STREET ADDRESS:

Lazarus Government Center

50 W. Town St, Suite 700

Columbus, Ohio 43215

October 25, 2010

State of Ohio Environmental Protection Agency

TELE (614) 644-3020 FAX (614) 644-3184

www.epa.state.oh.us

MAILING ADDRESS:

PO. Box 1049

Columbus,OH 43216-1049

Dr. Susan Hedman

Regional Administrator

U.S. EPA Region V

77 W. Jackson Blvd.

Chicago, IL 60604

NOV 08 2010

(i) Printed on Recycled Paper

Re: Requested Additional Demonstration under Section 110(1) ofthe Clean Air Act for

Amended Rule 3745-21-07 of the Ohio Administrative Code

Dear Dr. Hedman:

On April 27, 2010, Ohio EPA submitted a letter containing information to assist in the

approval of amended Ohio Administrative Code (OAC) rule 3745-21-07 as part of Ohio's

State Implementation Plan (SIP). (The amended rule became effective on February 18,

2008; and it was submitted to USEPA on April 7, 2008.) The information was submitted

because USEPA was concerned about the amended rule not being applicable to any new

sources installed after the effective date of the rule. The letter outlined Ohio EPA's review

of 107 permits issued between January, 2008 and March, 2010 and presented a

determination that, based on the review of the permits, the approval of amended OAC rule

3745-21-07 into Ohio's State Implementation Plan (SIP) should be acceptable.

This letter provides supplemental information to further demonstrate that adoption of

amended OAC rule 3745-21-07 into Ohio's SIP will not violate the requirements of Section

110(1) of the Clean Air Act (CAA).

Additional Permit Search

In Ohio EPA's April 27, 2010 letter, we presented data from a review of 107 permits issued

between January, 2008 and March, 2010. Based on our review, through March, 2010, no

permit was issued that would result in an increase in emissions of volatile organic

compounds (VOC) due to the promulgation of new paragraph (A)(5) of OAC rule 3745-21-

07.

Between March, 2010 and September, 2010, Ohio EPA issued an additional 51 permits

that referenced OAC rule 3745-21-07. Seven of the 51 permits included a requirement to

comply with OAC rule 3745-21-07. All 7 facilities are currently meeting the limits of 8 Ibs

OC/hr and 40 Ibs OC/day without controls, and 5 of the 7 have at least one emissions unit

with an operational restriction (based on BAT) prohibiting the use of photochemically

reactive materials (PRMs) in the process. Based on this review, because all of the facilities

Ted Strickland, Governor

Lee Fisher, Lieutenant Governor

Chris Korleski, Director

Ohio EPA is an Equal Opportunity Employer
Demonstration under Section 110(1) of the

Clean Air Act for Rule 3745-21-07 of the

Ohio Administrative Code 2

are currently meeting the 8/40 requirements without controls, the acceptance of new

paragraph (A)(5) into the SIP would not lead to an increase in emissions of VOC from

these facilities.

A copy of Ohio EPA's permit table adding the 51 additional permits to the 107 permits

originally submitted in the March, 2010 letter is attached to this letter as Attachment A, and

a CO containing a PDF version of each of the 51 permits is also included in Attachment A.

Quantification of Emissions from SMC Machines

USEPA also requested that Ohio EPA investigate the change in emissions from sheet

molding compound (SMC) machines due to the promulgation of new OAC rule 3745-21-25.

A search of permits in Ohio's Stars2 database indicates that there are 7 facilities

Statewide, operating a total of 12 SMC machines. The machines are located in Ashtabula,

Franklin, and Van Wert Counties. Of these 12 machines, 3 are controlled (1 at Core

Materials in Franklin County, facility 10 0125041046, and 2 at Premix, Inc. in Ashtabula

County, facility 10 0204000133), and 6 of the machines are meeting the 40 Ibs/day

requirement based on their maximum PTEs. A spreadsheet providing background

information on each of the machines is included in Attachment B.

Although highly unlikely with amended OAC rule 3745-21-07 and new OAC rule 3745-21-

25 for the composites manufacturing industry, if new paragraph (A)(5) of OAC rule 3745-

21-07 were adopted into the SIP, facilities could theoretically increase their uncontrolled

emissions from uncontrolled machines to 25 tons VOC/year. Assuming this as a worst case

scenario, the maximum potential to emit (PTE) for the 9 uncontrolled machines would be

225 tons VOC/yr (9 machines X 25 tons VOC/year). Under the current, SIP-approved

version of OAC rule 3745-21-07, the maximum uncontrolled emissions for the 9 machines

would be 65.7 tons VOC/yr (9 machines X 40 Ibs/day X 365 days/yr). Therefore, the worst

case scenario for an increase in uncontrolled VOC from SMC machines would be

approximately 159 tons ofVOC/yr (225 tons VOC/yr minus 65.7 tons VOC/yr). Ohio EPA

views this worst case scenario as unrealistic and purely hypothetical.

The actual emission increases from SMC machines are much lower than the worst case

scenario described above. Of the 9 uncontrolled SMC machines in the State, 7 of the

machines are meeting the 40 Ibs/day limitation without controls (based on their actual

PTEs); therefore, these facilities would not represent a potential increase in actual

emissions. There are currently only 2 SMC machines in Ohio that exceed the 40 Ibs

VOC/day limitation (or 7.3 tons VOC/year) and are uncontrolled, i.e., only emissions units

P001 and P002 at Continental Structural Plastic in Van Wert County (facility 10

0381020017). The average emissions for calendar years 2008 and 2009 were 11.2 and

10.5 tons VOC/yr, respectively, for emissions units P001 and P002. Therefore, the actual

emission increases that would result from emissions units P001 and P002, if amended

OAC rule 3745-21-07 were approved as part of the SIP, would be 3.9 and 3.2 tons VOC/yr,

respectively, for a total of 7.1 tons VOC/yr.
Demonstration under Section 110(1) of the

Clean Air Act for Rule 3745-21-07 of the

Ohio Administrative Code

Available Emissions Offsets

3

In December, 2007, Ohio EPA promulgated rules in OAC Chapter 3745-110, "NOx RACT."

These rules addressed the control of emissions of oxides of nitrogen (NOx) from stationary

combustion sources such as boilers, combustion turbines, and stationary internal

combustion engines. The rules were made applicable as an attainment strategy in the

Cleveland-Akron-Lorain ozone moderate nonattainment area.

On September 15,2009 (74 FR 47414), USEPA redesignated the Cleveland-Akron-Lorain

metropolitan area as attainment for the 1997 8-hour ozone National Ambient Air Quality

Standard (NAAQS). At the same time, USEPA approved a waiver, for the Cleveland-AkronLorain area, from the oxides of nitrogen (NOx) Reasonably Available Control Technology

(RACT) requirements of section 182(f) of the CAA. Ohio's NOx RACT rules are, therefore,

surplus and can be used to offset any increase in emissions from SMC machines in Ohio.

In 2007, Ohio EPA estimated that there would be approximately 3,000 tons of NOx

emission reductions in the Cleveland-Akron-Lorain area due to the promulgation of OAC

Chapter 3745-110 (based on emissions inventory data from 2005). For purposes of this

letter, however, Ohio EPA will only address the actual emission reductions from a single

facility, Arcelor-Mittal (facility 10 1318001613).

Prior to the promulgation of OAC Chapter 3745-110, Arcelor-Mittal used an emission factor

(established via a stack test) of 0.55 Ibs NOx/mmBtu for its 3 reheat furnaces (EU IDs

P046, P047, and P048). To meet the requirements of OAC Chapter 3745-110, ArcelorMittal installed low NOx burners in their 3 reheat furnaces, reducing their emission factor to

0.29 Ibs NOx/mmBtu (confirmed via stack testing). Based on actual gas usage reported in

STARS2 for years 2007 and 2008, the average reduction in NOx emissions for this facility

was approximately 538 tons NOx/year.

In the Cleveland-Akron-Lorain area, the ratio of NOx emissions to VOC emissions is

approximately 1.36 Ibs NOxilb VOC based on the 2008 emissions inventory (which

includes mobile sources). Applying this factor, the approximate VOC offset potential for the

Arcelor-Mittal NOx reductions is 396 tons VOC/year. A table outlining the calculations of

the offsets is included in Attachment C.

