Enclosure 1
ENCLOSURE 1

INFORMATION COLLECTION REQUEST FOR

Off-Site Waste and Recovery Operations

This information collection request is being conducted by the Environmental Protection Agency’s (EPA) 

Office of Air and Radiation (OAR) to assist the EPA Administrator in developing emission standards for 

Off-Site Waste and Recovery Operations under Clean Air Act (CAA) section 112. The survey is being sent 

under the authority of Section 114 of the CAA. 

BACKGROUND:

Section 112 (d) of the Clean Air Act (CAA) calls for EPA to promulgate national technology-based emission 

standards for hazardous air pollutants (NESHAP) for sources emitting one or more of the HAP listed in CAA 

section 112(b). For major sources, these technology-based standards must reflect the maximum degree of 

emissions reductions of HAP achievable (after considering cost, energy requirements, and nonair quality 

health and environmental impacts). In addition, under CAA section 112(d)(6), EPA is required to review 

the technology-based standards and revise them “as necessary (taking into account developments in 

practices, processes, and control technologies)” no less frequently than every 8 years. Furthermore, we are 

required by section 112(f) (2) of the Clean Air Act (CAA) to assess the risk remaining (residual risk) eight 

years after the promulgation of maximum achievable control technology (MACT) standards under section 

112(d). If we find the residual risk fails to protect public health with an ample margin of safety or to prevent 

(taking into consideration various factors) adverse environmental effects, we are required to promulgate 

more stringent standards. 

The Off-Site Waste and Recovery Operations maximum achievable control technology (MACT) standards 

were promulgated on July 1, 1996 (see 61 FR 34140). We are collecting specific detailed information to 

support development of standards as part of our review as described above. Please note this survey is for offsite waste and recovery operations only. 

CAA section 114(a) states that the Administrator may require any person who owns or operates any emission 

source, who manufactures emission control equipment or process equipment, who the Administrator believes 

may have information necessary for the purposes set forth in section 114(a), or who is subject to any 

requirement of the CAA (other than certain provisions under Title II), to provide EPA with information for 

the following purposes:

1. Developing or assisting in the development of the following:

a. State implementation plans (§§ 110 and 111(d));

b. New Source Performance Standards (NSPS) (§ 111);

c. National Emissions Standards for Hazardous Air Pollutants (NESHAP) (§ 112);

d. Solid waste combustion or other related solid waste regulations (§ 129);

2. Determining whether any person is in violation of any standards or requirements developed under 

the authorities cited above; or

3. Carrying out any provision under the CAA (except certain provisions under Title II).

The Administrator may require that those persons identified above do the following so the Administrator 

may have the information necessary for the items listed in #1-3:

 establish and maintain records; 

 make reports; 
 install, use, and maintain monitoring equipment, and use audit procedures, or methods; 

 sample emissions (in accordance with such procedures or methods, at such locations, at such 

intervals, during such periods, and in such manner as the Administrator shall prescribe); 

 keep records on control equipment parameters, production variables or other indirect data when 

direct monitoring of emissions is impractical; 

 submit compliance certifications in accordance with section 114(a)(3); and 

 provide such other information as the Administrator may reasonably require.

DIRECTIONS: 

 All recipients must complete and return this survey by April 10, 2013.

 Please identify clearly any response(s) that you consider to be confidential business 

information (CBI). Any responses not so identified will be included in a publicly available 

database. Refer to Enclosures 3, 4, 5, and 6 for more information on the treatment of CBI and a list 

of information you may be asked to submit later to substantiate a claim of confidentiality.

DEFINITIONS: For the purposes of this ICR only, terms used have the meanings attributed to them in 40 

CFR 63.681. 

CONFIDENTIAL BUSINESS INFORMATION (CBI): 

Please indicate if any CBI is included in this survey response: Y XN 

OFF-SITE WASTE AND RECOVERY OPERATIONS

We believe that you own a facility that has Off-Site Waste and Recovery Operations. If you believe that 

this survey does not pertain to you, please indicate your reason below: 

 The Off-Site Waste and Recovery Operations are permanently shut down. Please also identify the 

date the Off-Site Waste and Recovery Operations were shut down, what steps were taken to close the 

equipment or stop operations, and if you still have a permit.

_________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

 No Off-Site Waste and Recovery Operations at this facility. Please identify the operations at the 

facility. 

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

If your facility does not have Off-Site Waste and Recovery Operations, please respond as soon as 

possible. We will review that information and respond as to whether you need to complete any other part 

of the survey.
Enclosure 2
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 1 of 20

General Information

Name of Legal Owner: Systech Environmental Corporation

Legal Owner Address: 3085 Woodman Dr. , Suite 300, Dayton, OH 45420

Number of Legal Owner Employees: 937-643-1240

Facility Name: Systech Environmental Corporation- Paulding Facility

Facility Address: 11397 County Rd 176, Paulding, OH 45879

Mailing Address (if different from 

facility address): PO Box 266, Paulding, OH 45879

Facility Contact Name: Jeff Hunyor

Facility Contact Title: Facility Manager

Facility Contact Phone Number: 419-399-4835

Facility Contact Email Address: jeff.hunyor@lafarge-na.com

Number of Company Employees at 

the Entire Facility: 12

Please enter any other comments 

regarding general ownership 

information here:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 2 of 20

Facility Information

Is the facility a major source for HAP? (see definition below)

Major sources are any stationary source or group of stationary 

sources located within a contiguous area and under common 

control that emits or has the potential to emit considering 

controls, in the aggregate, 10 tons per year (TPY) or more of any 

hazardous air pollutant or 25 TPY or more of any combination of 

HAP. 

Are there one or more off-site waste management or recovery 

operations at the facility subject to the Off-Site Waste and 

Recovery Operations (OSWRO) MACT (40 CFR 63, subpart DD)?

Is the facility exempt from complying with the OSWRO MACT?

What type(s) of off-site waste does the facility accept? (please 

include shipment method, physical form (i.e., solid, liquid, 

sludge), and a general description)

Approximately how many sources (facilities) does that waste 

come from?

What is the base year for which information is being provided? 

(please limit reporting years between 2006 and 2012, and 

provide the most current year)

For this base year, what was the amount of off-site waste 

received? (please specify units; e.g., gal/yr)

2012

26,056,799 gallons/yr(2012)

If yes, please explain:

The site receives liquid organic hazardous waste 

from generators and other TSDFs in tanker trucks, 

rail cars and drums (totes/drums) 

65
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 3 of 20

Facility Information

For this base year, what was the HAP content of the off-site 

waste received? (please specify units; e.g., tons)

How many hours per year are control devices bypassed to the 

atmosphere to perform routine maintenance?

Are any OSWRO operations scheduled to be discontinued? 

Are any OSWRO operations scheduled to be added or expanded?

What is the permitting classification of your facility?

What are the operating permit IDs for the OSWRO operations at 

your facility?

Is your operating permit available online?

If yes, please provide dates of closure and explain 

changes:

a 150,000 gallon tank is scheduled to be built in 

none, whenever the primary control device is 

unavailable then the system automatically redirect 

Title V permit No. P0109368, emission units, T008, 

T009, T010, T011, T026, T027, T028, T029, P801, 

If yes, please provide a link to or a copy of your 

most recent operating permit. If no, please 

provide a copy of your most recent operating 

5,062,836 gallons for 2012

If yes, please provide date(s) that addition(s) 

and/or expansion(s) will begin production and 

explain changes:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 4 of 20

Facility Information

Please provide the coordinates (in decimal degrees) of your 

facility property boundary at each corner (node). Alternatively, 

please provide the minimum distance from any OSWRO emission 

point to the facility property boundary.

Please enter any other comments regarding the facility here:

50 feet
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 5 of 20

If no, please explain.

If no, please explain.

If "Other", please explain:

have also used the protocol for equipment leak emission rates 

EPA-453/R-95-017 Tables 2-9 and 2-1

If "Other", please explain:

If neither apply, please explain:

If yes, please describe the control technique(s):

With which subpart do you comply for equipment leaks?

Please provide documentation demonstrating the basis for 

the equipment leak emissions estimates. What type of 

documentation are you providing?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Equipment Leaks

Have you verified and/or corrected the equipment leak 

emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO equipment leaks in Enclosure 2A?

What emissions calculation approach was used to estimate 

the equipment leak emissions?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 6 of 20

Equipment Leaks

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Pumps 24

Compressors 0

Agitators 8

Pressure relief devices 8

Sampling connection systems 0

Open-ended valves or lines 0

Connectors 2246

Instrumentation systems 0

all opened ended lines are capped. Connectors includes 

flanges, in-line valves, tank fittings, closesd vent systems 

Please enter any other comments regarding equipment leaks 

here:

What is the number of each type of component for the 

equipment in OSWRO HAP service (equipment that contacts 

off-site material having a total HAP concentration ≥ 10% by 

weight for 300 hours/year or more)?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

the piping sysems are all welded unless there is a pump, 

flange or other piece of equipment in the line and thie leaks 

from these copemens are included on the with "equipment 

leaks."

If no, please explain.

see abpove explamation

If "Other", please explain:

If "Other", please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of this 

practice above that required by the OSWRO NESHAP:

as noted above, any transfer system emissions are 

accounted for in the equipment leak section since the 

Please enter any other comments regarding transfer systems 

here:

Transfer Systems

Have you entered the OSWRO transfer system emissions in 

Enclosure 2A?

Have you completed all control information fields for your 

OSWRO transfer systems in Enclosure 2A?

What emissions calculation approach was used to estimate 

the transfer system emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the transfer system emissions estimates. Are you providing 

emissions factors or source test data?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

there are no oil-water and organic separators at the facility

If no, please explain.

If "Other", please explain:

If "Other", please explain:

If yes, please describe the control technique(s):

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the oil-water and organic-water separators emissions 

estimates. Are you providing emissions factors or source 

test data?

Oil-water and organic-water separators

Have you entered the OSWRO oil-water and organic-water 

separators emissions in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO oil-water and organic-water separators in Enclosure 

2A?

What emissions calculation approach was used to estimate 

the oil-water and organic-water separators emissions?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Oil-water and organic-water separators

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Please enter any other comments regarding organic or oilwater separators here:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain.

If "Other", please explain:

also Tanks program

If yes, please describe the control technique(s):

Containers

Have you entered the OSWRO containers emissions in 

Enclosure 2A?

Have you completed all control information fields for your 

OSWRO containers in Enclosure 2A?

What emissions calculation approach was used to estimate 

the containers emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the containers emissions estimates. Are you providing 

emissions factors or source test data?

Please provide the additional capital and annual 

costs of this practice above that required by the 

OSWRO NESHAP:

If "Other", please explain:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Containers

Please list each OSWRO container requiring Level 1 or Level 2 control: 

Container ID Container capacity

Container emissions control level 

implemented

155 rail tanker cars approx. 20,000 gallons

bottom unloading, hatch open only to 

alow air in

120 totes approx. 300 gallons

93 55-gallon drums on ave. 55 gallons

4134 tanker trucks approx. 5500 gallons

Please enter any other comments regarding containers 

here:

Systech manages HAP material in that is shipped 

to it for processing before being used as a fuel in 

(add information for more containers as necessary)
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain.

If "Other", please explain:

If "Other", please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of this 

practice above that required by the OSWRO NESHAP:

Surface Impoundments

Have you entered the OSWRO surface impoundments 

emissions in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO surface impoundments in Enclosure 2A?

What emissions calculation approach was used to estimate 

the surface impoundments emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the surface impoundments emissions estimates. Are you 

providing emissions factors or source test data?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Surface Impoundments

Systech does not have any surface impoundments.

Please enter any other comments regarding surface 

impoundments here:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 14 of 20

If no, please explain.

If no, please explain.

If "Other", please explain:

Process Vent Emissions Information

Have you verified and/or corrected the process vent 

emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO process vent streams in Enclosure 2A?

What emissions calculation approach was used to estimate 

the process vent emissions?

If "Other", please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Please provide documentation demonstrating the basis for 

the process vent emissions estimates. Are you providing 

emissions factors or source test data?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 15 of 20

Process Vent Emissions Information

Systech does not have any process vents Please enter any other comments regarding process vents 

here:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 16 of 20

Tanks Emissions Information

Please list each OSWRO tank requiring Level 1 or Level 2 control: 

Tank ID Tank capacity Tank content MTVP1 Tank content AVP2 Tank height Tank diameter

Tank average 

annual throughput

Tank emissions 

control equipment

Tank 1 25000 gal

not available - mixture is 

not consistent 0.4465 30 ft. 12 ft. 2,600,000 gal kiln/carbon back-up

Tank 2 25000 gal see above 0.4465 30 ft. 12 ft. 2,700,000 gal kiln/carbon back-up

Tank 3 25000 gal see above 0.4465 30 ft. 12 ft. 2,200,000 gal kiln/carbon back-up

Tank 4 25000 gal see above 0.4465 30 ft. 12 ft. 1,400,000 gal kiln/carbon back-up

Tank 5 30000 gal see above 0.4465 36 ft. 12 ft. 4,300,000 gal kiln/carbon back-up

Tank 6 30000 gal see above 0.4465 36 ft. 12 ft. 3,300,000 gal kiln/carbon back-up

Tank 8 150000 gal see above 0.4465 30 ft. 30 ft. 13,000,000 gal kiln/carbon back-up

Tank 9 150000 gal see above 0.4465 30 ft. 30 ft. 13,000,000 gal kiln/carbon back-up

1

 Maximum True HAP Vapor Pressure 

If "Other", please explain:

Have you entered the tanks emissions for your OSWRO 

processes in Enclosure 2A?

Have you completed all control information fields for 

your OSWRO storage vessels in Enclosure 2A?

What emissions calculation approach was used to 

estimate the tank emissions?

If no, please explain.

If no, please explain.

Please provide documentation demonstrating the basis 

for the tanks emissions estimates. Are you providing 

emissions factors, source test data or other data?

Are you implementing work practices or other HAP 

control techniques beyond those required by the MACT 

standard?

Please provide the additional capital and annual costs of this 

practice above that required by the OSWRO NESHAP:

If "Other", please explain:

If yes, please describe the control technique(s):

(add information for more tanks as necessary)
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 17 of 20

Tanks Emissions Information

2

 Average HAP Vapor Pressure 

For each tank with an internal floating roof, please list the slotted ladder information: 

Tank ID

Number of ladders 

with slotted legs

Gasketed deck cover 

over slotted ladder(s)?

Ladder sleeve over 

slotted ladder(s)?

Pole wipers in place for 

slotted ladder legs?

