I can be of further assistance please contact me at your earliest convenience. 

Sincerely, 

Harold Strohmeyer 

Contracted Permit Reviewer 

cc: Dennis Bush, Ohio EPA NEDO, DAPC 
P.3 

of Ofilo Environmental Protection Agency 

RMIT TO OPERATE AN AIR CONTAMINANT SOURCE 

of Issuance j •? / C £ / j 4 Application No. i 7 j 5 o ? 0 C 11R C 0 a 

ive Date 0 9 / 0 Z / i A Permit Fee $ 0 0 0 

document constitutes issuance to: 

AMERICAN STAKOARO INC - SALf^ PLANT 

60 5 S -LLSlORTM 

SALr.M .3HIP *>4--v6C 

lermit to operate for: 

. A . 5A^UrL 5 SP2AY SYSTEM 

:PYi_I C DtPANT-idMT S^f-UY SYSTcM ».? 

ollowing terms and conditions are hereby expressly incorporated into this permit to operate: 

his permit to operate shall be effective until 0 9/01/9 7 

'ou will be contacted approximately six months prior to this date regarding the renewal of this permit. If you are not 

ontacted, please write to the appropriate Ohio EPA field office. 

'he above-described source is and shall remain in full compliance with all applicable State and federal laws and regilations and the terms and conditions of this permit. 

•rior to any modification of this source, as defined in rule 3745-31 -01 of the Ohio Administrative Code (OAC), a permit 

3 install must be granted by the Ohio EPA pursuant to OAC Chapter 3745-31. 

he Director of the Ohio EPA or an authorized representative may, subject to the safety requirements of the permit holder, 

nter upon the premises of this source at any time for purposes of making inspections, conducting tests, 

xamining records or reports pertaining to any emission of air contaminants, and determining compliance with any 

pplicable State and federal air pollution laws and regulations and the terms and conditions of this permit. 

v permit fee in the amount specified above must be remitted within 15 days from the issuance date of this permit. 

my transferee of this permit shall assume the responsibilities of the prior permit holder. The appropriate Ohio EPA 

eld office must be notified in writing of any transfer of this permit 

his source and any associated air pollution control system(s) shall be maintained regularly in accordance with good 

ngineering practices in order to minimize air contaminant emissions. Any malfunction of this source or any assoiated air pollution control system(s) shall be reported immediately to the appropriate Ohio EPA field office in accordnee with OAC rule 3745-15-06. Except as provided in that rule, any scheduled maintenance or malfunction necessiiting the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown of this 

ource. 

.ny unauthorized or emergency release of an air contaminant from this source which, due to the toxic or hazardous 

ature of the material, may pose a threat to public health, or otherwise endanger the safety or welfare of the public, 

hall be reported immediately to the appropriate Ohio EPA field office (during normal business hours) or to the Ohio 

EPA's Emergency Response Group (1-800-282-9378). (Additional reporting may be required pursuant to the federal 

lomprehensive Environmental Response, Compensation, and Liability Act.) 

he appropriate Ohio EPA field office is: 

NJRT M OHIO VALLhY A1 -V AUTHORITY 

314 ADAMS ST. 

3TEJ : :.:(•* V IL L 5 t CH 4 3 952 (614 ) la Z- Sl C a/ 3 .1 il ; 

] If this term and condition is checked, the permit holder is subject to the attached special terms and conditions. 

ENVIRONMENTAL PROTECTION AGENCY 

jJ&u^tfjJw<y>^ 

ar 

4 
P.4 

APPLICATION NUMBER: 1715090011 R008 

FACILITY NAME: American Standard Inc. - Salem Plant 

EQUIPMENT DESCRIPTION: A.A. Samuels Spray System 

COMPANY ID: Acrylic Spray System #2 

SPECIAL TERMS AND CONDITIONS 

1. Applicable State Regulation(s) 

The following rules of the Ohio Administrative Code establish the 

applicable emission limitations and/or control requirements for 

this source: 

OAC Rule 3745-31-05, and 21-07(G) and 17-07(A) 

(This condition in no way limits the applicability of other 

requirements of the Ohio Administrative Code to this source.) 

2. Allowable Emission Limitation(s) 

The emissions from this source shall, not exceed the following: 

In accordance with the provisions of OAC Rules 3745-21-07(G)(2) and 

3745-31-05, American Standard Salem shall employ a resin coating 

that contains one percent by weight of the styrene emission 

inhibitor agent to control the styrene release into the ambient air 

such that the discharge has been reduced by at least 85%, otherwise 

the volatile organic compounds emissions shall not exceed 8 lbs/hr. 

or 40 lbs./day. The annual actual emission of volatile organic 

compounds shall not exceed 7.3 tons per year. 

3. Record Keeping 

American Standard Inc. shall maintain monthly records which lists 

the following information for each surface coating employed in 

this source: 

(a) the company identification for each coating and cleanup 

material employed; 

(b) documentation on whether or not each coating and cleanup 

material is a photochemically reactive material (PRM); 

(c) the number of gallons of each coating and cleanup material 

employed; 

(d) the organic compound content of each coating and cleanup 

material, in pounds per gallon; 

(e) for each day during which a PRM is employed, the organic 

compound emission rate for each coating and cleanup 

material, in pounds per day; 

(f) for each day during which a PRM is employed, the total 

organic compound emission rate for all coatings and cleanup 

materials, in pounds per day; 

(g) for each day during which a PRM is employed, the total 

number of hours the coatings and cleanup materials were 

employed in the operation; and 

r 
P.5 

American Standard Inc. - Salem Plant 

- 1715090011 R008 

Page 2 

(h) Items f (pounds/day) divided by item g (total hours employed) 

to determine average pounds per hour for each day. 

(i) the total organic compound emission rate for all coatings and 

cleanup materials, in pounds per month. 

Note: The coating information required in (c) through (h) 

must be for the coatings as employed, including any 

thinning solvents added at the coating line. Also, 

the cleanup material information required in (c) through (h) 

is only for those cleanup materials that are determined to be 

PRMs.] 

I. Coating or Printing Lines Quarterly Reporting 

These monthly records, as well as any supporting coating or ink 

analyses and computations, shall be retained in the company's 

files for a period of not less than three years and shall be made 

available to the Director or any authorized representative of the 

Director for review during normal business hours. 

This facility shall submit quarterly reports to the Ohio EPA 

field office which summarize the following information for each 

coating or cleanup material employed in this source during the 

previous three calendar months: 

(a) the total organic compound emission rate for all coatings 

and cleanup materials employed during the reporting period; 

(b) an identification of each day during which the average 

hourly organic compound emission rate exceed 8 lbs/hr, and 

the actual average hourly organic compound emission rate for 

each such day; 

(c) an identification of each day during which the organic 

compound emission rate exceed 40 lbs/day, and the actual 

organic compound emission rate for each such day; and 

(d) a description of any corrective actions taken to address the 

exceedances identified in (b) and (c). 