Application of Offsets

To demonstrate that amended OAC rule 3745-21-07 can be adopted into Ohio's SIP in

compliance with Section 110(1) of the Clean Air Act, Ohio has calculated that more than

adequate emission reductions are available to offset even the most implausible worst case

scenarios as follows:

Offsets for New Sources

Ohio EPA has reviewed 158 permits issued between the promulgation of amended OAC

rule 3745-21-07 (February 18, 2008) and September 30,2010. Ohio EPA has shown that

none of these permits would result in an increase in emissions as a result of USEPA's

approval of amended OAC Rule 3745-21-07 into Ohio's SIP. Based on this demonstration,
Demonstration under Section 110(1) of the

Clean Air Act for Rule 3745-21-07 of the

Ohio Administrative Code 4

and assuming that the past issuance of PTls is a reasonable depiction of what will occur in

the future for new sources, no offsets would be required for new sources that are not

subject to the amended rule, even though substantial emissions offsets beyond those

provided by Arcelor-Mittal are currently available in the Cleveland-Akron-Lorain area.

Offsets for SMC machines

Ohio EPA has demonstrated that, even with the most unrealistic assumption, namely that

all of the uncontrolled SMC machines in Ohio would begin emitting at the maximum

uncontrolled rate of 25 tons VOC/year, there would be more than adequate offsets

available. The 369 tons VOC/year of emission reductions from Arcelor-Mittal alone are 2.3

times the 159 tons VOC/year required for the hypothetical, worst case scenario. Also,

based on Ohio EPA's calculations, the actual increase in emissions from SMC machines

that would require offsets would be approximately 7.1 tons/yr. This quantity is only a small

fraction of the hypothetical worst case scenario.

We would appreciate USEPA's expedited review of this material so that USEPA can

proceed with the approval of amended OAC rule 3745-21-07 and OAC rule 3745-21-25 as

part of Ohio's SIP. Please contact Jim Orlemann (614-644-3592 or

jim.orlemann@epa.state.oh.us) if you have any questions about this submittal.

Robert F. Hodanbosi, P.E.

Chief, Division of Air Pollution Control

cc: Jim Orlemann, DAPC

Jennifer Hunter, DAPC

Paul Braun, DAPC

Attachment
Attachment A

Updated Spreadsheet, "Permits Issued Since 1/1/2008

Referencing GAe Rule 3745-21-07"
Permits Issued 1/1/2008 to 9/1/2010 Referencing OAe Rule 3745-21-07

Attachment A

Permit Issuance 21-07 #EU's Applicable Unit Applicable Applicable #EU's Applicable Applicable

Facility Name FacilitylD County Name Permit Type Number Date searched? IY/N)? Applicable Unit Numbers Paragraph Numbers Dat. Pafilgraph Applicable Unit Numbers Date Paragraph Comments

See The permittee shall not employ any photochemically reactive material, as defined in OAe rule

Portage PTJ POI06296 8/26/2010 3745-21-Dl(C)(SJ, in this emissions unit. BAT requirements include compliance with 3745-21-

Custom Pultrusions Inc 1667020035 07IG).

K036 - The permittee shall not employ any coating or cleanup material in this emissions unit

Allen TVPTO POI06198 8/16/2010 ROO6 8/16/2010 (G){2) that is II photochemically reactive material. "Photochemically reactive material" is defined in

Metokote Corporation Plant 2 0302020064 OAC rule 3745-21-01(C)(5).

ROO4, ROO6, R003 OC emissions shall not exceed 8lbs/hr and 40 Ibs/day - BAT =7.30 tons OC/yr; ROO4- R007, ROOB, R003, Wyandot PTIO POOB7982 8/13/2010 ROll, R012, (G){2) R017 8/13/2010 (G){2) a. The emission limitation specified by this rule is less stringent than the emission limitation

R013, R014, R015 established pursuant to OAC rule 3745-31-05(A)(3)

GUARDIAN AUTOMOTIVE PRO 0388010022

Richland PTIO P0087486 8/11/2010 10 P019 to 8/11/2010 (G){2) 8 Ibs OC/hr; 40 Ibs OC/day Pittsburgh Glass Works, llC 0370000217 P028

Mahoning TVPTO POO8S775 7/20/2010 FOB 7/20/2010 (G){2) 31-D5(A)(3) - The requirements of this rule also include compliance with the requirements of

Parker Gear Pump Division 0250110316 OAC rules 3745-17-o7(B), 3745-17-08(8) and 3745-21-07(6)(2).

Organic compound emissions shall not exceed 8 pounds/hour and 40 pounds/day from all

Cuyahoga PTIO P0106074 6/11/2010 6/11/2010 IG)l2) coatings and photochemically reactive cleanup materials, on any day when photochemically

American Japanning Inc. 1318110513 reactive materials are employed.

lorain PTJ 5/25/2010 5/25/2010 IG)l2) Organic compounds (OC) emissions shall not exceed 8lbs/hr or40lbs/day.

Peny Fiberglass Products Inc 0247030996

PPG Industries - Delaware 0121010005 Delaware PTI 1/4/2010

WElLINGTON COMPRESSOR 1652000021 lorain PTIO 12/7/2009 STATION

WElLINGTON COMPRESSOR 1652000021 Medina PTIO 12/7/2009 STATION

R031, The control efficiency limitation specified by this rule is as stringent as or less stringent R032, IM)l1) & TS TRIM INDUSTRIES, INC. 0125031840 Franklin PTJO R033, (M)l2) than the control effICiency limitation established pursuant to OAC rule 3745-31-

R034 05IA)(3)(a)(II).

1677011093 PTJO Rool thru FERRIOT, INC. Summit 12/18/2008 IG)l2) R007

Butler PTI POI06336 9/2/2010 When coating non·metal parts in this emissions unit, the use of photochemically reactive

Pella Entry Systems 1409030092 material (coating or cleanup material) as defined in OAC rule 3745-21-o1(C)(5) is prohibited.

Butler PTJ POI06438 9/2/2010 When coating non-metal parts in this emissions unit, the use of photochemically reactive

Pella Entry Systems 1409030092 material (coating or cleanup material) as defined in OAC rule 3745-21-Ql(C)(5) is prohibited.

This emissions unit currently does not employ any photochemically reactive materials as

Hamilton PTJ POI06081 9/2/2010 defined in OAC rule 3745-21-o1(C)(5). It is, therefore, exempt from all emission limitations

Emery Oleochemicals llC 1431074278 and control requirements contained in OAC rule 3745-21-o7(G).

POOl, P003, POO4,

POO6, P007, POO9,

POlS, P016, P020,

P021, P022, P024, VOC emissions from each individual emissions unit shall not exceed 8lbs/hr or 40 Ibs/day. Franklin PTIO POI06568 9/1/2010 2' P025, P026, P027, 9/1/2010 IG)l2) BAT is 35.6 tons/yr as a group. P028, P029, P030,

P031, P034, P03S,

P037, P038, P039,

ISP CHEMICALS INC 0125040931 P04O, P041

Union PTJ 0010627-6 9/1/2010 This emissions unit is exempt from the emission limitation/control requirements contained in

Veyance Technologies, Inc. 0180010013 OAC rule 3745-21-07(G) because no photochemically reactive materials are employed.

Huron PTI POI04848 8/18/2010 The use of photochemically reactive materials, as defined in OAC rule 3745-21-01, in this

SolaellC 0339010005 emissions unit: is prohibited.

The requirements established pursuant to this rule are less stringent than or equivalent to the

Richland PTIO P0087487 8/18/2010 P029. P030, P033 IG)(2) requirements of OAC rule 3745-31-05 (A) i3l because the permittee does not always employ

Pittsburgh Glass Works, llC 0370000217 photochemically reactive materials in this emissions unit.

P031, P032, The requirements established pursuant to this rule are less stringent than or eqUivalent to the

Richland PTIO 8/11/2010 P034, P035, IG){2) requirements ofOAC rule 3745-31-05 (A) (3) because the permittee does not always employ

Pittsburgh Glass Works, llC 0370000217 P036, P037, P040 photochemically reactive materials in this emissions unit.

The requirements established pursuant to this rule are less stringent than or eqUivalent to the

Richland PTIO 8/11/2010 P038 (G){2) requirements ofOAC rule 3745-31-05 (A) (3) because the permittee does not always employ

Pittsburgh Glass Works, llC 0370000217 photochemically reactive materials in this emissions unit.