NA

For each tank with a fixed roof, please list the tank fitting information: 

Tank ID

Number of access 

hatches

Number of gauge 

hatches

Number of 

conservation vents

Number of 

valves/instruments

Number of 

emergency 

tank 1 1 1 1 2 1

tank 2 1 1 1 2 1

tank 3 1 1 1 2 1

tank 4 1 1 1 2 1

tank 5 1 1 1 2 1

tank 6 1 1 1 2 1

tank 7 2 1 1 2 1

tank 8 2 1 1 2 1

1 level indicator and 1 high level alarm

1

 Maximum True HAP Vapor Pressure

For each tank with a floating roof (internal or external), please list the tank information: 

Tank ID

Annual number of 

days roof rests on 

landing legs Length of landing legs

Please enter any other comments regarding tanks here: or pressure only available via Tanks 4.0

(add information for more tanks as necessary)

(add information for more tanks as necessary)

(add information for more tanks as necessary)
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 18 of 20

Off-Site Material Treatment

If you treat off-site waste using biological degradation, please answer the following questions:

What method of off-site waste HAP reduction is used?

Systech only processes the HAPs as part of the 

waste material received at the site. Once 

How do you characterize the components of the waste 

products you receive that are treated with biological 

degradation?

If "Other" or more than one of the above applies, 

please explain.

Please enter any other comments regarding off-site waste 

treatment here:

Do you perform any testing or other practices to determine 

whether fouling agents may be in the waste received?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 19 of 20

Startup and Shutdown Events

If no for any of the above, please explain:

Please provide the following information about all startup and shutdown events:

Transfer Systems

Containers

The United States Court of Appeals for the District of Columbia Circuit vacated portions of two provisions in the EPA’s CAA 

section 112 regulations governing the emissions of HAP during periods of startup, shutdown and malfunction (SSM). Sierra 

Club v. EPA, 551 F.3d 1019 (D.C. Cir. 2008). Specifically, the Court vacated the SSM exemption contained in 40 CFR 63.6(f)(1) 

and 40 CFR 63.6(h)(1), that are part of a regulation, commonly referred to as the “General Provisions Rule,” that the EPA 

promulgated under section 112 of the CAA. When incorporated into CAA section 112(d) regulations for specific source 

categories, these two, now vacated, provisions exempted sources from the requirement to comply with the otherwise 

applicable CAA section 112(d) emission standard during periods of SSM. To be consistent with the Court’s decision, facilities 

must comply with the applicable standards at all times.

For each emission source type, do the annual emissions estimate in the Enclosure 2A "Emissions (TPY)" field include the 

annual emissions from startup and shutdown events that you added in the "STARTUP EMISSIONS (TPY)" and "SHUTDOWN 

EMISSIONS (TPY)" fields? Please enter a separate response for each emissions point type below:

For each emission source type, can you comply with the emissions limitation and/or work practices in the regulation that 

apply during normal operation during startup and shutdown events? Please enter a separate response for each emissions 

point type below:

Surface Impoundments

Tanks

Organic and Oil-Water Separators

Equipment Leaks

Process Vents

Equipment Leaks

Transfer Systems

Organic and Oil-Water Separators

Containers

Surface Impoundments

Process Vents

Tanks
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 20 of 20

Startup and Shutdown Events

1. What emissions source types experience startup and shutdown events?

2. How often do startup or shutdown events occur? 

3. What is the average and range of event duration?

1.d. How are emissions released to the atmosphere (e.g., through a 

pressure relief device)?

1.c. How does the startup or shutdown event compare to normal 

operations (e.g., differences in flowrate, temp., pressure, alternate fuels 

used, alternate control devices used, etc.)?

1.a. Under normal operating conditions, do these emissions sources 

operate continuously?

1.b. What triggers the equipment to experience a startup or shutdown 

event (e.g. hot startup, startup after an emergency shutdown, re-start, 

control device startup)?

4. What marks the end of the startup or shutdown event?

9. During startup and shutdown events, if you cannot comply with the emissions 

limitation and/or work practices in the regulation that apply during normal 

operation, what is the minimum emissions level that could be achieved?

9.b. How much would it cost to minimize HAP emissions in this 

manner?

9.c. How much would HAP emissions be reduced compared to an 

uncontrolled event? (If "emission factor" is used as basis for emissions 

estimate, please provide the emission factor and sources of the 

emission factor.1)

Please enter any other comments 

regarding startup or shutdown here: ive to the passive in the event of a shutdown, there is really no time when the we hav 

1

 If "source test" is used as basis for emissions estimate, please provide a copy of the 

source test.

5. What safety issues are connected with a startup or shutdown event?

9.a. Please describe how HAP emissions would be minimized.

6. How do you determine the HAP emissions during the event? 

7. How are control devices and work practices used to minmize emissions during 

the startup or shutdown event?

8. What compliance determination method(s) do you use during startup and 

shutdown events (e.g., monitor with CEMS)? 
Enclosure 2a: 

Equipment 

Leaks
Enclosure 2a

Page 1

Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name

Emission 

Unit ID Process ID

Emission 

Release 

Point ID

SCC 

Code1

Emissions 

Start Date

Emissions 

End Date

Pollutant 

CAS 

Number2

Pollutant Name (include 

organic and nonorganic pollutants)

Actual 

Emissio

ns (TPY)

MACTAllowable 

Emissions 

(TPY)3

Routine 

Emission

s Max 

Hourly 

(lbs/hr)

Startup 

Emissio

ns (TPY)

Startup 

Emissio

ns 

(lbs/hr)

Shutdo

wn 

Emissio

ns 

(TPY)

Shutdo

wn 

Emissio

ns 

(lbs/hr) MACT Source Category

Emission 

Release 

Point Type4 

Stack 

Height (ft)

Exit Gas 

Temperatu

re (°F)

Stack 

Diameter (ft)

Exit Gas 

Velocity 

(ft/sec)

Exit Gas 

Flow 

Rate 

(ft3/sec)

Fugitive 

Length (EW) (ft)

Fugitive 

Width (NS) (ft)

Fugitive 

Angle 

(degrees) 

5

Longitude 

(decimal 

degrees)6

Latitude 

(decimal 

degrees)6

Is 

Control 

Measur

e In 

Place?

Control 

Measur

e 7

Control 

Measur

e 

Efficien

cy Comments

EXAMPLE 

ENTRY:

American Welding 

Paducah Plant 25 25 50310001 01/01/10 12/31/10 100414 Ethyl Benzene 2.45 4.32 6.7 1.24 0.08 0.61 0.2

Off-Site Waste and Recovery 

Operations vertical 44 1600 3.099999905 3.86999989 1758 NA NA NA -72.078903 41.44273758 yes flare 98%

reduction efficency based on 

manufacturer guarantees

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 75088 Acetonitrile 0.0001 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 107131 Acrylonitrile 0.0000 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 71432 Benzene 0.0000 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 121697 Diethyl (n,n) anilin 0.0000 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 68122 Dimethyl formamide 0.0000 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 140885 Ethyl Acrylate 0.0000 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 100414 Ethyl Benzene 0.0002 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 110543 Hexane (-n) 0.0012 n/a 0.0003 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 67561 Methyl Alcohol 0.0123 n/a 0.0028 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 108101 Methyl Isobutyl ketone 0.0002 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 74873 Methylene chloride 0.0023 n/a 0.0005 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 1634044 methyl t-butyl ether 0.0010 n/a 0.0002 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 100425 sytrene 0.0001 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 127184 tetrachloroethylene 0.0001 n/a <0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 108883 toluene 0.0034 n/a 0.0008 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - 

Paulding, OH Fugitive Fugitive Fugitive 50310001 1/1/2012 12/31/2012 1330207 xylene (mixed) 0.0006 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 899 187 57 -84.607301 41.179881 n/a n/a n/a Fugitive soureces - equipment lea

1

 For SCC Code, please input one of the following codes:

SCC SCC Description

50310001 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Equipment Leaks 

50310002 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Containers

50310003 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Tanks

50310004 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Organic and Oil-Water Separators

50310005 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Surface Impoundments

50310006 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Transfer Systems

50310007 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Process Vents

2

 See List of HAPs in separate worksheet for a table of CAS numbers and HAPs

3

 MACT- allowable emissions are the maximum emission levels allowed while in compliance with the MACT standards

4

 Emission point type choices include: fugitive, vertical, horizontal, goose neck, vertical with rain cap, or downward-facing vent

5

 Fugitive Angle: Specifies the rotation of the source from north (in the clockwise direction). The location coordinates should reflect the southwest corner of the area source as shown in this graphic: 

6 Location of stack or southwest corner of a fugitive emissions release point

7

 For control measures, please include all control measures used for that emission point, including but not limited to:

Activated Carbon 

Adsorption

list specific 

type in 

Control 

Measure 

Comments 

column

Combustor

list specific 

type in 

Control 

Measure 

Comments 

column

Electrostatic 

Precipitator

Fabric 

Filter/Baghouse

(annual average if the parameter varies)

Vertical Emissions Release Point Parameters Fugitive Emissions Release 

Point Parameters
Enclosure 2a

Page 2

Flare

Pressurized Tank

Fixed Roof Tank

Fixed Roof Tank 

Vented to Control 

Device

External Floating 

Roof Tank

Fixed Roof Tank 

with Internal 

Floating Roof

Vapor Balancing

Floating Membrane 

Cover

Cover Vented to 

Control Device

High-Efficiency 

Particulate Air Filter 

(HEPA)

Leak Detection and 

Repair Program

Condenser

Scrubber

list specific 

type in 

Control 

Measure 

Comments 

column

Multiple Controls in 

Series

list specific 

types in 

Control 

Measure 

Comments 

column

Other Control 

Device

describe in 

Control 

Measure 

Comments 

column

Pollution Prevention 

Technique

describe in 

Control 

Measure 

Comments 

column

Process 

Modification

describe in 

Control 

Measure 

Comments 

column
DRAFT

Pollutant Name CAS No.

Acetaldehyde 75070

Acetamide 60355

Acetonitrile 75058

Acetophenone 98862

2-Acetylaminofluorene 53963

Acrolein 107028

Acrylamide 79061

Acrylic acid 79107

Acrylonitrile 107131

Allyl chloride 107051

4-Aminobiphenyl 92671

Aniline 62533

o-Anisidine 90040

Asbestos 1332214

Benzene (including benzene from gasoline) 71432

Benzidine 92875

Benzotrichloride 98077

Benzyl chloride 100447

Biphenyl 92524

Bis(2-ethylhexyl)phthalate (DEHP) 117817

Bis(chloromethyl)ether 542881

Bromoform 75252

1,3-Butadiene 106990

Calcium cyanamide 156627

Captan 133062

Carbaryl 63252

Carbon disulfide 75150

Carbon tetrachloride 56235

Carbonyl sulfide 463581

Catechol 120809

Chloramben 133904

Chlordane 57749

Chlorine 7782505

Chloroacetic acid 79118

2-Chloroacetophenone 532274

Chlorobenzene 108907

Chlorobenzilate 510156

Chloroform 67663

Chloromethyl methyl ether 107302

Chloroprene 126998

Cresols/Cresylic acid (isomers and mixture) 1319773

o-Cresol 95487

m-Cresol 108394

p-Cresol 106445

Cumene 98828

2,4-D, salts and esters 94757

DDE 3547044

Diazomethane 334883

Dibenzofurans 132649

1,2-Dibromo-3-chloropropane 96128

Dibutylphthalate 84742

1,4-Dichlorobenzene(p) 106467

3,3-Dichlorobenzidene 91941

Dichloroethyl ether (Bis(2-chloroethyl)ether) 111444

1,3-Dichloropropene 542756

Dichlorvos 62737

Diethanolamine 111422

N,N-Diethyl aniline (N,N-Dimethylaniline) 121697

List of Hazardous Air Pollutants (HAP)
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Diethyl sulfate 64675

3,3-Dimethoxybenzidine 119904

Dimethyl aminoazobenzene 60117

3,3'-Dimethyl benzidine 119937

Dimethyl carbamoyl chloride 79447

Dimethyl formamide 68122

1,1-Dimethyl hydrazine 57147

Dimethyl phthalate 131113

Dimethyl sulfate 77781

4,6-Dinitro-o-cresol, and salts 534521

2,4-Dinitrophenol 51285

2,4-Dinitrotoluene 121142

1,4-Dioxane (1,4-Diethyleneoxide) 123911

1,2-Diphenylhydrazine 122667

Epichlorohydrin (l-Chloro-2,3-epoxypropane) 106898

1,2-Epoxybutane 106887

Ethyl acrylate 140885

Ethyl benzene 100414

Ethyl carbamate (Urethane) 51796

Ethyl chloride (Chloroethane) 75003

Ethylene dibromide (Dibromoethane) 106934

Ethylene dichloride (1,2-Dichloroethane) 107062

Ethylene glycol 107211

Ethylene imine (Aziridine) 151564

Ethylene oxide 75218

Ethylene thiourea 96457

Ethylidene dichloride (1,1-Dichloroethane) 75343

Formaldehyde 50000

Heptachlor 76448

Hexachlorobenzene 118741

Hexachlorobutadiene 87683

Hexachlorocyclopentadiene 77474

Hexachloroethane 67721

Hexamethylene-1,6-diisocyanate 822060

Hexamethylphosphoramide 680319

Hexane 110543

Hydrazine 302012

Hydrochloric acid 7647010

Hydrogen fluoride (Hydrofluoric acid) 7664393

Hydrogen sulfide 7783064

Hydroquinone 123319

Isophorone 78591

Lindane (all isomers) 58899

Maleic anhydride 108316

Methanol 67561

Methoxychlor 72435

Methyl bromide (Bromomethane) 74839

Methyl chloride (Chloromethane) 74873

Methyl chloroform (1,1,1-Trichloroethane) 71556

Methyl hydrazine 60344

Methyl iodide (Iodomethane) 74884

Methyl isobutyl ketone (Hexone) 108101

Methyl isocyanate 624839

Methyl methacrylate 80626

Methyl tert butyl ether 1634044

4,4-Methylene bis(2-chloroaniline) 101144

Methylene chloride (Dichloromethane) 75092

Methylene diphenyl diisocyanate (MDI) 101688

4,4'¬-Methylenedianiline 101779

Naphthalene 91203
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Nitrobenzene 98953

