p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

57) 11-1-57 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:23 PM Sheet 57 of 114 
*5K^-*"- P.2 

OhfeEFtt 

'" • *-*. — •••• /—r \ 

• r i •' ••" •' ? A 94 52 

State of Ohio Environmental Protection Agency 

;:' c o c 

,1 >-;-

:

 ~ -J 

ET ADDRESS: OHIO E.PA 

0 Water-Mark Drive 

jmbus, OH 43215-1099 

MMUNO ADDRESS: 

January 31, 1996 

TELE: (614) 644-3020 FAX: (614) 644-2329 

CERTIFIED MAIL 

N.W.D.O.. P.O. Box 1049 

Columbus, OH 43216-1049 

Re: Modification to Permit to Install No. 03-9078 

Wood County 

Budd Company, Plastics Division 

32055 Edward Avenue 

Madison Heights, MI 48071 

Attention: Vinod C. Shah 

Enclosed please find a modification to the Ohio EPA-Permit to 

Install referenced above which, will modify the terms and 

conditions. 

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

and may be appealed to the Environmental Board of Review pursuant 

,to Section 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, OH 43215. 

Very truly yours. 

fAr>ta**3~ 50^. f&e 

Thomas G. Rigo, nanager 

Field Operations and Permit Section 

Division of Air Pollution Control 

Enclosure 

cc: US EPA 

NORTHWEST DISTRICT OFFICE, DAPC 

George V. Voinovich, Governor 

Nancy P. Hollister, Lt. Governor 

Donald R. Schregardus, Director 
P.3 

IrtoEFft State of Ohio Environmental Protection Agency 

rmit to Install 

rms and Conditions 

Issuance Date: January 31, 1996 

Effective Date: January 31, 1996 

OHIO ENVIRONMENTAL PROTECTION AGENCY 

MODIFICATION TO PERMIT TO INSTALL 

Name of Applicant: Budd Company, Plastics Division 

Address: 100 South Poe Road 

City: North Baltimore, OH 

Telephone: (810)588-3200 

The Ohio EPA has received a request for a modification for the Ohio 

EPA Permit to Install referenced above. 

The Permit to Install issued to Budd Company, Plastics Division 

(PTI No. 03-9078) is hereby modified in the following manner: 

Terms and Conditions on pages 6 and 23 of Permit to Install issued 

December 20, 1995. 

The reason for the modification is: to modify the Air Emission 

Summary on Page 6 and Additional Special Terms and Conditions on 

Page 23 of PTI Number 03-9078, due to an administrative error. 

The above named entity is hereby granted a modification to the 

permit to ins tall des cr ibed above pursuant to Chapter .3.7.4 5-3.1 .of 

the Ohio Administrative Code. Issuance of this modification 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 included in the application, the above described 

source(s) of pollutants will be granted the necessary operating 

permits. 

Ohio Environmental Protection Agency 

J^efitwSTj 

X 

Director 
P.4 

OfioEFA 

State of Ohio Environmental Protection Agency 

:f ADDRESS: HAIUNOADHPF<«. 

i WaterMark Drive 

mbus, OH 43215-1099 

TELE: (614) 644-3020 FAX; (614) 644-2329 P.O. Box 1049 

Columbus, OH 43216-1049 

Re: Permit to Install 

Wood County 

Application No: 03-9078 

TOXIC REVIEW 

December 20, 1995 

BUDD COMPANY, PLASTICS DIVISION 

VINOD C. SHAH , 

32055'EDWARD AVENUE 

MADISON HEIGHTS, MI 48071 

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,"""... ' 