Ion
Permits Issued 1/1/2008 to 9/1/2010 Referencing OAe Rule 3745-21-07

Attachment A

Poo8 - DC emissions shall not exceed 8lbs/hr and 40 Ibs/day; POO9 - The emission limitation

8/10/2010 (G)(2) established pursuant to this rule is less stringent than the emission limitation established

pursuant to OAC rule 3745-31-o51A)(3).

P017 • The permittee has agreed to use of non-photochemically reactive material in order to

assure compliance with OAC rule 3745-21·07(G)(2).

This emissions unit becoml!S subject to the DC emission limitations of 8lbs/hr and 40 Ibs/day

(G)(2) [ OAC rule 3745-21-07 {G)(2}] on the days any photochemically reactive material (coating

and/or cleanup material) is employed in an operation involving non-ml!tal substrates, for

coatingjcleanuo material used associated with non-metal substrates.

Comments

On February 18, 2008, OAC rule 3745-21-07 was revised in its entirety; therefore, the 21-07

rule that was in effect prior to this date is no longer part of the State regulations. On April 4,

2008, the rule revision was submitted to the u.s. EPA as a revision to Ohio's State

Jmpll!ml!ntation Plan (SIP); however, until the U.S. EPA approves the revision to OAC rule

3745-21-07, the requirement to comply with the previous 21-07 rule provisions still exists as

part of the federally·approved SIP for Ohio.

This emissions unit currently dol!S not employ any photochemically reactive materials as

defined in OAC rule 3745-21-o1(C)(5). It is therefore exempt from all emission limitations and

control requirements contained in OAC rule 3745-21-07(6).

This emissions unit is exempt from the requirl!ments of OAe: rule 3745-21-071G) because

liquid organic materials are not employed.

POOl, P002, P003, POO9 to P012 • The only volatile liquid organic material that shall be

utilized in this emissions unit is formaldehyde, which is not a photochemically reactive

material as that term is definl!d by OAC rule 3745-21·01(C)15)(a).

The emission limitation and/or control requirements specifil!d in this rule are less stringent

than the emission limitations and/or control requirements established pursuant to OAC rule

3745-31-05(0).

The limits based on this rule are k!ss stringent than the limits established above. (BAT)

KOO6, K007, K018, K021, K027, Koo2, Koo3, KOO4, KOO9, K010, KOlI, K012, K022, K023, K024,

K025, P021 to P026 - The use of photochemically reactive materials, as definl!d in OAC rule

3745-21-01, in this emissions unit is prohibited.; K013 - Each emissions unit was installed

prior to February 15, 1972 and, therefore, OAC rule 3745-21-07 ts not applicable.

The sourcl!S are equal to or less stringent than the requirements of the associated MAG at

40 CFR Part 60, SubpartJJJJ.

The use of photochemically reactive material, as defined in OAC rule 3745-21-o1(C)(5j, is

prohibitl!d in thl"s emissions unit, except for any material used in the coating of metal parts.

The emission limitation and/or control requirements specified in this rule are less stringent

than the emission limitations and/or control requirements established pursuant to OAe rule

3745-31-o5{D).

The use of any photochemically reactive material, as defined in OAC rule 3745-21-01, in this

emissions unit is prohibited.

The limitations established by this rule are less stringent than the limitations established

pursuant to OAC rule 3745-31-oS(A)(3).

The control requirement specified by this rule is less stringent than the control requirement

established pursuant to OAC rule 3745-31-05(A)(3).

The control requirement specified by this rule is less stringent than the control requirement

establishl!d pursuant to OAC rule 3745-31-o5(A)(3).

POOl, POO6, P002, P003, POO4, P014 - The use of photochemically reactive materials, as

defined in OAC rule 3745-21-01 (C)(5), in this emissions unit ts prohibited.

Permit is for a storage tank, exempt from rule 21-07

Permit is for a storai!etank, exempt from rule 21-07

Permit is for a storage tank, I!xl!mDtfrom rule 21-07

Permit is for a storage tank, exempt from rule 21-07

Permit is for a storage tank, eXl!mDt from rule 21-07

Permit is for a stora~e tank, exempt from rule 21-07

Permit is for a storage tank, exempt from rule 21-07

Best Available Technology (BAT) requirements for this emission unit have been determined to

be the use of condenser and adsorber and compliance with the terms and conditions of this

permit.

Applicable Applicable

Date Paragraph

4/20/2010

21

Permit Issuance 21·01 # EU's Applicable Equ' # EU's Un. Applicable Appl".b~ I # EU's

FacilityNllme FacilltylD County Name Permit Type Number Date searched? (YIN)? Applicable Unit Numbers Paragraph • Applicable Numbers Date PillfliCraph Applicable Unit Numbers

Sandusky PTID POO87659 8/11/2010

WOODBRIDGE CORPORATION 0372030220

Butler PTI POI0S930 8/11/2010

Wausau Paper Towel & Tissue, 1409010043

The Cooper Tire Companv - Fin 0332010003 Hancock PTI POI06694 8/10/2010

Ott.wa PTID P0087403 8/10/2010 POO9 (G)(2) POO8

GUARDIAN MILLBURY CORP 0362000114

Wood PTIO P0031456 8/10/2010

LUBRIZOl ADVANCED MATERI 0387020333

LUBRIZOl ADVANCED MATERI 0387020333 Wood PTIO P0031465 8/10/2010

LUBRIZOL ADVANCED MATERI 0387020333 Wood PTIO P0031469 8/10/2010

LUBRIZOL ADVANCED MATERI 0387020333 Wood PTIO P0031475 8/10/2010

LUBRIZOl ADVANCED MATERI 0387020333 Wood PTIO P0031476 8/10/2010

LUBRIZOl ADVANCED MATERI 0387020333 Wood PlIO P0031484 8/10/2010

LUBRIZOL ADVANCED MATERI 0387020333 Wood PTIO P0031485 8/10/2010

LUBRIZOl ADVANCED MATERI 0387020333 Wood PTIO POO31490 8/10/2010

PSC Container Services LLC 0387000305 Wood PTIO P0031265 8/3/2010

Logan PTIO POI05378 8/3/2010

HBD INDUSTRIES, INC. 0546010034

(M)(1),(M)(2)

Montgomery PTIO POI06406 8/2/2010 POOl and (GJ(2)

from 1999 EURANO AMERICA INC 0857171794

P012, P017, (M)(1),(M)(2)

Montgomery PTIO POI06407 7/27/2010 P019, P008, and (G)(2)

P014, POlS, P020 from 1999 EURANO AMERICA INC 0857171794

0149000088 Madison PTI POI06532 7/26/2010 P307 to P313 (G)(2) SHOWA Aluminum Corporatio

0388010052 Wyandot PTIO POI05899 7/14/2010 M-TEK, INC.

Franklin PlIO POI06S4-2 7/1/2010 K012 (G)(2)

VERTlS INC 0125041807

Butler PTIO POI06429 6/30/2010

Chase Industries, Inc 1409000716

Wood PTI POI-D6111 6/10/2010 Y KOOl, K002

Pilkington North America Inc 0487010012

Huron 1VPTO _87290 5/12/2010

R. R. Oonnelley & Sons Compa 0339030135

HONEYWEll CPG FRAM OPER 0819070018 Darke PlIO POO91762 5/7/2010 P036, P037 (G)(l)

Franklin PlIO POI06183 5/4/2010 K012 (G)(l, (G)(2),

VERTIS INC 0125041807 (G)(6)(.)

Waste Manal!ement of Ohio is 0664000056 Peny PTI POI04875 4/28/2010 POO2 to POO9 (8)

Lucas TVPTO POI05419 4/27/2010

Tembec BTLSR Inc 0448010370

Shelby PTI POI05716 4/27/2010 C Honda of America Mfg., Inc. A 0575000174

< Crawford PTI IP010551. 4/20/2010 P035

GE Lighting Inc - Bucyrus Lamp 0317010010

20f7
Permits Issued 1/1/2008 to 9/1/2010 Referencing OAe Rule 3745-21-07

Attachment A

Permlt Issuance 21-07 • EU's Applicab~ .EU's UnO Applicab~ Applicable 'EU's Applicab'e Applicable

Facility Name Facility 10 County Name Permit Type Number Da•• Searched? (YIN)? Applicable Unit Numbers Paraeraph Applicable Numbers Date Paraeraph Applicable Unit Numbers Date Paragraph Comments

R6oo, R601, R602, R603 - This facility is locatl!!d in Fulton County, which is not considered a

Fulton TVPTO POO87013 4/20/2010 "Priority I" county as indicated in paragraph (A) of OAC rule 3745-21-D6, and is not a "new

source." Therefore, pursuant to OAC rule 3745-21-Q7(A), it is exempt from the requirements

Sauder Manufacturin 0326lXlO204 of OAC rule 3745-21-07(G).

