p.1 

OAR Box 1394 

Prepped by Ollie Stewart 

Document Number: 

24) II-B26 

Docket Number: 

A-94-52 

Printed 7/3/2008 8:19:45 AM Sheet 24 of 56 
p ? 

' » \ 

/T-6 -SL4 

FINAL TRIP REPORT 

NONCONFIDENTIAL VERSION BASED ON PLANT COMMENTS 

MEMORANDUM 

TO: 

FROM: 

DATE: 

SUBJECT: 

REFERENCE: 

Project file of Reinforced Plastics Composites Manufacturing NESHAP 

Keith Barnett, U. S. Environmental Protection Agency, Emission 

Standards Division 

December 28, 2000 

Site visit to A.R.E. Inc. 

Reinforced Plastics Composites Manufacturing NESHAP, ESD Project 

No. 93/58 

INTRODUCTION AND PURPOSE 

The purpose ofthis visit was to obtain information on the reinforced plastic 

composites manufacturing operations at the two A.R.E. Inc. facilities located in 

Ohio. Specifically we wanted to focus on the capture and control of emissions 

from these processes. 

II. 

UI. 

PLACE AND DATE 

A.R.E. Inc. 

500 Nave Road 

Massillon, Ohio 44648 

330-830-7800 ext. 201 

February 16, 2000 

ATTENDEES 

HJN 2 6 2001 

EFAAIR[:C",<ET 

Mr. Ralph Gatti, A.R.E. Inc. 

Mr. Chuck Taylor, GT Environmental, Inc. (consultant to A.R.E.) 

Mr. Keith Barnett, U. S. Environmental Protection Agency 

Ms. Melanie Proctor, Pacific Environmental Services (contractor for USEPA) 

IV. SITE INFORMATION 

This site visit covered two facilities, the manufacturing facility in Massillon, Ohio, and the 

facility in Mount Eaton, Ohio. The company had prepared a detailed response to a list of 

questions for both facilities prior to the site visit. This information is included as attachments 1 

1 
P.3 

and 2. Subsequent to the site visit, A.R.E provided additional information in a letter dated 

February 23, 2000. This included information on the two stack test reports, permit information, 

and a determination from Entropy (the company that performed the emissions test) that the exit 

tunnel from the laminating area is not a natural draft opening. This information may be found as 

Attachment 3 to this trip report. 

A.R.E originally had one facility in Mount Eaton. The Ohio EPA has a rule 

(Rule 21-07(G)(2)) that limits organic compound emissions from any one source to 40 pounds 

per day and 8 pounds per hour, or requires 85 percent control. The Mount Eaton facility could 

not meet that requirement without either reducing production by 2/3, or retrofitting add-on 

controls. A.R.E. decided that using add-on controls was the best solution, and that building a 

new facility designed to meet these requirements would be easier that trying to retrofit the Mount 

Eaton facility with add-on controls. They also needed to expand their production space. 

The decision to build the new facility was made in January 1994. At that time A.R.E. was 

a small business with less than 300 employees. The company is now a large business with over 

500 employees. The emissions from the Mount Eaton facility in 1993 (based in toxic release 

inventory reports) were 48 tons per year (tpy) of styrene and 74 tpy of total HAP. In 1994 

eniissions were 63 tpy of styrene and 91 tpy of total HAP. In 1995 emissions were 57 tpy of 

styrene and 70 tpy of total HAP. The other HAP emitted are from painting operations. In 

August, 1995 the Massillon facility started up. 

Due to the size ofthe new Massillon facility, Ohio EPA required all major processes to 

meet a 95 percent emission reduction requirement. Processes that do not meet the 95 percent 

requirement meet the 40 lb/day and 8 lb/hr requirement of Rule 21-07(G)(2). 

The original plan was to curtail operations at the Mount Eaton facility to the point where 

the facility would meet Ohio EPA rules once the Massillon facility started up. However, due to 

company growth, A.R.E. needed to keep the Mount Eaton facility operating. So they decided to 

retrofit add-on controls at the Mount Eaton facility. This retrofit was completed in 1999. 

Massillon Facility 

This facility produces caps for pick-up trucks. Figure 1 presents a process flow diagram 

for this facility. Emission points in Figure 1 identified by P are process operations. Emission 

points identified by "Z" are exempt from Ohio permitting requirements. Emission points identified 

by "K" are coating operations. Figure 1 also shows the portions ofthe process that are contained 

in a permanent total enclosure (PTE). Table 1 presents size and airflow information on specific 

production areas. 

Molds are stored next to the lamination area. A mold is taken from storage through mold 

maintenance, mold cleaning and release application, and then enters the lamination area through 
Figure 1. A.R.E., Inc. Massillon Facility General Process Flow Diagram as of 

February 11,2000. 

P002 

Fiberglass 

Spray-Up #1 

Geicoat 

(drums) 

Catalyst 

Defective 

Parts 

Returned 

P003 

Fiberglass 

Spray-Up #2 

P001 

Exterior 

Geicoat 

Waxed 

Part Mold 

Regenerative Thermal Oxidizer 

(RTO) 

Z307 

Repair 

Sanding 

Booth 

(Returns) 

Z308 

Paint Repair 

Booth 

(Returns) 

Repaired 

Parts 

P010 

Paint Mix Room 

P005 Paint Gun Cleaners 1-4 

K001 

Paint Spray 

Booth #1 

K002 

Paint Spray 

Booth #2 

K003 

Paint Spray 

Booth #3 

K004 

Paint Spray 

Booth #4 

Fiberglass 

Part 

P011 

Mold Cleaning 

and Release 

Application 

Booth 

Z318 

Railing 

Installation 

Paint Gun Cleaners: 

Z310,Z311,Z312,Z313 

Located throughout the shop 

Z301 

Mold 

Maintenance 

Z303 

Fossliner 

Booth 

Each Booth is an Enclosure 

Painted 

Part 

Z302 

Touch-Up 

Area 

Z314 

Railing 

Adhesive 

Applicaiton 

Z315 

Gluing Station 

Pelxus 

Material 

Z316 

Rubber Seal 

Application 

(Lids) 

Z317 

Plastic Trim 

Application 

(Lids) 

P006 & P007 

Sanding & 

Grinding 

Lids & Caps 

Z309 

Paint Repair 

Sanding and 

Grinding 

Booth 

P009 

Final Prep 

Area 

Z319 

Final 

Assembly 

Area 

*• 

j*. 
TABLE 1. A.R.E., INC, MASSILLON FACILITY PTE AND SPRAY BOOTH DESIGN 

INFORMATION. 

PTE Description 

Mold Maintenance 

Resin Mix Room 

Glass Room 

Geicoat Booth 

Geicoat Tunnel #1 

Laminate Room 

Resin Tunnel #2 

Exit Tunnel #3 

Total from Glass Room 

Paint Booth #1 

Paint Booth #2 

Paint Booth #3 

Paint Booth #4 

Paint Mix Room 

Total to RTO* 

Length 

(ft) 

30 

28.67 

164.67 

25.33 

78.67 

68 

78.67 

84 

|f"" " 

54 

54 

54 

54 

38.67 

Width 

(ft) 

18 

20.67 

68 

19 

11 

28 

10 

10 

13 

13 

13 

13 

20 

Height 

(ft) 

11 

22 

27 

9.25 

8.75 

11.25 

8.75 

8.75 

11 

11 

11 

11 

13.67 

Volume 

(cuft) 

5,940 

13,037 

302,334 

4,452 

7,572 

21,420 

6,884 

7,350 

»>»|^||| | 

7,722 

7,722 

7,722 

7,722 

10,572 

Exhaust 

(cfm) 

8,700 

900 

'T'-'-CB:-'*CY-*- -

13,500 

6,600 

14,940 

6,500 

8,700 

50,240 

12,500 

12,500 

12,500 

12,500 

1,000 

109,940 

Air Exchanges 

(#/min ) 

1.5 

0.1 

~ :7$&'4-;?>,;:/ .W.^it-'J-V'i 

3.0 

0.9 

0.7 

0.9 

1.2 

' . - *V C 

1.6 

1.6 

1.6 

1.6 

0.1 

Openings 

Description 

17@(1.5x1.5) 

None 

4 @ (5x2); 1 @(10x4) 

1 @ (16x6.67) 

2 @ (11x4) 

2 @ (10x8); 1 @(20x 

2 @ (10x4) 

2 @ (10x4) 

•i * 

i r T 

None 

None 

None 

None 

None 

Area 

38.25 

N/A 

40.0 

106.7 

88.0 

320.0 

80.0 

80.0 

•_ 

N/A 

N/A 

N/A 

N/A 

N/A 

Comments 

This unit is under construction 

Exhausts into Glass Room 

NDOs are 4 louvered air intake ducts in roof 

Opening inside Glass Room 

Openings inside Glass Room 

Openings inside Glass Room 

Openings inside Glass Room 

One opening inside and one NDO outside 

Each booth consists of a separate painting 

room and curing oven. 

Includes Mold Maintenance, Glass Room, 4 Paint Spray Booths and Paint Mix Room. 

02/15/2000 

*• 
P.6 

a tunnel. The tunnel entrance has a roll up door that is closed unless a mold is being moved into 

the tunnel. A mold cleaning and release spray booth that will be ducted to the regenerative 

thermal oxidizer (RTO) was under construction at the time ofthe site visit. This booth will be 

inside the PTE and will be assumed to meet 100 percent capture. Some minor mold repairs are 

performed in the mold maintenance area (Z301). 

The lamination area consists of two spray booths. The first is the gel coat booth (P001) 

where the gel coat is applied to the mold. The second is a long laminate spray booth (68 feet x 

28 feet) where two layers of laminate are applied using atomized spray-up (chopper guns) at two 

different stations (P002 and P003). The resin contains 36 percent styrene, and the gel coat 

contains up to 38 percent styrene by weight. However, the facility calculates their potential to 

emit assuming a 42 percent resin HAP content because their air emissions permit allows them to 

use resin with up to 42 percent styrene. The air exchange rates are 3 per minute in the gel coat 

booth and 0.7 per minute in the laminate spray booth. Roll-out ofthe first layer of laminate takes 

place between spray-up area #1 and #2. Roll-out ofthe second laminate layer takes place outside 

the spray booth but within the PTE. After roll-out the parts exit the PTE through a 84 foot 

tunnel. The resin cure time is approximately 90 minutes. Curing ofthe resin is completed in the 

exit tunnel. The tunnel itself is vented to the RTO. For this reason, the tunnel exit is not 

considered a natural draft opening (NDO) (See Attachment 3). At the time ofthe visit, the 

facility was making improvements to the seals on the bottoms ofthe roll-up doors. 

The resin and gel coat spray booths were designed to meet OSHA requirements for 

worker exposure. There were no special provisions made in the design ofthe spray booths 

because they were going into a permanent total enclosure. As shown in Figure 1, the facility met 

the requirements for a PTE by building a wall around the lamination area where the spray booths 

are located. The walls are cinder block walls that reach from the floor to the building roof. The 

roof is 27 feet above the floor. There are vents that route air from the PTE to the RTO in the 

roofs ofthe three spray booths (P001, P002, and P003), the gel coat tunnel, the resin tunnel, and 

the exit tunnel. The only natural draft openings (NDO) are 4 louvered air intake ducts high in the 

walls near the roof. These NDO open inside the building. More specific design information in the 

booths and enclosures may be found in attachment 1. The PTE design was done by Q Source in 

Cincinnati, Ohio, and GT Environmental. 

The PTE is not air conditioned. There are 4 air makeup fans that have maximum flow 

rates of 40,000 cfin each. The air flow is sufficient to maintain an acceptable interior temperature. 

The temperature in the lamination area in summer is approximately the same as the outside 

ambient temperature, except that it lags an hour or so behind outside temperature changes. In the 

summer the temperature can reach the 90s. In winter the makeup air is heated. 

After the parts exit the tunnel, railings and other parts are added and they are painted in 

one of 4 spray booths. The paint spray booths are also vented to the RTO and also meet the 

requirements of EPA Method 204 for a PTE. Each spray booth has two zones, a spray zone and 

a oven zone. Parts remain in the spray booths for approximately 44 minutes, of which 22 minutes 

is paint application and 22 minutes is paint drying. The part does not exit the spray booth until 

the paint is completely dry. All operations subsequent to the lamination area will not be covered 
P.7 

by the reinforced plastic composites NESHAP. The painting operations will be covered by the 

plastic parts coating NESHAP. 

Resin and gel coat use for the Massillon facility in 1997 were 3,539,728 and 584,866 

pounds respectively. The RTO operates at all times the facility operates. The RTO had an 

average destruction efficiency of 98.27 percent during a December 1995 test. The state permit 

requires a 95 percent destruction efficiency. At the same time the testing company certified that 

the enclosure meet the requirements of EPA Method 204 for a PTE. 

The emissions at the RTO inlet were measured as 69.27 pounds per hour as carbon in the 

1995 test. Approximately 57 percent ofthe mass flow to the RTO is styrene from the open 

molding operations. The remainder is various solvents from the painting operations. The inlet 

concentration to the RTO was 431 ppm. The relative air flows are 50,240 acfm from the open 

molding operations and 51,000 acfm from the painting operations. Note that all paint spray 

booths cannot operate in the spray mode at the same time if all other units are operating. 

This facility was retested on June 12, 2000. The RTO again met the 95 percent 

destruction requirement and the PTE was again certified as meeting the requirements of EPA 

Method 204. 

There are two resin storage tanks located inside the building that vent to the RTO. There 

are three tanks in the closed resin mix room. The tanks vent into the room, and the room vents 

into the lamination area PTE. 

The add-on controls allow the facility to have flexibility in their operations. They can use 

higher solvent paints and higher HAP resins than would be allowed if they did not have the addon controls. Worker exposure to styrene in the lamination areas was recently measured as 116 

ppm for the chopper gun operator when spraying is actually taking place. That is about 20 

percent ofthe time. Concentrations for other workers in the spray booths were 43 ppm. This 

facility meets the voluntary OSHA standard of 50 ppm for an 8-hour average. The spray gun 

operators wear respirators with charcoal filters as a precautionary measure. Any other workers 

with any exposure to 50 ppm or more of styrene are also required by company rules to wear 

respirators. 

This facility does not use any flow coaters or fluid impingement technology to apply resin. 

The stated reason was they believe that flow coaters do not work well when you have vertical 

surfaces. 

Startup from the weekend shutdown begins on Sunday at 8:00 pm arid takes about 2 

hours. The RTO typically operates at 1500° F, but is allowed to go as low as 1450° F. They do 

not have continuous emission monitors on the RTO, they must continuously monitor the RTO 

temperature. 

The original capital cost and operating costs ofthe system are shown in attachment 1. 

The cost impact ofthe control device did increase the prices for the truck caps. 
P.8 

The biggest technical challenge for the control system is properly balancing the air flow. 

You must keep the enclosure under negative pressure. However, too much negative pressure in 

the enclosure makes the equipment work harder then necessary to maintain the airflow out ofthe 

enclosure. The dampers for the air handling system are controlled from the RTO control room. 

Mount Eaton Facility 

The Mount Eaton facility does custom molding and produces the tools for both Mount 

Eaton and Massillon. This facility is about 1/3 the size of Massillon on a square footage basis. 

The types of parts produced at Mount Eaton include rooftop carriers, tanneau covers, and 

equipment covers. At one time they also produced custom car bodies. The largest part size is 

approximately 12' x 4' x 4'. Though this facility is 1/3 the size of Massillon in a square footage 

basis, it uses less than 1/3 ofthe amount of resin used at Massillon. In 1997 (prior to the 

installation ofthe RTO), this facility used 174,622 lb. of resin and 16,555 lb. of gel coat, which 

were less than 5 percent of total materials used by A.R.E. 

This facility was the original facility for A.R.E. that evolved from a one room area. Based 

on the success ofthe control system at the Massillon facility and the need to accommodate 

growth, A.R.E. decided to retrofit Mount Eaton with controls. They do not consider retrofit to 

be technically challenging if sufficient floor space is available. They built PTE in the existing 

building and then moved existing spray booths inside the PTE. The control device at Mount 

Eaton was started up in March of 1999. 

Figure 2 presents the current facility layout and Table 2 presents design information on 

individual spray booths. More detailed design and cost information are presented in 

Attachment 2. 

There are three spray booths and a large component spray-up area in the PTE. One spray 

booth is for gel coat, and the other two are for resin application. Molds enter the PTE, and parts 

exit, through large roll-up doors. The doors are kept closed during normal operation. Because 

this is a much lower volume operation, tunnels to allow curing to be completed are not necessary. 

The Mount Eaton facility also has a resin transfer molding operation. This includes a gel 

coat spray booth. Neither of these operations is vented to the RTO. The resin mix room and 

mold fabrication areas also do not vent to the RTO. Molds for both the Massillon and Mount 

Eaton facility are fabricated at Mount Eaton. 

There are 4 paint spray booths at the Mount Eaton facility. These booths were present 

prior to the retrofit ofthe RTO. Each booth is a separate PTE. These booths do not have 
Figure 2. A.R.E., Inc. Mount Eaton Facility General Process Flow Diagram as of 

February 11,2000. 