Thomas G. Rxgo, Manager 

Field Operations & Permit Section 

Division of Air Pollution Control 

cc: US EPA 

NORTHWEST DISTRICT OFFICE, DAPC 

George V. Voinovteh, Governor 

Nancy P. Hollister. U Governor 

Donald R. Schregardus, Director 

3 

< 0<A^ ^ Dt w 
P.5 

W@EF& State of Ohio Environmental Protection Agency 

jrmit to Install 

irms and Conditions 

Application No. 03-9078 

APS Premise No. 0387000042 

Permit Fee: $16800.00 

Name of Facility: BUDD COMPANY, PLASTICS DIVISION 

Person to Contact: VINOD C. SHAH 

Address: 32055 EDWARD AVENUE 

MADISON HEIGHTS, MI 48071 

Location of proposed source(s): 100 SOUTH POE ROAD 

NORTH BALTIMORE, OHIO 

Description of proposed source(s): 

TWENTY-TWO SHEET MOLDING COMPOUND COMPRESSION MOLDING PRESSE 

S. 

Date of Issuance: December 20, 1995 

Effective Date: December 20, 1995. 

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. 

Ohio Environmental Protection Agency .^: 

Director 

H 
P.6 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 2 of 23 

December 20, 1995 

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) 

5 
P.7 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 3 of 23 

December 20, 1995 

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 T<"> TWSTW.T. VV.V. 

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. 

c 
P.8 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 4 of 23 

December 20, 1995 

AIR EMISSION SUMMARY 

The air contaminant sources listed below comprise the Permit to 

Install for BUDD COMPANY, PLASTICS DIVISION located in Wood 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 

?A 

surce 

imber 

309 

Source 

Identification 

Description 

Compression 

molding press 

#1 

BAT 

Determination 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Applicable 

Federal & 

OAC Rules 

3745-31-05 

3745-17-11 

3745-17-07 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

1.98 lbs OC/hour* 

566,3 lbs OC/day 

and 70.8 tons OC/. 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

310 Compression 

molding press 

#2 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

1 

1.98 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 
P.9 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 5 of 23 

December 20, 1995 

tiio 

PA Source 

Duree Identification 

umber Description 

* 

Oil. Compression 

molding press 

#3 

• 

013 Compression 

molding press 

#5 

BAT 

Determination 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Applicable 

Federal & 

OAC Rules 

3745-31-05 

3745-17-11 

3745-17-07 

3745-31-05 

3745-17-11 

3745-17-07 

tf 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Recruirements 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

3.19 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional ' 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

1.65 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 
BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 6 of 23 

December 20, 1995 

io 

A Source 

urce Identification BAT 

mber Description Determination 

Applicable 

Federal & 

OAC Rules 

P.10 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Recruirements 

Term s an d 

Conditions** 

5.0 tons OC/month 

114 Compression 

molding press 

#6 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

1 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional" 

Special Terms and 

Conditions** 

1.54 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation.) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 
BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 7 of 23 

December 20, 1995 

p.11 

lio 

»A 

>urce 

imber 

>15 

Source 

Identification 

Description 

Compression 

molding press 

#7 

BAT 

Determination 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Applicable 

Federal & 

OAC Rules 

3745-31-05 

3745-17-11 

3745-17-07 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Recruirements 

3.08 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

)16 Compression 

molding press 

#8 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

5.0 tons OC/month 

and.40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional" 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

3.08 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-mohth 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

0 
BUDD COMPANY, PLASTICS DIVISION 

Applicatio n No. 03-9078 

Pag e 8 of 23 

December 20 , 1995 

P.12 

Lo 

K 

iree 

nber 

Source 

Identification 

Description 

BAT 

Determination 

Applicable 

Federal & 

OAC Rules 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Recruirements 

17 Compression 

molding press 

#9 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

18 Compression 

molding press 

#10 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

It 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

3.3 lbs OC/hour* 

566.3 lbs OC/day 

and'70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

..See.. Additional 

Special Terms and 

Conditions** 

4.29 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 
P.13 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 9 of 23 

December 20, 1995 

.o 

i Source 

irce Identification 

iber Description 

L9 Compression 

molding press 

#11 

• 

20 Compression 

molding press 

#12 

, 

BAT 

Determination 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Applicable 

Federal & 

OAC Rules 

3745-31-05 

3745-17-11 

3745-17-07 

3745-31-05 

3745-17-11 

3745-17-07 

12-

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Recruirements 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