Warrl!!n PTIO POI06004 4/19/2010 POOl- Exempt due to the use of non·photo-chl!!f1'lically reactive materials.

Atlas Rootin Corporation - Fe 1483040158

Pickaway PTI oo10S821 3/31/2010 To avoid the emission limitations/control requirements contained in OAC rule 3745-21-

DuPont-Circleville 0165010004 07(G){2J, no photochemically reactive materials shall be l!!mployl!!d in this emissions unit.

P103 - This l!!missions unit currently dOl!!s not employ any photochemically reactive materials

Hamilton PTI POI06056 3/29/2010 as defined in OAC rule 3745-21-Ql(C)(5j. It is, therefore, exempt from all emission limitations

Emery Oleochemicals LlC 1431074278 and control requirements contained in OAC rule 3745-21-Q7(G).

Rumpke Sanitary landfill, Inc. 1431092049 Hamilton PTI POlO5842 3/29/2010 Exempt due to the use of non-photochl!!micall reactive materials.

Columbiana PTIO POQ84305 3/24/2010 8004,8005 (B)(l) The l!!f1'lission limitation specified by this rule is less stringent than the emission limitation

FEDERAL CORRECTIONAllNST 021SlXlO326 established pursuant to OAC rule 3745--31..()S(A (3).

For POO], P009 - P020, P029, P030, Pa50 - Pa57 "As per 'Ihe White Rubber

Corporation v. Director (ERAC Case No. 675153r decision, OAC rule 3745-21-07(G)

PLASTI-KOTE CO., INC. 1652050060 Medina PTIO 3/11/2010 P025, P026 (G)(2) 31 Sl!eComments 3/11/2010 (G)(2) shall not apply to an operation that is purely a mixing process with no chemical

manufacturing or chemical reaction occurring. MK002, K003, and R003 - R007 are

sub'ect to 8/40 but not listed as BAT.

LUBRIZOl ADVANCED 0247030004 Lorain PTlO The requirements of this rule do not apply as the use of photochemically reactive

MATERIALS materials is rohibited.

When employing, applying, evaporating. or drying any photochemically reactive

material, or substance containing such photochemically reactive material, the

PLASTI-KOTE CO., INC. 1652050060 Medina PTlO 3/08/2010 KOOl 3/8/2010 (G) permittee shall not discharge more than 40 pounds of organic material into the

abnosphere in anyone day, nor more than 8 pounds of organic material in anyone

h ur.

American Japanning Inc. 1318110513 Cuyahoga PTlO POO95217 01/26/2010 KOO2, KOO6 4/8/2003 (G)(2) 8 pounds/hour and 40 pounds/day of OC emissions when coating non·metal parts

Elyria Foundry 0247040014 lorain PTI 00105001 01/21/2010 F016 The emission limitation required by this applicable rule is less stringent than the

emission limitation established ursuant to OAC rule 3745-31-05.

ChemDevelopment Plant 2 0243081428 lake PTIO 00105407 01/19/2010 KOO4, KooS (G)(2) While coating plastic, the emission limitation specified by this rule is less stringent than

the emission limitation established pursuant to OAC rule 3745-31-05(A)(3).

Elyria Foundry 0247040014 Lorain PTI POl04640 01/19/2010 F022 The emission limitation required by this rule is equivalent to and/or less stringent than

the emission limitation established pursuant to OAC rule 3745-31-05.

REPUBLIC POWDERED METALS 16520Soon Medina PTlO P024, P025 1/12/2010 (G)(2) The emission limitation based on this rule is less stringent than the limit established

ursuant to OAC rule 3745-31-05 D .

Mullet Cabinets Inc Holmes PTlO Rool, R003 to (G)(2) Organic compound (DC) emissions from each emissions unit shall not exceed forty OB8000104 ROOS (40) pounds per day and eight (8) pounds per hour.

Kinder Morgan liquids (1) Loading of volatile photochemically reactive materials into any tank truck, trailer or

1431072036 Hamilton PTIO lOOl (E) rail road tank car shall not exceed 40,000 gallons per day except as provided by OAC Tenninal- Qul!t!!n C rule 3745-21·07 E 1 athrouhc.

POll, P016, PaB,

Pa12, Pa13, P014, The OC emission limitations based on this rule are less stringent than the limitations REPUBLIC POWDERED METALS 1652050077 Ml!!dina PTIO 1. P015, POO8, POO9, 12/18/2009 (G)(2) established pursuant to OAC rule 3745-31-05. POD5, POO6, P007,

pon, POl8

To avoid the emission limitations/control requrements contained in OAC rule 3745-21-

Anchor Hocking Glass Co. 0123010078 Fairfil!!ld PTI POlOS055 12/14/2009 KOO3, KOO4 07(G)(2), no photochemically reactive materials (Le., as raw materials or cleanup

materials shall be em 10 ed in this emissions unit.

PI03, P113, P1l4, Synthetic Minor PTIO, Set emissions Imlts for EU's. but does not mention specifIC FRANKLIN INTERNATIONAL 0125040070 Franklin PTIO POI04737 12/08/2009 P124, P125, P126, (M)(3) controls to be utilized P128

Bridgestone APM Company· 0388010051 Wyandot PTI P0104512 12/08/2009 (G)(2) The permittee shall not employ any liquid organic material that is a photochemically

Foam Products Division reactive material in this emissions unit.

This emissions unit currently does not employ any photochemically reactive materials

Emery Oleochemicals LLC 1431074278 Hamilton PTI as defined in OAC rule 3745-21·01 (C)(5). It is. therefore, exempt from all emission

limitations and control requirements contained in DAC rule 3745-21-07(G).

3 on
Permits Issued 1/1/2008 to 9/1/2010 Referencing OAe Rule 3745-21-07

Attachment A

LeSS

Permit Issuance 21-07 ........ • EU's Applicab6e # EU's Unit Applicable Applialb6e • EU's Applicable AppliCllble

FacilltyNiln1e fBciUtylO County Name Permit Type Number Date Searched? IY/N)? ThanBAU Applicable Unit Numbers Paralrlilph Applicable Numbers Dat. Paragraph Applicable Unit Numbers Date Paragraph Comments

Each day that a photochemically reactive material, as defined in OAe rule 3745-21-

Plastpro Inc-Ashtabula Plant 0204000441 Ashtabula PTJ POl05074 11/23/2009 ROO4 11/23/2009 (GII2) 01(C), is employed, the organic compound (OC) emissions from all coating materials

and any photochemically reactive cleanup/purge materials shall not exceed 8 Ibslhr

and 40 lbslda .

M-TEK,INC. 0388010052 Wyandot PTIO POO87993 11/17{2009 (GII2) The pennitlee shall not employ any photochemically reactive material, as defined in

OAe rule 3745-21-01 C 5 in this emissions unit..

When coating non-metal parts in this emissions unit, the use of photochemically

Pella Entry Systems 1409030092 Butl!!!r PTJ POIOS3S2 11/16/2009 reactive material (coating or cleanup material) as defined in OAC rule 3745-21·

01 C 5 is rohibited.

Guardian Manufacturing Emissions of OC from emissions units P001, P002 and P004 shall be controlled by a

0339030016 Huron PTI 03~U424 11/12/2009 POOl, P002, POO4 3/16/1985 (G) carbon adsorption solvent recovery system which has 100 percent capture efficiency Company and a minimum removal efficienc of 96 ercent.

Riceland Cabinet Corp 0285032001 Wayne PTJ POI0S242 11/10/2009 R001- R007 (GII2) Emissions of photochemically reactive organic compounds shall not exceed 8 pounds

er hour and 40 ounds erda.