The reports shall be submitted by February 15, May 15, August 

15, and November 15 of each year and shall cover the previous 

three calendar months (January through March, April through June, 

July through September and October through December). 

5. Visible Emission Standard 

(a) Except as otherwise specified in paragraphs (A)(1)(b), (A)(2) 

and (A)(3) of OAC Rule 3745-17-07, visible particulate 

emissions from system 1 stacks shall not exceed twenty 

percent opacity, as a six-minute average. 

(b) Except as otherwise specified in paragraphs (A)(2) and (A)(3) 

of OAC Rule 3745-17-07, visible particulate emissions from 

system 1 stacks may exceed twenty percent opacity, as a sixminute average, for not more than six consecutive minutes in 

t 
P.6 

American Standard Inc. - Salem Plant 

1715090011 R008 

Page 3 

any sixty minutes, but shall not exceed sixty percent 

opacity, as a six-minute average, at any time. 

6. Stack Test requirements for Volatile Organic Compound or Organic 

Compound Emissions 

Within 6 months prior to the expiration of this permit, this 

facility shall conduct, or have conducted, emission tests for this 

source in order to demonstrate compliance with the allowable VOC or 

OC emission limitation and/or emission control system performance 

requirements. The emission tests shall be conducted in accordance 

with the test methods and procedures specified in OAC rule 3745-21-

10. The test(s) shall be conducted under maximum production rates 

unless otherwise specified or approved by the Ohio EPA. 

Not later than 30 days prior to the proposed test date(s), this 

facility shall submit an "Intent to Test" notification. The 

"Intent to Test" notification shall describe in detail the proposed 

test methods and procedures, the source operating parameters, the 

time(s) and date(s) of the tests, and the person(s) who will be 

conducting the tests. Failure to submit such notification for 

review and approval prior to the tests may result in the Ohio EPA 

field office's refusal to accept the results of the emission tests. 

Personnel from the Ohio EPA field office shall be permitted to 

witness the tests, examine the testing equipment, and acquire data 

and information regarding the source operating parameters. 

A comprehensive written report on the results of the emission tests 

shall be submitted with 30 days following completion of the tests. 

PREPARED BY: Harold Strohmeyer 

DATE PREPARED: May 4, 1994 

5 
• * 

- . 

OhfeEFft 

Jtate Of Ohio Environmental Protection Agency 

>O.Box 1049. 361 East Broad St ..Columbus, Ohio 43216-1049 

.614)466-8565 

Re: Permit to Instal l 

Columbiana County 

November 5, 1986 

P.7 

• r • i • 

^ ^ 

lll~^5§ 

^jp^ 

Richard F. Celeste.Governor 

A. S. SALEM 17-439 

605 S. ELLSWORTH ST. CERTIFIED MAIL 

SALEM, OHIO 44460 

ATTN: 0. WILLIAM BENSON 

Dear Sir: 

Enclosed please find an Ohio EPA Permit to Install which will 

allow you to install the described source(s) in a manner indicated 

in the permit. Because this permit contains several conditions 

and restrictions I urge you to read it carefully. 

You are hereby notified that this action by the Director is final 

and may be appealed to the Ohio Environmental Board of Review 

pursuant to Chapter 3745.04 of the Ohio Revised Code. The appeal 

must be in writing and set forth the action complained of and the 

grounds upon which the appeal is based. It must be filed with the 

Environmental Board of Review within thirty (30) days after notice 

of the Director's action. A copy of the appeal must be served on 

the Director of the Ohio Environmental Protection Agency and the 

Environmental Law Division of the Office of the Attorney General 

within three (3) days of filing with the Board. An appeal may be 

filed with the Environmental Board of Review at the following 

address: 

Environmental Board of Review 

250 East Town Street, Room 101 

Columbus, Ohio 43215 

Very truly yours, 

//fe^xa-SO7. 7fy 

Thoma ?homas s G. Rigo, Manager 

Field Operations Section 

Division of Air Pollution Control 

TGR/gs 

c c : US EPA 

North Ohio Valley Air Authority G 
P.8 

OhfeEFfc 

State of Ohio Environmental Protection A 

Permit to Install 

Terms and Conditions 

Application No. 17-439 

APS Premise No. 1715090011 

Permit Fee: 

Name of Facility: A. S. SALEM 

Person to Contact: J. WILLIAM BENSON 

Address: 605 S ELLSWORTH ST 

SALEM, OHIO 44460 

Location of proposed source(s): 605 S ELLSWORTH ST v 

SALEM, OHIO 

Description of proposed source(s): MODIFICATION TO ACRYLIC SPRAY 

BOOTHS #1 & #2. 

Date of Issuance: 

Effective Date: 

NOVEMBER 5, 1986 

NOVEMBER 5, 1986 

The above named entity is hereby granted a permit to install for 

the above described source(s) pursuant to Chapter 3745-31 of the 

Ohio Administrative Code. Issuance of this permit does not 

constitute expressed or implied approval or agreement that, if 

constructed or modified in*accordance with the plans included in 

the application, the above described source(s) of environmental 

pollutants will operate in compliance with applicable State and 

Federal laws and regulations, and does not constitute expressed or 

implied assurance that if constructed or modified in accordance 

with those plans and specifications, the above described source(s) 

of pollutants will be granted the necessary permits to operate 

(air) or NPDES permits as applicable. 

This permit is granted subject to the conditions attached hereto. 

Ohi ronment 

Warren W. Ty^er 

EPA 3156 

Protection Agency 

<\ 
P.9 

A. S. SALEM 

APPLICATION NO 17-439 

PAGE 2 

NOVEMBER 5, 1986 

Substantial construction for installation must take place within 

eighteen months of the effective date of this permit. This 

deadline may be extended by up to twelve months, if application is 

made to the Director no less than sixty days before the expiration 

of this permit and the party shows good cause for any such 

extension. 

The Director of the Ohio Environmental Protection Agency, or his 

authorized representatives, may enter upon the premises of the 

above named applicant during construction and operation at any 

reasonable time for the purpose of making inspections, conducting 

tests, examining records or reports pertaining to the 

construction, modification or installation of the above described 

source of environmental pollutants. 

If the construction of the proposed source has already begun or 

has been completed prior to the date the Director of the Ohio 

Environmental Protection Agency approves the permit application 

and plans, the approval does not constitute expressed or implied 

assurance that the proposed facility has been constructed in 

accordance with the approved plans. The action of beginning 

and/or completing construction prior to obtaining the Director's 

approval constitutes a violation of OAC Rule 3745-31-02. 