Catalyst 

oo 

Geicoat 

(drums) 

Catalyst 

Total Enclosure -

R013 

Fiberglass 

Spray-Up #1 

R014 

Fiberglass 

Spray-Up #2 

R012 

Geicoat Booth 

Z129 

Mold 

Maintenance 

R016 

Large 

Component 

Fiberglass 

Spray-Up Area 

Regenerative Thermal Oxidizer 

(RTO) 

Paint Mix Room 

Z112-Z115 

Paint Gun Cleaners 1-4 

Plant #2 Mold Fabrication 

Z128 Sanding and Grinding 

R008- Geicoat and Primer Booth#1 

R009-Gelcoat and Primer Booth #2 

R010-Ceramic Spray-Up Area 

R011-Spray-Up Area 

R004 

Paint Spray 

Booth #1 

R005 

Paint Spray 

Booth #2 

R006 

Paint Spray 

Booth #3 

R007 

Paint Spray 

Booth #4 

Waxed 

Part Mold 

Z120 

Welding Area 

Fiberglass 

Part 

Z123 

Fossliner 

Booth 

Z121 

WoodShop 

P003 

Trim Booth 

P001 

RTM 

Equipment 

Z122 RTM 

Tank 

R003 

Geicoat Booth 

Z127 

Foam 

Sanding 

P004 

Sanding/ 

Grinding 

Booth 

Each Booth is an Enclosure 

t 

Painted 

Part 

Z116-Z117 

Paint Gun Cleaners 

Located throughout 

the facility 

R015 

Primer Booth 

P002 Prep 

Area 

Z126 

CNC Cutting 

Room 

*• 

co 
V 

TABLE 2. A.R.E., INC, MOUNT EATON FACILITY PTE AND SPRAY BOOTH DESIGN 

INFORMATION. 

PTE Description Length 

(ft) 

Width 

(«) 

Height 

(ft) 

Volume 

(cuft) 

Exhaust 

(cfm) 

Air Exchanges 

(#/min) 

Openings 

Description Area 

Comments 

Glassroom 85 75 25 159,375 1 @ (8 x 6.33); 1 @ (8 x 8) 114.6 NDOs for parts egress and mold ingress/egress 

Geicoat Booth 17.5 15 12 3,150 5,890 1.9 None N/A Opening inside Glass Room 

Geicoat Flash-Off Area 40 16 5,120 4,930 1.0 None N/A Open area within Glass Room 

Spray-Up #1 18 16 12 3,456 7,580 2.2 None N/A Opening inside Glass Room 

Spray-Up #2 18 16 12 3,456 7,980 2.3 None N/A Opening inside Glass Room 

Rollout Flash-Off Area 4,680 Open area within Glass Room 

Total from Glass Room mm 31,060 tymm&m :$m r«" 

VO 

Paint Booth #1 27 14 3,402 6,300 1.9 

Paint Booth #2 27 14 3,402 6,200 1.8 

Paint Booth #3 27 14 3,402 3,840 1.1 

Paint Booth #4 27 14 3,402 3,860 1.1 

None 

None 

None 

None 

N/A 

N/A 

N/A 

N/A 

All four paint spray booths have two modes (spray 

and bake). The flowrate in the bake mode is less 

than the spray mode. Either booth #1 or #2 is in 

the bake mode when all units are in operation. 

Paint Mix Room 28.5 8 10 2,280 1,000 0.4 None N/A 

Total to RTO* 50,000 

Includes Glass Room, 4 Paint Spray Booths and Paint Mix Room. Note that all four Paint Spray Booths cannot be in the "spray" mode when all other units are operating. 

02/15/2000 

o 
P.11 

separate spray and oven zones. Both operations take place in the same zone. Parts are kept in 

the PTE until dry. The paint spray booths and paint mix room vent to the RTO. 

Control Equipment Maintenance and Costs 

ARE. has a maintenance contract with Durr, the company who manufactured the RTO. 

Durr now has the responsibility for all maintenance ofthe RTO and receives a fixed fee every 

month. This gives Durr an incentive to keep the RTO operating as efficiently as possible to 

reduce maintenance costs. They also upgrade as necessary to balance resource use and equipment 

longevity. There is a Durr employee on site who covers both facilities. Durr can also 

troubleshoot RTO problems remotely through a modem. 

Prior to this contract, A.R.E performed maintenance themselves. A.R.E. personnel stated 

that they believe cost estimates for RTO rarely take into account repair costs for fans, and burner 

parts. A.R.E has fixed the life cycle costs over ten years as a result ofthe contracts with Durr. 

A.R.E. said that the cost of natural gas, and the total system pressure drop had increased over 

time. 

A.R.E. choose to use an RTO rather than a hybrid concentrator/oxidizer system because 

of concerns related to the technical feasibility of concentrators with styrene and multiple other 

VOC constituents. They also had concerns that, because ofthe variety of solvents in the painting 

operations, the performance ofa hybrid system might be more variable that a RTO alone. When 

A.R.E. retrofitted add-on controls at Mount Eaton, they saw no reason to change the type of addon control because the Massillon control system was working well, and the Mount Eaton facility 

also had styrene emissions and painting operations. 

10 
P.12 

f\ 44PH r\f^e,M"V 4-

A.R.E., Inc. 

Massillon, Ohio 

(Ohio EPA Facility No. 15-76-13-1793) 

Response to US EPA MACT Questions 

February 16, 2000 
P.13 

A.R.E., Inc. 

Massillon, Ohio 

(Ohio EPA Facility No. 15-76-13-1793) 

Response to US EPA MACT Questions - February 16, 2000 

1. ADD-ON CONTROL DEVICE TECHNICAL DATA 

a. Hazardous air pollutant (HAP) concentration at the inlet to the control device. 

Performance testing conducted at the Massillon facility in December 1995 demonstrated an 

average non-methane hydrocarbon (NMHC) concentration at the Regenerative Thermal 

Oxidizer (RTO) inlet of 431.3 ppm. This includes styrene emissions from composite 

fabricating processes as well as other volatile organic compound (VOC) and hazardous air 

pollutant (HAP) emissions from fabricating and painting operations. Individual HAPs have 

not been identified. 

b. Flow rate to the add-on control device. 

The December 1995 perfonnance test demonstrated an average flow rate to the RTO of 

90,531 actual cubic feet per minute (acfm). The RTO has been modified since that date with 

the installation ofa replacement ceramic bed. The current calculated inlet air flow rate to the 

RTO is 109,940 acfm. Additional performance testing is scheduled for the summer of 2000. 

That testing will provide data to confirm the current inlet flow rate. 

[Note: The RTO had a design inlet flowrate of 100,000 cfm as originally equipped. Recent 

changes to the ceramic bed have increased the design inlet flowrate to" 115,000 cfm.] 

c. Annual operating hours of the control device. 

A.R.E., Inc. estimates that the RTO will operate for approximately 6,100 hours annually. 

This is based on operating 24 hr/day for 5 days/week. 

d. Status of control device during non-operational hours. 

The Massillon RTO is shut down during non-production periods (weekends and holidays). 

e. Destruction efficiency test results on the add-on control device. 

The December 1995 performance test demonstrated an average destruction efficiency of 

98.27 percent (%). [Note: The state installation permit requires a 95% destruction efficiency.] 

f. Method of demonstrating continuous compliance with destruction efficiency 

demonstrated during testing (continuous emission monitoring systems (CEMS) or 

continuous parameter monitoring systems (CPMS), and parameters monitored if using 

CPMS). 

Page 1 of 7 
P.14 

Compliance with the destruction efficiency required by the construction permit (i.e., 95%) 

is demonstrated by the operation ofthe RTO at a temperature of 1,500°F. A continuous 

temperature recorder documents that this operating temperature is maintained. 

g. Is destruction efficiency testing required annually, every 5 years, or at permit renewal? 

Destruction efficiency testing was required by the original installation permit. This is the 

testing performed in December 1995. The Canton Air Agency has requested additional 

testing that will be performed in the summer 2000. A.R.E., Inc. expects a regular test 

schedule will be established in the Title V operating permit for the facility. 

2. ADD-ON CONTROL DEVICE COST DATA 

•XA^* - *J• U 

a. Add-on control device capital cost and year of cost data. ^ ,Tr ^ 

The total capital cost ofthe RTO was $1,463,000 (1995 dollars). <**^ 

b. Instrumentation cost, freight cost, and sales tax. t&f&o (*§ 

Instrumentation cost - $0 (no instrumentation purchased) 

Freight cost- $133,000 

Installation cost - $304,000 

Sales tax - A.R.E., Inc. received a state tax exemption for air pollution 

control equipment 

c. Electrical power consumption and cost associated with add-on control device operation. 

The RTO uses approximately 200 kW of power each hour during regular operation. The 

current cost is $.065277/kW hour. 

d. Fuel usage and cost associated with add-on control device operation. 

The RTO uses approximately 8,237 cf of natural gas each hour during regular operation. The 

current cost is $3.22/1,000 cf. 

e. Control device site preparation costs and building cost to house control device. 

The RTO was installed on a concrete pad adjacent to the production facility. The total site 

preparation costs for the RTO are estimated at $70,000. 

f. Control device maintenance costs. 

The maintenance costs ofthe RTO are estimated at $6,081 per month. 

g. Overhead, property tax, insurance, and administration cost associated with the add-on 

control device. 

Overhead - $3,500/yr 

Page 2 of 7 
P.15 

Property tax - A.R.E., Inc. received a state tax exemption for air pollution control 

equipment 

Insurance - $3,500/yr 

Administration- $19,500/yr 

h. Recordkeeping and reporting time and costs associated with the add-on control device, 

list of records and reports currently required, and time and costs to prepare these 

reports. 

Daily RTO inspections -

 lA hour per day x 254 days x $24/hr = $3,048/yr 

Malfunction Reports - 1 Vz hour x 12 events/yr x $24/hr = $ 432/yr 

[Note: A.R.E., Inc. assumes other significant monitoring, recordkeeping and reporting costs 

would be incurred regardless of the presence ofthe add-on control system (i.e., material 

usage rates and uncontrolled emissions rates).] 

3. CAPTURE SYSTEM TECHNICAL DATA 

Please refer to the general process flow diagram in Exhibit A for additional information related 

to the PTEs at the A.R.E., Inc. Massillon facility. 

a. Number of permanent total enclosures (PTEs) that capture HAP emissions. 

There are eight PTEs at the Massillon facility. The eight PTEs are: 

1. Glass Room (includes geicoat and fiberglass resin spray-up operations) 

2. Resin Mix Room (resin storage and mixing tanks) 

3. Mold Cleaning and Release Application Room (under construction) 

4. Four Paint Spray Booths 

5. Paint Mix Room 

[Note: The four Paint Spray Booths and the Paint Mix Room involve operations that are not 

included in the reinforced plastic composites MACT standard.] 

b. List of HAP emission points captured by each PTE 

Glass Room 

1. Exterior Geicoat Booth and flash-off tunnel 

2. Fiberglass/Resin Spray-Up #1 and flash-off tunnel 

3. Fiberglass/Resin Spray-Up #2 

[Note: Fabricated components are retained in the Glass Room until fully cured. Components 

exit the Glass Room through the exit tunnel.] 

Page 3 of 7 
P.16 

Resin Mix Room 

1. Neat resin day tank 

2. Mixing tank 

3. Mixed resin day tank 

[Note: Emissions from the Resin Mix Room are vented into the Glass Room.] 

Mold Cleaning and Release Application Room 

1. Mold cleaning and release application line 

Paint Spray Booths #1 - #4 

1. Each Paint Spray Booth consists of a paint room and curing oven. 

Paint Mix Room 

1. Paint mixing equipment 

2. Paint gun cleaning units 

c. List of HAP emission points not captured by PTEs 

All ofthe operations associated with the reinforced plastic composites MACT standard that 

have HAP emissions are captured by a PTE. 

The Paint Repair Booth and the Paint Touch-Up Af ea have HAP emissions associated with 

the application of paints (coatings) that are not captured by a PTE. These emissions units are 

not included in the reinforced plastic composites MACT standard. 

d. Dimensions of each PTE (length x width x height) 

Please refer to the table in Exhibit B. 

e. Dimensions of natural draft openings (NDOs) and face velocity across NDOs 

Please refer to the table in Exhibit B. 

f. Number of air changes per minute for each PTE 

Please refer to the table in Exhibit B. 

g. Measured HAP concentration (ppm) in each PTE 

Personal air sampling (OSHA) has identified styrene concentrations within the Glass Room 

in the range of 50 ppm. Styrene concentrations within the Geicoat Booth and the 

Fiberglass/Resin Spray-Up Booths can exceed 100 ppm. 

Page 4 of 7 
P.17 

h. Number and size of permanently open doors or any other openings in the PTE 

Please refer to the table in Exhibit B. 

i. Basic PTE materials (walls/doors/windows/ceiling/Iighting) 

Walls - concrete block and dry wall 

Doors - metal 

Windows - none 

Ceiling - metal 

Lighting - halogenated (explosion proof in the Exterior Geicoat Booth and 

Fiberglass/Resin Spray-Up Booths) 

j . Basic PTE safety equipment (LEL monitors/alarm bells/alarm signals) 

Airflow is sufficient to prevent unacceptable concentrations from building up in any PTE. 

None ofthe PTEs has any special safety monitoring equipment. 

k. Basic instrumentation (differential pressure monitor/surge protector/alarm) 

The inherent design of the PTE (fans and airflow) ensures that the required Airflow is 

sufficient to prevent unacceptable concentrations from building up in any PTE. None ofthe 

PTEs has any special safety monitoring equipment. 

I. Louvers/make-up air fan used with PTEs? 

Please refer to the table in Exhibit B. --

m. Air conditioning used with PTEs? 

Air conditioning is not needed. The air flow is sufficient to maintain an acceptable interior 

temperature. 

n. Does each PTE meet EPA Method 204 criteria for a PTE? 

Yes. Refer to the information and data from the December 1995 test report that documents 

the performance of each PTE (see Exhibit C). 

[Note: The Mold Cleaning and Release Application Booth is currently under construction. 

This PTE will be tested pursuant to Method 204 during the testing planned for the summer 

of 2000.] 

o. Capture efficiency test results or PTE determination on each PTE 

Refer to the information and data from the December 1995 test report that documents the 

perfonnance of each PTE (see Exhibit C). 

Page 5 of 7 
P.18 

p. Method of demonstrating continuous compliance with capture efficiency 

The RTO flowrate and other inherent design features of each PTE ensure that the PTEs 

continuously perform as demonstrated during the Method 204 testing. 

q. Capture efficiency testing required annually, every 5 years, or at permit renewal? 

Testing pursuant to Method 204 was required by the original installation permit. This is the 

testing performed in December 1995. The Canton Air Agency has requested additional 

testing that will be performed in the summer 2000. A.R.E., Inc. expects a regular test 

schedule will be established in the Title V operating permit for the facility. 

4. CAPTURE SYSTEM COST DATA 

a. Capital cost of PTEs and year of the cost data 

The total capital cost ofthe PTE for the Glass Room was $350,000 (1999 dollars). 

The total capital cost ofthe PTE for the Resin Mix Room was $250,000 (1999 dollars). 

The total estimated capital cost ofthe PTE for the Mold Cleaning and Release Application 

Room is $37,600 (1999 dollars). 

b. Incremental operating and maintenance costs of the PTEs 

The total annual operating cost ofthe PTEs for the Glass Room and Resin Mix Room is 

estimated at $6,500. 

The total annual operating cost ofthe PTE for the Mold Cleaning ancTRelease Application 

Room is estimated at $3,500. 

5. DUCTWORK TECHNICAL DATA 

a. Basic ducting materials 

The ductwork is steel, circular and non-insulated. 

b. Basic ducting configuration 

Refer to the drawings in Exhibit D. 

c. How is ductwork joined prior to add-on control device? 

Ring and bolt with sealed (caulked) joints. 

d. Measured/estimated/assumed velocity of gas stream in ductwork? 

The December 1995 performance test demonstrated an average velocity of 45.47 feet per 

second (fps) in the duct at the inlet ofthe RTO. Additional performance testing is scheduled 

for the summer of 2000. That testing will provide data to confirm the current inlet velocity. 

Page 6 of 7 
P.19 

[Note: The RTO had a design inlet flowrate of 100,000 cfm as originally equipped. Recent 

changes to the ceramic bed have increased the design inlet flowrate to 115,000 cfm. This 

will increase the average velocity at the inlet to the RTO to approximately 58 fps.] 

6. DUCTWORK COST DATA 

a. Capital cost to ductwork to vent emissions to the control device and year of cost data. 

The total capital cost ofthe ductwork, including installation, was $192,000 (1999 dollars). 

b. Freight cost and sales tax for ductwork. 

Freight cost- $8,000 (1999 dollars) 

Sales tax - A.R.E., Inc. received a state tax exemption for air pollution control 

equipment 

c. Incremental electrical power consumption and cost associated with duct fan operation 

due to installation of add-on control device. 

These costs are included in the RTO operating costs. 

d. Incremental ductwork maintenance costs due to installation of add-on control device 

Labor - 1 hr/week x 52 weeks/yr x $ 17/lir = $884/yr 

Parts- $2,000/yr 

e. Incremental ductwork overhead, property tax, insurance, and administration cost due 

to installation of add-on control device 

Overhead- $l,000/yr 

Property tax - A.R.E., Inc. received a state tax exemption for air pollution control 

equipment 

Insurance.- included in RTO cost estimate 

Administration - included in RTO cost estimate 

Pao;e 7 of 7 
P.20 

Exhibit A 

General Process Flow Diagram 
Resin Mix Room 

Catalyst Catalyst 

-Total Enclosure -

P002 

Fiberglass 

Spray-Up #1 

Geicoat 

(drums) 

Catalyst 

A.R.E., Inc. 