2.75. lbs OC/hour* 

566.3 lbs OC/day 

and -70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

1.43 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 
P.M 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 10 of 23 

December 20, 1995 

io 

A 

urce 

mber 

Source 

Identification 

Description 

BAT 

Determination 

Applicable 

Federal & 

OAC Rules 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Recruirements 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

21 Compression 

molding press 

#13 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

1.1 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation j 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

13 
P.15 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 11 of 23 

December 20, 1995 

no 

?A 

jurce 

unber 

)22 

Source 

Identification 

Description 

Compression 

molding press 

#14 

BAT 

Determination 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Applicable 

Federal & 

OAC Rules 

3745-31-05 

3745-17-11 

3745-17-07 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

0.39 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s a n d 

Conditions** 

5.0 tons OC/month 

and. 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional" 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

)23 Compression 

molding press 

#15 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

0.83 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Terms and • 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

W 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 
P.16 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 12 of 23 

December 20, 1995 

LO 

ft. 

aree 

mber 

Source 

Identification 

Description 

BAT 

Determination 

Applicable 

Federal & 

OAC Rules 

24 Compression 

molding press 

#16 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

25 Compression 

molding press 

#18 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

See Additional 

Special Terms and 

Conditions** 

1.21 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding ) See 

Additional Special 

T e.r m s an d 

Conditions** 

5.0 tons OC/month . 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

0.39 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

15 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 
P.17 

• i 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 13 of 23 

December 20, 1995 

hio 

PA 

ource 

umber 

026 

'027 

Source 

Identification 

Description 

Compression 

molding press 

#19 

Compression 

molding press 

#20 

BAT 

Determination 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Applicable 

Federal & 

OAC Rules 

3745-

3745-

3745-

3745-

3745-

3745-

l(o 

•31-

-17-

-17-

-31-

-17-

-17-

-05 

-11 

-07 

-05 

-11 

-07 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

1.65 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional — 

Special Terms and 

Conditions** 

1.65 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 
P.18 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 14 of 23 

December 20, 1995 

.o 

L 

irce 

iber 

Source 

Identi f i cation 

Description 

BAT 

Determination 

Applicable 

Federal & 

OAC Rules 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

28 Compression 

molding press 

#21 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

1.65 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

n 
P.19 

1 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 15 of 23 

December 20, 1995 

io 

ft. 

tirce 

nber 

29 

30 

Source 

Identification 

Description 

Compression 

molding press 

#22 

-

Compression 

molding press 

#23 

BAT 

Determination 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

Applicable 

Federal & 

OAC Rules 

3745-31-05 

3745-17-11 

3745-17-07 

3745-31-05 

3745-17-11 

3745-17-07 

1* 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

1.65 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

Term s an d 

Conditions** 

5.0 tons OC/month 

and...40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional" 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

1.65 lbs OC/hour* 

566.3 lbs OC/day 

. and 70.8 tons OC/ 

rolling. 365 day _ 

period (compression 

molding) See ' 

Additional Special 

Terms . an d 

Conditions** 

5.0 tons OC/month 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 
BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 16 of 23 

December 20, 1995 

LO 

\ 

irce 

nber 

Source 

Identification 

Description 

BAT 

Determination 

Applicable 

Federal & 

OAC Rules 

31 Compression 

molding press 

#4 

Compliance 

with emission 

limits and 

terms and 

conditions of 

this permit 

3745-31-05 

3745-17-11 

3745-17-07 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Recruirements 

See Additional 

Special Terms and 

Conditions** 

4.07 lbs OC/hour* 

566.3 lbs OC/day 

and 70.8 tons OC/ 

rolling 365 day 

period (compression 

molding) See 

Additional Special 

T e...r m s an d 

Conditions** 

5.0 tons OC/month. 

and 40.4 tons OC/ 

rolling 12-month 

period (scrap 

generation) 

See Additional 

Special Terms 

and Conditions** 

14.3 lbs PM/day 

1.76 tons PM/yr 

Opacity restrictions 

See Additional 

Special Terms and 

Conditions** 

he pounds/hr limits established by this permit are based on the maximum SMC 

age in pounds per hour per press. No additional recordkeeping is required 

verify compliance with this limit. 