Furthermore, issuance of the Permit to Install does not constitute 

an assurance that the proposed source will operate in compliance 

with all Ohio laws and regulations. Approval of the plans in any 

case is not to be construed as an approval of the facility as 

constructed and/or compneved. Moreover, issuance of the Permit to 

Install is not to be construed as a waiver of any rights that the 

Ohio Environmental Protection Agency (or other persons) may have 

against the applicant for starting construction prior to the •> 

effective date of the permit. Additional facilities shall be 

installed upon orders of the Ohio Environmental Protection Agency 

if the proposed facilities prove to be inadequate or cannot meet 

applicable standards. 

The specified permit fee must be remitted within 15 days of the 

effective date of this permit to install. 

This permit shall apply only to the source(s) shown on the 

application approved by the Ohio Environmental Protection Agency. 

The permit holder shall conduct, or have conducted, performance 

testing of the subject air contaminant source(s) in accordance 

with procedures approved by the Agency and shall submit a written 

report, signed by the source owner, or his authorized agent, 

describing the test procedures followed and the results of such 

tests. The Director or his representative shall be allowed to 

witness the tests, examine testing equipment and acquire, or cause 

acquisition and/or submission of, data and information necessary 

to provide adequate assurance that source operation, process 

operating parameters and other conditions, together with testing 

procedures, provide a valid representation and proper 
P.10 

A. S. SALEM 

APPLICATION NO 17-439 

PAGE 3 

NOVEMBER 5, 1986 

characterization of the source's emissions and/or control 

equipment performance. 

Such testing shall be planned, scheduled and implemented so as to 

provide for: 

(1) Prior written notification to the Ohio Environmental 

Protection Agency, through the appropriate District 

Office or Local Air Pollution Control Agency where the 

original application was filed. Such notification shall 

be made thirty (30) days in advance and shall specify 

the source operating parameters, the proposed test 

procedures and the time, date, place and person(s) 

conducting such tests. 

(2) Submittal of the test results report within thirty (30) 

days after the test completion. 

NOTE: Test conducted on 6.27/86 

This permit to install is applicable only to the air contaminant 

sources listed below and does not include the installation of 

wastewater disposal systems or solid waste disposal facilities. 

Separate application must be made to the Director for the 

installation of any such sources. 

The air contaminant sources listed below comprise the Permit to 

Install for the A-S Salem, Inc. Plant, located in Columbiana 

County. Emissions from the sources shall not exceed the limits 

specified below: 

OEPA Annual 

Source Source and BAT Applicable Emissions 

No. Identification Determination OAC Rule (T/YR) 

R007 Acrylic Spray Inhibited 3745-21-07 7.3 

Booth #1 Styrene Monomer (G) 

Low Styrene 3745-31-05 

Emission Agent 

R008 Acrylic Spray Same as above 3745-21-07 7.3 

Booth #2 (G) 

SUMMARY 

TOTAL NEW SOURCE EMISSIONS 

Pollutant Tons/Year 

Volatile Organic Compounds 14.6 

As specified in OAC 3745-31-05, all new sources must at a minimum, 

employ Best Available Technology (BAT). The following terms and 

conditions fulfill these requirements and any applicable federal 

regulations. 
P.11 

A. S. SALEM 

APPLICATION NO 17-439 

PAGE 4 

NOVEMBER 5, 1986 

In accordance with the requirements of OAC Rules 3745-21-07(G)(2) 

and 3745-31-05, A-S Salem, Inc. shall employ a resin coating that 

contains sufficient concentrations of the low styrene emission 

agent to seal off the styrene release into the ambient air such 

that the emission rate shall not exceed 8 lb/hr or 40 lb/day, 

unless said discharge has been reduced by eighty-five percent 

(85%). In accordance with the requirements of OAC Rule 

3745-31-05(0, A-S Salem, Inc. shall respond to the following 

record keeping and reporting requirements. 

A-S Salem, Inc. shall maintain monthly records which list the 

following information. 

a. the company identification of the resin coating; 

b. the number of gallons employed; 

c. the VOC content, in pounds of VOC per gallon of resin; 

d. the low styrene emission agent content in percent based on 

resin weight; 

e. the non-volatile (solids) content, in percent by volume. 

These monthly records, as well as any supporting resin analysis 

and computations, shall be retained in the company's files for a 

period of not less than two years and shall be made available to 

the Director or any authorized representative of the Director for 

review during normal business hours. 

A-S Salem, Inc. shall submit semiannual reports to the Ohio EPA 

field office (NOVAA) which summarize the following information for 

each coating employed in this source during the previous six 

calendar months. 

a. company identification of the resin coating; 

b. the total number of gallons employed; 

c. the VOC content (in pounds VOC per gallon of coating, minus 

water); 

d. the non-volatile (solids) content; 

e. the quantity of low styrene emission agents used. 

The reports shall be submitted by February 1 and August 1 of each 

year and shall cover the previous six calendar months, July 

through September and January through June, respectively. 

A-S Salem, Inc. shall comply with any applicable state and federal 

requirements concerning the disposal of waste generated at this 

facility. 

/c 
P.12 

OrtoEFA 

Hate of Ohio Environmental Protection Agency 

J

.O. Box 163669.1800 WaterMark Dr. 

Columbus, Ohio 43216-3669 

614)644-3020 

rAX (614) 644-2329 

NereuBewVaEfoHio^962 

George V. Voinovich 

Governor 

Re: Permit to Install 

Columbiana County 

Application No: 17-1327 

TOXIC REVIEW 

December 29, 1994 

AMERICAN STANDARD, INC. -

JAMES WILGUS, JR. 

605 S. ELLSWORTH AVE. 

SALEM, OH 44460 

CERTIFIED MAIL 

Enclosed please find an Ohio EPA Permit to Install which will allow 

you to install the described source(s) in a manner indicated in the 

permit. Because this permit contains several conditions and 

restrictions I urge you to read it carefully. 

The Ohio EPA is urging companies to investigate pollution prevention 

and energy conservation. Not only will this reduce pollution and 

energy'consumption, but it can also save you money. If you would 

like to learn ways you can save money while protecting the environment, 

please contact our Office of Pollution Prevention at (614) 644-3469. 

You are hereby notified that this action by the Director is final and 

may be appealed to the Ohio Environmental Board of Review pursuant to 

Chapter 3745.04 of the Ohio Revised Code. The appeal must be in 

writing and set forth the action complained of and the grounds upon 

which the appeal is based. It must be filed with the Environmental 

Board of Review within thirty (30) days after notice of the Director's 

action. A copy of the appeal must be served on the Director of the 

Ohio Environmental Protection Agency within three (3) days of filing 

with the Board. An appeal may be filed with the Environmental Board of 

Review at the following address: 

Environmental Board of Review 

236 East Town Street, Room 300 

Columbus, Ohio 43215 

Very truly yours, 

/^w^us?. /K* 

Thomas G. Rigo, Manager 

Field Operations & Permit Section 

Division of Air Pollution Control 

cc: US EPA 

NORTH OHIO VALLEY AIR AUTHORITY 

,OK3 Printed on recycled paper 

EPA 1613 (rev. 5/94) 

ll 
P.13 

ONoEFft State of Ohio Environmental Protection Age 

Permit to Install 

Terms and Conditions 

Application No. 17-1327 

APS Premise No. 1715090011 

Permit Fee: $200.00 

Name of Facility: AMERICAN STANDARD, INC. 