Massillon (Facility ID No.15-76-13-1793) 

General Process Flow Diagram 

February 11, 2000 

T.. i 

P003 

Fiberglass 

Spray-Up #2 

P001 

Exterior 

Geicoat 

Waxed 

Part Mold 

Regenerative Thermal Oxidizer 

(RTO) 

Defective 

Parts 

Returned 

2307 

Repair 

Sanding 

Booth 

(Returns) 

Z308 

Paint Repair 

Booth 

(Returns) 

Repaired 

Parts 

, P010 

Paint Mix Room 

P005 Paint Gun Cleaners 1-4 

K001 

Paint Spray 

Booth #1 

_i 

K002 

Paint Spray 

Booth #2 

K003 

Paint Spray 

Booth #3 

K004 

Paint Spray 

Booth #4 

T 

Fiberglass 

Part 

P011 

Mold Cleaning 

and Release 

Application 

Booth 

2318 

Railing 

Installation 

Z301 

Mold 

Maintenance 

T 

Paint Gun Cleaners: 

Z310.Z311,2312, Z313 

Located throughout the shop 

Z303 

Fossllner 

Booth 

Each Booth is an Enclosure 

Painted 

Part 

Z302 

Touch-Up 

Area 

Z314 

Railing 

Adhesive 

Applicalton 

Z315 

Gluing Station 

Pelxus 

Material 

Z3/I6 

Rubber Seal 

Application 

(Lids) 

Z317 

Plastic Trim 

Application 

(Lids) 

P006 & P007 

Sanding & 

Grinding 

Lids & Caps 

Z309 

Paint Repair 

Sanding and 

Grinding 

Booth 

P009 

Final Prep 

Area 

Z319 

, Final 

Assembly 

Area 

*• 
P.22 

Exhibit B 

Permanent Total Enclosure Data Table 
A.R.E., Inc. 

Massillon, Ohio 

Permanent Total Enclosures (PTE) Associated with Regenerative Thermal Oxidizer (RTO) 

PTE Description Length Width 

(ft) 

Height 

(ft) 

Volume 

(cuft) 

Exhaust 

(cfm) 

Air Exchanges 

(#/min) 

Openings 

Description Area 

Comments 

Mold Maintenance 30 18 11 5,940 8,700 1.5 17 @ (1.5x1.5) 38.25 This unit is under construction 

Resin Mix Room 28.67 20.67 22 13,037 900 0.1. None N/A Exhausts into Glass Room 

Glass Room 164.67 68 27 302,334 4 @ (5x2); 1 @(10x4) 40.0 

NDOs are 4 louvered air intake ducts in roof 

and the opening to the exit tunnel 

Geicoat Booth 25.33 19 9.25 4,452 13,500 3.0 1 @ (16x6.67) 106.7 Opening inside Glass Room 

Geicoat Tunnel #1 78.67 11 8.75 7,572 6,600 0.9 2 @ (11 x4) 88.0 Openings inside Glass Room 

Laminate Room 68 28 11.25 21,420 14,940 0.7 2 @ (10x8); 1 @(20x 320.0 Openings inside Glass Room 

Resin Tunnel #2 78.67 10 8.75 6,884 6,500 0.9 2 @ (10x4) 80.0 Openings inside Glass Room 

Exit Tunnel #3 84 10 8.75 

Total from Glass Room 

8,700 1.2 

50,240 

2 @(10 x 4) inside and one NDO outside 

Paint Booth #1 54 13 11 7,722 12,500 1.6 None N/A 

Paint Booth #2 54 13 11 7,722 12,500 1.6 None N/A 

Paint Booth #3 54 13 11 7,722 12,500 1.6 None N/A 

Paint Booth #4 54 13 11 7,722 12,500 1.6 None 

Paint Mix Room 38.67 20 13.67 10,572 1,000 0.1 

Total to RTO* 109,940 

* Includes Mold Maintenance, Glass Room, 4 Paint Spray Booths and Paint Mix Room. 

None 

N/A 

N/A 

Each booth consists of a separate painting 

room and curing oven. 

02/15/2000 

ro 
P.24 

Exhibit C 

Excerpts from December 1995 Test Report 
P.25 

INC. 

Specialists in Air Emissions Technology 

P.O. Box 12291 • Research Triangle Park, North Carolina 27709-2291 

(919)781-3550 • (800)486-3550 • Fax (919) 787-8442 

STATIONARY SOURCE SAMPUNG REPORT 

REFERENCE NO. 14900 

A.R.E., INC. 

MASSILLON, OHIO 

EMISSIONS TESTING FOR: 

DESTRUCTION EFFICIENCY 

CAPTURE EFFICIENCY 

REGENERATIVE THERMAL OXIDIZER 

DECEMBER 1995 
P.26 

A.R.E, inc. 

Massillon, Ohio EI-14900 

TABLE 2-1 

DESTRUCTION EFFICIENCY SUMMARY 

REGENERATIVE THERMAL OXIDIZER 

A.R.E.. INC 

DECEMBER 1995 

Run No. 

2 

3 

4 

Average 

Flow 

Rate 

(dscfm) 

87,930 

81,370 

88,668 

85.989 

INLET 

NMHC 

(ppmC) 

455.5 

448.7 

389.7 

431.3 

Emission 

Rate 

(IbC/hr) 

74.90 

68.29 

64.62 

69.27 

FlQW 

Rate 

(dscfm) 

113,343 

117,517 

117,075 

115,978 

OUTLET 

NMHC 

(ppmC) 

8.9 

2.1 

5.8 

5.6 

Emission 

Rate 

(IbC/hr) 

1.89 

0.47 

1.28 

1.21 

' • '-•;•• • • •''•-. , 

Destruction 

Efficiency 

(%) 

97.48 

99.31 

98.02 

98.27 
P.27 

AR.E, Inc. 

Massillon, Ohio El-14900 

TABLE 2-2 

VERIFICATION OF PERMANENT TOTAL ENCLOSURES 

A.R.E., INC 

DECEMBER 1995 

Source 

ID 

K001 

K002 

K003 

K004 

P001 

P002 

P003 

P004 

P005 

P010 

Description 

Paint Spray/ 

Cure Both #1 

Paint Spray/ 

Cure Both #2 

Paint Spray/ 

Cure Both #3 

Paint Spray/ 

Cure Both #4 

Geicoat 

Exterior Spray 

Fiberglass 

Spray #1 

Rberglass 

Spray #2 

Geicoat 

Interior Spray 

Paint Gun 

Cleaners 

Paint Mix 

and Storage 

NDO Area 

<5%of 

Total Area 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

All NDO >4D 

to VOC 

Emission Pt.~ 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes " 

Yes 

Yes 

Yes 

Yes 

All NDO >4D 

to Exhaust 

Duct 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Pressure 

Differential 

'.V(in*H20) 

-0.30 

-0.27 

-0.30 

-0.18 

-0.016 

" -0.016 

-0.016 

• -0.016 

-0.016 

-O.047 

; ,Alr Flow 

" Inward 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

2-3 
P.28 

TOTAL HYDROCARBON MEASUREMENT RESULTS SUMMARY 

PLANT NAME: ARE Inc., - Massillon, OH 

TEST LOCATION: Regenerative Thermal Oxidizer Inlet 

TEST DATE: 12/14/95 

OPERATOR: Lauren Sherwood 

THC Zero Gas 

Low-Level Gas 

Mid-Level Gas 

High-Level Gas 

0.0 

301.5 

508.5 

830.1 

1.3 

301.0 

507.9 

831.6 

ppmC values = pprnC3H8 values x 3 

Drif t Determinations 

Run Number I-M25A-2 I-M25A-3 

Zero Sys.Cal.Response 1.3 1.3 

Zero Drift Response 3.1 0.6 

Zero Drift ' 0.2 -0.1 

Upscale Sys.Cal.Resp. 507.9 507.9 

Upscale Drift Response 507.5 489.9 

Upscale Drift -0.0 -1.8 

0.13 

-0.17 

-0.12 

0.18 

************************ * 

Test Results-

* RUN NO.: 

Pre-Test 

SPAN VALUE: 

1,000 

(ppm as C) 

Calibration Error Check ---

CALIBRATION SYSTEM 

GAS VALUE CAL. ERROR 

(ppmC)* RESPONSE 

CAL. 

ERROR 

X 

* 

* 

* 

* 

* 

* 

/ 

RUN TIME: 

THC (ppmwC): 

XH20: 

I-M25A-2 I-M25A-3 

1535-1635 1802-1902 

445.0 438.4 

2.30 2.30 

* THC (ppmdC): 455.5 448.7 

* DSCFM: 87,930 81,370 

* 

* THC (lb/hr C): 74.90 68.29 

* 

**************** * ****** * 

ppmd = ppmw / (1-(XH2O/100)) 

lb/hr = (ppmd x DSCFM x 60 x Mol.Wt.) / 385.3 E06 

Where: Mol.Wt. Carbon = 12.01 lb/lb mole 

System Cal.Response - Cal.Gas Value 

Cal.Error = - x 100 

** Cal.Gas Value 

Drift Response - System Cal.Response 

Drift = x 100 

Span Value 

** For zero gas calibration error use span value 
P.29 

TOTAL HYDROCARBON MEASUREMENT RESULTS SUMMARY 

PLANT NAME: ARE Inc., - Massillon, OH 

TEST LOCATION: Regenerative Thermal Oxidizer Inlet 

TEST DATE: 12/15/95 

OPERATOR: Lauren Sherwood 

Pre-Test Calibration Error Check 

SPAN VALUE: CALIBRATION SYSTEM CAL. 

1,000 GAS VALUE CAL. ERROR ERROR 

(ppm as C) (ppmC)* RESPONSE X 

THC Zero Gas 

Low-Level Gas 

Mid-Level Gas 

High-Level Gas 

0.0 

301,5 

508.5 

830.1 

1.7 

305.3 

510.1 

829.3 

ppn-C values = ppmC3H8 values x 3 

Drift Detenninations 

Run Number I-M25A-4 

Zero Sys.Cal.Response 1.7 

Zero Drift Response 8.8 

Zero Drift 0.7 

Upscale Sys.Cal.Resp. 510.1 

Upscale Drift Response 479.7 

Upscale Drift -3.0 

0.17 

1.26 

0.31 

-0.10 

********* * *********** * 

RUN NO.: 

RUN TIME: 

THC (ppmwC): 

XH20: 

Test Results 

I-M25A-4 

1134-1234 

384.2 

1.40 

* THC (ppmdC): 389.7 * 

* * 

* DSCFM: 88,668 * 

* * 

* THC (lb/hr C): 64.62 * 

* * 

***************************** * 

ppmd = ppmw / (1-(XH2O/100)) 

lb/hr = (ppmd x DSCFM x 60 x Mol.Wt.) / 385.3 E06 

Where: Mol.Wt. Carbon = 12.01 lb/lb mole . 

System Cal.Response - Cal.Gas Value 

Cal.Error = '- x 100 

** Cal.Gas Value 

Drift Response - System Cal.Response 

Drift = - x 100 

Span Value 

** For zero gas calibration error use span value 
P.30 

TOTAL HYDROCARBON MEASUREMENT RESULTS SUMMARY 

PLANT NAME: ARE Inc., - Massillon, OH 

TEST LOCATION: Regenerative Thermal Oxidizer Outlet 

TEST DATE: 

OPERATOR: 

Pre-Test 

SPAN VALUE: 

100 

(ppm as C) 

THC Zero Gas 

Low-Level Gas 

Mid-Level Gas 

High-Level Gas 

12/14/95 

Calibration Error Check — 

CALIBRATION 

GAS VALUE 

(ppmC)* 

0.0 

29.9 

51.5 

83.8 

SYSTEM 

CAL. ERROR 

RESPONSE 

0.3 

30.0 

51.6 

83.5 

CAL. 

ERROR 

X 

0.30 

0.33 

0.19 

-0.36 

.* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

******** * 

RUN NO.: 

RUN TIME: 

THC (ppmwC): 

XH20: 

THC (ppmdC): 

DSCFH: 

THC (lb/hr C): 

ppmd = ppmw 

***** * 

0-M25A-2 

1535-1635 

8.9 

1.61 

8.9 

113,343 

1.89 

******** * 

0-M25A-3 

1802-1902 

2.1 

1.02 

2.1 

117,517 

0.47 

/ (1-(XH2O/100)) 

**** * 

* 

.* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

* 

ppmC values = ppmC3H8 values x 3 

Drift Determinations 

lb/hr = (ppmd x DSCFM x 60 x Mol.Wt.) / 385.3 E06 

Where: Mol.Wt. Carbon = 12.01 lb/lb mole 

Run Number 0-M25A-2 0-H25A-3 

Zero Sys.Cal.Response 0.3 0.3 

Zero Drift Response 

Zero Drift 

Upscale Sys.Cal.Resp. 

Upscale Drift Response 30.6 

Upscale Drift 

1.0 

0.7 

30.0 

30.6 

0.6 

0.8 

0.5 

30.0 

31.5 

1.5 

System Cal.Response - Cal.Gas Value 

Cal.Error = --- x 100 

** Cal.Gas Value 

Drift Response - System Cal.Response 

Drift = x 100 

Span Value 

** For zero gas calibration error use span value 
P.31 

TOTAL HYDROCARBON MEASUREMENT RESULTS SUMMARY 

PLANT NAME: ARE Inc., - Massillon, OH 

TEST LOCATION: Regenerative Thermal Oxidizer Outlet 

TEST DATE:

 - 12/15/95 

OPERATOR: Lauren Sherwood 

Pre-Test 

SPAN VALUE: 

100 

(ppm as C) 

THC Zero Gas 

Low-Level Gas 

Mid-Level Gas 

High-Level Gas 

Calibration Error 

CALIBRATION 

GAS VALUE 

(ppmC)* 

0.0 

29.9 

51.5 

83.8 

Check ---

SYSTEM 

CAL ERROR 

RESPONSE 

0.4 

29.7 

51.6 

82.9 

CAL. 

ERROR 

X 

0.40 

-0.67 

0.19 

-1.07 

.* ppmC values = ppmC3H8 values x 3 

Drift Determinations 

Run Number 0-M25A-4 

Zero Sys.Cal.Response 0.4 

Zero Drift Response -1.7 

Zero Drift -2.1 

Upscale Sys.Cal.Resp. 29.7 

Upscale Drift Response 30.3 

Upscale Drift 0.6 

************** * 

* RUN NO.: 

* 

* RUN TIME: 

* 

* THC (ppmwC): 

* 

* XH20: 

* 

* THC (ppmdC): 

* 

* DSCFM: 

* 

* THC (lb/hr C): 

* 

******** * 

-r Test Results0-M25A-4 

1134-1234 

5.8 

0.73 

5.8 

117,075 

1.28 

********** * ***** * 

ppmd = ppmw / (1-(XH2O/100)) 

lb/hr = (ppmd x DSCFH x 60 x Hol.Wt.) / 385.3 E06 

Where: Mol.Wt. Carjwn = 12.01 lb/lb mole* 

System Cal.Response - Cal.Gas Value 

Cal.Error = -*- x 100 

** Cal.Gas Value 

Drift Response - System Cal.Response 

Drift = T x 100 

Span Value 

For zero gas calibration error use.span value 
P.32 

VOLUMETRIC FLOU RATE DETERMINATION 

PLANT: A.R.E. Inc - Massillon, OH 

TEST LOCATION: RTO Inlet 

TEST DATE: 12-14-95 

Pbar 

Pg 

Ps 

ts 

Ita-p 

TRAVERSE 

Run Start Time 

Run Finish Time 

Net Traversing Points 

Barometric Pressure, Inches' Hg 

Flue Gas Static Pressure, Inches H20 

Absolute Flue Gas Pressure, Inches Hg 

Flue Gas Temperature, Degrees F 

Average Velocity Head, Inches H20 

Duct Area (A): 4778.4 

Pitot Tube Coefficient (Cp): . 0.84 

Percent 02 (X02): 20.9 

Percent C02 (XC02): 0.0 

Percent Moisture (XH20): 2.3 

OTHER 

OATA 

I-M2-3 

1530 

1540 

16 

29.80" 

-0.72 

29.75 

81 

0.7467 

DATA 

sq. inches 

X 02 

X C02 

X H20 

CALCULATIONS 

I-M2-4 

1700 

1710 

16 

29.80 

-0.70 

29.75 

83 

0.5786 

Average 

29.75 

82 

0.6627 

DRY MOLE FRACTION OF STACK GAS: 

Mfd = 1 - (XH2O/100) = 0.977 

DRY MOLECULAR WEIGHT OF STACK GAS: 

Md = 0.44(XCO2) '+ 0.32(X02) + 0.28(XN2) = 28.84 Ib/lb-mole 

WET MOLECULAR WEIGHT OF STACK GAS: 

Ms = (MdKMfd) • 0.18(XH2O) = 28.59 Ib/lb-mole 

AVERAGE STACK GAS VELOCITY: 

Vs = 85.49(Cp) X SQRT[(Pavg)(Ts + 460)/(Ps)(Ms)J = 46.67 ft/sec 

WET VOLUMETRIC STACK GAS FLOW RATE: 

Qaw = (60/144)(Vs)(A) = 92,920 ACFM 

DRY VOLUMETRIC STACK GAS FLOU RATE: 

Qsd = 7.353(Mfd)(Vs)(A)(Ps)/(Ts + 460) = 87,930 SCFM 
VOLUMETRIC FLOU RATE DETERMINATION 

PLANT: A.R.E. Inc - Massillon, OH 

TEST LOCATION: RTO Inlet 

TEST DATE: 12-14-95 

TRAVERSE DATA 

P.33 

I-H2-4 I-M2-5 

Run Start Time 

Run Finish Time 

Net Traversing Points 

Pbar Barometric Pressure, Inches Hg 

Pg Flue Gas Static Pressure, Inches H20 

Ps Absolute Flue Gas Pressure, Inches Hg 

ts Flue Gas Temperature, Degrees F 

Delta-p Average Velocity Head, Inches H20 

1700 

1710 

16 

29.80" 

-0.7 

29.75 

83 

0.5786 

1937 

1946 

16 

29.80 

-0.56 

29.76 

80 

0.5550 

Average 

29.75 

82 

0.5668 

OTHER DATA 

Duct Area (A): • 

Pitot Tube Coefficient (Cp): 

Percent 02 (X02): 

Percent C02 (XC02): 

Percent Moisture (XH20): 

4778.4 sq. inches 

0.84 

20.9 X 02 

0.0 X C02 

2.3 X H20 

CALCULATIONS 

DRY HOLE FRACTION OF STACK GAS: 

Hfd = 1 - (XH2O/100) = 0.977 

DRY MOLECULAR WEIGHT OF STACK GAS: 