4-Nitrobiphenyl 92933

4-Nitrophenol 100027

2-Nitropropane 79469

N-Nitroso-N-methylurea 684935

N-Nitrosodimethylamine 62759

N-Nitrosomorpholine 59892

Parathion 56382

Pentachloronitrobenzene (Quintobenzene) 82688

Pentachlorophenol 87865

Phenol 108952

p-Phenylenediamine 106503

Phosgene 75445

Phosphine 7803512

Phosphorus 7723140

Phthalic anhydride 85449

Polychlorinated biphenyls (Aroclors) 1336363

1,3-Propane sultone 1120714

beta-Propiolactone 57578

Propionaldehyde 123386

Propoxur (Baygon) 114261

Propylene dichloride (1,2-Dichloropropane) 78875

Propylene oxide 75569

1,2-Propylenimine (2-Methyl aziridine) 75558

Quinoline 91225

Quinone 106514

Styrene 100425

Styrene oxide 96093

2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746016

1,1,2,2-Tetrachloroethane 79345

Tetrachloroethylene (Perchloroethylene) 127184

Titanium tetrachloride 7550450

Toluene 108883

2,4-Toluene diamine 95807

2,4-Toluene diisocyanate 584849

o-Toluidine 95534

Toxaphene (chlorinated camphene) 8001352

1,2,4-Trichlorobenzene 120821

1,1,2-Trichloroethane 79005

Trichloroethylene 79016

2,4,5-Trichlorophenol 95954

2,4,6-Trichlorophenol 88062

Triethylamine 121448

Trifluralin 1582098

2,2,4-Trimethylpentane 540841

Vinyl acetate 108054

Vinyl bromide 593602

Vinyl chloride 75014

Vinylidene chloride (1,1-Dichloroethylene) 75354

Xylenes (isomers and mixture) 1330207

o-Xylenes 95476

m-Xylenes 108383

p-Xylenes 106423

Antimony Compounds 0

Arsenic Compounds (inorganic including arsine) 0

Beryllium Compounds 0

Cadmium Compounds 0

Chromium Compounds 0

Cobalt Compounds 0

Coke Oven Emissions 0
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Cyanide Compounds 0

Glycol ethers 0

Lead Compounds 0

Manganese Compounds 0

Mercury Compounds 0

Fine mineral fibers 0

Nickel Compounds 0

Polycylic Organic Matter 0

Radionuclides (including radon) 0

Selenium Compounds 0
Enclosure 2a: 

Tanks 1-6
Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name

Emission 

Unit ID Process ID

Emissio

n 

Release 

Point ID

SCC 

Code1

Emissions 

Start Date

Emissions 

End Date

Pollutant 

CAS 

Number2

Pollutant Name 

(include organic 

and non-organic 

pollutants)

Actual 

Emissio

ns (TPY)

MACTAllowable 

Emissions 

(TPY)3

Routine 

Emission

s Max 

Hourly 

(lbs/hr)

Startup 

Emissio

ns (TPY)

Startup 

Emissio

ns 

(lbs/hr)

Shutdo

wn 

Emissio

ns 

(TPY)

Shutdo

wn 

Emissio

ns 

(lbs/hr) MACT Source Category

Emission 

Release 

Point 

Type4 

Stack 

Height (ft)

Exit Gas 

Temperatu

re (°F)

Stack 

Diameter (ft)

Exit Gas 

Velocity 

(ft/sec)

Exit Gas 

Flow 

Rate 

(ft3/sec)

Fugitive 

Length (EW) (ft)

Fugitive 

Width (N-S) 

(ft)

Fugitive 

Angle 

(degrees) 

5

Longitude 

(decimal 

degrees)6

Latitude 

(decimal 

degrees)6

Is 

Control 

Measur

e In 

Place?

Control 

Measur

e 7

Control 

Measur

e 

Efficien

cy Comments

EXAMPLE 

ENTRY:

American Welding 

Paducah Plant 25 25 25 50310001 01/01/10 12/31/10 100414 Ethyl Benzene 2.45 4.32 6.7 1.24 0.08 0.61 0.2

Off-Site Waste and Recovery 

Operations vertical 44 1600 3.099999905 3.86999989 1758 NA NA NA -72.078903 41.44273758 yes flare 98%

reduction efficency based on 

manufacturer guarantees

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 75088 Acetonitrile 0.0210 n/a 0.0048 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 107131 Acrylonitrile 0.0021 0.0005 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 71432 Benzene 0.0061 n/a 0.0014 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 121697 Diethyl Anilin 0.0000 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 68122 Dimethyl formamide 0.0002 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 140885 Ethyl acrylate 0.0021 0.0005 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 100414 Ethyl Benzene 0.0043 n/a 0.0010 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 110543 hexane 0.0383 0.0087 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 67561 Methyl Alcohol 0.2649 n/a 0.0605 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 108101

Methyl Isobutyl 

ketone 0.0070 n/a 0.0016 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 75092 methylene chloride 0.0478 0.0109 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 1634044 methyl t-butyl ether 0.0407 n/a 0.0093 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 100425 styrene 0.0013 n/a 0.0003 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 127184 tetrachloroethylene 0.0005 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 108883 toluene 0.0855 n/a 0.0195 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

Systech Environment Tanks 1-6 Tanks 1-6 Cement K 50310003 1/1/2012 12/31/2012 1330207 xylene (mixed) 0.0141 n/a 0.0032 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ carb kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.99 Control Devices and units combined for report 

1

 For SCC Code, please input one of the following codes:

SCC SCC Description

50310001 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Equipment Leaks 

50310002 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Containers

50310003 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Tanks

50310004 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Organic and Oil-Water Separators

50310005 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Surface Impoundments

50310006 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Transfer Systems

50310007 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Process Vents

2

 See List of HAPs in separate worksheet for a table of CAS numbers and HAPs

3

 MACT- allowable emissions are the maximum emission levels allowed while in compliance with the MACT standards

4

 Emission point type choices include: fugitive, vertical, horizontal, goose neck, vertical with rain cap, or downward-facing vent

5

 Fugitive Angle: Specifies the rotation of the source from north (in the clockwise direction). The location coordinates should reflect the southwest corner of the area source as shown in this graphic: 

6 Location of stack or southwest corner of a fugitive emissions release point

7

 For control measures, please include all control measures used for that emission point, including but not limited to:

Activated Carbon 

Adsorption

list specific 

type in 

Control 

Measure 

Comments 

column

Combustor

list specific 

type in 

Control 

Measure 

Comments 

column

Electrostatic 

Precipitator

Fabric 

Filter/Baghouse

Flare

Pressurized Tank

Fixed Roof Tank

Fixed Roof Tank 

Vented to Control 

Device

External Floating 

Roof Tank

Fixed Roof Tank 

with Internal 

Floating Roof

Vapor Balancing

Floating Membrane 

Cover

Cover Vented to 

Control Device

High-Efficiency 

Particulate Air Filter 

(HEPA)

Leak Detection and 

Repair Program

Condenser

Scrubber

list specific 

type in 

Control 

Measure 

Comments 

column

Multiple Controls in 

Series

list specific 

types in 

Control 

Measure 

Comments 

column

Other Control 

Device

describe in 

Control 

Measure 

Comments 

column

Pollution Prevention 

Technique

describe in 

Control 

Measure 

Comments 

column

Process 

Modification

describe in 

Control 

Measure 

Comments 

column

Vertical Emissions Release Point Parameters Fugitive Emissions Release Point 

(annual average if the parameter varies) Parameters
Enclosure 2a: 

Tanks 8-9
Enclosure 2a

Page 1

Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name

Emission 

Unit ID Process ID

Emissio

n 

Release 

Point ID

SCC 

Code1

Emissions 

Start Date

Emissions 

End Date

Pollutant 

CAS 

Number2

Pollutant Name 

(include organic 

and non-organic 

pollutants)

Actual 

Emissio

ns (TPY)

MACTAllowable 

Emissions 

(TPY)3

Routine 

Emission

s Max 

Hourly 

(lbs/hr)

Startup 

Emissio

ns (TPY)

Startup 

Emissio

ns 

(lbs/hr)

Shutdo

wn 

Emissio

ns 

(TPY)

Shutdo

wn 

Emissio

ns 

(lbs/hr) MACT Source Category

Emission 

Release 

Point Type4 

Stack 

Height (ft)

Exit Gas 

Temperatu

re (°F)

Stack 

Diameter (ft)

Exit Gas 

Velocity 

(ft/sec)

Exit Gas 

Flow 

Rate 

(ft3/sec)

Fugitive 

Length (EW) (ft)

Fugitive 

Width (N-S) 

(ft)

Fugitive 

Angle 

(degrees) 

5

Longitude 

(decimal 

degrees)6

Latitude 

(decimal 

degrees)6

Is 

Control 

Measur

e In 

Place?

Control 

Measur

e 7

Control 

Measur

e 

Efficien

cy Comments

EXAMPLE 

ENTRY:

American Welding 

Paducah Plant 25 25 25 50310001 01/01/10 12/31/10 100414 Ethyl Benzene 2.45 4.32 6.7 1.24 0.08 0.61 0.2

Off-Site Waste and Recovery 

Operations vertical 44 1600 3.099999905 3.86999989 1758 NA NA NA -72.078903 41.44273758 yes flare 98%

reduction efficency based on 

manufacturer guarantees

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 75088 Acetonitrile 0.0004 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 107131 Acrylonitrile <0.0001 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 71432 Benzene 0.0001 n/a 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 121697 Diethyl Anilin <0.0001 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 68122 Dimethyl formamide <0.0001 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 140885 Ethyl acrylate <0.0001 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 100414 Ethyl Benzene 0.0001 n/a 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 110543 hexane 0.0007 0.0002 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 67561 Methyl Alcohol 0.0048 n/a 0.0759 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 108101

Methyl Isobutyl 

ketone 0.0001 n/a 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 75092 methylene chloride 0.0009 0.0002 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 1634044 methyl t-butyl ether 0.0007 n/a 0.0002 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 100425 styrene <0.0001 n/a 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 127184 tetrachloroethylene <0.0001 n/a 0.0000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 108883 toluene 0.0016 n/a 0.0004 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

Systech Environmen Tanks 8&9 Tanks 8&9 Cement K 50310003 1/1/2012 12/31/2012 1330207 xylene (mixed) 0.0003 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln s kiln stack 25 kiln 430/ car kiln 12' /carbon Kiln 38 /carbo kiln 4333 /c N/A N/A N/A -84.3625 41.1048 yes Cement K Kiln 99.9 Control Devices and units combin 

1

 For SCC Code, please input one of the following codes

SCC SCC Description

50310001 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Equipment Leaks 

50310002 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Containers

50310003 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Tanks

50310004 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Organic and Oil-Water Separators

50310005 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Surface Impoundments

50310006 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Transfer Systems

50310007 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Process Vents

2

 See List of HAPs in separate worksheet for a table of CAS numbers and HAPs

3

 MACT- allowable emissions are the maximum emission levels allowed while in compliance with the MACT standards

4

 Emission point type choices include: fugitive, vertical, horizontal, goose neck, vertical with rain cap, or downward-facing vent

5

 Fugitive Angle: Specifies the rotation of the source from north (in the clockwise direction). The location coordinates should reflect the southwest corner of the area source as shown in this graphic: 

6 Location of stack or southwest corner of a fugitive emissions release point

7

 For control measures, please include all control measures used for that emission point, including but not limited to:

Activated Carbon 

Adsorption

list specific 

type in 

Control 

Measure 

Comments 

column

Combustor

list specific 

type in 

Control 

Measure 

Comments 

column

Electrostatic 

Precipitator

Fabric 

Filter/Baghouse

Flare

Pressurized Tank

Fixed Roof Tank

Fixed Roof Tank 

Vented to Control 

Device

External Floating 

Roof Tank

Fixed Roof Tank 

with Internal 

Floating Roof

Vapor Balancing

Floating Membrane 

Cover

Cover Vented to 

Control Device

High-Efficiency 

Particulate Air Filter 

(HEPA)

Leak Detection and 

Repair Program

Condenser

(annual average if the parameter varies)

Vertical Emissions Release Point Parameters Fugitive Emissions Release Point 

Parameters
Enclosure 2a

Page 2

Scrubber

list specific 

type in 

Control 

Measure 

Comments 

column

Multiple Controls in 

Series

list specific 

types in 

Control 

Measure 

Comments 

column

Other Control 

Device

describe in 

Control 

Measure 

Comments 

column

Pollution Prevention 

Technique

describe in 

Control 

Measure 

Comments 

column

Process Modification

describe in 

Control 

Measure 

Comments 

column
DRAFT

Pollutant Name CAS No.

Acetaldehyde 75070

Acetamide 60355

Acetonitrile 75058

Acetophenone 98862

2-Acetylaminofluorene 53963

Acrolein 107028

Acrylamide 79061

Acrylic acid 79107

Acrylonitrile 107131

Allyl chloride 107051

4-Aminobiphenyl 92671

Aniline 62533

o-Anisidine 90040

Asbestos 1332214

Benzene (including benzene from gasoline) 71432

Benzidine 92875

Benzotrichloride 98077

Benzyl chloride 100447

Biphenyl 92524

Bis(2-ethylhexyl)phthalate (DEHP) 117817

Bis(chloromethyl)ether 542881

Bromoform 75252

1,3-Butadiene 106990

Calcium cyanamide 156627

Captan 133062

Carbaryl 63252

Carbon disulfide 75150

Carbon tetrachloride 56235

Carbonyl sulfide 463581

Catechol 120809

Chloramben 133904

Chlordane 57749

Chlorine 7782505

Chloroacetic acid 79118

2-Chloroacetophenone 532274

Chlorobenzene 108907

Chlorobenzilate 510156

Chloroform 67663

Chloromethyl methyl ether 107302

Chloroprene 126998

Cresols/Cresylic acid (isomers and mixture) 1319773

o-Cresol 95487

m-Cresol 108394

p-Cresol 106445

Cumene 98828

2,4-D, salts and esters 94757

DDE 3547044

Diazomethane 334883

Dibenzofurans 132649

1,2-Dibromo-3-chloropropane 96128

Dibutylphthalate 84742

1,4-Dichlorobenzene(p) 106467

3,3-Dichlorobenzidene 91941

Dichloroethyl ether (Bis(2-chloroethyl)ether) 111444

1,3-Dichloropropene 542756

Dichlorvos 62737

Diethanolamine 111422

N,N-Diethyl aniline (N,N-Dimethylaniline) 121697

List of Hazardous Air Pollutants (HAP)
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Diethyl sulfate 64675