Person to Contact: JAMES WILGUS, JR. 

Address: 605 S. ELLSWORTH AVE. 

SALEM, OH 44460 

Location of proposed source(s): 605 S. ELLSWORTH AVE. 

SALEM, OHIO 

Description of proposed source(s): 

IDEALCAST MOLD MAKING BOOTH. 

Date of Issuance: December 29, 1994 

Effective Date: December 29, 1994 

The above named entity is hereby granted a permit to install for the 

above described source(s) pursuant to Chapter 3745-31 of the Ohio 

Administrative Code. Issuance of this permit does not constitute 

expressed or implied approval or agreement that, if constructed or 

modified in accordance with the plans included in the application, tt 

above described source(s) of environmental pollutants will operate ir 

compliance with applicable State and Federal laws and regulations, ai 

does not constitute expressed or implied assurance that if construct* 

or modified in accordance with those plans and specifications, the 

above described source(s) of pollutants will be granted the necessary 

permits to operate (air) or NPDES permits as applicable. 

This permit is granted subject to the conditions attached hereto. 

Ohio Environmental Protection Agency 

a 
P.M 

AMERICAN STANDARD, INC. 

Application No. 17-1327 

Page 2 of 6 

December 29, 1994 

TERMINATION OF PERMIT TO INSTALL 

Substantial construction for installation must take place within 

18 months of the effective date of this permit. This deadline may 

be extended by up to 12 months if application is made to the 

Director within a reasonable time before the termination date and 

the party shows good cause for any such extension. 

NOTICE OF INSPECTION ' 

The Director of the Ohio Environmental Protection Agency, or his 

authorized representatives, may enter upon the premises of the 

above-named applicant during construction and operation at any 

reasonable time for the purpose of making inspections, conducting 

tests, or to examine records or reports pertaining to the 

construction, modification or installation of the source(s) of 

environmental pollutants identified within this permit. 

CONSTRUCTION OF NEW SOURCES(S) 

The proposed source(s) shall be constructed in strict accordance 

with the plans and application submitted for this permit to the 

Director of the Ohio Environmental Protection Agency. There may 

be no deviation from the approved plans without the express, 

written approval of the Agency. Any deviations from the approved 

plans or the above conditions may lead to such sanctions and 

penalties as provided under Ohio law. Approval of these plans does 

not constitute an assurance that the proposed facilities will 

operate in compliance with all Ohio laws and regulations. 

Additional facilities shall be installed upon orders of the Ohio 

Environmental Protection Agency if the proposed sources are 

inadequate or cannot meet applicable standards. 

If the construction of the proposed source(s) has already begun or 

has been completed prior to the date the Director of the 

Environmental Protection Agency approves the permit application and 

plans, the approval does not constitute expressed or implied 

assurance that the proposed facility has been constructed in 

accordance with the approved plans. The action of beginning and/or 

completing construction prior to obtaining the Director's approval 

constitutes a violation of Ohio Administrative Code (OAC) Rule 

3745-31-02. Furthermore, issuance of the Permit to Install does not 

constitute an assurance that the proposed source will operate in 

compliance with all Ohio laws and regulations. Approval of the 

plans in any case is not to be construed as an approval of the 

facility as constructed and/or completed. Moreover, issuance of the 

Permit to Install is not to be construed as a waiver of any rights 

that the Ohio Environmental Protection Agency (or other persons) 

may have against the applicant for starting construction prior to 

^ 
P.15 

AMERICAN STANDARD, INC. 

Application No. 17-1327 

Page 3 of 6 

December 29, 1994 

the effective date of the permit. Additional facilities shall be 

installed upon orders of the Ohio Environmental Protection Agency 

if the proposed facilities prove to be inadequate or cannot meet 

applicable standards. 

PERMIT TO TWRTAT.T. PEE 

In accordance with Ohio Revised Code 3745.11, the specified Permit 

to Install fee must be remitted within 15 days of the effective 

date of this permit to install. 

PUBLIC DISCLOSURE 

The facility is hereby notified that this permit, and all agency 

records concerning the operation of this permitted source, are 

subject to public disclosure in accordance with OAC Rule 3745-49-

03. 

APPLICABILITY 

This Permit to Install is applicable only to the contaminant 

sources identified. Separate application must be made to the 

Director for the installation or modification of any other 

contaminant sources. 

BEST AVAILABLE TECHNOLOGY 

As specified in OAC Rule 3745-31-05, all new sources must employ 

Best Available Technology (BAT). Compliance with the terms and 

conditions of this permit will fulfill this requirement. 

PERMIT TO OPERATE APPLICATION 

A Permit to Operate application must be submitted to the 

appropriate field office for each air contaminant source in this 

Permit to Install. In accordance with OAC Rule 3745-35-02, the 

application shall be made at least 90 days prior to start-up of the 

source. 

NINETY DAY OPERATING PERIOD 

The facility will be permitted to operate during a 90-day period 

in accordance with OAC Rule 3745-35-02(C)(4) (b). The purpose of 

this period bf operation is to fulfill the performance tests 

conditions used in the determination of compliance with the 

provisions of this Permit to Install or other applicable Ohio EPA 

rules. 

W 
P.16 

AMERICAN STANDARD, INC. 

Application No. 17-1327 

Page 4 of 6 

December 29, 1994 

SOURCE OPERATION AFTER COMPLETION OF CONSTRUCTION 

This facility is permitted to operate each source described by this 

permit to install for a period of up to one year from the date the 

source commenced operation. This permission to operate is granted 

only if the facility complies with all requirements contained in 

this permit and all applicable air.pollution laws, regulations, and 

policies. 

AIR EMISSION SUMMARY 

The air contaminant sources listed below comprise the Permit to 

Install for AMERICAN STANDARD, INC. located in Columbiana County. 

The sources listed below shall not exceed the emission 

limits/control requirements contained in the table. This condition 

in no way limits the applicability of any other state or federal 

regulations. Additionally, this condition does not limit the 

applicability of additional special terms and conditions of this 

permit. 

n o 

PA 

Duree 

amber 

D18 

Source 

Identification 

Description 

Ideal Cast 

Mold Making 

Booth 

BAT 

Determination 

Coating Formulation; recordkeeping, reporting; baffles w/fabric 

filter 

Applicable 

Federal & 

OAC Rules 

Pennit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

3745-31-05 

3745-15-06 

3745-15-07 

3745-21-07(G) VOC: 

0.74 ton/yr. 