Md = 0.44(XC02) + 0.32(XO2) -*• 0.28(XN2) = 28.84 Ib/lb-mole 

WET MOLECULAR WEIGHT OF STACK GAS: 

Ms = (Md)(Hfd) + 0.18(XH20) = 28.59 Ib/lb-mole 

AVERAGE STACK GAS VELOCITY: 

Vs = 85.49(Cp) X SQRTt(Pavg)(Ts + 460)/(Ps)(Hs)] = 43.14 ft/sec 

WET VOLUMETRIC STACK GAS FLOW RATE: 

Qaw = (60/144)(Vs)(A) = 85,892 ACFM 

DRY VOLUMETRIC STACK GAS FLOW RATE: 

Qsd = 7.353(Hfd)(Vs)(A)(Ps)/(Ts + 460) = 81,370 SCFM 

8 
VOLUMETRIC FLOW RATE DETERMINATION 

PLANT: A.R.E. Inc - Massillon, OH 

TEST LOCATION: RTO Inlet 

TEST DATE: 12-15-95 

TRAVERSE DATA 

P.34 

I-M2-6 I-M2-7 

Run Start Time 

Run Finish Time 

Net Traversing Points 

Pbar Barometric Pressure, Inches Hg 

Pg Flue Gas Static Pressure, Inches H20 

Ps Absolute Flue Gas Pressure, Inches Hg 

ts Flue Gas Temperature, Degrees F 

Delta-p Average Velocity Head, Inches H20 

1114 

1121 

16 

29.68" 

-0.95 

29.61 

80 

0.6748 

1256 

1304 

16 

29.68 

-1.13 

29.60 

78 

0.6524 

• • 

Average 

29.60 

79 

0.6636 

OTHER DATA 

Duct Area (A): 

Pitot Tube Coefficient (Cp): 

Percent 02 (X02): 

Percent C02 (XC02): 

Percent Moisture (XH20): 

4778.4 sq. inches 

0.84 

20.9 X 02 

0.0 X C02 

1.4 X H20 

CALCULATIONS 

DRY MOLE FRACTION OF STACK GAS: 

Mfd = 1 - (XH20/100) = 0.986 

DRY MOLECULAR WEIGHT OF STACK GAS: 

Hd = 0.44(XCO2) + 0.32(XO2) + 0.28(XN2) = 28.84 Ib/lb-mole 

WET HOLECULAR WEIGHT OF STACK GAS: 

Ms = (Hd)(Mfd) + 0.18(XH2O) = 28.69 Ib/lb-mole 

AVERAGE STACK GAS VELOCITY: 

Vs = 85.49(Cp) X SQRtt(Pavg)(Ts + 460)/(Ps)(Ms)] = 46.60 ft/sec 

WET VOLUMETRIC STACK GAS FLOW RATE: 

Qaw = (60/144)(Vs)(A) = 92,781 ACFM 

DRY VOLUMETRIC STACK GAS FLOW RATE: 

Qsd = 7.353(Mfd)(Vs)(A)(Ps)/(Ts + 460) = 88,668 SCFM 
VOLUMETRIC FLOW RATE DETERMINATION 

PLANT: A.R.E. Inc - Massillon, OH 

TEST LOCATION: RTO Outlet 

TEST DATE: 12-14-95 

TRAVERSE DATA 

P.35 

S-M2-3 S-M2-4 

Run Start Time 

Run Finish Time 

Net Traversing Points 

Pbar Barometric Pressure, Inches Hg 

Pg Flue Gas Static Pressure, Inches H20 

Ps Absolute Flue Gas Pressure, Inches Hg 

ts Flue Gas Temperature, Degrees F 

Oelta-p Average Velocity Head, Inches H20 

1527 

1535 

16 

29.8fJ 

-0.68 

29.75 

165 

0.8915 

1650 

1658 

16 

29.80 

-0.95 

29.73 

159 

0.9675 

Average 

29.74 

162 

0.9295 

OTHER OATA 

Duct Area (A): 

Pitot Tube Coefficient (Cp): 

Percent 02 (X02): 

Percent C02 (XC02): 

Percent Moisture (XH20): 

5541.8 sq. inches 

0.84 

20.8 X 02 

0.1 X C02 

1.61 X H20 

CALCULATIONS 

DRY MOLE FRACTION OF STACK GAS: 

Mfd = 1 - (XH20/100) = 0.984 

DRY MOLECULAR WEIGHT OF STACK GAS: 

Md = 0.44(XCO2) + 0.32(XO2) + 0.28(XN2) = 28.85 Ib/lb-mole 

WET MOLECULAR WEIGHT OF STACK GAS: 

Ms = (HdXMfd) + 0.18(XH20) = 28.68 Ib/lb-mole 

AVERAGE STACK GAS VELOCITY: 

Vs <** 85.49(Cp) X SORT[(Pavg)(Ts + 460)/(Ps)(Hs)] = 59.12 ft/sec 

WET VOLUMETRIC STACK GAS FLOW RATE: 

Qaw = (60/144)(Vs)(A) = 136,513 ACFM 

DRY VOLUMETRIC STACK GAS FLOW RATE: 

Qsd = 7.353(Mfd)(Vs)(A)(Ps)/(Ts + 460) = 113,343 SCFM 

10 
VOLUMETRIC FLOW RATE DETERMINATION 

PLANT: A.R.E. Inc - Massillon, OH 

TEST LOCATION: RTO Outlet 

TEST DATE: 12-14-95 

TRAVERSE DATA 

P.36 

S-M2-4 S-M2-5 

Run Start Time 

Run Finish Time 

Net Traversing Points 

Pbar Barometric Pressure, Inches Hg 

Pg Flue Gas Static Pressure, Inches H20 

Ps Absolute Flue Gas Pressure, Inches Hg 

ts Flue Gas Temperature, Degrees F 

Detta-p Average Velocity Head, Inches H20 

1650 

1658 

16 

29.80" 

-0.95 

29.73 

159 

0.9675 

1913 

1924 

16 

29.80 

-1.10 

29.72 

162 

1.0083 

Average 

29.72 

161 

0.9879 

OTHER DATA 

Duct Area (A): 

Pitot Tube Coefficient (Cp): 

Percent 02 (X02): 

Percent C02 (XC02): 

Percent Moisture (XH20): 

5541.8 sq. inches 

.0.84 

20.6 X 02 

0.2 X C02 

1.02 X H20 

CALCULATIONS 

DRY HOLE FRACTION OF STACK GAS: 

Mfd = 1 - (XH2O/100) = 0.990 

DRY MOLECULAR WEIGHT OF STACK GAS: 

Md = 0.44(XCO2) + 0.32(XO2) + 0.28(XN2) = 28.86 Ib/lb-mole 

WET MOLECULAR WEIGHT OF STACK GAS: 

Ms = (MdKMfd) + 0.18(XH2O) = 28.76 Ib/lb-mole 

AVERAGE STACK GAS VELOCITY: 

Vs = 85.49(Cp) X SQRT[(Pavg)(Ts + 460)/(Ps)(Ms)] = 60.81 ft/sec 

WET VOLUMETRIC STACK GAS FLOW RATE: 

Qaw = (60/144)(Vs)(A) = 140,415 ACFM 

DRY VOLUMETRIC STACK GAS FLOW RATE: 

Qsd = 7.353(Mfd)(Vs)(A)(Ps)/(Ts + 460) = 117,517 SCFM 

11 
VOLUMETRIC FLOU RATE DETERMINATION 

PLANT: A.R.E. Inc - Massillon, OH 

TEST LOCATION: RTO Outlet 

TEST DATE: 12-15-95 

TRAVERSE DATA 

P.37 

S-M2-6 S-M2-7 

Run Start Time 

Run Finish Time 

Net Traversing Points 

Pbar Barometric Pressure, Inches Hg 

Pg Flue Gas Static Pressure, Inches H20 

Ps Absolute Flue Gas Pressure, Inches Hg 

ts Flue Gas Temperature, Degrees F 

Delta-p Average Velocity Head, Inches H20 

1115 

1123 

16 

29.68" 

-0.9 

29.61 

178 

1.0276 

1246 

1252 

16 

29.68 

-0.92 

29.61 

174 

0.9796 

Average 

29.61 

176 

1.0036 

OTHER OATA 

Duct Area (A): 

Pitot Tube Coefficient (Cp): 

Percent 02 (X02): 

Percent C02 (XC02): 

Percent Moisture (XH20): 

5541.8 sq. inches 

0.84 

. 20.6 X 02 

0.2 X C02 

0.73 X H20 

CALCULATIONS 

DRY MOLE FRACTION OF STACK GAS: 

Mfd = 1 - (XH2O/100) = 0.993 

DRY MOLECULAR WEIGHT OF STACK GAS: 

Hd = 0.44(XC02) + 0.32(XO2) + 0.28(XN2) - 28.86 Ib/lb-mole 

WET MOLECULAR WEIGHT OF STACK GAS: 

Ms = (MdXNfd) • 0.18(XH2O) = 28.79 Ib/lb-mole 

AVERAGE STACK GAS VELOCITY: 

Vs = 85.49(Cp) X SQRT[(Pavg)(Ts + 460)/(Ps)(Ms)] = 62.14 ft/sec 

WET VOLUMETRIC STACK GAS FLOW RATE: 

Qaw = (60/144)(Vs)(A) = 143,486 ACFM 

DRY VOLUHETRIC STACK GAS FLOW RATE: 

Qsd = 7.353(Mfd)(Vs)(A)(Ps)/(Ts + 460) = 117,075 SCFM 

12 
MOISTURE TESTING SUMMARY 

P.38 

PLANT: A.R.E. Inc - Massillon, OH 

SOURCE: RTO Outlet 

S-M4-2 S-M4-3 S-M4-4 

Test Date 

Run Start Time 

Run Stop Time 

Net Traverse Points 

Theta Net Run Time,Minutes. 

Y Dry Gas Meter Calibration Factor 

Pbar Barometric Pressure, Inches Hg 

Delta H Average Pressure Differential 

of Orifice Meter,Inches H20 

Vm Volume of Metered Gas Sample, Dry ACF 

tm Dry Gas Meter Temperature, Degrees F 

ts Stack Gas Temperature,Degrees F 

Pg Stack Static Pressure, inches H20 .^ 

%H20sat Saturation Moisture Value at Stack 

Conditions, Percent by Volume 

Vmstd Volume of Metered Gas Sample, DSCF * 

Vic Total Weight of Liquid Collected in 

Impingers and Silica Gel, Grams 

Vwstd Volume of Water Vapor, SCF * 

%H20 Moisture Content, Percent by Volume 

Mfd D*cy Mole Fraction of Stack Gas 

12-14-95 12-14-95 12-15-95 

1535 

1635 

1 

60 

0.9989 

29.80 

1.79 

46.247 

98.9 

160 

-0.8-

32.4 

43.642 

15.2 

0.715 

1.61 

0.9839 

1802 

1902 

1 

60 

0.9989 

29.80 

1.79 

46.119 

99.1 

160 

-1.0 

32.3 

43.505 

9.5 

0.447 

1.02 

0.9898 

1134 

1234 r-l 

60 

0.9989 

29.68 

1.79 

46.079 

98.3 

176 

-0.9 

47.0 

43.355 

6.8 

0.320 

0.73 

0.9927 

* 68 deg. F(20 deg. C) -- 29.92 Inches of Mercury (Hg) 

13 
P.39 

Exhibit D 

Ductwork Configuration Drawings 
P.40 

/\{4ft<:.We.AT /-

A.R.E., Inc. 

Mt. Eaton, Ohio 

(Ohio EPA Facility No. 02-85-00-0291) 

Response to US EPA MACT Questions 

February 16,2000 

n 
P.41 

*****************i 

AR.E., Inc. 

Mt. Eaton, Ohio 

(Ohio EPA Facility No. 02-85-00-0291) 

Response to US EPA MACT Questions - February 16, 2000 

1. ADD-ON CONTROL DEVICE TECHNICAL DATA 

a. Hazardous air pollutant (HAP) concentration at the inlet to the control device. 

Perfonnance testing conducted at the Mt. Eaton facility in June 1999 (the report is dated July 

1999) demonstrated an average hydrocarbon concentration at the Regenerative Thermal 

Oxidizer (RTO) inlet of 366.23 ppm. This includes styrene emissions from composite 

fabricating processes as well as other volatile organic compound (VOC) and hazardous air 

pollutant (HAP) emissions from fabricating and painting operations. Individual HAPs have 

not been identified. 

b. Flow rate to the add-on control device. 

The June 1999 performance test demonstrated an average flow rate to the RTO of 36,903 

actual cubic feet per minute (acfm). 

[Note: The RTO has a design maximum inlet flowrate of 50,000 cfm.] 

c. Annual operating hours of the control device. 

A.R.E., Inc. estimates that the RTO will operate for approximately 6; 100 hours annually. 

This is based on operating 24 hr/day for 5 days/week. 

d. Status of control device during non-operational hours. 

The Mt. Eaton RTO is set in a stand-by mode during the third-shift on week nights and is 

shutdown during non-production periods (weekends and holidays). 

e. Destruction efficiency test results on the add-on control device. 

The June 1999 performance test demonstrated an average destruction efficiency of 97.9 

percent (%). [Note: The state installation permit requires a 95% destruction efficiency.] 

f. Method of demonstrating continuous compliance with destruction efficiency 

demonstrated during testing (continuous emission monitoring systems (CEMS) or 

continuous parameter monitoring systems (CPMS), and parameters monitored if using 

CPMS). 

Compliance with the destruction efficiency required by the construction permit (i.e., 95%) 

is demonstrated by the operation ofthe RTO at a temperature of 1,500°F. A continuous 

temperature recorder documents that this operating temperature is maintained. 

Page 1 of 7 
P.42 

g. Is destruction efficiency testing required annually, every 5 years, or at permit renewal? 

Destruction efficiency testing was required by the original installation permit. This is the 

testing performed in June 1999. A.R.E., Inc. expects a regular test schedule will be 

established in the Title V operating permit for the facility. 

2. ADD-ON CONTROL DEVICE COST DATA 

a. Add-on control device capital cost and year of cost data. 

The total capital cost ofthe RTO was $1,001,000 (1999 dollars). 

b. Instrumentation cost, freight cost, and sales tax. 

Instrumentation cost - $0 (no instrumentation purchased) 

Freight cost- $91,000 

Installation cost - $208,000 

Sales tax - A.R.E., Inc. received a state tax exemption for air pollution 

control equipment 

c. Electrical power consumption and cost associated with add-on control device operation. 

The RTO uses approximately 2,000 kW of power each hour during regular operation. The 

current cost is $. 014269/kW-hour. 

d. Fuel usage and cost associated with add-on control device operation. 

The RTO uses approximately 16,000 cf of natural gas each hour during regular operation. 

The current cost is $3.84/1,000 cf. 

e. Control device site preparation costs and building cost to house control device. 

The RTO was installed on a concrete pad adjacent to the production facility. The total site 

preparation costs for the RTO are estimated at $45,643. 

f. Control device maintenance costs. 

The annual maintenance costs of the RTO are estimated at $42,000. 

[Note: The Mt. Eaton RTO has been in operation for less than one year.] 

g. Overhead, property tax, insurance, and administration cost associated with the add-on 

control device. 

Overhead- $3,500/yr 

Property tax - A.R.E., Inc. received a state tax exemption for air pollution control 

equipment 

Insurance - $3,500/yr 

Administration- $19,500/yr 

Page 2 of 7 
P.43 

h. Recordkeeping and reporting time and costs associated with the add-on control device, 

list of records and reports currently required, and time and costs to prepare these 

reports. 

:

 Daily RTO inspections - !4 hour per day x 254 days x $24/hr = $3,048/yr 

Malfunction Reports - ' VAhour x 12events/yr x $24/hr = $ 432/yr 

' < . .• • • 

[Note: A.R.E., Inc. assumes other significant monitoring, recordkeeping and reporting costs 

would be incurred regardless ofthe presence of the add-on control system (i.e., material 

usage rates and uncontrolled emissions rates).] 

. •• . • '"•(• ' 

3. CAPTURE SYSTEM TECHNICAL DATA 

Please refer to the general process flow diagram in Exhibit A for additional information related 

to the PTEs at the A.R.E., Inc. Mt. Eaton facility. 

a. Number of permanent total enclosures (PTEs) that capture HAP emissions. 

There are six PTEs at the Mt. Eaton facility. The six PTEs are: 

1. Glass Room (includes geicoat and fiberglass resin spray-up operations) 

2. Four Paint Spray Booths 

3. Paint Mix Room 

[Note: The four Paint Spray Booths and the Paint Mix Room involve operations that are not 

included in the reinforced plastic composites MACT standard.] 

b. List of HAP emission points captured by each PTE. 

Glass Room 

1. Exterior Geicoat Booth and flash-off 

2. Fiberglass/Resin Spray-Up Booth #1 

3. Fiberglass/Resin Spray-Up Booth #2 

4. Large component Spray-Up area (open within Glass Room) 

[Note: Fabricated components are retained inthe Glass Room until fiilly cured. Components 

exit the Glass Room through the exit opening.] 

Paint Spray Booths #1 - #4 

1. Each Paint Spray Booth consists ofa combination paint room and curing oven. 

Paint Mix Room 

1. Paint mixing equipment 

2. Paint gun cleaning units 

Page 3 of 7 
P.44 

c. List of HAP emission points not captured by PTEs 

Several operations associated with the reinforced plastic composites MACT standard have 

HAP emissions that are not captured by a PTE. These include the geicoat ahd resin transfer 

molding (RTM) operations and Mold Maintenance area in Plant #1 as well as the mold 

fabrication operations in Plant #2. Material usage is restricted at each of these emissions 

units to meet the requirements of Ohio Administrative Code (OAC) rule 3745-21-07(G)(2) 

[i.e., total organic compound emissions must be less than 8 pounds per hour and less than 40 

pounds per day.] • . 