These allowable OC and TSP emission limitations represent the combined 

issions from all compression molding presses and the associated scrap 

ndling operations. 

SUMMARY 

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS 

Pollutant 

Organic Compounds (OC) 

PM 

Tons/Yea r 

111. 2 

1.76 

\°\ 
P.21 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 17 of 23 

December 20, 1995 

RECORDSS^ RETENTION AND AVAILABILITY 

All records required by this Permit to Install shall be retained 

on file for a period of not less than three years unless otherwise 

indicated by Ohio Environmental Protection Agency. All records 

shall be made available to the Director, or any representative of 

the Director, for review during normal business hours. 

REPORTING REQUIREMENTS 

Unless otherwise specified, reports" required by the Permit to 

Install need only be submitted to OEPA Northwest District Office 

- DAPC, 347 North Dunbridge Road, P.O. Box 466, Bowling Green, Ohio 

43402. 

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 OEPA Northwest District Office - DAPC, 

347 North Dunbridge Road, P.O. Box 466, Bowling Green, Ohio 43402. 

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. 

2-0 
BUDD COMPANY, PLASTICS DIVISION 

Applicatio n No. 03-9078 

Page 18 of 23 

December 20 , 1995 

ADDITIONAL SPECIAL TERMS AND CONDITIONS 

Genera l 

This PTI is being done to correct permit deficiencies for 

emission units installed after January 1, 1974. These 

emission units have never been issued a permit to install. 

The following is a listing of all compression molding presses 

at the facility and the date each was installed: 

Source* 

P009 

P010 

POll 

P013 

P014 

P015 

Source* 

P016 

P017 

P018 

P019 

P020 

P021 

P022 

P023 

P024 

P025 

P026 

P027 

P028 

P029 

P030 

P031 

Description 

Compression Molding Press #1 

Compression Molding Press #2 

Compression Molding Press #3 

Compression Molding Press #5 

Compression Molding Press #6 

Compression Molding Press #7 

Description 

Compression Molding Press #8 

Compression Molding Press #9 

Compression Molding Press #10 

Compression Molding Press #11 

Compression Molding Press #12 

Compression Molding Press #13 

Compression Molding Press #14 

Compression Molding Press #15 

Compression Molding Press #16 

Compression Molding Press #18 

Compression Molding Press #19 

Compression Molding Press #20 

Compression Molding Press #21 

Compression Molding Press #22 

Compression Molding Press #23 

Compression Molding Press #4 

B. Facilitv Desionation 

Date 

1973 

1973 

1993 

1973 

1973 

1993 

Date 

1978 

1978 

1978 

1981 

1973 

1978 

1978 

1978 

1978 

1978 

1989 

1989 

1994 

1994 

1995 

1995 

Installed 

(No PTI required) 

(No PTI required) 

(No PTI required) 

(No PTI required) 

Installed 

(No PTI required) 

t 

This facility is presently not a "major" for PSD purposes. 

Current potential OC emissions from the facility are not 

greater than 250 tons/year. Potential emissions from painting 

operations, emission units R012, R013, R014 and R015 are 87.6 

tons/yr and were established in PTI number 03-5217. The 

limits established in this PTI for Compression Molding are 

based on the maximum capacities of the presses. Issuance of 

this permit will not make the facility a "major source" for 

PSD purposes. 

z\ 
P.23 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 19 of 23 

December 20, 1995 

C. BAT/Cost Effectiveness 

The agency typically requires a facility to conduct a cost 

effectiveness study when OC emission identified within a PTI 

exceed 40 tons per year. Although this permit to install 

allows for 111.2 tons of OC emissions from the presses and 

associated scrap operations, the presses were installed over 

a period' of years and no one press or group of presses 

approached the level that would have required a cost 

effectiveness study. 