PM: 

Styrene: 5.3 lbs/hr, 

40 lbs/day, 

2 tons/yr. 

3.0 lbs/hr, 

1.0 lbs/hr, 

0.40 ton/yr. 

SUMMARY 

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS 

Pollutant Tons/Year 

Styrene 

VOC 

PM 

2.0 

0.74 

0.40 

REPORTING REQUIREMENTS 

Unless otherwise specified, reports required by the Permit to 

Install need only be submitted to North Ohio Valley Air Authority, 

814 Adams, Steubenville, Ohio 43952. 

I. 
P.17 

AMERICAN STANDARD, INC. 

Application No. 17-1327 

Page 5 of 6 

December 29, 1994 

WASTE DISPOSAL 

The owner/operator shall comply with any applicable state and 

federal requirements governing the storage, treatment, transport 

and disposal of any waste material generated by the operation of 

the sources. 

MAINTENANCE OF EQUIPMENT 

This source and its associated air pollution control system(s) 

shall be maintained regularly in accordance with good engineering 

practices and the recommendations of the respective manufacturers 

in order to minimize air contaminant emissions. 

MALFUNCTION/ABATEMENT 

In accordance with OAC RULE 3745-15-06, any malfunction of the 

source(s) or associated air pollution control system(s) shall be 

reported immediately to the North Ohio Valley Air Authority, 814 

Adams, Steubenville, Ohio 43952. 

Except as provided by OAC Rule 3745-15-06(A)(3), scheduled 

maintenance of air pollution control equipment that requires the 

shutdown or bypassing of air pollution control system(s) must be 

accompanied by the shutdown of the associated air pollution 

sources. 

AIR POLLUTION NUISANCES PROHIBITED 

The air contaminant source(s) identified in this permit may not 

cause a public nuisance in violation of OAC Rule 3745-15-07. 

CONSTRUCTION COMPLIANCE CERTIFICATION 

The applicant shall provide Ohio EPA with a written certification 

(see enclosed form) that the facility has been constructed in 

accordance with the Permit to Install application and the terms and 

conditions of the Permit to Install. The certification shall be 

provided to Ohio EPA upon completion of construction but prior to 

startup of the source. 

ADDITIONAL SPECIAL TERMS AND CONDITIONS R018: 

Recordkeeping Requirements 

This facility shall maintain hourly and daily records (by 

using the attached Paint Usage Recording Form or comparable 

form approved by the Ohio EPA) which list the following 

information for each surface coating or ink employed in this 

source: 

% 
P.18 

AMERICAN STANDARD, INC. 

Application No. 17-1327 

Page 6 of 6 

December 29, 1994 

1. the company identification of the surface coating; 

2. the number of gallons employed per hour and per day; 

3. the Volatile Organic Compound (VOC) content in pounds of 

VOC per gallon of coating, as employed; 

4. the pounds of VOC sprayed per hour and per day; 

5. the number of gallons of clean-up solvent used per hour 

and per day; and 

6. prior approval shall be obtained from Ohio EPA before 

employing any other coating or clean-up solvent in this 

source. 

These daily records, as well as any supporting coating 

analyses and computations, shall be retained in the company's 

files for a period of not less than three years and shall be 

made available to the Director or any authorized 

representative of the Director for review during normal 

business hours. 

Reportinq Requirements 

This facility shall submit quarterly reports to the Ohio EPA 

field office which identify each day during which the 5.3 lbs 

VOC/hr limitation and/or the 40 lbs VOC/day limitation was 

(were) exceeded. 

The reports shall be submitted by February 15, May 15, August 

15, and November 15-of each year and shall cover the previous 

three calendar months (October through December, January 

through March, April through June, and July through September, 

respectively). 

If no exceedances of the lb VOC/hr or lb VOC/day limits 

occurred during the reporting period, then a report is 

required stating so. 

n 
P.19 

PAINT SPRAY BOOTH RECORDING FORM 

COMP* 

DATE: 

LNY NAME: 

JCOLUMN (A) [COLUMN (B) jCOL (A) X COL (B) 

Clean-Uo ID !GALLONS !VOC CONTENT*!LBS VOC 

|TIME COATING ID !SPRAYED !LBS/GALLON !SPRAYED** 

| 1 2 ! 

! i 5 

! i : 

! 2 : 

! 2 : 

! 3 : 

| 3' : 

! 4 : 

!

 4 : 

! 5 : 

i 5 : 

! 6 : 

1

 6 : 

i 7 : 

!

 7 : 

! 8 ' 

! & -

!

 9 : 

! 9 ; 

jlO : 

}10 

in 

j 12 {12 

| 1 

| I 

!

 2 

! 2 

! 3 ' 

!

 3 

! * 

! * 

! s i 5 

! 6 

!

 6 

i 7 

! 7 

!

 8 

! s 

| 9 

i 9 

|10 

|10 

'11 

i l l 

112 

00am- j | | | 

00am- { II I 

00am- } •*• | j ! 

00am- | } I t 

00am- J IS ! 

00am- | j I I 

00am- | | j j 

00am- J II I 

00am- J S ' 1 ! 

00am- j II I 

00am- j | j | 

00am- } II I 

00am- | II I 

00am- | | | | 

:00am- | j j j 

•00am- | } } | 

00am- | | j | 

00am- | J I' l 

:00am- j 1 j 1 

:00am- } I I 1 

:00ara- j IS ! 

:00am- j II ! 

:00am- } j j j 

:00am- J | | ! 

:00pm- | SI' S 

:00pm- } J I ! 

:00pra- | S j S 

:00pm- } j J j 

:00pm- | II I 1 

:00pm- | | } | • j 

:00pm- S i S i i 

:00pm- j II I 1 

:00pm- j j S i \ 

:00pm- | { | | • j 

:00pm- j . S i 1 j 

:00pm- | II I 1 

:00pm- j ll i I 

:00pm- | II I 1 

:00pm- j j j i | 

:00pm- j il l I 

:00pm- J J i i j 

:00pm- ! I j j | 

:00pm- | | j J ] 

:00pm- | | | j " | 

:00pm- j { j J | 

:00pm- '!| | | 

:00pm- j ii i | 

:00pm- I ' | | | 

|TOTAL DAILY j j 

[EMISSIONS***! 1 

* VOC stands for Volatile Organic Compound 

** If this value exceeds 5.3 lbs/hr then report this to the Ohio EPA. 

*** If this value exceeds 40 lbs/day then report this to the Ohio EPA. 

ft .. 
P.20 

OhteEPtX 

State of Ohio Environmental Protection Agency 

HEETAOOBESS: MAOJNOAOORESS: 

300 Water-Mark Drive 

olumbus, OH 43215-1099 TELE: (614) 644-3020 FAX: (614) 644-2329 

P.O. Box 1049 

Columbus. OH 43216-1049 

Re: Permit to Install 

Columbiana County 

Application No: 17-1493 

SYNTHETIC MINOR 

October 30, 1996 

AMERICAN STANDARD, INC. 