These emissions units meet the conditions contained in OAC rule 3745-21-

Bridgestone APM Co.- AVO 0388010047 Wyandot PTI POI05318 11/09/2009 ROO3, ROO4 6/5/2007 (M) 07(M)(3)(c)(iii), which are more stringent than the requirements of OAC rule 3745-21-

Plant 07(M)(2). Therefore. OAe rules 3745-21-07(M)(3)(a) and 3745-21-07(M)(3)(b) are

not considered a licable.

To avoid the emission limitations/control requirements contained in OAC rule 3745-21·

GERSTENSLAGER CO 0372020239 Sandusky PTIO 130087633 11/03/2009 07(G)(2), no photochemically reactive materials (i.e., as raw materials or cleanup

materials shall be em 10 d in this emissions unit.

Ford Motor Company, P048, POS2, The emission limitation specified by this rule is less stringent than the emission

Cleveland Engine Plants 1318120179 Cuyahoga PTJ POI0S3n 11/03/2009 POS3, P054, (G) limitation established pursuant to OAC rule 3745-31-05(A)(3). P05S, P061, P064

Amt!!!kco Industries To avoid the emission limitations/control requirements contained in OAC rule

Incorporated 0125043113 Franklin PTJO POIDS401 10/28/2009 R001 5/30/2006 (GII2) 3745-21-07(G)(2), no photochemically reactive materials (i.e., as raw materials or

cleanu materials shall be em 10 ed in this emissions unit.

The emission Imitations and control requirements from the amended 21~07 rule, and

the associated operational restrictions and the monitoring, record keeping, and

AS AMERICA, INC.-SALEM, OH 0215090011 Columbiana PTIO reporting requirements contained in this permit, shall become federally enforceable on

PLANT the date the U.S. EPA approves the revised OAC rule 3745-21-07 as a revision to the

Ohio State Implementation Plan. The following terms shall become federally

enforceable after U.S. EPA approves the rule revision: None.

Norplas Industries Inc. 0387000362 Wood PTI POI0S542 10/13/2009 R001 (GII2) The control requirements specified by this rule are less stringent than the

requirements established pursuant to OAC rule 3745-31-05(A)(3).

Bridgestone APM Company- 0388010051 Wyandot PTJ POI049ZS 10/13/2009 (GII2) The permittee shall not employ any liquid organic material that is a photochemically

Foam Products Division reactive material in this emissions unit.

Elyria Found 0247040014 Lorain PTJ POI04634 10/09/2009 F021 9/1O!1990 IG OC emissions shall not exceed 8 ounds er hour and 40 ounds erda.

R. R. Donnelley & Sons 0339030135 Huron PTI POID5541 10/08/2009 The use of photochemically reactive materials, as defined in OAC rule 3745-21-01, in

Company this emissions unit is rohibited.

GRAPHITE SALES INC 0303000138 Ashland PTIO POID4802 10/06/2009

Clean Harbors Recycling 0145020235 Licking PTJ POI04904 09/30/2009 POll 9/30/2009 (GII2) Photochemically reactive organr; compound emissions shall not exceed 8 pounds per

Services of Ohio LLC. hour and 40 ounds erda .

The Lubrizol Corporation 0243000024 Lake PTI POID5269 09/30/2009 This emissions unit does not load volatile photochemically reactive material as defined

in OAC rule 3745-21-01; therefore, the requirements of this rule do not apply.

The permittee has satisfied the "latest avaUable control techniques and operating

The Medical Cent!!!r Company 1318003059 Cuyahoga PTJ POI04976 30/2009 (8) practices" required pursuant to OAC rules 3745-21-07(8) by committing to comply

with the best available technology requirements established pursuant to OAC rule

3745-31-05 A 3.

Champion Graphics The use of photochemically reactive materials, as defined in OAC rule 3745-21·

CorpolGtion 1431070383 Hamilton PTIO POI05098 09/11/2009 01(C)(5), is prohibited; therefore, this emissions unit is exempt from the requirements

of this rule.

This emissions unit currently does not employ any photochemically reactive materials

Em!!!ry Oleochemicals LLC 1431074278 Hamilton PTI POIDS206 09/11/2009 as defined in OAC rule 3745-21-01(C)(5). ft is, therefore, exempt from all emission

limitations and control requirements contained in OAC rule 374S.21~07(G).

The permittee has satisfied the "latest available control techniques and operating

Nationwide Children's 0125040588 Franklin PTIO POIOS112 09/01/2009 B017, B018 9/1/2009 (8) practices~ required pursuant to OAC rules 3745-21-07(8) by committing to comply

Hospital with the best available technology requirements established pursuant to OAC rule

3745-31-05 A 3.

OMNOVA Solutions Inc. 16670CKXXl7 Portage PTIO 08/31/2009 POlS

This emissions unit currently does not employ any photochemically reactive materials

Endicott Cincinnati liC 1431004336 Hamilton PTIO POI04716 08/24/2009 P002, TOOl, T002 (GII2) as defined in OAC rule 3745-21-01 (C)(5). It is therefore, exempt from all emission

limitations and control requirements contained in OAC rule 3745-21-07(G)

LEATHER RESOURCE OF 0204020430 Ashtabula PTIO POID4831 08/18/2009 The use of photochemically reactive materials, as defined in OAC rule 3745-21-

AMERICA, INC. 01 C 5, in an of the s ecified emissions units is rohiblted.

LEATHER RESOURCE OF 0204020430 Ashtabula PTIO f'OI04117 08/18/2009 The use of photochemQilly reactiVe materials, as defined in OAC rule 3745-21-

AMERICA, INC. 01 C 5,inan of the specified emissions units is rohlbited.

Ford Motor Co.~Lima 0302020143 Allen PTI POI05203 08/07/2009 P114, P116 (GII2) The emission limitation specified by this rule is less stringent than the emission

limitation established ursuant to OAC rule 3745-31-05 A 3.

Quantum Technologies & 0180010401 Union PTJO POI04565 07/23/2009 KI01, P101 7/23/2009 (G) Photochemically reactiVe organk; compound emissions shall not exceed 8 pounds per

Servic!!!s, Inc. hour and 40 ounds erda.

4017
Permits Issued 1/1/2008 to 9/1/2010 Referencing OAe Rule 3745-21-07

Attachment A

Permit Issuance • EU's Applicable # EU's Un" Applicable Applicable # EU's Applicable Applicable

Facility Name FacilitylD County Name PerrnltTYJM! Number Dote Searched? Applicable Unit Numbers Paragraptl Applicable Numbers Dote Paragraph Applicable Unit Numbers Dote Paragraph Comments

This emissions unit is located in Wyandot County, which is not a ~Priority r county as

MILLS COMPANY 0388010029 Wyandot PTIO POO87983 07/15/2009 indicated in paragraph (A) of OAG rule 3745-21-06 and was installed prior to February

15,1972. Therefore, pursuant to OAe rule 3745-21-07(A), tt: is exempt from the

re uirements of OAG rule 3745-21-07 G .

Defiance casting Operations 0320010001 Defiance P11 POI04241 07/09/2009 ThiS emissions unit is not subject to the requirements in GAG rule 3745-21-

07(G) because no liquid organic material is employed in this emissions unit.

Johnson Controls Inc. The "Best Available Technology" (BAT) requirements for this emissk:ms unit have

Automotive Experience 0386010201 Williams PTlO POO87835 06/30/2009 R029 11/7/2000 (G)(2) been determined to be the use of a dry filtration system and compliance with the

r uirements of 3745-21·07 G 2 and OAC rUle 3745-17-07 A .

The permittee has satisfied the "best available control techniques and operating

practices" required pursuant to OAC rule 3745-21-07{B) and the "latest available

Camon limestone landfill Gas control techniques and operating practices" required pursuant to OAC rules 3745-21-

Power Station 0250050996 Mahoning PTI ,. Pool- P014 (0) 06(B) by committing to comply with the best available technology (BAT) requrements

established pursuant to OAC rule 3745-31-05{A){3) in this permit to install. The

design of the emissions unit and the technology associated with the current operating

practices satisfy the BAT requirements.

This emissions unit becomes SUbject to the OC emission Imitations of 8 Ibslhr and 40

GE lighting Inc - Bucyrus Lamp POO6, L4, P007, L5, IbsJday [OAC rule 3745-21·07 (G)(2)] on the days any photochemk:;ally reactive

Plant 0317010010 Crawford PTl POOB, l6 12/13/1985 (G)(2) material (coating and/or cleanup material) is employed in an operation involving nonmetal substrates, for coating /cleanup material used associated wtth non-metal

substrates.