D. Air Toxic Policv Applicability -

Modeling of styrene emissions was done on all presses 

installed in 1984 and after. Modeling showed compliance with 

Ohio EPA's air toxics policy. 

E. Allowable Mass Emission Limits/Operating Restrictions 

1. Raw sheet molding compound (SMC) usage in emission units 

P009, P010, POll, P013, P014, P015, P016, P017, P018, 

P019, P020, P021, P022, P023, P024, P025, P026, P027, 

P028, P029, P030, P031, shall not exceed a combined total 

of 161,800 lbs per day (80.9 tons/day) and 40.45 million 

lbs per year (20,225 tons/yr). 

2. The OC emission limits for these emission units are based 

on total SMC used in the facility on a daily and annual 

basis. Since it is impossible for the company to track 

SMC usage on individual presses, the limits are based on 

the maximum daily and annual usage of SMC in all the 

presses. This requires the company to accept limits for 

presses #1, #2, #5, #6 and #12, Ohio EPA emission unit 

numbers P009, P010, P013, P014 an P020, respectively, 

which were installed prior to January 1, 1974 and would 

normally be exempt from any mass OC emission iimit. 

The combined OC emissions from emission units P009, P010, 

POll, P013, P014, P015, P016, P017, P018, P019, P020, 

P021, P022, P023, P024, P025, P026, P027, P028, P029, 

P030 and P031 shall not exceed the following: 

a. from compression molding, OC emissions shall not 

exceed 566.3 lbs/day and 7 0.8 tons per rolling 365-

day period. This limitation includes those 

emissions associated with material handling and the 

generation of final SMC product, which includes SMC 

Charging, Molding, Vacuum Assisted Molding and 

Preheating SMC charges. Emissions as a result of 

scrap generation are not included. In order to 

ensure federal enforceability during the first 12 

calendar months of operation under this permit, The 

Budd Company shall not exceed the following 

cumulative emission restrictions: 
P.24 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 20 of 23 

December 20, 1995 

Month 

b. 

Allowable Cumulative Total 

Emission Restrictions (tons) 

5.9 

11.8 

17.7 

23.6 

29.5 

35.4 

41.3 

47.2 

53.1 

59.0 

64.9 

70.8 

From scrap generation, OC emissions shall not exceed 

5 tons per month or 40.4 tons/rolling' 12 month 

period. This limitation includes only those 

emissions associated with the generation of scrap. 

In order to ensure federal enforceability during the 

first 12 calendar months of operation under this 

permit, The Budd Company shall not exceed the 

following cumulative emission restrictions: 

1 

1-

1-

1-

1-

1-

1-

1-

1-

1-

1-

1-

-2 

-3 

-4 

-5 

-6 

-7 

-8 

-9 

-10 

-11 

-12 

Month 

1 

1-2 

1-3 

1-4 

1-5 

Month 

1-6 

1-7 

1-8 

1-9 

1-10 

1-11 

1-12 

Allowable Cumulative Total 

Emission Restrictions (tons) 

5.0 

10.0 

15.0 

20.0 

25.0 

All pwable. .Cumulative Tot a 1 

Emission Restrictions (tons) 

30.0 

35.0 

40 

40 

40 

40 

40.4 

3. The combined particulate matter emissions from emission 

unit numbers P009, P010, POll, P013, P014, P015, P016, 

P017, P018, P019, P020, P021, P022, P023, P024, P025, 

P026, P027, P028, P029, P030, P031, shall not exceed 0.60 

lb/hr and 2.63 tons/yr. 

Particulate Matter (PM) emission limits for these 

emission units are based on the results of testing 

performed by the company. Most PM emissions from the 

^3 
P.25 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 21 of 23 

December 20, 1995 

presses are controlled by two baghouse systems. A small 

portion is fugitive and is emitted into the plant and 

escapes through the general ventilation system. The PM 

limits established are for the combined emissions from 

all presses and take into account all three emission 

points. 