JAMES WILGUS 

605 SOUTH ELLSWORTH AVENUE 

SALEM, OH 44460 

CERTIFIED MAIL 

HOV 0 4 1996 

NOVAA 

STEUBENViU.E.OHIO 4&wS2 

Enclosed please find an Ohio EPA Permit to Install which will allow 

you to install the described source(s) in a manner indicated in the 

permit. Because this permit contains several conditions and 

restrictions I urge you to read it carefully. 

The Ohio EPA is urging companies to investigate pollution prevention 

and energy conservation. Not only will this reduce pollution and 

energy consumption, but it can also save you money. If you would 

like to learn ways you can save money while protecting the environment, 

please contact our Office of Pollution Prevention at (614) 644-3469. 

You are hereby notified that this action by the Director is final and 

may be appealed to the Ohio Environmental Board of Review pursuant to 

Chapter 3745.04 of the Ohio Revised Code. The appeal must be in 

writing and set forth the action complained of and the grounds upon 

which the appeal is based. It must be filed with the Environmental 

Board of Review within thirty (30) days after notice of the Director's 

action. A copy of the appeal must be served on the Director of the 

Ohio Environmental Protection Agency within three (3) days of filing 

with the Board. An appeal may be filed with the Environmental Board of 

Review at the following address: 

Environmental Board of Review 

236 East Town Street, Room 300 

Columbus, Ohio 43215 

Very truly yours, 

/y^ra«^du 7C7. /£& 

Thomas G. Rigo, Manager 

Field Operations & Permit Section 

Division of Air Pollution Control 

cc: US EPA 

NORTH OHIO VALLEY AIR AUTHORITY 

A 1613 (rev. 5/96) 

Primed on Recycled Pacer 

!

 ' i 

George V. Voinovich, Governor / ] 

Nancy P. Hollister, Lt. Governor 

Donald R. Schregardus, Director 
P.21 

ONeEFft State of Ohio Environmental Protection Ager 

Permit to Install 

Terms and Conditions 

Application No. 17-1493 

APS Premise No. 1715090011. 

Permit Fee: $1800.00 

Name of Facility: AMERICAN STANDARD, INC. 

Person to Contact: JAMES WILGUS 

Address: 605 SOUTH ELLSWORTH AVENUE 

SALEM, OH 44460 

Location of proposed source(s): 605 SOUTH ELLSWORTH AVENUE 

SALEM, OHIO 

Description of proposed source(s): 

BATH TUB COVER COAT SPRAY BOOTH, STAN-SURE SPRAY BOOTH, SPRA 

Y-UP FIBERGLASS CURE OVEN AND IDEAL CAST NAUTA MIXER. 

Date of Issuance: October 30, 1996 

Effective Date: October 30, 1996 

The above named entity is hereby granted a permit to install for the 

above described source(s) pursuant to Chapter 3745-31 of the Ohio 

Administrative Code. Issuance of this permit does not constitute 

expressed or implied approval or agreement that, if constructed or 

modified in accordance with the plans included in the application, t] 

above described source(s) of environmental pollutants will operate i] 

compliance with applicable State and Federal laws and regulations, ai 

does not constitute expressed or implied assurance that if construct 

or modified in accordance with those plans and specifications, the 

above described source(s) of pollutants will be granted the necessar 

permits to operate (air) or NPDES permits as applicable. 

This permit is granted subject to the conditions attached hereto. 

Ohio Environmental Protection Agency 

TL^^/i^f^-

Director 

-UV .0 
P.22 

AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 2 of 11 

October 30, 1996 

TERMINATION OF PERMIT TO INSTALL 

Substantial construction for installation must take place within 

18 months of the effective date of this permit. This deadline may 

be extended by up to 12 months if application is made to the 

Director within a reasonable time before the termination date and 

the party shows good cause for any such extension. 

NOTICE OF INSPECTION 

The Director of the Ohio Environmental Protection Agency, or his 

authorized representatives, may enter upon the premises of the 

above-named applicant during construction and operation at any 

reasonable time for the purpose of making inspections, conducting 

tests, or to examine records or reports pertaining to the 

construction, modification or installation of the source(s) of 

environmental pollutants identified within this permit. 

CONSTRUCTION OF NEW SOURCES 

The proposed source(s) shall be constructed in strict accordance 

with the plans and application submitted for this permit to the 

Director of the Ohio Environmental Protection Agency. There may 

be no deviation from the approved plans without the express, 

written approval of the Agency. Any deviations from the approved 

plans or the above conditions may lead to such sanctions and 

penalties as provided under Ohio law. Approval of these plans does 

not constitute an assurance that the proposed facilities will 

operate in compliance with all Ohio laws and regulations. 

Additional facilities shall be installed upon orders of the Ohio 

Environmental Protection Agency if the proposed sources are 

inadequate or cannot meet applicable standards. 

If the construction of the proposed source(s) has already begun or 

has been completed prior to the date the Director of the 

Environmental Protection Agency approves the permit application 

and plans, the approval does not constitute expressed or implied 

assurance that the proposed facility has been constructed in 

accordance with the approved plans. The action of beginning and/or 

completing construction prior to obtaining the Director's approval 

constitutes a violation of Ohio Administrative Code (OAC) Rule 

3745-31-02. Furthermore, issuance of the Permit to Install does not 

constitute an assurance that the proposed source will operate in 

compliance with all Ohio laws and regulations. Approval of the 

plans in any case is not to be construed as an approval of the 

facility as constructed and/or completed. Moreover, issuance of the 

Permit to Install is not to be construed as a waiver of any rights 

that the Ohio Environmental Protection Agency (or other persons) 
P.23 

AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 3 of 11 

October 30, 1996 

may have against the applicant for starting construction prior to 

the effective date of the permit. Additional facilities shall be 

installed upon orders of the Ohio Environmental Protection Agency 

if the proposed facilities prove to be inadequate or cannot meet 

applicable standards. 

PERMIT TO INSTALL FEE 

In accordance with Ohio Revised Code 3745.11, the specified Permit 

to Install fee must be remitted within 30 days of the effective 

date of this permit to install. 

PUBLIC DISCLOSURE 

The facility is hereby notified that this permit, and all agency 

records concerning the operation of this permitted source, are 

subject to public disclosure in accordance with OAC Rule 3745-49-

03. 

APPLICABILITY 

This Permit to Install is applicable only to the contaminant 

sources identified. Separate application must be made to the 

Director for the installation or modification of any other 

contaminant sources. 