The Primer Paint Booth has HAP emissions associated with the application of paints 

(coatings) that are not captured by a PTE. These emissions units are not included in the 

reinforced plastic composites MACT standard. 

d. Dimensions of each PTE (length x width x height) 

Please refer to the table in Exhibit B. 

e. Dimensions of natural draft openings (NDOs) and face velocity across NDOs 

Please refer to the table in Exhibit B. 

f. Number of air changes per minute for each PTE 

Please refer to the table in Exhibit B. 

g. Measured HAP concentration (ppm) in each PTE 

Personal air sampling (OSHA) has identified styrene concentrations within the Glass Room 

in the range of 50 ppm. Styrene concentrations within the Geicoat Booth and the 

Fiberglass/Resin Spray-Up Booths can exceed 100 ppm. 

h. Number and size of permanently open doors or any other openings in the PTE. 

Please refer to the table in Exhibit B. 

i. Basic PTE materials (walls/doors/windows/ceiling/lighting). 

Walls - concrete block and dry wall 

Doors - metal 

Windows - none 

Ceiling - metal 

Lighting - halogenated (explosion proof in the Exterior Geicoat Booth and 

Fiberglass/Resin Spray-Up Booths) 

Page 4 of 7 
P.45 

j . Basic PTE safety equipment (LEL monitors/alarm bells/alarm signals). 

Airflow is sufficient to prevent unacceptable concentrations from building up in any PTE. 

None ofthe PTEs has any special safety monitoring equipment. 

k. Basic instrumentation (differential pressure monitor/surge protector/alarm). 

The inherent design of the PTE (fans and airflow) ensures that the required Airflow is 

sufficient to prevent unacceptable concentrations from building up in any PTE% None ofthe 

PTEs has any special safety momtoring equipment. 

I. Louvers/make-up air fan used with PTEs? 

Please refer to the table in Exhibit B. 

m. Air conditioning used with PTEs? 

Air conditioning is not needed. The air flow is sufficient to maintain an acceptable interior 

temperature. ••••.••, • 

n. Does each PTE meet EPA Method 204 criteria for a PTE? 

Yes. Refer to the information and data from the June 1999 test report that documents the 

performance of each PTE (see Exhibit 0). 

o. Capture efficiency test results or PTE determination on each PTE. 

Refer to the information and data from the June 1999 test report that documents the 

performance of each PTE (see Exhibit C). 

p. Method of demonstrating continuous compliance with capture efficiency. 

The RTO flowrate and other inherent design features of each PTE ensure that the PTEs 

continuously perform as demonstrated during the Method 204 testing. 

q. Capture efficiency testing required annually, every 5 years, or at permit renewal? 

Testing pursuant to Method 204 was required by the original installation permit. A.R.E., Inc. 

expects a regular test schedule will be established in the Title V operating permit for the 

facility. 

4. CAPTURE SYSTEM COST DATA 

a. Capital cost of PTEs and year of the cost data. 

The total capital cost of the PTE for the Glass Room was $ 160,000 (1999 dollars). 

[Note: This includes the cost ofthe air make-up system.] 

Page 5 of 7 
P.46 

b. Incremental operating and maintenance costs of the PTEs. 

The total annual operating cost ofthe PTE for the Glass Room is estimated at $5,200. 

[Note: This includes the operating costs associated with the air make-up system.] 

5. DUCTWORK TECHNICAL DATA 

a. Basic ducting materials. 

The ductwork is steel, circular and non-insulated. 

b. Basic ducting configuration. 

This level of detail is not currently available. 

c. How is ductwork joined prior to add-on control device? 

Ring and bolt with sealed (caulked) joints. 

d. Measured/estimated/assumed velocity of gas stream in ductwork? 

The June 1999 performance test demonstrated an average velocity of 36.80 feet per second 

(fps) in the duct at the inlet of the RTO. 

6. DUCTWORK COST DATA 

a. Capital cost to retrofit ductwork to vent emissions to the control device and year of cost 

data. 

The total capital cost ofthe ductwork, including installation, was $115,527 (1999 dollars). 

b. Freight cost and sales tax for ductwork retrofitting. 

Freight cost- $5,500 (1999 dollars) 

Sales tax- A.R.E., Inc. received a state tax exemption for. air pollution control 

equipment 

c. Incremental electrical power consumption and cost associated with duct fan operation 

due to installation of add-on control device. 

These costs are included in the RTO operating costs. 

d. Incremental ductwork maintenance costs due to installation of add-on control device 

Labor- 1 hr/weekx 52 weeks/yr x $17/hr = $884/yr 

Parts- $2,000/yr 

Page 6 of 7 
P.47 

e. Incremental ductwork overhead, property tax, insurance, and administration cost due 

to installation of add-on control device 

Overhead- $l,000/yr 

Property tax - A.R.E., Inc. received a state tax exemption for air pollution control 

equipment 

Insurance - included in RTO cost estimate 

Administration - included in RTO cost estimate 

Page 7 of 7 
P.48 

Exhibit A 

General Process Flow Diagram 
Resin Mix Room 

Catalyst Catalyst 

-Total Enclosure -

R013 

Fiberglass 

Spray-Up #1 

Geicoat 

(drums) 

Catalyst 

A.R.E., Inc. 

Mt. Eaton (Facility ID No. 02-85-00-0291) 

General Process Flow Diagram 

February 11, 2000 

R014 

Fiberglass 

Spray-Up #2 

R012 

Geicoat Booth 

Z129 

Mold 

Maintenance 

R016 

Large 

Component 

Fiberglass 

Spray-Up Area 

Regenerative Thermal Oxidizer 

(RTO) 

Paint Mix Room 

Z112-Z115 

Paint Gun Cleaners 1-4 

Plant #2 Mold Fabrication 

Z128 Sanding and Grinding 

R008- Geicoat and Primer Booth#1 

R009-Gelcoat and Primer Booth #2 

R010-Ceramic Spray-Up Area 

R011-Spray-Up Area 

R004 

Paint Spray 

Booth #1 

•+• 

R005 

Paint Spray 

Booth #2 

R006 

Paint Spray 

Booth #3 

R007 

Paint Spray 

Booth #4 

Waxed 

Part Mold 

Z120 

•Velding Area 

Fiberglass 

Part 

Z123 

Fossliner 

Booth 

Z121 

WoodShop 

P003 

Trim Booth 

P001 

RTM 

Equipment 

Z122RTM 

Tank 

R003 

Geicoat Booth 

Z127 

Foam 

Sanding 

P004 

Sanding/ 

Grinding 

Booth 

Each Booth is an Enclosure 

t 

Painted 

Part 

Z116-Z117 

Paint Gun Cleaners 

Located throughout 

the facility 

R015 

Primer Booth 

P002 Prep 

Area 

Z126 

CNC Cutting 

Room 
P.50 

Exhibit B 

Permanent Total Enclosure Data Table 
A.R.E., Inc. 

Mt. Eaton, Ohio 

Permanent Total Enclosures (PTE) Associated with Regenerative Thermal Oxidizer (RTO) 

PTE Description Length 

(ft) 

Width 

(«) 

Height 

(ft) 

Volume 

(cuft) 

Air Exchanges 

#/min' 

Openings 

Description Area 

Comments 

Glassroom 85 75 25 159,375 1 @ (8 x 6.33); 1 @ (8 x 8) 114.6 NDOs for parts egress and mold ingress/egress 

Geicoat Booth 17.5 15 12 3,150 5,890 1.9 None N/A Opening inside Glass Room 

Geicoat Flash-Off Area 40 16 5,120 4,930 1.0 None N/A Open area within Glass Room 

Spray-Up #1 18 16 12 3,456 7,580 2.2 None N/A Opening inside Glass Room 

Spray-Up #2 

Rollout Flash-Off Area 

16 1? 12 3.456 7,980 

p^i^W-^.ftfH ' '&1* ':$:?* *•••-* 4,680 

2.3 None N/A Opening inside Glass Room 

Total from Glass Room 

Paint Booth #1 

r-'-w-tfi-s-.?-*:'..»»v-£ 2yte£&- 31,060 

,Jj ***• ^ ^ #1 Ik m^ ^*A t^m W> *T_ ^m ' I^^A^^i^*k^*H^B^ ft * 

27 14 9 3,402 [ 6,300 

Open area within Glass Room 

Paint Booth #2 

Paint Booth #3 

Paint Booth #4 

27 

27 

27 

14 

14 

14 9 

3,402 

3,402 

3,402 

1.9 None N/A 

6,200 1.8 None N/A 

3,840 1.1 None N/A 

3,860 1.1 None N/A 

All four paint spray booths have two modes (spray 

and bake). The flowrate in the bake mode is less 

than the spray mode. Either booth #1 or #2 is in 

the bake mode when all units are in operation. 

Paint Mix Room 28.5 8 10 2,280 1,000 0.4 None N/A 

Total to RTO* 50,000 

* Includes Glass.Room, 4 Paint Spray Booths and Paint Mix Room. Note that all four Paint Spray.Booths cannot be in the "spray" mode when all other units are operating. 

02/15/2000 

*• 
P.52 

Exhibit C 

Excerpts from June 1999 Test Report 
P.53 

TABLE 1 

METHOD 204 ENCLOSURE VERIFICATION 

CLASSROOM 

A.R.E..INC. 

MOUNT EATON, OHIO 

JUNE 8,1999 

NDO opening diameters from emission points 

NtX) Equivalent Diameter (inches) 

Exterior Geicoat Booth distance to NDO (diameters) 

Neat Resin Booth distance to NDO (diameters) 

Filler Resin Booth distance to NDO (diameters) 

Solvent Drums distance to NDO (diameters) 

Exhaust opening diameters from emission points 

Exterior Geicoat Booth 

Neat Resin Booth 

Filter Resin Booth 

Exterior Geicoat Flash-off Entrance 

Exterior Geicoat Flash-off Exit 

Roll-off Area Exhaust 

NDO to Enclosure Area Ratio (NEAR) 

Area of Total Enclosure (ft2) 

Area of NDO (ft2) 

Ratio 

NDO Facial Velocity 

Average flow rate entering the control device (scfm) 

Make-up air flow (scfm) 

Total area of NDO (ft2) 

Average velocity through NDOs (fpm) 

Capture Efficiency Verification 

Any NDO less than four opening diameters from each VOC emitting 

point? 

Any exhaust point less than four dud/hood diameters from each NDO? 

Total NDO Area less than 5% ofthe total enclosure area? 

Average inward facial velocity through all NDOs greater than 200 feet 

per minute? 

100% capture efficiency assumed? 

76.8 

6.5 

1*4.6 

10.8 

13.9 

5.4 

12.2. 

9.0 

5.7 

9.0 

38.9 

19.278 

42.7 

0.22% 

22,826 

9,892 

42.7 

3033^ 

No 

No 

Yes 

Yed 

Yes 

OUT Envlronr******-*'. Ins. 

ProXwt No. 71595.01 

Torr«tlno. -Myl» 9 

Air Quillty Serwcw ARE CALCULATION SPReADSMEETOUseroom EncKrtuf* Vw il. 
P.54 

l-f. 

TABLE 2 

METHOD 204 ENCLOSURE VERIFICATION 

PAINT SPRAYBOOTHS 

A.R.E., INC. 

JUNE 8,1999 

tntaka Air Velocity Meag-jrefrwnts 

Spraybooth #1 

Spray-booth #2 

Spraybooth #3 

Spraybooth #4 

Feet per minute 

470 

510 

388 

608 

Note: The spraybooth* are fully enclosed wtth a aingte air Intake and 

a single air exhaust Each air intake was measured and 

velocity detennined. The minimum velocity required to 

tasuuime 100% capture efficiency ie "200 feet per minute. 

Durr Environmental, Inc. 

Project No. 71595.01 

TolTest, Inc. 

Air Quality Services 

July 1999 

Are-deSpraybooth Enclosure Verif. 
TABLE 3 

TOTAL HYDROCARBON DESTRUCTION EFFICIENCY 

COATING LINES RTO 

A.R.E., INC. 

MOUNT EATON, OHIO 

JUNE 9,1999 

RUN 

Start Time 

Stop Tim* 

I RTO INLET 

GAS CONDITIONS 

Oxygen (percent) 

Carbon Dioxide (percent) 

Temperature (degrees F) 

Moisture (percent) 

VOLUMETRIC FLOW RATE 

Actual Conditions (acfm) 

Standard Conditions (scfm) 

Dry Standard Conditions (dscfm) 

TOTAL HYDROCARBONS 

Concentration (ppm) 

Emission Rate (lb/hr) 

OU RTO OUTLET 

GAS CONDITIONS 

Oxygen (percent) 

Carbon Dioxide (percent) 

Temperature (degrees F) 

Moisture (percent) 

VOLUMETRIC FLOW RATE 

Actual Conditions (acfm) 

Standard Conditions (scfm) 

Diy Standard Conditions (dscfm) 

TOTAL HYDROCARBONS 

Concentration (ppm) 

Concentration (lb/scf) 

Emission Rate (Ib/hr) 

DESTRUCTION EFFICIENCY 

Total Hydrocarbon, Ib/hr Basis 

1 

10:01 

11:01 

20.9 

0.0 

82 

3.75 

34.820 

33,354 

32,104 

322.2 

73.65 

20,5 

0.5 

215 

3.04 

43,934 

33,962 

32,624 

6.10 

6.97E-07 

1.42 

98.1% 

2 

11:12 

12:12 

20.8 

0.0 

88 

3.75 

35,168 

33,319 

32,070 

412.1 

94.10 

20.5 

0.5 

240 

• 3.94 

48,639 

36.231 

34,804 

8.11 

9.26E-07 

2.01 

97.9% 

3 

12.18 

13:18 

20.9 

0.0 

95 

3.75 ' 

40,720 

38.092 

38,664 . 

364.4 

95.13 

i ' 

20.5 

0.5 

216 

3.94 

60,066 

46,369 

44.542 

6 52 

7.45E-07 

2.07 

97.8% 

Average 

20.9 

0.0 

88 

3.76 

36,903 

34,922 

33,912 

3S6.23 

87.63 

20.5 

0.5 

224 

3.94 

60,880 

38,854 

37,324 

8.91 

7.89E-07 

1.84 

•• 

97.9% 

Ourr Envtroni-n«nul, Ino. 

Project No. 71595.01 

TolTett. Ino. 

Air Quality Sarvicas 

July 1999 

ARE CALCULATION SPftEA.OSHEET.xUR.Mull T«bl« 
P.56 

HYDROCARBON EMISSIONS 

RTO OUTLET 

COATING UNES RTO 

A.R.E. INC. 

JUNES. 1999 

RUN NUMBER 

STACK DIAMETER (Inches) 

STACK AREA (sq.ft.) 

No. SAMPLE POINTS 

TOTAL SAMPLE TIME 

NOZZLE DIAMETER (hchej) 

NOZZLE AREA (sq. ft.) 

CALIBRATION FACTORS: 

PITOT TUBE. Cp 

GAS METER, y 

BAROMETRIC PRESSURE (inches H0 | 

STACK STATIC PRESSURE 

(Inches H20 measured) 

(absolute inches Hgi 

STACK OAS TEMP, 

(dew- F) 

(deg. R) 

STACK QAS MOISTURE CONTENT 

AVG. METCR TEMP (deg. F) 

AVG. METER PRESS (in. Hg) 

METER VOL., ACTUAL (cu. ft.) 

METER VOL @STP (cu.ft.) 

CONDENSED WATER (fl). 

SlUCAGEL(g) 

VAPOR VOL & STP (cu. ft.) 

TOTAL GAS SAMPLED ©STP (cu. fl.) 

PERCENT MCXSTURE 

AVG Sqrt VEL HEAD (in. H2OA0.6> 

ORY GAS COMPOSITION 

%02 

%C02 

• KCO 

•KN2 

MOLECULAR Wt. -STACK GAS 

DRY flb/lb-moll 

WET (Ib/lb-mol) 

AVERAGE GAS VELOCITY 

(fpm) 

<ff») 

VOLUMETRIC FLOW RATE 

ACTUAL. Qa. (acfm) 

STANDAftD,Q*td. (scfm) 

STANOARO ORY.Qdg, (dscfm) 

TOTAL HYOROCARBONS EMISSION RATE 

Concentration (ppm) 

Concentration (lb/scf) 

Emission Rate (lb/hr) 

?"" Environ*,,,,!, foe. 

•"ro^ctNo, 3M69S.01 

65.0 

23.04 

16 

60.0 

N/A 

N/A 

0.640 

0.9680 

29.67 

-0.21 

29.66 

214.69 

674.69 

104.1 

29.71 

19.930 

17.924 

5.7 

8.8 

0.7:35 

18.659 

3.94 

0.494 

20.6 

O.S 

0.0 

79.0 

28.00* 

26.47 

1.907 

31.78 

43.934 

33,962 

32,624 

6.10 

6.97E-07 

1.42 

65.0 

23.04 

16 

60.0 

N/A 

N/A 

0.840 

0.9660 

29.57 

-0.20 

29.66 

240.19 

700.19 

N/A 

N/A 

N/A 

N/A 

— N/A 

N/A 

N/A 

N/A 

3.94 

0.637 

20.5 

0.5 

0.0 

79.0 

28.90 

26.47 

2,111 

35.1B 

48,639 

36,231 

34,804 

8.11 

9.26 E-07 

2.01 

65.0 

23.04 

16 

60.0 

N/A 

N/A 

0.840 

0.9680 

29.57 

-0.20 

29.56 

215.63 

675.63 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

3.94 

0.675 

20.5 

0.5 

0.0 

79.0 

28.90 

28.47 

2.607 

43.44 

60,066 

46,369 

44,642 

6.52 

7.45E-07 

2.07 

Average 

0.840 

29.57 

-0.20 

29.56 

223.50 

683.50 

104.1 

29.71 

19.830 

17.624 

$.700 

94 

0.736 

18.669 

3.84 

0.569 

20.5 

0.5 

0.0 

78.0 

28.90 

28.47 

2.2 J 

36.80 

60.880 

38,864 

37,324 

6.91 

7.89E-07 

1.84 

To/Test. Inc. 