3,3-Dimethoxybenzidine 119904

Dimethyl aminoazobenzene 60117

3,3'-Dimethyl benzidine 119937

Dimethyl carbamoyl chloride 79447

Dimethyl formamide 68122

1,1-Dimethyl hydrazine 57147

Dimethyl phthalate 131113

Dimethyl sulfate 77781

4,6-Dinitro-o-cresol, and salts 534521

2,4-Dinitrophenol 51285

2,4-Dinitrotoluene 121142

1,4-Dioxane (1,4-Diethyleneoxide) 123911

1,2-Diphenylhydrazine 122667

Epichlorohydrin (l-Chloro-2,3-epoxypropane) 106898

1,2-Epoxybutane 106887

Ethyl acrylate 140885

Ethyl benzene 100414

Ethyl carbamate (Urethane) 51796

Ethyl chloride (Chloroethane) 75003

Ethylene dibromide (Dibromoethane) 106934

Ethylene dichloride (1,2-Dichloroethane) 107062

Ethylene glycol 107211

Ethylene imine (Aziridine) 151564

Ethylene oxide 75218

Ethylene thiourea 96457

Ethylidene dichloride (1,1-Dichloroethane) 75343

Formaldehyde 50000

Heptachlor 76448

Hexachlorobenzene 118741

Hexachlorobutadiene 87683

Hexachlorocyclopentadiene 77474

Hexachloroethane 67721

Hexamethylene-1,6-diisocyanate 822060

Hexamethylphosphoramide 680319

Hexane 110543

Hydrazine 302012

Hydrochloric acid 7647010

Hydrogen fluoride (Hydrofluoric acid) 7664393

Hydrogen sulfide 7783064

Hydroquinone 123319

Isophorone 78591

Lindane (all isomers) 58899

Maleic anhydride 108316

Methanol 67561

Methoxychlor 72435

Methyl bromide (Bromomethane) 74839

Methyl chloride (Chloromethane) 74873

Methyl chloroform (1,1,1-Trichloroethane) 71556

Methyl hydrazine 60344

Methyl iodide (Iodomethane) 74884

Methyl isobutyl ketone (Hexone) 108101

Methyl isocyanate 624839

Methyl methacrylate 80626

Methyl tert butyl ether 1634044

4,4-Methylene bis(2-chloroaniline) 101144

Methylene chloride (Dichloromethane) 75092

Methylene diphenyl diisocyanate (MDI) 101688

4,4'¬-Methylenedianiline 101779

Naphthalene 91203
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Nitrobenzene 98953

4-Nitrobiphenyl 92933

4-Nitrophenol 100027

2-Nitropropane 79469

N-Nitroso-N-methylurea 684935

N-Nitrosodimethylamine 62759

N-Nitrosomorpholine 59892

Parathion 56382

Pentachloronitrobenzene (Quintobenzene) 82688

Pentachlorophenol 87865

Phenol 108952

p-Phenylenediamine 106503

Phosgene 75445

Phosphine 7803512

Phosphorus 7723140

Phthalic anhydride 85449

Polychlorinated biphenyls (Aroclors) 1336363

1,3-Propane sultone 1120714

beta-Propiolactone 57578

Propionaldehyde 123386

Propoxur (Baygon) 114261

Propylene dichloride (1,2-Dichloropropane) 78875

Propylene oxide 75569

1,2-Propylenimine (2-Methyl aziridine) 75558

Quinoline 91225

Quinone 106514

Styrene 100425

Styrene oxide 96093

2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746016

1,1,2,2-Tetrachloroethane 79345

Tetrachloroethylene (Perchloroethylene) 127184

Titanium tetrachloride 7550450

Toluene 108883

2,4-Toluene diamine 95807

2,4-Toluene diisocyanate 584849

o-Toluidine 95534

Toxaphene (chlorinated camphene) 8001352

1,2,4-Trichlorobenzene 120821

1,1,2-Trichloroethane 79005

Trichloroethylene 79016

2,4,5-Trichlorophenol 95954

2,4,6-Trichlorophenol 88062

Triethylamine 121448

Trifluralin 1582098

2,2,4-Trimethylpentane 540841

Vinyl acetate 108054

Vinyl bromide 593602

Vinyl chloride 75014

Vinylidene chloride (1,1-Dichloroethylene) 75354

Xylenes (isomers and mixture) 1330207

o-Xylenes 95476

m-Xylenes 108383

p-Xylenes 106423

Antimony Compounds 0

Arsenic Compounds (inorganic including arsine) 0

Beryllium Compounds 0

Cadmium Compounds 0

Chromium Compounds 0

Cobalt Compounds 0

Coke Oven Emissions 0
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Cyanide Compounds 0

Glycol ethers 0

Lead Compounds 0

Manganese Compounds 0

Mercury Compounds 0

Fine mineral fibers 0

Nickel Compounds 0

Polycylic Organic Matter 0

Radionuclides (including radon) 0

Selenium Compounds 0
Other ICR 

Response Info.
Oh10 Environmental Protection Agency

FINAL

Division of Air Pollution Control

Title V Permit

for

Systech Environmental Corporation

Facility ID: 0363000046Permit Number: P01 09068Permit Type: Minor Permit ModificationIssued: 5/23/2012

Effective: 5/23/2012Expiration: 2/4/2014
Table of Cot~ttentS

Authorization I

A. Standard Terms and Conditions 2

1. Federally Enforceable Standard Terms and Conditions 3

2. Monitoring and Related Record Keeping and Reporting Requirements 33. Scheduled Maintenance 6

4. Risk Management Plans 6

5. Title IV Provisions 7

6. Severability Clause 7

7. General Requirements 78. Fees 89. Marketable Permit Programs 8

10. Reasonably Anticipated Operating Scenarios 8

II. Reopening for Cause 9

12. Federal and State Enforceability 913. Compliance Requirements 914. Permit Shield 11

15. Operational Flexibility 1116. Emergencies 1117. Off-Permit Changes 11

18. Compliance Method Requirements 12

19. Insignificant Activities or Emissions Levels 12

20. Permit to Install Requirement 1221. Air Pollution Nuisance 13

22. Permanent Shutdown of an Emissions Unit 1323. Title VI Provisions 1324. Reporting Requirements Related to Monitoring and Record Keeping Requirements Under State Law

Only 14

25. Records Retention Requirements Under State Law Only 1426. Inspections and Information Requests .14

27. Scheduled Maintenance/Malfunction Reporting 1528. Permit Transfers 15

Facility ID: 0363000046Fáàilif~D~sbriptióri: Wast~-~leñved Fuel Supplier

Application N umber(s): M0001 439

Permit Number: P01 09068Permit Description: Minor Modification of Title V permit - include PTI for four new (replacement) waste-derived fuel

storage tanks; and also, general updates /corrections to the permit, to accurately reflect ‘sunset’of RCRA/BIF rules, and accurately reflect Lafarge cement kilns as Systech’s closed-vent system

control device.

Permit Type: Minor Permit ModificationIssue Date: 5/23/2012Effective Date: 5/23/2012

Expiration Date: 2/4/2014

Superseded Permit Number: P0087431

This document constitutes issuance of an CAC Chapter 3745-77 Title V permit to:

Systech Environmental Corporation

11435 County Road 176

P.O. Box 160

Paulding, OH 45879

Ohio EPA District Office or local air agency responsible for processing and administering your permit:

Ohio EPA DAPCI Northwest District Office

347 North Dunbridge Road

Bowling Green, OH 43402

(419)352-8461

The above named entity is hereby granted a Title V permit pursuant to Chapter 3745-77 of the Ohio Administrative Code.This permit and the authorization to operate the air contaminant sources (emissions units) at this facility shall expire at

midnight on the expiration date shown above. You will be sent a notice approximately 18 months prior to the expiration

date regarding the renewal of this permit If you do not receive a notice, please contact the Ohio EPA DAPC, Northwest

District Office. If a renewal permit is not issued prior to the expiration date, the permittee may continue to operate

pursuant to OAC rule 3745-77-08(E) and in accordance with the terms of this permit beyond the expiration date, if a timelyrenewal application is submitted. A renewal application will be considered timely if it is submitted no earlier than 18months (540 days) and no later than 6 months (180 days) prior to the expiration date.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Scott J. Nally

Director

Page 1 of 39
A. Standard Terms and Conditions

Page 2 of 39
y

(1) Standard Term and Condition A. 24., Reporting Requirements Related to Monitoring and

Record Keeping Requirements of State-Only Enforceable Permit Terms and Conditions

(2) Standard Term and Condition A. 25., Records Retention Requirements for State-Only

Enforceable Permit Terms and Conditions

(3) Standard Term and Condition A. 27., Scheduled Maintenance/Malfunction Reporting(4) Standard Term and Condition A. 29., Additional Reporting Requirements When There

Are No Deviations of Federally Enforceable Emission Limitations, Operational

Restrictions, or Control Device Operating Parameter Limitations

(Authority for term: ORC 3704.036(A))

Monitoring and Related Record Keeping and Reporting Requirements

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

(i.e., in section C. Emissions Unit Terms and Conditions of this Title V permit), the permittee

shall maintain records that include the following, where applicable, for any required monitoring

under this permit:(1) The date, place (as defined in the permit), and time of sampling or measurements.

(2) The date(s) analyses were performed.

(3) The company or entity that performed the analyses.

(4) The analytical techniques or methods used.(5) The results of such analyses.

(6) The operating conditions existing at the time of sampling or measurement.

(Authority for term: QAC rule 3745-77-07(A) (3) (b) (I))

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 all calibration and maintenance records and all original strip

chart recordings for continuous monitoring instrumentation, and copies of all reports required by

this permit. Such records may be maintained in computerized form.

(Authority for term. OAC rule 3745-77-07(A) (3)(b)(ii))

Page 3of39
Any malfunction, as defined in OAC rule 3745.-15-06(B)(1), shall be promptly reported to

the Ohio EPA in accordance with OAC rule 3745-15-06. In addition, to fulfill the QAC

rule 3745-77-07(A)(3).(c) deviation reporting r~qUirern~ents fqr malfunctions, writtenreports that identify each malfunction that occurred during each calendar quarter(including each malfunction reported only verbally in accordance with OAC rule 3745-15-

06) shall be submitted (i.e., postmarked) by January 31, April 30, July 31, and October31 of each year in accordance with Standã~d Teim and CoWdition A.2.c)(2) below; andeach report shall cover the previous calendar quarter. An exceedance of the visibleemission limitations specified in QAC rule 3745-17-07(A)(1) that is caused by a

malfunction is not

a violation and does not need to be reported as

a deviation if the

owner or operator of the affected air contaminant source or air pollution control

equipment complies with the requirements of QAC rule 3745-1 7-07(A)(3)(c).

In accordance with OAC rule 3745-15-06, a malfunction reportable under OAC rule

3745-1 5-06(B) is

a deviation of the federally enforceable permit requirements. Even

though verbal notifications and written reports are required for malfunctions pursuant to

OAC rule 3745-15-06, the written reports required pursuant to this term must be

submitted quarterly to satisfy the prompt reporting provision of OAC rule 3745-77-

07(A)(3)(c).

In identifying each deviation caused by a malfunction, the permittee shall specify the

emission limitation(s) (or control requirement(s)) for which the deviation occurred,

describe each deviation, and provide the, magnitude and duration of each deviation. Fora specific malfunction, if this information has been provided in a written report that wassubmitted in accordance with QAC rule 3745-15-06, the permittee may simply reference

that written report to identify the deviation. Nevertheless, all malfunctions, includingthose reported only verbally in accordance with QAC rule 3745-15-06, must be reported

in writing on a quarterly basis.

Any scheduled maintenance, as referenced in QAC rule 3745-15-06(A)(1), that results in

a deviation from a federally enforceable emission limitation (or control requirement) shallbe reported in the same manner as described above for malfunctions.

(Authority for term: OAC rule 3 745-77-07(A)(3)(c))

(2) Except as may otherwise be provided in the terms and conditions for a specific

emissions unit (i.e., in section C. Emissions Unit Terms and Conditions of this Title

V

permit or, in some cases, in section B. Facility-Wide Terms and Conditions of this Title

V

permit), all reporting required in accordance with OAC rule 3745-77-07(A)(3)(c) for

deviations of the emission limitations, operational restrictions, and control device

operating parameter limitations shall be submitted in the following manner:

Written reports of (a) any deviations from federally enforceable emission limitations,

operational restrictions, and control device operating parameter limitations, (b) the

probable cause of such deviations, and (c) any corrective actions or preventive

Page

4 of 39
lñidéñtif~i~ôhdé~iàtiöñ~théj5érñiittee sh&l specify ~hé éi~ñi iölihit~ti&ñ~)7 — — operational restriction(s), and/or control device operating parameter limitation(s) for

which the deviation occurred, describe each deviation, and provide the estimated

magnitude and duration of each deviation.

These written deviation reports shall satisfy the requirements of OAC rule 3745-77-

07(A)(3)(c) pertaining to the submission of monitoring reports every six months and to

the prompt reporting of all deviations. Full compliance with CAC rule 3745-77-

07(A)(3)(c) requires reporting of all other deviations of the federa!ly enforceablerequirements specified in the permit as required by such rule.

If an emissions unit has a deviation reporting requirement for a specific emission

limitation, operational restriction, or control device operating parameter limitation that isnot on a quarterly basis (e.g., within 30 days following the end of the cajej2dar month, or

within 30 or 45 days after the exceedance occurs), that deviation repo~ti~ requirement

satisfies the reporting requirements specified in this Standard Term and Condition for

that specific emission limitation, operational restriction, or control device parameter

limitation. Following the provisions of that non-quarterly deviation reporting requirement

will also satisfy (for the deviations so reported) the requirements of OAC rule 3745-77-

07(A)(3)(c) pertaining to the submission of monitoring reports every six months and to

the prompt reporting of all deviations, and additional quarterly deviation reports for that

specific emission limitation, operational restriction, or control device parameter limitation

are not required pursuant to this Standard Term and Condition.See A.29 below if no deviations occurred during the quarter.(Authority for term: QAC rule 3745-77-07(A)(3)(c))

(3) All reporting required in accordance with the QAC rule 3745-77-07(A)(3)(c) for other

deviations of the federally enforceable permit requirements which are not reported in

accordance with Standard Term and Condition A.2)c)(2) above shall be submitted in the

following manner:

Unless otherwise specified by rule, written reports that identify deviations of the following

federally enforceable requirements contained in this permit; Standard Terms and

Conditions: A.3, A.4, A.5, A.7.e), A.8, A.13, A.15, A.19, A.20, A.21, and A.23 of ths Title

V permit, as well as any deviations from the requirements in section C. Emissions Unit

Terms and Conditions of this Title V permit and any monitoring, record keeping and

reporting requirements, which are not reported in accordance with Standard Term and

Condition A.2.c)(2) above shall be submitted (i.e., postmarked) to the appropriate Ohio

EPA District Office or local air agency by January 31 and July 31 of each year; and each

report shall cover the previous six calendar months. Unless otherwise specified by rule,

all other deviations from federally enforceable requirements identified in this permit shallbe submitted annually as part of the annual compliance certification, including deviations

of federally enforceable requirements not specifically addressed by permit or rule for the

Page 5 of 39
In identifying each deviation, the permittee shall specify the federally enforceable

requirement for which the deviation occurred, describe each deviation, and provide the

magnitude and duration of each deviation.