Ford Motor Company, 1318120180 Cuyahoga P11 13·04702 06/15/2009 P41Z, P414 (G)(9)(h) The requirements of this rule are equivalent to the requirements of OAC rule 3745-31-

Cleveland casting Plant 05 A 3 for control of catal t as emissions.

R. R. Donnelley & 50ns 0339030135 Huron PTl P0104538 06/11/2009 The use of photochemically reactive materials, as defined in OAC rule 3745~21·01, in

Company this emissions unit is rohibit:ed.

Riceland cabinet Corporation 0285010312 Wayne PTl 02-21941 06/10/2009 12 R005 to R016 12/1/2001 (G)(2) Emissions of organic compounds (OC) shall not exceed 8 pounds per hour and 40

unds er da .

OAC rule 3745-21-07(G)(2) does not apply because the emissions unit is not involved

Bulk Molding Compounds, Inc. 0387040001 Wood P11 POI05003 06/10/2009 in "employing, applying, evaporating or drying" photochemk:;ally reactive material

(Ohio Supreme Court's decision in Ashland Chemical Company vs. Jones (2001),92

Ohio St. 3d 234 .

This emissions unit is exempt from the emission Imitation/control requirements

Veyance Technologies, Inc. 0180010013 Union P11 POI04892 06/08/2009 contained in OAC rule 3745-21-07(G) because no photochemically reactive materials

are em 10 ed. See b 2 b. below.

The permittee shall not employ any material in this emissions unit that is a

HJ. Heinz, loP. 0372030070 sandusky PTl 03~13946 06/01/2009 photochemicallyreactive material. "Photochemk:;ally reactive material" is defined in

OAC rule 3745-21-01 C 1.

Comfort line Ltd. 0448011664 lucas PTl POI04626 OS/28/2009 P014 5/28/2009 (G)(2) Only OC emissions that are photochemically reactive in this emissions unit are

assumed to be VOC emissions and subject to OAC rule 3745-21-07(G)(1).

General Electric Aircraft 1431150060 Hamilton PTI POI04631 OS/28/2009 PZ74 5/28/2009 (G) Organic compound (OC) emissions shall not exceed 8 pounds per hour and 40

Engines, Evendale Plant ounds er da from this emission unit.

Pechiney Plastic Packaging Inc 1677000105 Summit PTl OS/21/2009 POlO 5/21/2009 (G)(2) Exempt, the use of PRM not allowed.

The Permittee has satisfied the "latest available control techniques and operating

OHIO REFORMATORY FOR 0180010017 Union PTIO POI03985 05/19/2009 practices" required pursuant to OAC rules 3745-21-07(B) by committing to comply

WOMEN with the best available technology requirements established pursuant to OAC ruie

3745-31-05 A 3.

Each day that a photochemically reactive material, as defined in OAC rule 3745-21-

ALL AMERICAN SPORTS CORP 0247040955 Lorain PTlO P0104537 05/19/2009 ROO6, R007 5/19/2009 (G)(2) 01(C)(5), is employed, the organic compound (OC) emissions from all coating

materials and any photochemically reactive cleanup materials shall not exceed 8

IbsJhr and 40 IbsJda from each emissions unit.

Various

Research Organics Inc. 1318172081 Cuyahoga P110 POO9532-o 05/19/2009 Approx 50 See Comment Between 1972 IG)(2) Organic compound (OC) emissions shall not exceed 8.00 IbsJhr and 40.0 IbsJday.

and 2007

Each day that a photochemically reactive material (as defined in OAe 3745-21-

01 (C)(5)] is employed, the organic compound (OC) emissions from all coatings and

dba Yutzy's Finishing 0238000158 Holmes P110 POI04650 05/18/2009 Rool, RooZ 1/16/2007 (G)(2) photochemically reactive cleanup material shall not exceed 8 pounds per hour and 40

pounds per day. OC emissions from cleanup material that is not a photochemically

reactive material shall not be included in showing compliance with these emission

Imitations.

When employing, applying, evaporating, or drying any photochemk:;ally reactive

SAINT GOBAIN PERFORMANCE material, or substance containing such photochemically reactive material, the

PLA5TlCS 1667060007 Portage PTlO R007, ROO8 5/18/2010 (G) permittee shall not discharge more than 40 pounds of organic material into the

abnosphere in anyone day, nor more than 8 pounds of organic material in anyone

hour.

Each day that a photochemically reactive material {as defined in OAC 3745-21-

01 (C)(5)] is employed, the organic compound (OC) emissions from all coatings and

dba Yutzy's Finishing OZ38ooo158 Holmes PTIO Rool, RooZ 1/16/2007 (G)(2) photochemically reactive cleanup material shall not exceed 8 pounds per hour and 40

pounds per day. OC emissions from cleanup material that is not a photochemically

reactive material shall not be included in showing compliance with these emission

Imitations.

Champion Graphics 1431070383 Hamilton PTlO R001- ROO6, ROO8 5/20/1994 (G)(2) Only non-photochemically reactive materials shall be employed in this emissions unit. Corporation

50f7
Permits Issued 1/1/2008 to 9/1/2010 Referencing OAe Rule 3745-21-07

Attachment A

LeSS:

Permit Issuance 21-07 Strirtprrt • EU's Applicable .EU's Unit Applicable Applicable # EU's Applk:able Applicable

Facility Name Facility 10 County Name Permit Type Number Date Searched? IY/N)? T-hanBAT1 Applicable Unit Numbers P.afaeraph Applicable Numbers Date Paragraph Applicable Unit Numbers Dat. Pafaeraph Comments

P001 • The OC emissions from this emissions unit shall not exceed 40.0 IbsJday; P004-

PQ11 - (2) Prior to employing any photochemically reactive material in this emissions

DAYTON POLYMERIC 0857043129 Montgomery PliO POO93066 05/06/2009 POOl, POO4· POO9 4/2'/2004 (G)(2) unit, the permittee shall provkte written notification to the Director (the appropriate

PRODUCTS District Office or local air agency). Such notifICation shall include information sufficient

to determine compliance with the emission Imils and/or control requirements specified

in OAG rule 3745-21-07(G).

Heritage Fireplace Equipment 1677010272 Summit PTIO KOO9 IG)(2) BAT more stringent than 21-07 Co.

OAe rule 3745-21-07(G)(2) does not apply because the emissions unit is not involved

Bulk Molding Compounds, Inc. 0387040001 Wood PTI in ~employing, applying, evaporating or drying" photochemically reactive material

(Ohio Supreme Court's decision in Ashland Chemical Company vs. Jones (2001), 92

Ohio St. 3d 234 .

POO4, POB,

OMNOVA Solutions Inc. 16670ססoo7 Portage PTIO P014, PI06, (G)(2)

PllD, PHS

To avoid the emission limitations/control requr-ements contained in OAe rule

longaberger Company 0660000111 Muskingum Pn POI04103 04/24/2009 R005 IGII2) 3745-21-07(G)(2), no photochemk:ally reactive materials (Le., as coatings or cleanup

materials shall be em I ad in this emissions unit.

Honda of America Mfg., Inc., POO4, P330, K221, This emissions unit shall use only nonphotochemically reactive materials or materials

Marysville Auto Plant 0180010193 Union PTI POI04S33 04/20/2009 1<222 (G) exempt per OAC 3745--21·07(G)(9)· for antispatter material and cleaning solution

usa e.

Honda of America Mfg., Inc., This emission unit is exempt from the emission Imitation of OAC rule 3745--21·

0180010193 Union Pn POl04487 04/20/2009 P313 IG) 07(G)(2) when employing only non-photochemical reactive materials or material Marysville Auto Plant exem t under 3745--21·07 G 9.

R. R. Donnelley & Sons 0339030135 Huron PTI P010480S 04/20/200. The use of photochemically reactive materials, as defined in OAC rule 3745--21-01 , in

Company this emissions unit is rohiblted.

The requrementof OAC rule 3745--21-07(G)(1) that OC emissions shall not exceed 3

Autoplas 0339010151 Huron PTIO POO87246 04/17/2009 R013 IG)(2) pounds per hour from curing oven operations is less stringent that the emission

limitation of 2.64 pounds OC per hour for the entire coating line established pursuant

to OAC rule 3745-31-05 A 3.