Ah QuaUty S«vlc«« July 1999 

ARE CAlCtAATION WREAOSHEFT.rfKJutiot RUUIM 
P.57 

The Top Line For Your Truck 

ve Road S.E. 

x1100 

an, OH 44648-1100 

30-4500 

0) 830-4545 

www.4are.com 

<§>4are.com 

February 23,2000 

Mr. Keith Barnett 

Organic Chemical Group 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 277 ll 

Dear Keith: 

Thank you for taking the time to visit the A.R.E., Inc. facilities in Massillon and Mt. Eaton, 

Ohio. At the end of your visit we identified four items that required additional information and 

data: 

1. Enclosed is a copy of the latest Permit-to-Install (PTI) issued by the Ohio EPA for the Mt. 

Eaton facility. Also enclosed is a copy ofthe PTI issued for the installation ofthe new Mold 

Cleaning and Release Application Booth at the Massillon facility. 

2. The stack test report prepared by Entropy, Inc. for the Massillon facility and the stack test 

report prepared by TolTest, Inc. for the Mt. Eaton facility are both correct. The Entropy test 

reports VOC as "carbon", while the TolTest test reports VOC as "propane". If the TolTest 

results are converted to "as carbon" the average emissions rate at the Mt. Eaton facility 

during the three-hour test was approximately 23 lb/hr. 

The hourly RTO inlet emissions rates "as carbon" should not be interpreted as the hourly 

uncontrolled emissions rates for the various organic compounds that are used in the 

fiberglass fabricating operations and paint spray booths. The "as carbon" results at the RTO 

inlet can be converted to volatile organic compound (VOC) emissions based on the weight 

percent of carbon in the individual VOC species. Assuming the most prevalent VOC species 

is styrene (with a molecular formula of CgHs and a weight % of carbon of 92.3%) and that 

the paint VOCs have comparable weight % carbon, the total VOC emissions at the RTO inlet 

during both stack tests are approximately equal to the "as carbon" results (lb/hr "as 

carbon"/0.923 = lb/hr "as styrene"). 

The most important conclusion of both test reports is the demonstrated destruction efficiency. 

Both the Entropy report for Massillon and the TolTest report for Mt. Eaton demonstrate a 

total VOC destruction efficiency well above the 95% required by the construction permits 

issued by the Ohio EPA. 
P.58 

Mr. Keith Barnett 

February 23, 2000 

Page 2 

3. VOC emissions from the new Mold Cleaning and Release Application Booth at the 

Massillon facility will be directly vented to the RTO as indicated on the flow diagram 

provided to you at our meeting. 

4. Entropy determined the opening from the exit tunnel ofthe Massillon Glass Room was not a 

natural draft opening (NDO). A copy of Entropy's assessment is enclosed. We plan to have 

this opening re-evaluated pursuant to the Method 204 criteria during the testing that is 

scheduled to be performed in the summer ofthis year. 

I believe that this letter and enclosures responds to the questions we were unable to address 

during the site visit. Please feel free to contact me at any time if you have any additional 

questions. Also, please keep me informed as you make progress in the development of the 

MACT standard. I am looking forward to hearing from you. 

Sincerely, 

Ralph Gatti 

President 

Enclosures 

cc: Melanie S. Proctor (Pacific Environmental Services, Inc.) w/enclosures 
P.59 

T...STREET ADDRESS: 

ON@E»\ 

State of Ohio Environmental Protection Agency 

'800 WaterMark Drive 

Columbus, OH 43215-1099 

February 03, 1999 

WAYNE COUNTY ( fl\o\>-^ If irW J 

ARE Inc 

Clyde Richey 

PO Box 1100 

Massillo n OH, 44648-1100 

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

MAILING ADDRESS: 

P.O. Box 1049 

Columbus, OH 43216-1049 

CERTIFIED MAIL 

Penult Type Summajry 

•wxic REVIEW 

•pSTT 

SYNTHETIC MINOR 

HEMS' 

MACT 

NSPS' 

NESHAPS 

NETTING 

MAJOR NON-ATTAINMENT 

MUVEhlNU SUBM1TTEURE Permit To Install Number 02-2379 ADMINISTRATIVE MODIFICATION 

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 by the Director is final and 

may be appealed to the Ohio Environmental Review Appeals Commission 

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 within thirty (30) days 

after the notice of the Directors 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 Commission. An appeal may be 

filed with the Environmental Review Appeals Commission at the following 

address: 

Environmental Review Appeals Commission 

23 6 East Town Street, Room 3 00 

Columbus, Ohio 43215 

Very truly yours, 

Thomas G. Rigo^ Manager 

Field Operations and Permit Section 

Division of Air Pollution Control 

Enclosur e 

c c : USEPA 

DAPC, NEDO 
P.60 

RECBVED 

2 of 17 Pages f-FR Q g 1909 

Facility Name: ARE , Inc 

Application Number: 02-2379 AuRaE. ENCc 

Date: Febama-cy 3, 1999 

GENERAL PERMIT CONDITIONS 

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 N3EW 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 
P.61 

RECEIVED 

3 of 17 Pages FEB Q 8 1999 

Facility Name: ARE , Inc 

Application Number: 02-2379 /LRLE * fiftSCc 

Date: FebrAiarry 3, 1999 

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 df any rights that the Ohio Environmental 

Protection Agency (or other persons) may have against the 

applicant for starting construction prior to the effective date 

of the permit. Additional facilities shall be installed upon 

orders of the Ohio Environmental Protection Agency if the 

proposed facilities cannot meet applicable standards. 

PERMIT TO INSTALL FEE 

In accordance with Ohio Revised Code 3745.11, the specified 

Permit to Install fee must be remitted within 3 0 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 tb 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. 
P.62 

4 of 17 Pages 

Facility Name: ARE , Inc 

Application Number: 02-2379 

Date: February 3, 1999 ""Lb lj •:• 1999 

BEST AVAILABLE TECHNOLOGY A-IHLE..-. ClraC-c 

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 

and regulations. 
P.63 

5 of 17 Pages 

Facility Name: ARE , Inc 

Application Number: 02-2379 

Date: February 3, 1999 

AIR EMISSION SUMMARY 

RECEIVED 

rC:. ij i m 

AJR.E. we* 

The air contaminant emissions units listed below comprise the 

Permit to Install for ARE , Inc located in Wayne County. The 

emissions units listed below shall not exceed the emission 

limits/control requirements contained in the table. 

condition in no way limits the applicability of any 

This 

other state 

or federal regulations. Additionally, this condition does not 

limit the appl 

conditions of 

Ohio 

EPA Source 

icability of additional special terms 

this permit. 

Applicable 

Source Identification BAT Federal & 

Number Description Determination OAC Rules 

R004 Paint spray 

booth no. 1 

ROO5 Paint spray 

booth no. 2 

:

 -Y*' 

Use of total 3745-21-07 

permanent enclosure; (G) 

RTO with 95 percent 

DE; and compliance 

with Air Toxics 3745-21-09 

Policy (U) 

3745-31-05 

Use of total 3745-21-07 

permanent enclosure; (G) 

RTO with 95 percent 

DE; and compliance 

with Air Toxics 3745-21-09 

Policy (U) 

and 

Permit Allowable 

Mass Emissions 

and/or 

Control/Usage 

Requirements 

Equivalent to or 

less stringent 

than BAT 

Equivalent to or 

less stringent 

than BAT 

OC & VOC - 5^, 0 

pounds per hour 

from RTO 

COMBUSTION 

EMISSIONS 

N0X - 1.0 pound 

per hour 

Equivalent to or 

less stringent 

than BAT 

Equivalent to or 

less stringent 

than BAT 

3745-31-05 OC & VOC - 5.0 

lbs/hr from RTO 
P.64 

6 of 17 Pages 

Facilit y Name: ARE , Inc 

r,^., Applicatio n Number: 02-2379 

) Date : February 3, 1999 

RfeOiiVH 

A.R.E.o fcd'c'ifc (NC 

Ohio 

EPA 

Source 

Number 

R005 

Cont' d 

Source 

Identification 

Number 

BAT 

Determination 

Applicable Federal 

& OAC Rules 

Permit Allowable Mass 

Emissions and/or 

Control/Usage 

Requirements 

COMBUSTION 

EMISSIONS 

N0X - 1.0 lb/hr 

ROO6 Paint spray 

booth no. 3 

Use of total 3745-21-07 

permanent enclosure; (G) 

RTO with 95 percent 

DE; and compliance 

with Air Toxics 3745-21-09 

Policy (U) 

Equivalent to or 

less stringent 

than BAT 

Equivalent to or 

less stringent 

than BAT 

3745-31-05 

OC & VOC - 5.0 

lbs/hr from RTO 

COMBUSTION 

EMISSIONS 

N0V 1.0 lb/hr 

R007 Paint spray 

booth no. 4 

Use of total 3745-21-07 

permanent enclosure; (G) 

RTO with 95 percent 

DE; and compliance 

with Air Toxics 3745-21-09 

Policy (U) 

Equivalent to or 

less stringent 

than BAT 

Equivalent to or. 

less stringent 

than BAT 

3745-31-05 OC & VOC - 5.0 

lbs/hr from RTO 

COMBUSTION 

EMISSIONS 

N0X - 1.0 lb/hr 

L2 Geicoat 

station 

Use of total 3745-21-07 

permanent enclosure; (G) 

RTO with 95 percent 

DE; and compliance 

Equivalent to or 

less stringent 

than BAT 
P.65 

7 of 17 Pages 

Facilit y Name: ARE , Inc 

Applicatio n Number: 02-2379 

1 Date : February 3 , 1999 

^fcOsWto 

MrEo£. 

Ohio 

EPA 

Source 

Number 

Source 

Identification 

Number 

BAT 

Determination 

Applicable Federal 

& OAC Rules 

Permit Allowable Mass 

Emissions and/or 

Control/Usage 

Requirements 

R012 

Cont' d 

with Air Toxics 

Policy 

3745-21-09 

(U) 

Equivalent to or 

less stringent 

than BAT 

3745-31-05 OC & VOC - 5.0 

pounds per hour 

from RTO 

COMBUSTION 

EMISSIONS 

N0X - 1.0 pound 

per hour 

13 Polyester Use of total 3745-21-07 

resin station permanent enclosure; (G) 

RTO with 95 percent 

DE; and compliance 

with Air Toxics 3745-21-09 

Policy (U) 

Equivalent to or 

less stringent 

than BAT 

Equivalent to or 

less stringent 

than BAT 

3745-31-05 OC & VOC.- 5.0 

pounds per hour 

from RTO 

COMBUSTION 

EMISSIONS 

N0X - 1.0 pound 

per hour 

R014 Polyester Use of total 3745-21-07 

resin station permanent enclosure; (G) 

RTO with 95 percent 

DE; and compliance 

with Air Toxics 3745-21-09 

Policy (U) 

Equivalent to or 

less stringent 

than BAT 

Equivalent to or 

less stringent 

than BAT 
P.66 

8 of 17 Pages 

Facility Name: ARE , Inc 

.,-.,. Application Number: 02-2379 

'* Date: February 3, 1999 

Ohio 

EPA 

Source 

Number 

R014 

Cont•d 

Source 

Identification 

Number 

BAT 

Determination 

Applicable Federal 

& OAC Rules 

3745-31-05 

m j i Xh & : .' 

I . "w \.i W ^-

Permit Allowable Mass 

Emissions and/or 

Control/Usage 

Requirements 

OC & VOC - 5.0 

pounds per hour 

from RTO 

COMBUSTION 

EMISSIONS 

N0X - 1.0 pound 

per hour 

P004 Relocated 

sanding/ 

grinding 

booth 

Use of 4 bag 

filters 

3745-17-07 

3745-17-07 

Equivalent to or 

less stringent 

than BAT 

Equivalent to or 

less stringent 

than BAT 

3745-31-05 PM - 0.03 grain 

per dscf 

No visible 

emissions 

SUMMARY 

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS 

Pollutant Tons/Year 

oc/voc 

PM 

21.9* 

12.8 

This is a decrease of 21.9 TPY of allowable VOC/OC 

emissions. 
P.67 

!<J W 'v' 

9 of 17 Pages 

Facilit y Name: ARE , Inc REOEH V 

Application Number: 02-2379 

Date: February 3, 1999 

' A PERFORMANCE TEST REOUIREMENTS £** 

The permittee shall conduct, or have conducted, performance testing 

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

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

the test procedures followed and the results of such tests shall be 

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

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

witness the test, examine testing equipment, and require the 

acquisition or submission of data and information necessary to 

assure that the source operation and testing procedures provide a 

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

performance of the control equipment. 

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

appropriate Ohio EPA District Office or Local Air Pollution 

Control Agency where the original permit application was 

filed. This notice shall be made 30 days in advance and shall 

specify the source operating parameters, the proposed test 

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

such tests. 

B. Two copies of the test results shall be submitted within 3 0 

days after the completion of the performance test. 

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

pollutants(s): 

Source Pollutant(s) 

R004 - R007, VOC/OC 

R012 - R014 

REPORTING REOUIREMENTS 

Unless otherwise specified, reports required by the Permit to 

Install need only be submitted to Ohio EPA, Northeast District 

Office, 2110 E. Aurora Road, Twinsburg, OH 44087. 
P.68 

>*^ ** 

10 of 17 Pages 

Facility Name: ARE , Inc RECEIVE D 

Application Number: 02-2379 

Date: February 3, 1999

 rL'J Q ::• Uzt 

WASTE DISPOSAL AnR-E c li^lCc 

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 EOUIPMENT 

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 Ohio EPA, Northeast District Office, 

2110 E. Aurora Road, Twinsburg, OH 44087. 

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

maintenance of air pollution control equipment that requires the 

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

accompanied by the shutdown of the associated air pollution 

sources. 

AIR POLLUTION NUISANCES PROHIBITED 

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

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

CONSTRUCTION COMPLIANCE CERTIFICATION 

The applicant shall provide Ohio EPA with a written certification 

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

accordance with the Permit to Install application and the terms 

and conditions of the Permit to Install. The certification shall 

be provided to Ohio EPA upon completion of construction but prior 

to startup of the source. 
P.69 

Y"*'-^ 

H of 17 Pages RECEIVE D 

Facility Name: ARE , Inc 

Application Number: 02-2379 'ill' ~ 5 %2:l 

Date: February 3, 1999 „ ,. , 

ADDITIONAL SPECIAL TERMS AND CONDITIONS 

INTRODUCTION 

The A.R.E., Inc., facility in Mt. Eaton consists of two separate 

buildings designated as Plants No. 1 and No.2. The facility 

produces FRP and aluminum truck accessories. This permit 

involves plant #1. The four paint spray booths will be modified; 

a new geicoat booth and flash-off area will be added; two new 

polyester resin/fiberglass spray-up stations and flash-off areas 

will be added; and a new sanding/grinding booth will be 

installed. The currently existing geicoat booth (R001) and 

polyester resin spray-up booth (R002) will be removed. 

A. Emission Limitations and Control Requirements 

1. The new geicoat booth and two resin spray-up operations 

with associated flash-off areas will be installed in a 

total permanent enclosure. The four paint booths will 

be modified to be total permanent enclosures. These 

seven emission units will be exhausted to a 50,000 cfm 

regenerative thermal oxidizer with a minimum 

destruction efficiency of 95 percent; The facility has 

proposed emissions from the oxidizer be restricted to 5 

pounds VOC/OC per hour. 

2. The new sanding/grinding booth will be controlled by 

four bag filter devices which exhaust back into the 

building. The emissions will be restricted to 0.03 

grain per dry standard cubic foot', which totals 2.93 

pounds per hour. There will be no visible emissions. 

3. The oxidizer has a gas-fired burner with a heat input 

of 10.0 MMBtu/hour. The N0X emissions from combustion 

shall not exceed 1.0 pound per hour. 

B. OPERATIONAL RESTRICTIONS 

1. The average combustion temperature within the thermal 

incinerator, for any 3-hour block of time when the 

emissions unit is in operation, shall not be less than 

1500 degrees Fahrenheit. 
P.70 

12 of 17 Pages RECEDED 

Facility Name: ARE, Inc 

Application Number: 02-2379 '• L'J Q •:':• 1b'8 ° 

Date: February 3, 1999 „ _,, _ 

A.RL1 •aa 

3D 

2. Each permanent total enclosure shall be maintained 

under negative pressure, at a minimum face velocity 

that is not less than 200 feet per minute across all 

natural draft openings, whenever the emissions units 

are in operation. 

C. Monitoring and Recordkeeping Requirements 

1. The permittee shall operate and maintain a continuous 

temperature monitor and recorder which measures and 

records the combustion temperature within the thermal 

incinerator when the emissions unit is in operation. 

Units shall be in degrees Fahrenheit. The monitoring 

and recording devices shall be capable of accurately 

measuring the desired parameter. The temperature 

monitor and recorder shall be installed, calibrated, 

operated and maintained in accordance with the 

manufacturer's recommendations, with any modifications 

deemed necessary by the permittee. 

2. The permittee shall collect and record the following 

information for each day: 

a. all 3-hour blocks of time during which the average 

combustion temperature within the thermal 

incinerator, when any associated emissions unit 

was in operation, was less than 1450 degrees 

Fahrenheit; and, 

b. a log of the downtime for the capture (collection) 

system, control device, and monitoring equipment, 

when the associated emissions unit was in 

operation. 