These semi-annual and annual written reports shall satisfy the reporting requirements of

OAC rule 3745-77-07(A)(3)(c) for any deviations from the federally enforceable

requirements contained in this permit that are not reported in accordance with Standard

Term and Condition A.2.c)(2) above.

If no such deviations occurred during a six-month period, the permittee shall submit a

semi-annual report which states that no such deviations occurred during that period.

(Authority for term: QAC rules 3745-77-07(A)(3)(c)(i) and (ii) and QAC rule 3745-77-

07(A)(13)(b))

(4) 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 (including any written malfunction reports required by QAC rule 3745-15-06

that are referenced in the deviation reports) are true, accurate, and complete.”

(Authority for term: QAC rule 3745-77-07(A) (3)(a)(iv))

(5) Reports of any required monitoring and/or record keeping information shall be submitted

to Ohio EPA DAPC, Northwest District Office.

(Authority for term: QAC rule 3745-77-07(A)(3)(a))

3. Scheduled Maintenance

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

paragraph (A) of OAC rule 3745-15-06. Except as provided in OAC rule 3745-15-06(A)(3), any

scheduled maintenance necessitating the shutdown or bypassing of any air pollution control system(s)shall be accompanied by the shutdown of the emissions unit(s) that is (are) served by such controlsystem(s). Any scheduled maintenance, as defined in OAC rule 3745-15-06(A)(1), that results in a

deviation from a federally enforceable emission limitation (or control requirement) shall be reported in

the same manner as described for malfunctions in Standard Term and Condition A.2.c)(1) above.

(Authority for term: QAC rule 3745-77-07(A) (3)(a))

4. Risk Management Plans

If applicable, the permittee shall develop and register a risk management plan pursuant to section

112(r) of the Clean Air Act, as amended, 42 U.S.C. § 7401 et seq. (“Act”); and, pursuant to 40 C.F.R.

68.215(a), the permittee shall submit either of the following:

Page 6 of 39
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Chapter 3745-1 04, inöluding the registration and submission of the risk management plan.

(Authority for term: OAC rule 3745-77-07(A)(4))

5. 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 exceedingany allowances that are lawfully held under Title IV of the Act, or any regulations adopted thereunder,are prohibited.(Authority for term: OAC rule 3745-77-07(A)(5))

6. Severability Clause

A determination that any tern, or condition of this 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 jn

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

(Authority for term: QAC rule 3745-77-07(A)(6))

7. General Requirements

a) The permittee must comply with all terms and conditions of this permit. Any noncompliance with

the federally enforceable terms and conditions of this 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 of a 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 of this permit.

c) This permit may be modified, reopened, revoked, or revoked and reissued, for cause, in

accordance with Standard Term and Condition A.11 below. The filing of a request by the

permittee for a permit modification, revocation and reissuance, or revocation, or of a notification

of planned changes or anticipated noncompliance does not stay any term and condition of thispermit.

d) This permit does not convey any property rights of any sort, or any exclusive privilege.e) The permittee shall furnish to the Director of the 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 of the Director, copies of records requiredto be kept by this permit. For information claimed to be confidential in the submittal to the

Page7of39
becomes eligible for non-title V permits, this permit shall cease to be enforceable when:

(1) the permittee submits an approved facility-wide potential to emit analysis supporting a

claim that the facility no longer meets the definition of a “major source” as defined in

OAC rule 3745-77-01 (W) based on the permanent shutdown and removal of one or

more emissions units identified in this permit; or the permittee no longer meets the

definition of a “major source” as defined in OAC rule 3745-77-01(W) based on obtaining

restrictions on the facility-wide potential(s) to emit that are federally enforceable orlegally and practically enforceable; or a combination of (1) and (2) above.

The permittee shall continue to comply with all applicable OAC Chapter 3745-31 requirements

for all regulated air contaminent sources once this permit ceases to be enforceable. The

permittee shall comply with any residual requirements, such as quarterly deviation reports,semi-annual deviation reports, and annual compliance certifications covering the period during

which this Title V permit was enforceable. All records relating to this permit must be maintained

in accordance with law.

(Authority for term: QAC rule 3745-77-01(149, OAC rule 3745-77-07(A)(3)(b) (ii), OAC rule 3745-

77(A) (7))

8. Fees

The permittee shall pay fees to the Director of the Ohio EPA in accordance with CRC section 3745.11

and OAC Chapter 3745-78.

(Authority for term: QAC rule 3745-77-07(A)(8))

9. Marketable Permit Programs

No revision of this permit is required under any approved economic incentive, marketable permits,

emissions trading, and other similar programs or processes for changes that are provided for in this

permit.

(Authority for term: QAC rule 3745-77-07(A) (9))

10. Reasonably Anticipated Operating Scenarios

The permittee is hereby authorized to make changes among operating scenarios authorized in this

permit without notice to the Ohio EPA, but, contemporaneous with making a change from one operating

scenario to another, the permittee must record in a log at the permitted facility the scenario under which

the permittee is operating. The permit shield provided in these standard terms and conditions shall

apply to all operating scenarios authorized in this permit.

(Authority for term: QAC rule 3745-77-07(A)(10))

Page 8 of 39
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— — - -- ~Units covered by this permit, a~d this permit h8s a rernai~ing term ~f three or more yeers. Such

a reopening shall be completed not later than eighteen (18) months after promulgation of theapplicable requirement. No such reopening is required if the effective date of the requirement is

later than the date on which the permit is due to expire, unless the original permit or any of its

terms and conditions has been extended pursuant to paragraph (E)(1) of QAC rule 3745-77-08.

b) This permit is issued to an affected source under the acid rain program and additional

requirements (including excess emissions requirements) become applicable. Upon approval by

the Administrator, excess emissions offset plans shall be deemed to be incorporated into the

permit, and shall not require a reopening of this permit.

c) The Director of the Ohio EPA or the Administrator of the U.S. EPA determines that the federally

applicable requirements in this permit are based on a material mistake, or that inaccurate

statements were made in establishing the emissions standards or other terms4~d conditions of

this permit related to such federally applicable requirements.

d) The Administrator of the U.S. EPA or the Director of the Ohio EPA determines that this permit

must be revised or revoked to assure compliance with the applicable requirements.

(Authority for term: QAC rules 3745-77-07(A)(12) and 3 745-77-08(D))

12. Federal and State Enforceability

Only those terms and conditions designated in this permit as federally enforceable, that are requiredunder the Act, or any of its applicable requirements, including relevant provisions designed to limit thepotential to emit of a source, are enforceable by the Administrator of the U.S. EPA, the State, and

citizens under the Act. All other terms and conditions of this permit shall not be federally enforceableand shall be enforceable under State law only.

(Authority for term: QAC rule 3745~77-07(B))

13. Compliance Requirements

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

applicable requirement in this Title V 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:(1) 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.

Page 9 of 39
pollution control equipment), practices, or operations regulated or required under this

permit.

(4) As authorized by the Act, sample or monitor at reasonable times substances or

parameters for the purpose of assuring compliance with the permit and applicablerequirements.

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 of the Ohio EPA. Progress reports shall contain the

following:

(1) Dates for achieving the activities, milestones, or compliance required in any schedule of

compliance, and dates when such activities, milestones, or compliance were achieved.

(2) 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.

d) Compliance certifications concerning the terms and conditions contained in this permit that are

federally enforceable emission limitations, standards, or work practices, shall be submitted tothe Director (the appropriate Ohio EPA District Office or local air agency) and the Administrator

of the U.S. EPA in the following manner and with the following content:

(1) Compliance certifications shall be submitted annually on a calendar year basis. The

annual certification shall be submitted (i.e., postmarked) on or before April 30th of each

year during the permit term.

(2) Compliance certifications shall include the following:

a. An identification of each term or condition of this permit that is the basis of the

certification.

b. The permittee’s current compliance status.

c. Whether compliance was continuous or intermittent.

d. The method(s) used for determining the compliance status of the source

currently and over the required reporting period.

e. Such other facts as the Director of the Ohio EPA may require in the permit to

determine the compliance status of the source.

Page 10 of 39
14. Permit Shield

a) Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, butexcluding terms and conditions for which the permit shield is expressly prohibited under QAC

rule 3745-77-07) shall be deemed compliance with the applicable requirements identified and

addressed in this permit as of the date of permit issuance.

b) This permit shield provision shall apply to any requirement identified in this permit pursuant to

OAC rule 3745-77-07(F)(2), as a requirement that does not apply to the souröe or to one ormore emissions units within the source.

(Authority for term: QAC rule 3745-77-07(F))

15. Operational Flexibility

The permittee is authorized to make the changes identified in QAC rule 3745-77-07(H)(1)(a) to (H)(1)(c)

within the permitted stationary source without obtaining a permit revision, if such change is not a

modification under any provision of Title I of the Act [as defined in QAC rule 3745-77-01(JJ)], and doesnot result in an exceedance of the emissions allowed under this permit (whether expressed therein as arate of emissions or in terms of total emissions), and the permittee provides the Administrator of theU.S. EPA and the appropriate Ohio EPA District Office or local air agency with written notification within

a minimum of seven days in advance of the proposed changes, unless the change is associated with,.or in response to, emergency conditions. If less than seven days notice is provided because of a need~~

to respond more quickly to such emergency conditions, the permittee shall provide, notice to the

Administrator of the U.S. EPA and the appropriate District Office of the Ohio EPA or local air agency as

soon as possible after learning of the need to make the change. The notification shall contain the items

required under OAC rule 3745-77-07(H)(2)(d).(Authority for term: QAC rules 3745-77-07(H)(1) and (2))

16. Emergencies

The permittee shall have an affirmative defense of emergency to an action brought for noncompliancewith technology-based emission limitations if the conditions of OAC rule 3745-77-07(G)(3) are met.This emergency defense provision is in addition to any emergency or upset provision contained in any

applicable requirement.

(Authority for term: QAC rule 3 745-77-07(G))

17. Off-Permit Changes

The owner or operator of a Title V source may make any change in its operations or emissions at the

source that is not specifically addressed or prohibited in the Title V permit, without obtaining an

amendment or modification of the permit, provided that the following conditions are met:

Page 11 of 39
qualify as insignificant emissions levels or activities as defined in OAC rule 3745-77-01(U).

Such written notice shall describe each such change, the date of such change, any change in

emissions or pollutants emitted, and any federally applicable requirement that would apply as a

result of the change.

c) The change shall not qualify for the permit shield under OAC rule 3745-77-07(F).d) The permittee shall keep a record describing all changes made at the source that result in

emissions of a regulated air pollutant subject to an applicable requirement, but not otherwiseregulated under the permit, and the emissions resulting from those changes.

e) The change is not subject to any applicable requirement under Title IV of the Act or is not a

modification under any provision of Title I of the Act.

Paragraph (I) of rule 3745-77-07 of the Administrative Code applies only to modification or amendment

of the permitte&s Title V permit. The change made may require a permit-to-install under Chapter 3745-

31 of the Administrative Code if the change constitutes a modification as defined in that Chapter.

Nothing in paragraph (I) of rule 3745-77-07 of the Administrative Code shall affect any applicable

obligation under Chapter 3745-31 of the Administrative Code.

(Authority for term: OAC rule 3745-77-07(l))

18. ComplIance Method Requirements

Nothing in this permit shall alter or affect the ability of any person to establish compliance with, or a

violation of, any applicable requirement through the use of credible evidence to the extent authorized by

law. Nothing in this permit shall be construed to waive any defenses otherwise available to thepermittee, including but not limited to, any challenge to the Credible Evidence Rule (see 62 Fed. Reg.8314, Feb. 24, 1997), in the context of any future proceeding.(This term is provided for informational purposes only.)

19. Insignificant Activities or Emissions Levels

Each IEU that has one or more applicable requirements shall comply with those applicable

requirements.

(Authority for term: OAC rule 3745-77-07(A)(1))

20. Permit to Install Requirement

Prior to the “installation” or “modification” of any “air contaminant source,” as those terms are defined in

QAC rule 3745-31-01, a permit to install must be obtained from the Ohio EPA pursuant to OAC Chapter3745-31.

(Authority for term: QAC rule 3745-77-07(A)(1))

Page 12 of 39
- (Authorityfo~ term: QAC rule 3745L77~07(A)(1))~

22. Permanent Shutdown of an Emissions Unit

The permittee may notify Ohio EPA of any emissions unit that is permanently shut down by submitting

a certification from the responsible official that identifies the date on which the emissions unit was

permanently shut down. Authorization to operate the affected emissions unit shall cease upon the date

certified by the responsible official that the emissions unit was permanently shut down.

After the date on which an emissions unit is permanently shut down (i.e., that has .been physically

removed from service or has been altered in such a way that it can no longer operate without a

subsequent “modification” or “installation” as defined in CAC Chapter 3745-3 1 and therefore ceases to

meet the definition of an “emissions unit” as defined in OAC rule 3745-77-01(0)), rendering existingpermit terms and conditions irrelevant, the permittee shall not be required, after, the date of the

certification and submission to Ohio EPA, to meet any Title V permit requirements ~ppJicable to that

emissions unit, except for any residual requirements, such as the quarterly deviation reports, semiannual deviation reports and annual compliance certification covering the period during which theemissions unit last operated. All records relating to the shutdown emissions unit, generated while the

emissions unit was in operation, must be maintained in accordance with law.

No emissions unit certified by the responsible official as being permanently shut down may resume

operation without first applying for and obtaining a permit to install pursuant to QAC Chapter 3745-31.

(Authority for term: OAC rule 3 745-77-01)

23. Title VI Provisions

If applicable, the permittee shall comply with the standards for recycling and reducing emissions of

ozone depleting substances pursuant to 40 CFR Part 82, Subpart F, except as provided for motor

vehicle air conditioners in Subpart B of 40 CFR Part 82:

a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices specified in 40 CFR 82.156.

b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply

with the standards for recycling and recovery equipment specified in 40 CFR 82.158.

c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by

an approved technician certification program pursuant to 40 CFR 82.161.