To avoid the emission Imitations/control requirements contained in OAC rule

Longaberger Company 06601XlOl11 Muskingum PTI POI04102 04/17/2009 22 K033 - KOS4 (G)(2) 374S-21-07(G)(2), no photochemically reactive materials (i.e., as coatings or cleanup

materials shall be em I ed in this emissions unit.

This emissions unit currently does not employ any photochemically reactive materials

St. Bernard Soap Company 1431394137 Hamilton Pn POI04582 04/14/2009 as defined in OAC rule 3745--21·01(C)(S). tt is therefore, exempt from all emission

limitations and control requirements contained in OAC rule 374S-21-07(G).

Honda of America Mfg., Inc., This emission unit is exempt from the emission Imitation of OAC rule 3745-21·

0180010193 Union PTl POI04402 04/09/2009 P348 IG) 07(G)(2) when employing only non·photochemical reactive materials or material Marysville Auto Plant exam t under 3745--21-07 G 9.

It should be noted that OAC rule 3745-21·07(G)(2) does not establish any

Allied Moulded Products, Inc. 0386010104 Williams PTI P0103672 03/24/2009 requirements for this emissions unit due to the restriction prohibiting the use of

hotochemicall reactive material see c 2 .

Organic compound (OC) emissions shall not exceed 8 pounds per hour from coating

materials (resins and gel coats, excluding cleanup materials). Organic compound

(OC) emissions shall not exceed 40 pounds per day from coating materials (resins

and gel coats, excluding cleanup materials). (1) The permittee shall employ coating

Plas--Tanks Industries, Inc. 1409040850 Butler PTI POD1- POO6 2/25/2003 IG)(2) materials (resins and gel coats) with a combination of resin or gel coat type (vapor

suppressed or non-vapor suppressed), organic compound content, method of

application, and usage Quantity that are suffICient to comply with the allowable OC

emission Imitations specified in b)(1) of the terms and conditions of this permit and as

required by OAG rule 3745-21-07(G)(2).

This emissions unit currently does not employ any photochemically reactive materials

St. Bernard Soap Company 1431394137 Hamilton Pn as defined in OAC rule 3745--21-01 (C)(S). It is therefore, exempt from all emission

Imitations and control requirements contained in OAC rule 374S-21-07(G).

On any day when employing photochemically reactive materials to non metal parts,

Honda R&D North America 0180000156 Union PTI K005 3/16/2009 (G)(2) emissions shall not exceed 8 Ibslhr and 40 Ibs/day organK: compounds for the

Inc. coatings and photochemically reactive cleanup materials applied to the non metal

rts.

Helwig Enterprises Inc. 1409000699 Butler PTIO The use of photochemically reactive cleanup material as defined in OAC rule 3745--21-

01 C S is rohibited.

POOl, POD3, POO4,

BAKER Mc MILLEN COMPANY 1677110035 Summit PnO PODS, R002, R003, 3/5/2009 (GII2) The use of PRM not allowed.

ROO4

Spring Grove Resource 1431072600 Hamilton PTIO T012, T013, 10)(2) The control measure specified by this rule is less stringent than the control measures

Recovery Inc T014, T015, T017 specWied by OAG rule 3745-31-05(A)(3).

Spring Grove Resource 1431072600 Hamilton PTIO T016 (0112) The control measure specified by this rule is less stringent than the control measures

Recove In< S ecifled bOAC rule 3745-31·0S A 3.

Honda of America Mfg., Inc., To avoid the emission limitations/control requrements contained in OAC rule 3745--21-

0180010193 Union PTI 07(G)(2), only materials exempt per OAC rule 3745--21-07(G)(9) or non- Marysville Auto Plant photochemically reactive materials shall be applied to non-metal in this emissions unit.

Honda of America Mfg., Inc., This emission unit is exempt from the emission limitation of OAC rule 374S-21·

Marysville Auto Plant 0180010193 Union PTI 00104434 02/09/2009 P313 2/./2009 IG) 07(G)(2) when employing only non·photochemical reactive materials or material

exem t under 3745--21-07 G 9.

60f7
Permits Issued 1/1/2008 to 9/1/2010 Referencing OAe Rule 3745-21-07

Attachment A

2147

Permit Issuance 21-07 lEU's AppliCllb~ EquMoientto lEU's Un" Applicable Applicable lEU's Applicable Applicable

FllcilityName Facility 10 County Name Permit Type Number Date Searched? (Y/N)? Applicable Unit Numbers Paragraph BAn? Applicable Numbers Date Paragraph Applicable Unit Numbers Date Paragraph Comments

This emissions unit is not subject to the control requirements of OAe rule 3745-21-07

Creation Industries, LLC 0228000339 Geauga PTIO POO84642 02/03/2009 POOl IMII3I1b) (M)(3)(a) and 3745-21-07 (M)(3)(b), since the potential, uncontrolled organic

compound (Oe) emissions are no more than 40 pounds per day.

Emissions units K001, K002, K003, K004, and/or K005 shall become sUbject to OAe

rule 3745-21-07{G)(2) for each day when a photochemically reactive material is

Alpha Coatings, Inc. 0374010217 Seneca PTIQ POI04078 01/27/2009 KOO1- KOO5 1/27/2009 (GII2) applied to any non-metal substrate. On any such day, all emissions from both the

application of photochemically reactive and non·photochemically reactive materials

(coatings) on non-metal substrates are applicable to the requirement that OC

emissions shall not exceed 8 pounds/hour and 40 pounds/day.

The 8 pounds per hour and 40 pounds per day OC limitations apply to emissions

Pittsburgh Glass Works, LLC 0370000217 Richland PTiO (&17442 01/06/2009 P041 to P043 1/6/2009 IG)l2) associated the application of primer and adhesive materials. Emissions associated

with cleanup operations do not apply to the 8 pounds per hour and 40 pounds per day

OC limttations see c 2 .

It should be noted that OAC rule 3745-21-07(G)(2) does not establish any

Bridgestone APM Company- requirements for this emissions unit due to the restriction prohibiting the use of

0388010051 Wyandot PTi 03-17452 12/31/2008 (GII2) photochemically reactive material. The restriction on the use of photochemically Foam Products Division reactive material shall terminate on the date the U.S. EPA approves the rule

rescindment and new rule as a revision of the Ohio SIP.

Sigma Ohio tnc. PLT 3 formerly Ashtabula PTI P0103932 12/29/2008 R027 and R019 (G)l2) The daily emission limitation required by this applicable rule is less stringent than the

Picken's Plastics Inc. 0204000423 to R023 daily emission limitation established pursuant to OAC rule 3745--31-05(E).

The requirements established pursuant to this rule are less stringent than or

Pittsburgh Glass Works, LLC 0370000217 Richland PTlD POI03821 12/29/2008 P039 (G)l2) equivalent to the requirements of OAC rule 3745--31-05 (A) (3) because the perrnmee

does not always employ photochemically reactive materials in this emissions unit.

Each day, when photochemically reactive materials are not employed, the volatile

Carlisle Oak 0238000188 Holmes PTIO POI03675 12/04/2008 R001, R003 10/20/2005 (GII2) organic compound (VOC) emissions from art coatings shall nol exceed 19.74 pounds

per hour for each emissions unit. This emission limitation is based upon the maximum

application rate of 3.5 gallons per hour for each of emissions units R001 and ROO3.

Valley View Oak, LLC 0238000194 Holmes PTIO POO84799 11/26/2008 Y Roo1 to ROO6 6/27/2006 IG)l2) Organic compound (OC) emissions from each emissions unit shalt not exceed forty

40 unds erda ande' ht 8 ounds er hour.

Custom Hardwoods 0370010310 Richland PTIO P0100990 11/13/2008 R001 10/30/2007 IGII2) 81bso anic com oundslhr. 40.0 Ibs OC/da from coatin o erations

AL-CO Products, Inc. 0363000035 Paulding PTlO 03-0964-1 09/26/2008 POOl, Rool (GII2) The hourly emission limitation specified by this rule is less stringent than the hourly

and daily emission limitation established pursuant to OAC rule 3745--31-05(A)(3).

Each day when photochemically reactive materials are not employed in this emissions

Hobby Hilt Woodworking 0238062001 Holmes PTiD P0103809 09/04/2008 R001 9/4/2008 IGII2) unit, volatile organic compound (VOC) emissions from coatings shall not exceed 19.61

pounds per hour. This emission limitation is based upon the maxmum coating

a lication rate of 3.5 allons erhour.