3. The permittee shall collect and record the following 

information for each day for the coating (R004-R007) , 

geicoat spay-up (R012), polyester resin spray-up (R013, 

R014), and clean-up operations: 

a. the company identification for each such material 

employed; 

b. the number of gallons of each such material 

employed; 
P.71 

13 of 17 Pages RECEIVED 

Facilit y Name: ARE , Inc 

Applicatio n Number: 02-2379 f£jj q >] Y$% 

Date : February 3, 1999 

A.R.E. mo. 

c. the organic compound content of each such 

material, in pounds per gallon; 

d. the total controlled organic compound emission 

rate for all coatings and cleanup materials, in 

pounds per day (i.e., calculated using the 

overall control efficiency from the most recent 

performance test that demonstrated that the 

emissions unit was in compliance) ; 

e. the total number of hours the associated emissions 

units were in operation; and, 

f. the average hourly controlled organic^ compound 

emission rate for all such materials, [i.e., 

(d)/(e), in pounds per hour (average)]. 

D. Reporting Requirements 

1. The permittee shall submit deviation (excursion) 

reports which identify all 3-hour blocks of time during 

which the average combustion temperature within the 

thermal incinerator does not comply with the 

temperature limitation specified above. These reports 

shall be submitted to the Ohio EPA Northeast District 

Office and shall be received within 45 days of any 

incident. 

2. The permittee shall submit deviation (excursion) 

reports which include an identification of each day 

during which the average hourly controlled organic 

compound emissions from the coating, geicoat spray-up, 

polyester resin spray-up, and clean-up operations 

exceeded 5 pounds per hour, and the actual average 

hourly controlled organic compound emissions for each 

such day. 

3. These reports shall be submitted to the Ohio EPA 

Northeast District Office and shall be received within 

45 days of any incident. 
14 of 17 Pages R' Fgf* ^ f \ f lg ^ 

Facilit y Name: ARE , In c rt£WtSlb if &IU': 

Applicatio n Number: 02-2379 r*-n , ,**, •..-.,•••,•. 

-"CD f; ij !.H.L':; 

Date : Februar y 3 , 1999 

„ „ ,. , . , A.R.E.BN&, 

E. Testing Requirements 

1. Compliance with the emission limitation(s) in Section 

A.I. of these terms and conditions shall be determined 

in accordance with the following method(s): 

a. Emission Limitation 

0.03 grain per dry standard cubic foot of exhaust 

from 4 bag filters 

Applicable Compliance Method 

OAC rule 3745-17-03(B) (10), if requested. 

b. Emission Limitation 

No visible emissions 

Applicable Compliance Method 

OAC rule 3745-17-03(B)(1), if requested 

c. Emission Limitation 

5.0 pounds per hour from RTO 

Applicable Compliance Method 

OAC rul e 3745-21-10(B). Recordkeeping specified 

above shall be used to determine compliance. 

Formulation data or USEPA Method 24 (for coatings) 

shal l be used to determine the organic compound 

contents of the organic materials. Results of the 

latest emissions testin g shall be used to 

(

 determine actual emissions. When calculating 

geicoa t emissions, an emission factor of 19.9 

percent shall be used. When calculating polyester 

resi n emissions, an emission factor of 12 percent 

shall be used. These emission factors are from 

the CFA recommended emission factors released by 

US EPA on March 18, 1998. 
P.73 

15 of 17 Pages 

Facilit y Name: ARE , Inc REOSE^E D 

Applicatio n Number: 02-2379 

Date: February 3, 1999 iY r> P ioc$ 

< _ -•' 

d. Emission Limitation A„IRLEo M C 

1.0 pound NOx per hour from RTO combustion 

Applicable Compliance Method 

Method "7 through 7E or Method 20 of 40 CFR Part 

60, Appendix A, if requested 

e. Emission Limitation 

Use of total permanent enclosure 

Applicable Compliance Method 

Method 204 through 204F of 40 CFR Part 60, 

Appendix A 

f. Emission Limitation 

95 percent Destruction Efficiency in RTO 

Applicable Compliance Method 

The permittee shall conduct, or have conducted, 

emission testing for this emissions unit in 

accordance with the following requirements: 

i. the emission testing shall be conducted 

within 3 months of startup of the RTO; 

ii. the emission testing shall be conducted to 

demonstrate compliance with the 95 percent 

destruction efficiency; 

iii. the following test method(s) shall be 

employed to demonstrate compliance - 18, 18A, 

25, or 25A. Alternative U.S. EPA approved 

test methods may be used,with prior approval 

from the Ohio EPA; 
P.74 

16 of 17 Pages Rpf**WF*r * 

Facilit y Name: ARE , Inc

 L^UWl£,[. tyfcQ? 

Applicatio n Number: 02-2379 -•-,-

Date : February 3 , 1999 -.••*- -i-cr 

M, P$ ^ 

iv. the test(s) shall be conducted while the0 

emissions units are operating at or near its 

maximum capacity, unless otherwise specified 

or approved by the Ohio EPA Northeast 

District Office; 

v. the capture efficiency shall be determined 

using Methods 204 through 204F, as specified 

in 40 CFR Part 51, Appendix M, or the 

permittee may request to use an alternative 

method or procedure for the determination of 

capture efficiency in accordance with the 

USEPA's "Guidelines for Determining Capture 

Efficiency," dated January 9, 1995. (The 

Ohio EPA will consider the request, including 

an evaluation of the applicability, 

necessity, and validity of the alternative, 

and may approve the use of the alternative if 

such approval does not contravene any other 

applicable requirement.) The control 

efficiency (i.e., the percent reduction in 

mass emissions between the inlet and outlet 

of the control system) shall be determined in 

accordance with the test methods and 

procedures specified in OAC rule 3745-21-10. 

The test methods and procedures selected 

shall be based on a consideration of the 

diversity of the organic species present and 

their total concentration, and on a 

consideration of the potential presence of 

interfering gases. 

Not later than 30 days prior to the proposed 

test date(s), the permittee shall submit an 

"Intent to Test" notification to the Ohio EPA 

Northeast District Office. The "Intent to 

Test" notification shall describe in detail 

the proposed test methods and procedures, the 

emissions unit operating parameters, the 

time(s) and date(s) of the test(s), and the 

person(s) who will be conducting the test(s). 
P.75 

17 of 17 Pages -A ts W £= I tf IS U' 

Facility Name: ARE , Inc --•--••. 

. • i- !•;•; ' •'. ;'"•;"• 

Application Number: 02-2379 '"- - ••

 ;»'-: 

Date: February 3, 1999 A.R.E. IN 

Failure to submit such notification for> 

review and approval prior to the test(s) may 

result in the Ohio EPA District Office's 

refusal to accept the results of the emission 

test(s). 

Personnel from the Ohio EPA Northeast 

District Office shall be permitted to witness 

the test(s), examine the testing equipment, 

and acquire data and information necessary to 

ensure that the operation of the emissions 

unit and the testing procedures provide a 

valid characterization of the emissions from 

the emissions unit and/or the performance of 

the control equipment. 

A comprehensive written report on the results 

of the emissions test(s) shall be signed by 

the person or persons responsible for the 

tests and submitted to the Ohio EPA Northeast 

District Office within 30 days following 

completion of the test(s). The permittee may 

request additional time for the submittal of 

the written report, where warranted, with 

prior approval from the Ohio EPA Northeast 

District Office. 

F. Miscellaneous Requirements 

1. None. 
P.76 

ONoEFA 

State of Ohio Environmental Protection Agency 

It Address: 

RECEIVED 

OCT 0 4 1999 

A.R.E, mc. 

Mailing Address: 

Lazarus Gov. Center 

122 S. Front Street 

Columbus, OH 43215 

TELE: (614) 644-3020 FAX: (614) 644-2329 Lazarus Gov. Center 

P.O. Box 1049 

Columbus, OH 43216-1049 

RE: FINAL PERMIT TO INSTALL 

STARK COUNTY 

Application No: 15-1386 

DATE: September 29,1999 

A.R.E., Inc. 

Clyde Richey 

PO Box 1100 

Massillon, OH 44648 

CERTIFIED MAIL 

"TOXIC REVfeNT " ~ 

PSD 

SYNTHETIC MINOR 

CEMS 

MACT 

NSPS 

NESHAPS 

NETTING 

MAJOR NON-ATTAINMENT 

MODELING SUBMITTED 

GASOLINE DISPENSING FACILITY 

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 

Review Appeals Commission pursuant to Chapter 3 745.04 ofthe 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 within thirty 

(30) days after the notice ofthe Directors action. A copy ofthe appeal must be served on the Director ofthe Ohio 

Environmental Protection Agency within three (3) days of filing with the Commission. An appeal may be filed with 

the Environmental Review Appeals Commission at the following address: 

Environmental Review Appeals Commission 

236 East Town Street, Room 300 

Columbus, Ohio 43215 

Very truly yours, 

Thomas G. Rigo 

jield Operations and Permit Section 

"Division of Air Pollution Control 

USEPA 

CANTON CITY HEALTH DEPARTMENT 
P.77 

OhfeEFft 

~?AG£ ±CF\<o 

STATE OF OHIO ENVIRONMENTAL PROTECTION AGENCY 

Permit To Install 

Terms and Conditions 

Issue Date: September 29,1999 

Effective Date: September 29. 1999 

FINAL PERMIT TO INSTALL 15-1386 

Application Number: 15-1386 

APS Premise Number: 1576131793 

Permit Fee: $200 

Name of Facility: A.R.E., Inc. 

Person to Contact: Clyde Richey 

Address: PO Box 1100 

Massillon, OH 44648 

Location of proposed air contaminant source(s) [emissions unit(s)]: 

400 Nave Road 

Massillon, Ohio 

Description of proposed emissions unit(s): 

MOLD CLEANING & RELEASE APPLICATION BOOTH WITH THERMAL OXIDIZER. 

The above named entity is hereby granted a Permit to Install for the above described emissions unit(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 emissions unit(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 emissions unit(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 
P.78 

Page 2 of 16 

A.R.E.,Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

September 29,1999 

Part I - GENERAL TERMS AND CONDITIONS 

A. State and Federally Enforceable Permit To Install General Terms and Conditions 

1. Monitoring and Related Recordkeeping and Reporting Requirements 

a. Except as may otherwise be provided in the terms and conditions for a specific emissions 

unit, the permittee shall maintain records that include the following, where applicable, for 

any required monitoring under this permit: 

i. The date, place (as defined in the pennit), and time of sampling or measurements. 

ii. The date(s) analyses were performed. 

iii. The company or entity that performed the analyses. 

iv. The analytical techniques or methods used. 

v. The results of such analyses. 

vi. The operating conditions existing at the time of sampling or measurement. 

b. Each record of any monitoring data, testing data, and support information required pursuant 

to this permit shall be retained for a period of five years from the date the record was created. 

Support information shall include, but not be limited to, all calibration and maintenance 

records and all original strip-chart recordings for continuousmonitoringinstrumentation, and 

copies of all reports required by this permit. Such records may be maintained in 

computerized form. 

c. Except as may otherwise be provided in the terms and conditions for a specific emissions 

unit, the permittee shall submit required reports in the following manner: 

i. Reports of any required monitoring and/or recordkeeping qf federally enforceable 

information shall be submitted to the appropriate Ohio EPA District Office or local 

air agency. 

ii. Quarterly written reports of (i) any deviations from federally enforceable emission 

limitations, operational restrictions, and control device operating parameter 

limitations, excluding deviations resulting from malfunctions reported in accordance 

with OAC rule 3745-15-06, that have been detected by the testing, monitoring and 

recordkeeping requirements specified in this permit, (ii) the probable cause of such 

deviations, and (iii) any corrective actions or preventive measures taken, shall be 

made to the appropriate Ohio EPA District Office or local air agency. The written 

reports shall be submitted quarterly, i.e., by January 31, April 30, July 31, and 

KK'-KrilkaJi^-f i 
P.79 

Page 3 of 16 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

September 29,1999 

October 31 of each year and shall cover the previous calendar quarters. See B. 11 

below if no deviations occurred during the quarter. 

iii. Written reports, which identify any deviations from the federally enforceable 

monitoring, recordkeeping, and reporting requirements contained in this permit shall 

be submitted to the appropriate Ohio EPA District Office or local air agency every 

six months, i.e., by January 31 and July 31 of each year for the previous six calendar 

months. If no deviations occurred during a six-month period, the permittee shall 

submit a semi-annual report, which states that no deviations occurred during that 

period. 

iv. Each written report shall be signed by a responsible official certifying that, based on 

information and belief formed after reasonable inquiry, the statements and 

information in the report are true, accurate, and complete. 

2. Scheduled Maintenance/Malfunction Reporting 

Any scheduled maintenance of air pollution control equipment shall be performed in accordance 

with paragraph (A) of OAC rule 3745-15-06. The malfunction, i.e., upset, of any emissions units 

or any associated air pollution control system(s) shall be reported to the appropriate Ohio EPA 

District Office or local air agency in accordance with paragraph (B) of OAC rule 3 745-15-06. (The 

definition ofan upset condition shall be the same as that used in OAC rule 3745-15-06(B)(l) for a 

malfunction.) The verbal and written reports shall be submitted pursuant to OAC rule 3745-15-06. 

Except as provided in that rule, any scheduled maintenance or malfunction necessitating the 

shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown 

ofthe emission unit(s) that is (are) served by such control system(s). 

3. Risk Management Plans 

If the permittee is required to develop and register a risk management plan pursuant to section 112(r) 

ofthe Clean Air Act, as amended, 42 U.S.C. 7401 et seq. ("Act"), the permittee shall comply with 

the requirement to register such a plan. 

4. Title IV Provisions 

If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee 

shall ensure that any affected emissions unit complies with those requirements. Emissions exceeding 

any allowances that are lawfully held under Title IV of the Act, or any regulations adopted 

thereunder, are prohibited. 
P.80 

Page 4 of 16 

A.R.E.,Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

-September 29,1999 

5. Severability Clause 

A determination that any term or condition ofthis permit is invalid shall not invalidate the force or 

effect of any other term or condition thereof, except to the extent that any other term or condition 

depends in whole or in part for its operation or implementation upon the term or condition declared 

invalid. 

6. General Requirements 

a. The permittee must comply with all terms and conditions ofthis pennit. Any noncompliance 

with the federally enforceable terms and conditions ofthis permit constitutes a violation of 

the Act, and is grounds for enforcement action or for permit revocation, revocation and 

reissuance, or modification, or for denial ofa permit renewal application. 

b. It shall not be a defense for the permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

federally enforceable terms and conditions ofthis permit. 

c. This permit may be modified, reopened, revoked, or revoked and reissued, for cause. The 

filing ofa request by the permittee for a permit modification, revocation and reissuance, or 

revocation, or ofa notification of planned changes or anticipated noncompliance does not 

stay any term and condition ofthis permit. 

d. This permit does not convey any property rights of any sort, or any exclusive privilege. 

e. The permittee shall furnish to the Director ofthe Ohio EPA, or an authorized representative 

of the Director, upon receipt of a written request and within a reasonable time, any 

information that may be requested to determine whether cause exists for modifying, 

reopening or revoking this permit or to determine compliance with this permit. Upon 

request, the permittee shall also furnish to the Director or an authorized representative ofthe 

Director, copies of records required to be kept by this permit. For information claimed to be 

confidential in the submittal to the Director, if the Admimstrator ofthe U.S. EPA requests 

such information, the permittee may furnish such records directly to the Admimstrator along 

with a claim of confidentiality. , 

7. Fees 

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 

3745.11 and OAC Chapter 3745-78. The permittee shall pay all applicable Permit To Install fees 

within 30 days after the issuance ofthis Permit To Install. 
P.81 

Page 5 of 16 • 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

September 29,1999 

8. Federal and State Enforceability 

Only those terms and conditions designated in this permit as federally enforceable, that are required 

under the Act, or any of its applicable requirements, including relevant provisions designed to limit 

the potential to emit of a source, are enforceable by the Administrator ofthe U.S. EPA, the State, 

and citizens under the Act. All other terms and conditions of this permit shall not be federally 

enforceable and shall be enforceable under State law only. 

9. Compliance Requirements 

a. Any document (including reports) required to be submitted and required by a federally 

applicable requirement in this permit shall include a certification by a responsible official 

that, based on information and belief formed after reasonable inquiry, the statements in the 

document are true, accurate, and complete. 

b. Upon presentation of credentials and other documents as may be required by law, the 

permittee shall allow the Director of the Ohio EPA or an authorized representative of the 

Director to: 

i. At reasonable times, enter upon the permittee's premises where a source is located 

or the emissions-related activity is conducted, or where records must be kept under 

the conditions of this permit. 

ii. Have access to and copy, at reasonable times, any records that must be kept under the 

conditions ofthis permit, subject to the protection from disclosure to the public of 

confidential information consistent with ORC section 3704.08. 

iii. Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under this 

permit. 

iv. As authorized by the Act, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the permit and applicable 

requirements. 

c. The permittee shall submit progress reports to the appropriate Ohio EPA District Office or 

local air agency concerning any schedule of compliance for meeting an applicable 

requirement. Progress reports shall be submitted semiannually, or more frequently if 

specified in the applicable requirement or by the Director ofthe Ohio EPA. Progress reports 

shall contain the following: 

i. Dates for achieving the activities, milestones, or compliance required in any schedule 

of compliance, and dates when such activities, milestones, or compliance were 

achieved. 
P.82 

Page 6 of 16 

A.R.E.,Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

September 29,1999 

ii. An explanation of why any dates in any schedule of compliance were not or will not 

be met, and any preventive or corrective measures adopted. 

10. Permit To Operate Application 

If the permittee is required to apply for a Title V permit pursuant to OAC Chapter 3745-77, 

the permittee shall submit a complete Title V permit application or a complete Title V permit 

modification application within twelve (12) months after commencing operation of the 

emissions units covered by this permit. However, if the proposed new or modified source(s) 

would be prohibited by the terms and conditions of an existing Title V permit, a Title V 

permit modification must be obtained before the operation of such new or modified source(s) 

pursuant to OAC rule 3745-77-04(D) and OAC rule 3745-77-08(C)(3)(d). 