(Authority for term.’ QAC rule 3745-77-01(H)(1 1))

Page 13 of 39
a) Reports of any required monitoring and/or record keeping 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 (i) any deviations (excursions) from emission limitations, operational

restrictions, and control device operating parameter limitations that have been detected by the

testing, monitoring, and record keeping requirements specified in this permit, (ii) the probable

pause of such deviations, and (iii) any corrective actions or preventive measures which havebeen or will be taken, shall be submitted to the appropriate Ohio EPA District Office or local air

agency. In identifying each deviation, the permittee shall specify the applicable requirement for

which the deviation occurred, describe each deviation, and provide the magnitude and duration

of each deviation. 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 (i.e., postmarked) quarterly, by January 31, April 30, July 31, and October31

of each year and shall cover the previous calendar quarters. (These quarterly reports shallexclude deviations resulting from malfunctions reported in accordance with QAC rule 3745-15-06.)

25. Records Retention Requirements Under State Law Only

Each record of any monitoring data, testing data, and support information required pursuant to thispermit 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 originalstrip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by

this permit. Such records may be maintained in computerized form.

26. Inspections and Information Requests

The Director of the Ohio EPA, or an authorized representative of the Director, may, subject to the safety

requirements of the permittee and without undue delay, enter upon the premises of this source at anyreasonable time for purposes of making inspections, conducting tests, examining records or reportspertaining to any emission of air contaminants, and determining compliance with any applicable Stateair pollution laws and regulations and the terms and conditions of this permit. The permittee shall

furnish to the Director of the 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 withthis permit. Upon verbal or written request, the permittee shall also furnish to the Director of the Ohio

EPA, or an authorized representative of the Director, copies of records required to be kept by thispermit.

(Authority for term: QAC rule 3 745-77-07(C))

Page 14 of 39
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á~énàic~6rdance With ~aragra~h (B) of QAC ftile 3745-15-06. Except iiprovided in that rule, anyscheduled maintenance or malfunction necessitating the shutdown or bypassing of any air pollutioncontrol system(s) shall be accompanied by the shutdown of the emissions unit(s) that is (are) served by

such control system(s).

28. Permit Transfers

Any transferee of this permit 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 thispermit.(Authority for term: OAC rule 3 745-77-01(C))

29. Additional Reporting Requirements When There Are No Deviations of Federajjy. Enforceable

Emission Limitations, Operational Restrictions, or Control Device Oper4)~ig. ParameterLimitationsIf no emission limitation (or control requirement), operational restriction and/or control device parameter

limitation 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 (i.e.,

postmarked) by January 31, April 30, July 31, and October31 of each year; and each report shall cover

the previous calendar quarter.The permittee is not required to submit a quarterly report which states that no deviations occurredduring that quarter for the following situations:a) where an emissions unit has deviation reporting requirements for a specific emission limitation,

operational restriction, or control device parameter limitation that override the deviation reportingrequirements specified in Standard Term and Condition A.2.c)(2); or

b) where an uncontrolled emissions unit has ho monitoring, record keeping, or reporting

requirements and the emissions unit’s applicable emission limitations are established at the

potentials to emit; or

c) where the company’s responsible official has certified that an emissions unit has been

permanently shut down.

Page 15 of 39
B. Facility-Wide Terms and Conditions

Page 16 of 39
2. The following regulation shall apply to this facility: 40 CFR 61 .340 et seq. (NESHAP Subpart FF - Benzene Waste Operations). The permittee shall comply with the following Subpart FF applicable

emission limitations/control measures at this facility:a) Standards for Tanks:

The permittee shall comply with the following standards for each tank (i.e., emissions unitsT007, T008, T009, TOlD, TOll, T012, T013, T026, T027, T028, and T029) employed at this

facility:

(1) The permittee shall install, operate, and maintain a fixed-roof and clos’ed-vent system

that routes all organic vapors vented from the tank to a control device. The fixed roof

shall comply with the requirements of (2) and (3) as follows:

(2) The cover and all openings on the fixed roofs (e.g., access hatches, sampling ports, and

gauge wells), shall be designed to operate with no detectable emissions as indicated by

an instrument reading of less than 500 parts per million by volume (ppmv) above

background, as determined at least once per year by the methods specified in B.5.

(3) Each opening shall be maintained in a closed, sealed position (e.g., covered by a lid that

is gasketed and latched) at all times that waste is in tank except when it is necessary touse the opening for waste sampling or removal, or for equipment inspection,maintenance, or repair.

(4) The closed-vent system and control devices shall be designed and operated in

accordance with the requirements in B.2.e).

[40 CFR 61.343(a)(l) and QAC rule 3745-77-07(A)(l)]

b) Standards for Containers:

The permittee shall comply with the following standards for each container in which waste is

placed:

(1) The cover and all openings (e.g., bungs, hatches, and sampling ports) shall be designed

to operate with no detectable emissions as indicated by an instrument reading of lessthan 500 ppmv above background, as determined at least once per year by the methods

specified in B.5.*

(2) Each opening shall be maintained in a closed, sealed position (e.g., covered by a lid that

is gasketed and latched) at all times that waste is in the container except when it isnecessary to use the opening for waste loading, removal, inspection, or sampling.

(3) When a waste is transferred into a container by pumping, the permittee shall perform the

transfer using a submerged fill pipe. The submerged fill pipe outlet shall extend to withintwo fill pipe diameters of the bottom of the container while the container is being loaded.

During loading of the waste, the cover shall remain in place and all openings shall be

Page 17of39
be performed by the owner or operator in a manner such that, while the waste is being

treated, the covered or closed container is vented directly through a closed-vent systemto a control device. The closed-vent system and control device** must be designed and

operated in accordance with the requirements of 40 CFR 61.349. For a container cover,

the cover and all openings (e.g., doors, hatches) must be designed to operate with no

detectable emissions as indicated by an instrument reading of less than 500 ppmvabove background, initially and thereafter at least once per year by the methodsspecified in B.5.a) Safety devices, as defined in Subpart FE, may be installed andoperated as necessary on any container, enclosure, closed-vent system, or controldevice used to comply with this subsection. Fuel blending is considered to be part of the

treatment process under this subsection.

* Containers having a volume of less than 111 gallons, and meeting the US DOT specificationsand testing requirements under 49 CFR 178, are exempt from the monitoring requirement of

B.2.b)(2), provided such containers are covered and not vented to the atmosphere. (consideringUS EPA letter - June 27, 1995 - Region VI to Dow Chemical Co.)

** See B.2.e)(4).

[40 CFR 61 .345(a) and OAC rule 3745-77-07(A)(1)]

C) Standards for Individual Drain Systems:

The permittee shall comply with the following standards for each individual drain system inwhich waste is placed:

(1) The permittee shall install, operate, and maintain on each drain system opening a cover

and closed-vent system that routes all organic vapors vented from the drain system to

the control device. The cover on each individual drain system shall comply with the

requirements of (2) and (3) as follows:

(2) The cover and all openings (e.g., doors, hatches) shall be designed to operate with no

detectable emissions as indicated by an instrument reading of less than 500 ppmv

above background, as determined at least once per year by the methods specified in

B.5.

(3) Each opening shall be maintained in a closed, sealed position (e.g., covered by a lid that

is gasketed and latched) at all times that waste is in the drain system except when it is

necessary to use the opening for waste sampling or removal, or for equipment

inspection, maintenance, or repair.

[40 CFR 61.346(a)(1)(i)(A) and (B), and QAC rule 3745-77-07(A)(1)]

Page 18 of 39
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at -— ~destroys benzene in the waste stream by incinerating the waste in a combustiGn unitthat

achieves a destruction efficiency of 99 percent or greater for benzene.

(2) The permittee may aggregate or mix together individual waste streams to create a

combined waste stream for the purpose of facilitating treatment of waste to comply with

the above requirements.

(3) If the treatment process has any openings (e.g., access doors, hatches, etc.), all such

openings shall be sealed (e.g., gasketed, latched, etc.) and kept closed at all times when

waste is being treated, except during inspection and maintenance.

[40 CFR 61.348(a)(1)(iii), (a)(4), (e), and QAC rule 3745-77-07(A)(1)]

e) Standards for Closed-vent Systems:

The permittee shall properly design, install, operate, and maintain the closed~I&,t system and

control device in accordance with the following requirements:(1) The closed-vent system shall be designed to operate with no detectable emissions as

indicated by an instrument reading of less than 500 ppmv above background, as

determined at least once per year by the methods specified in B.5.

(2) All gauging and sampling devices shall be gas-tight except when gauging or sampling is

taking place.

(3) For the closed-vent system(s), one or more devices which vent directly to the

atmosphere may be used on the closed-vent system provided each device remains in aclosed, sealed position during normal operations except when the device needs to open

to prevent physical damage or permanent deformation of the closed-vent system

resulting from malfunction of the unit in accordance with good engineering and safetypractices for handling flammable, explosive, or other hazardous materials.

(4) The control device for the closed-vent system shall be designed and operated to reduce

the organic emissions vented to it by 95 weight percent or greater. Note: Systech (the

permittee) currently complies with requirements for the closed-vent system control

device through more stringent requirements, i.e. 40 CFR 1200 et seq. - MACT Subpart

EEE (Lafarge emissions units P014 and P015) - i.e. the closed-vent organic vapors are

destroyed in the cement kiln(s) combustion zone. Carbon canisters are used as back-up

when both cement kilns are off-line.

(5) The closed-vent system and control device shall be operated at all times when waste is

placed in the tanks (or other waste management units) except when maintenance orrepair of the control device cannot be completed without a shutdown of the control

device.

[40 CFR 61.349(a)(1)(i), (iii), and (iv), (a)(2)(i)(A), and (b), and OAC rule 3745-77-07(A)(1)]

Page 19of39
[40 CFR 61.350 and OAC rule 3745-77-07(A)(1)]

The permittee shall comply with the following Subpart FF monitoring and/or record keeping

requirements:

a) Tanks:

(1) Each fixed-roof, seal, access door, and all other openings shall be checked by visual

inspection quarterly to ensure that no cracks or gaps occur and that access doors and

other openings are closed and gasketed properly.

(2) Except as provided in B.2.f), when a broken seal or gasket or other problem is identified,

or when detectable emissions are measured, first efforts at repair shall be made as soon

as practicable, but not later than 45 calendar days after identification.

[40 CFR 61.343(c) and (d) and QAC rule 3745-77-07(C)(1)]Containers:(I) Each cover and all openings shall be visually inspected quarterly to ensure that they are

closed and gasketed properly.

(2) Except as provided in B.2.f), when a broken seal or gasket or other problem is identified,

first efforts at repair shall be made as soon as practicable, but not later than 15 calendar

days after identification.

[40 CFR 61.345(b) and (C) and OAC rule 3745-77-07(C)(1)]

Individual Drain Systems:

(1) Each cover seal, access hatch, and all other openings shall be checked by visual

inspection quarterly to ensure that no cracks or gaps occur and that access hatches andother openings are closed and gasketed properly.

(2) Except as provided in B.2.f), when a broken seal or gasket or other problem is identified,

or when detectable emissions are measured, first efforts at repair shall be made as soonas practicable, but not later than 15 calendar days after identification.

[40 CFR 61.346(a)(2) and (3) and QAC rule 3745-77-07(C)(1)]

Treatment Process:

(1) Each seal, access door, and all other openings shall be checked by visual inspections

quarterly to ensure that no cracks or gaps occur and that openings are closed andgasketed properly.

Page 20 of 39
e) Closed-vent System:

(1) Each closed-vent system and control device shall be visually inspected quarterly. The

visual inspection shall include inspection of ductwork and piping and connections tocovers and control devices for evidence of visible defects such as holes in ductwork orpiping and loose connections.

(2) Except as provided in B.2.f), if visible defects are observed during an inspection, or if

other problems are identified, or if detectable emissions are measured, a first effort torepair the closed-vent system and control device shall be made as soon as practicablebut no later than 5 calendar days after detection. Repair shall be completed no later than

15 calendar days after the emissions are detected or the visible defect is observed.

[40 CFR 61.349(f) and (g) and QAC rule 3745-77-07(C)(1)]

f) The permittee shall maintain engineering design documentation for all controlteqLlipment that is

installed on tanks, containers, individual drain systems, or other waste management units as

defined in 40 CFR 61.341. The documentation shall be retained for the life of the control

equipment.

[40 CFR 61 .356(d) and OAC rule 3745-77-07(C)(1)]

g) The permittee shall retain the following documentation for the life of the control device:

(1) A statement signed and dated by the permittee certifying that the closed-vent system

and control device are designed to operate at the documented performance level when

the waste management unit vented to the control device is or would be operating at the

highest load or capacity expected to occur.

(2) The permittee shall maintain a record for each visual inspection required in B.3 that

identifies a problem (such as a broken seal, gap or other problem) which could result inbenzene emissions. The record shall include the date of the inspection, wastemanagement unit and control equipment location where the problem is identified, a

description of the problem, a description of the corrective action taken, and the date thecorrective action was completed.

[40 CFR 61.356(f)(1), (g) and QAC rule 3745-77-07(C)(1)]

h) The permittee shall maintain a record for each test of no detectable emissions required by B.2.

The record shall include the following information: date the test is performed, background level

measured during test, and maximum concentration indicated by the instrument reading

measured for each potential leak interface, If detectable emissions are measured at a leakinterface, then the record shall also include the waste management unit, control equipment, andleak interface location where detectable emissions were measured, a description of the

problem, a description of the corrective action taken, and the date the corrective action was

completed.

[40 CFR 61.356(h) and QAC rule 3745-77-07(C)(1)]

Page 21 of 39
61 .354(c), refer to Lafarge Title V permit - Fac. ID 03 63 00 0002 (P0107002), or renewal asapplicable - emissions units P014 and P015.

k) Regarding combustion efficiency parametric monitoring requirement for the closed-vent system

control device under 40 CFR 61 .356(j)(4), refer to Lafarge Title V permit - Fac. ID 03 63 00 0002

(P0107002), or renewal, as applicable - emissions units P014 and P015.

I) Regarding engineering design requirement for the closed-vent system control device under 40

CFR 61.349(c)(1), refer to Lafarge Title V permit - Fac. ID 03 63 00 0002 (P0107002) orrenewal, as applicable - emissions units P014 and P015.

m) The permittee shall maintain documentation that includes the following information regarding the

closed-vent system /control device operation:(1) Dates of startup and shutdown of the closed-vent system.(2) Periods when the closed-vent system is not operated as designed.

Regarding control device performance records requirement under 40 CFR 61 .356(j)(1), (3), and

(4), refer to Lafarge Title V permit (Facility ID 03 63 00 0002 -P0107002), or renewal, asapplicable - emissions units P014 and P015. Note: even at times of Lafarge cement kilnoperation when not firing waste-derived fuel (and therefore not under MACT Subpart EEEstandards), process standards for proper cement production still require a combustion

temperature of approximately 2200 deg F, easily surpassing temperatures commonly

associated with 95 percent organic destruction efficiency [See B.2.e)(4)]. Systech has recordsshowing that the carbon canisters, although used only as back-up for times when neither kiln is

operating (i.e. rarely), have been designed in accordance with standards such as in 40 CFR

61 .356(f)(2)(i)(G).