BEST AVAILABLE TECHNOLOGY 

As specified in OAC Rule 3745-31-05, all new sources must employ 

Best Available Technology (BAT) . Compliance with the terms and 

conditions of this permit will fulfill this requirement. 

PERMIT TO OPERATE APPLICATION 

A Permit to Operate application must be submitted to the 

appropriate field office for each air contaminant source in this 

Permit to Install. In accordance with OAC Rule 3745-35-02, the 

application shall be filed no later than thirty days after 

commencement of operation. 

SOURCE OPERATION AFTER COMPLETION OF CONSTRUCTION 

This facility is permitted to operate each source described by this 

permit to install for a period of up to one year from the date the 

source commenced operation. This permission to operate is granted 

only if the facility complies with all requirements contained in 

this permit and all applicable air pollution laws, regulations, and 

policies. 
P.24 

AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 4 of 11 

October 30, 1996 

AIR EMISSION SUMMARY 

The air contaminant sources listed below comprise the Permit to 

Install for AMERICAN STANDARD, INC. located in Columbiana County. 

The sources listed below shall not exceed the emission 

limits/control requirements contained in the table. This condition 

in no way limits the applicability of any other state or federal 

regulations. Additionally, this condition does not limit the 

applicability of additional special terms and conditions of this 

permit. 

lio 

?A 

jurce 

unber 

)20 

)21 

)08 

(09 

Source 

Identification 

Description 

Bath tub cover 

spray booth 

-porcelain 

enamel 

Bath tub line 

Stan-sure spray 

booth-porcelain 

enamel 

Spray-up 

fiberglass 

cure-oven 

Ideal cast 

Nauta mixer 

BAT 

Determination 

Fabric filter 

*(TLCC DC) 

water based 

coating. 99% 

design 

efficiency 

Fabric filter 

*(TLCC DC) 

water based 

coating. 99% 

design 

efficiency 

Concentrator 

with incineration average 

design efficiency is 95%, 

95,000 units/ 

year 

Concentrator 

with incineration average 

design efficiency is 95%, 

fabric filter 

99% design 

efficiency90,000 units/yr 

Applicable 

Federal & 

OAC Rules 

3745-31-05 

3745-17-07 

(A) 

3745-17-11 

3745-15-06 

3745-15-07 

3745-31-05 

3745-17-07 

(A) 

3745-17-11 

3745-15-06 

3745-15-07 

3745-31-05 

3745-21-07 

(G) (2) 

3745-15-06 

3745-15-07 

3745-31-05 

3745-15-06 

3745-15-07 

3745-17-11 

3745-17-07 

(A) 

3745-21-07 

(G)(20 

*TLCC DC = Tubline Cover Coat Dust Collecto 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

PM - 1.43 lbs/hr 

and 6.6 tons/yr 

PM = 0.1 lb/hr 

and 0.44 ton/yr 

Styrene = 0.58 lb/ 

hr and 0.93 ton/yr 

Styrene =0.14 lb/ 

hr and 0.16 ton/yr 

PM = 0.15 lb/hr and 

0.45 ton/yr 

?3 
P.25 

AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 5 of 11 

October 30, 1996 

SUMMARY 

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS 

Pollutant Tons/Year 

PM 7.49 

Styrene 0.99 

PERFORMANCE TEST REQUIREMENTS 

The permittee shall conduct, or have conducted, performance testing 

on the air contaminant source(s) in accordance with procedures 

approved by the Agency. Two copies of the written report describing 

the test procedures followed and the results of such tests shall 

be submitted and signed by the person responsible for the test. 

The Director, or an Ohio EPA representative, shall be allowed to 

witness the test, examine testing equipment, and require the 

acquisition or submission of data and information necessary to 

assure that the source operation and testing procedures provide a 

valid characterization of the emissions from the source and/or the 

performance of the control equipment. 

A. A completed Intent to Test form shall be submitted to 

the appropriate Ohio EPA District Office or Local Air 

Pollution Control Agency where the original permit 

application was filed. This notice shall be made 30 

days in advance and shall specify the source operating 

parameters, the proposed test procedures, and the time, 

date, place and person(s) conducting such tests. 

B. Two copies of the test results shall be submitted within 

30 days after the completion of the performance test. 

C. Tests shall be performed for the following source (s) and 

pollutants(s): 

Source Pollutants 

R020, R021 PM 

P008, P009 Styrene 

WASTE DISPOSAL 

The owner/operator shall comply with any applicable state and 

federal requirements governing the storage, treatment, transport 

and disposal of any waste material generated by the operation of 

the sources. 

IA 
P.26 

AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 6 of 11 

October 30, 1996 

MAINTENANCE OF EQUIPMENT 

This source and its associated air pollution control system(s) 

shall be maintained regularly in accordance with good engineering 

practices and the recommendations of the respective manufacturers 

in order to minimize air contaminant emissions. 

MALFUNCTION /ABATEMENT 

In accordance with OAC RULE 3745-15-06, any malfunction of the 

source(s) or associated air pollution control system(s) shall be 

reported immediately to the North Ohio Valley Air Authority, 814 

Adams, Steubenville, Ohio 43952. 

Except as provided by OAC Rule 3745-15-06(A)(3) , scheduled 

maintenance of air pollution control equipment that requires the 

shutdown or bypassing of air pollution control system(s) must be 

accompanied by the shutdown of the associated air pollution 

sources. 

AIR POLLUTION NUISANCES PROHIBITED 

The air contaminant source (s) identified in this permit may not 

cause a public nuisance in violation of OAC Rule 3745-15-07. 

NINETY DAY OPERATING PERIOD 

The facility will be permitted to operate during a 90-day period 

in accordance with OAC Rule 3745-35-02(C)(4)(b). The purpose of 

this period of operation is to fulfill the performance tests 

conditions used in the determination of compliance with the 

provisions of this Permit to Install or other applicable Ohio EPA 

rules. 

CONSTRUCTION COMPLIANCE CERTIFICATION 

The applicant shall provide Ohio EPA with a written certification 

(see enclosed form) that the facility has been constructed in 

accordance with the Permit to Install application and the terms and 

conditions of the Permit to Install. The certification shall be 

provided to Ohio EPA upon completion of construction but prior to 

startup of the source. 

A" 7- •n 
P.27 

AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 7 of 11 

October 30, 1996 

ADDITIONAL SPECIAL TERMS AND CONDITIONS 

R020 and R021 

1. Operational requirements for a baghouse 

To ensure the baghouse is operated according to the 

manufacturer's specifications and to maintain compliance with 

the allowable particulate emission rate, a pressure drop 

across the baghouse of not less than 2.0 inches of water or 

greater than 6.0 inches of water shall be maintained at all 

times. 

2. Baghouse monitoring and recordkeeping requirements 

The permittee shall properly operate and maintain a monitoring 

device capable of accurately measuring the pressure drop 

across the fabric filter. 