4. Raw scrap SMC shall be collected and placed a in sealed 

container as quickly as possible after generation. At 

a minimum raw scrap SMC must be collected every eight 

hours (i.e. at the end of each shift), weighed and placed 

in a closed container which will minimize volatilization 

of additional styrene. 

F. Recordkeeping 

1. The company shall collect and record the following 

information each day and maintain the information at the 

facility for a period of five years. 

a. total mass (lbs/day) of raw SMC used in all 

compression molding presses; 

b. the total mass (lbs/day) of raw SMC that was 

preheated before use in the presses; 

c. the total mass (lbs/day) of raw SMC not preheated 

(a-b); 

d. company identification of each type of scrap SMC 

generated; 

e. the total mass in pounds/day and tons/day of scrap 

SMC generated; 

f. the monomer content of each type of scrap SMC 

generated; 

g. the weight in pounds of each type of scrap SMC 

generated; and 

h. the calculated average styrene content for all scrap 

SMC generated. 

G. Emission Calculation Requirements 

1. The company shall calculate the emission rate (lbs/day) 

from compression molding operations associated with 

emission units P009, P010, POll, P013, P014, P015, P016, 

P017, P018, P019, P020, P021, P022, P023, P024, P025, 

P026, P027, P028, P029, P030, and P031 on a daily basis 

in accordance with the following: 

2H 
P.26 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 22 of 23 

December 20, 1995 (vv^.V^\^VE =^2 (Mt) (Pi) 

where: E = the daily OC emissions, in pounds/day 

Mi= the mass of raw SMC used that day, in tons 

per day (not including scrap) 

Ft= emission factor in pounds OC per ton of 

raw SMC used in each of the above emission 

units as follows: 

7.00 lbs/OC with preheating 

4.00 lbs/OC without preheating 

2. The company shall calculate the emission rate 

(tons/month) or scrap generation from compression molding 

operations associated with emission units P009, P010, 

POll, P013, P014, P015, P016, P017, P018, P019, P020, 

P021, P022, P023, P024, P025, P026, P027, P028, P029, 

P030, and P031 on a monthly basis in accordance with the 

following: 

E = E (Mi)(Si)(Fi) 

where: E = 

Mt= 

S,= 

Fi= 

monthly OC emissions, in tons per month 

amount of scrap SMC generated in ton per 

month 

average styrene content in percent by 

weight, expressed as ton(s) styrene per 

ton(s) SMC 

0.40 

3. The emission limitations established in the PTI are based 

on company supplied emission factors. Due to the 

difficulties in measuring emissions from these emission 

units, Budd Company is continuously attempting to refine 

testing methodologies.. Until a MACT standard is 

developed for these emission units, Budd Company shall 

continue to update the Ohio EPA on any emissions testing 

that may affect the emission factors used to establish 

the emission limits of this permit. The company may, at 

any time, petition Ohio EPA to reestablish any of the 

emission factors used in this permit. 

H. Reportinq Requirement 

The company shall notify the Ohio EPA, Northwest District 

Office, Division of Air Pollution Control, within 5 

calendar days of any records which show an exceedance of 

the emission limitations or usage restrictions of this 

permit. The company shall submit a copy of such records 

within 30 days of the end of the calendar month when the 

exceedance occurred. 

2. The company shall submit an annual report to the Ohio EPA 

field office which summarizes all exceedances of the 
P.27 

BUDD COMPANY, PLASTICS DIVISION 

Application No. 03-9078 

Page 23 of 23 

December 20, 1995 

emission limitations or SMC usage restrictions of this 

permit. The report shall also include a summary of the 

actual emissions from compression molding and scrap 

generation and the results of any additional emissions 

testing conducted by the facility which may affect permit 

emission limits. 

The annual reports shall be submitted by January 15 of 

each year and shall cover the previous 12 calendar 

months. 

3. All reports, notifications, etc. required by the above 

terms and conditions shall, be submitted to the Ohio 

Environmental Protection Agency, Division of Air 

Pollution Control, Northwest District Office, 347 North 

Dunbridge Road, Bowling Green, Ohio 43402. 

2.C