4. The permittee shall comply with the following Subpart FF reporting requirements:

a) The permittee shall submit to the Director (Ohio EPA, Northwest District) annual reports that

summarize the following information (if the information in the annual report is not changed in the

following year, the permittee may submit a statement to that effect):

(1) Whether or not the water content of the waste stream is greater than 10 percent.

(2) Whether or not the waste stream is a process wastewater stream, product tank

drawdown, or landfill leachate.

(3) Annual waste quantity for the waste stream.(4) Range of benzene concentrations for the waste stream.(5) Annual average flow-weighted benzene concentration for the waste stream.(6) Annual benzene quantity for the waste stream.

Page 22 of 39
b) The permittee shall submit quarterly to the Director (Ohio EPA District Office or local air agency)

a certification that all of the required inspections have been carried out in accordance with the

requirements of B.3. The certification shall be submitted within 30 days following the end of the

calendar quarter.

[40 CFR 61.357(d)(6) and QAC rule 3745-77-07(C)(1)]

c) The permittee shall submit annually to the Director (Ohio EPA District Office or local air agency)

a report that summarizes all inspections required during which d~tect~bEe erñissions aremeasured or a problem (such as a broken seal, gap or oth~r problem) that ~c~uld re~sult inbenzene emissions is identified, including iñföThi~tibn about the repairs or corrective action

taken. The certification shall be submitted within 30 days following the end of the calendarquarter.

[40 CFR 61.357(d)(8) and OAC rule 3745-77-07(C)(1)]

d) Regarding operational excursion reporting requirement for the closed-vent~system control

device under 40 CFR 61.357(d)(7)(iv)(A), refer to Lafarge Tite V permit - Fac. ID 0363 00 0002

(P0107002), or renewal, as applicable - emissions units P014 and P015 (e.g. for any time

periods where neither kiln is in operation).

5. The permittee shall comply with the following Subpart FF testing requirements:

a) The permittee shall annually test equipment for compliance with no detectable emissions in

accordance with the following requirements:(1) Monitoring shall comply with Method 21 from Appendix A of 40 CFR Part 60.(2) The detection instrument shall meet the performance criteria of Method 21.(3) The instrument shall be calibrated before use on each day of its use by the procedures

specified in Method 21.

(4) Calibration gases shall be: zero air (less than 10 ppm of hydrocarbons in air); and, a

mixture of methane or n-hexane and air at a concentration of approximately, but less

than, 10,000 ppm methane or n~hexane.*

(5) The background level shall be determined as set forth in Method 21.

(6) The instrument probe shall be traversed around all potential leak interfaces as close as

possible to the interface as described in Method 21.

(7) The arithmetic difference between the maximum concentration indicated by the

instrument and the background level is compared to 500 ppm for determining

compliance.

Page 23 of 39
b) The permittee shall provide sufficient information to document the flow-weighted annual average

benzene concentration of each waste stream. Examples of information that could constituteknowledge include material balances, records of chemicals purchases, or previous test results

provided the results are still relevant to the current waste stream. If test data are used, then theowner or operator shall provide documentation describing the testing protocol and the means by

which sampling variability and analytical variability were accounted for in the determination ofthe flow-weighted annual average benzene concentration for the waste stream. When the

permittee and Ohio EPA do not agree on determinations of the flow-weighted annual averagebenzene concentration based on knowledge of the waste, the procedures under 40 CFR

61 .355(c)(3) shall be used to resolve the disagreement.[40 CFR 61.355(c)(2) and OAC rule 3745-77-07(C)(1)]

c) The facility has been determined to be exempt from compliance demonstration for B.2.d)(1)

under 40 CFR 61.348(d)(2). That is, the facility must instead be in compliance with 40 CFR

266.100 et seq. (Subpart H) or 40 CFR 63.1200 et seq. (Subpart EEE) for the cement kilns

(emissions units P014 and P105) located at the Lafarge cement plant, which is permitted under

the same premise number as this facility.

[OAC rule 3745-77-07(C)(1)]

6. Waste subject to processing (i.e., receipt, handling, and treatment), pursuant to 40 CFR, Part 61,

Subpart FF standards for the highest total annual benzene (TAB) category of greater than 10 mega

grams per year [40 CFR 61.342(c)], is not considered ‘off-site material’ under 40 CFR 63.680(b)(2)(vi),and is therefore explicitly excluded from 40 CFR, Part 63 Subpart DD applicability.

All of the fuel quality waste that the permittee processes is currently processed under Subpart FE

requirements as described above, but this is chosen and voluntary, i.e., not all of the fuel quality wasteactually falls under Subpart FF applicability. This Title V permit recognizes that, pursuant to this permit,

the permittee has committed to continue to process all the fuel quality waste under the Subpart FF

requirements as described above. The exclusion from Subpart DD applicability as described above is

therefore extended to all the fuel quality waste, under authority of this Title V permit.

[OAC rule 3745-77-07(C)(1)]

7. The following equipment at the facility~ intended /used to operate in volatile hazardous air pollutant

(VHAP) service as defined in 40 CFR 61.241, is subject to the requirements of 40 CFR 61.240 et seq.(Subpart V - Equipment Leaks) under this permit: pumps, pressure relief devices, sampling connection

systems, open-ended valves or lines, valves, and connectors.

[40 CFR 61.240(a)]

a) Each piece of equipment to which Subpart V under this permit applies shall be marked in such a

manner that it can be distinguished readily from other pieces of equipment.[40 CFR 61.242-1(d) and OAC rule 3745-77-07(C)(1)1

Page 24 of 39
a) Standards for pumps

(1) Each pump shall be monitored monthly to detect leaks by the methods specified in

B.19.a) through B.19.f), except as provided in B.8.c) through B.8.I). If an instrument

reading of 10,000 ppm or greater is measured, a leak is detected.

(2) Each pump shall be checked by visual inspection each calendar week for indications of

liquids dripping from the pump seal. If there are indications of liquids dripping from the

pump seal, a leak is detected.

[40 CFR 61 .242-2(a), (b) and QAC rule 3745-77-07(C)(1)1

b) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15

calendar days after it is detected, except as provided in B.16.

A first attempt at repair shall be made no later than 5 calendar days after each F~’ak is detected.

[40 CFR 61 .242-2(c) and QAC rule 3745-77-07(C)(1)]

c) Each pump equipped with a dual mechanical seal system that includes a barrier fluid system is

exempt from the requirements of B.8.a) and B.8.i), provided the requirements of B.8.d) through

B.8.g) are met.[40 CFR 61.242-2(d) and QAC rule 3745-77-07(A)(1)]

d) As provided in B.8.c), if applicable, each dual mechanical seal system must be:

(1) operated with the barrier fluid at a pressure that is at all times greater than the pump

stuffing box pressure;

(2) equipped with a barrier fluid degassing reservoir that is routed to a process or fuel gas

system; or

(3) equipped with a system that purges the barrier fluid into a process stream with zero

VHAP emissions to atmosphere.

[40 CFR 61.242-2(d)(1) and QAC rule 3745-77-07(A)(1)]

e) As provided in B.8.c), if applicable, the barrier fluid must not be in VHAP service and, if the

pump is covered by standards under 40 CFR part 60, is not in VOC service.[40 CFR 61.242-2(d)(2) and QAC rule 3745-77-07(A)(1))

f) As provided in B.8.c), if applicable, each barrier fluid system must be equipped with a sensor

that will detect failure of the seal system, the barrier fluid system, or both.

[40 CFR 61.242-2(d)(3) and QAC rule 3745-77-07(A)(1)]

g) As provided in B.8.c), if applicable, each pump must be checked by visual inspections each

calendar week for indications of liquids dripping from the pump seal.

Page 25 of 39
presence of VHAP, a leak is detected. For the purpose of this paragraph, the monitormay be calibrated with VHAP, or may employ a gas chromatography column to limit the

response of the monitor to VHAP, at the option of the permittee.

(3) If an instrument reading of 10,000 ppm or greater (total VOC) is measured, a leak is

detected.

[40 CFR 61 .242-2(d)(4) and DAC rule 3745-77-07(C)(1)]

h) As provided in B.8.c), if applicable, each sensor as described in B.8.f) must be checked daily or

must be equipped with an audible alarm.[40 CFR 61.242-2(d)(5) and QAC rule 3745-77-07(C)(1)]

i) As provided in B.8.c), if applicable, the permittee must determine, based on design

considerations and operating experience, criteria applicable to the presence and frequency of

drips and to the sensor that indicates failure of the seal system, the barrier fluid system, or both.

(1) If indications of liquids dripping from the pump seal exceed the criteria established

above, or if, based on the criteria established above, the sensor indicates failure of theseal system, the barrier fluid system, or both, a leak is detected.

(2) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15

calendar days after it is detected, except as provided in B.16.

(3) A first attempt at repair shall be made no later than five calendar days after each leak is

detected.

[40 CFR 61 .242-2(d)(6) and QAC rule 3745-77-07(C)(1)]

j) Any pump that is designated, as described in j)(2) below, for no detectable emissions, as

indicated by an instrument reading of less than 500 ppm above background, is exempt from therequirements of B.8.a) through B.8.i) if the pump:

(1) has no externally actuated shaft penetrating the pump housing;(2) is demonstrated to be operating with no detectable emissions, as indicated by an

instrument reading of less than 500 ppm above background, as measured by themethod specified in B.19.g; and

(3) is tested for compliance with j)(2) above initially upon designation, annually, and at other

times requested by the Administrator.

[40 CFR 61 .242-2(e) and QAC rule 3745-77-07(C)(1)]

k) If any pump is equipped with a closed-vent system capable of capturing and transporting any

leakage fro~n the seal or seals to a process or fuel gas system, it is exempt from the

requirements of B.8.a) through B.8.j).[40 CFR 61.242-2(f) and QAC rule 3745-77-07(A)(1)]