AMERICAN TRIM LLC- 0306020025 Auglaize PTIO POI03619 08/12/2008 POO5, POO6 8/12/2008 (GII2) OC emissions shall not e)i£eed 8 pounds per hour and 40 pounds per day PRODUCT CENTER 4

Three Bond International, Inc. 0857103289 PTI 08·04nB 06/12/2008 KOOl- KOO5, K007, 12/5/2006 (GII2) On the days when coating nonmetal parts the Organic compound (OC) emissions Montgomery KOO8 from this emissions unit shalt not exceed 8 pounds per hour and 40 pounds per day.

BP-Husky Refining LlC 0448020007 Lucas PTI 04-01496 06/03/2008

Each day that a photochemically reactive material [as defined in OAC 374S~21-

Schlabach Wood Design 0616000217 Coshocton PTI 06-08334 05/01/2008 R001 5/1/2008 (G)(2) 01(C)(S)] is employed, the organic compound (OC) emissions from all coatings and

from photochemically reactive cleanup or thinner materials shall not exceed 8.0

ounds er hour and 40.0 ound erda.

AAP 5AINT MARYS CORP 0306010032 Auglaize PTI 03-17368 01/15/2008

Liteflex LLC - Maywood Ave. 0857043342 Montgomery PTI 08-04895 01/10/2008 The use of photochemically reactive materials, as defined in OAC rule 374S.21~

Facility 01 C 5, in this emissions unit is rohibited.

7of7
Attachment B

Spreadsheet - SMC Machines in Ohio
Attachment B

Permitted SMC Machines in Ohio

Title V Number SMC Installed Basis for Actual

County Attainment Status Facility of SMC Emissions Unit as New Source PTllssued Issuance Emission Emissions

__;.:'.::;d:::lity:.;N:;;.:::m;:;,e_-f_.:;co::';;;nty....+...:.;'.::;cil:::'ty:.;';;;.D;..-+_..1.:;0.;.;75;.;5;::"::.:;nd;:'::'d.;.)_+..(Y;.:./N;;:)~;;;m:::";;;h'::.:;ne:::'t-....':::D_-+_.:;(Y::.;/N:::I_+..(Y;.:./N;;:)~;.;PT.;.,N:.;;':::m;;;b:::e'+-.;D;;;";;.e~_....;A:::"O;;;w::.:::b'e:.O::;C/V;:.;.:O:;;c.,';Em:::':::·"::'o::.:;n':...._t- E:;;.m;;":::";;;on.;.:',:.o1:;;:o:;;.';;;c':::.':.::'e::;n';.:;'y;;;u::'e;;.d -+....;';::.01;::0.;.'_ 2008 (tons)

Actual Permitted Basis for

Emissions Allowable Allowable Controls

2009 {tons} .....:E::;m;;iss::;io::;n:.'....,~E:;;m;::":::sio:::n::.' -+.:E::;m:;;p':::oy:;ed::..r ...::co;::m::;m;.:e::;n":::/:;;M;::iSC:;;.. _

EF =the OC emission factor, in 0.0012 pound of styrene emissions

per pound of available styrene content, as determined from a Budd

Plastics Division study, as presented to the October, 1999

4/12/2005 81b hr/4O lb/day Composite Fabricators Association Conference.

Core Materials Coro Franklin 0125041046 Non-Attainment 84.0 POO7

Premix, Inc Ashtabula 0204000133 Non-Attainment (84.3) PD30 6/1/1981

P031 6/1/1981

P032 6/1/1989

Molded Fiberglass

Companies, Plant 2 Ashtabula 0204010230 Non-Attainment (84.3) PDQ7 1/1/1980

2ehrco Plastics, inc. (Plant

2) Ashtabula 0204010265 Non~Attainment 84.3} PDQl 1/1/1985

POO4 6/1/1987

Continental Structural

Plastics of Ohio llC aka CSP

OH Ashtabula 0204020245 Non-Attainment (84.3) POOl No-6/1/72 02-18224

OC Emissions 44.2 Ib/da

BAT limit - Organic compound (OC)

emissions shall not exceed 60 Ibs/day and

10.95 tons/year, including emissions from

the cleanup materials.

8/40, 10.95 tons/yr

8 Ib hr/4O Ib/dav

EF =emission factor for styrene emissions from compounding

machines, which is 0.001 pounds per pound of available styrene, as

determined from en ineering estimates.

The overall control efficiency (capture and control) for the

organic compound emissions employed in this emissions unit

shall be at least 85%, by weight. The control efficiency of the

____-f t-----!_--1thermal incinerator shall be at least 90%, by weight

40 Ibs/day and 7.3

1.98 1.56 'py 5tackTest

81b hr/4O lb/day Emission Factor

3.17 5.58 8 Ib hr/4O Ib/day Emission Factor

literature 2.32 2.34

P027 5/1/2002

Organic compound (OC) emissions shall not

exceed 261.1lbs/week from cleanup/purge

operations. DC emissions shall not exceed the styrene emissions factor, in 0.00389 pound ofstyrene emissions

14.09 tons/year from production per pound of available styrene content, as determined from results

operations and from cleanup/purge of U.S. EPA Methods 204, 204B and 2040 tests, conducted on

02-16224 4/12/2005 operations. November 18, 2004.. test 1.76 1.69

CSP - POOl and P002 are the only two uncontrolled SMC

Continental Structural machines in Ohio exceeding the 40 Ibs./day (7.3 tpy)

-"P"""""'''''''-- -Fv.'''n-'w'''e"rt_-fD3,,8:::'0'''2oo='7'-----fA'''tt'''.i'''nm'''e"'nO.!t("'73"'.3"-1__+---'_+---"_+---;;::=:_t-.:;:~7.:7.j~'"':;:;:-II--:---t-;:;;;~~;;~:;:::2~;c:+;':j;:;:"~~;;;~~;;;~+-----------+-----------------+----t-:;::'":~~9-f_::,~".~66:'8_!- !- -I-__---jlimitation

POO9 2/1/1997 POI05926 5/4/2010 4.67 4.71

Total Number of SMC Machines: 12 Actual Emissions Statewide (from Stars2 database) ; 37.4 35.9

Potential Uncontrolled Maximum under 3475-21-07 (= 9 uncontrolled machines X7.3 tpy): 65.7 65.7

Potential Max under 3745-21-25 (= 9 uncontrolled machines X25 tpy): 225 225

Hypothetical Worst case Maximum Increase (21-25 Max - 21-07 max): 159.3 159.3

Actual Offsets Needed (Actual Emissions from CSP in Van Wert county - 7.3 tpy) : 8.9 5.4 (7.15 tpy avg.)
Attachment C

Spreadsheet - Offset Calculations
Attachment C

Offset Calculation Using Arcelor/Mittal*** NOx Reductions for VOC Offsets from SMC Machines

2003 Emission Rate (Stack Test):

2010 Emission Rate (RACT):

0.55 Ib/mmbtu

0.29 Ib/mmbtu

8 County total NOx emissions including Mobile (2005 EIS):

8 County total VOC emissions including Mobile (2005 EIS):

138,114 tons

101,596 tons

RACT Emission Reduction (2003 rate - 2010 rate): 0.26 Ib/mmbtu Ratio: 1.36 NOx!VOC

Boiler Number

Emissions Using Actual Gas Burned (mmcf)*

2007 2008 2009

2010 Emission Factor Actual Actual Actual

(Stack Test) (mmcf) (mmcf) (mmcf)**

Average Reduction using 2010 stack test data:

Offsets after NOx!VOC ratio applied:

Total Gas Burned at Facility:

Actual NOx Emissions Reduction (tons) using 2010 Stack Test Factor:

1364 320

1260 244

1564 325

4188 889

629.08 132.21

462.75 97.26

454.25

1581

1540

775

445.74

3896

605.96

0.29

0.18

0.29

P046

P047

P048

Reduction Using RACT Emission Reduction Factor: 519.142 558.051 118.45925

Offsets after NOx!VOC ratio applied: 381.88 410.50 87.14

Average Reduction using RACT Emission Reduction: 1- 396.191

*: Source Stars2 Emissions Report

**: Facility was down due to the recession and for maintenance in 2009, Numbers are not included in averages,

***: Facility ID - 1318001613