The permittee shall visually inspect the after filters two 

times each month. 

The permittee shall lubricate bearings as needed up to one 

time each month. 

The permittee shall inspect the belts two times each month. 

The permittee shall check the pressure drop once a day and 

maintain daily records of the pressure drop readings and 

records of inspection and maintenance activities. 

3. Baghouse reporting requirements 

The permittee shall submit deviation (excursion) reports which 

identify all exceedances of the above-mentioned allowable 

pressure drop range. 

P008 

Emissions split for booth and oven 

For purposes of calculating the organic compound emission 

rates for this emissions unit and the associated spray booth 

(R008) , the permittee shall utilize a value of 47% as the 

maximum percentage of the organic compounds employed in the 

spray booth that are emitted uncontrolled from the spray 

booth. The remaining 53% of the organic compounds employed 

in the spray booth shall be considered to be uncontrolled 

emissions for this emissions unit. This split of organic 

compound emissions between this emissions unit and the 

associated spray booth is based upon information provided in 

the permit to install application for P008 and the FESOP 

application for R008. 

7JU 
P.28 

'AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 8 of 11 

October 30, 1996 

2. Record keeping requirements 

The permittee shall collect and record the following 

information each day for the oven: 

a. the total potential uncontrolled daily organic compound 

emission rate for all coatings employed in the coating 

operation associated with this emissions unit, multiplied 

by the maximum percentage of the emissions associated 

with this emissions unit (as defined in P008 condition 

#1 of this permit), in pounds per day; 

b. the total controlled organic compound emission rate for 

this emissions unit, in pounds per day (i.e., the value 

from (a) multiplied by the overall control efficiency 

from the most recent performance test that demonstrated 

that this emissions unit was in compliance); 

c. the total number of hours this emissions unit was in 

operation (this number should be the same as the number 

of hours the associated coating operation was in 

operation); and 

d. the total controlled, average hourly organic compound 

emission rate for this emissions unit, i.e., (b)/(c), in 

pounds per hour (average). 

3. . Reporting requirements 

The permittee shall submit deviation (excursion) reports which 

include the following information: 

a. an identification of each day during which the average 

controlled hourly organic compound emission rate exceeded 

0.58 pound per hour, and the actual average controlled 

hourly organic compound emission rate for each such day; 

and 

b. an identification of each day during which the controlled 

organic compound emission rate exceeded 13.92 pounds per 

day, and the actual controlled organic compound emission 

rate for each such day. 

4. Parametric Monitoring 

This facility shall maintain and operate the Polyad Unit such 

that the following parameters are not exceeded: 

a. minimum combustion chamber shall not be less than 550 

degrees fahrenheit; 

b. temperature at inlet to catalyst bed shall not exceed 550 

degrees fahrenheit; 
P.29 

AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 9 of 11 

October 30, 1996 

c. pressure differential across the desorber shall not 

exceed 5 inches water column; and 

d. air temperature at desorber exhaust shall not exceed 230 

degrees fahrenheit. 

Daily records shall be maintained of each parameter and all 

excursions and corrective actions shall be reported to the 

Ohio EPA representative on a calendar quarter basis by the 

fifteenth of the following month. 

5. Operating restrictions 

The sprayup fiberglass cure-oven (P008) shall be limited to 

a maximum of 95,000 units produced per rolling 365 day period. 

The facility shall maintain daily records indicating the 

amount of units produced and the calculated rolling 365 day 

total amount of units produced. In order to ensure federal 

enforceability, for the first twelve calendar months of 

operations, American Standard shall not exceed the following 

production limits for the specified time period: 

Month Total Allowable Production 

1 

1-2 

1-3 

1-4 

1-5 

1-6 

1-7 

1-8 

1-9 

1-10 

1-11 

1-12 

7 

15 

23 

31, 

39, 

47, 

55, 

63, 

71, 

79, 

87, 

95, 

917 

834 

751 

668 

585 

502 

419 

336 

253 

170 

087 

000 

P009 

Parametric Monitoring 

This facility shall maintain and operate the Polyad Unit such 

that the following parameters are not exceeded: 

a. minimum combustion chamber shall not be less than 550 

degrees fahrenheit; 

b. temperature at inlet to catalyst bed shall not exceed 550 

degrees fahrenheit; 

c. pressure differential across the desorber shall not 

exceed 5 inches water column; and 

d. air temperature at desorber exhaust shall not exceed 23 0 

degrees fahrenheit. 
P.30 

'AMERICAN STANDARD, INC 

Application No. 17-1493 

Page 10 of 11 

October 30, 1996 

Daily records shall be maintained of each parameter and all 

excursions and corrective actions shall be reported to the 

Ohio EPA representative on a calendar quarter basis by the 

fifteenth of the following month. 

2. Baghouse operational restrictions 

The pressure drop across the baghouse shall be maintained 

within the range of minimum pressure drop of 0.25 inches of 

water and a maximum pressure drop of 0.90 inches of water 

while the emissions unit is in operation. 

3. Baghouse pressure drop monitoring and recordkeeping 

requirements 

The permittee shall properly install, operate and maintain 

equipment to monitor the pressure drop across the baghouse 

while the emissions unit is in operation. The monitoring 

equipment shall be installed, calibrated, operated, and 

maintained in accordance with the manufacturer's 

recommendations, instructions, and operating manual(s). The 

permittee shall record the pressure drop across the baghouse 

on per operating shift basis. 

4. Baghouse pressure drop reporting requirements 

The permittee shall submit pressure drop deviation (excursion) 

reports that identify that all period of time during which the 

pressure drop across the baghouse did not comply with the 

allowable range specified above. These reports along with 

corrective actions shall be submitted to the Ohio EPA 

representative on a quarterly basis by the fifteenth of the 

following month. 

5. Operating restrictions 

The Ideal Cast Nauta Mixer (P009) shall be limited to a 

maximum of 90,000 production units per rolling 365 day period. 

The facility shall maintain records indicating the daily 

amount of production and the calculated rolling 365 day total 

amount of units produced. In order to ensure federal 

enforceability, for the first twelve calendar months of 

operation, American Standard shall not exceed the following 

production limits for the specified time period for the mixer: 

Month Total Allowable Production 

l 

1-2 

1-3 

1-4 

1-5 

1-6 

2-1 

7, 

15, 

22, 

30, 

37, 

45, 

500 

000 

500 

000 

500 

000 
P.31 

AMERICAN STANDARD, INC 

Applicatio n No. 17-1493 

Page 11 of 11 

Octobe r 30 , 1996 

Month Tota l Allowabl e Productio n 

1-7 

1-8 

1-9 

1-10 

1-11 

1-12 

52,500 

60,000 

67,500 

75,000 

82,500 

90,000 

•1,0