Page 26 of 39
personnel would be exposed to an immediate danger as a consequence of complying

~~~With B.8.a); and~~

(2) the permittee has a written plan that requires monitoring of the pump as frequently as

practicable during safe-to-monitor times but no more frequently than the periodicmonitoring schedule otherwise applicable, and repair of the equipment according to the

procedures in B.8.b) if a leak is detected.

[40 CFR 61 .242-2(g) and QAC rule 3745-77-07(C)(1)]

9. [RESERVED)

10. STANDARDS: PRESSURE RELIEF DEVICES

a) Except during pressure releases, each pressure relief device in gas/vapor service shall be

operated with no detectable emissions, as indicated by an instrument reading of less than 500ppm above background, as measured by the method specified in B. 1 9.g). ~[40 CFR 61 .242-4(a) and OAC rule 3745-77-07(A)(1)]

b) Pressure Relief Devices:

(1) After each pressure release, the pressure relief device shall be returned to a of no

detectable emissions, as indicated by an instrument reading of less than 500 ppm above

background, as soon as practicable, but no later than 5 calendar days after eachpressure release, except as provided in B.16.

(2) No later than 5 calendar days after the pressure release, the pressure relief device shall

be monitored to confirm the condition of no detectable emissions, as indicated by an

instrument reading of less than 500 ppm above background, as measured by themethod specified in B.19.g).

[40 CFR 61 .242-4(b) and QAC rule 3745-77-07(C)(1)]

C) Any pressure relief device that is routed to a process or fuel gas system is exempt from the

requirements of B.10.a and B.10.b above.

[40 CFR 61.242-4(c) and DAC rule 3745-77-07(A)(1)]

d) Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief

device is exempt from the requirements of B.10.a) and B.10.b), provided the permittee complies

with the following:

After each pressure release, a new rupture disk shall be installed upstream of the pressure relief

device as soon as practicable, but no later than 5 calendar days after each pressure release,except as provided in B.16.

[40 CFR 61 .242-4(d) and QAC rule 3745-77-07(C)(1)]

Page 27 of 39
In-situ sampling systems and sampling systems without purges are exempt from the above

requirements.[40 CFR 61.242-5(a), (C) and OAC rule 3745-77-07(A)(1)]STANDARDS: OPEN-ENDED VALVES OR LINES

a) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second

valve.The cap, blind flange, plug, or second valve shall seal the open end at all times except during

operations requiring process fluid flow through the open-ended valve or line.[40 CFR 61.242-6(a) and OAC rule 3745-77-07(A)(1))

b) Each open-ended valve or line equipped with a second valve shall be operated in a manner

such that the valve on the process fluid end is closed before the second valve is closed.

[40 CFR 61.242-6(b) and OAC rule 3745-77-07(A)(1))

c) When a double block and bleed system is being used, the bleed valve or line may remain open

during operations that require venting the line between the block valves but shall comply with a)at all other times.[40 CFR 61.242-6(c) and OAC rule 3745-77-07(A)(1)]

d) Open-ended valves or lines in an emergency shutdown system which are designed to open

automatically in the event of a process upset are exempt from the requirements of a), b), andc).

[40 CFR 61.242-6(d) and OAC rule 3745-77-07(A)(1))

e) Open-ended valves or lines containing materials which would autocatalytically polymerize or

would present an explosion, serious overpressure, or other safety hazard if capped or equippedwith a double block and bleed system as specified in a), b), and C), are exempt from the

requirements of those.

[40 CFR 61.242-6(e) and OAC rule 3745-77-07(A)(1)]STANDARDS: VALVESa) Each valve shall be monitored monthly to detect leaks by the method specified in B.19.a)

through B.19.f) and shall comply with B.13.b) through B.13.d), except as provided in B.13.e)through B.13.j). If an instrument reading of 10,000 ppm or greater is measured, a leak is

detected.

[40 CFR 61 .242-7(a), (b) and OAC rule 3745-77-07(C)(1)]

Page 28 of 39
[40 CFR 61.242-7(c) and QAC rule 3745-77-07(C)(1)J

c) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15

calendar days after the leak is detected, except as provided in B.16.

A first attempt at repair shall be made no later than 5 calendar days after each leak is detected.

[40 CFR 61 .242-7(d) and QAC rule 3745-77-07(C)(1)]

d) First attempts at repair include, but are not limited to, the following best practices where

practicable:(1) tightening of bonnet bolts;

(2) replacement of bonnet bolts;

(3) tightening of packing gland nuts; and

• (4) injection of lubricant into lubricated packing.

[40 CFR 61 .242-7(e) and OAC rule 3745-77-07(C)(1)]

e) Any valve that is designated, as described in B.17.c)(2), for no detectable emissions, as

indicated by an instrument reading of less than 500 ppm above background, is exempt from therequirements of B.13.a) if the valve:(1) Has no external actuating mechanism in contact with the process fluid;

(2) Is operated with emissions less than 500 ppm above background, as measured by the

method specified in B.19.g); and

(3) Is tested for compliance with e)(2) above initially upon designation, annually, and at

other times requested by the Director.

[40 CFR 61.242-7(f) and OAC rule 3745-77-07(C)(1)]

f) Any valve that is designated, as described in B.17.d)(1), as an unsafe-to-monitor valve is

exempt from the requirements of B.13.a) if:

(1) the permittee demonstrates that the valve is unsafe to monitor because monitoring

personnel would be exposed to an immediate danger as a consequence of complying

with B.13.a); and

(2) the permittee has a written plan that requires monitoring of the valve as frequent as

practicable during safe-to-monitor times.

[40 CFR 61.242-7(g) and QAC rule 3745-77-07(C)(1)]

Page 29 of 39
(2) the process unit within which the valve is located is an existing process unit; and(3) the permittee follows a written plan that requires monitoring of the valve at least once per

calendar year.

[40 CFR 61.242-7(h) and OAC rule 3745-77-07(C)(1)]

h) The permittee may elect for all valves within a process unit to comply with one of the alternative

work practices specified in B.13.i)(2) and B.13.i)(3) below.The permittee must notify the Director (Ohio EPA, Northwest District) before implementing one

of the alternative work practices: The permittee shall notify the Director (Ohio EPA, Northwest

District) of the alternative standard selected 90 days before implementing either of theprovisions.[40 CFR 61.243-2(a), 40 CFR 61-247(d), and CAC rule 3745-77-07(C)(1))

i) As provided in B.13.h) if applicable,

(1) The permittee shall comply initially with the requirements for valves, as described in

B.13.a) through B.13.g) above.

(2) After 2 consecutive quarterly leak detection periods with the percentage of valves

leaking equal to or less than 2.0, the permittee may begin to skip one of the quarterly

leak detection periods for the valves in VHAP service.

(3) After five consecutive quarterly leak detection periods with the percentage of valves

leaking equal to or less than 2.0, the permittee may begin to skip three of the quarterlyleak detection periods for the valves in VHAP service.

(4) If the percentage of valves leaking is greater than 2.0, the permittee shall comply with

the requirements as described in B.13.a) through B.13.g), but may again elect to use this

provision.

[40 CFR 61.243-2(b) and OAC rule 3745-77-07(C)(1)]

j) The permittee may comply with the alternative valve standard provisions of 40 CFR 61.243-1 in accordance with that provision, and upon notification to the Ohio EPA Director (Ohio EPA,

Northwest District) and the US EPA Administrator under that provision.[QAC rule 3745-77-07(C)(1)]

Page 30 of 39
g p

(1) The permittee shall eliminate the visual, audible, olfactory, or other indication of a

potential leak.

(2) The permittee shall monitor the equipment within 5 days by the method specified in

B.19.a) through B.19.f) and shall comply with the requirements of B.14.b). If an

instrument reading of 10,000 ppm or greater is measured, a leak is detected.

[40 CFR 61.242-8(a), (b) and QAC rule 3745-77-07(C)(1)]

b) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15

calendar days after it is detected, except as provided in B.16. 1

The first attempt at repair shall be made no later than 5 calendar days after each leak isdetected. First attempts at repair include, but are not limited to, the following best practices

where practicable: Tightening of bonnet bolts; Replacement of bonnet boli~y Tightening of

packing gland nuts; and Injection of lubricant into lubricated packing.[40 CFR 61.242-8(c), (d) and OAC rule 3745-77-07(C)(1))

15. [RESERVED]

16. STANDARDS: DELAY OF REPAIR

a) Delay of repair of equipment for which leaks have been detected will be allowed if repair within

15 days is technically infeasible without a process unit shutdown. Repair of this equipment shall - occur before the end of the next process unit shutdown.

b) [40 CFR 61 .242-1 0(a) and QAC rule 3745-77-07(C)(1)]

C) Delay of repair of equipment for which leaks have been detected will be allowed for equipment

that is isolated from the process and that does not remain in VHAP service.

[40 CFR 61 .242-1 0(b) and QAC rule 3745-77-07(C)(1)]

d) Delay of repair for valves will be allowed if:

(1) the permittee demonstrates that emissions of purged material resulting from immediate

repair are greater than the fugitive emissions likely to result from delay of repair; and

(2) when repair procedures are effected, the purged material is collected and destroyed in a

control device complying with 40 CFR 61.242-11, i.e., achieving a destruction efficiencyof 95 percent, by weight.

[40 CFR 61 .242-1 0(c) and QAC rule 3745-77-07(C)(1)J

Page 31 of 39
(2) repair is completed as soon as practicable, but not later than 6 months after the leak was

detected.

[40 CFR 61.242-10(d) and QAC rule 3745-77-07(C)(1)]Delay of repair beyond a process unit shutdown will be allowed for a valve if the valve assemblyreplacement is necessary during the process unit shutdown, the valve assembly supplies havebeen depleted, and the valve assembly supplies had been sufficiently stocked before thesupplies were depleted. Delay of repair beyond the next process unit shutdown will not beallowed unless the next process unit shutdown occurs sooner than 6 months after the first

process unit shutdown.[40 CFR 61.242-10(e) and QAC rule 3745-77-07(C)(1)]

17. Additional Subpart V Monitoring and Recordkeeping Requirements

a) When each leak is detected as specified in B.8, B.13, and B.14, the following requirements shall

apply:

(1) A weatherproof and readily visible identification, marked with the equipment identification

number, shall be attached to the leaking equipment.

(2) The identification on a valve may be removed after it has been monitored for 2

successive months as specified in B.13.b) and no leak has been detected during those 2

months.

(3) The identification on equipment, except on a valve, may be removed after it has been

repaired.

[40 CFR 61.246(b) and QAC rule 3745-77-07(C)(1)]

b) When each leak is detected as specified in B.8, B.13, and B.14, the following information shall

be recorded in a log and shall be kept for 2 years in a readily accessible location:(1) the instrument and operator dentification numbers and the e quipment identification

number;

(2) the date the leak was detected and the dates of each attempt to repair the leak;(3) repair methods applied in each attempt to repair the leak;(4) “above 10,000 ppm” if the maximum instrument reading measured by the methods

specified in B.19 after each repair attempt is equal to or greater than 10,000 ppm;

(5) “repair delayed” and the reason for the delay if a leak is not repaired within 15 calendar

days after discovery of the leak;

(6) the signature of the permittee representative (or designate) whose decision it was that

repair could not be effected without a process shutdown;

Page 32 of 39
— 19) — the dateof successful repair of the leak.

[40 CFR 61.246(c) and OAC rule 3745-77-07(C)(1)J

c) The following information pertaining to all equipment to which the standard applies shall be

recorded in a log that is kept in a readily accessible location:(1) a list of identification numbers for equipment (except welded fittings) subject to the

requirements of Subpart V under this permit.

(2) a list of identification numbers for equipment that the permittee elects to designate for no

detectable emissions as indicated by an instrument reading of less than 500 ppm above

background (the designation of this equipment for no detectable emissions shall be

signed by the permittee representative);

(3) a list of equipment identification numbers for pressure relief devices r~..ired to comply

with B.10.a);

(4) the dates of each compliance test required in B.10 and B.8.j) and B.13.e), the

background level measured during each test, and the maximum instrument readingmeasured at the equipment during each test; and

(5) a list of identification numbers for equipment in vacuum service.[40 CFR 61.246(e) and QAC rule 3745-77-07(C)(1)]

d) The following information pertaining to all valves subject to the requirements of B.13.f) and

B.13.g) and to all pumps subject to the requirements of B.8.l shall be recorded in a log that is

kept in a readily accessible location:(1) a list of identification numbers for valves and pumps that are designated as unsafe to

monitor, an explanation for each valve or pump stating why the valve or pump is unsafe

to monitor, and the plan for monitoring each valve or pump; and

(2) a list of identification numbers for valves that are designated as difficult to monitor, an

explanation for each valve stating why the valve is difficult to monitor, and the plannedschedule for monitoring each valve.

[40 CFR 61.246(f) and OAC rule 3745-77-07(C)(1)]

e) If applicable, the following information shall be recorded for valves complying with B.13.h) and

B.13.i):(1) a schedule for monitoring; and(2) the percent of valves found leaking during each monitoring period.

[40 CFR 60.246(g) and QAC rule 3745-77-07(C)(1)]

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[40 CFR 60.246(h) and QAC rule 3745-77-07(C)(1)]

18. Subpart V Reporting Requirements

a) A report shall be submitted to the Ohio EPA, Northwest District by January 31 and July 31 of

each year that includes the following information as set forth in B. 18b) through B.1 8.f):

b) The process unit identification.c) For each month during the semiannual reporting period:

(1) The number of valves for which leaks were detected as described in B.13.a), or under

B.13.h) if applicable.

(2) The number of valves for which leaks were not repaired as required in B.1 3.c).(3) The number of pumps for which leaks were detected as described in B.8.a) and B.8,i).

(4) The number of pumps for which leaks were not repaired as required in B.8.b) and B.8.i).(5) The facts that explain any delay of repairs and, where appropriate, why a process unit

shutdown was technically infeasible.

d) Dates of process unit shutdowns which occurred within the semiannual reporting period.e) Revisions to items reported according to 40 CFR 61 .247(a) if changes have occurred since the

initial report or subsequent revisions to the initial report.

f) The results of all performance tests and monitoring to determine compliance with no detectable

emissions and, if applicable, with B.13.h), B.13.i), and/or B.13.j), conducted within the

semiannual reporting period.

[40 CFR 61.247(b) and QAC rule 3745-77-07(C)(1): B.18.a -f]Note: Compliance with the requirements of 40 CFR 61.10(c) is not required for revisions

documented under B.18.b) through B.18.f).

g) An application for approval of construction or modification under 40 CFR 61.05(a) and 61.07,

will not be required if -- (1) the new source complies with the 40 CFR 61.242 Subpart V standards under this permit;

(2) the new source is not part of the construction of a process unit; and(3) in the next semiannual report required by B.18.a), the information in 40 CFR

61 .247(a)(5) is reported.

[40 CFR 61 .247(e) and OAC rule 3745-77-07(C)(1)j

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b) Monitoring shall comply with Method 21-of Appendix A of 40 CFR Part 60.

c) The detection instrument shall meet the performance criteria of Method 21.

d) The instrument shall be calibrated before use on each day of its use by the procedures specified

in Method 21.

e) Calibration gases shall be:

(1) zero air (less than 10 ppm of hydrocarbon in air); and

(2) a mixture of methane or n-hexane and air at a concentration of approximately, but less

than, 10,000 ppm methane or n_hexane.*

* The permittee may, at its option, elect to use the more stringent ‘action leve~.Iassification for

leak detection of 500 ppm (absolute) for all equipment, regardless of the piece of equipment orapplicable regulation that applies. If this option is used, the permittee is instructed to use a

corresponding calibration gas concentration of approximately 500 ppm methane or n-hexane.

The instrument probe shall be traversed around all potential leak interfaces as close to the

interface as possible as described in Method 21.[40 CFR 61 .245(b) and QAC rule 3745-77-07(C)(1): B.19.a -f]

g) When equipment is tested for compliance with or monitored for no detectable emissions, the

permittee shall comply with the following requirements:(1) The requirements of b) through e) shall apply.(2) The background level shall be determined, as set forth in Method 21

(3) The instrument probe shall be traversed around all potential leak interfaces as close to

the interface as possible as described in Method 21.

(4) The arithmetic difference between the maximum concentration indicated by the

instrument and the background level is compared with 500 ppm for determiningcompliance.

[40 CFR 61 .245(c) and QAC rule 3745-77-07(C)(1)] - Page 35 of 39
of the process fluid that is contained in or contacts equipment, procedures that conform to themethods described in ASTM Method D-2267 (incorporated by the reference as specified in 40CFR 61.18) shall be used.

[40 CFR 61.245(d)(1) and OAC rule 3745-77-07(C)(1)]

i) The permittee may use engineering judgment rather than the procedures in h) to demonstrate

that the percent VHAP content does not exceed 10 percent by weight, provided that the

engineering judgment demonstrates that the VHAP content clearly does not exceed 10 percent,by weight. When the permittee and the Director do not agree on whether a piece of equipmentis not in VHAP service, however, the procedures in h) shall be used to resolve thedisagreement.

If the permittee determines that a piece of equipment is in VHAP service, the determination can

be revised only after following the procedures in h).[40 CFR 61.245(d)(2) and OAC rule 3745-77-07(C)(1)]

j) With regard to h) and i) above, samples used in determining the percent VHAP content shall be

representative of the process fluid or gas that is contained in or contacts the equipment.[40 CFR 61 .245(d)(3) and OAC rule 3745-77-07(C)(1)]

20. Miscellaneous Requirements and Provisions

Upon prior written approval of the US EPA administrator, and upon modification of the Title V permit as

approved by Ohio EPA, the permittee may otherwise comply with certain requirements of Subpart V,under a ‘determination of alternative means of emission limitation’ as provided in 40 CFR 60.242-1 (c).[OAC rule 3745-77-07(C)(1)]

21. The following insignificant emissions units at this facility must comply with all applicable State and

federal regulations, and well as any emission limitations and/or control requirements contained within

the identified permit to install for the emissions unit. The insignificant emissions units listed below are

subject to one or more applicable requirements contained in a permit to install or in the SIP-approved

versions of OAC Chapters 3745-17, 3745-18, 3745-21, and/or4O CFR Part 61, Subparts V and FF.

P018 - Mixer I (PTI 03-5052)

P019 - Mixer 2 (PTI 03-5052)

—T007 - Tank 7 (PTI 03-2817)

(T008 - Tank 8 (PTI 03-10007) LT009 - Tank 9 (PTI 03-10007)

rTOlO-Tank 10 (PTI 03-13006)

~ LTOII-Tankll (PTIO3-13006)

FT026 - Tank I (PTI P0108233) T027-Tank2(PT1P0108233)

T028 - Tank 3 (PTI P0108233)

LT029 -Tank 4 (PTI P0108233)

P801 - Tank Storage System Fugitives

Page 36 of 39
P806 

Systank Processing Fugitives 

(Authority for term: QAC rule 3745-77-07(A)(1 3))

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C. Emissions Unit Terms and Conditions

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