If the permittee is required to apply for permit(s) pursuant to OAC Chapter 3745-35 , the 

source(s) identified in this Permit To Install is (are) permitted to operate for a period of up 

to one year from the date the source(s) commenced operation. 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. Pursuant to OAC Chapter 3745-35, 

the permittee shall submit a complete operating permit application within thirty (30) days 

after commencing operation ofthe source(s) covered by this permit. 
P.83 

Page 7 of 16 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

^September 29,1999 

B. State Only Enforceable Permit To Install General Terms and Conditions 

1. Compliance Requirements 

The emissions unit(s) identified in this Permit to Install shall remain in full compliance with all 

applicable State laws and regulations and the terms and conditions ofthis permit. 

2. Reporting Requirements Related to Monitoring and Recordkeeping Requirements 

The permittee shall submit required reports in the following manner: 

a. Reports of any required monitoring and/or recordkeeping of state-only enforceable 

information shall be submitted to the appropriate Ohio EPA District Office or local air 

agency. 

b. Except as otherwise may be provided in the terms and conditions for a specific emissions 

unit, quarterly written reports of (a) any deviations (excursions) from state-only required 

emission limitations, operational restrictions, and control device operating parameter 

limitations that have been detected by the testing, monitoring, and recordkeeping 

requirements specified in this permit, (b) the probable cause of such deviations, and (c) any 

corrective actions or preventive measures which have been or will be taken, shall be 

submitted to the appropriate Ohio EPA District Office or local air agency. If no deviations 

occurred during a calendar quarter, the permittee shall submit a quarterly report, which states 

that no deviations occurred during that quarter. The reports shall be submitted quarterly, i.e., 

by January 31, April 30, July 31, and October 31 of each year and shall cover the previous 

calendar quarters. (These quarterly reports shall exclude deviations resulting from 

malfunctions reported in accordance with OAC rule 3745-15-06.) 

3. Permit Transfers 

Any transferee of this pennit shall assume the responsibilities of the prior permit holder. The 

appropriate Ohio EPA District Office or local air agency must be notified in writing of any transfer 

of this permit. 

4. Air Pollution Nuisance 

The air contaminants emitted by the emissions units covered by this pennit shall not cause a public 

nuisance, in violation of OAC rule 3745-15-07. 

5. Termination of Permit To Install 

J This pennit to install shall terminate within eighteen months ofthe effective date ofthe permit to 

install if the owner or operator has not undertaken a continuing program of installation or 

modification or has not entered into a binding contractual obligation to undertake and complete 
P.84 

Page 8 of 16 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

"September 29,1999 

within a reasonable time a continuing program of installation or modification. 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. 

6. Construction of New Sources(s) 

The proposed emissions unit(s) shall be constructed in strict accordance with the plans and 

application submitted for this permit to the Director ofthe Ohio Environmental Protection Agency. 

There may be no deviation from the approved plans without the express, written approval ofthe 

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 ofthe Ohio Environmental Protection Agency if the proposed 

sources are inadequate or cannot meet applicable standards. 

If the construction ofthe proposed emissions unit(s) has already begun or has been completed prior 

to the date the Director ofthe Environmental Protection Agency approves the permit application and 

plans, the approval does not constitute expressed or implied assurance that the proposed facility has 

been constructed in accordance with the approved plans. The action of beginning and/or completing 

construction prior to obtaining the Director's approval constitutes a violation of OAC rule 3745-31 -

02. Furthermore, issuance of the Permit to Install does not constitute an assurance that the proposed 

source will operate in compliance with all Ohio laws and regulations. Approval ofthe plans in any 

case is not to be construed as an approval ofthe facility as constructed and/or completed. Moreover, 

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

Environmental Protection Agency (or other persons) may have against the applicant for starting 

construction prior to the effective date ofthe permit. Additional facilities shall be installed upon 

orders ofthe Ohio Environmental Protection Agency if the proposed facilities prove to be inadequate 

or cannot meet applicable standards. 

7. 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. 

8. Applicability 

This Permit to Install is applicable only to the emissions unit(s) identified in the Permit To Install, 

Separate application must be made to the Director for the installation or modification of any other 

emissions unit(s). 

9. 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 ofthis permit will fulfill this requirement. 
P.85 

Page 9 of 16 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

September 29,1999 

10. Construction Compliance Certification 

The applicant shall provide Ohio EPA with a written certification (see enclosed form) that the 

facility has been constructed in accordance with the Permit To Install application and the terms and 

conditions ofthe Permit to Install. The certification shall be provided to Ohio EPA upon completion 

of construction but prior to startup ofthe source. 

11. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable 

Emission Limitations, Operational Restrictions, or Control Device Operating Parameter 

Limitations (See Section A of This Permit) 

If no deviations occuned during a calendar quarter, the. permittee shall submit a quarterly report, 

which states that no deviations occuned during that quarter. The reports shall be submitted 

quarterly, i.e., by January 31, April 30, July 31, and October 31 of each year and shall cover the 

previous calendar quarters. 

C. Permit To Install Summary of Allowable Emissions 

The following information summarizes the total allowable emissions, by pollutant, based on the 

individual allowable emissions of each air contaminant source identified in this permit. 

SUMMARY (for informational purposes only) 

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS 

Pollutant Tons Per Year 

OC 1.89 
P.86 

Page 10 of 16 

A.R.E.,Inc. Facility ID: 1576131793 

PTI Application: 15-1386 

September 29,1999 

Part II - FACILITY SPECIFIC TERMS AND CONDITIONS 

A. State and Federally Enforceable Permit To Install Facility Specific Terms and Conditions 

1. None 

B. State Only Enforceable Permit To Install Facility Specific Terms and Conditions 

1. None 

3 
P.87 

Page 11 of 16 

A.R.E., Inc. 

PTI Application: 15-1386 

September 29,1999 

Facility ID: 1576131793 

Emissions Unit ID: POH 

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S) 

A. State and Federally Enforceable Section 

I. Applicable Emissions Limitations and/or Control Requirements 

1. The specific operations(s), property, and/or equipment which constitute this emissions unit 

are listed in the following table along with the applicable rules and/or requirements and with 

the applicable emissions limitations and/or control measures. Emissions from this unit shall 

not exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table. 

Operations, Property, 

and/or Equipment 

Mold cleaning & release 

application booth with 

thermal oxidizer 

Applicable Rules/Requirements 

OAC rule 3745-21-07(G) 

OAC rule 3745-17-07 

OAC rule 3745-17-11 

Applicable Emissions 

Limitations/Control Measures 

8 pounds OC/hour 

40 pounds OC/day 

See A.I.2.a. 

20% opacity, as a 6-minute average, 

except as provided by rule 

0.551 pound PM/hour 

2. Additional Terms and Conditions 

2.a Instead of meeting the 8 lbs/hr and 40 lbs/day organic compound limits, an emissions 

unit can reduce the OC emissions by at least 85% and still be in compliance with 

OAC rule 3745-21 -07(G)(2). In addition, OAC rule 3745-21 -07(G)(6) requires that 

if OC emissions are reduced by an oxidizer, this oxidizer must have a minimum 

destruction efficiency of 90% at all times during operation. (Note: BAT found in 

section B.I.2.a. requires an overall control efficiency of 95%). 

II. Operational Restrictions 

1. The permittee shall employ a dry exhaust filtration system to catch overspray before it enters 

the ductwork leading to the oxidizer. 

2. The average combustion temperature within the thermal oxidizer, for any 3-hour block of 

time the emissions unit is in operation, shall not be more than 50 degrees below the average 

temperature during the most recent emission test that demonstrated the emissions unit was 

in compliance. 

The permittee shall maintain records ofthe maintenance performed on the thermal oxidizer. 
P.88 

Page 12 of 16 

A.R.E.,Inc. Facility ID: 1576131793 

PTI Application: 15-1386 Emissions Unit ID: POH 

f*5f eptember 29,1999 

III. Monitoring and/or Recordkeeping Requirements 

1. The permittee shall operate and maintain a continuous temperature momtor and recorder 

which measures and records the combustion temperature within the thermal oxidizer when 

the emissions unit is in operation. Units shall be in degrees Fahrenheit. The monitoring and 

recording devices shall be capable of accurately measuring the desired parameter. The 

temperature monitor and recorder shall be installed, calibrated, operated and maintained in 

accordance with the manufacturer's recommendations, with any modifications deemed 

necessary by the permittee. 

The permittee shall collect and record the following information for each day: 

a. all 3-hour blocks of time during which the average combustion temperature within 

the thermal oxidizer, when the emissions unit is in operation, was more than 50 

degrees below the average temperature during the most recent eniissions test that 

demonstrated the emissions unit was in compliance; and, 

b. a log of the downtime for the capture (collection) system, control device, and 

monitoring equipment, when the associated emissions unit was in operation. 

2. The permittee shall collect and record the following information on a monthly basis for the 

purposes of determining monthly emissions: 

a. the name and identification number of each mold release coating, cleaner and 

cleanup solvent employed; 

b. the OC content of each mold release coating, cleaner and cleanup solvent in pounds 

per gallon; 

c. the number of gallons of each mold release coating, cleaner and cleanup solvent 

employed; 

d. the total uncontrolled OC emissions from all mold release coatings, cleaners and 

cleanup solvents employed, in pounds or tons; and, 

e. the calculated, controlled OC emission rate for all mold release coatings, cleaners 

and cleanup solvents, in pounds or tons. The controlled OC emission rate shall be 

calculated using the overall control efficiency for the control equipment as 

determined during the most recent emission test that demonstrated that the emission 

unit was in compliance. 

IV. Reporting Requirements 

1. The permittee shall submit quarterly deviation (excursion) reports which identify all 3-hour 

blocks of time during which the average combustion temperature within the thermal oxidizer 

does not comply with the temperature limitation specified above. 
P.89 

Page 13 of 16 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 Emissions Unit ID: POH 

^September 29,1999 

V. Testing Requirements 

1. Compliance with the emission limitation(s) ofthis permit shall be determined in accordance 

with the following method(s): 

a. Emission Limitation: 

An emissions unit can reduce the OC emissions by at least 85% and still be in 

compliance with OAC rule 3745-21-07(G)(2). In addition, OAC rule 3745-21-

07(G)(6) requires that if OC emissions are reduced by an oxidizer, this oxidizer must 

have a minimum destruction efficiency of 90% at all times during operation. 

Applicable Compliance Method: 

Emission testing and operation ofthe mold cleaning & release application booth in 

conformance with the requirements of a total permanent enclosure. 

b. Visible Emission Limitation: 

20% opacity, as a 6-minute average, except as provided by rule 

Applicable Compliance Method: 

Compliance shall be determined by visible emission evaluations performed in 

accordance with procedures specified in OAC rule 3745-17-03(B)(l) using the 

methods and procedures specified in USEPA Reference Method 9. 

c. Emission Limitation: 

0.551 lb PM/hr 

Applicable Compliance Method: 

To determine the actual worst case emission rate for particulate matter, the following 

equation shall be used: 

E = [maximum coating solids usage rate (in pounds per hour)] X (1-TE) X (1-CE) 

E = particulate emissions rate (lbs/hr) 

TE = transfer efficiency = 70%, which is the ratio ofthe amount of coating solids 

deposited on the coated part to the amount of coating solids used 

CE = control efficiency = 95% (both the dry exhaust filtration system and the 

thermal oxidizer) 

2. The permittee shall conduct, or have conducted, emission testing for this emissions unit in 

accordance with the following requirements: 

a. The emission testing shall be conducted within 6 months after startup of this 

emissions unit. 
P.90 

Page 14 of 16 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 Emissions Unit ID: P011 

-September 29,1999 

b. The emission testing shall be conducted to demonstrate compliance with the OC 

capture efficiency and control efficiency requirements specified in section A.I.2.a. 

(Note: BAT requires a 95% overall control efficiency see B.I.2.a.). 

c. The test(s) shall be conducted while all ofthe emissions units vented to the thermal 

oxidizer are operating at or near their maximum capacities, unless otherwise 

specified or approved by the Canton local air agency. 

d. The capture efficiency shall be determined using Methods 204 through 204F, as 

specified in 40 CFR Part 51, Appendix M, or the permittee may request an 

alternative method or procedure for the determination of capture efficiency in 

accordance with the "Guidelines for Determining Capture Efficiency", dated January 

9, 1995. (The Ohio EPA will consider the request, including an evaluation ofthe 

applicability, necessity, and validity ofthe alternative, and may approve the use of 

the alternative if such approval does not contravene any other applicable 

requirement.) 

e. The control efficiency (i.e., the percent reduction in mass emissions between the inlet 

and the outlet ofthe control system) shall be determined in accordance with the test 

methods and procedures specified in OAC rule 3745-21-10 or an approved 

alternative test protocol. The test methods and procedures selected shall be based on 

a consideration of the diversity of the organic species present and their total 

concentration, and on a consideration ofthe potential presence of interfering gases. 

f. Not later than 30 days prior to the proposed test date(s), the permittee shall submit 

an "Intent to Test" notification to the Canton local air agency. The "Intent to Test" 

notification shall describe in detail the proposed test methods and procedures, the 

emissions unit operating parameters, the time(s) and date(s) ofthe test(s), and the 

person(s) who will be conducting the test(s). Failure to submit such notification for 

review and approval prior to the test(s) may result in the Canton Local Air Agency's 

refusal to accept the results of the emission test(s). 

Personnel from the Canton local air agency shall be permitted to witness the test(s), 

examine the testing equipment, and acquire data and information necessary to ensure 

that the operation ofthe emissions unit and the testing procedures provide a valid 

characterization ofthe emissions from the emissions unit and/or the performance of 

the control equipment. 

A comprehensive written report on the results ofthe emissions test(s) shall be signed 

by the person or persons responsible for the tests and submitted to the Canton local air 

agency within 30 days following completion ofthe test(s). 

VI. Miscellaneous Requirements 

1. None 
P.91 

Page 15 of 16 

A.R.E., Inc. 

PTI Application: 15-1386 

^September 29,1999 

B. State Only Enforceable Section 

Facility ID: 1576131793 

Emissions Unit ID: POH 

Applicable Emissions Limitations and/or Control Requirements 

1. The specific operations(s), property, and/or equipment which constitute this emissions unit 

are listed in the following table along with the applicable rules and/or requirements and with 

the applicable emissions limitations and/or control measures. Emissions from this unit shall 

not exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table. 

Operations, Property, 

and/or Equipment 

Mold cleaning & release 

application booth with 

thermal oxidizer 

Applicable 

Rules/Requirements 

OAC rule 3745-31-05 

Applicable Emissions 

Limitations/Control Measures 

OC: 

10.38 pounds/day 

1.89 tons/year 

see T&Cs 2.a, 2.b & 2.c below 

Additional Terms and Conditions 

2.a The OC emissions from this emissions unit shall be reduced by at least 95%. 

2.b This emissions unit shall be totally enclosed such that OC emissions are captured 

and contained for discharge through the thermal oxidizer. The capture efficiency 

shall be determined using Methods 204 through 204F, as specified in 40 CFR Part 

51, Appendix M, or the permittee may request an alternative method or procedure 

for the determination of capture efficiency in accordance with the "Guidelines for 

Determining Capture Efficiency", dated January 9, 1995. (The Ohio EPA will 

consider the request, including an evaluation of the applicability, necessity, and 

validity of the alternative, and may approve the use of the alternative if such 

approval does not contravene any other applicable requirement.) The operation ofthe 

mold cleaning & release application booth shall conform with the requirements for 

a total permanent enclosure consistent with conditions demonstrated during the most 

recent performance test. 

2.c High Volume Low Pressure (HVLP) spray guns shall be employed for any material 

that is applied by the use ofa spray gun. 

II. Operational Restrictions 

None 
P.92 

Page 16 of 16 

A.R.E., Inc. Facility ID: 1576131793 

PTI Application: 15-1386 Emissions Unit ID: PO 11 

September 29,1999 

IU. Monitoring and/or Recordkeeping Requirements 

1. None 

IV. Reporting Requirements 

1. None 

V. Testing Requirements 

1. Compliance with the emission limitation(s) ofthis permit shall be determined in accordance 

with the following method(s): 

a. Emission Limitation: 

10.38 pounds OC/day 

1.89 tons OC/year 

Applicable Compliance Method: 

Compliance is to be based upon a one-time calculation using maximum capabilities 

ofthe coating equipment and permit allowable overall control efficiency. 

VI. Miscellaneous Requirements 

1. Pursuant to Engineering Guide #69, modeling to demonstrate compliance with the Ohio 

EPA's Air Toxic Policy was not necessary since the emissions unit's maximum annual 

emissions for each toxic compound will be less than 1.0 ton. OAC Chapter 3745-31 requires 

permittees to apply for and obtain a new or modified permit to install prior to making a 

"modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that 

changes in the composition of materials, or use of new materials, that would result in an 

increase in emissions of any pollutant that has a listed TLV to above 1.0 ton per year may 

require the permittee to apply for and obtain a new permit to install. 
P.93 

Kb-b. i"->.<-2-**> iii ; C3<iH' l MKtL LUdd l i rj. it i r.e:' 

ENTROPY, INC. 

P.O. Box900G7 

Raleigh, North Carolina 27675-0067 

i 

Telephone' 919.7813650 FAX: 919.787.8442 

i 800.486.3550 

FAX \C O V £ R SHEET 

DATE: ! Febnjary 14.2000 

I 

TO: | Clyde Richey 

COMPANY: I A.R.E., Inc. 

FAX: ! 3304307845 

CC: 

FROM: 

PAGES (Inchxfing cover): 2 

Carl F. Fink 

TELEPHONE: 800-464-2042 x211 

FAX: 

ext 260 

SUBJECT: Copy of airflow checks at tunnel outiet 

Message 

Here] Is a copy ofthe airflow checks that we did during the December 1995 testing. These 

measurements were taken at the Assembly Area end of the tunnel. This data was not 

Induced in the report because the tunnel was not considered an NDO forthe enclosure 

room. 

If youi have any more questions, please call me at 80O-486-3550, ext 260. I'll try to get you 

the njew quote In the next 2 or 3 days. 

Tharjks. 
P.94 

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